DAQ-2025-000551

State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Lieutenant Governor

Department of Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper

RN103030032
January 21, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Josh Nelson,

Re: Engineer Review:
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

Please review and sign this letter and attached Engineer Review (ER) within 10 business days.
For this document to be considered as the application for a Title V administrative amendment, a
Title V Responsible Official must sign the next page.

Please contact John Jenks at [phone] if you have any questions or concerns about the ER.
If you accept the contents of this ER, please email this signed cover letter to John Jenks at
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 1

[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the
DAQ will consider any comments received and will issue the Approval Order.

If you do not respond to this letter within 10 business days, the project will move forward
without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue
an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 2

OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible
Official, as defined in R307-415-3, must sign the statement below. THIS IS STRICTLY
OPTIONAL.

If you do not want the Engineer Review to be considered as an application to administratively
amend your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will
require submittal of a separate Operating Permit Application to revise the Title V permit in
accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document:
Title V Operating Permit Application Due Dates clarifies the required due dates for Title V
operating permit applications and can be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality

“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate
and complete and request that this Approval Order be considered as an application
to administratively amend the Operating Permit.”

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 3

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N103030032
Owner Name Ash Grove Cement Company
Mailing Address P.O. Box 38069
Leamington, UT, 84638

Source Name Ash Grove Cement Company- Leamington Cement
Plant
Source Location Hwy 132
Leamington, UT 84638

UTM Projection 397000 m Easting, 4380100 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3241 (Cement, Hydraulic)

Source Contact Cody Watkins
Phone Number [phone]
Email [e-mail]

Billing Contact Cody Watkins
Phone Number 385.225.0615
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 30, 2022
Date of Accepted Application November 28, 2024

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
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Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 5

SOURCE DESCRIPTION

General Description
Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried
on site), are correctly proportioned, ground and mixed, and then fed into a rotating kiln. The kiln
alters the materials and recombines them into small stones called cement clinker. The clinker is
cooled and ground with gypsum and additional limestone into a fine powdered cement. The final
product is stored on site for later shipping. The major sources of air emissions are from the
combustion of fuels for the kiln operation, from the kiln, and from the clinker cooling process.
The Leamington cement plant is a major source for emissions of PM2.5, PM10, NOx, CO, HAPs
and GHG. It is a minor source of SO2 emissions.

NSR Classification:
Major PSD Modification

Source Classification
Located in Attainment Area,
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Proposal
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower, various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
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These changes result in increases in actual emissions, but decreases in most potential emissions.
There will be an increase in the potential emissions of VOC and greenhouse gases.

EMISSION IMPACT ANALYSIS
The complete modeling review is located in DAQE-MN103030032-24. [Last updated January 14, 2025]

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
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SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
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Review of BACT for New/Modified Emission Units

1. BACT review regarding the Leamington Plant Upgrade Project
Any major stationary source or major modification subject to PSD review must undergo an
analysis to ensure the use of BACT. The requirement to conduct a BACT analysis is set forth in 40
CFR 52.21. Similarly, Utah requires the installation of BACT for all sources of air pollution under
R307-401-5(2)(d)), BACT is defined in 40 CFR 52.21 (and R307-401-2) as:

". . . best available control technology means an emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for each pollutant subject to regulation under
Act which would be emitted from any proposed major stationary source or major modification
which the Administrator, on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such source or modification
through application of production processes or available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion techniques for control of such
pollutant . . ."

Therefore, a BACT analysis is required for each new or physically modified emission unit for each
pollutant that exceeds an applicable PSD significant emission rate (SER). Since the PM10 and PM2.5
emissions from the proposed project exceed the applicable PSD SER, a BACT analysis is required
to assess the required levels of control for these pollutants. Because the CO2e emissions are subject
to regulation as a result of the proposed project resulting in an increase of 75,000 tons or more per
year CO2e, a BACT analysis is also required for that pollutant. Note that HAPs listed under CAA
Section 112(b)(1) are excluded from NSR (New Source Review) or PSD (i.e., BACT) review.

In a memorandum dated December 1, 1987, the United States Environmental Protection Agency
(EPA) stated its preference for a "top-down" BACT analysis. After determining if any New Source
Performance Standard (NSPS) is applicable, the first step in this approach is to determine, for the
emission unit in question, the most stringent control available for a similar or identical source or
source category. If it can be shown that this level of control is technically, environmentally, or
economically infeasible for the unit in question, then the next most stringent level of control is
determined and similarly evaluated. This process continues until the BACT level under
consideration cannot be eliminated by any substantial or unique technical, environmental, or
economic objections.

Presented below are the five basic steps of a top-down BACT review as identified by the EPA.
Step 1 - Identify All Control Technologies
Step 2 - Eliminate Technically Infeasible Options
Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Step 4 - Evaluate Most Effective Controls and Document Results
Step 5 - Select BACT

Ash Grove has elected to follow this methodology and based the BACT review on each individual
pollutant. The complete BACT analysis follows. [Last updated January 14, 2025]

2. BACT review regarding PM10 and PM2.5 Sources
PM10 and PM2.5 Modified Equipment
The existing kiln precalciner, preheater, and alleviator system are proposed to be modified, and the
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
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kiln's ID fan and clinker cooler fans are proposed to be replaced, which will result in increased
airflow. Additionally, the clinker cooler baghouse will be converted from a plenum pulse to a pulse
jet baghouse. These modifications are projected to result in a net increase of potential PM10 and
PM2.5 emissions.

Kiln Upgrade BACT
The rotary cement kiln is the core of the cement manufacturing process, transforming the blended
raw materials or "rawmix" into clinker through pyro processing. Emissions from the kiln occur
from fuel combustion plus the physical and chemical reactions needed to transform the rawmix
into clinker. This project involves process and energy efficiency improvements and an increase in
kiln production, resulting in an increase of PM10 and PM2.5 emissions. This section specifically
addresses filterable PM10 and PM2.5. The condensable fraction is represented with the other
precursors as applicable to proposed emission increases.

The Leamington Plant's Kiln is subject to NSPS, Subpart F for particulate. Therefore, a BACT
analysis addresses applicability of the proposed changes to the kiln system to NSPS and review of
the RBLC. A summary of the resources reviewed include the following:

NSPS Subpart F - Standards of Performance for Portland Cement Plants establishes emission
standards for cement kiln operations. Specifically, kilns modified after June 16, 2008, are limited to
0.07 lbs PM/ton of clinker produced.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028) and
Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from kiln operations are as follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM emissions are most effectively controlled using a collection system with enclosures routed to
baghouses providing up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Ash Grove
has selected technology with the highest control efficiency, so there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
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Step 5 - Select BACT
Ash Grove proposes that BACT for PM10 and PM2.5 emissions from the kiln consist of a collection
system routed to a baghouse or fabric filter that complies with NSPS Subpart F's emission standard
for a modified source. BACT for the Leamington Plant's kiln are 10% opacity and 0.07 lb of
PM/ton (NSPS Subpart F emission standard) of clinker.
[Last updated January 14, 2025]

3. BACT review regarding PM10 and PM2.5 sources cont.
Clinker Cooler Upgrade BACT
The clinker cooler reduces the temperature of the clinker exiting the kiln. It is necessary to reduce
clinker temperature before it enters the finish mill to maintain product quality and reduce wear and
tear on equipment. The clinker cooler is equipped with a heat exchanger that captures waste heat
and transfers it to the kiln preheater for process and energy efficiency. Emissions from the clinker
cooler are vented to a baghouse. The Leamington Plant's clinker cooler is also subject to NSPS
Subpart F for particulate. Ash Grove's proposed changes to the clinker cooler meet the definition of
a reconstruction under NSPS. Therefore, in order to meet the requirements of NSPS Subpart F, Ash
Grove will be required to meet a limit of 0.02 lb of PM/ton of clinker.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from clinker cooler operations are as
follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM10 and PM2.5 emissions are most effectively controlled using a collection system with enclosures
routed to a baghouse, which can achieve up to 99.9% control efficiency. Other technologies such as
wet scrubbers, cyclones and ESPs are feasible, but provide lower control efficiencies than a
baghouse. Because the most efficient control technology is proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for PM10 and PM2.5 emissions from the clinker cooler is a collection system routed to a
baghouse or fabric filter. In order to meet the requirements of NSPS Subpart F, Ash Grove will
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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meet a reduced emission limit of 0.02 lb of PM/ton of clinker. A 10% opacity limit is also
applicable. [Last updated January 14, 2025]

4. BACT review regarding PM10 and PM2.5 sources cont.
New Finish Mill BACT
The proposed Plant upgrade include adding a second finish mill. The new finish mill will use an
energy efficient vertical roller mill assisted with a grinding aid. A total of five (5) point sources are
planned for the finish mill. In accordance with NSPS Subpart F, emissions from finish mill are
restricted to 10% opacity. Ash Grove has reviewed the following sources to identify available
control technologies.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);12 and

Region 8 General Permit for Concrete Batch Plants.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 emissions from plant material handling operations are as
follows:
Baghouse / Fabric Filter;
Best Management & Operational Practices;
Cyclone;
ESP;
Enclosure;
Water Application (Watering); and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
With the exception of water application, all options are technically feasible. Water application is
eliminated as clinker exiting the kiln along with additives in the finish mill must remain dry to
maintain product quality. Therefore, it is technically infeasible to water material in the finish mill.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Enclosure 50-90%
5. Cyclone 20-70%
6. Best Management & Operational Practices varies

Step 4 - Evaluate Most Effective Controls and Document Results
Baghouses provide the highest emission control efficiency, controlling up to 99.9% of PM
emissions from finish mill equipment. After baghouses, using a wet scrubber or ESP provides
similar PM control. Notably, baghouses, scrubbers, and ESPs require enclosures to aid in capturing
emissions and ducting to the control. Therefore, optimal PM emission control can be achieved
through implementing both baghouses and enclosures where feasible. Plant material sizing and
handling is currently done using a series of buildings and enclosures routed to baghouse controls.
Various silos storing material inputs are also equipped with fabric filters. As the highest ranked
technology is applied, there are no adverse energy, environmental or cost impacts to consider with
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January 21, 2025
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the use of these control technologies. Thus, no further analysis is required under EPA's top-down
BACT approach.

Step 5 - Select BACT
BACT for finish mill PM10 emissions is compliance with NSPS Subpart F, Standards of
Performance for Portland Cement Manufacturing where applicable. Ash Grove will achieve BACT
for PM10 emissions from finish mill equipment through the implementation of enclosures,
baghouses, and best management practices. All baghouses at the finish mill will have a 10%
opacity limitation and a grain loading of 0.005 grains/dscf. [Last updated January 14, 2025]

5. BACT review regarding PM10 and PM2.5 sources cont.
Material Transfer, Sizing, and Storage BACT
The Leamington Plant has sources of fugitive emissions through raw material transfer. Materials
transferred include limestone and other raw materials, coal, clinker, and cement. These materials
are transferred by conveyor belt, screw conveyor, elevator, pneumatic conveyance or chutes via
gravity. At the Leamington Plant the fugitive emissions are enclosed at their transfer points and
routed to baghouses.

The following emission units are included in this category:
Limestone Crushing, Sizing, and Material Transfer;
Raw Material Transfer;
Coal Sizing and Transfer;
Existing Finish Mill;
Clinker Storage and Transfer;
Cement Storage and Truck and Rail Cement Loadout;
New Rail Loading and Loadout; and
New Clinker Reclaim Hopper Baghouse.

Generally, controls for these units have not changed or they are similar to current existing controls.
A full BACT analysis of each unit is included in Ash Grove's NOI and additional submitted
information. However, given that most controls remain unaltered, only the results of Step 5 -
Select BACT will be included here.

Limestone Crushing, Sizing, and Material Transfer
Subject to NSPS Subpart OOO opacity limits for existing sources.
Existing baghouses. No change from bag manufacturer's specifications.

Raw Material Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Coal Storage and Transfer
Existing Equipment. No change from bag manufacturer's specifications
20% Opacity

Clinker Storage and Transfer
Subject to NSPS Subpart F opacity limits:
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10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Existing Finish Mill Grinding, Storage and Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Cement Storage and Truck and Rail Cement Loadout, New Rail Loadout
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

New Rail Loadout, controlled by baghouse
Emissions Limit - 0.005 gr/dscfm

New Clinker Reclaim Hopper, controlled by baghouse
Subject to NSPS Subpart F opacity limits:
10% opacity
Emissions Limit - 0.005 gr/dscfm [Last updated January 14, 2025]

6. BACT review regarding PM10 and PM2.5 sources cont.
PM10 and PM2.5 Fugitive Emissions
The following fugitive emissions sources will increase emissions of PM10 and PM2.5 as a result of
the Leamington Plant's proposed throughput increase. The sources addressed in the following
BACT analyses are primarily in the quarry, but also include emissions from roads and dumping of
raw materials within the plant boundary.

The sources evaluated are listed below:
Roads;
Loading and Unloading;
Stockpiles;
Bulldozing and Grading;
Disturbed Areas; and
Drilling and Blasting.

Ash Grove currently controls emissions from these processes, and generally, controls for these
units have not changed. A full BACT analysis of each unit is included in Ash Grove's NOI and
additional submitted information. However, given that most controls remain unaltered, only the
results of Step 5 - Select BACT will be included here.

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
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January 21, 2025
Page 15

Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

Stockpiles BACT
BACT shall consist of restricting fugitive emissions to the opacity standard of 20% opacity at the
property boundary. BACT for stockpiles will be achieved through applying good management
practices through its fugitive dust plan as appropriate.

Bulldozing and Grading BACT
BACT shall consist of restricting fugitive emissions from bulldozing and grading activities to no
more than 20% opacity, and that emissions are controlled with periodic watering of the disturbed
surface. The frequency of water application will depend on ambient weather conditions and
inherent moisture content of the material being moved.

Disturbed Areas BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. BACT for
disturbed areas will be achieved through best management practices, watering, scarification, and
revegetation.

Drilling and Blasting BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. This is achievable
through best management practices, shrouds, watering, and dust collection. [Last updated January
14, 2025]

7. BACT review regarding kiln system NOx emissions
Kiln System (Kiln, Raw Mill, and Coal Mill) - NOx BACT
Although there are physical changes to the kiln system, these changes are primarily related to
particulate emissions. NOx emissions are generated from the combustion of fuel - and no changes
in NOx emissions are expected from the kiln (hourly capacity to emit). The kiln NOx emissions will
remain the same as a result of upgrades to the SNCR system. The replacement of the various
components of the kiln system and portions of the preheater tower, along with new injection points,
will ensure that increased mixing of ammonia is achieved to enhance the SNCR system's ability to
reduce NOx and minimize ammonia slip. This will allow the Leamington Plant to maintain the NOx
hourly capacity to emit unchanged from current levels Leamington Plant Upgrade Project. At
present Ash Grove has no restriction on the amount of fuel combusted, only a limit on total NOx
generated, and with this project the allowed NOx PTE is decreasing from 1,352 tpy to 1,226 tpy.

Additional ammonia will be used in the existing SNCR system. While the SNCR system has
adequate capacity to accommodate the additional ammonia demand resulting from the system
upgrades, more ammonia ports are proposed to be added with the kiln system's proposed changes
of the equipment. The changes proposed to the kiln system will increase residence time and
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
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temperature which will improve the SNCR system's effectiveness to control NOx emissions and
minimize ammonia slip emissions to the atmosphere. No additional review of NOx BACT for the
kiln system is required under this proposal. [Last updated January 14, 2025]

8. BACT review regarding new finish mill heater emissions
Finish Mill Heater
The proposed finish mill will include a process heater to maintain a minimum temperature during
milling. The proposed heater will run on natural gas and is rated at 10 MMBtu/hr. Startup and
shutdown emissions from the heater are anticipated to be no greater than normal operation as the
process is simply a matter of bringing the heater to operating temperature. Emissions evaluated in
the BACT analysis for the finish mill heater include NOx, SO2, CO, and VOCs, PM10, and PM2.5.
Pollutants with identical control technologies are grouped together in the analysis.

NOx - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for NOx from units of this size range are as follows:
Ultra-Low-NOx Burners (ULNB);
Low NOx Burners;
Selective Catalytic Reduction (SCR);
Selective Noncatalytic Reduction (SNCR);
Good Combustion Practices; and
Use of Natural Gas.

Step 2 - Eliminate Technically Infeasible Options
Low exit temperatures render the use of SCR and SNCR ineffective. Particulate entrainment within
the finish mill could potentially foul (plug) the nozzles of ULNB. Low-NOx burners, the use of
natural gas as fuel and good combustion practices are all considered technically feasible.

Step 3 and Step 4 - Rank Remaining Control Technologies by Control Effectiveness and Evaluate
Most Effective Controls and Document Results
Since the three feasible control technologies are proposed for the finish mill heater, no detailed
economic, energy, and environmental impact evaluations were conducted. No ranking of control
effectiveness is required as all three controls are proposed.

Step 5 - Select BACT
BACT for NOx is the use of natural gas as fuel, good combustion practices and the use of Low NOx
burners.

CO, SO2, and VOC - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for CO, SO2, and VOC from units of this size are as follows:
Good Combustion Practices
Use of Natural Gas

The finish mill heater combusts natural gas. Related natural gas combustion emissions are
anticipated to be minimal.

Step 2 - Eliminate Technically Infeasible Options
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Both control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Both technologies offer intrinsic emission reductions from combustion. Since the technologies do
not compete, both technologies can and will be used simultaneously.

Step 4 - Evaluate Most Effective Controls and Document Results
Because both control technologies identified in Step 1 are proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for CO, SO2, and VOC are good combustion practices and the use of natural gas.

PM10 and PM2.5 BACT for the finish mill has been addressed in the PM10/PM2.5 sources section.
[Last updated January 14, 2025]

9. BACT review regarding SO2, VOC, and Lead Sources
The following BACT analysis is grouped by pollutants that will experience an increase in potential
emissions and the associated technically feasible control technologies. As such, the BACT analysis
is separated into SO2, VOC, and lead respectively with organic HAPs addressed with VOCs.

SO2 - Cement Kiln BACT
NSPS Subpart F - Standards of Performance for Portland Cement Plants, establishes emission
standards for cement kiln operations. Specifically, kilns constructed or reconstructed after June 16,
2008, are limited to 0.4 lbs SO2/ton clinker on a 30-day rolling average respectively. This limit is
an existing emission limit in the Leamington Plant's approval order and Title V. Ash Grove will
continue to achieve this emission limitation while achieving BACT for the kiln operations. Ash
Grove has reviewed the following sources to identify available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019); and

NSPS Subpart F as an affected emissions facility in 40 CFR 60.62(a)(4);

Portland Cement Association's Formation and Techniques for Control of Sulfur Dioxide and Other
Sulfur Compounds in Portland Cement Kiln Systems.

SO2 emissions are a result of oxidation of sulfur compounds in the rawmix and/or the coal used to
fire the kiln. However, the alkaline nature of the cement provides for direct absorption of SO2 into
the product, thereby mitigating the quantity of SO2 emissions in the exhaust stream.

Step 1 - Identify All Control Technologies
Control technologies identified for SO2 emissions from coal-fired kiln operations are as follows:
Baghouse or fabric filter;
Dry reagent injection prior to baghouse;
Wet scrubber;
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Process optimization; and
Good combustion practices.

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below:

1. Process Optimization 99%
2. Wet Scrubber 99%
3. Dry Reagent Injection 60%
4. Good Combustion Practices 30%
5. Baghouse Variable

Step 4 - Evaluate Most Effective Controls and Document Results
SO2 emissions are most effectively controlled by optimizing the process and utilizing the inherent
SO2 scrubbing properties of the kiln system itself. Although wet scrubbers alone can achieve equal
control efficiencies as process optimization, additional capital and operational expenses are
required for water consumption and wastewater discharge. Whereas process optimization achieves
the same control effectiveness and has the added benefit of reduced operational costs. Ash Grove
optimizes the kiln process by routing the exhaust from the kiln to a preheater and raw mill to
interact with the raw mix, thus creating an atmosphere similar to a dry scrubber system. Good
combustion practices also reduce SO2 formation with the added benefit of energy efficiency.

Step 5 - Select BACT
BACT for control of SO2 emissions from kiln operations shall consist of process optimization by
routing kiln exhaust to the preheater and raw mill, good combustion practices, and use of a
baghouse prior to exhausting to the atmosphere. As a modification of the kiln, 40 CFR 60.62(a)(4)
requires an emission limit of 0.4 pounds of sulfur dioxide (SO2) per ton of clinker on a
30-operating day rolling average. [Last updated January 14, 2025]

10. BACT review regarding SO2, VOC, and Lead Sources cont.
VOC - Cement Kiln BACT
VOCs are generated by incomplete combustion in the kiln. 40 CFR 63 Subpart LLL - NESHAP
from the Portland Cement Industry limits total hydrocarbon and total organic HAP emissions to 24
and 12 ppmv at 7% oxygen. Ash Grove will achieve or exceed these emission limitations while
achieving BACT for the kiln operations. Ash Grove has reviewed the following sources to identify
available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028); and

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for VOC emissions from coal fired kiln operations are as follows:
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Process optimization,
Good combustion practices

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below.

1. Process Optimization Variable
2. Good Combustion Practices Variable

Step 4 - Evaluate Most Effective Controls and Document Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove optimizes the
kiln process by capturing waste heat from the clinker cooler and routing to a kiln preheater. Good
combustion practices also reduce VOC formation with the added benefit of energy efficiency.
There are no adverse energy, environmental or cost impacts to consider with the use of this control
technology.

Step 5 - Select BACT
BACT for control of VOC emissions from kiln operations shall consist of process optimization by
routing kiln heat to the preheater and good combustion practices. An emission limit of 24 ppmv
VOC @ 7% O2 is imposed by NESHAP Subpart LLL.

VOC - Grinding Aid BACT
A grinding aid containing VOC is added to the new finish mill to disperse particles within the mill
and expose more surface area to grinding. An increase in grinding aid usage proportionally
increases potential VOC emissions because volatiles from the grinding aid are not combusted in
the kiln.

There is only one identified control option for limiting the VOC emissions from the grinding aid.
Process optimization is technically feasible. VOC emissions are most effectively controlled by
optimizing the process. Ash Grove proposes to install a vertical finish mill with this project. Due to
the new modern mill's efficiency, it is anticipated that a reduced amount of grinding aid will be
required for each ton of clinker ground. Ash Grove estimates total VOC emissions from the
grinding aid at 2.37 tpy.

Lead Emissions
The lead emissions are anticipated to increase as a result of the proposed increase in clinker
throughput with the Leamington Plant upgrade project. Lead emissions result from residual
amounts of lead in raw materials and fuel. Lead emissions will be controlled the same as PM,
therefore a separate top-down BACT analysis has not been conducted as the Leamington Plant has
applied the most effective controls. [Last updated January 14, 2025]

11. BACT review regarding Greenhouse Gases
GHG Background
On October 9, 2009, the mandatory GHG reporting regulation, referred to as 40 CFR 98, was
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published in the Federal Register. Through 40 CFR 98, the U.S. EPA established the GHG
Reporting Rule, which requires the annual reporting of GHG data and other relevant information
from large sources and suppliers in the United States. Monitoring through the GHG Reporting
Program (GHGRP) began in 2010, with the first reports due by March 31, 2011. Per 40 CFR
98.2(a)(1), any facility associated with cement production is subject to the GHGRP and must report
CO2e emissions. The CO2e is the sum of equivalent GHG emissions from CO2, CH4, and N2O,
with their respective global warming potentials (GWP) applied. Ash Grove's facility is subject to
GHG Reporting Rule and monitors CO2 emissions from its kiln with a continuous emissions
monitoring system (CEMs). On June 23, 2014, the U.S. Supreme Court held that required PSD
permits (based on emissions of non-GHG pollutants) may continue to require limitations on GHG
emissions based on the application of BACT as an "anyway source". The Leamington Plant
modification project is a major source for PSD for both PM10 and PM2.5, and GHGs are estimated
to be greater than 75,000 tpy and greater than zero on a mass basis; therefore, GHGs are evaluated
for BACT as an anyway source.

Cement Manufacturing GHG BACT
A BACT analysis has been conducted for CO2e emissions from the kiln system. For this GHG
BACT analysis, various control technologies or combinations of technologies were identified using
the RACT/BACT/LAER Clearinghouse, available literature including guidance published by EPA
and South Coast Air Quality Management District (SCAQMD), current air regulations, other
regulatory organizations, and engineering experience. In March 2011, EPA published GHG
permitting guidance, as well as a white paper on available and emerging technologies for reducing
GHG emissions from the Portland cement industry in October 2010. Additionally, EPA published a
series of videos on GHG permit training in December 2010. The SCAQMD published GHG BACT
guidance in 2021. Additional sources of information were reviewed and documented based on
publications from trade organizations and other governmental committees with GHG or carbon
reduction guidelines and/or recommendations.

EPA has defined in 40 CFR 86.1818-12(a) GHGs as a group of six gases: CO2, nitrous oxide
(N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF6). GHG emissions from the kiln result from calcination and fuel combustion.
Since the primary GHG emitted by a kiln is CO2, the BACT analysis focuses on CO2 emissions
from the kiln. Emissions of CH4 and N2O are minimal from cement kilns. Per EPA guidance, GHG
control technologies for consideration in a BACT analysis for Portland Cement Manufacturing
include:

Source-wide energy efficiency strategies;
Raw material substitution;
Blended cements;
Carbon capture utilization and storage; and
Fuel switching.
Other emerging technologies [Last updated January 14, 2025]

12. BACT review regarding Greenhouse Gases cont.
Step 1: Identify All Control Technologies
The CO2 emissions from a cement kiln are generated by the calcination process (conversion of the
calcium carbonate in limestone to calcium oxide) and by combustion of fuel in the kiln. Potential
control technologies to reduce these CO2 emissions for a cement kiln are addressed in EPA's white
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paper on Available and Emerging Technologies for Reducing GHG Emissions from the Portland
Cement Industry.

These technologies fall into three categories:
Energy Efficiency Improvements for the Clinker Production Process
Fuel Substitution
Carbon Capture and Sequestration

Step 2: Eliminate Technically Infeasible Options
Several potential energy efficiency improvements are technically feasible: Pre-heater/Pre-calciner
Kiln Process, Kiln Seal Management Program, Refractory Selection (Kiln Insulation), and Energy
Recovery from the Clinker Cooler. The use of alternative fuels such as natural gas, whole tires and
biofuel) is also technically feasible. Other control options, such as Use of Fluxes and Mineralizers,
Heat Recovery for Power - Cogeneration, Carbon Sequestration, Oxyfuel combustion, and
Post-combustion Capture have been deemed infeasible.

Step 3: Rank Remaining Control Technologies by Control Effectiveness
All four remaining control techniques are currently implemented at the Leamington Plant. This
permitting project incorporates energy efficiency improvements. Ash Grove has had a fuel
substitution program in place for several years, and this program is continually reviewed and
updated as new sources and types of fuel are identified.

Step 4: Evaluate Most Effective Controls and Document Results
Since all technically feasible energy efficiency improvements and changes to product composition
will be implemented, this section will focus on economic and environmental considerations of fuel
substitution to operate exclusively on natural gas.

Firing natural gas as the primary kiln fuel can reduce CO2 emissions from fuel combustion by as
much as 40%. However, studies have shown that use of natural gas as primary kiln fuel can result
in three times more NOx emissions than NOx emissions from coal firing. Creating more NOx to
reduce GHG emissions is undesirable as it is a precursor to both ozone and PM2.5. Fuel substitution
essentially trades emissions of one regulated pollutant for another. Estimated capital cost to switch
to natural gas fuel exceeds $25M. Implementing natural gas technology would provide incremental
public health and welfare benefit globally by reducing CO2 emissions, while increasing NOx
emissions and negatively impacting public health and welfare locally. Switching fuels to another
fossil fuel has finite potential to mitigate CO2 emissions.

Step 5: Select BACT
In addition to the proposed energy efficiency improvements addressed elsewhere in this BACT
analysis, BACT is a limit of 0.92-ton CO2e/ton clinker. Ash Grove will use a continuous emission
monitoring system (CEMS) for CO2 to demonstrate compliance with this limit. [Last updated
January 14, 2025]

13. BACT review regarding Leamington Plant Upgrade Project conclusion
The control processes and techniques covered in this BACT analysis have been reviewed by the
NSR Section of the UDAQ. Ash Groves proposed controls and associated emission limitations
represent BACT. Any emission limitations not expressed in an associated NSPS or NESHAP will
be included in the terms and conditions of this AO. A listing of all associated NSPS and NESHAP
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programs is also included in the Source Information section of this document under Applicable
Federal Programs. [Last updated December 13, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
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.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date
of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
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proper credit when notifying the Director, send the documentation to the Director, attn.: NSR
Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

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

II.A.3
NEW
Stockpiles
Coal storage
Area: 1 acre
Annual throughput 20,000 tpy

AF and ARM stockpiles
Area: 0.25 acre
Annual throughput 8,000 tpy

II.A.4 Stationary Crusher
Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction
of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000
acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)

II.A.5 Raw Material Transfer
Crushed material is transported to raw material storage by belt B8. The raw material transfers
at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor
transfer point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total
filter area & water sprays. (pre-1983)

II.A.6 Material Handling
Conveyor belt systems, secondary feeders and screens, stacker system

II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit specific requirements

II.A.8 Belt Conveyor Transfer Baghouse
Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area
and 1,800 acfm total air flow, controls emissions from the conveyor belt that transfers the
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stacked material to the raw material silos.

II.A.9 Raw Material Silos
Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The
four silos are equipped with one common Fuller, plenum pulse baghouse (315.BF1) - 1,689 ft2
filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage).

II.A.10 Fifth Component Silo
Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse
(315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw
mill feed. This system includes vibrating feeders, a conveyor system, and surge bin.
Emissions are controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3,
316.BF4, 316.BF5) - each is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1
A/C ratio.

II.A.12 Cross-Belt Analyzer
Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6)

II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom
of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw
materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38).
The following equipment is installed: low-NOx burner, selective non-catalytic reduction
(SNCR) for NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued
mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric
monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct
for mercury adsorption capacity. The carbon injection system is not an emission point as it is
in an enclosed building.

II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

II.A.16 Two Kiln Feed Blending Silos
Raw material is blended in one of two blending silos prior to feeding the kiln. The blending
silos are controlled by one common Fuller, plenum pulse baghouse (411.BF1) - 1,351 ft2 filter
area; 7,160 acfm total air flow.

II.A.17 Blending Silo Elevators (2)
Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped
with a Fuller, pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow
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through stack E34.

II.A.18 Kiln Feed Alleviator
A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the
central material silo between the blending silos and the preheater. Raw feed is removed from
the system near the top of the preheater tower.

II.A.19 Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner.
The coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter
area; 1,700 acfm total air flow.

II.A.20 Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in
the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2):
19,500 acfm rated airflow with 3.75:1 A/C ratio

II.A.21 Clinker Cooler and Baghouse
Reconstructed grate type cooler used for cooling clinker from the kiln prior to transfer to
clinker storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) -
173,869 acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter
monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two
clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse
(419.BF8). The exhaust is routed to the clinker cooler stack.

II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions
generated when loading the east and west clinker silos and the out-of-spec silo are controlled
by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1):
1,800 acfm, that discharges into the clinker tunnel.

II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm, that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2)
Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers.
Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses
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(511.HP1 and new 511.HP2): 1,800 acfm each.

II.A.27 Gypsum Silo
Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2
total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust
during loading.

II.A.28 Clinker Tunnel Exitway
The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse
(511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel all discharge in the clinker tunnel.
Emissions are vented through the tunnel exitway.

II.A.29 Limestone Silo
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust
during loading. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement product. Dust
generated during milling is captured by a BHA, pulse jet baghouse (514.BF2) - 6,080 ft2 filter
area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding
stack).

II.A.31 Finish Mill (Ball Mill) Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized
cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA, pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow
controlling particulates from stack G55 (finish mill stack).

II.A.32
NEW
Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The
stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4)
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1,
525.BF1 thru 3)

II.A.33 Finish Cement Storage Silos
There are six storage and two interstice silos where the finished cement product is stored. A
single common Fuller, plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm
total air flow through stack H7 is located on top of the silos and is used to control emissions
during loading and unloading operations.

II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail
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shipping. This baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out
The cement loadout system located on the South side of the silos (truck load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF2) during unloading from the silos for truck
shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement
conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed
space inside the silos.

II.A.36
NEW
Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

II.A.37 MHO: Materials Handling Operation
Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1
& 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4;
512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.

II.A.38 LBS: Limestone Bypass System
Additional limestone is added to the clinker and gypsum by the limestone bypass system
(LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays
at the screen and material handling drop points.

II.A.39 GEN: Emergency Generators
One diesel-fired emergency generator (new)
Rating: 762 hp
(Kiln, Tier 3, permitted 2022)

Two natural gas-fired emergency generators
Rating: 304 hp
(Main office and control room, permitted in 2023)

One diesel-fired emergency generator
Rating: 560 hp
(Shipping, permitted 2023).

II.A.40 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14 inch knife gate, 8 inch knife gate, 8 inch air
slides, surge bin), and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm)
on the fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

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II.A.41
NEW
Miscellaneous Storage Tanks
One diesel storage tank (<2,000 gallons)
One gasoline storage tank (500 gallons)
Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Requirements on the Cement Plant:
II.B.1.a
NEW
The following limits shall not be exceeded:

A. Clinker production - 1,155,000 tons per rolling 12-month period

B. Used oil consumption - 85,724 gallons per rolling 12-month period

C. Limestone bypass material processed - 216,260 tons per rolling 12-month period.
[R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 25th day of each month using data from the previous 12 months.
Records shall be kept for all periods when the plant is in operation. Consumption and
production shall be calculated through use of the plant's acquisition system. [R307-401-8]

II.B.1.b
NEW
Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations:

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

SO2: 0.4 lbs per ton of clinker (3-hr average)

CO: 3,395 tons per rolling 12-month period, and 6,600 lbs/hr

NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average, and 1,233 tons per rolling
12-month period

Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is
400oF or less.

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Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)

THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)

CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)

PM: 0.02 lbs filterable PM per ton of clinker. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL,
R307-401-8]

II.B.1.c
NEW
A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR
60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust
emissions control plan shall be monitored to demonstrate that appropriate control measures are
being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of
the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall
be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in
the plan and that the source is operating in accordance with the submitted plan. For petitions
to approve alternative control measures, the permittee shall keep a copy of the submitted
petition and any approvals received. [40 CFR 60 Subpart Y]

II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area
source of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2). [40 CFR
63 Subpart LLL]

II.B.1.e
NEW
Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b
and II.B.1.d shall be performed as specified below:

A. Kiln/Raw Mill Stack
Pollutant Test Status Test Frequency
PM * #

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

B. Clinker Cooler (F31)
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Pollutant Test Status Test Frequency
PM + #

C. Testing Status (To be applied above)
* The initial testing has already been performed.

** The SO2 initial performance test was conducted on August 26, 2013.

*** The initial compliance test shall be conducted within the first 30 operating days of
operation in which the affected source operates using a CEMS.

# Test once every year. If performance testing would be required less than 15 operating days
after the Kiln has completed Startup after being down for more than 24 hours, then
performance testing may be deferred up to 15 operating days after completion of the Startup.
The Director may require testing at any time.

## Test at least once every two years. The Director may require testing at any time.

+ Initial testing is required within 180 days of startup of the reconstructed equipment

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must 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 PM CPMS is not out-of-control. The owner/operator must
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 on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

+++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.e.1
NEW
Notification
The Director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The notification requirements for performance tests subject to 40
CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-165]

II.B.1.e.2
NEW
Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational
Safety and Health Administration (OSHA)- or Mine Safety and Health Administration
(MSHA)-approved access shall be provided to the test location. [R307-165]

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II.B.1.e.4
NEW
PM
40 CFR 60, Appendix A, Method 5 or 5I or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three (3) runs with
each run at least 120 minutes in duration and each run collecting a sample of 60 dry standard
cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.3
NEW
Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2. [R307-165]

II.B.1.e.5
NEW
Carbon Monoxide (CO)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.6
NEW
Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.7
NEW
Sulfur Dioxide (SO2)
40 CFR 60, Method 6 or 6C of Appendix A-4 or other EPA-approved method as acceptable to
the Director. [R307-165]

II.B.1.e.8
NEW
Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]

II.B.1.e.9
NEW
Total Hydrocarbons (THC)
Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL]

II.B.1.e.10
NEW
Mercury (Hg)
Continuous Emission or integrated sorbent trap monitoring (See Condition II.B.3.a). [40 CFR
63 Subpart LLL]

II.B.1.e.11
NEW
HCl
Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other
EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]

II.B.1.e.12
NEW
Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.13
NEW
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. [R307-165]

II.B.1.e.14
NEW
Existing Source Operation
For an existing source/emission point, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three years.
[R307-165]

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II.B.1.e.15
NEW
New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the maximum production rate listed in this AO. If the maximum AO
allowable production rate has not been achieved at the time of the test, the following
procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This new
allowable maximum production rate shall remain in effect until successfully tested at a higher
rate.

3) The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate (110%
of the new rate) will then be allowed if the test is successful. This process may be repeated
until the maximum AO production rate is achieved. [R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL.
[40 CFR 63 Subpart LLL]

II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times
of Dust Shuttle System operation to assist in the capture of Mercury emission. [R307-401-8]

II.B.1.h
NEW
Visible emissions from the following emission points shall not exceed the following values:

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

L. All baghouses - 10% opacity
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M. Fugitive dust - 20% opacity

N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y,
R307-401-8]

II.B.1.i 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 must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

If any partially enclosed or unenclosed conveying system transfer point is located in a
building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to
40 CFR 60, according to the following:

(i) The owner/operator must conduct a monthly ten-minute visible emissions test of each
affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The
performance test must be conducted while the affected source is in operation.

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator 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 owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iii) If no visible emissions are observed during the semi-annual test for any affected source,
the owner/operator 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 owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iv) If visible emissions are observed during any Method 22 performance test, of Appendix
A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations,
recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60.
The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour
of any observation of visible emissions.

(v) If visible emissions from a building are monitored, the requirements of paragraphs (i)
through (iv) of this Condition apply to the monitoring of the building, and the owner/operator
must also test visible emissions from each side, roof, and vent of the building for at least ten
minutes. [R307-401]

II.B.1.j
NEW
Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed
0.005 gr/dscf:

520.BF1
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520.BF2
520.BF3
520.BF4
521.BF2
521.BF1
524.BF1
524.BF2
524.BF4
524.BF3
525.BF1
525.BF2
525.BF3
511.HP2
NRL_UPR
NRL_LWR. [R307-401-8]

II.B.1.j.1
NEW
To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration
through at least three (3) annual tests that the PM limits are not being exceeded, the
owner/operator may request approval from the Director to conduct stack testing less
frequently than annually. [R307-401-8]

II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive
dusts as dry conditions warrant or as determined necessary by the Director to maintain opacity
limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated to control fugitive dust. The application of
water or chemical treatment shall be used. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a damp/moist condition unless it is below freezing.
If chemical treatment is to be used, the plan must be approved by the Director. Records of
water and/or chemical treatment shall be kept for all periods when the plant is in operation.
The records shall include the following items: Instances of water and/or chemical application
to unpaved areas shall be recorded and maintained by the owner/operator. The ambient
temperature shall be recorded any time water should be applied but cannot due to freezing
conditions. [R307-401-8]

II.B.2.c
NEW
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

The sprays shall operate whenever dry conditions warrant meeting the required opacity
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limitations or as determined necessary by the Director. Water sprays shall not be required
during periods of freezing temperatures. [R307-401-8]

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation
of fugitive dusts as dry conditions warrant or as determined necessary by the Director.
[R307-401-8]

II.B.2.e
NEW
The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5
PM. [R307-401-8]

II.B.3 Continuous Emission Monitoring Requirements:
II.B.3.a
NEW
The owner/operator shall install, calibrate, maintain and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler.

A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the
missing data substitution procedures used by the UDAQ or the missing data substitution
procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate by the UDAQ.

B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period
including during each startup, shutdown, or malfunction.

C. The monitoring system shall comply with all applicable sections of R307-170, UAC; and
40 CFR 60, Appendix B.

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be
installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the
kiln/raw mill stack.

F. The owner/operator shall record the output of the system: including the quantity of NOx,
CO, O2 THC, Hg, HCl, and CO2 emissions at the kiln stack.

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source 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.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker
cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except
during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments,
the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a
PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the
results of the performance test demonstrating compliance with the filterable PM limit and
using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust
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the SSOL developed in accordance with the results of the most recent PM performance test
demonstrating compliance with the PM emission limit. The owner/operator shall use the PM
CPMS to demonstrate continuous compliance with the SSOL in accordance with the
requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

II.B.4 Fuel Limitations:
II.B.4.a
NEW
The owner/operator shall use only the following fuels in the kiln and pre-calciner:

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.

If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b
NEW
Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the
Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the
results of suitable tests giving data similar to a Proximate and Ultimate analysis of the
proposed coal additive. [R307-401-8]

II.B.4.b.1 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. [R307-401-8]

II.B.4.b.2 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 owner/operator 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 in Condition
II.B.4.b. [R307-401-8]

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II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel burning or process
installation not covered by New Source Performance Standards for sulfur emissions or
covered elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross
Btu heat input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input
for any oil except used oil. The sulfur content shall comply with all applicable sections of
UAC R307-203. [R307-203, R307-401-8]

II.B.4.c.1
NEW
Certification of fuels shall be either by the owner/operator's own testing or test reports from
the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be
available onsite. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials, UAC R307-203-1 (4)

A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be
used.

B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be
used.

C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85 are to be used. [R307-203]

II.B.4.d
NEW
The concentration/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight
3) Cadmium 2 ppm by weight
4) Chromium. 10 ppm by weight
5) Lead 100 ppm by weight
6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be
tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the burn tank and burned. [R307-401-8]

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II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned
in the rotary kiln:

A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than
five minutes in any 60-minute period

B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes
in any 60-minute period. [R307-401-8]

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the
Director. The calibration procedure and frequency shall be according to manufacturer's
specifications. Use of factory-calibrated thermocouples for temperature measurement is
approved. However, any other method of temperature measurement must be approved by the
Director prior to use. The monitoring equipment for both temperature and oxygen content
shall be located such that an inspector can at any time safely read the output. [R307-401-8]

II.B.5
NEW
Emergency Engine Requirements
II.B.5.a
NEW
The owner/operator shall only operate the emergency engines for testing and maintenance
purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency
operation. [R307-401-8]

II.B.5.b
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each emergency engine. [R307-401-8]

II.B.5.b.1
NEW
The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.5.b.2
NEW
To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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Page 39

PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN103030035-24 dated November 27, 2024
Is Derived From Source Submitted NOI dated November 30, 2022
Incorporates Additional Information Received dated April 26, 2023
Incorporates Additional Information Received dated September 26, 2023
Incorporates Additional Information Received dated July 23, 2024
Incorporates Additional Information Received dated October 25, 2024
Incorporates Additional Information Received dated November 25, 2024

REVIEWER COMMENTS

1. Comment regarding applicability of federal requirements:
New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable
by the best demonstrated technology as specified in the applicable provisions. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.

40 CFR 60, Subpart A (General Provisions)
All affected facilities subject to a source-specific NSPS are subject to the general provisions of
NSPS, Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires
initial notification, performance testing, recordkeeping, and monitoring, provides reference methods,
and mandates general control device requirements for all other subparts.

40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of
performance for affected facilities in Portland Cement Plants which have been constructed or
modified after August 17, 1971.

40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart
F: Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and
unloading systems. The Leamington coal mill is an in-line coal mill and considered an integral part
of the Leamington kiln. In-line coal mills are not subject to NSPS Subpart Y. Therefore, the coal mill
is addressed under NSPS Subpart F as part of the kiln system. The coal silos and conveying system
are subject to NSPS Subpart Y.

Ash Grove's proposed changes to the kiln system must be evaluated as to whether they trigger new
NSPS Subpart F obligations based on whether the proposed project is either a modification or a
reconstruction, as those terms are defined in NSPS Subpart A.

Ash Grove's proposed changes to the kiln system do not meet the definition of a reconstruction, nor
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Page 40

do they meet the definition of a modification for NOx. However, the changes meet the definition of a
modification for PM and SO2. Therefore, Ash Grove will comply with all relevant emission
standards; testing requirements; monitoring, recordkeeping, and reporting obligations that apply to
the Leamington kiln system as an existing source under NSPS Subpart F. Under NSPS Subpart A
and F, the clinker cooler is considered a reconstructed unit. Thus new limits will apply to this unit.
[Last updated January 14, 2025]

2. Comment regarding applicability of federal requirements cont.:
NSPS Subpart Y - Standards of Performance for Coal Preparation and Processing Plants
This subpart provides standards of performance for affected facilities in coal preparation and
processing plants that process more than 200 tons of coal per day.

The Leamington plant's coal silo and coal conveying system are existing affected facilities under
NSPS Subpart Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses
controlling affected facilities subject to match the limit in NSPS Subpart Y from 0.016 gr/dscf to
0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade Project. Since there are no proposed
modifications or reconstruction to the coal silo and coal conveying system, nothing about the
proposed upgrade project affects the existing applicability of NSPS Subpart Y.

NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
This subpart provides standards of performance for affected facilities located at fixed or portable
nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August
31, 1983, with additional requirements applicable to sources constructed on or after April 22, 2008.

As the crushing and screening system is controlled by baghouses and an increase in PM10 actual
emissions on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS.
Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the
Leamington Plant Upgrade Project.

Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1),
60.676(f), and 60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO
monitoring and recordkeeping requirements.

[Last updated January 14, 2025]

3. Comment regarding applicability of federal requirements cont.:
National Emission Standards for Hazardous Pollutants (NESHAPs)
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or
greater than 10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as
specified by each subpart. NESHAP apply to sources in specifically regulated industrial source
classifications (CAA Section 112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities
not regulated as a specific industrial source type. The Ash Grove Leamington Plant is a major source
of HAPs and thus is subject to certain NESHAP standards.

Subpart A - General Provisions
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 41

All affected sources are subject to the general provisions of Subpart A unless otherwise specified by
the source-specific NESHAP. Subpart A generally requires initial notification and performance
testing, recordkeeping, monitoring, provides reference methods, and mandates general control device
requirements for all other subparts as applicable.

Subpart LLL - Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry
This subpart establishes process/source specific emission limits for PM, VOC (expressed as total
hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and
gaseous HAP compounds by limiting PM and THC emissions because portions of such emissions
are USEPA-listed HAPs. Subpart LLL requires compliance with applicable emissions limits on and
after the initial startup of cement production. To further reduce emissions, Subpart LLL also
establishes operational requirements for the use of cement kiln dust (CKD), fly ash, fuel and control
equipment. Subpart LLL also specifies process/source specific emissions testing, monitoring,
recordkeeping, reporting, and compliance demonstration requirements. The compliance requirements
for the site are detailed in Approval Order Condition II.B.1.b. Ash Grove will continue to comply
with the requirements of Subpart LLL to demonstrate compliance. This cement kiln will remain an
existing source with respect to the kiln emission standards in Subpart LLL as this project does not
trigger the definition of a new source in Subpart LLL. New source standards apply only to affected
sources that were constructed or reconstructed after May 6, 2009.
[Last updated December 20, 2024]

4. Comment regarding PSD applicability analysis:
Ash Grove is proposing to increase the throughput of limestone from the quarry to supply the New
Finish Mill to increase the amount of low-carbon cement from the Leamington Plant. Additionally,
along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
modified, and the clinker cooler will be reconstructed. These changes are anticipated to result in an
increase in clinker production. Emission calculations for this project have been completed assuming
an increase in clinker production capacity while utilizing current fuel types. This will result in an
increase in the throughput of fuel.

The Leamington Plant is considered an existing major source under PSD based on potential
emissions of PM10, PM2.5, NOx, CO, SO2, and CO2e. If a major source undergoes a physical or
operational change, the facility must determine whether the project will be considered a major
modification. Per 40 CFR 52.21(b)(2)(i), in order to be a major modification, the project must result
in a significant emissions increase, and a significant net emissions increase.

As defined at 40 CFR 52.21(b)(40): Significant emissions increase means, for a regulated NSR
pollutant, an increase in emissions that is significant for that pollutant. Significant is further defined
to mean, in reference to a net emissions increase or the potential of a source to emit any of the
following pollutants, a rate of emissions that would equal or exceed the values outlined in 40 CFR
52.21(b)(23). If the increase in emissions from the project are not significant, a major modification
has not occurred.

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 42

increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

For all pollutants, the project emissions increase was calculated as the difference between the
projected actual emissions (PAE) after the proposed project and the actual emissions prior to the
project (baseline actual emissions or BAE).

Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
". . . projected actual emissions means the maximum annual rate, in tons per year, at which an
existing emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years
(12-month period) following the date the unit resumes regular operation after the project, or in any
one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit of that regulated NSR pollutant and full utilization of the unit would
result in a significant emissions increase or a significant net emissions increase at the major
stationary source." [Last updated January 14, 2025]

5. Comment regarding PSD applicability analysis cont.:
Ash Grove estimates that the projected actual production capacity following the project will be
1,155,000 tons of clinker per year and 1,341,266 tons of limestone per year. These capacities were
used to calculate projected actual emissions from the project using representative emission factors.
Additionally, to estimate emissions from material transfer baghouses, the actual flow rates and actual
projected hours were used as a basis for projected actual emissions.

Project Emission Calculations

Project emission increases from the kiln and coal mill systems are calculated for all criteria
pollutants based on emission factors that are derived from stack testing, CEMS data, or emission
factors (i.e., VOCs and Lead), and the associated projected incremental clinker increase.

NOx emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain
hourly capacity to emit and annual potential to emit at current levels. The kiln's NOx emissions rate
will not change as a result of the physical modifications proposed by the project.

Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission
factor and multiplied by the incremental increase in clinker production. The emission factor was
selected based on the average of the 24-month consecutive month emissions for 2020 and 2021. The
CO emissions will increase.

The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing
conducted at the plant. The SO2 emissions will increase.

VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production. VOC emissions will increase.

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 43

can be found in the original NOI and subsequent addendums submitted to UDAQ.

As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from
the proposed project, each increase of emissions from both existing and new sources shall be
summed together and compared to the PSD permitting thresholds. The increase of emissions is the
"positive" difference between the projected actual emissions and baseline actual emissions (projected
minus baseline).

New Emissions Sources

The actual to projected actuals calculation is not available to new emission units. For new emission
units, the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected
emissions are based on the new sources' potentials to emit. (40 CFR § 52.21(a)(2)(iv)(f)).

The new equipment proposed includes the New Finish Mill, a new rail and truck loading/loadout,
one (1) new clinker reclaim loading hopper with a dust collector and one (1) existing clinker reclaim
hopper with a dust collector, a new Clinker Cooler to replace the existing one, and a new kiln feed
alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions:

The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;

The finish mill heater was calculated based on its maximum firing capacity and flow rates; and

The fugitive emissions were calculated based on the projected annual throughput of the New Finish
Mill, the rail loadout, and clinker production. [Last updated January 14, 2025]

6. Comment regarding PSD applicability analysis cont.:
Existing Emission Sources

For the existing sources, the projected actual emissions are the maximum annual rates in tons per
year projected to occur during the next five (5) to ten (10) years if the existing sources' design
capacities increase. Ash Grove Leamington projected the actual emissions for the next five (5) years
based on the new kiln system producing an annual average of 3,250 tons of clinker per day.

Baseline actual emissions (BAE) are defined at 40 CFR 52.21(b)(48)(ii) as:

". . . baseline actual emissions means the average rate, in tons per year, at which the emissions unit
actually emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the 10-year period immediately preceding either the date the owner or operator
begins actual construction of the project, or the date a complete permit application is received by the
Administrator."

Ash Grove has selected to use the years 2020 and 2021 for each pollutant as the representative
baseline years.

In its NOI, Ash Grove calculated the emission increase from the project as being divided into two
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 44

phases. Phased construction projects are discussed in two sections of the federal PSD regulations -
40 CFR 52.21(j)(4) and 40 CFr 52.21(r)(2). UDAQ is not processing this project as a phased
construction project, nor did Ash Grove request such a determination. Therefore, Ash Grove
provided a summary table outlining the final change in emissions from this project:

Projected Actual Increase Compared to PSD threshold (tons per year)
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2e
BAE 76.64 39.64 1,187 6.87 3,315 55.47 641,385
PAE 203.15 113.47 1,226 45.87 3,414 72.07 1,067,984

Change in Emissions 126.51 73.83 39.00 39.00 99.00 16.59 426,598

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes

If the emissions increase is greater than the PSD significance threshold for a particular pollutant, Ash
Grove has the option of conducting a PSD review or continuing through the rest of the steps to
determine if it can "net" out of a PSD review. If the project increase is less than the PSD significant
threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant.

The change in emissions from the project exceeds the significant emission threshold for three
pollutants: PM10, PM2.5 and CO2e. Ash Grove elected to attempt to net out of a PSD major
modification for the remainder of the criteria pollutants.

Netting

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant
Upgrade Project and ends on the date the upgrade begins operation. Only PM10, PM2.5, CO2e are in
excess of SERs and therefore considered in the netting analysis.

Ash Grove estimated that the commencement of construction will be in December 2024. Therefore,
the contemporaneous period for this project is December 2019 through a projected date the project
upgrade begins operation. [Last updated January 21, 2025]

7. Comment regarding PSD applicability analysis cont.:
Contemporaneous Decreases

Ash Grove replaced an existing kiln emergency drive engine with a USEPA Tier 4 diesel engine in
2022. Concurrently, Ash Grove requested an increase in the capacity of 1L Cement. Additionally,
Ash Grove submitted a minor modification NOI air permit application on June 12, 2023, which
proposes replacing the shipping generator during the contemporaneous period. The kiln emergency
drive engine and shipping generator are both higher EPA tier ratings therefore result in decreases for
PM10 and PM2.5. These changes were approved in AO DAQE-AN103030033-24 issued March 21,
2024.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 45

Contemporaneous Increases

As stated above, the existing kiln emergency drive engine and shipping generator were permitted and
replaced in 2024. This resulted in an increase in emissions of CO2e.

The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout
in an effort to improve truck traffic at the loadout. The modification to add these dust collectors to
the loadout was included in DAQE-AN103030029-19. The baghouses are three (3) levels up in the
silos' enclosed space (approximately 40 feet). Both dust collectors vent directly into the interior of
the silo structure and are not vented into the atmosphere. Ash Grove requests to remove these
baghouses from its existing permitted emissions inventory. Therefore, these emissions have been
documented in the netting analysis as zero emissions.

Also included in DAQE-AN103030033-24 were two new natural gas-fired emergency generators
and increases in stockpiles, material handling and road emissions.

Could Have Been Accommodated Emissions

In calculating project emissions increase, USEPA allows the exclusion of existing
production/emissions rates that could have been accommodated during the baseline period. These
"could have been accommodated" emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as
follows:

". . . Shall exclude, in calculating any increase in emissions that results from the particular project,
that portion of the unit's emissions following the project that an existing unit could have
accommodated during the consecutive 24-month period used to establish the baseline actual
emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project,
including any increased utilization due to product demand growth;"

Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the
exclusion of existing production and emissions rates that could have been accommodated during the
baseline period, it has elected not to use this exclusion at this time. Therefore, calculation of the
"could have been" accommodated emissions have not been included in this application's
applicability analysis.

The increase from the project is added to the contemporaneous decreases and contemporaneous
increases. The resulting calculation is then compared to the PSD significance threshold to determine
if a significant net emissions increase has occurred. [Last updated January 14, 2025]

8. Comment regarding PSD applicability analysis cont.:
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2 e
Contemporaneous Inc. 1.61 0.45 0.41 0 0.27 0.07 51.74

Contemporaneous Dec. -1.54 -3.97 -0.48 -0.02 -0.27 -0.09 0

Change in Emissions 125.02 69.21 38.93 38.98 99.00 16.58 426,650

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes
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January 21, 2025
Page 46

The results of the netting analysis conclude that both a significant emissions increase and a
significant net emissions increase in both particulates (PM10 and PM2.5) and CO2e will occur from
this project. Thus, the project must be reviewed as a PSD major modification. [Last updated January
14, 2025]

9. Comment regarding emission calculations:
This engineering review includes updated potential emission totals for both criteria and HAP
emissions. The potential-to-emit (PTE) values were calculated using updated values for clinker
produced and raw material inputs. BACT emission factors and limitations were used where
appropriate. Certain emission totals (NOx, SO2 and CO) were set based on avoiding a significant
increase in emissions. Specifically, the projected actual increase was set at just under the baseline
actual emissions + the significance level. As these emissions are monitored by CEM, UDAQ agrees
with this approach. Please see the netting analysis for further details on calculation of projected
actual increase. The NOx hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project.

CO2e emissions were calculated using the GHG emission factor calculated from 40 CFR Part 98
Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in Subpart A Table
A-1.

To calculate the PTE tons per year, the maximum hours (i.e., 8760) per year and the source's
emissions rates were multiplied with the throughputs. The potential throughputs have been updated
at UDAQ's request so that PAE is equal to PTE and represents the equipment's maximum design
potential.

Additional emission calculations based on source testing and monitoring, and EPA's compilation of
air emission factors AP-42. [Last updated January 14, 2025]

10. Comment regarding requirements for PSD review:
In addition to the permitting requirements of R307-401-5 through R307-401-8, there are additional
requirements under PSD that must be addressed:

1. Calculation of ambient air increments (40 CFR 52.12(c)), ambient air ceilings ((40 CFR 52.12(d)),
source impact analysis (40 CFR 52.12(k)), air quality models (40 CFR 52.12(l)) - these items are
addressed in the modeling memo DAQE-MN103030032-24.

2. Stack heights (40 CFR 52.12(h)) - Ash Grove's stack heights have been reviewed with respect to
good engineering practice and operate in a vertical unrestricted manner.

3. Control technology review (40 CFR 52.12(j)) - this is addressed in the BACT analysis section of
this review document.

4. Air quality analysis: preapplication analysis (40 CFR 52.12(m)) - this is covered in the PSD
applicability and netting analysis sections of this review document, ambient monitoring and
background data collection is also included in the modeling memo DAQE-MN103030032-24.

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 47

grain loading limit included in II.B.1.j.1 represents the required post-construction monitoring.
6. Source information (40 CFR 52.12(n)) - this is addressed under the requirements of R307-401-5
and was submitted by Ash Grove as part of the NOI package.

7. Additional impact analysis (40 CFR 52.12(o)) - these requirements cover soils, vegetation, growth
and visibility concerns. They are discussed in the modeling memo DAQE-MN103030032-24.

8. Federal land manager review (40 CFR 52.12(p)) - UDAQ provided initial notification to all
federal land managers upon receipt of the original NOI package. The draft permit and engineering
review will also be provided to the federal land managers 60-days prior to initiation of public
comment for their further review.

9. Public participation (40 CFR 52.12(q)) - this project will have a 30-day public comment period.

10. Source obligation (40 CFR 52.12(r)) - this requirement discusses source compliance with other
parts of the CAA, which is addressed within UDAQ's permitting rules in R307.
[Last updated January 14, 2025]

11. Comment regarding changes in equipment list:
The equipment list is being updated for clarity as well as adding new pieces of equipment. The
following changes are taking place:

The naming scheme is being updated to remove the numerical code from the unit designation. This
code generally referred to the associated control device and not to the emitting unit itself. This can
cause confusion especially when the same code was applied to multiple pieces of equipment.
Instead, the control devices (typically baghouse dust collectors) will be identified in the description
along with the appropriate numerical code.

Specific changes are as follows:

1. The kiln description has been updated

2. Clinker Cooler description has been updated to include a larger pulse jet baghouse.

3. The clinker storage silos, east and west clinker belts, clinker belt transfer and clinker tunnel have
been consolidated to avoid confusion

4. The north and south cement loadout exhausts now vent internally into the cement storage silos

5. The dust shuttle system has been consolidated into one line item, most identifiers removed from
subsystem descriptions as only two baghouses serve as exhaust points.

6. A new finish mill with heater has been added. Included in the description are the thirteen total
baghouses for dust control (1 main stack, 2 transfer points, 10 nuisance dust filters)

7. A new clinker reclaim hopper has been added. Both reclaim hoppers are controlled by baghouses
with updated identifiers

8. A new rail and truck loading/unloading system with two baghouses has been added.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 48

[Last updated December 20, 2024]

12. Comment regarding changes in conditions:
As a result of this project, several conditions will be added or changed. This includes one new
general condition (I.8). Changes to the equipment list (section II.A) will be addressed in a separate
reviewer comment:

I.8 - Adding this general condition to cover the requirements of R307-401-18 Eighteen Month
Review. The status of construction/installation of the new equipment shall be reviewed after
18-months.

II.B.1.a - Clinker production increases to 1,155,000 tpy
Use of limestone bypass material increases to 215,260 tpy

II.B.1.b - The NOx limit on the kiln decreases to 1,223 tpy, CO emissions from the kiln decrease to
3,395 tpy,
Adding a new CO2e limit of 0.92 tons CO2e/ton of clinker produced
PM limit on the clinker cooler decreased to 0.02 lb PM (filterable)/ton of clinker
Rule reference updated to include 40 CFR 60 Subpart F, and R307-401-8

II.B.1.e - Initial testing on the clinker cooler is now required within 180 days of startup of the unit.
Monitoring of CO2 from the kiln will be by CEM.
Formatting changes on paragraph designated ++, improve clarity, include reference to CO2
monitoring, define CPMS

II.B.1.e.4 - Update to address general PM monitoring and reference R307-401-8

II.B.1.e.14 - New condition to address new or reconstructed emission units monitoring requirements,
applicable to the clinker cooler and new finish mill.

II.B.1.h - Adding references to Subpart OOO units (limestone processing) with updated opacity
limits.
Adding 20% opacity limit on coal transfer and storage
Adding property boundary opacity limit of 20%
Updating rule reference to include Subpart OOO

II.B.1.j - New condition to address outlet grain loading limits on new baghouses, One identical limit,
15 total new baghouses.

II.B.1.j.1 - Monitoring on new baghouses as per II.B.1.e.4, added an allowance to test less frequently
than annually with three successful tests.

II.B.3.a - Updating formatting to add clarity and include reference to CO2 CEM

II.B.5 - New conditions on emergency engines, diesel fuel sulfur limits, hour of operation
restrictions, non resettable hour meter

[Last updated December 20, 2024]
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 49

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 50

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 51

TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 52

DAQE-IN103030032-25

January 22, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Mr. Nelson:

Re: Intent to Approve: Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — ) A A v A ? A D @ A w D D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — ) A A v A ? A D @ A w D D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ash Grove Cement Company Ash Grove Cement Company - Leamington Cement Plant

Mailing Address Physical Address
P.O. Box 38069 Highway 132
Leamington, UT 84638 Leamington, UT 84638

Source Contact UTM Coordinates
Name: Cody Watkins 397000 m Easting
Phone: [phone] 4380100 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3241 (Cement, Hydraulic)

SOURCE INFORMATION
General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried on site),
are correctly proportioned, ground, and mixed and then fed into a rotating kiln. The kiln alters the
materials and recombines them into small stones called cement clinker. The clinker is cooled and ground
with gypsum and additional limestone into a fine powdered cement. The final product is stored on site for
later shipping. The major sources of air emissions are from the combustion of fuels for the kiln operation,
from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source of
emissions of PM2.5, PM10, NOx, CO, HAPs, and GHG. It is a minor source of SO2 emissions.
NSR Classification
Major PSD Modification

Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
DAQE-IN103030032-25
Page 4

Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

These changes result in increases in actual emissions but decreases in most potential emissions. There will
be an increase in the potential emissions of VOCs and greenhouse gases.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
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Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
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I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, 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. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO 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. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
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II.A.4 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)
II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area, and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, stacker systems. II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit-specific requirements.
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total air flow controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter
area; 9,865 acfm total air flow, controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are
controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each
is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6). II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The
following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for
NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.
II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low-pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

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II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow through stack
E34.
II.A.18 Kiln Feed Alleviator A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the central material silo between the blending silos and the preheater. Raw feed is removed from the system near the top of the preheater tower.
II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The
coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter area;
1,700 acfm total air flow.
II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker
storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1): 1,800 acfm that discharges into the clinker tunnel.
II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
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II.A.27 Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during loading.
II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel, all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during loading. 512.BF3 (1,000 acfm) is located on top of the silo. II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement products. Dust generated
during milling is captured by a BHA pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).

II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates from stack G55 (finish mill stack).
II.A.32 Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4).
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1 thru 3).

II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total air flow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations.
II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This
baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

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II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.
II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023)
II.A.40 Dust Shuttle System A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides, surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the
fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

II.A.41 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons) Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
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II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)
THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)
CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)
PM: 0.02 lbs filterable PM per ton of clinker.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR 60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to approve alternative control measures, the permittee shall keep a copy of the submitted petition and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source
of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2).
[40 CFR 63 Subpart LLL]

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II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must 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 PM CPMS is not out of control. The owner/operator must 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 on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
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II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

II.B.1.e.3 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-165]
II.B.1.e.4 PM 40 CFR 60, Appendix A, Method 5, or 5I, or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three runs, with each
run at least 120 minutes in duration and each run collecting a sample of 60 dry standard cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 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. [R307-165]
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II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
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II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
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II.B.1.i 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 must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator 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 owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator 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 owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
DAQE-IN103030032-25
Page 17

II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: Instances of water and/or chemical application to unpaved areas shall be recorded and maintained by the owner/operator. The ambient temperature shall be recorded any time water should be applied but cannot due to freezing conditions. [R307-401-8]
II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

The sprays shall operate whenever dry conditions warrant meeting the required opacity
limitations or as determined necessary by the Director. Water sprays shall not be required during
periods of freezing temperatures.

[R307-401-8]

DAQE-IN103030032-25
Page 18

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

C. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the kiln/raw mill stack

F. The owner/operator shall record the output of the system: including the quantity of NOx, CO, O2, THC, Hg, HCl, and CO2 emissions at the kiln stack

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an
affected source 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.

[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]
II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments, the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the results of the performance test demonstrating compliance with the filterable PM limit and using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust the SSOL developed in accordance with the results of the most recent PM performance test demonstrating compliance with the PM emission limit. The owner/operator shall use the PM CPMS to demonstrate continuous compliance with the SSOL in accordance with the requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

DAQE-IN103030032-25
Page 19

II.B.4 Fuel Limitations: II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke F. Fuel Oil
G. Used Oil Fuel

H. Synthetic Fuel
I. Wood
J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 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. [R307-401-8]
II.B.4.b.2 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 owner/operator 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 in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

DAQE-IN103030032-25
Page 20

II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight
A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation
C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit-no less than 1500oF for more than five minutes in any 60-minute period B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
DAQE-IN103030032-25
Page 21

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the Director. The calibration procedure and frequency shall be according to manufacturer's specifications. Use of factory-calibrated thermocouples for temperature measurement is approved. However, any other method of temperature measurement must be approved by the Director prior to use. The monitoring equipment for both temperature and oxygen content shall be located such that an inspector can at any time safely read the output. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall only operate the emergency engines for testing and maintenance purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency operation. [R307-401-8]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.5.b.2 To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From Source Submitted NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-IN103030032-25
Page 22

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-GN103030032F-25

January 22, 2025

Via Certified Mail 70190700000208349796

Erik Vernon
Bureau of Land Management
440 West 200 South Suite 500
Salt Lake City, Utah 84101
[e-mail]

Dear Mr. Vernon:

RE: Notice of Publication for Ash Grove Cement Company - Leamington Cement Plant – CDS A;
MACT (Part 63), Compliance Assurance Monitoring (CAM), Title V (Part 70) Major Source,
Major Criteria Source, Major HAP Source, Attainment Area, NSPS (Part 60),
Project Number: N103030032

On January 22, 2025, the Director has completed his review of a Prevention of Significant Deterioration
project submitted by Ash Grove Cement Company. Attached to this letter are the draft Approval Order
document (Intent to Approve) and the full engineering review. Following a 60-day review by the Federal
Land Managers, this project will be submitted for a 30-day public comment period. Written comments
received by the Division at this same address during these comment periods will be considered in making
the final decision on the approval/disapproval of the proposed Approval Order. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director at the Division in writing, a hearing
will be held in accordance with R307-401-7, UAC.

If you have any questions, please contact John Jenks, who may be reached at [phone].

Sincerely,

Jon L. Black, Manager
New Source Review Division

Enclosures: Engineering Review
Modeling Memo
Intent to Approve

JLB:JJ:jg
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

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State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
RN103030032
January 21, 2025
Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]
Dear Josh Nelson,
Re: Engineer Review:
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032
Please review and sign this letter and attached Engineer Review (ER) within 10 business days.
For this document to be considered as the application for a Title V administrative amendment, a
Title V Responsible Official must sign the next page.
Please contact John Jenks at [phone] if you have any questions or concerns about the ER.
If you accept the contents of this ER, please email this signed cover letter to John Jenks at
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 1

[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the
DAQ will consider any comments received and will issue the Approval Order.

If you do not respond to this letter within 10 business days, the project will move forward
without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue
an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 2

OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible
Official, as defined in R307-415-3, must sign the statement below. THIS IS STRICTLY
OPTIONAL.

If you do not want the Engineer Review to be considered as an application to administratively
amend your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will
require submittal of a separate Operating Permit Application to revise the Title V permit in
accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document:
Title V Operating Permit Application Due Dates clarifies the required due dates for Title V
operating permit applications and can be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality

“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate
and complete and request that this Approval Order be considered as an application
to administratively amend the Operating Permit.”

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 3

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N103030032
Owner Name Ash Grove Cement Company
Mailing Address P.O. Box 38069
Leamington, UT, 84638

Source Name Ash Grove Cement Company- Leamington Cement
Plant
Source Location Hwy 132
Leamington, UT 84638

UTM Projection 397000 m Easting, 4380100 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3241 (Cement, Hydraulic)

Source Contact Cody Watkins
Phone Number [phone]
Email [e-mail]

Billing Contact Cody Watkins
Phone Number 385.225.0615
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 30, 2022
Date of Accepted Application November 28, 2024

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 4

SOURCE DESCRIPTION

General Description
Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried
on site), are correctly proportioned, ground and mixed, and then fed into a rotating kiln. The kiln
alters the materials and recombines them into small stones called cement clinker. The clinker is
cooled and ground with gypsum and additional limestone into a fine powdered cement. The final
product is stored on site for later shipping. The major sources of air emissions are from the
combustion of fuels for the kiln operation, from the kiln, and from the clinker cooling process.
The Leamington cement plant is a major source for emissions of PM2.5, PM10, NOx, CO, HAPs
and GHG. It is a minor source of SO2 emissions.

NSR Classification:
Major PSD Modification

Source Classification
Located in Attainment Area,
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Proposal
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower, various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 6

These changes result in increases in actual emissions, but decreases in most potential emissions.
There will be an increase in the potential emissions of VOC and greenhouse gases.

EMISSION IMPACT ANALYSIS
The complete modeling review is located in DAQE-MN103030032-24. [Last updated January 14, 2025]

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 7

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 8

Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 9

Review of BACT for New/Modified Emission Units

1. BACT review regarding the Leamington Plant Upgrade Project
Any major stationary source or major modification subject to PSD review must undergo an
analysis to ensure the use of BACT. The requirement to conduct a BACT analysis is set forth in 40
CFR 52.21. Similarly, Utah requires the installation of BACT for all sources of air pollution under
R307-401-5(2)(d)), BACT is defined in 40 CFR 52.21 (and R307-401-2) as:

". . . best available control technology means an emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for each pollutant subject to regulation under
Act which would be emitted from any proposed major stationary source or major modification
which the Administrator, on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such source or modification
through application of production processes or available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion techniques for control of such
pollutant . . ."

Therefore, a BACT analysis is required for each new or physically modified emission unit for each
pollutant that exceeds an applicable PSD significant emission rate (SER). Since the PM10 and PM2.5
emissions from the proposed project exceed the applicable PSD SER, a BACT analysis is required
to assess the required levels of control for these pollutants. Because the CO2e emissions are subject
to regulation as a result of the proposed project resulting in an increase of 75,000 tons or more per
year CO2e, a BACT analysis is also required for that pollutant. Note that HAPs listed under CAA
Section 112(b)(1) are excluded from NSR (New Source Review) or PSD (i.e., BACT) review.

In a memorandum dated December 1, 1987, the United States Environmental Protection Agency
(EPA) stated its preference for a "top-down" BACT analysis. After determining if any New Source
Performance Standard (NSPS) is applicable, the first step in this approach is to determine, for the
emission unit in question, the most stringent control available for a similar or identical source or
source category. If it can be shown that this level of control is technically, environmentally, or
economically infeasible for the unit in question, then the next most stringent level of control is
determined and similarly evaluated. This process continues until the BACT level under
consideration cannot be eliminated by any substantial or unique technical, environmental, or
economic objections.

Presented below are the five basic steps of a top-down BACT review as identified by the EPA.
Step 1 - Identify All Control Technologies
Step 2 - Eliminate Technically Infeasible Options
Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Step 4 - Evaluate Most Effective Controls and Document Results
Step 5 - Select BACT

Ash Grove has elected to follow this methodology and based the BACT review on each individual
pollutant. The complete BACT analysis follows. [Last updated January 14, 2025]

2. BACT review regarding PM10 and PM2.5 Sources
PM10 and PM2.5 Modified Equipment
The existing kiln precalciner, preheater, and alleviator system are proposed to be modified, and the
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 10

kiln's ID fan and clinker cooler fans are proposed to be replaced, which will result in increased
airflow. Additionally, the clinker cooler baghouse will be converted from a plenum pulse to a pulse
jet baghouse. These modifications are projected to result in a net increase of potential PM10 and
PM2.5 emissions.

Kiln Upgrade BACT
The rotary cement kiln is the core of the cement manufacturing process, transforming the blended
raw materials or "rawmix" into clinker through pyro processing. Emissions from the kiln occur
from fuel combustion plus the physical and chemical reactions needed to transform the rawmix
into clinker. This project involves process and energy efficiency improvements and an increase in
kiln production, resulting in an increase of PM10 and PM2.5 emissions. This section specifically
addresses filterable PM10 and PM2.5. The condensable fraction is represented with the other
precursors as applicable to proposed emission increases.

The Leamington Plant's Kiln is subject to NSPS, Subpart F for particulate. Therefore, a BACT
analysis addresses applicability of the proposed changes to the kiln system to NSPS and review of
the RBLC. A summary of the resources reviewed include the following:

NSPS Subpart F - Standards of Performance for Portland Cement Plants establishes emission
standards for cement kiln operations. Specifically, kilns modified after June 16, 2008, are limited to
0.07 lbs PM/ton of clinker produced.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028) and
Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from kiln operations are as follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM emissions are most effectively controlled using a collection system with enclosures routed to
baghouses providing up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Ash Grove
has selected technology with the highest control efficiency, so there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.
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January 21, 2025
Page 11

Step 5 - Select BACT
Ash Grove proposes that BACT for PM10 and PM2.5 emissions from the kiln consist of a collection
system routed to a baghouse or fabric filter that complies with NSPS Subpart F's emission standard
for a modified source. BACT for the Leamington Plant's kiln are 10% opacity and 0.07 lb of
PM/ton (NSPS Subpart F emission standard) of clinker.
[Last updated January 14, 2025]

3. BACT review regarding PM10 and PM2.5 sources cont.
Clinker Cooler Upgrade BACT
The clinker cooler reduces the temperature of the clinker exiting the kiln. It is necessary to reduce
clinker temperature before it enters the finish mill to maintain product quality and reduce wear and
tear on equipment. The clinker cooler is equipped with a heat exchanger that captures waste heat
and transfers it to the kiln preheater for process and energy efficiency. Emissions from the clinker
cooler are vented to a baghouse. The Leamington Plant's clinker cooler is also subject to NSPS
Subpart F for particulate. Ash Grove's proposed changes to the clinker cooler meet the definition of
a reconstruction under NSPS. Therefore, in order to meet the requirements of NSPS Subpart F, Ash
Grove will be required to meet a limit of 0.02 lb of PM/ton of clinker.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from clinker cooler operations are as
follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM10 and PM2.5 emissions are most effectively controlled using a collection system with enclosures
routed to a baghouse, which can achieve up to 99.9% control efficiency. Other technologies such as
wet scrubbers, cyclones and ESPs are feasible, but provide lower control efficiencies than a
baghouse. Because the most efficient control technology is proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for PM10 and PM2.5 emissions from the clinker cooler is a collection system routed to a
baghouse or fabric filter. In order to meet the requirements of NSPS Subpart F, Ash Grove will
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meet a reduced emission limit of 0.02 lb of PM/ton of clinker. A 10% opacity limit is also
applicable. [Last updated January 14, 2025]

4. BACT review regarding PM10 and PM2.5 sources cont.
New Finish Mill BACT
The proposed Plant upgrade include adding a second finish mill. The new finish mill will use an
energy efficient vertical roller mill assisted with a grinding aid. A total of five (5) point sources are
planned for the finish mill. In accordance with NSPS Subpart F, emissions from finish mill are
restricted to 10% opacity. Ash Grove has reviewed the following sources to identify available
control technologies.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);12 and

Region 8 General Permit for Concrete Batch Plants.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 emissions from plant material handling operations are as
follows:
Baghouse / Fabric Filter;
Best Management & Operational Practices;
Cyclone;
ESP;
Enclosure;
Water Application (Watering); and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
With the exception of water application, all options are technically feasible. Water application is
eliminated as clinker exiting the kiln along with additives in the finish mill must remain dry to
maintain product quality. Therefore, it is technically infeasible to water material in the finish mill.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Enclosure 50-90%
5. Cyclone 20-70%
6. Best Management & Operational Practices varies

Step 4 - Evaluate Most Effective Controls and Document Results
Baghouses provide the highest emission control efficiency, controlling up to 99.9% of PM
emissions from finish mill equipment. After baghouses, using a wet scrubber or ESP provides
similar PM control. Notably, baghouses, scrubbers, and ESPs require enclosures to aid in capturing
emissions and ducting to the control. Therefore, optimal PM emission control can be achieved
through implementing both baghouses and enclosures where feasible. Plant material sizing and
handling is currently done using a series of buildings and enclosures routed to baghouse controls.
Various silos storing material inputs are also equipped with fabric filters. As the highest ranked
technology is applied, there are no adverse energy, environmental or cost impacts to consider with
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the use of these control technologies. Thus, no further analysis is required under EPA's top-down
BACT approach.

Step 5 - Select BACT
BACT for finish mill PM10 emissions is compliance with NSPS Subpart F, Standards of
Performance for Portland Cement Manufacturing where applicable. Ash Grove will achieve BACT
for PM10 emissions from finish mill equipment through the implementation of enclosures,
baghouses, and best management practices. All baghouses at the finish mill will have a 10%
opacity limitation and a grain loading of 0.005 grains/dscf. [Last updated January 14, 2025]

5. BACT review regarding PM10 and PM2.5 sources cont.
Material Transfer, Sizing, and Storage BACT
The Leamington Plant has sources of fugitive emissions through raw material transfer. Materials
transferred include limestone and other raw materials, coal, clinker, and cement. These materials
are transferred by conveyor belt, screw conveyor, elevator, pneumatic conveyance or chutes via
gravity. At the Leamington Plant the fugitive emissions are enclosed at their transfer points and
routed to baghouses.

The following emission units are included in this category:
Limestone Crushing, Sizing, and Material Transfer;
Raw Material Transfer;
Coal Sizing and Transfer;
Existing Finish Mill;
Clinker Storage and Transfer;
Cement Storage and Truck and Rail Cement Loadout;
New Rail Loading and Loadout; and
New Clinker Reclaim Hopper Baghouse.

Generally, controls for these units have not changed or they are similar to current existing controls.
A full BACT analysis of each unit is included in Ash Grove's NOI and additional submitted
information. However, given that most controls remain unaltered, only the results of Step 5 -
Select BACT will be included here.

Limestone Crushing, Sizing, and Material Transfer
Subject to NSPS Subpart OOO opacity limits for existing sources.
Existing baghouses. No change from bag manufacturer's specifications.

Raw Material Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Coal Storage and Transfer
Existing Equipment. No change from bag manufacturer's specifications
20% Opacity

Clinker Storage and Transfer
Subject to NSPS Subpart F opacity limits:
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10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Existing Finish Mill Grinding, Storage and Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Cement Storage and Truck and Rail Cement Loadout, New Rail Loadout
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

New Rail Loadout, controlled by baghouse
Emissions Limit - 0.005 gr/dscfm

New Clinker Reclaim Hopper, controlled by baghouse
Subject to NSPS Subpart F opacity limits:
10% opacity
Emissions Limit - 0.005 gr/dscfm [Last updated January 14, 2025]

6. BACT review regarding PM10 and PM2.5 sources cont.
PM10 and PM2.5 Fugitive Emissions
The following fugitive emissions sources will increase emissions of PM10 and PM2.5 as a result of
the Leamington Plant's proposed throughput increase. The sources addressed in the following
BACT analyses are primarily in the quarry, but also include emissions from roads and dumping of
raw materials within the plant boundary.

The sources evaluated are listed below:
Roads;
Loading and Unloading;
Stockpiles;
Bulldozing and Grading;
Disturbed Areas; and
Drilling and Blasting.

Ash Grove currently controls emissions from these processes, and generally, controls for these
units have not changed. A full BACT analysis of each unit is included in Ash Grove's NOI and
additional submitted information. However, given that most controls remain unaltered, only the
results of Step 5 - Select BACT will be included here.

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
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Page 15

Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

Stockpiles BACT
BACT shall consist of restricting fugitive emissions to the opacity standard of 20% opacity at the
property boundary. BACT for stockpiles will be achieved through applying good management
practices through its fugitive dust plan as appropriate.

Bulldozing and Grading BACT
BACT shall consist of restricting fugitive emissions from bulldozing and grading activities to no
more than 20% opacity, and that emissions are controlled with periodic watering of the disturbed
surface. The frequency of water application will depend on ambient weather conditions and
inherent moisture content of the material being moved.

Disturbed Areas BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. BACT for
disturbed areas will be achieved through best management practices, watering, scarification, and
revegetation.

Drilling and Blasting BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. This is achievable
through best management practices, shrouds, watering, and dust collection. [Last updated January
14, 2025]

7. BACT review regarding kiln system NOx emissions
Kiln System (Kiln, Raw Mill, and Coal Mill) - NOx BACT
Although there are physical changes to the kiln system, these changes are primarily related to
particulate emissions. NOx emissions are generated from the combustion of fuel - and no changes
in NOx emissions are expected from the kiln (hourly capacity to emit). The kiln NOx emissions will
remain the same as a result of upgrades to the SNCR system. The replacement of the various
components of the kiln system and portions of the preheater tower, along with new injection points,
will ensure that increased mixing of ammonia is achieved to enhance the SNCR system's ability to
reduce NOx and minimize ammonia slip. This will allow the Leamington Plant to maintain the NOx
hourly capacity to emit unchanged from current levels Leamington Plant Upgrade Project. At
present Ash Grove has no restriction on the amount of fuel combusted, only a limit on total NOx
generated, and with this project the allowed NOx PTE is decreasing from 1,352 tpy to 1,226 tpy.

Additional ammonia will be used in the existing SNCR system. While the SNCR system has
adequate capacity to accommodate the additional ammonia demand resulting from the system
upgrades, more ammonia ports are proposed to be added with the kiln system's proposed changes
of the equipment. The changes proposed to the kiln system will increase residence time and
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temperature which will improve the SNCR system's effectiveness to control NOx emissions and
minimize ammonia slip emissions to the atmosphere. No additional review of NOx BACT for the
kiln system is required under this proposal. [Last updated January 14, 2025]

8. BACT review regarding new finish mill heater emissions
Finish Mill Heater
The proposed finish mill will include a process heater to maintain a minimum temperature during
milling. The proposed heater will run on natural gas and is rated at 10 MMBtu/hr. Startup and
shutdown emissions from the heater are anticipated to be no greater than normal operation as the
process is simply a matter of bringing the heater to operating temperature. Emissions evaluated in
the BACT analysis for the finish mill heater include NOx, SO2, CO, and VOCs, PM10, and PM2.5.
Pollutants with identical control technologies are grouped together in the analysis.

NOx - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for NOx from units of this size range are as follows:
Ultra-Low-NOx Burners (ULNB);
Low NOx Burners;
Selective Catalytic Reduction (SCR);
Selective Noncatalytic Reduction (SNCR);
Good Combustion Practices; and
Use of Natural Gas.

Step 2 - Eliminate Technically Infeasible Options
Low exit temperatures render the use of SCR and SNCR ineffective. Particulate entrainment within
the finish mill could potentially foul (plug) the nozzles of ULNB. Low-NOx burners, the use of
natural gas as fuel and good combustion practices are all considered technically feasible.

Step 3 and Step 4 - Rank Remaining Control Technologies by Control Effectiveness and Evaluate
Most Effective Controls and Document Results
Since the three feasible control technologies are proposed for the finish mill heater, no detailed
economic, energy, and environmental impact evaluations were conducted. No ranking of control
effectiveness is required as all three controls are proposed.

Step 5 - Select BACT
BACT for NOx is the use of natural gas as fuel, good combustion practices and the use of Low NOx
burners.

CO, SO2, and VOC - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for CO, SO2, and VOC from units of this size are as follows:
Good Combustion Practices
Use of Natural Gas

The finish mill heater combusts natural gas. Related natural gas combustion emissions are
anticipated to be minimal.

Step 2 - Eliminate Technically Infeasible Options
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Both control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Both technologies offer intrinsic emission reductions from combustion. Since the technologies do
not compete, both technologies can and will be used simultaneously.

Step 4 - Evaluate Most Effective Controls and Document Results
Because both control technologies identified in Step 1 are proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for CO, SO2, and VOC are good combustion practices and the use of natural gas.

PM10 and PM2.5 BACT for the finish mill has been addressed in the PM10/PM2.5 sources section.
[Last updated January 14, 2025]

9. BACT review regarding SO2, VOC, and Lead Sources
The following BACT analysis is grouped by pollutants that will experience an increase in potential
emissions and the associated technically feasible control technologies. As such, the BACT analysis
is separated into SO2, VOC, and lead respectively with organic HAPs addressed with VOCs.

SO2 - Cement Kiln BACT
NSPS Subpart F - Standards of Performance for Portland Cement Plants, establishes emission
standards for cement kiln operations. Specifically, kilns constructed or reconstructed after June 16,
2008, are limited to 0.4 lbs SO2/ton clinker on a 30-day rolling average respectively. This limit is
an existing emission limit in the Leamington Plant's approval order and Title V. Ash Grove will
continue to achieve this emission limitation while achieving BACT for the kiln operations. Ash
Grove has reviewed the following sources to identify available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019); and

NSPS Subpart F as an affected emissions facility in 40 CFR 60.62(a)(4);

Portland Cement Association's Formation and Techniques for Control of Sulfur Dioxide and Other
Sulfur Compounds in Portland Cement Kiln Systems.

SO2 emissions are a result of oxidation of sulfur compounds in the rawmix and/or the coal used to
fire the kiln. However, the alkaline nature of the cement provides for direct absorption of SO2 into
the product, thereby mitigating the quantity of SO2 emissions in the exhaust stream.

Step 1 - Identify All Control Technologies
Control technologies identified for SO2 emissions from coal-fired kiln operations are as follows:
Baghouse or fabric filter;
Dry reagent injection prior to baghouse;
Wet scrubber;
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Process optimization; and
Good combustion practices.

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below:

1. Process Optimization 99%
2. Wet Scrubber 99%
3. Dry Reagent Injection 60%
4. Good Combustion Practices 30%
5. Baghouse Variable

Step 4 - Evaluate Most Effective Controls and Document Results
SO2 emissions are most effectively controlled by optimizing the process and utilizing the inherent
SO2 scrubbing properties of the kiln system itself. Although wet scrubbers alone can achieve equal
control efficiencies as process optimization, additional capital and operational expenses are
required for water consumption and wastewater discharge. Whereas process optimization achieves
the same control effectiveness and has the added benefit of reduced operational costs. Ash Grove
optimizes the kiln process by routing the exhaust from the kiln to a preheater and raw mill to
interact with the raw mix, thus creating an atmosphere similar to a dry scrubber system. Good
combustion practices also reduce SO2 formation with the added benefit of energy efficiency.

Step 5 - Select BACT
BACT for control of SO2 emissions from kiln operations shall consist of process optimization by
routing kiln exhaust to the preheater and raw mill, good combustion practices, and use of a
baghouse prior to exhausting to the atmosphere. As a modification of the kiln, 40 CFR 60.62(a)(4)
requires an emission limit of 0.4 pounds of sulfur dioxide (SO2) per ton of clinker on a
30-operating day rolling average. [Last updated January 14, 2025]

10. BACT review regarding SO2, VOC, and Lead Sources cont.
VOC - Cement Kiln BACT
VOCs are generated by incomplete combustion in the kiln. 40 CFR 63 Subpart LLL - NESHAP
from the Portland Cement Industry limits total hydrocarbon and total organic HAP emissions to 24
and 12 ppmv at 7% oxygen. Ash Grove will achieve or exceed these emission limitations while
achieving BACT for the kiln operations. Ash Grove has reviewed the following sources to identify
available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028); and

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for VOC emissions from coal fired kiln operations are as follows:
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Page 19

Process optimization,
Good combustion practices

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below.

1. Process Optimization Variable
2. Good Combustion Practices Variable

Step 4 - Evaluate Most Effective Controls and Document Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove optimizes the
kiln process by capturing waste heat from the clinker cooler and routing to a kiln preheater. Good
combustion practices also reduce VOC formation with the added benefit of energy efficiency.
There are no adverse energy, environmental or cost impacts to consider with the use of this control
technology.

Step 5 - Select BACT
BACT for control of VOC emissions from kiln operations shall consist of process optimization by
routing kiln heat to the preheater and good combustion practices. An emission limit of 24 ppmv
VOC @ 7% O2 is imposed by NESHAP Subpart LLL.

VOC - Grinding Aid BACT
A grinding aid containing VOC is added to the new finish mill to disperse particles within the mill
and expose more surface area to grinding. An increase in grinding aid usage proportionally
increases potential VOC emissions because volatiles from the grinding aid are not combusted in
the kiln.

There is only one identified control option for limiting the VOC emissions from the grinding aid.
Process optimization is technically feasible. VOC emissions are most effectively controlled by
optimizing the process. Ash Grove proposes to install a vertical finish mill with this project. Due to
the new modern mill's efficiency, it is anticipated that a reduced amount of grinding aid will be
required for each ton of clinker ground. Ash Grove estimates total VOC emissions from the
grinding aid at 2.37 tpy.

Lead Emissions
The lead emissions are anticipated to increase as a result of the proposed increase in clinker
throughput with the Leamington Plant upgrade project. Lead emissions result from residual
amounts of lead in raw materials and fuel. Lead emissions will be controlled the same as PM,
therefore a separate top-down BACT analysis has not been conducted as the Leamington Plant has
applied the most effective controls. [Last updated January 14, 2025]

11. BACT review regarding Greenhouse Gases
GHG Background
On October 9, 2009, the mandatory GHG reporting regulation, referred to as 40 CFR 98, was
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published in the Federal Register. Through 40 CFR 98, the U.S. EPA established the GHG
Reporting Rule, which requires the annual reporting of GHG data and other relevant information
from large sources and suppliers in the United States. Monitoring through the GHG Reporting
Program (GHGRP) began in 2010, with the first reports due by March 31, 2011. Per 40 CFR
98.2(a)(1), any facility associated with cement production is subject to the GHGRP and must report
CO2e emissions. The CO2e is the sum of equivalent GHG emissions from CO2, CH4, and N2O,
with their respective global warming potentials (GWP) applied. Ash Grove's facility is subject to
GHG Reporting Rule and monitors CO2 emissions from its kiln with a continuous emissions
monitoring system (CEMs). On June 23, 2014, the U.S. Supreme Court held that required PSD
permits (based on emissions of non-GHG pollutants) may continue to require limitations on GHG
emissions based on the application of BACT as an "anyway source". The Leamington Plant
modification project is a major source for PSD for both PM10 and PM2.5, and GHGs are estimated
to be greater than 75,000 tpy and greater than zero on a mass basis; therefore, GHGs are evaluated
for BACT as an anyway source.

Cement Manufacturing GHG BACT
A BACT analysis has been conducted for CO2e emissions from the kiln system. For this GHG
BACT analysis, various control technologies or combinations of technologies were identified using
the RACT/BACT/LAER Clearinghouse, available literature including guidance published by EPA
and South Coast Air Quality Management District (SCAQMD), current air regulations, other
regulatory organizations, and engineering experience. In March 2011, EPA published GHG
permitting guidance, as well as a white paper on available and emerging technologies for reducing
GHG emissions from the Portland cement industry in October 2010. Additionally, EPA published a
series of videos on GHG permit training in December 2010. The SCAQMD published GHG BACT
guidance in 2021. Additional sources of information were reviewed and documented based on
publications from trade organizations and other governmental committees with GHG or carbon
reduction guidelines and/or recommendations.

EPA has defined in 40 CFR 86.1818-12(a) GHGs as a group of six gases: CO2, nitrous oxide
(N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF6). GHG emissions from the kiln result from calcination and fuel combustion.
Since the primary GHG emitted by a kiln is CO2, the BACT analysis focuses on CO2 emissions
from the kiln. Emissions of CH4 and N2O are minimal from cement kilns. Per EPA guidance, GHG
control technologies for consideration in a BACT analysis for Portland Cement Manufacturing
include:

Source-wide energy efficiency strategies;
Raw material substitution;
Blended cements;
Carbon capture utilization and storage; and
Fuel switching.
Other emerging technologies [Last updated January 14, 2025]

12. BACT review regarding Greenhouse Gases cont.
Step 1: Identify All Control Technologies
The CO2 emissions from a cement kiln are generated by the calcination process (conversion of the
calcium carbonate in limestone to calcium oxide) and by combustion of fuel in the kiln. Potential
control technologies to reduce these CO2 emissions for a cement kiln are addressed in EPA's white
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paper on Available and Emerging Technologies for Reducing GHG Emissions from the Portland
Cement Industry.

These technologies fall into three categories:
Energy Efficiency Improvements for the Clinker Production Process
Fuel Substitution
Carbon Capture and Sequestration

Step 2: Eliminate Technically Infeasible Options
Several potential energy efficiency improvements are technically feasible: Pre-heater/Pre-calciner
Kiln Process, Kiln Seal Management Program, Refractory Selection (Kiln Insulation), and Energy
Recovery from the Clinker Cooler. The use of alternative fuels such as natural gas, whole tires and
biofuel) is also technically feasible. Other control options, such as Use of Fluxes and Mineralizers,
Heat Recovery for Power - Cogeneration, Carbon Sequestration, Oxyfuel combustion, and
Post-combustion Capture have been deemed infeasible.

Step 3: Rank Remaining Control Technologies by Control Effectiveness
All four remaining control techniques are currently implemented at the Leamington Plant. This
permitting project incorporates energy efficiency improvements. Ash Grove has had a fuel
substitution program in place for several years, and this program is continually reviewed and
updated as new sources and types of fuel are identified.

Step 4: Evaluate Most Effective Controls and Document Results
Since all technically feasible energy efficiency improvements and changes to product composition
will be implemented, this section will focus on economic and environmental considerations of fuel
substitution to operate exclusively on natural gas.

Firing natural gas as the primary kiln fuel can reduce CO2 emissions from fuel combustion by as
much as 40%. However, studies have shown that use of natural gas as primary kiln fuel can result
in three times more NOx emissions than NOx emissions from coal firing. Creating more NOx to
reduce GHG emissions is undesirable as it is a precursor to both ozone and PM2.5. Fuel substitution
essentially trades emissions of one regulated pollutant for another. Estimated capital cost to switch
to natural gas fuel exceeds $25M. Implementing natural gas technology would provide incremental
public health and welfare benefit globally by reducing CO2 emissions, while increasing NOx
emissions and negatively impacting public health and welfare locally. Switching fuels to another
fossil fuel has finite potential to mitigate CO2 emissions.

Step 5: Select BACT
In addition to the proposed energy efficiency improvements addressed elsewhere in this BACT
analysis, BACT is a limit of 0.92-ton CO2e/ton clinker. Ash Grove will use a continuous emission
monitoring system (CEMS) for CO2 to demonstrate compliance with this limit. [Last updated
January 14, 2025]

13. BACT review regarding Leamington Plant Upgrade Project conclusion
The control processes and techniques covered in this BACT analysis have been reviewed by the
NSR Section of the UDAQ. Ash Groves proposed controls and associated emission limitations
represent BACT. Any emission limitations not expressed in an associated NSPS or NESHAP will
be included in the terms and conditions of this AO. A listing of all associated NSPS and NESHAP
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programs is also included in the Source Information section of this document under Applicable
Federal Programs. [Last updated December 13, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
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.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date
of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
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proper credit when notifying the Director, send the documentation to the Director, attn.: NSR
Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

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

II.A.3
NEW
Stockpiles
Coal storage
Area: 1 acre
Annual throughput 20,000 tpy

AF and ARM stockpiles
Area: 0.25 acre
Annual throughput 8,000 tpy

II.A.4 Stationary Crusher
Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction
of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000
acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)

II.A.5 Raw Material Transfer
Crushed material is transported to raw material storage by belt B8. The raw material transfers
at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor
transfer point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total
filter area & water sprays. (pre-1983)

II.A.6 Material Handling
Conveyor belt systems, secondary feeders and screens, stacker system

II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit specific requirements

II.A.8 Belt Conveyor Transfer Baghouse
Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area
and 1,800 acfm total air flow, controls emissions from the conveyor belt that transfers the
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stacked material to the raw material silos.

II.A.9 Raw Material Silos
Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The
four silos are equipped with one common Fuller, plenum pulse baghouse (315.BF1) - 1,689 ft2
filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage).

II.A.10 Fifth Component Silo
Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse
(315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw
mill feed. This system includes vibrating feeders, a conveyor system, and surge bin.
Emissions are controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3,
316.BF4, 316.BF5) - each is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1
A/C ratio.

II.A.12 Cross-Belt Analyzer
Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6)

II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom
of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw
materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38).
The following equipment is installed: low-NOx burner, selective non-catalytic reduction
(SNCR) for NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued
mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric
monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct
for mercury adsorption capacity. The carbon injection system is not an emission point as it is
in an enclosed building.

II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

II.A.16 Two Kiln Feed Blending Silos
Raw material is blended in one of two blending silos prior to feeding the kiln. The blending
silos are controlled by one common Fuller, plenum pulse baghouse (411.BF1) - 1,351 ft2 filter
area; 7,160 acfm total air flow.

II.A.17 Blending Silo Elevators (2)
Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped
with a Fuller, pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow
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through stack E34.

II.A.18 Kiln Feed Alleviator
A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the
central material silo between the blending silos and the preheater. Raw feed is removed from
the system near the top of the preheater tower.

II.A.19 Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner.
The coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter
area; 1,700 acfm total air flow.

II.A.20 Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in
the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2):
19,500 acfm rated airflow with 3.75:1 A/C ratio

II.A.21 Clinker Cooler and Baghouse
Reconstructed grate type cooler used for cooling clinker from the kiln prior to transfer to
clinker storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) -
173,869 acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter
monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two
clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse
(419.BF8). The exhaust is routed to the clinker cooler stack.

II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions
generated when loading the east and west clinker silos and the out-of-spec silo are controlled
by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1):
1,800 acfm, that discharges into the clinker tunnel.

II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm, that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2)
Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers.
Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses
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(511.HP1 and new 511.HP2): 1,800 acfm each.

II.A.27 Gypsum Silo
Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2
total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust
during loading.

II.A.28 Clinker Tunnel Exitway
The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse
(511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel all discharge in the clinker tunnel.
Emissions are vented through the tunnel exitway.

II.A.29 Limestone Silo
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust
during loading. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement product. Dust
generated during milling is captured by a BHA, pulse jet baghouse (514.BF2) - 6,080 ft2 filter
area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding
stack).

II.A.31 Finish Mill (Ball Mill) Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized
cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA, pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow
controlling particulates from stack G55 (finish mill stack).

II.A.32
NEW
Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The
stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4)
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1,
525.BF1 thru 3)

II.A.33 Finish Cement Storage Silos
There are six storage and two interstice silos where the finished cement product is stored. A
single common Fuller, plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm
total air flow through stack H7 is located on top of the silos and is used to control emissions
during loading and unloading operations.

II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail
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shipping. This baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out
The cement loadout system located on the South side of the silos (truck load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF2) during unloading from the silos for truck
shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement
conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed
space inside the silos.

II.A.36
NEW
Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

II.A.37 MHO: Materials Handling Operation
Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1
& 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4;
512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.

II.A.38 LBS: Limestone Bypass System
Additional limestone is added to the clinker and gypsum by the limestone bypass system
(LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays
at the screen and material handling drop points.

II.A.39 GEN: Emergency Generators
One diesel-fired emergency generator (new)
Rating: 762 hp
(Kiln, Tier 3, permitted 2022)

Two natural gas-fired emergency generators
Rating: 304 hp
(Main office and control room, permitted in 2023)

One diesel-fired emergency generator
Rating: 560 hp
(Shipping, permitted 2023).

II.A.40 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14 inch knife gate, 8 inch knife gate, 8 inch air
slides, surge bin), and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm)
on the fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

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II.A.41
NEW
Miscellaneous Storage Tanks
One diesel storage tank (<2,000 gallons)
One gasoline storage tank (500 gallons)
Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Requirements on the Cement Plant:
II.B.1.a
NEW
The following limits shall not be exceeded:

A. Clinker production - 1,155,000 tons per rolling 12-month period

B. Used oil consumption - 85,724 gallons per rolling 12-month period

C. Limestone bypass material processed - 216,260 tons per rolling 12-month period.
[R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 25th day of each month using data from the previous 12 months.
Records shall be kept for all periods when the plant is in operation. Consumption and
production shall be calculated through use of the plant's acquisition system. [R307-401-8]

II.B.1.b
NEW
Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations:

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

SO2: 0.4 lbs per ton of clinker (3-hr average)

CO: 3,395 tons per rolling 12-month period, and 6,600 lbs/hr

NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average, and 1,233 tons per rolling
12-month period

Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is
400oF or less.

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Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)

THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)

CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)

PM: 0.02 lbs filterable PM per ton of clinker. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL,
R307-401-8]

II.B.1.c
NEW
A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR
60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust
emissions control plan shall be monitored to demonstrate that appropriate control measures are
being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of
the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall
be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in
the plan and that the source is operating in accordance with the submitted plan. For petitions
to approve alternative control measures, the permittee shall keep a copy of the submitted
petition and any approvals received. [40 CFR 60 Subpart Y]

II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area
source of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2). [40 CFR
63 Subpart LLL]

II.B.1.e
NEW
Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b
and II.B.1.d shall be performed as specified below:

A. Kiln/Raw Mill Stack
Pollutant Test Status Test Frequency
PM * #

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

B. Clinker Cooler (F31)
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Pollutant Test Status Test Frequency
PM + #

C. Testing Status (To be applied above)
* The initial testing has already been performed.

** The SO2 initial performance test was conducted on August 26, 2013.

*** The initial compliance test shall be conducted within the first 30 operating days of
operation in which the affected source operates using a CEMS.

# Test once every year. If performance testing would be required less than 15 operating days
after the Kiln has completed Startup after being down for more than 24 hours, then
performance testing may be deferred up to 15 operating days after completion of the Startup.
The Director may require testing at any time.

## Test at least once every two years. The Director may require testing at any time.

+ Initial testing is required within 180 days of startup of the reconstructed equipment

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must 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 PM CPMS is not out-of-control. The owner/operator must
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 on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

+++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.e.1
NEW
Notification
The Director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The notification requirements for performance tests subject to 40
CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-165]

II.B.1.e.2
NEW
Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational
Safety and Health Administration (OSHA)- or Mine Safety and Health Administration
(MSHA)-approved access shall be provided to the test location. [R307-165]

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II.B.1.e.4
NEW
PM
40 CFR 60, Appendix A, Method 5 or 5I or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three (3) runs with
each run at least 120 minutes in duration and each run collecting a sample of 60 dry standard
cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.3
NEW
Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2. [R307-165]

II.B.1.e.5
NEW
Carbon Monoxide (CO)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.6
NEW
Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.7
NEW
Sulfur Dioxide (SO2)
40 CFR 60, Method 6 or 6C of Appendix A-4 or other EPA-approved method as acceptable to
the Director. [R307-165]

II.B.1.e.8
NEW
Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]

II.B.1.e.9
NEW
Total Hydrocarbons (THC)
Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL]

II.B.1.e.10
NEW
Mercury (Hg)
Continuous Emission or integrated sorbent trap monitoring (See Condition II.B.3.a). [40 CFR
63 Subpart LLL]

II.B.1.e.11
NEW
HCl
Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other
EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]

II.B.1.e.12
NEW
Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.13
NEW
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. [R307-165]

II.B.1.e.14
NEW
Existing Source Operation
For an existing source/emission point, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three years.
[R307-165]

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II.B.1.e.15
NEW
New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the maximum production rate listed in this AO. If the maximum AO
allowable production rate has not been achieved at the time of the test, the following
procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This new
allowable maximum production rate shall remain in effect until successfully tested at a higher
rate.

3) The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate (110%
of the new rate) will then be allowed if the test is successful. This process may be repeated
until the maximum AO production rate is achieved. [R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL.
[40 CFR 63 Subpart LLL]

II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times
of Dust Shuttle System operation to assist in the capture of Mercury emission. [R307-401-8]

II.B.1.h
NEW
Visible emissions from the following emission points shall not exceed the following values:

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

L. All baghouses - 10% opacity
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M. Fugitive dust - 20% opacity

N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y,
R307-401-8]

II.B.1.i 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 must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

If any partially enclosed or unenclosed conveying system transfer point is located in a
building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to
40 CFR 60, according to the following:

(i) The owner/operator must conduct a monthly ten-minute visible emissions test of each
affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The
performance test must be conducted while the affected source is in operation.

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator 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 owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iii) If no visible emissions are observed during the semi-annual test for any affected source,
the owner/operator 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 owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iv) If visible emissions are observed during any Method 22 performance test, of Appendix
A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations,
recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60.
The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour
of any observation of visible emissions.

(v) If visible emissions from a building are monitored, the requirements of paragraphs (i)
through (iv) of this Condition apply to the monitoring of the building, and the owner/operator
must also test visible emissions from each side, roof, and vent of the building for at least ten
minutes. [R307-401]

II.B.1.j
NEW
Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed
0.005 gr/dscf:

520.BF1
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520.BF2
520.BF3
520.BF4
521.BF2
521.BF1
524.BF1
524.BF2
524.BF4
524.BF3
525.BF1
525.BF2
525.BF3
511.HP2
NRL_UPR
NRL_LWR. [R307-401-8]

II.B.1.j.1
NEW
To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration
through at least three (3) annual tests that the PM limits are not being exceeded, the
owner/operator may request approval from the Director to conduct stack testing less
frequently than annually. [R307-401-8]

II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive
dusts as dry conditions warrant or as determined necessary by the Director to maintain opacity
limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated to control fugitive dust. The application of
water or chemical treatment shall be used. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a damp/moist condition unless it is below freezing.
If chemical treatment is to be used, the plan must be approved by the Director. Records of
water and/or chemical treatment shall be kept for all periods when the plant is in operation.
The records shall include the following items: Instances of water and/or chemical application
to unpaved areas shall be recorded and maintained by the owner/operator. The ambient
temperature shall be recorded any time water should be applied but cannot due to freezing
conditions. [R307-401-8]

II.B.2.c
NEW
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

The sprays shall operate whenever dry conditions warrant meeting the required opacity
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limitations or as determined necessary by the Director. Water sprays shall not be required
during periods of freezing temperatures. [R307-401-8]

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation
of fugitive dusts as dry conditions warrant or as determined necessary by the Director.
[R307-401-8]

II.B.2.e
NEW
The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5
PM. [R307-401-8]

II.B.3 Continuous Emission Monitoring Requirements:
II.B.3.a
NEW
The owner/operator shall install, calibrate, maintain and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler.

A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the
missing data substitution procedures used by the UDAQ or the missing data substitution
procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate by the UDAQ.

B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period
including during each startup, shutdown, or malfunction.

C. The monitoring system shall comply with all applicable sections of R307-170, UAC; and
40 CFR 60, Appendix B.

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be
installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the
kiln/raw mill stack.

F. The owner/operator shall record the output of the system: including the quantity of NOx,
CO, O2 THC, Hg, HCl, and CO2 emissions at the kiln stack.

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source 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.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker
cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except
during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments,
the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a
PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the
results of the performance test demonstrating compliance with the filterable PM limit and
using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust
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the SSOL developed in accordance with the results of the most recent PM performance test
demonstrating compliance with the PM emission limit. The owner/operator shall use the PM
CPMS to demonstrate continuous compliance with the SSOL in accordance with the
requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

II.B.4 Fuel Limitations:
II.B.4.a
NEW
The owner/operator shall use only the following fuels in the kiln and pre-calciner:

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.

If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b
NEW
Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the
Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the
results of suitable tests giving data similar to a Proximate and Ultimate analysis of the
proposed coal additive. [R307-401-8]

II.B.4.b.1 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. [R307-401-8]

II.B.4.b.2 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 owner/operator 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 in Condition
II.B.4.b. [R307-401-8]

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II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel burning or process
installation not covered by New Source Performance Standards for sulfur emissions or
covered elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross
Btu heat input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input
for any oil except used oil. The sulfur content shall comply with all applicable sections of
UAC R307-203. [R307-203, R307-401-8]

II.B.4.c.1
NEW
Certification of fuels shall be either by the owner/operator's own testing or test reports from
the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be
available onsite. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials, UAC R307-203-1 (4)

A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be
used.

B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be
used.

C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85 are to be used. [R307-203]

II.B.4.d
NEW
The concentration/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight
3) Cadmium 2 ppm by weight
4) Chromium. 10 ppm by weight
5) Lead 100 ppm by weight
6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be
tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the burn tank and burned. [R307-401-8]

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II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned
in the rotary kiln:

A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than
five minutes in any 60-minute period

B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes
in any 60-minute period. [R307-401-8]

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the
Director. The calibration procedure and frequency shall be according to manufacturer's
specifications. Use of factory-calibrated thermocouples for temperature measurement is
approved. However, any other method of temperature measurement must be approved by the
Director prior to use. The monitoring equipment for both temperature and oxygen content
shall be located such that an inspector can at any time safely read the output. [R307-401-8]

II.B.5
NEW
Emergency Engine Requirements
II.B.5.a
NEW
The owner/operator shall only operate the emergency engines for testing and maintenance
purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency
operation. [R307-401-8]

II.B.5.b
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each emergency engine. [R307-401-8]

II.B.5.b.1
NEW
The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.5.b.2
NEW
To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN103030035-24 dated November 27, 2024
Is Derived From Source Submitted NOI dated November 30, 2022
Incorporates Additional Information Received dated April 26, 2023
Incorporates Additional Information Received dated September 26, 2023
Incorporates Additional Information Received dated July 23, 2024
Incorporates Additional Information Received dated October 25, 2024
Incorporates Additional Information Received dated November 25, 2024

REVIEWER COMMENTS

1. Comment regarding applicability of federal requirements:
New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable
by the best demonstrated technology as specified in the applicable provisions. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.

40 CFR 60, Subpart A (General Provisions)
All affected facilities subject to a source-specific NSPS are subject to the general provisions of
NSPS, Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires
initial notification, performance testing, recordkeeping, and monitoring, provides reference methods,
and mandates general control device requirements for all other subparts.

40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of
performance for affected facilities in Portland Cement Plants which have been constructed or
modified after August 17, 1971.

40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart
F: Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and
unloading systems. The Leamington coal mill is an in-line coal mill and considered an integral part
of the Leamington kiln. In-line coal mills are not subject to NSPS Subpart Y. Therefore, the coal mill
is addressed under NSPS Subpart F as part of the kiln system. The coal silos and conveying system
are subject to NSPS Subpart Y.

Ash Grove's proposed changes to the kiln system must be evaluated as to whether they trigger new
NSPS Subpart F obligations based on whether the proposed project is either a modification or a
reconstruction, as those terms are defined in NSPS Subpart A.

Ash Grove's proposed changes to the kiln system do not meet the definition of a reconstruction, nor
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January 21, 2025
Page 40

do they meet the definition of a modification for NOx. However, the changes meet the definition of a
modification for PM and SO2. Therefore, Ash Grove will comply with all relevant emission
standards; testing requirements; monitoring, recordkeeping, and reporting obligations that apply to
the Leamington kiln system as an existing source under NSPS Subpart F. Under NSPS Subpart A
and F, the clinker cooler is considered a reconstructed unit. Thus new limits will apply to this unit.
[Last updated January 14, 2025]

2. Comment regarding applicability of federal requirements cont.:
NSPS Subpart Y - Standards of Performance for Coal Preparation and Processing Plants
This subpart provides standards of performance for affected facilities in coal preparation and
processing plants that process more than 200 tons of coal per day.

The Leamington plant's coal silo and coal conveying system are existing affected facilities under
NSPS Subpart Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses
controlling affected facilities subject to match the limit in NSPS Subpart Y from 0.016 gr/dscf to
0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade Project. Since there are no proposed
modifications or reconstruction to the coal silo and coal conveying system, nothing about the
proposed upgrade project affects the existing applicability of NSPS Subpart Y.

NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
This subpart provides standards of performance for affected facilities located at fixed or portable
nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August
31, 1983, with additional requirements applicable to sources constructed on or after April 22, 2008.

As the crushing and screening system is controlled by baghouses and an increase in PM10 actual
emissions on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS.
Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the
Leamington Plant Upgrade Project.

Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1),
60.676(f), and 60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO
monitoring and recordkeeping requirements.

[Last updated January 14, 2025]

3. Comment regarding applicability of federal requirements cont.:
National Emission Standards for Hazardous Pollutants (NESHAPs)
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or
greater than 10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as
specified by each subpart. NESHAP apply to sources in specifically regulated industrial source
classifications (CAA Section 112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities
not regulated as a specific industrial source type. The Ash Grove Leamington Plant is a major source
of HAPs and thus is subject to certain NESHAP standards.

Subpart A - General Provisions
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All affected sources are subject to the general provisions of Subpart A unless otherwise specified by
the source-specific NESHAP. Subpart A generally requires initial notification and performance
testing, recordkeeping, monitoring, provides reference methods, and mandates general control device
requirements for all other subparts as applicable.

Subpart LLL - Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry
This subpart establishes process/source specific emission limits for PM, VOC (expressed as total
hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and
gaseous HAP compounds by limiting PM and THC emissions because portions of such emissions
are USEPA-listed HAPs. Subpart LLL requires compliance with applicable emissions limits on and
after the initial startup of cement production. To further reduce emissions, Subpart LLL also
establishes operational requirements for the use of cement kiln dust (CKD), fly ash, fuel and control
equipment. Subpart LLL also specifies process/source specific emissions testing, monitoring,
recordkeeping, reporting, and compliance demonstration requirements. The compliance requirements
for the site are detailed in Approval Order Condition II.B.1.b. Ash Grove will continue to comply
with the requirements of Subpart LLL to demonstrate compliance. This cement kiln will remain an
existing source with respect to the kiln emission standards in Subpart LLL as this project does not
trigger the definition of a new source in Subpart LLL. New source standards apply only to affected
sources that were constructed or reconstructed after May 6, 2009.
[Last updated December 20, 2024]

4. Comment regarding PSD applicability analysis:
Ash Grove is proposing to increase the throughput of limestone from the quarry to supply the New
Finish Mill to increase the amount of low-carbon cement from the Leamington Plant. Additionally,
along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
modified, and the clinker cooler will be reconstructed. These changes are anticipated to result in an
increase in clinker production. Emission calculations for this project have been completed assuming
an increase in clinker production capacity while utilizing current fuel types. This will result in an
increase in the throughput of fuel.

The Leamington Plant is considered an existing major source under PSD based on potential
emissions of PM10, PM2.5, NOx, CO, SO2, and CO2e. If a major source undergoes a physical or
operational change, the facility must determine whether the project will be considered a major
modification. Per 40 CFR 52.21(b)(2)(i), in order to be a major modification, the project must result
in a significant emissions increase, and a significant net emissions increase.

As defined at 40 CFR 52.21(b)(40): Significant emissions increase means, for a regulated NSR
pollutant, an increase in emissions that is significant for that pollutant. Significant is further defined
to mean, in reference to a net emissions increase or the potential of a source to emit any of the
following pollutants, a rate of emissions that would equal or exceed the values outlined in 40 CFR
52.21(b)(23). If the increase in emissions from the project are not significant, a major modification
has not occurred.

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 42

increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

For all pollutants, the project emissions increase was calculated as the difference between the
projected actual emissions (PAE) after the proposed project and the actual emissions prior to the
project (baseline actual emissions or BAE).

Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
". . . projected actual emissions means the maximum annual rate, in tons per year, at which an
existing emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years
(12-month period) following the date the unit resumes regular operation after the project, or in any
one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit of that regulated NSR pollutant and full utilization of the unit would
result in a significant emissions increase or a significant net emissions increase at the major
stationary source." [Last updated January 14, 2025]

5. Comment regarding PSD applicability analysis cont.:
Ash Grove estimates that the projected actual production capacity following the project will be
1,155,000 tons of clinker per year and 1,341,266 tons of limestone per year. These capacities were
used to calculate projected actual emissions from the project using representative emission factors.
Additionally, to estimate emissions from material transfer baghouses, the actual flow rates and actual
projected hours were used as a basis for projected actual emissions.

Project Emission Calculations

Project emission increases from the kiln and coal mill systems are calculated for all criteria
pollutants based on emission factors that are derived from stack testing, CEMS data, or emission
factors (i.e., VOCs and Lead), and the associated projected incremental clinker increase.

NOx emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain
hourly capacity to emit and annual potential to emit at current levels. The kiln's NOx emissions rate
will not change as a result of the physical modifications proposed by the project.

Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission
factor and multiplied by the incremental increase in clinker production. The emission factor was
selected based on the average of the 24-month consecutive month emissions for 2020 and 2021. The
CO emissions will increase.

The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing
conducted at the plant. The SO2 emissions will increase.

VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production. VOC emissions will increase.

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 43

can be found in the original NOI and subsequent addendums submitted to UDAQ.

As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from
the proposed project, each increase of emissions from both existing and new sources shall be
summed together and compared to the PSD permitting thresholds. The increase of emissions is the
"positive" difference between the projected actual emissions and baseline actual emissions (projected
minus baseline).

New Emissions Sources

The actual to projected actuals calculation is not available to new emission units. For new emission
units, the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected
emissions are based on the new sources' potentials to emit. (40 CFR § 52.21(a)(2)(iv)(f)).

The new equipment proposed includes the New Finish Mill, a new rail and truck loading/loadout,
one (1) new clinker reclaim loading hopper with a dust collector and one (1) existing clinker reclaim
hopper with a dust collector, a new Clinker Cooler to replace the existing one, and a new kiln feed
alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions:

The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;

The finish mill heater was calculated based on its maximum firing capacity and flow rates; and

The fugitive emissions were calculated based on the projected annual throughput of the New Finish
Mill, the rail loadout, and clinker production. [Last updated January 14, 2025]

6. Comment regarding PSD applicability analysis cont.:
Existing Emission Sources

For the existing sources, the projected actual emissions are the maximum annual rates in tons per
year projected to occur during the next five (5) to ten (10) years if the existing sources' design
capacities increase. Ash Grove Leamington projected the actual emissions for the next five (5) years
based on the new kiln system producing an annual average of 3,250 tons of clinker per day.

Baseline actual emissions (BAE) are defined at 40 CFR 52.21(b)(48)(ii) as:

". . . baseline actual emissions means the average rate, in tons per year, at which the emissions unit
actually emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the 10-year period immediately preceding either the date the owner or operator
begins actual construction of the project, or the date a complete permit application is received by the
Administrator."

Ash Grove has selected to use the years 2020 and 2021 for each pollutant as the representative
baseline years.

In its NOI, Ash Grove calculated the emission increase from the project as being divided into two
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 44

phases. Phased construction projects are discussed in two sections of the federal PSD regulations -
40 CFR 52.21(j)(4) and 40 CFr 52.21(r)(2). UDAQ is not processing this project as a phased
construction project, nor did Ash Grove request such a determination. Therefore, Ash Grove
provided a summary table outlining the final change in emissions from this project:

Projected Actual Increase Compared to PSD threshold (tons per year)
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2e
BAE 76.64 39.64 1,187 6.87 3,315 55.47 641,385
PAE 203.15 113.47 1,226 45.87 3,414 72.07 1,067,984

Change in Emissions 126.51 73.83 39.00 39.00 99.00 16.59 426,598

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes

If the emissions increase is greater than the PSD significance threshold for a particular pollutant, Ash
Grove has the option of conducting a PSD review or continuing through the rest of the steps to
determine if it can "net" out of a PSD review. If the project increase is less than the PSD significant
threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant.

The change in emissions from the project exceeds the significant emission threshold for three
pollutants: PM10, PM2.5 and CO2e. Ash Grove elected to attempt to net out of a PSD major
modification for the remainder of the criteria pollutants.

Netting

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant
Upgrade Project and ends on the date the upgrade begins operation. Only PM10, PM2.5, CO2e are in
excess of SERs and therefore considered in the netting analysis.

Ash Grove estimated that the commencement of construction will be in December 2024. Therefore,
the contemporaneous period for this project is December 2019 through a projected date the project
upgrade begins operation. [Last updated January 21, 2025]

7. Comment regarding PSD applicability analysis cont.:
Contemporaneous Decreases

Ash Grove replaced an existing kiln emergency drive engine with a USEPA Tier 4 diesel engine in
2022. Concurrently, Ash Grove requested an increase in the capacity of 1L Cement. Additionally,
Ash Grove submitted a minor modification NOI air permit application on June 12, 2023, which
proposes replacing the shipping generator during the contemporaneous period. The kiln emergency
drive engine and shipping generator are both higher EPA tier ratings therefore result in decreases for
PM10 and PM2.5. These changes were approved in AO DAQE-AN103030033-24 issued March 21,
2024.

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Page 45

Contemporaneous Increases

As stated above, the existing kiln emergency drive engine and shipping generator were permitted and
replaced in 2024. This resulted in an increase in emissions of CO2e.

The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout
in an effort to improve truck traffic at the loadout. The modification to add these dust collectors to
the loadout was included in DAQE-AN103030029-19. The baghouses are three (3) levels up in the
silos' enclosed space (approximately 40 feet). Both dust collectors vent directly into the interior of
the silo structure and are not vented into the atmosphere. Ash Grove requests to remove these
baghouses from its existing permitted emissions inventory. Therefore, these emissions have been
documented in the netting analysis as zero emissions.

Also included in DAQE-AN103030033-24 were two new natural gas-fired emergency generators
and increases in stockpiles, material handling and road emissions.

Could Have Been Accommodated Emissions

In calculating project emissions increase, USEPA allows the exclusion of existing
production/emissions rates that could have been accommodated during the baseline period. These
"could have been accommodated" emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as
follows:

". . . Shall exclude, in calculating any increase in emissions that results from the particular project,
that portion of the unit's emissions following the project that an existing unit could have
accommodated during the consecutive 24-month period used to establish the baseline actual
emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project,
including any increased utilization due to product demand growth;"

Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the
exclusion of existing production and emissions rates that could have been accommodated during the
baseline period, it has elected not to use this exclusion at this time. Therefore, calculation of the
"could have been" accommodated emissions have not been included in this application's
applicability analysis.

The increase from the project is added to the contemporaneous decreases and contemporaneous
increases. The resulting calculation is then compared to the PSD significance threshold to determine
if a significant net emissions increase has occurred. [Last updated January 14, 2025]

8. Comment regarding PSD applicability analysis cont.:
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2 e
Contemporaneous Inc. 1.61 0.45 0.41 0 0.27 0.07 51.74

Contemporaneous Dec. -1.54 -3.97 -0.48 -0.02 -0.27 -0.09 0

Change in Emissions 125.02 69.21 38.93 38.98 99.00 16.58 426,650

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 46

The results of the netting analysis conclude that both a significant emissions increase and a
significant net emissions increase in both particulates (PM10 and PM2.5) and CO2e will occur from
this project. Thus, the project must be reviewed as a PSD major modification. [Last updated January
14, 2025]

9. Comment regarding emission calculations:
This engineering review includes updated potential emission totals for both criteria and HAP
emissions. The potential-to-emit (PTE) values were calculated using updated values for clinker
produced and raw material inputs. BACT emission factors and limitations were used where
appropriate. Certain emission totals (NOx, SO2 and CO) were set based on avoiding a significant
increase in emissions. Specifically, the projected actual increase was set at just under the baseline
actual emissions + the significance level. As these emissions are monitored by CEM, UDAQ agrees
with this approach. Please see the netting analysis for further details on calculation of projected
actual increase. The NOx hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project.

CO2e emissions were calculated using the GHG emission factor calculated from 40 CFR Part 98
Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in Subpart A Table
A-1.

To calculate the PTE tons per year, the maximum hours (i.e., 8760) per year and the source's
emissions rates were multiplied with the throughputs. The potential throughputs have been updated
at UDAQ's request so that PAE is equal to PTE and represents the equipment's maximum design
potential.

Additional emission calculations based on source testing and monitoring, and EPA's compilation of
air emission factors AP-42. [Last updated January 14, 2025]

10. Comment regarding requirements for PSD review:
In addition to the permitting requirements of R307-401-5 through R307-401-8, there are additional
requirements under PSD that must be addressed:

1. Calculation of ambient air increments (40 CFR 52.12(c)), ambient air ceilings ((40 CFR 52.12(d)),
source impact analysis (40 CFR 52.12(k)), air quality models (40 CFR 52.12(l)) - these items are
addressed in the modeling memo DAQE-MN103030032-24.

2. Stack heights (40 CFR 52.12(h)) - Ash Grove's stack heights have been reviewed with respect to
good engineering practice and operate in a vertical unrestricted manner.

3. Control technology review (40 CFR 52.12(j)) - this is addressed in the BACT analysis section of
this review document.

4. Air quality analysis: preapplication analysis (40 CFR 52.12(m)) - this is covered in the PSD
applicability and netting analysis sections of this review document, ambient monitoring and
background data collection is also included in the modeling memo DAQE-MN103030032-24.

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 47

grain loading limit included in II.B.1.j.1 represents the required post-construction monitoring.
6. Source information (40 CFR 52.12(n)) - this is addressed under the requirements of R307-401-5
and was submitted by Ash Grove as part of the NOI package.

7. Additional impact analysis (40 CFR 52.12(o)) - these requirements cover soils, vegetation, growth
and visibility concerns. They are discussed in the modeling memo DAQE-MN103030032-24.

8. Federal land manager review (40 CFR 52.12(p)) - UDAQ provided initial notification to all
federal land managers upon receipt of the original NOI package. The draft permit and engineering
review will also be provided to the federal land managers 60-days prior to initiation of public
comment for their further review.

9. Public participation (40 CFR 52.12(q)) - this project will have a 30-day public comment period.

10. Source obligation (40 CFR 52.12(r)) - this requirement discusses source compliance with other
parts of the CAA, which is addressed within UDAQ's permitting rules in R307.
[Last updated January 14, 2025]

11. Comment regarding changes in equipment list:
The equipment list is being updated for clarity as well as adding new pieces of equipment. The
following changes are taking place:

The naming scheme is being updated to remove the numerical code from the unit designation. This
code generally referred to the associated control device and not to the emitting unit itself. This can
cause confusion especially when the same code was applied to multiple pieces of equipment.
Instead, the control devices (typically baghouse dust collectors) will be identified in the description
along with the appropriate numerical code.

Specific changes are as follows:

1. The kiln description has been updated

2. Clinker Cooler description has been updated to include a larger pulse jet baghouse.

3. The clinker storage silos, east and west clinker belts, clinker belt transfer and clinker tunnel have
been consolidated to avoid confusion

4. The north and south cement loadout exhausts now vent internally into the cement storage silos

5. The dust shuttle system has been consolidated into one line item, most identifiers removed from
subsystem descriptions as only two baghouses serve as exhaust points.

6. A new finish mill with heater has been added. Included in the description are the thirteen total
baghouses for dust control (1 main stack, 2 transfer points, 10 nuisance dust filters)

7. A new clinker reclaim hopper has been added. Both reclaim hoppers are controlled by baghouses
with updated identifiers

8. A new rail and truck loading/unloading system with two baghouses has been added.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 48

[Last updated December 20, 2024]

12. Comment regarding changes in conditions:
As a result of this project, several conditions will be added or changed. This includes one new
general condition (I.8). Changes to the equipment list (section II.A) will be addressed in a separate
reviewer comment:

I.8 - Adding this general condition to cover the requirements of R307-401-18 Eighteen Month
Review. The status of construction/installation of the new equipment shall be reviewed after
18-months.

II.B.1.a - Clinker production increases to 1,155,000 tpy
Use of limestone bypass material increases to 215,260 tpy

II.B.1.b - The NOx limit on the kiln decreases to 1,223 tpy, CO emissions from the kiln decrease to
3,395 tpy,
Adding a new CO2e limit of 0.92 tons CO2e/ton of clinker produced
PM limit on the clinker cooler decreased to 0.02 lb PM (filterable)/ton of clinker
Rule reference updated to include 40 CFR 60 Subpart F, and R307-401-8

II.B.1.e - Initial testing on the clinker cooler is now required within 180 days of startup of the unit.
Monitoring of CO2 from the kiln will be by CEM.
Formatting changes on paragraph designated ++, improve clarity, include reference to CO2
monitoring, define CPMS

II.B.1.e.4 - Update to address general PM monitoring and reference R307-401-8

II.B.1.e.14 - New condition to address new or reconstructed emission units monitoring requirements,
applicable to the clinker cooler and new finish mill.

II.B.1.h - Adding references to Subpart OOO units (limestone processing) with updated opacity
limits.
Adding 20% opacity limit on coal transfer and storage
Adding property boundary opacity limit of 20%
Updating rule reference to include Subpart OOO

II.B.1.j - New condition to address outlet grain loading limits on new baghouses, One identical limit,
15 total new baghouses.

II.B.1.j.1 - Monitoring on new baghouses as per II.B.1.e.4, added an allowance to test less frequently
than annually with three successful tests.

II.B.3.a - Updating formatting to add clarity and include reference to CO2 CEM

II.B.5 - New conditions on emergency engines, diesel fuel sulfur limits, hour of operation
restrictions, non resettable hour meter

[Last updated December 20, 2024]
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 49

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 51

TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 52

DAQE-MN103030032-24

M E M O R A N D U M

TO: John Jenks, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler
Dave Prey, Air Quality Modeler

DATE: December 12, 2024

SUBJECT: Modeling Analysis Review for the Ash Grove Cement Company – Leamington Plant,
located in Millard County, Utah
___________________________________________________________________________________
This is a Major Modification to a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Ash Grove Cement Company (Applicant) has submitted a Notice of Intent (NOI) air permit
application for a project referred to as the Leamington Upgrade Project (LUP). The proposed
upgrade project includes the construction and installation of new pollution control equipment, new
emission sources, and modifications to existing emission sources. Emission increases associated
with the LUP constitute a major modification to a Prevention of Significant Deterioration (PSD)
source subject to PSD permitting regulations. PSD regulations require the Applicant to include and
air quality impact analysis (AQIA) of the proposed projects impact on the EPA national ambient air
quality standards (NAAQS) and air quality related values (AQRV) as part of a complete NOI.

This report prepared by the New Source Review (NSR) modeling staff contains a review of the
Applicant’s Air Quality Impact Analysis (AQIA) including the methodology, data sources,
assumptions, and modeling results for comparison with State and Federal air quality standards. The
AQIA was reviewed and referenced in this report include the:
● Notice of Intent – Ash Grove Cement Leamington Plant PSD Notice of Intent Air Permit
Application, dated November 30, 2022.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

0 0
Jason Krebs

DP
DAQE-MN103030032-24
Page 2

II. APPLICABLE RULES AND ANALYSES

A Utah Air Quality Rules

The UDAQ has determined that the Applicant’s NOI is subject to the following rules for conducting an
AQIA:

R307-401 Permits: New and Modified Sources
R307-405 Permits: Major Sources Located in Attainment or Unclassified Area (PSD)
R307-406-2 Visibility – Source Review
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutant Impacts in Attainment Areas

B. Applicability

The proposed increases in emissions of PM10 and PM2.5 exceed the emission thresholds outlined in R307-
406-5 and R307-410-4. Therefore, an AQIA consistent with the requirements of R307-405-6, R307-406-
2, and R307-410-3 was submitted as part of the Applicant’s NOI. R307-410-3 establishes the U. S.
Environmental Protection Agency (US EPA) – Guideline on Air Quality Models as a formal basis for
defining the scope of the analysis, as well as the model’s construction. The results of the AQIA are
required to demonstrate the proposed project’s impact on state and federal air quality standards,
acceptable levels of impact, and action triggering thresholds referenced or listed in R307-401-6(2), R307-
401-6(3), R307-403-3(1), R307-403-5(1)(a), R307-405-4(1), R307-405-6. Annual emissions for criteria
pollutants requiring an AQIA are listed in Table 1.

Table 1: Ash Grove Leamington Proposed Net Emissions Increase

Criteria
Pollutants
Net Emission
Increase (TPY)
AQIA Trigger
Level (TPY) AQIA Required?
PM10 126.6 15 Yes
PM2.5 70.3 10 Yes

C. Required Analyses

R307-405 requires the Applicant to perform a pre-construction modeling analysis for all pollutants
emitted in a significant quantity. The purpose of the analysis is to determine if the extent of the source’s
impact is significant enough to warrant an on-site measurement of the ambient background concentration
levels. This data is included in the NAAQS analysis to represent the quality of the air prior to the
construction of the proposed project. The Applicant included a pre-construction modeling analysis for
PM10 and PM2.5 as part of the NOI. The pre-construction modeling analysis was also used to determine if
the proposed emissions would result in a significant impact to the environment, thereby triggering the
requirement for a cumulative analysis of the proposed project and other nearby existing sources.

R307-401-8 requires the Division to determine that the proposed project will comply with the NAAQS
prior to the issuance of an Approval Order (AO). R307-405(7) requires the Applicant to perform a
DAQE-MN103030032-24
Page 3
NAAQS analysis for all pollutants emitted in a significant quantity. The analysis is to include all
emissions at the proposed site under normal operating conditions using maximum anticipated short-term
release and annual release rates. Consistent with UDAQ policy, a cumulative analysis to include the
ambient background concentration and any contribution from other nearby sources is not required if the
proposed project’s impact does not exceed the PSD Class II Significant Impact Level (SIL).

R307-401-8 also requires the Division to determine that the proposed project will comply with PSD
increments prior to the issuance of an AO. Under R307-405(6), the Applicant is required to perform a
PSD Class I and II increment consumption analysis for all pollutants emitted in significant quantities.
The purpose of this analysis is to quantify any degradation in air quality since the major source baseline
date. The analysis is to include all increment consuming emissions at the proposed site under normal
operating conditions using maximum anticipated short-term and annual release rates. A cumulative
analysis to include contributions associated with growth and other increment consuming sources is not
required if the proposed project’s impact does not exceed the PSD Class I or II SIL.

R307-410-5 requires the Applicant to perform a HAPs analysis for any pollutant emitted above a
pollutant specific emission threshold value. This analysis is to include all emissions of the pollutants
resulting from the proposed modification under normal operating conditions using maximum anticipated
one-hour release rates. The Applicant did not trigger modeling for HAPs.

R307-406-2 requires the Applicant to perform a plume blight analysis. A plume blight analysis is required
to determine if plumes emanating from the proposed project would be visible inside any Class I area
within 50 kilometers of the source. The plume blight analysis is to include all emissions of NO2, SO4, and
PM10.

Under R307-405-16, an AQRV analysis is performed which evaluates regional haze and acid deposition
impacts at each of the Class I areas within 300 kilometers of the source. A regional haze analysis is
required to determine if the plumes would reduce the visual range of an observer inside the Class I area.
The regional haze analysis is to include all emissions of SO2, NOX and PM10. The deposition analysis
examines impacts from sulfur and nitrogen compounds at the Class I areas, and is based on all emissions
of SO2 and NOX. The Federal Land Managers use the Q/D approach to determine whether a PSD project
should provide detailed AQRV impact analyses, where: Q/D= [ H2SO4 + SO2 + NOx + PM10 emissions
(tpy)]/ distance (km). If Q/D is less than 10, no AQRV analysis is required.

R307-405 requires the Applicant to perform a soils and vegetation analysis. The analysis should quantify
the effects of pollutants on soils and vegetation near the highest impact location and in areas where
sensitive plant species may be impacted.

III. ON-SITE PRE-CONSTRUCTION MONITORING

A. Meteorological Data

Consistent with the US EPA - Meteorological Monitoring Guidance for Regulatory Modeling
Applications, one year of on-site data was collected using a 50-meter tower during the period October 1,
2021 through September 30, 2022. Parameters collected on-site included wind speed and direction,
temperature, delta-T, and solar radiation.

DAQE-MN103030032-24
Page 4

B. Ambient Pollutant Data

A preliminary analysis was conducted to determine the necessity for pre-construction ambient pollutant
monitoring. The results indicate that predicted concentrations of PM10 and PM2.5 exceed the monitoring
trigger level listing in the rule. A continuous PM10/PM2.5 monitor with filter based samplers was
installed near the northern edge of the Applicants property boundary, and collected particulate matter
from October 1, 2021 through September 30, 2022.

IV. MODEL SELECTION

The EPA-AERMOD dispersion modeling system is the preferred model specified in the US EPA –
Guideline on Air Quality Models to predict air pollutant concentrations in the near field (within 50
kilometers of the source). The US EPA - CALPUFF - Version 5.8 model is the preferred model to predict
concentrations in the far field (long range transport conditions beyond 50 kilometers from the source).

V. MODELING INPUTS AND ASSUMPTIONS

A. Technical Options

The regulatory default options were selected in AERMOD by the Applicant to quantify all concentrations.

B. Urban or Rural Area Designation

A review of the appropriate 7.5-minute quadrangles determined that the area should be classified as
“rural” for air modeling purposes.

C. Topography/Terrain

The Plant is at an elevation of 4,950 feet with nearby terrain features that have an effect on concentration
predictions.

a. Zone: 12
b. Location: UTM (NAD83): 397000 meters East, 4379850 meters North

D. Ambient Air

It was determined that the Plant boundary used in the AQIA meets the State’s definition of an ambient air
boundary.

E. Receptor and Terrain Elevations

The modeling domain has simple and complex terrain features in the near field. Therefore, receptor
points representing actual terrain elevations from the area were used in the analysis.

The far-field modeling domain consisted of a rectangular region covering all Class I areas within Utah,
and extending 50 kilometers beyond this area so that the model can account for re-circulation of the
plume.

DAQE-MN103030032-24
Page 5

F. Emission Rates and Release Parameters

The emission estimates and source parameters used in AERMOD for all proposed emission sources at the
site are presented in the NOI.

Speciated emission rates and source parameters used in the CALPUFF modeling are presented in Table 2.

Table 2: CALPUFF Emission Rates

Source
LCC Coordinates Modeled Emission Rates
Easting Northing SO2 SO4 NOX HNO3 NO3 SOA PMC SOIL EC
(m) (m) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr)
317.BF3 -1289410 -3738 52.81 5.03 307.58 0.00 0.00 5.03 2.60 2.90 0.11
419.BF1 -1289314 -3631 0.00 0.00 0.00 0.00 0.00 0.55 1.51 1.61 0.06
41B.BF2 -1289389 -3663 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.68 0.00
N1_FM2 -1289526 -3414 0.00 0.00 0.00 0.00 0.00 0.00 1.65 3.95 0.00
414.BF1N -1289407 -3683 0.00 0.00 0.00 0.00 0.00 0.00 0.10 0.25 0.00
2FM_HTR -1289528 -3415 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.08 0.00
514.BF1 -1289451 -3675 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.70 0.00
COMBO -1289424 -3668 0.00 0.00 0.00 0.00 0.00 0.00 1.37 5.72 0.00
FM2_CMB -1289454 -3439 0.00 0.00 0.00 0.00 0.00 0.00 0.50 1.21 0.00

Total Lb/hr 52.81 5.03 307.58 0.00 0.00 5.58 8.32 17.10 0.17
Hrs/Yr 8760 8760 8760 8760 8760 8760 8760 8760 8760
Ton/yr 231.3 22.0 1347.2 0.0 0.0 24.4 36.4 74.9 0.8

Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
317.BF3 POINT 4902.8 41.2 135.0 488 10.10 3.35
419.BF1 POINT 4891.2 18.3 60.0 388 6.36 2.90
41B.BF2 POINT 4895.2 68.6 224.9 294 17.83 0.74
N1_FM2 POINT 4832.0 49.7 163.0 363 40.08 1.40
414.BF1N POINT 4896.1 76.8 251.9 353 9.91 0.70
2FM_HTR POINT 4832.0 49.7 163.0 363 40.08 1.40
514.BF1 POINT 4889.5 39.6 130.0 294 11.86 0.91
COMBO POINT 4904.2 13.3 43.7 276 9.76 0.32
DAQE-MN103030032-24
Page 6
FM2_CMB POINT 4832.0 30.6 100.3 294 11.40 0.37

G. Building Downwash

The Applicant used the US EPA Building Profile Input Program (BPIP) to determine Good Engineering
Practice (GEP) stack heights and cross-sectional building dimensions for input into the model.

H. Ambient Background Concentrations

Millard County is in attainment for all criteria pollutants. The NAAQS analyses for PM2.5 and PM10 used
monitoring data collected on site during the pre-construction monitoring analysis. The background values
used in the NAAQS analysis are presented in Table 3.

Table 3: Background Concentrations

Pollutant Averaging
Period
Background
Concentration
(μg/m3)
PM10 24-hour 65.4
PM2.5 24-hour 10.2
Annual 4.2

I. Meteorological Data Processing

For the AERMOD model, on-site horizontal and vertical wind speed, direction, solar radiation and,
temperature data was combined with National Weather Service (NWS) upper air data collected at the Salt
Lake City International Airport (SLCIA) for the same period using the US EPA AERMET processing
system.

Meteorological data used for the CALPUFF modeling analysis consisted of 3 years (2018-2020) of data
developed by the Forest Service. The grid was 708 km (east-west) by 492 km (north-south) with a
resolution of 12 kilometers.

VI. RESULTS AND CONCLUSIONS

The Applicant performed a series of analyses to estimate the impact from the proposed project. Modeling
results and conclusions from the review of the analyses are outlined in detail below.

A. Pre-Construction Monitoring and Significant Impact Modeling

The Applicant performed a preliminary criteria pollutant analysis of the proposed modification. This
analysis indicated that increases in concentration levels of PM2.5 and PM10 were greater than the Class II
SIL, and therefore, a cumulative analysis for these pollutants was required.

DAQE-MN103030032-24
Page 7

B. NAAQS Analysis

The Applicant performed a modeling analysis to determine if the combined impact from the proposed
source, other industrial sources operating in the area, and ambient background would comply with the
NAAQS. The NAAQS analysis was reviewed by the Division and determined to be consistent with the
requirements of R307-410-3. Table 4 provides a comparison of the Applicant’s predicted air quality
concentrations and the NAAQS.

Table 4: Model Predicted NAAQS Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-hour 28.3 5 65.4 0 93.7 150 62.5%
PM2.5 24-hour 9.6 1.2 10.2 0 19.8 35 56.6%
Annual 4.4 0.3 4.2 0 8.6 9 95.6%
* Note: Only included other sources and background if source impact was above Class II SIL

C. PSD Class II Increments

The Applicant performed an analysis to determine if the impact from the proposed source would comply
with PSD Class II increments. The analysis was reviewed by the Division and determined to be
consistent with the requirements of R307-410-3. Table 5 provides a comparison of the predicted
concentrations and the PSD Class II increment.

Table 5: Model Predicted PSD Class II Increment Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Nearby
Sources*
Total Increment Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
PM10 Annual 8.1 1 0 8.1 25 32.4%
24-hour 28.3 5 0 28.3 30 94.3%
PM2.5 24-hour 6.1 1.2 0 6.1 9 67.8%
Annual 2.4 0.3 0 2.4 4 60.0%

D. Hazardous Air Pollutants

DAQE-MN103030032-24
Page 8
The Applicant performed an analysis to determine if HAP modeling is required. The analysis was
reviewed by the Division and determined to be consistent with the requirements of R307-410-3. The
analysis indicated that HAP modeling was not triggered by this modification, and therefore no HAP
modeling was performed.

E. PSD Class I Increment Consumption Analysis

The Applicant performed a CALPUFF analysis to determine if the impact from the proposed source along
with other increment consuming sources would comply with federal PSD Class I increments. The
analysis was reviewed by the Division and determined to be consistent with the requirements of R307-
410-3. The results for all Class I areas within 300 kilometers are provided in Table 6.

Table 6: Model Predicted PSD Class I Increment Concentrations

Air Period Prediction
Class I
Significant
Impact
Level
Other
Sources* Total Increment Percent
Pollutant (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
Capitol Reef
NO2 Annual 0.0018 0.1 2.5
SO2
3-Hour 0.0494 1 25
24-
Hour 0.0150 0.2 5
Annual 0.0008 0.1 2
PM2.5
24-
Hour 0.0430 0.27 2
Annual 0.0021 0.05 1
PM10
24-
Hour 0.0444 0.3 8
Annual 0.0021 0.2 4
Arches
NO2 Annual 0.0008 0.1 2.5
SO2
3-Hour 0.0408 1 25
24-
Hour 0.0102 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0522 0.27 2
Annual 0.0018 0.05 1
DAQE-MN103030032-24
Page 9
PM10
24-
Hour 0.0531 0.3 8
Annual 0.0019 0.2 4
Canyonlands
NO2 Annual 0.0010 0.1 2.5
SO2
3-Hour 0.0354 1 25
24-
Hour 0.0100 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0577 0.27 2
Annual 0.0019 0.05 1
PM10
24-
Hour 0.0591 0.3 8
Annual 0.0020 0.2 4
Bryce
NO2 Annual 0.0006 0.1 2.5
SO2
3-Hour 0.0369 1 25
24-
Hour 0.0082 0.2 5
Annual 0.0003 0.1 2
PM2.5
24-
Hour 0.0189 0.27 2
Annual 0.0010 0.05 1
PM10
24-
Hour 0.0194 0.3 8
Annual 0.0010 0.2 4
Zion
NO2 Annual 0.0011 0.1 2.5
SO2
3-Hour 0.0293 1 25
24-
Hour 0.0105 0.2 5
Annual 0.0005 0.1 2
PM2.5
24-
Hour 0.0266 0.27 2
Annual 0.0011 0.05 1
PM10 24-
Hour 0.0271 0.3 8
DAQE-MN103030032-24
Page 10
Annual 0.0012 0.2 4
* Note: Only included other increment consuming sources if source impact was above Class I SIL

Since the proposed project’s model predicted impacts at the Class I areas were less than the PSD Class I
significance levels, a cumulative analysis was not warranted.

DAQE-MN103030032-24
Page 11
F. Visibility – Plume Blight
Since the Class I areas are greater than 50 kilometers from the source, a plume blight analysis using
VISCREEN was not required.

G. Visibility – Regional Haze

The results of the Q/D analysis for the emissions increase was less than 10 but the FLMs wanted the
entire source included in the Q term. The results of including the total emissions resulted in a Q/D >10,
so an AQRV analysis was performed for visibility and acid deposition. The results shown in Table 7
indicate that the impacts are below the 0.5 Deciview (DV) threshold established by the National Park
Service, indicating that no further analysis is required.

Table 7: CALPUFF Visibility Results

Class I Area Year Maximum
Delta DV
98th
Percentile
change in
DV
#
Days
#
Days Threshold
(DV)
Below
Threshold
> 1 > 0.5
2018 0.248 0.06 0 0 0.5 Yes
Arches 2019 0.291 0.054 0 0 0.5 Yes
2020 0.216 0.106 0 0 0.5 Yes
2018 0.223 0.081 0 0 0.5 Yes
Canyonlands 2019 0.312 0.068 0 0 0.5 Yes
2020 0.186 0.085 0 0 0.5 Yes
2018 0.059 0.03 0 0 0.5 Yes
Bryce 2019 0.081 0.045 0 0 0.5 Yes
2020 0.071 0.03 0 0 0.5 Yes
2018 0.183 0.074 0 0 0.5 Yes
Capital Reef 2019 0.196 0.092 0 0 0.5 Yes
2020 0.126 0.078 0 0 0.5 Yes
2018 0.069 0.04 0 0 0.5 Yes
Zion 2019 0.123 0.039 0 0 0.5 Yes
2020 0.102 0.057 0 0 0.5 Yes

DAQE-MN103030032-24
Page 12

H. Acid Deposition

The Applicant performed a deposition analysis on impacts within the Class I areas. Results of the
analysis indicate that the impacts are below the deposition threshold (DAT) established by the National
Park Service, indicating that no further analysis is required

Table 8: CALPUFF Deposition Results for Highest Year

Class I Area
Total
Nitrate
Deposition
Total
Sulfate
Deposition
Deposition
Analysis
Threshold
(kg/ha/yr) (kg/ha/yr) (kg/ha/yr)
Canyonlands 0.0006 0.0003
0.005
Zion 0.0004 0.0002
Arches 0.0006 0.0003
Bryce 0.0006 0.0002
Capitol Reef 0.0011 0.0005

I. Soils and Vegetation Analysis

The Applicant performed an analysis to determine the extent of impacts from the proposed source on soil
and vegetation. Results of the analysis are presented in a supplemental document titled “Soil and
Vegetation Impact Analysis for the Leamington, UT Facility, June 29, 2023”. The analysis indicated that
predicted concentrations compared against the secondary NAAQS at several sensitive receptors would not
result in an adverse impact on soils and vegetation in the vicinity of the proposed project.

DP/JK:jg

DAQE-IN103030032-25

January 22, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Mr. Nelson:

Re: Intent to Approve: Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — ) A A v A ? A D @ A w D D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — ) A A v A ? A D @ A w D D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ash Grove Cement Company Ash Grove Cement Company - Leamington Cement Plant

Mailing Address Physical Address
P.O. Box 38069 Highway 132
Leamington, UT 84638 Leamington, UT 84638

Source Contact UTM Coordinates
Name: Cody Watkins 397000 m Easting
Phone: [phone] 4380100 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3241 (Cement, Hydraulic)

SOURCE INFORMATION
General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried on site),
are correctly proportioned, ground, and mixed and then fed into a rotating kiln. The kiln alters the
materials and recombines them into small stones called cement clinker. The clinker is cooled and ground
with gypsum and additional limestone into a fine powdered cement. The final product is stored on site for
later shipping. The major sources of air emissions are from the combustion of fuels for the kiln operation,
from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source of
emissions of PM2.5, PM10, NOx, CO, HAPs, and GHG. It is a minor source of SO2 emissions.
NSR Classification
Major PSD Modification

Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
DAQE-IN103030032-25
Page 4

Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

These changes result in increases in actual emissions but decreases in most potential emissions. There will
be an increase in the potential emissions of VOCs and greenhouse gases.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
DAQE-IN103030032-25
Page 5

Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
DAQE-IN103030032-25
Page 6

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, 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. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO 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. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
DAQE-IN103030032-25
Page 7

II.A.4 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)
II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area, and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, stacker systems. II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit-specific requirements.
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total air flow controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter
area; 9,865 acfm total air flow, controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are
controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each
is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6). II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The
following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for
NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.
II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low-pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

DAQE-IN103030032-25
Page 8

II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow through stack
E34.
II.A.18 Kiln Feed Alleviator A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the central material silo between the blending silos and the preheater. Raw feed is removed from the system near the top of the preheater tower.
II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The
coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter area;
1,700 acfm total air flow.
II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker
storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1): 1,800 acfm that discharges into the clinker tunnel.
II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
DAQE-IN103030032-25
Page 9

II.A.27 Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during loading.
II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel, all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during loading. 512.BF3 (1,000 acfm) is located on top of the silo. II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement products. Dust generated
during milling is captured by a BHA pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).

II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates from stack G55 (finish mill stack).
II.A.32 Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4).
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1 thru 3).

II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total air flow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations.
II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This
baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

DAQE-IN103030032-25
Page 10

II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.
II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023)
II.A.40 Dust Shuttle System A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides, surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the
fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

II.A.41 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons) Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
DAQE-IN103030032-25
Page 11

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)
THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)
CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)
PM: 0.02 lbs filterable PM per ton of clinker.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR 60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to approve alternative control measures, the permittee shall keep a copy of the submitted petition and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source
of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2).
[40 CFR 63 Subpart LLL]

DAQE-IN103030032-25
Page 12

II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must 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 PM CPMS is not out of control. The owner/operator must 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 on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
DAQE-IN103030032-25
Page 13

II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

II.B.1.e.3 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-165]
II.B.1.e.4 PM 40 CFR 60, Appendix A, Method 5, or 5I, or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three runs, with each
run at least 120 minutes in duration and each run collecting a sample of 60 dry standard cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 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. [R307-165]
DAQE-IN103030032-25
Page 14

II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
DAQE-IN103030032-25
Page 15

II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
DAQE-IN103030032-25
Page 16

II.B.1.i 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 must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator 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 owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator 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 owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
DAQE-IN103030032-25
Page 17

II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: Instances of water and/or chemical application to unpaved areas shall be recorded and maintained by the owner/operator. The ambient temperature shall be recorded any time water should be applied but cannot due to freezing conditions. [R307-401-8]
II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

The sprays shall operate whenever dry conditions warrant meeting the required opacity
limitations or as determined necessary by the Director. Water sprays shall not be required during
periods of freezing temperatures.

[R307-401-8]

DAQE-IN103030032-25
Page 18

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

C. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the kiln/raw mill stack

F. The owner/operator shall record the output of the system: including the quantity of NOx, CO, O2, THC, Hg, HCl, and CO2 emissions at the kiln stack

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an
affected source 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.

[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]
II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments, the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the results of the performance test demonstrating compliance with the filterable PM limit and using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust the SSOL developed in accordance with the results of the most recent PM performance test demonstrating compliance with the PM emission limit. The owner/operator shall use the PM CPMS to demonstrate continuous compliance with the SSOL in accordance with the requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

DAQE-IN103030032-25
Page 19

II.B.4 Fuel Limitations: II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke F. Fuel Oil
G. Used Oil Fuel

H. Synthetic Fuel
I. Wood
J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 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. [R307-401-8]
II.B.4.b.2 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 owner/operator 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 in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

DAQE-IN103030032-25
Page 20

II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight
A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation
C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit-no less than 1500oF for more than five minutes in any 60-minute period B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
DAQE-IN103030032-25
Page 21

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the Director. The calibration procedure and frequency shall be according to manufacturer's specifications. Use of factory-calibrated thermocouples for temperature measurement is approved. However, any other method of temperature measurement must be approved by the Director prior to use. The monitoring equipment for both temperature and oxygen content shall be located such that an inspector can at any time safely read the output. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall only operate the emergency engines for testing and maintenance purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency operation. [R307-401-8]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.5.b.2 To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From Source Submitted NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-IN103030032-25
Page 22

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-GN103030032G-25
January 22, 2025
Via Certified Mail 70190700000208349758
Pleasant McNeel
Regional Air Program Manager
USDA Forest Service Intermountain Region
324 25th Street
Ogden, UT 84401
[e-mail]
Dear Ms. McNeel:
RE: Notice of Publication for Ash Grove Cement Company- Leamington Cement Plant – CDS A;
MACT (Part 63), Compliance Assurance Monitoring (CAM), Title V (Part 70) Major Source,
Major Criteria Source, Major HAP Source, Attainment Area, NSPS (Part 60),
Project Number: N103030032
On January 22, 2025, the Director has completed his review of a Prevention of Significant Deterioration
project submitted by Ash Grove Cement Company. Attached to this letter are the draft Approval Order
document (Intent to Approve) and the full engineering review. Following a 60-day review by the Federal
Land Managers, this project will be submitted for a 30-day public comment period. Written comments
received by the Division at this same address during these comment periods will be considered in making
the final decision on the approval/disapproval of the proposed Approval Order. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director at the Division in writing, a hearing
will be held in accordance with R307-401-7, UAC.
If you have any questions, please contact John Jenks, who may be reached at [phone].
Sincerely,
Jon L. Black, Manager
New Source Review Division
Enclosures: Engineering Review
Modeling Memo
Intent to Approve
JLB:JJ:jg
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
Jon Black (Jan 22, 2025 15:44 MST)
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
RN103030032
January 21, 2025
Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]
Dear Josh Nelson,
Re: Engineer Review:
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032
Please review and sign this letter and attached Engineer Review (ER) within 10 business days.
For this document to be considered as the application for a Title V administrative amendment, a
Title V Responsible Official must sign the next page.
Please contact John Jenks at [phone] if you have any questions or concerns about the ER.
If you accept the contents of this ER, please email this signed cover letter to John Jenks at
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 1

[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the
DAQ will consider any comments received and will issue the Approval Order.

If you do not respond to this letter within 10 business days, the project will move forward
without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue
an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 2

OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible
Official, as defined in R307-415-3, must sign the statement below. THIS IS STRICTLY
OPTIONAL.

If you do not want the Engineer Review to be considered as an application to administratively
amend your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will
require submittal of a separate Operating Permit Application to revise the Title V permit in
accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document:
Title V Operating Permit Application Due Dates clarifies the required due dates for Title V
operating permit applications and can be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality

“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate
and complete and request that this Approval Order be considered as an application
to administratively amend the Operating Permit.”

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 3

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N103030032
Owner Name Ash Grove Cement Company
Mailing Address P.O. Box 38069
Leamington, UT, 84638

Source Name Ash Grove Cement Company- Leamington Cement
Plant
Source Location Hwy 132
Leamington, UT 84638

UTM Projection 397000 m Easting, 4380100 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3241 (Cement, Hydraulic)

Source Contact Cody Watkins
Phone Number [phone]
Email [e-mail]

Billing Contact Cody Watkins
Phone Number 385.225.0615
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 30, 2022
Date of Accepted Application November 28, 2024

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 4

SOURCE DESCRIPTION

General Description
Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried
on site), are correctly proportioned, ground and mixed, and then fed into a rotating kiln. The kiln
alters the materials and recombines them into small stones called cement clinker. The clinker is
cooled and ground with gypsum and additional limestone into a fine powdered cement. The final
product is stored on site for later shipping. The major sources of air emissions are from the
combustion of fuels for the kiln operation, from the kiln, and from the clinker cooling process.
The Leamington cement plant is a major source for emissions of PM2.5, PM10, NOx, CO, HAPs
and GHG. It is a minor source of SO2 emissions.

NSR Classification:
Major PSD Modification

Source Classification
Located in Attainment Area,
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Proposal
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower, various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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These changes result in increases in actual emissions, but decreases in most potential emissions.
There will be an increase in the potential emissions of VOC and greenhouse gases.

EMISSION IMPACT ANALYSIS
The complete modeling review is located in DAQE-MN103030032-24. [Last updated January 14, 2025]

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SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
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Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

Note: Change in emissions indicates the difference between previous AO and proposed modification.

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Review of BACT for New/Modified Emission Units

1. BACT review regarding the Leamington Plant Upgrade Project
Any major stationary source or major modification subject to PSD review must undergo an
analysis to ensure the use of BACT. The requirement to conduct a BACT analysis is set forth in 40
CFR 52.21. Similarly, Utah requires the installation of BACT for all sources of air pollution under
R307-401-5(2)(d)), BACT is defined in 40 CFR 52.21 (and R307-401-2) as:

". . . best available control technology means an emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for each pollutant subject to regulation under
Act which would be emitted from any proposed major stationary source or major modification
which the Administrator, on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such source or modification
through application of production processes or available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion techniques for control of such
pollutant . . ."

Therefore, a BACT analysis is required for each new or physically modified emission unit for each
pollutant that exceeds an applicable PSD significant emission rate (SER). Since the PM10 and PM2.5
emissions from the proposed project exceed the applicable PSD SER, a BACT analysis is required
to assess the required levels of control for these pollutants. Because the CO2e emissions are subject
to regulation as a result of the proposed project resulting in an increase of 75,000 tons or more per
year CO2e, a BACT analysis is also required for that pollutant. Note that HAPs listed under CAA
Section 112(b)(1) are excluded from NSR (New Source Review) or PSD (i.e., BACT) review.

In a memorandum dated December 1, 1987, the United States Environmental Protection Agency
(EPA) stated its preference for a "top-down" BACT analysis. After determining if any New Source
Performance Standard (NSPS) is applicable, the first step in this approach is to determine, for the
emission unit in question, the most stringent control available for a similar or identical source or
source category. If it can be shown that this level of control is technically, environmentally, or
economically infeasible for the unit in question, then the next most stringent level of control is
determined and similarly evaluated. This process continues until the BACT level under
consideration cannot be eliminated by any substantial or unique technical, environmental, or
economic objections.

Presented below are the five basic steps of a top-down BACT review as identified by the EPA.
Step 1 - Identify All Control Technologies
Step 2 - Eliminate Technically Infeasible Options
Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Step 4 - Evaluate Most Effective Controls and Document Results
Step 5 - Select BACT

Ash Grove has elected to follow this methodology and based the BACT review on each individual
pollutant. The complete BACT analysis follows. [Last updated January 14, 2025]

2. BACT review regarding PM10 and PM2.5 Sources
PM10 and PM2.5 Modified Equipment
The existing kiln precalciner, preheater, and alleviator system are proposed to be modified, and the
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kiln's ID fan and clinker cooler fans are proposed to be replaced, which will result in increased
airflow. Additionally, the clinker cooler baghouse will be converted from a plenum pulse to a pulse
jet baghouse. These modifications are projected to result in a net increase of potential PM10 and
PM2.5 emissions.

Kiln Upgrade BACT
The rotary cement kiln is the core of the cement manufacturing process, transforming the blended
raw materials or "rawmix" into clinker through pyro processing. Emissions from the kiln occur
from fuel combustion plus the physical and chemical reactions needed to transform the rawmix
into clinker. This project involves process and energy efficiency improvements and an increase in
kiln production, resulting in an increase of PM10 and PM2.5 emissions. This section specifically
addresses filterable PM10 and PM2.5. The condensable fraction is represented with the other
precursors as applicable to proposed emission increases.

The Leamington Plant's Kiln is subject to NSPS, Subpart F for particulate. Therefore, a BACT
analysis addresses applicability of the proposed changes to the kiln system to NSPS and review of
the RBLC. A summary of the resources reviewed include the following:

NSPS Subpart F - Standards of Performance for Portland Cement Plants establishes emission
standards for cement kiln operations. Specifically, kilns modified after June 16, 2008, are limited to
0.07 lbs PM/ton of clinker produced.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028) and
Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from kiln operations are as follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM emissions are most effectively controlled using a collection system with enclosures routed to
baghouses providing up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Ash Grove
has selected technology with the highest control efficiency, so there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.
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Step 5 - Select BACT
Ash Grove proposes that BACT for PM10 and PM2.5 emissions from the kiln consist of a collection
system routed to a baghouse or fabric filter that complies with NSPS Subpart F's emission standard
for a modified source. BACT for the Leamington Plant's kiln are 10% opacity and 0.07 lb of
PM/ton (NSPS Subpart F emission standard) of clinker.
[Last updated January 14, 2025]

3. BACT review regarding PM10 and PM2.5 sources cont.
Clinker Cooler Upgrade BACT
The clinker cooler reduces the temperature of the clinker exiting the kiln. It is necessary to reduce
clinker temperature before it enters the finish mill to maintain product quality and reduce wear and
tear on equipment. The clinker cooler is equipped with a heat exchanger that captures waste heat
and transfers it to the kiln preheater for process and energy efficiency. Emissions from the clinker
cooler are vented to a baghouse. The Leamington Plant's clinker cooler is also subject to NSPS
Subpart F for particulate. Ash Grove's proposed changes to the clinker cooler meet the definition of
a reconstruction under NSPS. Therefore, in order to meet the requirements of NSPS Subpart F, Ash
Grove will be required to meet a limit of 0.02 lb of PM/ton of clinker.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from clinker cooler operations are as
follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM10 and PM2.5 emissions are most effectively controlled using a collection system with enclosures
routed to a baghouse, which can achieve up to 99.9% control efficiency. Other technologies such as
wet scrubbers, cyclones and ESPs are feasible, but provide lower control efficiencies than a
baghouse. Because the most efficient control technology is proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for PM10 and PM2.5 emissions from the clinker cooler is a collection system routed to a
baghouse or fabric filter. In order to meet the requirements of NSPS Subpart F, Ash Grove will
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meet a reduced emission limit of 0.02 lb of PM/ton of clinker. A 10% opacity limit is also
applicable. [Last updated January 14, 2025]

4. BACT review regarding PM10 and PM2.5 sources cont.
New Finish Mill BACT
The proposed Plant upgrade include adding a second finish mill. The new finish mill will use an
energy efficient vertical roller mill assisted with a grinding aid. A total of five (5) point sources are
planned for the finish mill. In accordance with NSPS Subpart F, emissions from finish mill are
restricted to 10% opacity. Ash Grove has reviewed the following sources to identify available
control technologies.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);12 and

Region 8 General Permit for Concrete Batch Plants.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 emissions from plant material handling operations are as
follows:
Baghouse / Fabric Filter;
Best Management & Operational Practices;
Cyclone;
ESP;
Enclosure;
Water Application (Watering); and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
With the exception of water application, all options are technically feasible. Water application is
eliminated as clinker exiting the kiln along with additives in the finish mill must remain dry to
maintain product quality. Therefore, it is technically infeasible to water material in the finish mill.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Enclosure 50-90%
5. Cyclone 20-70%
6. Best Management & Operational Practices varies

Step 4 - Evaluate Most Effective Controls and Document Results
Baghouses provide the highest emission control efficiency, controlling up to 99.9% of PM
emissions from finish mill equipment. After baghouses, using a wet scrubber or ESP provides
similar PM control. Notably, baghouses, scrubbers, and ESPs require enclosures to aid in capturing
emissions and ducting to the control. Therefore, optimal PM emission control can be achieved
through implementing both baghouses and enclosures where feasible. Plant material sizing and
handling is currently done using a series of buildings and enclosures routed to baghouse controls.
Various silos storing material inputs are also equipped with fabric filters. As the highest ranked
technology is applied, there are no adverse energy, environmental or cost impacts to consider with
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the use of these control technologies. Thus, no further analysis is required under EPA's top-down
BACT approach.

Step 5 - Select BACT
BACT for finish mill PM10 emissions is compliance with NSPS Subpart F, Standards of
Performance for Portland Cement Manufacturing where applicable. Ash Grove will achieve BACT
for PM10 emissions from finish mill equipment through the implementation of enclosures,
baghouses, and best management practices. All baghouses at the finish mill will have a 10%
opacity limitation and a grain loading of 0.005 grains/dscf. [Last updated January 14, 2025]

5. BACT review regarding PM10 and PM2.5 sources cont.
Material Transfer, Sizing, and Storage BACT
The Leamington Plant has sources of fugitive emissions through raw material transfer. Materials
transferred include limestone and other raw materials, coal, clinker, and cement. These materials
are transferred by conveyor belt, screw conveyor, elevator, pneumatic conveyance or chutes via
gravity. At the Leamington Plant the fugitive emissions are enclosed at their transfer points and
routed to baghouses.

The following emission units are included in this category:
Limestone Crushing, Sizing, and Material Transfer;
Raw Material Transfer;
Coal Sizing and Transfer;
Existing Finish Mill;
Clinker Storage and Transfer;
Cement Storage and Truck and Rail Cement Loadout;
New Rail Loading and Loadout; and
New Clinker Reclaim Hopper Baghouse.

Generally, controls for these units have not changed or they are similar to current existing controls.
A full BACT analysis of each unit is included in Ash Grove's NOI and additional submitted
information. However, given that most controls remain unaltered, only the results of Step 5 -
Select BACT will be included here.

Limestone Crushing, Sizing, and Material Transfer
Subject to NSPS Subpart OOO opacity limits for existing sources.
Existing baghouses. No change from bag manufacturer's specifications.

Raw Material Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Coal Storage and Transfer
Existing Equipment. No change from bag manufacturer's specifications
20% Opacity

Clinker Storage and Transfer
Subject to NSPS Subpart F opacity limits:
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10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Existing Finish Mill Grinding, Storage and Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Cement Storage and Truck and Rail Cement Loadout, New Rail Loadout
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

New Rail Loadout, controlled by baghouse
Emissions Limit - 0.005 gr/dscfm

New Clinker Reclaim Hopper, controlled by baghouse
Subject to NSPS Subpart F opacity limits:
10% opacity
Emissions Limit - 0.005 gr/dscfm [Last updated January 14, 2025]

6. BACT review regarding PM10 and PM2.5 sources cont.
PM10 and PM2.5 Fugitive Emissions
The following fugitive emissions sources will increase emissions of PM10 and PM2.5 as a result of
the Leamington Plant's proposed throughput increase. The sources addressed in the following
BACT analyses are primarily in the quarry, but also include emissions from roads and dumping of
raw materials within the plant boundary.

The sources evaluated are listed below:
Roads;
Loading and Unloading;
Stockpiles;
Bulldozing and Grading;
Disturbed Areas; and
Drilling and Blasting.

Ash Grove currently controls emissions from these processes, and generally, controls for these
units have not changed. A full BACT analysis of each unit is included in Ash Grove's NOI and
additional submitted information. However, given that most controls remain unaltered, only the
results of Step 5 - Select BACT will be included here.

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
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Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

Stockpiles BACT
BACT shall consist of restricting fugitive emissions to the opacity standard of 20% opacity at the
property boundary. BACT for stockpiles will be achieved through applying good management
practices through its fugitive dust plan as appropriate.

Bulldozing and Grading BACT
BACT shall consist of restricting fugitive emissions from bulldozing and grading activities to no
more than 20% opacity, and that emissions are controlled with periodic watering of the disturbed
surface. The frequency of water application will depend on ambient weather conditions and
inherent moisture content of the material being moved.

Disturbed Areas BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. BACT for
disturbed areas will be achieved through best management practices, watering, scarification, and
revegetation.

Drilling and Blasting BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. This is achievable
through best management practices, shrouds, watering, and dust collection. [Last updated January
14, 2025]

7. BACT review regarding kiln system NOx emissions
Kiln System (Kiln, Raw Mill, and Coal Mill) - NOx BACT
Although there are physical changes to the kiln system, these changes are primarily related to
particulate emissions. NOx emissions are generated from the combustion of fuel - and no changes
in NOx emissions are expected from the kiln (hourly capacity to emit). The kiln NOx emissions will
remain the same as a result of upgrades to the SNCR system. The replacement of the various
components of the kiln system and portions of the preheater tower, along with new injection points,
will ensure that increased mixing of ammonia is achieved to enhance the SNCR system's ability to
reduce NOx and minimize ammonia slip. This will allow the Leamington Plant to maintain the NOx
hourly capacity to emit unchanged from current levels Leamington Plant Upgrade Project. At
present Ash Grove has no restriction on the amount of fuel combusted, only a limit on total NOx
generated, and with this project the allowed NOx PTE is decreasing from 1,352 tpy to 1,226 tpy.

Additional ammonia will be used in the existing SNCR system. While the SNCR system has
adequate capacity to accommodate the additional ammonia demand resulting from the system
upgrades, more ammonia ports are proposed to be added with the kiln system's proposed changes
of the equipment. The changes proposed to the kiln system will increase residence time and
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temperature which will improve the SNCR system's effectiveness to control NOx emissions and
minimize ammonia slip emissions to the atmosphere. No additional review of NOx BACT for the
kiln system is required under this proposal. [Last updated January 14, 2025]

8. BACT review regarding new finish mill heater emissions
Finish Mill Heater
The proposed finish mill will include a process heater to maintain a minimum temperature during
milling. The proposed heater will run on natural gas and is rated at 10 MMBtu/hr. Startup and
shutdown emissions from the heater are anticipated to be no greater than normal operation as the
process is simply a matter of bringing the heater to operating temperature. Emissions evaluated in
the BACT analysis for the finish mill heater include NOx, SO2, CO, and VOCs, PM10, and PM2.5.
Pollutants with identical control technologies are grouped together in the analysis.

NOx - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for NOx from units of this size range are as follows:
Ultra-Low-NOx Burners (ULNB);
Low NOx Burners;
Selective Catalytic Reduction (SCR);
Selective Noncatalytic Reduction (SNCR);
Good Combustion Practices; and
Use of Natural Gas.

Step 2 - Eliminate Technically Infeasible Options
Low exit temperatures render the use of SCR and SNCR ineffective. Particulate entrainment within
the finish mill could potentially foul (plug) the nozzles of ULNB. Low-NOx burners, the use of
natural gas as fuel and good combustion practices are all considered technically feasible.

Step 3 and Step 4 - Rank Remaining Control Technologies by Control Effectiveness and Evaluate
Most Effective Controls and Document Results
Since the three feasible control technologies are proposed for the finish mill heater, no detailed
economic, energy, and environmental impact evaluations were conducted. No ranking of control
effectiveness is required as all three controls are proposed.

Step 5 - Select BACT
BACT for NOx is the use of natural gas as fuel, good combustion practices and the use of Low NOx
burners.

CO, SO2, and VOC - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for CO, SO2, and VOC from units of this size are as follows:
Good Combustion Practices
Use of Natural Gas

The finish mill heater combusts natural gas. Related natural gas combustion emissions are
anticipated to be minimal.

Step 2 - Eliminate Technically Infeasible Options
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Both control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Both technologies offer intrinsic emission reductions from combustion. Since the technologies do
not compete, both technologies can and will be used simultaneously.

Step 4 - Evaluate Most Effective Controls and Document Results
Because both control technologies identified in Step 1 are proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for CO, SO2, and VOC are good combustion practices and the use of natural gas.

PM10 and PM2.5 BACT for the finish mill has been addressed in the PM10/PM2.5 sources section.
[Last updated January 14, 2025]

9. BACT review regarding SO2, VOC, and Lead Sources
The following BACT analysis is grouped by pollutants that will experience an increase in potential
emissions and the associated technically feasible control technologies. As such, the BACT analysis
is separated into SO2, VOC, and lead respectively with organic HAPs addressed with VOCs.

SO2 - Cement Kiln BACT
NSPS Subpart F - Standards of Performance for Portland Cement Plants, establishes emission
standards for cement kiln operations. Specifically, kilns constructed or reconstructed after June 16,
2008, are limited to 0.4 lbs SO2/ton clinker on a 30-day rolling average respectively. This limit is
an existing emission limit in the Leamington Plant's approval order and Title V. Ash Grove will
continue to achieve this emission limitation while achieving BACT for the kiln operations. Ash
Grove has reviewed the following sources to identify available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019); and

NSPS Subpart F as an affected emissions facility in 40 CFR 60.62(a)(4);

Portland Cement Association's Formation and Techniques for Control of Sulfur Dioxide and Other
Sulfur Compounds in Portland Cement Kiln Systems.

SO2 emissions are a result of oxidation of sulfur compounds in the rawmix and/or the coal used to
fire the kiln. However, the alkaline nature of the cement provides for direct absorption of SO2 into
the product, thereby mitigating the quantity of SO2 emissions in the exhaust stream.

Step 1 - Identify All Control Technologies
Control technologies identified for SO2 emissions from coal-fired kiln operations are as follows:
Baghouse or fabric filter;
Dry reagent injection prior to baghouse;
Wet scrubber;
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Process optimization; and
Good combustion practices.

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below:

1. Process Optimization 99%
2. Wet Scrubber 99%
3. Dry Reagent Injection 60%
4. Good Combustion Practices 30%
5. Baghouse Variable

Step 4 - Evaluate Most Effective Controls and Document Results
SO2 emissions are most effectively controlled by optimizing the process and utilizing the inherent
SO2 scrubbing properties of the kiln system itself. Although wet scrubbers alone can achieve equal
control efficiencies as process optimization, additional capital and operational expenses are
required for water consumption and wastewater discharge. Whereas process optimization achieves
the same control effectiveness and has the added benefit of reduced operational costs. Ash Grove
optimizes the kiln process by routing the exhaust from the kiln to a preheater and raw mill to
interact with the raw mix, thus creating an atmosphere similar to a dry scrubber system. Good
combustion practices also reduce SO2 formation with the added benefit of energy efficiency.

Step 5 - Select BACT
BACT for control of SO2 emissions from kiln operations shall consist of process optimization by
routing kiln exhaust to the preheater and raw mill, good combustion practices, and use of a
baghouse prior to exhausting to the atmosphere. As a modification of the kiln, 40 CFR 60.62(a)(4)
requires an emission limit of 0.4 pounds of sulfur dioxide (SO2) per ton of clinker on a
30-operating day rolling average. [Last updated January 14, 2025]

10. BACT review regarding SO2, VOC, and Lead Sources cont.
VOC - Cement Kiln BACT
VOCs are generated by incomplete combustion in the kiln. 40 CFR 63 Subpart LLL - NESHAP
from the Portland Cement Industry limits total hydrocarbon and total organic HAP emissions to 24
and 12 ppmv at 7% oxygen. Ash Grove will achieve or exceed these emission limitations while
achieving BACT for the kiln operations. Ash Grove has reviewed the following sources to identify
available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028); and

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for VOC emissions from coal fired kiln operations are as follows:
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Process optimization,
Good combustion practices

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below.

1. Process Optimization Variable
2. Good Combustion Practices Variable

Step 4 - Evaluate Most Effective Controls and Document Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove optimizes the
kiln process by capturing waste heat from the clinker cooler and routing to a kiln preheater. Good
combustion practices also reduce VOC formation with the added benefit of energy efficiency.
There are no adverse energy, environmental or cost impacts to consider with the use of this control
technology.

Step 5 - Select BACT
BACT for control of VOC emissions from kiln operations shall consist of process optimization by
routing kiln heat to the preheater and good combustion practices. An emission limit of 24 ppmv
VOC @ 7% O2 is imposed by NESHAP Subpart LLL.

VOC - Grinding Aid BACT
A grinding aid containing VOC is added to the new finish mill to disperse particles within the mill
and expose more surface area to grinding. An increase in grinding aid usage proportionally
increases potential VOC emissions because volatiles from the grinding aid are not combusted in
the kiln.

There is only one identified control option for limiting the VOC emissions from the grinding aid.
Process optimization is technically feasible. VOC emissions are most effectively controlled by
optimizing the process. Ash Grove proposes to install a vertical finish mill with this project. Due to
the new modern mill's efficiency, it is anticipated that a reduced amount of grinding aid will be
required for each ton of clinker ground. Ash Grove estimates total VOC emissions from the
grinding aid at 2.37 tpy.

Lead Emissions
The lead emissions are anticipated to increase as a result of the proposed increase in clinker
throughput with the Leamington Plant upgrade project. Lead emissions result from residual
amounts of lead in raw materials and fuel. Lead emissions will be controlled the same as PM,
therefore a separate top-down BACT analysis has not been conducted as the Leamington Plant has
applied the most effective controls. [Last updated January 14, 2025]

11. BACT review regarding Greenhouse Gases
GHG Background
On October 9, 2009, the mandatory GHG reporting regulation, referred to as 40 CFR 98, was
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published in the Federal Register. Through 40 CFR 98, the U.S. EPA established the GHG
Reporting Rule, which requires the annual reporting of GHG data and other relevant information
from large sources and suppliers in the United States. Monitoring through the GHG Reporting
Program (GHGRP) began in 2010, with the first reports due by March 31, 2011. Per 40 CFR
98.2(a)(1), any facility associated with cement production is subject to the GHGRP and must report
CO2e emissions. The CO2e is the sum of equivalent GHG emissions from CO2, CH4, and N2O,
with their respective global warming potentials (GWP) applied. Ash Grove's facility is subject to
GHG Reporting Rule and monitors CO2 emissions from its kiln with a continuous emissions
monitoring system (CEMs). On June 23, 2014, the U.S. Supreme Court held that required PSD
permits (based on emissions of non-GHG pollutants) may continue to require limitations on GHG
emissions based on the application of BACT as an "anyway source". The Leamington Plant
modification project is a major source for PSD for both PM10 and PM2.5, and GHGs are estimated
to be greater than 75,000 tpy and greater than zero on a mass basis; therefore, GHGs are evaluated
for BACT as an anyway source.

Cement Manufacturing GHG BACT
A BACT analysis has been conducted for CO2e emissions from the kiln system. For this GHG
BACT analysis, various control technologies or combinations of technologies were identified using
the RACT/BACT/LAER Clearinghouse, available literature including guidance published by EPA
and South Coast Air Quality Management District (SCAQMD), current air regulations, other
regulatory organizations, and engineering experience. In March 2011, EPA published GHG
permitting guidance, as well as a white paper on available and emerging technologies for reducing
GHG emissions from the Portland cement industry in October 2010. Additionally, EPA published a
series of videos on GHG permit training in December 2010. The SCAQMD published GHG BACT
guidance in 2021. Additional sources of information were reviewed and documented based on
publications from trade organizations and other governmental committees with GHG or carbon
reduction guidelines and/or recommendations.

EPA has defined in 40 CFR 86.1818-12(a) GHGs as a group of six gases: CO2, nitrous oxide
(N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF6). GHG emissions from the kiln result from calcination and fuel combustion.
Since the primary GHG emitted by a kiln is CO2, the BACT analysis focuses on CO2 emissions
from the kiln. Emissions of CH4 and N2O are minimal from cement kilns. Per EPA guidance, GHG
control technologies for consideration in a BACT analysis for Portland Cement Manufacturing
include:

Source-wide energy efficiency strategies;
Raw material substitution;
Blended cements;
Carbon capture utilization and storage; and
Fuel switching.
Other emerging technologies [Last updated January 14, 2025]

12. BACT review regarding Greenhouse Gases cont.
Step 1: Identify All Control Technologies
The CO2 emissions from a cement kiln are generated by the calcination process (conversion of the
calcium carbonate in limestone to calcium oxide) and by combustion of fuel in the kiln. Potential
control technologies to reduce these CO2 emissions for a cement kiln are addressed in EPA's white
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paper on Available and Emerging Technologies for Reducing GHG Emissions from the Portland
Cement Industry.

These technologies fall into three categories:
Energy Efficiency Improvements for the Clinker Production Process
Fuel Substitution
Carbon Capture and Sequestration

Step 2: Eliminate Technically Infeasible Options
Several potential energy efficiency improvements are technically feasible: Pre-heater/Pre-calciner
Kiln Process, Kiln Seal Management Program, Refractory Selection (Kiln Insulation), and Energy
Recovery from the Clinker Cooler. The use of alternative fuels such as natural gas, whole tires and
biofuel) is also technically feasible. Other control options, such as Use of Fluxes and Mineralizers,
Heat Recovery for Power - Cogeneration, Carbon Sequestration, Oxyfuel combustion, and
Post-combustion Capture have been deemed infeasible.

Step 3: Rank Remaining Control Technologies by Control Effectiveness
All four remaining control techniques are currently implemented at the Leamington Plant. This
permitting project incorporates energy efficiency improvements. Ash Grove has had a fuel
substitution program in place for several years, and this program is continually reviewed and
updated as new sources and types of fuel are identified.

Step 4: Evaluate Most Effective Controls and Document Results
Since all technically feasible energy efficiency improvements and changes to product composition
will be implemented, this section will focus on economic and environmental considerations of fuel
substitution to operate exclusively on natural gas.

Firing natural gas as the primary kiln fuel can reduce CO2 emissions from fuel combustion by as
much as 40%. However, studies have shown that use of natural gas as primary kiln fuel can result
in three times more NOx emissions than NOx emissions from coal firing. Creating more NOx to
reduce GHG emissions is undesirable as it is a precursor to both ozone and PM2.5. Fuel substitution
essentially trades emissions of one regulated pollutant for another. Estimated capital cost to switch
to natural gas fuel exceeds $25M. Implementing natural gas technology would provide incremental
public health and welfare benefit globally by reducing CO2 emissions, while increasing NOx
emissions and negatively impacting public health and welfare locally. Switching fuels to another
fossil fuel has finite potential to mitigate CO2 emissions.

Step 5: Select BACT
In addition to the proposed energy efficiency improvements addressed elsewhere in this BACT
analysis, BACT is a limit of 0.92-ton CO2e/ton clinker. Ash Grove will use a continuous emission
monitoring system (CEMS) for CO2 to demonstrate compliance with this limit. [Last updated
January 14, 2025]

13. BACT review regarding Leamington Plant Upgrade Project conclusion
The control processes and techniques covered in this BACT analysis have been reviewed by the
NSR Section of the UDAQ. Ash Groves proposed controls and associated emission limitations
represent BACT. Any emission limitations not expressed in an associated NSPS or NESHAP will
be included in the terms and conditions of this AO. A listing of all associated NSPS and NESHAP
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programs is also included in the Source Information section of this document under Applicable
Federal Programs. [Last updated December 13, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
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.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date
of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
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proper credit when notifying the Director, send the documentation to the Director, attn.: NSR
Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

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

II.A.3
NEW
Stockpiles
Coal storage
Area: 1 acre
Annual throughput 20,000 tpy

AF and ARM stockpiles
Area: 0.25 acre
Annual throughput 8,000 tpy

II.A.4 Stationary Crusher
Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction
of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000
acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)

II.A.5 Raw Material Transfer
Crushed material is transported to raw material storage by belt B8. The raw material transfers
at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor
transfer point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total
filter area & water sprays. (pre-1983)

II.A.6 Material Handling
Conveyor belt systems, secondary feeders and screens, stacker system

II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit specific requirements

II.A.8 Belt Conveyor Transfer Baghouse
Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area
and 1,800 acfm total air flow, controls emissions from the conveyor belt that transfers the
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stacked material to the raw material silos.

II.A.9 Raw Material Silos
Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The
four silos are equipped with one common Fuller, plenum pulse baghouse (315.BF1) - 1,689 ft2
filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage).

II.A.10 Fifth Component Silo
Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse
(315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw
mill feed. This system includes vibrating feeders, a conveyor system, and surge bin.
Emissions are controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3,
316.BF4, 316.BF5) - each is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1
A/C ratio.

II.A.12 Cross-Belt Analyzer
Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6)

II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom
of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw
materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38).
The following equipment is installed: low-NOx burner, selective non-catalytic reduction
(SNCR) for NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued
mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric
monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct
for mercury adsorption capacity. The carbon injection system is not an emission point as it is
in an enclosed building.

II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

II.A.16 Two Kiln Feed Blending Silos
Raw material is blended in one of two blending silos prior to feeding the kiln. The blending
silos are controlled by one common Fuller, plenum pulse baghouse (411.BF1) - 1,351 ft2 filter
area; 7,160 acfm total air flow.

II.A.17 Blending Silo Elevators (2)
Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped
with a Fuller, pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow
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through stack E34.

II.A.18 Kiln Feed Alleviator
A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the
central material silo between the blending silos and the preheater. Raw feed is removed from
the system near the top of the preheater tower.

II.A.19 Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner.
The coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter
area; 1,700 acfm total air flow.

II.A.20 Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in
the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2):
19,500 acfm rated airflow with 3.75:1 A/C ratio

II.A.21 Clinker Cooler and Baghouse
Reconstructed grate type cooler used for cooling clinker from the kiln prior to transfer to
clinker storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) -
173,869 acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter
monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two
clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse
(419.BF8). The exhaust is routed to the clinker cooler stack.

II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions
generated when loading the east and west clinker silos and the out-of-spec silo are controlled
by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1):
1,800 acfm, that discharges into the clinker tunnel.

II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm, that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2)
Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers.
Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses
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(511.HP1 and new 511.HP2): 1,800 acfm each.

II.A.27 Gypsum Silo
Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2
total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust
during loading.

II.A.28 Clinker Tunnel Exitway
The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse
(511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel all discharge in the clinker tunnel.
Emissions are vented through the tunnel exitway.

II.A.29 Limestone Silo
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust
during loading. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement product. Dust
generated during milling is captured by a BHA, pulse jet baghouse (514.BF2) - 6,080 ft2 filter
area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding
stack).

II.A.31 Finish Mill (Ball Mill) Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized
cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA, pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow
controlling particulates from stack G55 (finish mill stack).

II.A.32
NEW
Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The
stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4)
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1,
525.BF1 thru 3)

II.A.33 Finish Cement Storage Silos
There are six storage and two interstice silos where the finished cement product is stored. A
single common Fuller, plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm
total air flow through stack H7 is located on top of the silos and is used to control emissions
during loading and unloading operations.

II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail
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shipping. This baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out
The cement loadout system located on the South side of the silos (truck load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF2) during unloading from the silos for truck
shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement
conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed
space inside the silos.

II.A.36
NEW
Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

II.A.37 MHO: Materials Handling Operation
Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1
& 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4;
512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.

II.A.38 LBS: Limestone Bypass System
Additional limestone is added to the clinker and gypsum by the limestone bypass system
(LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays
at the screen and material handling drop points.

II.A.39 GEN: Emergency Generators
One diesel-fired emergency generator (new)
Rating: 762 hp
(Kiln, Tier 3, permitted 2022)

Two natural gas-fired emergency generators
Rating: 304 hp
(Main office and control room, permitted in 2023)

One diesel-fired emergency generator
Rating: 560 hp
(Shipping, permitted 2023).

II.A.40 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14 inch knife gate, 8 inch knife gate, 8 inch air
slides, surge bin), and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm)
on the fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

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II.A.41
NEW
Miscellaneous Storage Tanks
One diesel storage tank (<2,000 gallons)
One gasoline storage tank (500 gallons)
Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Requirements on the Cement Plant:
II.B.1.a
NEW
The following limits shall not be exceeded:

A. Clinker production - 1,155,000 tons per rolling 12-month period

B. Used oil consumption - 85,724 gallons per rolling 12-month period

C. Limestone bypass material processed - 216,260 tons per rolling 12-month period.
[R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 25th day of each month using data from the previous 12 months.
Records shall be kept for all periods when the plant is in operation. Consumption and
production shall be calculated through use of the plant's acquisition system. [R307-401-8]

II.B.1.b
NEW
Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations:

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

SO2: 0.4 lbs per ton of clinker (3-hr average)

CO: 3,395 tons per rolling 12-month period, and 6,600 lbs/hr

NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average, and 1,233 tons per rolling
12-month period

Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is
400oF or less.

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Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)

THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)

CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)

PM: 0.02 lbs filterable PM per ton of clinker. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL,
R307-401-8]

II.B.1.c
NEW
A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR
60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust
emissions control plan shall be monitored to demonstrate that appropriate control measures are
being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of
the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall
be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in
the plan and that the source is operating in accordance with the submitted plan. For petitions
to approve alternative control measures, the permittee shall keep a copy of the submitted
petition and any approvals received. [40 CFR 60 Subpart Y]

II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area
source of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2). [40 CFR
63 Subpart LLL]

II.B.1.e
NEW
Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b
and II.B.1.d shall be performed as specified below:

A. Kiln/Raw Mill Stack
Pollutant Test Status Test Frequency
PM * #

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

B. Clinker Cooler (F31)
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Pollutant Test Status Test Frequency
PM + #

C. Testing Status (To be applied above)
* The initial testing has already been performed.

** The SO2 initial performance test was conducted on August 26, 2013.

*** The initial compliance test shall be conducted within the first 30 operating days of
operation in which the affected source operates using a CEMS.

# Test once every year. If performance testing would be required less than 15 operating days
after the Kiln has completed Startup after being down for more than 24 hours, then
performance testing may be deferred up to 15 operating days after completion of the Startup.
The Director may require testing at any time.

## Test at least once every two years. The Director may require testing at any time.

+ Initial testing is required within 180 days of startup of the reconstructed equipment

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must 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 PM CPMS is not out-of-control. The owner/operator must
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 on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

+++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.e.1
NEW
Notification
The Director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The notification requirements for performance tests subject to 40
CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-165]

II.B.1.e.2
NEW
Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational
Safety and Health Administration (OSHA)- or Mine Safety and Health Administration
(MSHA)-approved access shall be provided to the test location. [R307-165]

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II.B.1.e.4
NEW
PM
40 CFR 60, Appendix A, Method 5 or 5I or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three (3) runs with
each run at least 120 minutes in duration and each run collecting a sample of 60 dry standard
cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.3
NEW
Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2. [R307-165]

II.B.1.e.5
NEW
Carbon Monoxide (CO)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.6
NEW
Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.7
NEW
Sulfur Dioxide (SO2)
40 CFR 60, Method 6 or 6C of Appendix A-4 or other EPA-approved method as acceptable to
the Director. [R307-165]

II.B.1.e.8
NEW
Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]

II.B.1.e.9
NEW
Total Hydrocarbons (THC)
Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL]

II.B.1.e.10
NEW
Mercury (Hg)
Continuous Emission or integrated sorbent trap monitoring (See Condition II.B.3.a). [40 CFR
63 Subpart LLL]

II.B.1.e.11
NEW
HCl
Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other
EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]

II.B.1.e.12
NEW
Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.13
NEW
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. [R307-165]

II.B.1.e.14
NEW
Existing Source Operation
For an existing source/emission point, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three years.
[R307-165]

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II.B.1.e.15
NEW
New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the maximum production rate listed in this AO. If the maximum AO
allowable production rate has not been achieved at the time of the test, the following
procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This new
allowable maximum production rate shall remain in effect until successfully tested at a higher
rate.

3) The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate (110%
of the new rate) will then be allowed if the test is successful. This process may be repeated
until the maximum AO production rate is achieved. [R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL.
[40 CFR 63 Subpart LLL]

II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times
of Dust Shuttle System operation to assist in the capture of Mercury emission. [R307-401-8]

II.B.1.h
NEW
Visible emissions from the following emission points shall not exceed the following values:

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

L. All baghouses - 10% opacity
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M. Fugitive dust - 20% opacity

N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y,
R307-401-8]

II.B.1.i 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 must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

If any partially enclosed or unenclosed conveying system transfer point is located in a
building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to
40 CFR 60, according to the following:

(i) The owner/operator must conduct a monthly ten-minute visible emissions test of each
affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The
performance test must be conducted while the affected source is in operation.

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator 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 owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iii) If no visible emissions are observed during the semi-annual test for any affected source,
the owner/operator 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 owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iv) If visible emissions are observed during any Method 22 performance test, of Appendix
A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations,
recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60.
The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour
of any observation of visible emissions.

(v) If visible emissions from a building are monitored, the requirements of paragraphs (i)
through (iv) of this Condition apply to the monitoring of the building, and the owner/operator
must also test visible emissions from each side, roof, and vent of the building for at least ten
minutes. [R307-401]

II.B.1.j
NEW
Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed
0.005 gr/dscf:

520.BF1
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520.BF2
520.BF3
520.BF4
521.BF2
521.BF1
524.BF1
524.BF2
524.BF4
524.BF3
525.BF1
525.BF2
525.BF3
511.HP2
NRL_UPR
NRL_LWR. [R307-401-8]

II.B.1.j.1
NEW
To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration
through at least three (3) annual tests that the PM limits are not being exceeded, the
owner/operator may request approval from the Director to conduct stack testing less
frequently than annually. [R307-401-8]

II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive
dusts as dry conditions warrant or as determined necessary by the Director to maintain opacity
limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated to control fugitive dust. The application of
water or chemical treatment shall be used. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a damp/moist condition unless it is below freezing.
If chemical treatment is to be used, the plan must be approved by the Director. Records of
water and/or chemical treatment shall be kept for all periods when the plant is in operation.
The records shall include the following items: Instances of water and/or chemical application
to unpaved areas shall be recorded and maintained by the owner/operator. The ambient
temperature shall be recorded any time water should be applied but cannot due to freezing
conditions. [R307-401-8]

II.B.2.c
NEW
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

The sprays shall operate whenever dry conditions warrant meeting the required opacity
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limitations or as determined necessary by the Director. Water sprays shall not be required
during periods of freezing temperatures. [R307-401-8]

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation
of fugitive dusts as dry conditions warrant or as determined necessary by the Director.
[R307-401-8]

II.B.2.e
NEW
The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5
PM. [R307-401-8]

II.B.3 Continuous Emission Monitoring Requirements:
II.B.3.a
NEW
The owner/operator shall install, calibrate, maintain and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler.

A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the
missing data substitution procedures used by the UDAQ or the missing data substitution
procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate by the UDAQ.

B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period
including during each startup, shutdown, or malfunction.

C. The monitoring system shall comply with all applicable sections of R307-170, UAC; and
40 CFR 60, Appendix B.

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be
installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the
kiln/raw mill stack.

F. The owner/operator shall record the output of the system: including the quantity of NOx,
CO, O2 THC, Hg, HCl, and CO2 emissions at the kiln stack.

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source 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.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker
cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except
during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments,
the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a
PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the
results of the performance test demonstrating compliance with the filterable PM limit and
using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust
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the SSOL developed in accordance with the results of the most recent PM performance test
demonstrating compliance with the PM emission limit. The owner/operator shall use the PM
CPMS to demonstrate continuous compliance with the SSOL in accordance with the
requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

II.B.4 Fuel Limitations:
II.B.4.a
NEW
The owner/operator shall use only the following fuels in the kiln and pre-calciner:

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.

If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b
NEW
Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the
Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the
results of suitable tests giving data similar to a Proximate and Ultimate analysis of the
proposed coal additive. [R307-401-8]

II.B.4.b.1 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. [R307-401-8]

II.B.4.b.2 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 owner/operator 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 in Condition
II.B.4.b. [R307-401-8]

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II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel burning or process
installation not covered by New Source Performance Standards for sulfur emissions or
covered elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross
Btu heat input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input
for any oil except used oil. The sulfur content shall comply with all applicable sections of
UAC R307-203. [R307-203, R307-401-8]

II.B.4.c.1
NEW
Certification of fuels shall be either by the owner/operator's own testing or test reports from
the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be
available onsite. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials, UAC R307-203-1 (4)

A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be
used.

B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be
used.

C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85 are to be used. [R307-203]

II.B.4.d
NEW
The concentration/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight
3) Cadmium 2 ppm by weight
4) Chromium. 10 ppm by weight
5) Lead 100 ppm by weight
6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be
tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the burn tank and burned. [R307-401-8]

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II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned
in the rotary kiln:

A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than
five minutes in any 60-minute period

B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes
in any 60-minute period. [R307-401-8]

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the
Director. The calibration procedure and frequency shall be according to manufacturer's
specifications. Use of factory-calibrated thermocouples for temperature measurement is
approved. However, any other method of temperature measurement must be approved by the
Director prior to use. The monitoring equipment for both temperature and oxygen content
shall be located such that an inspector can at any time safely read the output. [R307-401-8]

II.B.5
NEW
Emergency Engine Requirements
II.B.5.a
NEW
The owner/operator shall only operate the emergency engines for testing and maintenance
purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency
operation. [R307-401-8]

II.B.5.b
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each emergency engine. [R307-401-8]

II.B.5.b.1
NEW
The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.5.b.2
NEW
To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN103030035-24 dated November 27, 2024
Is Derived From Source Submitted NOI dated November 30, 2022
Incorporates Additional Information Received dated April 26, 2023
Incorporates Additional Information Received dated September 26, 2023
Incorporates Additional Information Received dated July 23, 2024
Incorporates Additional Information Received dated October 25, 2024
Incorporates Additional Information Received dated November 25, 2024

REVIEWER COMMENTS

1. Comment regarding applicability of federal requirements:
New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable
by the best demonstrated technology as specified in the applicable provisions. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.

40 CFR 60, Subpart A (General Provisions)
All affected facilities subject to a source-specific NSPS are subject to the general provisions of
NSPS, Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires
initial notification, performance testing, recordkeeping, and monitoring, provides reference methods,
and mandates general control device requirements for all other subparts.

40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of
performance for affected facilities in Portland Cement Plants which have been constructed or
modified after August 17, 1971.

40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart
F: Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and
unloading systems. The Leamington coal mill is an in-line coal mill and considered an integral part
of the Leamington kiln. In-line coal mills are not subject to NSPS Subpart Y. Therefore, the coal mill
is addressed under NSPS Subpart F as part of the kiln system. The coal silos and conveying system
are subject to NSPS Subpart Y.

Ash Grove's proposed changes to the kiln system must be evaluated as to whether they trigger new
NSPS Subpart F obligations based on whether the proposed project is either a modification or a
reconstruction, as those terms are defined in NSPS Subpart A.

Ash Grove's proposed changes to the kiln system do not meet the definition of a reconstruction, nor
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Page 40

do they meet the definition of a modification for NOx. However, the changes meet the definition of a
modification for PM and SO2. Therefore, Ash Grove will comply with all relevant emission
standards; testing requirements; monitoring, recordkeeping, and reporting obligations that apply to
the Leamington kiln system as an existing source under NSPS Subpart F. Under NSPS Subpart A
and F, the clinker cooler is considered a reconstructed unit. Thus new limits will apply to this unit.
[Last updated January 14, 2025]

2. Comment regarding applicability of federal requirements cont.:
NSPS Subpart Y - Standards of Performance for Coal Preparation and Processing Plants
This subpart provides standards of performance for affected facilities in coal preparation and
processing plants that process more than 200 tons of coal per day.

The Leamington plant's coal silo and coal conveying system are existing affected facilities under
NSPS Subpart Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses
controlling affected facilities subject to match the limit in NSPS Subpart Y from 0.016 gr/dscf to
0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade Project. Since there are no proposed
modifications or reconstruction to the coal silo and coal conveying system, nothing about the
proposed upgrade project affects the existing applicability of NSPS Subpart Y.

NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
This subpart provides standards of performance for affected facilities located at fixed or portable
nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August
31, 1983, with additional requirements applicable to sources constructed on or after April 22, 2008.

As the crushing and screening system is controlled by baghouses and an increase in PM10 actual
emissions on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS.
Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the
Leamington Plant Upgrade Project.

Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1),
60.676(f), and 60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO
monitoring and recordkeeping requirements.

[Last updated January 14, 2025]

3. Comment regarding applicability of federal requirements cont.:
National Emission Standards for Hazardous Pollutants (NESHAPs)
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or
greater than 10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as
specified by each subpart. NESHAP apply to sources in specifically regulated industrial source
classifications (CAA Section 112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities
not regulated as a specific industrial source type. The Ash Grove Leamington Plant is a major source
of HAPs and thus is subject to certain NESHAP standards.

Subpart A - General Provisions
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All affected sources are subject to the general provisions of Subpart A unless otherwise specified by
the source-specific NESHAP. Subpart A generally requires initial notification and performance
testing, recordkeeping, monitoring, provides reference methods, and mandates general control device
requirements for all other subparts as applicable.

Subpart LLL - Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry
This subpart establishes process/source specific emission limits for PM, VOC (expressed as total
hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and
gaseous HAP compounds by limiting PM and THC emissions because portions of such emissions
are USEPA-listed HAPs. Subpart LLL requires compliance with applicable emissions limits on and
after the initial startup of cement production. To further reduce emissions, Subpart LLL also
establishes operational requirements for the use of cement kiln dust (CKD), fly ash, fuel and control
equipment. Subpart LLL also specifies process/source specific emissions testing, monitoring,
recordkeeping, reporting, and compliance demonstration requirements. The compliance requirements
for the site are detailed in Approval Order Condition II.B.1.b. Ash Grove will continue to comply
with the requirements of Subpart LLL to demonstrate compliance. This cement kiln will remain an
existing source with respect to the kiln emission standards in Subpart LLL as this project does not
trigger the definition of a new source in Subpart LLL. New source standards apply only to affected
sources that were constructed or reconstructed after May 6, 2009.
[Last updated December 20, 2024]

4. Comment regarding PSD applicability analysis:
Ash Grove is proposing to increase the throughput of limestone from the quarry to supply the New
Finish Mill to increase the amount of low-carbon cement from the Leamington Plant. Additionally,
along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
modified, and the clinker cooler will be reconstructed. These changes are anticipated to result in an
increase in clinker production. Emission calculations for this project have been completed assuming
an increase in clinker production capacity while utilizing current fuel types. This will result in an
increase in the throughput of fuel.

The Leamington Plant is considered an existing major source under PSD based on potential
emissions of PM10, PM2.5, NOx, CO, SO2, and CO2e. If a major source undergoes a physical or
operational change, the facility must determine whether the project will be considered a major
modification. Per 40 CFR 52.21(b)(2)(i), in order to be a major modification, the project must result
in a significant emissions increase, and a significant net emissions increase.

As defined at 40 CFR 52.21(b)(40): Significant emissions increase means, for a regulated NSR
pollutant, an increase in emissions that is significant for that pollutant. Significant is further defined
to mean, in reference to a net emissions increase or the potential of a source to emit any of the
following pollutants, a rate of emissions that would equal or exceed the values outlined in 40 CFR
52.21(b)(23). If the increase in emissions from the project are not significant, a major modification
has not occurred.

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 42

increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

For all pollutants, the project emissions increase was calculated as the difference between the
projected actual emissions (PAE) after the proposed project and the actual emissions prior to the
project (baseline actual emissions or BAE).

Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
". . . projected actual emissions means the maximum annual rate, in tons per year, at which an
existing emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years
(12-month period) following the date the unit resumes regular operation after the project, or in any
one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit of that regulated NSR pollutant and full utilization of the unit would
result in a significant emissions increase or a significant net emissions increase at the major
stationary source." [Last updated January 14, 2025]

5. Comment regarding PSD applicability analysis cont.:
Ash Grove estimates that the projected actual production capacity following the project will be
1,155,000 tons of clinker per year and 1,341,266 tons of limestone per year. These capacities were
used to calculate projected actual emissions from the project using representative emission factors.
Additionally, to estimate emissions from material transfer baghouses, the actual flow rates and actual
projected hours were used as a basis for projected actual emissions.

Project Emission Calculations

Project emission increases from the kiln and coal mill systems are calculated for all criteria
pollutants based on emission factors that are derived from stack testing, CEMS data, or emission
factors (i.e., VOCs and Lead), and the associated projected incremental clinker increase.

NOx emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain
hourly capacity to emit and annual potential to emit at current levels. The kiln's NOx emissions rate
will not change as a result of the physical modifications proposed by the project.

Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission
factor and multiplied by the incremental increase in clinker production. The emission factor was
selected based on the average of the 24-month consecutive month emissions for 2020 and 2021. The
CO emissions will increase.

The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing
conducted at the plant. The SO2 emissions will increase.

VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production. VOC emissions will increase.

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 43

can be found in the original NOI and subsequent addendums submitted to UDAQ.

As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from
the proposed project, each increase of emissions from both existing and new sources shall be
summed together and compared to the PSD permitting thresholds. The increase of emissions is the
"positive" difference between the projected actual emissions and baseline actual emissions (projected
minus baseline).

New Emissions Sources

The actual to projected actuals calculation is not available to new emission units. For new emission
units, the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected
emissions are based on the new sources' potentials to emit. (40 CFR § 52.21(a)(2)(iv)(f)).

The new equipment proposed includes the New Finish Mill, a new rail and truck loading/loadout,
one (1) new clinker reclaim loading hopper with a dust collector and one (1) existing clinker reclaim
hopper with a dust collector, a new Clinker Cooler to replace the existing one, and a new kiln feed
alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions:

The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;

The finish mill heater was calculated based on its maximum firing capacity and flow rates; and

The fugitive emissions were calculated based on the projected annual throughput of the New Finish
Mill, the rail loadout, and clinker production. [Last updated January 14, 2025]

6. Comment regarding PSD applicability analysis cont.:
Existing Emission Sources

For the existing sources, the projected actual emissions are the maximum annual rates in tons per
year projected to occur during the next five (5) to ten (10) years if the existing sources' design
capacities increase. Ash Grove Leamington projected the actual emissions for the next five (5) years
based on the new kiln system producing an annual average of 3,250 tons of clinker per day.

Baseline actual emissions (BAE) are defined at 40 CFR 52.21(b)(48)(ii) as:

". . . baseline actual emissions means the average rate, in tons per year, at which the emissions unit
actually emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the 10-year period immediately preceding either the date the owner or operator
begins actual construction of the project, or the date a complete permit application is received by the
Administrator."

Ash Grove has selected to use the years 2020 and 2021 for each pollutant as the representative
baseline years.

In its NOI, Ash Grove calculated the emission increase from the project as being divided into two
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 44

phases. Phased construction projects are discussed in two sections of the federal PSD regulations -
40 CFR 52.21(j)(4) and 40 CFr 52.21(r)(2). UDAQ is not processing this project as a phased
construction project, nor did Ash Grove request such a determination. Therefore, Ash Grove
provided a summary table outlining the final change in emissions from this project:

Projected Actual Increase Compared to PSD threshold (tons per year)
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2e
BAE 76.64 39.64 1,187 6.87 3,315 55.47 641,385
PAE 203.15 113.47 1,226 45.87 3,414 72.07 1,067,984

Change in Emissions 126.51 73.83 39.00 39.00 99.00 16.59 426,598

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes

If the emissions increase is greater than the PSD significance threshold for a particular pollutant, Ash
Grove has the option of conducting a PSD review or continuing through the rest of the steps to
determine if it can "net" out of a PSD review. If the project increase is less than the PSD significant
threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant.

The change in emissions from the project exceeds the significant emission threshold for three
pollutants: PM10, PM2.5 and CO2e. Ash Grove elected to attempt to net out of a PSD major
modification for the remainder of the criteria pollutants.

Netting

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant
Upgrade Project and ends on the date the upgrade begins operation. Only PM10, PM2.5, CO2e are in
excess of SERs and therefore considered in the netting analysis.

Ash Grove estimated that the commencement of construction will be in December 2024. Therefore,
the contemporaneous period for this project is December 2019 through a projected date the project
upgrade begins operation. [Last updated January 21, 2025]

7. Comment regarding PSD applicability analysis cont.:
Contemporaneous Decreases

Ash Grove replaced an existing kiln emergency drive engine with a USEPA Tier 4 diesel engine in
2022. Concurrently, Ash Grove requested an increase in the capacity of 1L Cement. Additionally,
Ash Grove submitted a minor modification NOI air permit application on June 12, 2023, which
proposes replacing the shipping generator during the contemporaneous period. The kiln emergency
drive engine and shipping generator are both higher EPA tier ratings therefore result in decreases for
PM10 and PM2.5. These changes were approved in AO DAQE-AN103030033-24 issued March 21,
2024.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 45

Contemporaneous Increases

As stated above, the existing kiln emergency drive engine and shipping generator were permitted and
replaced in 2024. This resulted in an increase in emissions of CO2e.

The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout
in an effort to improve truck traffic at the loadout. The modification to add these dust collectors to
the loadout was included in DAQE-AN103030029-19. The baghouses are three (3) levels up in the
silos' enclosed space (approximately 40 feet). Both dust collectors vent directly into the interior of
the silo structure and are not vented into the atmosphere. Ash Grove requests to remove these
baghouses from its existing permitted emissions inventory. Therefore, these emissions have been
documented in the netting analysis as zero emissions.

Also included in DAQE-AN103030033-24 were two new natural gas-fired emergency generators
and increases in stockpiles, material handling and road emissions.

Could Have Been Accommodated Emissions

In calculating project emissions increase, USEPA allows the exclusion of existing
production/emissions rates that could have been accommodated during the baseline period. These
"could have been accommodated" emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as
follows:

". . . Shall exclude, in calculating any increase in emissions that results from the particular project,
that portion of the unit's emissions following the project that an existing unit could have
accommodated during the consecutive 24-month period used to establish the baseline actual
emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project,
including any increased utilization due to product demand growth;"

Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the
exclusion of existing production and emissions rates that could have been accommodated during the
baseline period, it has elected not to use this exclusion at this time. Therefore, calculation of the
"could have been" accommodated emissions have not been included in this application's
applicability analysis.

The increase from the project is added to the contemporaneous decreases and contemporaneous
increases. The resulting calculation is then compared to the PSD significance threshold to determine
if a significant net emissions increase has occurred. [Last updated January 14, 2025]

8. Comment regarding PSD applicability analysis cont.:
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2 e
Contemporaneous Inc. 1.61 0.45 0.41 0 0.27 0.07 51.74

Contemporaneous Dec. -1.54 -3.97 -0.48 -0.02 -0.27 -0.09 0

Change in Emissions 125.02 69.21 38.93 38.98 99.00 16.58 426,650

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 46

The results of the netting analysis conclude that both a significant emissions increase and a
significant net emissions increase in both particulates (PM10 and PM2.5) and CO2e will occur from
this project. Thus, the project must be reviewed as a PSD major modification. [Last updated January
14, 2025]

9. Comment regarding emission calculations:
This engineering review includes updated potential emission totals for both criteria and HAP
emissions. The potential-to-emit (PTE) values were calculated using updated values for clinker
produced and raw material inputs. BACT emission factors and limitations were used where
appropriate. Certain emission totals (NOx, SO2 and CO) were set based on avoiding a significant
increase in emissions. Specifically, the projected actual increase was set at just under the baseline
actual emissions + the significance level. As these emissions are monitored by CEM, UDAQ agrees
with this approach. Please see the netting analysis for further details on calculation of projected
actual increase. The NOx hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project.

CO2e emissions were calculated using the GHG emission factor calculated from 40 CFR Part 98
Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in Subpart A Table
A-1.

To calculate the PTE tons per year, the maximum hours (i.e., 8760) per year and the source's
emissions rates were multiplied with the throughputs. The potential throughputs have been updated
at UDAQ's request so that PAE is equal to PTE and represents the equipment's maximum design
potential.

Additional emission calculations based on source testing and monitoring, and EPA's compilation of
air emission factors AP-42. [Last updated January 14, 2025]

10. Comment regarding requirements for PSD review:
In addition to the permitting requirements of R307-401-5 through R307-401-8, there are additional
requirements under PSD that must be addressed:

1. Calculation of ambient air increments (40 CFR 52.12(c)), ambient air ceilings ((40 CFR 52.12(d)),
source impact analysis (40 CFR 52.12(k)), air quality models (40 CFR 52.12(l)) - these items are
addressed in the modeling memo DAQE-MN103030032-24.

2. Stack heights (40 CFR 52.12(h)) - Ash Grove's stack heights have been reviewed with respect to
good engineering practice and operate in a vertical unrestricted manner.

3. Control technology review (40 CFR 52.12(j)) - this is addressed in the BACT analysis section of
this review document.

4. Air quality analysis: preapplication analysis (40 CFR 52.12(m)) - this is covered in the PSD
applicability and netting analysis sections of this review document, ambient monitoring and
background data collection is also included in the modeling memo DAQE-MN103030032-24.

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 47

grain loading limit included in II.B.1.j.1 represents the required post-construction monitoring.
6. Source information (40 CFR 52.12(n)) - this is addressed under the requirements of R307-401-5
and was submitted by Ash Grove as part of the NOI package.

7. Additional impact analysis (40 CFR 52.12(o)) - these requirements cover soils, vegetation, growth
and visibility concerns. They are discussed in the modeling memo DAQE-MN103030032-24.

8. Federal land manager review (40 CFR 52.12(p)) - UDAQ provided initial notification to all
federal land managers upon receipt of the original NOI package. The draft permit and engineering
review will also be provided to the federal land managers 60-days prior to initiation of public
comment for their further review.

9. Public participation (40 CFR 52.12(q)) - this project will have a 30-day public comment period.

10. Source obligation (40 CFR 52.12(r)) - this requirement discusses source compliance with other
parts of the CAA, which is addressed within UDAQ's permitting rules in R307.
[Last updated January 14, 2025]

11. Comment regarding changes in equipment list:
The equipment list is being updated for clarity as well as adding new pieces of equipment. The
following changes are taking place:

The naming scheme is being updated to remove the numerical code from the unit designation. This
code generally referred to the associated control device and not to the emitting unit itself. This can
cause confusion especially when the same code was applied to multiple pieces of equipment.
Instead, the control devices (typically baghouse dust collectors) will be identified in the description
along with the appropriate numerical code.

Specific changes are as follows:

1. The kiln description has been updated

2. Clinker Cooler description has been updated to include a larger pulse jet baghouse.

3. The clinker storage silos, east and west clinker belts, clinker belt transfer and clinker tunnel have
been consolidated to avoid confusion

4. The north and south cement loadout exhausts now vent internally into the cement storage silos

5. The dust shuttle system has been consolidated into one line item, most identifiers removed from
subsystem descriptions as only two baghouses serve as exhaust points.

6. A new finish mill with heater has been added. Included in the description are the thirteen total
baghouses for dust control (1 main stack, 2 transfer points, 10 nuisance dust filters)

7. A new clinker reclaim hopper has been added. Both reclaim hoppers are controlled by baghouses
with updated identifiers

8. A new rail and truck loading/unloading system with two baghouses has been added.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 48

[Last updated December 20, 2024]

12. Comment regarding changes in conditions:
As a result of this project, several conditions will be added or changed. This includes one new
general condition (I.8). Changes to the equipment list (section II.A) will be addressed in a separate
reviewer comment:

I.8 - Adding this general condition to cover the requirements of R307-401-18 Eighteen Month
Review. The status of construction/installation of the new equipment shall be reviewed after
18-months.

II.B.1.a - Clinker production increases to 1,155,000 tpy
Use of limestone bypass material increases to 215,260 tpy

II.B.1.b - The NOx limit on the kiln decreases to 1,223 tpy, CO emissions from the kiln decrease to
3,395 tpy,
Adding a new CO2e limit of 0.92 tons CO2e/ton of clinker produced
PM limit on the clinker cooler decreased to 0.02 lb PM (filterable)/ton of clinker
Rule reference updated to include 40 CFR 60 Subpart F, and R307-401-8

II.B.1.e - Initial testing on the clinker cooler is now required within 180 days of startup of the unit.
Monitoring of CO2 from the kiln will be by CEM.
Formatting changes on paragraph designated ++, improve clarity, include reference to CO2
monitoring, define CPMS

II.B.1.e.4 - Update to address general PM monitoring and reference R307-401-8

II.B.1.e.14 - New condition to address new or reconstructed emission units monitoring requirements,
applicable to the clinker cooler and new finish mill.

II.B.1.h - Adding references to Subpart OOO units (limestone processing) with updated opacity
limits.
Adding 20% opacity limit on coal transfer and storage
Adding property boundary opacity limit of 20%
Updating rule reference to include Subpart OOO

II.B.1.j - New condition to address outlet grain loading limits on new baghouses, One identical limit,
15 total new baghouses.

II.B.1.j.1 - Monitoring on new baghouses as per II.B.1.e.4, added an allowance to test less frequently
than annually with three successful tests.

II.B.3.a - Updating formatting to add clarity and include reference to CO2 CEM

II.B.5 - New conditions on emergency engines, diesel fuel sulfur limits, hour of operation
restrictions, non resettable hour meter

[Last updated December 20, 2024]
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 49

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 51

TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 52

DAQE-MN103030032-24

M E M O R A N D U M

TO: John Jenks, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler
Dave Prey, Air Quality Modeler

DATE: December 12, 2024

SUBJECT: Modeling Analysis Review for the Ash Grove Cement Company – Leamington Plant,
located in Millard County, Utah
___________________________________________________________________________________
This is a Major Modification to a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Ash Grove Cement Company (Applicant) has submitted a Notice of Intent (NOI) air permit
application for a project referred to as the Leamington Upgrade Project (LUP). The proposed
upgrade project includes the construction and installation of new pollution control equipment, new
emission sources, and modifications to existing emission sources. Emission increases associated
with the LUP constitute a major modification to a Prevention of Significant Deterioration (PSD)
source subject to PSD permitting regulations. PSD regulations require the Applicant to include and
air quality impact analysis (AQIA) of the proposed projects impact on the EPA national ambient air
quality standards (NAAQS) and air quality related values (AQRV) as part of a complete NOI.

This report prepared by the New Source Review (NSR) modeling staff contains a review of the
Applicant’s Air Quality Impact Analysis (AQIA) including the methodology, data sources,
assumptions, and modeling results for comparison with State and Federal air quality standards. The
AQIA was reviewed and referenced in this report include the:
● Notice of Intent – Ash Grove Cement Leamington Plant PSD Notice of Intent Air Permit
Application, dated November 30, 2022.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

0 0
Jason Krebs

DP
DAQE-MN103030032-24
Page 2

II. APPLICABLE RULES AND ANALYSES

A Utah Air Quality Rules

The UDAQ has determined that the Applicant’s NOI is subject to the following rules for conducting an
AQIA:

R307-401 Permits: New and Modified Sources
R307-405 Permits: Major Sources Located in Attainment or Unclassified Area (PSD)
R307-406-2 Visibility – Source Review
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutant Impacts in Attainment Areas

B. Applicability

The proposed increases in emissions of PM10 and PM2.5 exceed the emission thresholds outlined in R307-
406-5 and R307-410-4. Therefore, an AQIA consistent with the requirements of R307-405-6, R307-406-
2, and R307-410-3 was submitted as part of the Applicant’s NOI. R307-410-3 establishes the U. S.
Environmental Protection Agency (US EPA) – Guideline on Air Quality Models as a formal basis for
defining the scope of the analysis, as well as the model’s construction. The results of the AQIA are
required to demonstrate the proposed project’s impact on state and federal air quality standards,
acceptable levels of impact, and action triggering thresholds referenced or listed in R307-401-6(2), R307-
401-6(3), R307-403-3(1), R307-403-5(1)(a), R307-405-4(1), R307-405-6. Annual emissions for criteria
pollutants requiring an AQIA are listed in Table 1.

Table 1: Ash Grove Leamington Proposed Net Emissions Increase

Criteria
Pollutants
Net Emission
Increase (TPY)
AQIA Trigger
Level (TPY) AQIA Required?
PM10 126.6 15 Yes
PM2.5 70.3 10 Yes

C. Required Analyses

R307-405 requires the Applicant to perform a pre-construction modeling analysis for all pollutants
emitted in a significant quantity. The purpose of the analysis is to determine if the extent of the source’s
impact is significant enough to warrant an on-site measurement of the ambient background concentration
levels. This data is included in the NAAQS analysis to represent the quality of the air prior to the
construction of the proposed project. The Applicant included a pre-construction modeling analysis for
PM10 and PM2.5 as part of the NOI. The pre-construction modeling analysis was also used to determine if
the proposed emissions would result in a significant impact to the environment, thereby triggering the
requirement for a cumulative analysis of the proposed project and other nearby existing sources.

R307-401-8 requires the Division to determine that the proposed project will comply with the NAAQS
prior to the issuance of an Approval Order (AO). R307-405(7) requires the Applicant to perform a
DAQE-MN103030032-24
Page 3
NAAQS analysis for all pollutants emitted in a significant quantity. The analysis is to include all
emissions at the proposed site under normal operating conditions using maximum anticipated short-term
release and annual release rates. Consistent with UDAQ policy, a cumulative analysis to include the
ambient background concentration and any contribution from other nearby sources is not required if the
proposed project’s impact does not exceed the PSD Class II Significant Impact Level (SIL).

R307-401-8 also requires the Division to determine that the proposed project will comply with PSD
increments prior to the issuance of an AO. Under R307-405(6), the Applicant is required to perform a
PSD Class I and II increment consumption analysis for all pollutants emitted in significant quantities.
The purpose of this analysis is to quantify any degradation in air quality since the major source baseline
date. The analysis is to include all increment consuming emissions at the proposed site under normal
operating conditions using maximum anticipated short-term and annual release rates. A cumulative
analysis to include contributions associated with growth and other increment consuming sources is not
required if the proposed project’s impact does not exceed the PSD Class I or II SIL.

R307-410-5 requires the Applicant to perform a HAPs analysis for any pollutant emitted above a
pollutant specific emission threshold value. This analysis is to include all emissions of the pollutants
resulting from the proposed modification under normal operating conditions using maximum anticipated
one-hour release rates. The Applicant did not trigger modeling for HAPs.

R307-406-2 requires the Applicant to perform a plume blight analysis. A plume blight analysis is required
to determine if plumes emanating from the proposed project would be visible inside any Class I area
within 50 kilometers of the source. The plume blight analysis is to include all emissions of NO2, SO4, and
PM10.

Under R307-405-16, an AQRV analysis is performed which evaluates regional haze and acid deposition
impacts at each of the Class I areas within 300 kilometers of the source. A regional haze analysis is
required to determine if the plumes would reduce the visual range of an observer inside the Class I area.
The regional haze analysis is to include all emissions of SO2, NOX and PM10. The deposition analysis
examines impacts from sulfur and nitrogen compounds at the Class I areas, and is based on all emissions
of SO2 and NOX. The Federal Land Managers use the Q/D approach to determine whether a PSD project
should provide detailed AQRV impact analyses, where: Q/D= [ H2SO4 + SO2 + NOx + PM10 emissions
(tpy)]/ distance (km). If Q/D is less than 10, no AQRV analysis is required.

R307-405 requires the Applicant to perform a soils and vegetation analysis. The analysis should quantify
the effects of pollutants on soils and vegetation near the highest impact location and in areas where
sensitive plant species may be impacted.

III. ON-SITE PRE-CONSTRUCTION MONITORING

A. Meteorological Data

Consistent with the US EPA - Meteorological Monitoring Guidance for Regulatory Modeling
Applications, one year of on-site data was collected using a 50-meter tower during the period October 1,
2021 through September 30, 2022. Parameters collected on-site included wind speed and direction,
temperature, delta-T, and solar radiation.

DAQE-MN103030032-24
Page 4

B. Ambient Pollutant Data

A preliminary analysis was conducted to determine the necessity for pre-construction ambient pollutant
monitoring. The results indicate that predicted concentrations of PM10 and PM2.5 exceed the monitoring
trigger level listing in the rule. A continuous PM10/PM2.5 monitor with filter based samplers was
installed near the northern edge of the Applicants property boundary, and collected particulate matter
from October 1, 2021 through September 30, 2022.

IV. MODEL SELECTION

The EPA-AERMOD dispersion modeling system is the preferred model specified in the US EPA –
Guideline on Air Quality Models to predict air pollutant concentrations in the near field (within 50
kilometers of the source). The US EPA - CALPUFF - Version 5.8 model is the preferred model to predict
concentrations in the far field (long range transport conditions beyond 50 kilometers from the source).

V. MODELING INPUTS AND ASSUMPTIONS

A. Technical Options

The regulatory default options were selected in AERMOD by the Applicant to quantify all concentrations.

B. Urban or Rural Area Designation

A review of the appropriate 7.5-minute quadrangles determined that the area should be classified as
“rural” for air modeling purposes.

C. Topography/Terrain

The Plant is at an elevation of 4,950 feet with nearby terrain features that have an effect on concentration
predictions.

a. Zone: 12
b. Location: UTM (NAD83): 397000 meters East, 4379850 meters North

D. Ambient Air

It was determined that the Plant boundary used in the AQIA meets the State’s definition of an ambient air
boundary.

E. Receptor and Terrain Elevations

The modeling domain has simple and complex terrain features in the near field. Therefore, receptor
points representing actual terrain elevations from the area were used in the analysis.

The far-field modeling domain consisted of a rectangular region covering all Class I areas within Utah,
and extending 50 kilometers beyond this area so that the model can account for re-circulation of the
plume.

DAQE-MN103030032-24
Page 5

F. Emission Rates and Release Parameters

The emission estimates and source parameters used in AERMOD for all proposed emission sources at the
site are presented in the NOI.

Speciated emission rates and source parameters used in the CALPUFF modeling are presented in Table 2.

Table 2: CALPUFF Emission Rates

Source
LCC Coordinates Modeled Emission Rates
Easting Northing SO2 SO4 NOX HNO3 NO3 SOA PMC SOIL EC
(m) (m) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr)
317.BF3 -1289410 -3738 52.81 5.03 307.58 0.00 0.00 5.03 2.60 2.90 0.11
419.BF1 -1289314 -3631 0.00 0.00 0.00 0.00 0.00 0.55 1.51 1.61 0.06
41B.BF2 -1289389 -3663 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.68 0.00
N1_FM2 -1289526 -3414 0.00 0.00 0.00 0.00 0.00 0.00 1.65 3.95 0.00
414.BF1N -1289407 -3683 0.00 0.00 0.00 0.00 0.00 0.00 0.10 0.25 0.00
2FM_HTR -1289528 -3415 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.08 0.00
514.BF1 -1289451 -3675 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.70 0.00
COMBO -1289424 -3668 0.00 0.00 0.00 0.00 0.00 0.00 1.37 5.72 0.00
FM2_CMB -1289454 -3439 0.00 0.00 0.00 0.00 0.00 0.00 0.50 1.21 0.00

Total Lb/hr 52.81 5.03 307.58 0.00 0.00 5.58 8.32 17.10 0.17
Hrs/Yr 8760 8760 8760 8760 8760 8760 8760 8760 8760
Ton/yr 231.3 22.0 1347.2 0.0 0.0 24.4 36.4 74.9 0.8

Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
317.BF3 POINT 4902.8 41.2 135.0 488 10.10 3.35
419.BF1 POINT 4891.2 18.3 60.0 388 6.36 2.90
41B.BF2 POINT 4895.2 68.6 224.9 294 17.83 0.74
N1_FM2 POINT 4832.0 49.7 163.0 363 40.08 1.40
414.BF1N POINT 4896.1 76.8 251.9 353 9.91 0.70
2FM_HTR POINT 4832.0 49.7 163.0 363 40.08 1.40
514.BF1 POINT 4889.5 39.6 130.0 294 11.86 0.91
COMBO POINT 4904.2 13.3 43.7 276 9.76 0.32
DAQE-MN103030032-24
Page 6
FM2_CMB POINT 4832.0 30.6 100.3 294 11.40 0.37

G. Building Downwash

The Applicant used the US EPA Building Profile Input Program (BPIP) to determine Good Engineering
Practice (GEP) stack heights and cross-sectional building dimensions for input into the model.

H. Ambient Background Concentrations

Millard County is in attainment for all criteria pollutants. The NAAQS analyses for PM2.5 and PM10 used
monitoring data collected on site during the pre-construction monitoring analysis. The background values
used in the NAAQS analysis are presented in Table 3.

Table 3: Background Concentrations

Pollutant Averaging
Period
Background
Concentration
(μg/m3)
PM10 24-hour 65.4
PM2.5 24-hour 10.2
Annual 4.2

I. Meteorological Data Processing

For the AERMOD model, on-site horizontal and vertical wind speed, direction, solar radiation and,
temperature data was combined with National Weather Service (NWS) upper air data collected at the Salt
Lake City International Airport (SLCIA) for the same period using the US EPA AERMET processing
system.

Meteorological data used for the CALPUFF modeling analysis consisted of 3 years (2018-2020) of data
developed by the Forest Service. The grid was 708 km (east-west) by 492 km (north-south) with a
resolution of 12 kilometers.

VI. RESULTS AND CONCLUSIONS

The Applicant performed a series of analyses to estimate the impact from the proposed project. Modeling
results and conclusions from the review of the analyses are outlined in detail below.

A. Pre-Construction Monitoring and Significant Impact Modeling

The Applicant performed a preliminary criteria pollutant analysis of the proposed modification. This
analysis indicated that increases in concentration levels of PM2.5 and PM10 were greater than the Class II
SIL, and therefore, a cumulative analysis for these pollutants was required.

DAQE-MN103030032-24
Page 7

B. NAAQS Analysis

The Applicant performed a modeling analysis to determine if the combined impact from the proposed
source, other industrial sources operating in the area, and ambient background would comply with the
NAAQS. The NAAQS analysis was reviewed by the Division and determined to be consistent with the
requirements of R307-410-3. Table 4 provides a comparison of the Applicant’s predicted air quality
concentrations and the NAAQS.

Table 4: Model Predicted NAAQS Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-hour 28.3 5 65.4 0 93.7 150 62.5%
PM2.5 24-hour 9.6 1.2 10.2 0 19.8 35 56.6%
Annual 4.4 0.3 4.2 0 8.6 9 95.6%
* Note: Only included other sources and background if source impact was above Class II SIL

C. PSD Class II Increments

The Applicant performed an analysis to determine if the impact from the proposed source would comply
with PSD Class II increments. The analysis was reviewed by the Division and determined to be
consistent with the requirements of R307-410-3. Table 5 provides a comparison of the predicted
concentrations and the PSD Class II increment.

Table 5: Model Predicted PSD Class II Increment Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Nearby
Sources*
Total Increment Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
PM10 Annual 8.1 1 0 8.1 25 32.4%
24-hour 28.3 5 0 28.3 30 94.3%
PM2.5 24-hour 6.1 1.2 0 6.1 9 67.8%
Annual 2.4 0.3 0 2.4 4 60.0%

D. Hazardous Air Pollutants

DAQE-MN103030032-24
Page 8
The Applicant performed an analysis to determine if HAP modeling is required. The analysis was
reviewed by the Division and determined to be consistent with the requirements of R307-410-3. The
analysis indicated that HAP modeling was not triggered by this modification, and therefore no HAP
modeling was performed.

E. PSD Class I Increment Consumption Analysis

The Applicant performed a CALPUFF analysis to determine if the impact from the proposed source along
with other increment consuming sources would comply with federal PSD Class I increments. The
analysis was reviewed by the Division and determined to be consistent with the requirements of R307-
410-3. The results for all Class I areas within 300 kilometers are provided in Table 6.

Table 6: Model Predicted PSD Class I Increment Concentrations

Air Period Prediction
Class I
Significant
Impact
Level
Other
Sources* Total Increment Percent
Pollutant (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
Capitol Reef
NO2 Annual 0.0018 0.1 2.5
SO2
3-Hour 0.0494 1 25
24-
Hour 0.0150 0.2 5
Annual 0.0008 0.1 2
PM2.5
24-
Hour 0.0430 0.27 2
Annual 0.0021 0.05 1
PM10
24-
Hour 0.0444 0.3 8
Annual 0.0021 0.2 4
Arches
NO2 Annual 0.0008 0.1 2.5
SO2
3-Hour 0.0408 1 25
24-
Hour 0.0102 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0522 0.27 2
Annual 0.0018 0.05 1
DAQE-MN103030032-24
Page 9
PM10
24-
Hour 0.0531 0.3 8
Annual 0.0019 0.2 4
Canyonlands
NO2 Annual 0.0010 0.1 2.5
SO2
3-Hour 0.0354 1 25
24-
Hour 0.0100 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0577 0.27 2
Annual 0.0019 0.05 1
PM10
24-
Hour 0.0591 0.3 8
Annual 0.0020 0.2 4
Bryce
NO2 Annual 0.0006 0.1 2.5
SO2
3-Hour 0.0369 1 25
24-
Hour 0.0082 0.2 5
Annual 0.0003 0.1 2
PM2.5
24-
Hour 0.0189 0.27 2
Annual 0.0010 0.05 1
PM10
24-
Hour 0.0194 0.3 8
Annual 0.0010 0.2 4
Zion
NO2 Annual 0.0011 0.1 2.5
SO2
3-Hour 0.0293 1 25
24-
Hour 0.0105 0.2 5
Annual 0.0005 0.1 2
PM2.5
24-
Hour 0.0266 0.27 2
Annual 0.0011 0.05 1
PM10 24-
Hour 0.0271 0.3 8
DAQE-MN103030032-24
Page 10
Annual 0.0012 0.2 4
* Note: Only included other increment consuming sources if source impact was above Class I SIL

Since the proposed project’s model predicted impacts at the Class I areas were less than the PSD Class I
significance levels, a cumulative analysis was not warranted.

DAQE-MN103030032-24
Page 11
F. Visibility – Plume Blight
Since the Class I areas are greater than 50 kilometers from the source, a plume blight analysis using
VISCREEN was not required.

G. Visibility – Regional Haze

The results of the Q/D analysis for the emissions increase was less than 10 but the FLMs wanted the
entire source included in the Q term. The results of including the total emissions resulted in a Q/D >10,
so an AQRV analysis was performed for visibility and acid deposition. The results shown in Table 7
indicate that the impacts are below the 0.5 Deciview (DV) threshold established by the National Park
Service, indicating that no further analysis is required.

Table 7: CALPUFF Visibility Results

Class I Area Year Maximum
Delta DV
98th
Percentile
change in
DV
#
Days
#
Days Threshold
(DV)
Below
Threshold
> 1 > 0.5
2018 0.248 0.06 0 0 0.5 Yes
Arches 2019 0.291 0.054 0 0 0.5 Yes
2020 0.216 0.106 0 0 0.5 Yes
2018 0.223 0.081 0 0 0.5 Yes
Canyonlands 2019 0.312 0.068 0 0 0.5 Yes
2020 0.186 0.085 0 0 0.5 Yes
2018 0.059 0.03 0 0 0.5 Yes
Bryce 2019 0.081 0.045 0 0 0.5 Yes
2020 0.071 0.03 0 0 0.5 Yes
2018 0.183 0.074 0 0 0.5 Yes
Capital Reef 2019 0.196 0.092 0 0 0.5 Yes
2020 0.126 0.078 0 0 0.5 Yes
2018 0.069 0.04 0 0 0.5 Yes
Zion 2019 0.123 0.039 0 0 0.5 Yes
2020 0.102 0.057 0 0 0.5 Yes

DAQE-MN103030032-24
Page 12

H. Acid Deposition

The Applicant performed a deposition analysis on impacts within the Class I areas. Results of the
analysis indicate that the impacts are below the deposition threshold (DAT) established by the National
Park Service, indicating that no further analysis is required

Table 8: CALPUFF Deposition Results for Highest Year

Class I Area
Total
Nitrate
Deposition
Total
Sulfate
Deposition
Deposition
Analysis
Threshold
(kg/ha/yr) (kg/ha/yr) (kg/ha/yr)
Canyonlands 0.0006 0.0003
0.005
Zion 0.0004 0.0002
Arches 0.0006 0.0003
Bryce 0.0006 0.0002
Capitol Reef 0.0011 0.0005

I. Soils and Vegetation Analysis

The Applicant performed an analysis to determine the extent of impacts from the proposed source on soil
and vegetation. Results of the analysis are presented in a supplemental document titled “Soil and
Vegetation Impact Analysis for the Leamington, UT Facility, June 29, 2023”. The analysis indicated that
predicted concentrations compared against the secondary NAAQS at several sensitive receptors would not
result in an adverse impact on soils and vegetation in the vicinity of the proposed project.

DP/JK:jg

DAQE-IN103030032-25

January 22, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Mr. Nelson:

Re: Intent to Approve: Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — ) A A v A ? A D @ A w D D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — ) A A v A ? A D @ A w D D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ash Grove Cement Company Ash Grove Cement Company - Leamington Cement Plant

Mailing Address Physical Address
P.O. Box 38069 Highway 132
Leamington, UT 84638 Leamington, UT 84638

Source Contact UTM Coordinates
Name: Cody Watkins 397000 m Easting
Phone: [phone] 4380100 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3241 (Cement, Hydraulic)

SOURCE INFORMATION
General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried on site),
are correctly proportioned, ground, and mixed and then fed into a rotating kiln. The kiln alters the
materials and recombines them into small stones called cement clinker. The clinker is cooled and ground
with gypsum and additional limestone into a fine powdered cement. The final product is stored on site for
later shipping. The major sources of air emissions are from the combustion of fuels for the kiln operation,
from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source of
emissions of PM2.5, PM10, NOx, CO, HAPs, and GHG. It is a minor source of SO2 emissions.
NSR Classification
Major PSD Modification

Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
DAQE-IN103030032-25
Page 4

Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

These changes result in increases in actual emissions but decreases in most potential emissions. There will
be an increase in the potential emissions of VOCs and greenhouse gases.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
DAQE-IN103030032-25
Page 5

Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
DAQE-IN103030032-25
Page 6

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, 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. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO 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. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
DAQE-IN103030032-25
Page 7

II.A.4 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)
II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area, and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, stacker systems. II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit-specific requirements.
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total air flow controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter
area; 9,865 acfm total air flow, controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are
controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each
is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6). II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The
following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for
NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.
II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low-pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

DAQE-IN103030032-25
Page 8

II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow through stack
E34.
II.A.18 Kiln Feed Alleviator A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the central material silo between the blending silos and the preheater. Raw feed is removed from the system near the top of the preheater tower.
II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The
coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter area;
1,700 acfm total air flow.
II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker
storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1): 1,800 acfm that discharges into the clinker tunnel.
II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
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II.A.27 Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during loading.
II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel, all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during loading. 512.BF3 (1,000 acfm) is located on top of the silo. II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement products. Dust generated
during milling is captured by a BHA pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).

II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates from stack G55 (finish mill stack).
II.A.32 Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4).
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1 thru 3).

II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total air flow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations.
II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This
baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

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II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.
II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023)
II.A.40 Dust Shuttle System A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides, surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the
fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

II.A.41 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons) Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
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II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)
THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)
CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)
PM: 0.02 lbs filterable PM per ton of clinker.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR 60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to approve alternative control measures, the permittee shall keep a copy of the submitted petition and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source
of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2).
[40 CFR 63 Subpart LLL]

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II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must 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 PM CPMS is not out of control. The owner/operator must 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 on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
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II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

II.B.1.e.3 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-165]
II.B.1.e.4 PM 40 CFR 60, Appendix A, Method 5, or 5I, or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three runs, with each
run at least 120 minutes in duration and each run collecting a sample of 60 dry standard cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 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. [R307-165]
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II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
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II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
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II.B.1.i 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 must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator 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 owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator 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 owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
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II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: Instances of water and/or chemical application to unpaved areas shall be recorded and maintained by the owner/operator. The ambient temperature shall be recorded any time water should be applied but cannot due to freezing conditions. [R307-401-8]
II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

The sprays shall operate whenever dry conditions warrant meeting the required opacity
limitations or as determined necessary by the Director. Water sprays shall not be required during
periods of freezing temperatures.

[R307-401-8]

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II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

C. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the kiln/raw mill stack

F. The owner/operator shall record the output of the system: including the quantity of NOx, CO, O2, THC, Hg, HCl, and CO2 emissions at the kiln stack

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an
affected source 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.

[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]
II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments, the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the results of the performance test demonstrating compliance with the filterable PM limit and using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust the SSOL developed in accordance with the results of the most recent PM performance test demonstrating compliance with the PM emission limit. The owner/operator shall use the PM CPMS to demonstrate continuous compliance with the SSOL in accordance with the requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

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II.B.4 Fuel Limitations: II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke F. Fuel Oil
G. Used Oil Fuel

H. Synthetic Fuel
I. Wood
J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 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. [R307-401-8]
II.B.4.b.2 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 owner/operator 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 in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

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II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight
A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation
C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit-no less than 1500oF for more than five minutes in any 60-minute period B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
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II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the Director. The calibration procedure and frequency shall be according to manufacturer's specifications. Use of factory-calibrated thermocouples for temperature measurement is approved. However, any other method of temperature measurement must be approved by the Director prior to use. The monitoring equipment for both temperature and oxygen content shall be located such that an inspector can at any time safely read the output. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall only operate the emergency engines for testing and maintenance purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency operation. [R307-401-8]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.5.b.2 To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From Source Submitted NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-IN103030032-25
Page 22

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-GN103030032H-25

January 22, 2025

Via Certified Mail 70190700000208349772

Don Shepherd
National Park Service
Air Resources Division
7333 W Jefferson Ave
Lakewood, CO 80235
[e-mail]

Dear Mr. Shepherd:

RE: Notice of Publication for Ash Grove Cement Company - Leamington Cement Plant – CDS A;
MACT (Part 63), Compliance Assurance Monitoring (CAM), Title V (Part 70) Major Source,
Major Criteria Source, Major HAP Source, Attainment Area, NSPS (Part 60),
Project Number: N103030032

On January 22, 2025, the Director has completed his review of a Prevention of Significant Deterioration
project submitted by Ash Grove Cement Company. Attached to this letter are the draft Approval Order
document (Intent to Approve) and the full engineering review. Following a 60-day review by the Federal
Land Managers, this project will be submitted for a 30-day public comment period. Written comments
received by the Division at this same address during these comment periods will be considered in making
the final decision on the approval/disapproval of the proposed Approval Order. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director at the Division in writing, a hearing
will be held in accordance with R307-401-7, UAC.

If you have any questions, please contact John Jenks, who may be reached at [phone].

Sincerely,

Jon L. Black, Manager
New Source Review Division

Enclosures: Engineering Review
Modeling Memo
Intent to Approve

JLB:JJ:jg
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

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State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
RN103030032
January 21, 2025
Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]
Dear Josh Nelson,
Re: Engineer Review:
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032
Please review and sign this letter and attached Engineer Review (ER) within 10 business days.
For this document to be considered as the application for a Title V administrative amendment, a
Title V Responsible Official must sign the next page.
Please contact John Jenks at [phone] if you have any questions or concerns about the ER.
If you accept the contents of this ER, please email this signed cover letter to John Jenks at
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 1

[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the
DAQ will consider any comments received and will issue the Approval Order.

If you do not respond to this letter within 10 business days, the project will move forward
without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue
an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 2

OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible
Official, as defined in R307-415-3, must sign the statement below. THIS IS STRICTLY
OPTIONAL.

If you do not want the Engineer Review to be considered as an application to administratively
amend your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will
require submittal of a separate Operating Permit Application to revise the Title V permit in
accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document:
Title V Operating Permit Application Due Dates clarifies the required due dates for Title V
operating permit applications and can be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality

“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate
and complete and request that this Approval Order be considered as an application
to administratively amend the Operating Permit.”

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 3

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N103030032
Owner Name Ash Grove Cement Company
Mailing Address P.O. Box 38069
Leamington, UT, 84638

Source Name Ash Grove Cement Company- Leamington Cement
Plant
Source Location Hwy 132
Leamington, UT 84638

UTM Projection 397000 m Easting, 4380100 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3241 (Cement, Hydraulic)

Source Contact Cody Watkins
Phone Number [phone]
Email [e-mail]

Billing Contact Cody Watkins
Phone Number 385.225.0615
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 30, 2022
Date of Accepted Application November 28, 2024

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 4

SOURCE DESCRIPTION

General Description
Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried
on site), are correctly proportioned, ground and mixed, and then fed into a rotating kiln. The kiln
alters the materials and recombines them into small stones called cement clinker. The clinker is
cooled and ground with gypsum and additional limestone into a fine powdered cement. The final
product is stored on site for later shipping. The major sources of air emissions are from the
combustion of fuels for the kiln operation, from the kiln, and from the clinker cooling process.
The Leamington cement plant is a major source for emissions of PM2.5, PM10, NOx, CO, HAPs
and GHG. It is a minor source of SO2 emissions.

NSR Classification:
Major PSD Modification

Source Classification
Located in Attainment Area,
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Proposal
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower, various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 6

These changes result in increases in actual emissions, but decreases in most potential emissions.
There will be an increase in the potential emissions of VOC and greenhouse gases.

EMISSION IMPACT ANALYSIS
The complete modeling review is located in DAQE-MN103030032-24. [Last updated January 14, 2025]

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 7

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 8

Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 9

Review of BACT for New/Modified Emission Units

1. BACT review regarding the Leamington Plant Upgrade Project
Any major stationary source or major modification subject to PSD review must undergo an
analysis to ensure the use of BACT. The requirement to conduct a BACT analysis is set forth in 40
CFR 52.21. Similarly, Utah requires the installation of BACT for all sources of air pollution under
R307-401-5(2)(d)), BACT is defined in 40 CFR 52.21 (and R307-401-2) as:

". . . best available control technology means an emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for each pollutant subject to regulation under
Act which would be emitted from any proposed major stationary source or major modification
which the Administrator, on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such source or modification
through application of production processes or available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion techniques for control of such
pollutant . . ."

Therefore, a BACT analysis is required for each new or physically modified emission unit for each
pollutant that exceeds an applicable PSD significant emission rate (SER). Since the PM10 and PM2.5
emissions from the proposed project exceed the applicable PSD SER, a BACT analysis is required
to assess the required levels of control for these pollutants. Because the CO2e emissions are subject
to regulation as a result of the proposed project resulting in an increase of 75,000 tons or more per
year CO2e, a BACT analysis is also required for that pollutant. Note that HAPs listed under CAA
Section 112(b)(1) are excluded from NSR (New Source Review) or PSD (i.e., BACT) review.

In a memorandum dated December 1, 1987, the United States Environmental Protection Agency
(EPA) stated its preference for a "top-down" BACT analysis. After determining if any New Source
Performance Standard (NSPS) is applicable, the first step in this approach is to determine, for the
emission unit in question, the most stringent control available for a similar or identical source or
source category. If it can be shown that this level of control is technically, environmentally, or
economically infeasible for the unit in question, then the next most stringent level of control is
determined and similarly evaluated. This process continues until the BACT level under
consideration cannot be eliminated by any substantial or unique technical, environmental, or
economic objections.

Presented below are the five basic steps of a top-down BACT review as identified by the EPA.
Step 1 - Identify All Control Technologies
Step 2 - Eliminate Technically Infeasible Options
Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Step 4 - Evaluate Most Effective Controls and Document Results
Step 5 - Select BACT

Ash Grove has elected to follow this methodology and based the BACT review on each individual
pollutant. The complete BACT analysis follows. [Last updated January 14, 2025]

2. BACT review regarding PM10 and PM2.5 Sources
PM10 and PM2.5 Modified Equipment
The existing kiln precalciner, preheater, and alleviator system are proposed to be modified, and the
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 10

kiln's ID fan and clinker cooler fans are proposed to be replaced, which will result in increased
airflow. Additionally, the clinker cooler baghouse will be converted from a plenum pulse to a pulse
jet baghouse. These modifications are projected to result in a net increase of potential PM10 and
PM2.5 emissions.

Kiln Upgrade BACT
The rotary cement kiln is the core of the cement manufacturing process, transforming the blended
raw materials or "rawmix" into clinker through pyro processing. Emissions from the kiln occur
from fuel combustion plus the physical and chemical reactions needed to transform the rawmix
into clinker. This project involves process and energy efficiency improvements and an increase in
kiln production, resulting in an increase of PM10 and PM2.5 emissions. This section specifically
addresses filterable PM10 and PM2.5. The condensable fraction is represented with the other
precursors as applicable to proposed emission increases.

The Leamington Plant's Kiln is subject to NSPS, Subpart F for particulate. Therefore, a BACT
analysis addresses applicability of the proposed changes to the kiln system to NSPS and review of
the RBLC. A summary of the resources reviewed include the following:

NSPS Subpart F - Standards of Performance for Portland Cement Plants establishes emission
standards for cement kiln operations. Specifically, kilns modified after June 16, 2008, are limited to
0.07 lbs PM/ton of clinker produced.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028) and
Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from kiln operations are as follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM emissions are most effectively controlled using a collection system with enclosures routed to
baghouses providing up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Ash Grove
has selected technology with the highest control efficiency, so there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 11

Step 5 - Select BACT
Ash Grove proposes that BACT for PM10 and PM2.5 emissions from the kiln consist of a collection
system routed to a baghouse or fabric filter that complies with NSPS Subpart F's emission standard
for a modified source. BACT for the Leamington Plant's kiln are 10% opacity and 0.07 lb of
PM/ton (NSPS Subpart F emission standard) of clinker.
[Last updated January 14, 2025]

3. BACT review regarding PM10 and PM2.5 sources cont.
Clinker Cooler Upgrade BACT
The clinker cooler reduces the temperature of the clinker exiting the kiln. It is necessary to reduce
clinker temperature before it enters the finish mill to maintain product quality and reduce wear and
tear on equipment. The clinker cooler is equipped with a heat exchanger that captures waste heat
and transfers it to the kiln preheater for process and energy efficiency. Emissions from the clinker
cooler are vented to a baghouse. The Leamington Plant's clinker cooler is also subject to NSPS
Subpart F for particulate. Ash Grove's proposed changes to the clinker cooler meet the definition of
a reconstruction under NSPS. Therefore, in order to meet the requirements of NSPS Subpart F, Ash
Grove will be required to meet a limit of 0.02 lb of PM/ton of clinker.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from clinker cooler operations are as
follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM10 and PM2.5 emissions are most effectively controlled using a collection system with enclosures
routed to a baghouse, which can achieve up to 99.9% control efficiency. Other technologies such as
wet scrubbers, cyclones and ESPs are feasible, but provide lower control efficiencies than a
baghouse. Because the most efficient control technology is proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for PM10 and PM2.5 emissions from the clinker cooler is a collection system routed to a
baghouse or fabric filter. In order to meet the requirements of NSPS Subpart F, Ash Grove will
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 12

meet a reduced emission limit of 0.02 lb of PM/ton of clinker. A 10% opacity limit is also
applicable. [Last updated January 14, 2025]

4. BACT review regarding PM10 and PM2.5 sources cont.
New Finish Mill BACT
The proposed Plant upgrade include adding a second finish mill. The new finish mill will use an
energy efficient vertical roller mill assisted with a grinding aid. A total of five (5) point sources are
planned for the finish mill. In accordance with NSPS Subpart F, emissions from finish mill are
restricted to 10% opacity. Ash Grove has reviewed the following sources to identify available
control technologies.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);12 and

Region 8 General Permit for Concrete Batch Plants.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 emissions from plant material handling operations are as
follows:
Baghouse / Fabric Filter;
Best Management & Operational Practices;
Cyclone;
ESP;
Enclosure;
Water Application (Watering); and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
With the exception of water application, all options are technically feasible. Water application is
eliminated as clinker exiting the kiln along with additives in the finish mill must remain dry to
maintain product quality. Therefore, it is technically infeasible to water material in the finish mill.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Enclosure 50-90%
5. Cyclone 20-70%
6. Best Management & Operational Practices varies

Step 4 - Evaluate Most Effective Controls and Document Results
Baghouses provide the highest emission control efficiency, controlling up to 99.9% of PM
emissions from finish mill equipment. After baghouses, using a wet scrubber or ESP provides
similar PM control. Notably, baghouses, scrubbers, and ESPs require enclosures to aid in capturing
emissions and ducting to the control. Therefore, optimal PM emission control can be achieved
through implementing both baghouses and enclosures where feasible. Plant material sizing and
handling is currently done using a series of buildings and enclosures routed to baghouse controls.
Various silos storing material inputs are also equipped with fabric filters. As the highest ranked
technology is applied, there are no adverse energy, environmental or cost impacts to consider with
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 13

the use of these control technologies. Thus, no further analysis is required under EPA's top-down
BACT approach.

Step 5 - Select BACT
BACT for finish mill PM10 emissions is compliance with NSPS Subpart F, Standards of
Performance for Portland Cement Manufacturing where applicable. Ash Grove will achieve BACT
for PM10 emissions from finish mill equipment through the implementation of enclosures,
baghouses, and best management practices. All baghouses at the finish mill will have a 10%
opacity limitation and a grain loading of 0.005 grains/dscf. [Last updated January 14, 2025]

5. BACT review regarding PM10 and PM2.5 sources cont.
Material Transfer, Sizing, and Storage BACT
The Leamington Plant has sources of fugitive emissions through raw material transfer. Materials
transferred include limestone and other raw materials, coal, clinker, and cement. These materials
are transferred by conveyor belt, screw conveyor, elevator, pneumatic conveyance or chutes via
gravity. At the Leamington Plant the fugitive emissions are enclosed at their transfer points and
routed to baghouses.

The following emission units are included in this category:
Limestone Crushing, Sizing, and Material Transfer;
Raw Material Transfer;
Coal Sizing and Transfer;
Existing Finish Mill;
Clinker Storage and Transfer;
Cement Storage and Truck and Rail Cement Loadout;
New Rail Loading and Loadout; and
New Clinker Reclaim Hopper Baghouse.

Generally, controls for these units have not changed or they are similar to current existing controls.
A full BACT analysis of each unit is included in Ash Grove's NOI and additional submitted
information. However, given that most controls remain unaltered, only the results of Step 5 -
Select BACT will be included here.

Limestone Crushing, Sizing, and Material Transfer
Subject to NSPS Subpart OOO opacity limits for existing sources.
Existing baghouses. No change from bag manufacturer's specifications.

Raw Material Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Coal Storage and Transfer
Existing Equipment. No change from bag manufacturer's specifications
20% Opacity

Clinker Storage and Transfer
Subject to NSPS Subpart F opacity limits:
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 14

10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Existing Finish Mill Grinding, Storage and Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Cement Storage and Truck and Rail Cement Loadout, New Rail Loadout
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

New Rail Loadout, controlled by baghouse
Emissions Limit - 0.005 gr/dscfm

New Clinker Reclaim Hopper, controlled by baghouse
Subject to NSPS Subpart F opacity limits:
10% opacity
Emissions Limit - 0.005 gr/dscfm [Last updated January 14, 2025]

6. BACT review regarding PM10 and PM2.5 sources cont.
PM10 and PM2.5 Fugitive Emissions
The following fugitive emissions sources will increase emissions of PM10 and PM2.5 as a result of
the Leamington Plant's proposed throughput increase. The sources addressed in the following
BACT analyses are primarily in the quarry, but also include emissions from roads and dumping of
raw materials within the plant boundary.

The sources evaluated are listed below:
Roads;
Loading and Unloading;
Stockpiles;
Bulldozing and Grading;
Disturbed Areas; and
Drilling and Blasting.

Ash Grove currently controls emissions from these processes, and generally, controls for these
units have not changed. A full BACT analysis of each unit is included in Ash Grove's NOI and
additional submitted information. However, given that most controls remain unaltered, only the
results of Step 5 - Select BACT will be included here.

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 15

Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

Stockpiles BACT
BACT shall consist of restricting fugitive emissions to the opacity standard of 20% opacity at the
property boundary. BACT for stockpiles will be achieved through applying good management
practices through its fugitive dust plan as appropriate.

Bulldozing and Grading BACT
BACT shall consist of restricting fugitive emissions from bulldozing and grading activities to no
more than 20% opacity, and that emissions are controlled with periodic watering of the disturbed
surface. The frequency of water application will depend on ambient weather conditions and
inherent moisture content of the material being moved.

Disturbed Areas BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. BACT for
disturbed areas will be achieved through best management practices, watering, scarification, and
revegetation.

Drilling and Blasting BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. This is achievable
through best management practices, shrouds, watering, and dust collection. [Last updated January
14, 2025]

7. BACT review regarding kiln system NOx emissions
Kiln System (Kiln, Raw Mill, and Coal Mill) - NOx BACT
Although there are physical changes to the kiln system, these changes are primarily related to
particulate emissions. NOx emissions are generated from the combustion of fuel - and no changes
in NOx emissions are expected from the kiln (hourly capacity to emit). The kiln NOx emissions will
remain the same as a result of upgrades to the SNCR system. The replacement of the various
components of the kiln system and portions of the preheater tower, along with new injection points,
will ensure that increased mixing of ammonia is achieved to enhance the SNCR system's ability to
reduce NOx and minimize ammonia slip. This will allow the Leamington Plant to maintain the NOx
hourly capacity to emit unchanged from current levels Leamington Plant Upgrade Project. At
present Ash Grove has no restriction on the amount of fuel combusted, only a limit on total NOx
generated, and with this project the allowed NOx PTE is decreasing from 1,352 tpy to 1,226 tpy.

Additional ammonia will be used in the existing SNCR system. While the SNCR system has
adequate capacity to accommodate the additional ammonia demand resulting from the system
upgrades, more ammonia ports are proposed to be added with the kiln system's proposed changes
of the equipment. The changes proposed to the kiln system will increase residence time and
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temperature which will improve the SNCR system's effectiveness to control NOx emissions and
minimize ammonia slip emissions to the atmosphere. No additional review of NOx BACT for the
kiln system is required under this proposal. [Last updated January 14, 2025]

8. BACT review regarding new finish mill heater emissions
Finish Mill Heater
The proposed finish mill will include a process heater to maintain a minimum temperature during
milling. The proposed heater will run on natural gas and is rated at 10 MMBtu/hr. Startup and
shutdown emissions from the heater are anticipated to be no greater than normal operation as the
process is simply a matter of bringing the heater to operating temperature. Emissions evaluated in
the BACT analysis for the finish mill heater include NOx, SO2, CO, and VOCs, PM10, and PM2.5.
Pollutants with identical control technologies are grouped together in the analysis.

NOx - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for NOx from units of this size range are as follows:
Ultra-Low-NOx Burners (ULNB);
Low NOx Burners;
Selective Catalytic Reduction (SCR);
Selective Noncatalytic Reduction (SNCR);
Good Combustion Practices; and
Use of Natural Gas.

Step 2 - Eliminate Technically Infeasible Options
Low exit temperatures render the use of SCR and SNCR ineffective. Particulate entrainment within
the finish mill could potentially foul (plug) the nozzles of ULNB. Low-NOx burners, the use of
natural gas as fuel and good combustion practices are all considered technically feasible.

Step 3 and Step 4 - Rank Remaining Control Technologies by Control Effectiveness and Evaluate
Most Effective Controls and Document Results
Since the three feasible control technologies are proposed for the finish mill heater, no detailed
economic, energy, and environmental impact evaluations were conducted. No ranking of control
effectiveness is required as all three controls are proposed.

Step 5 - Select BACT
BACT for NOx is the use of natural gas as fuel, good combustion practices and the use of Low NOx
burners.

CO, SO2, and VOC - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for CO, SO2, and VOC from units of this size are as follows:
Good Combustion Practices
Use of Natural Gas

The finish mill heater combusts natural gas. Related natural gas combustion emissions are
anticipated to be minimal.

Step 2 - Eliminate Technically Infeasible Options
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Both control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Both technologies offer intrinsic emission reductions from combustion. Since the technologies do
not compete, both technologies can and will be used simultaneously.

Step 4 - Evaluate Most Effective Controls and Document Results
Because both control technologies identified in Step 1 are proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for CO, SO2, and VOC are good combustion practices and the use of natural gas.

PM10 and PM2.5 BACT for the finish mill has been addressed in the PM10/PM2.5 sources section.
[Last updated January 14, 2025]

9. BACT review regarding SO2, VOC, and Lead Sources
The following BACT analysis is grouped by pollutants that will experience an increase in potential
emissions and the associated technically feasible control technologies. As such, the BACT analysis
is separated into SO2, VOC, and lead respectively with organic HAPs addressed with VOCs.

SO2 - Cement Kiln BACT
NSPS Subpart F - Standards of Performance for Portland Cement Plants, establishes emission
standards for cement kiln operations. Specifically, kilns constructed or reconstructed after June 16,
2008, are limited to 0.4 lbs SO2/ton clinker on a 30-day rolling average respectively. This limit is
an existing emission limit in the Leamington Plant's approval order and Title V. Ash Grove will
continue to achieve this emission limitation while achieving BACT for the kiln operations. Ash
Grove has reviewed the following sources to identify available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019); and

NSPS Subpart F as an affected emissions facility in 40 CFR 60.62(a)(4);

Portland Cement Association's Formation and Techniques for Control of Sulfur Dioxide and Other
Sulfur Compounds in Portland Cement Kiln Systems.

SO2 emissions are a result of oxidation of sulfur compounds in the rawmix and/or the coal used to
fire the kiln. However, the alkaline nature of the cement provides for direct absorption of SO2 into
the product, thereby mitigating the quantity of SO2 emissions in the exhaust stream.

Step 1 - Identify All Control Technologies
Control technologies identified for SO2 emissions from coal-fired kiln operations are as follows:
Baghouse or fabric filter;
Dry reagent injection prior to baghouse;
Wet scrubber;
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Process optimization; and
Good combustion practices.

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below:

1. Process Optimization 99%
2. Wet Scrubber 99%
3. Dry Reagent Injection 60%
4. Good Combustion Practices 30%
5. Baghouse Variable

Step 4 - Evaluate Most Effective Controls and Document Results
SO2 emissions are most effectively controlled by optimizing the process and utilizing the inherent
SO2 scrubbing properties of the kiln system itself. Although wet scrubbers alone can achieve equal
control efficiencies as process optimization, additional capital and operational expenses are
required for water consumption and wastewater discharge. Whereas process optimization achieves
the same control effectiveness and has the added benefit of reduced operational costs. Ash Grove
optimizes the kiln process by routing the exhaust from the kiln to a preheater and raw mill to
interact with the raw mix, thus creating an atmosphere similar to a dry scrubber system. Good
combustion practices also reduce SO2 formation with the added benefit of energy efficiency.

Step 5 - Select BACT
BACT for control of SO2 emissions from kiln operations shall consist of process optimization by
routing kiln exhaust to the preheater and raw mill, good combustion practices, and use of a
baghouse prior to exhausting to the atmosphere. As a modification of the kiln, 40 CFR 60.62(a)(4)
requires an emission limit of 0.4 pounds of sulfur dioxide (SO2) per ton of clinker on a
30-operating day rolling average. [Last updated January 14, 2025]

10. BACT review regarding SO2, VOC, and Lead Sources cont.
VOC - Cement Kiln BACT
VOCs are generated by incomplete combustion in the kiln. 40 CFR 63 Subpart LLL - NESHAP
from the Portland Cement Industry limits total hydrocarbon and total organic HAP emissions to 24
and 12 ppmv at 7% oxygen. Ash Grove will achieve or exceed these emission limitations while
achieving BACT for the kiln operations. Ash Grove has reviewed the following sources to identify
available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028); and

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for VOC emissions from coal fired kiln operations are as follows:
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Process optimization,
Good combustion practices

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below.

1. Process Optimization Variable
2. Good Combustion Practices Variable

Step 4 - Evaluate Most Effective Controls and Document Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove optimizes the
kiln process by capturing waste heat from the clinker cooler and routing to a kiln preheater. Good
combustion practices also reduce VOC formation with the added benefit of energy efficiency.
There are no adverse energy, environmental or cost impacts to consider with the use of this control
technology.

Step 5 - Select BACT
BACT for control of VOC emissions from kiln operations shall consist of process optimization by
routing kiln heat to the preheater and good combustion practices. An emission limit of 24 ppmv
VOC @ 7% O2 is imposed by NESHAP Subpart LLL.

VOC - Grinding Aid BACT
A grinding aid containing VOC is added to the new finish mill to disperse particles within the mill
and expose more surface area to grinding. An increase in grinding aid usage proportionally
increases potential VOC emissions because volatiles from the grinding aid are not combusted in
the kiln.

There is only one identified control option for limiting the VOC emissions from the grinding aid.
Process optimization is technically feasible. VOC emissions are most effectively controlled by
optimizing the process. Ash Grove proposes to install a vertical finish mill with this project. Due to
the new modern mill's efficiency, it is anticipated that a reduced amount of grinding aid will be
required for each ton of clinker ground. Ash Grove estimates total VOC emissions from the
grinding aid at 2.37 tpy.

Lead Emissions
The lead emissions are anticipated to increase as a result of the proposed increase in clinker
throughput with the Leamington Plant upgrade project. Lead emissions result from residual
amounts of lead in raw materials and fuel. Lead emissions will be controlled the same as PM,
therefore a separate top-down BACT analysis has not been conducted as the Leamington Plant has
applied the most effective controls. [Last updated January 14, 2025]

11. BACT review regarding Greenhouse Gases
GHG Background
On October 9, 2009, the mandatory GHG reporting regulation, referred to as 40 CFR 98, was
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published in the Federal Register. Through 40 CFR 98, the U.S. EPA established the GHG
Reporting Rule, which requires the annual reporting of GHG data and other relevant information
from large sources and suppliers in the United States. Monitoring through the GHG Reporting
Program (GHGRP) began in 2010, with the first reports due by March 31, 2011. Per 40 CFR
98.2(a)(1), any facility associated with cement production is subject to the GHGRP and must report
CO2e emissions. The CO2e is the sum of equivalent GHG emissions from CO2, CH4, and N2O,
with their respective global warming potentials (GWP) applied. Ash Grove's facility is subject to
GHG Reporting Rule and monitors CO2 emissions from its kiln with a continuous emissions
monitoring system (CEMs). On June 23, 2014, the U.S. Supreme Court held that required PSD
permits (based on emissions of non-GHG pollutants) may continue to require limitations on GHG
emissions based on the application of BACT as an "anyway source". The Leamington Plant
modification project is a major source for PSD for both PM10 and PM2.5, and GHGs are estimated
to be greater than 75,000 tpy and greater than zero on a mass basis; therefore, GHGs are evaluated
for BACT as an anyway source.

Cement Manufacturing GHG BACT
A BACT analysis has been conducted for CO2e emissions from the kiln system. For this GHG
BACT analysis, various control technologies or combinations of technologies were identified using
the RACT/BACT/LAER Clearinghouse, available literature including guidance published by EPA
and South Coast Air Quality Management District (SCAQMD), current air regulations, other
regulatory organizations, and engineering experience. In March 2011, EPA published GHG
permitting guidance, as well as a white paper on available and emerging technologies for reducing
GHG emissions from the Portland cement industry in October 2010. Additionally, EPA published a
series of videos on GHG permit training in December 2010. The SCAQMD published GHG BACT
guidance in 2021. Additional sources of information were reviewed and documented based on
publications from trade organizations and other governmental committees with GHG or carbon
reduction guidelines and/or recommendations.

EPA has defined in 40 CFR 86.1818-12(a) GHGs as a group of six gases: CO2, nitrous oxide
(N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF6). GHG emissions from the kiln result from calcination and fuel combustion.
Since the primary GHG emitted by a kiln is CO2, the BACT analysis focuses on CO2 emissions
from the kiln. Emissions of CH4 and N2O are minimal from cement kilns. Per EPA guidance, GHG
control technologies for consideration in a BACT analysis for Portland Cement Manufacturing
include:

Source-wide energy efficiency strategies;
Raw material substitution;
Blended cements;
Carbon capture utilization and storage; and
Fuel switching.
Other emerging technologies [Last updated January 14, 2025]

12. BACT review regarding Greenhouse Gases cont.
Step 1: Identify All Control Technologies
The CO2 emissions from a cement kiln are generated by the calcination process (conversion of the
calcium carbonate in limestone to calcium oxide) and by combustion of fuel in the kiln. Potential
control technologies to reduce these CO2 emissions for a cement kiln are addressed in EPA's white
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paper on Available and Emerging Technologies for Reducing GHG Emissions from the Portland
Cement Industry.

These technologies fall into three categories:
Energy Efficiency Improvements for the Clinker Production Process
Fuel Substitution
Carbon Capture and Sequestration

Step 2: Eliminate Technically Infeasible Options
Several potential energy efficiency improvements are technically feasible: Pre-heater/Pre-calciner
Kiln Process, Kiln Seal Management Program, Refractory Selection (Kiln Insulation), and Energy
Recovery from the Clinker Cooler. The use of alternative fuels such as natural gas, whole tires and
biofuel) is also technically feasible. Other control options, such as Use of Fluxes and Mineralizers,
Heat Recovery for Power - Cogeneration, Carbon Sequestration, Oxyfuel combustion, and
Post-combustion Capture have been deemed infeasible.

Step 3: Rank Remaining Control Technologies by Control Effectiveness
All four remaining control techniques are currently implemented at the Leamington Plant. This
permitting project incorporates energy efficiency improvements. Ash Grove has had a fuel
substitution program in place for several years, and this program is continually reviewed and
updated as new sources and types of fuel are identified.

Step 4: Evaluate Most Effective Controls and Document Results
Since all technically feasible energy efficiency improvements and changes to product composition
will be implemented, this section will focus on economic and environmental considerations of fuel
substitution to operate exclusively on natural gas.

Firing natural gas as the primary kiln fuel can reduce CO2 emissions from fuel combustion by as
much as 40%. However, studies have shown that use of natural gas as primary kiln fuel can result
in three times more NOx emissions than NOx emissions from coal firing. Creating more NOx to
reduce GHG emissions is undesirable as it is a precursor to both ozone and PM2.5. Fuel substitution
essentially trades emissions of one regulated pollutant for another. Estimated capital cost to switch
to natural gas fuel exceeds $25M. Implementing natural gas technology would provide incremental
public health and welfare benefit globally by reducing CO2 emissions, while increasing NOx
emissions and negatively impacting public health and welfare locally. Switching fuels to another
fossil fuel has finite potential to mitigate CO2 emissions.

Step 5: Select BACT
In addition to the proposed energy efficiency improvements addressed elsewhere in this BACT
analysis, BACT is a limit of 0.92-ton CO2e/ton clinker. Ash Grove will use a continuous emission
monitoring system (CEMS) for CO2 to demonstrate compliance with this limit. [Last updated
January 14, 2025]

13. BACT review regarding Leamington Plant Upgrade Project conclusion
The control processes and techniques covered in this BACT analysis have been reviewed by the
NSR Section of the UDAQ. Ash Groves proposed controls and associated emission limitations
represent BACT. Any emission limitations not expressed in an associated NSPS or NESHAP will
be included in the terms and conditions of this AO. A listing of all associated NSPS and NESHAP
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programs is also included in the Source Information section of this document under Applicable
Federal Programs. [Last updated December 13, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
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.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date
of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
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proper credit when notifying the Director, send the documentation to the Director, attn.: NSR
Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

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

II.A.3
NEW
Stockpiles
Coal storage
Area: 1 acre
Annual throughput 20,000 tpy

AF and ARM stockpiles
Area: 0.25 acre
Annual throughput 8,000 tpy

II.A.4 Stationary Crusher
Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction
of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000
acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)

II.A.5 Raw Material Transfer
Crushed material is transported to raw material storage by belt B8. The raw material transfers
at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor
transfer point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total
filter area & water sprays. (pre-1983)

II.A.6 Material Handling
Conveyor belt systems, secondary feeders and screens, stacker system

II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit specific requirements

II.A.8 Belt Conveyor Transfer Baghouse
Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area
and 1,800 acfm total air flow, controls emissions from the conveyor belt that transfers the
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stacked material to the raw material silos.

II.A.9 Raw Material Silos
Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The
four silos are equipped with one common Fuller, plenum pulse baghouse (315.BF1) - 1,689 ft2
filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage).

II.A.10 Fifth Component Silo
Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse
(315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw
mill feed. This system includes vibrating feeders, a conveyor system, and surge bin.
Emissions are controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3,
316.BF4, 316.BF5) - each is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1
A/C ratio.

II.A.12 Cross-Belt Analyzer
Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6)

II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom
of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw
materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38).
The following equipment is installed: low-NOx burner, selective non-catalytic reduction
(SNCR) for NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued
mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric
monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct
for mercury adsorption capacity. The carbon injection system is not an emission point as it is
in an enclosed building.

II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

II.A.16 Two Kiln Feed Blending Silos
Raw material is blended in one of two blending silos prior to feeding the kiln. The blending
silos are controlled by one common Fuller, plenum pulse baghouse (411.BF1) - 1,351 ft2 filter
area; 7,160 acfm total air flow.

II.A.17 Blending Silo Elevators (2)
Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped
with a Fuller, pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow
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through stack E34.

II.A.18 Kiln Feed Alleviator
A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the
central material silo between the blending silos and the preheater. Raw feed is removed from
the system near the top of the preheater tower.

II.A.19 Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner.
The coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter
area; 1,700 acfm total air flow.

II.A.20 Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in
the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2):
19,500 acfm rated airflow with 3.75:1 A/C ratio

II.A.21 Clinker Cooler and Baghouse
Reconstructed grate type cooler used for cooling clinker from the kiln prior to transfer to
clinker storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) -
173,869 acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter
monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two
clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse
(419.BF8). The exhaust is routed to the clinker cooler stack.

II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions
generated when loading the east and west clinker silos and the out-of-spec silo are controlled
by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1):
1,800 acfm, that discharges into the clinker tunnel.

II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm, that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2)
Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers.
Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses
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(511.HP1 and new 511.HP2): 1,800 acfm each.

II.A.27 Gypsum Silo
Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2
total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust
during loading.

II.A.28 Clinker Tunnel Exitway
The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse
(511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel all discharge in the clinker tunnel.
Emissions are vented through the tunnel exitway.

II.A.29 Limestone Silo
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust
during loading. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement product. Dust
generated during milling is captured by a BHA, pulse jet baghouse (514.BF2) - 6,080 ft2 filter
area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding
stack).

II.A.31 Finish Mill (Ball Mill) Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized
cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA, pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow
controlling particulates from stack G55 (finish mill stack).

II.A.32
NEW
Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The
stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4)
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1,
525.BF1 thru 3)

II.A.33 Finish Cement Storage Silos
There are six storage and two interstice silos where the finished cement product is stored. A
single common Fuller, plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm
total air flow through stack H7 is located on top of the silos and is used to control emissions
during loading and unloading operations.

II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail
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shipping. This baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out
The cement loadout system located on the South side of the silos (truck load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF2) during unloading from the silos for truck
shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement
conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed
space inside the silos.

II.A.36
NEW
Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

II.A.37 MHO: Materials Handling Operation
Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1
& 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4;
512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.

II.A.38 LBS: Limestone Bypass System
Additional limestone is added to the clinker and gypsum by the limestone bypass system
(LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays
at the screen and material handling drop points.

II.A.39 GEN: Emergency Generators
One diesel-fired emergency generator (new)
Rating: 762 hp
(Kiln, Tier 3, permitted 2022)

Two natural gas-fired emergency generators
Rating: 304 hp
(Main office and control room, permitted in 2023)

One diesel-fired emergency generator
Rating: 560 hp
(Shipping, permitted 2023).

II.A.40 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14 inch knife gate, 8 inch knife gate, 8 inch air
slides, surge bin), and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm)
on the fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

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II.A.41
NEW
Miscellaneous Storage Tanks
One diesel storage tank (<2,000 gallons)
One gasoline storage tank (500 gallons)
Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Requirements on the Cement Plant:
II.B.1.a
NEW
The following limits shall not be exceeded:

A. Clinker production - 1,155,000 tons per rolling 12-month period

B. Used oil consumption - 85,724 gallons per rolling 12-month period

C. Limestone bypass material processed - 216,260 tons per rolling 12-month period.
[R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 25th day of each month using data from the previous 12 months.
Records shall be kept for all periods when the plant is in operation. Consumption and
production shall be calculated through use of the plant's acquisition system. [R307-401-8]

II.B.1.b
NEW
Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations:

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

SO2: 0.4 lbs per ton of clinker (3-hr average)

CO: 3,395 tons per rolling 12-month period, and 6,600 lbs/hr

NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average, and 1,233 tons per rolling
12-month period

Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is
400oF or less.

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Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)

THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)

CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)

PM: 0.02 lbs filterable PM per ton of clinker. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL,
R307-401-8]

II.B.1.c
NEW
A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR
60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust
emissions control plan shall be monitored to demonstrate that appropriate control measures are
being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of
the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall
be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in
the plan and that the source is operating in accordance with the submitted plan. For petitions
to approve alternative control measures, the permittee shall keep a copy of the submitted
petition and any approvals received. [40 CFR 60 Subpart Y]

II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area
source of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2). [40 CFR
63 Subpart LLL]

II.B.1.e
NEW
Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b
and II.B.1.d shall be performed as specified below:

A. Kiln/Raw Mill Stack
Pollutant Test Status Test Frequency
PM * #

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

B. Clinker Cooler (F31)
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Pollutant Test Status Test Frequency
PM + #

C. Testing Status (To be applied above)
* The initial testing has already been performed.

** The SO2 initial performance test was conducted on August 26, 2013.

*** The initial compliance test shall be conducted within the first 30 operating days of
operation in which the affected source operates using a CEMS.

# Test once every year. If performance testing would be required less than 15 operating days
after the Kiln has completed Startup after being down for more than 24 hours, then
performance testing may be deferred up to 15 operating days after completion of the Startup.
The Director may require testing at any time.

## Test at least once every two years. The Director may require testing at any time.

+ Initial testing is required within 180 days of startup of the reconstructed equipment

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must 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 PM CPMS is not out-of-control. The owner/operator must
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 on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

+++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.e.1
NEW
Notification
The Director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The notification requirements for performance tests subject to 40
CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-165]

II.B.1.e.2
NEW
Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational
Safety and Health Administration (OSHA)- or Mine Safety and Health Administration
(MSHA)-approved access shall be provided to the test location. [R307-165]

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II.B.1.e.4
NEW
PM
40 CFR 60, Appendix A, Method 5 or 5I or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three (3) runs with
each run at least 120 minutes in duration and each run collecting a sample of 60 dry standard
cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.3
NEW
Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2. [R307-165]

II.B.1.e.5
NEW
Carbon Monoxide (CO)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.6
NEW
Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.7
NEW
Sulfur Dioxide (SO2)
40 CFR 60, Method 6 or 6C of Appendix A-4 or other EPA-approved method as acceptable to
the Director. [R307-165]

II.B.1.e.8
NEW
Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]

II.B.1.e.9
NEW
Total Hydrocarbons (THC)
Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL]

II.B.1.e.10
NEW
Mercury (Hg)
Continuous Emission or integrated sorbent trap monitoring (See Condition II.B.3.a). [40 CFR
63 Subpart LLL]

II.B.1.e.11
NEW
HCl
Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other
EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]

II.B.1.e.12
NEW
Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.13
NEW
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. [R307-165]

II.B.1.e.14
NEW
Existing Source Operation
For an existing source/emission point, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three years.
[R307-165]

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II.B.1.e.15
NEW
New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the maximum production rate listed in this AO. If the maximum AO
allowable production rate has not been achieved at the time of the test, the following
procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This new
allowable maximum production rate shall remain in effect until successfully tested at a higher
rate.

3) The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate (110%
of the new rate) will then be allowed if the test is successful. This process may be repeated
until the maximum AO production rate is achieved. [R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL.
[40 CFR 63 Subpart LLL]

II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times
of Dust Shuttle System operation to assist in the capture of Mercury emission. [R307-401-8]

II.B.1.h
NEW
Visible emissions from the following emission points shall not exceed the following values:

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

L. All baghouses - 10% opacity
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M. Fugitive dust - 20% opacity

N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y,
R307-401-8]

II.B.1.i 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 must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

If any partially enclosed or unenclosed conveying system transfer point is located in a
building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to
40 CFR 60, according to the following:

(i) The owner/operator must conduct a monthly ten-minute visible emissions test of each
affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The
performance test must be conducted while the affected source is in operation.

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator 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 owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iii) If no visible emissions are observed during the semi-annual test for any affected source,
the owner/operator 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 owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iv) If visible emissions are observed during any Method 22 performance test, of Appendix
A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations,
recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60.
The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour
of any observation of visible emissions.

(v) If visible emissions from a building are monitored, the requirements of paragraphs (i)
through (iv) of this Condition apply to the monitoring of the building, and the owner/operator
must also test visible emissions from each side, roof, and vent of the building for at least ten
minutes. [R307-401]

II.B.1.j
NEW
Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed
0.005 gr/dscf:

520.BF1
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520.BF2
520.BF3
520.BF4
521.BF2
521.BF1
524.BF1
524.BF2
524.BF4
524.BF3
525.BF1
525.BF2
525.BF3
511.HP2
NRL_UPR
NRL_LWR. [R307-401-8]

II.B.1.j.1
NEW
To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration
through at least three (3) annual tests that the PM limits are not being exceeded, the
owner/operator may request approval from the Director to conduct stack testing less
frequently than annually. [R307-401-8]

II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive
dusts as dry conditions warrant or as determined necessary by the Director to maintain opacity
limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated to control fugitive dust. The application of
water or chemical treatment shall be used. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a damp/moist condition unless it is below freezing.
If chemical treatment is to be used, the plan must be approved by the Director. Records of
water and/or chemical treatment shall be kept for all periods when the plant is in operation.
The records shall include the following items: Instances of water and/or chemical application
to unpaved areas shall be recorded and maintained by the owner/operator. The ambient
temperature shall be recorded any time water should be applied but cannot due to freezing
conditions. [R307-401-8]

II.B.2.c
NEW
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

The sprays shall operate whenever dry conditions warrant meeting the required opacity
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limitations or as determined necessary by the Director. Water sprays shall not be required
during periods of freezing temperatures. [R307-401-8]

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation
of fugitive dusts as dry conditions warrant or as determined necessary by the Director.
[R307-401-8]

II.B.2.e
NEW
The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5
PM. [R307-401-8]

II.B.3 Continuous Emission Monitoring Requirements:
II.B.3.a
NEW
The owner/operator shall install, calibrate, maintain and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler.

A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the
missing data substitution procedures used by the UDAQ or the missing data substitution
procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate by the UDAQ.

B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period
including during each startup, shutdown, or malfunction.

C. The monitoring system shall comply with all applicable sections of R307-170, UAC; and
40 CFR 60, Appendix B.

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be
installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the
kiln/raw mill stack.

F. The owner/operator shall record the output of the system: including the quantity of NOx,
CO, O2 THC, Hg, HCl, and CO2 emissions at the kiln stack.

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source 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.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker
cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except
during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments,
the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a
PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the
results of the performance test demonstrating compliance with the filterable PM limit and
using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust
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the SSOL developed in accordance with the results of the most recent PM performance test
demonstrating compliance with the PM emission limit. The owner/operator shall use the PM
CPMS to demonstrate continuous compliance with the SSOL in accordance with the
requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

II.B.4 Fuel Limitations:
II.B.4.a
NEW
The owner/operator shall use only the following fuels in the kiln and pre-calciner:

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.

If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b
NEW
Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the
Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the
results of suitable tests giving data similar to a Proximate and Ultimate analysis of the
proposed coal additive. [R307-401-8]

II.B.4.b.1 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. [R307-401-8]

II.B.4.b.2 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 owner/operator 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 in Condition
II.B.4.b. [R307-401-8]

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II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel burning or process
installation not covered by New Source Performance Standards for sulfur emissions or
covered elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross
Btu heat input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input
for any oil except used oil. The sulfur content shall comply with all applicable sections of
UAC R307-203. [R307-203, R307-401-8]

II.B.4.c.1
NEW
Certification of fuels shall be either by the owner/operator's own testing or test reports from
the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be
available onsite. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials, UAC R307-203-1 (4)

A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be
used.

B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be
used.

C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85 are to be used. [R307-203]

II.B.4.d
NEW
The concentration/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight
3) Cadmium 2 ppm by weight
4) Chromium. 10 ppm by weight
5) Lead 100 ppm by weight
6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be
tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the burn tank and burned. [R307-401-8]

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II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned
in the rotary kiln:

A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than
five minutes in any 60-minute period

B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes
in any 60-minute period. [R307-401-8]

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the
Director. The calibration procedure and frequency shall be according to manufacturer's
specifications. Use of factory-calibrated thermocouples for temperature measurement is
approved. However, any other method of temperature measurement must be approved by the
Director prior to use. The monitoring equipment for both temperature and oxygen content
shall be located such that an inspector can at any time safely read the output. [R307-401-8]

II.B.5
NEW
Emergency Engine Requirements
II.B.5.a
NEW
The owner/operator shall only operate the emergency engines for testing and maintenance
purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency
operation. [R307-401-8]

II.B.5.b
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each emergency engine. [R307-401-8]

II.B.5.b.1
NEW
The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.5.b.2
NEW
To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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Page 39

PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN103030035-24 dated November 27, 2024
Is Derived From Source Submitted NOI dated November 30, 2022
Incorporates Additional Information Received dated April 26, 2023
Incorporates Additional Information Received dated September 26, 2023
Incorporates Additional Information Received dated July 23, 2024
Incorporates Additional Information Received dated October 25, 2024
Incorporates Additional Information Received dated November 25, 2024

REVIEWER COMMENTS

1. Comment regarding applicability of federal requirements:
New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable
by the best demonstrated technology as specified in the applicable provisions. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.

40 CFR 60, Subpart A (General Provisions)
All affected facilities subject to a source-specific NSPS are subject to the general provisions of
NSPS, Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires
initial notification, performance testing, recordkeeping, and monitoring, provides reference methods,
and mandates general control device requirements for all other subparts.

40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of
performance for affected facilities in Portland Cement Plants which have been constructed or
modified after August 17, 1971.

40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart
F: Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and
unloading systems. The Leamington coal mill is an in-line coal mill and considered an integral part
of the Leamington kiln. In-line coal mills are not subject to NSPS Subpart Y. Therefore, the coal mill
is addressed under NSPS Subpart F as part of the kiln system. The coal silos and conveying system
are subject to NSPS Subpart Y.

Ash Grove's proposed changes to the kiln system must be evaluated as to whether they trigger new
NSPS Subpart F obligations based on whether the proposed project is either a modification or a
reconstruction, as those terms are defined in NSPS Subpart A.

Ash Grove's proposed changes to the kiln system do not meet the definition of a reconstruction, nor
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 40

do they meet the definition of a modification for NOx. However, the changes meet the definition of a
modification for PM and SO2. Therefore, Ash Grove will comply with all relevant emission
standards; testing requirements; monitoring, recordkeeping, and reporting obligations that apply to
the Leamington kiln system as an existing source under NSPS Subpart F. Under NSPS Subpart A
and F, the clinker cooler is considered a reconstructed unit. Thus new limits will apply to this unit.
[Last updated January 14, 2025]

2. Comment regarding applicability of federal requirements cont.:
NSPS Subpart Y - Standards of Performance for Coal Preparation and Processing Plants
This subpart provides standards of performance for affected facilities in coal preparation and
processing plants that process more than 200 tons of coal per day.

The Leamington plant's coal silo and coal conveying system are existing affected facilities under
NSPS Subpart Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses
controlling affected facilities subject to match the limit in NSPS Subpart Y from 0.016 gr/dscf to
0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade Project. Since there are no proposed
modifications or reconstruction to the coal silo and coal conveying system, nothing about the
proposed upgrade project affects the existing applicability of NSPS Subpart Y.

NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
This subpart provides standards of performance for affected facilities located at fixed or portable
nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August
31, 1983, with additional requirements applicable to sources constructed on or after April 22, 2008.

As the crushing and screening system is controlled by baghouses and an increase in PM10 actual
emissions on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS.
Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the
Leamington Plant Upgrade Project.

Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1),
60.676(f), and 60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO
monitoring and recordkeeping requirements.

[Last updated January 14, 2025]

3. Comment regarding applicability of federal requirements cont.:
National Emission Standards for Hazardous Pollutants (NESHAPs)
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or
greater than 10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as
specified by each subpart. NESHAP apply to sources in specifically regulated industrial source
classifications (CAA Section 112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities
not regulated as a specific industrial source type. The Ash Grove Leamington Plant is a major source
of HAPs and thus is subject to certain NESHAP standards.

Subpart A - General Provisions
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January 21, 2025
Page 41

All affected sources are subject to the general provisions of Subpart A unless otherwise specified by
the source-specific NESHAP. Subpart A generally requires initial notification and performance
testing, recordkeeping, monitoring, provides reference methods, and mandates general control device
requirements for all other subparts as applicable.

Subpart LLL - Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry
This subpart establishes process/source specific emission limits for PM, VOC (expressed as total
hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and
gaseous HAP compounds by limiting PM and THC emissions because portions of such emissions
are USEPA-listed HAPs. Subpart LLL requires compliance with applicable emissions limits on and
after the initial startup of cement production. To further reduce emissions, Subpart LLL also
establishes operational requirements for the use of cement kiln dust (CKD), fly ash, fuel and control
equipment. Subpart LLL also specifies process/source specific emissions testing, monitoring,
recordkeeping, reporting, and compliance demonstration requirements. The compliance requirements
for the site are detailed in Approval Order Condition II.B.1.b. Ash Grove will continue to comply
with the requirements of Subpart LLL to demonstrate compliance. This cement kiln will remain an
existing source with respect to the kiln emission standards in Subpart LLL as this project does not
trigger the definition of a new source in Subpart LLL. New source standards apply only to affected
sources that were constructed or reconstructed after May 6, 2009.
[Last updated December 20, 2024]

4. Comment regarding PSD applicability analysis:
Ash Grove is proposing to increase the throughput of limestone from the quarry to supply the New
Finish Mill to increase the amount of low-carbon cement from the Leamington Plant. Additionally,
along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
modified, and the clinker cooler will be reconstructed. These changes are anticipated to result in an
increase in clinker production. Emission calculations for this project have been completed assuming
an increase in clinker production capacity while utilizing current fuel types. This will result in an
increase in the throughput of fuel.

The Leamington Plant is considered an existing major source under PSD based on potential
emissions of PM10, PM2.5, NOx, CO, SO2, and CO2e. If a major source undergoes a physical or
operational change, the facility must determine whether the project will be considered a major
modification. Per 40 CFR 52.21(b)(2)(i), in order to be a major modification, the project must result
in a significant emissions increase, and a significant net emissions increase.

As defined at 40 CFR 52.21(b)(40): Significant emissions increase means, for a regulated NSR
pollutant, an increase in emissions that is significant for that pollutant. Significant is further defined
to mean, in reference to a net emissions increase or the potential of a source to emit any of the
following pollutants, a rate of emissions that would equal or exceed the values outlined in 40 CFR
52.21(b)(23). If the increase in emissions from the project are not significant, a major modification
has not occurred.

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
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January 21, 2025
Page 42

increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

For all pollutants, the project emissions increase was calculated as the difference between the
projected actual emissions (PAE) after the proposed project and the actual emissions prior to the
project (baseline actual emissions or BAE).

Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
". . . projected actual emissions means the maximum annual rate, in tons per year, at which an
existing emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years
(12-month period) following the date the unit resumes regular operation after the project, or in any
one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit of that regulated NSR pollutant and full utilization of the unit would
result in a significant emissions increase or a significant net emissions increase at the major
stationary source." [Last updated January 14, 2025]

5. Comment regarding PSD applicability analysis cont.:
Ash Grove estimates that the projected actual production capacity following the project will be
1,155,000 tons of clinker per year and 1,341,266 tons of limestone per year. These capacities were
used to calculate projected actual emissions from the project using representative emission factors.
Additionally, to estimate emissions from material transfer baghouses, the actual flow rates and actual
projected hours were used as a basis for projected actual emissions.

Project Emission Calculations

Project emission increases from the kiln and coal mill systems are calculated for all criteria
pollutants based on emission factors that are derived from stack testing, CEMS data, or emission
factors (i.e., VOCs and Lead), and the associated projected incremental clinker increase.

NOx emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain
hourly capacity to emit and annual potential to emit at current levels. The kiln's NOx emissions rate
will not change as a result of the physical modifications proposed by the project.

Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission
factor and multiplied by the incremental increase in clinker production. The emission factor was
selected based on the average of the 24-month consecutive month emissions for 2020 and 2021. The
CO emissions will increase.

The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing
conducted at the plant. The SO2 emissions will increase.

VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production. VOC emissions will increase.

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 43

can be found in the original NOI and subsequent addendums submitted to UDAQ.

As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from
the proposed project, each increase of emissions from both existing and new sources shall be
summed together and compared to the PSD permitting thresholds. The increase of emissions is the
"positive" difference between the projected actual emissions and baseline actual emissions (projected
minus baseline).

New Emissions Sources

The actual to projected actuals calculation is not available to new emission units. For new emission
units, the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected
emissions are based on the new sources' potentials to emit. (40 CFR § 52.21(a)(2)(iv)(f)).

The new equipment proposed includes the New Finish Mill, a new rail and truck loading/loadout,
one (1) new clinker reclaim loading hopper with a dust collector and one (1) existing clinker reclaim
hopper with a dust collector, a new Clinker Cooler to replace the existing one, and a new kiln feed
alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions:

The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;

The finish mill heater was calculated based on its maximum firing capacity and flow rates; and

The fugitive emissions were calculated based on the projected annual throughput of the New Finish
Mill, the rail loadout, and clinker production. [Last updated January 14, 2025]

6. Comment regarding PSD applicability analysis cont.:
Existing Emission Sources

For the existing sources, the projected actual emissions are the maximum annual rates in tons per
year projected to occur during the next five (5) to ten (10) years if the existing sources' design
capacities increase. Ash Grove Leamington projected the actual emissions for the next five (5) years
based on the new kiln system producing an annual average of 3,250 tons of clinker per day.

Baseline actual emissions (BAE) are defined at 40 CFR 52.21(b)(48)(ii) as:

". . . baseline actual emissions means the average rate, in tons per year, at which the emissions unit
actually emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the 10-year period immediately preceding either the date the owner or operator
begins actual construction of the project, or the date a complete permit application is received by the
Administrator."

Ash Grove has selected to use the years 2020 and 2021 for each pollutant as the representative
baseline years.

In its NOI, Ash Grove calculated the emission increase from the project as being divided into two
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 44

phases. Phased construction projects are discussed in two sections of the federal PSD regulations -
40 CFR 52.21(j)(4) and 40 CFr 52.21(r)(2). UDAQ is not processing this project as a phased
construction project, nor did Ash Grove request such a determination. Therefore, Ash Grove
provided a summary table outlining the final change in emissions from this project:

Projected Actual Increase Compared to PSD threshold (tons per year)
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2e
BAE 76.64 39.64 1,187 6.87 3,315 55.47 641,385
PAE 203.15 113.47 1,226 45.87 3,414 72.07 1,067,984

Change in Emissions 126.51 73.83 39.00 39.00 99.00 16.59 426,598

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes

If the emissions increase is greater than the PSD significance threshold for a particular pollutant, Ash
Grove has the option of conducting a PSD review or continuing through the rest of the steps to
determine if it can "net" out of a PSD review. If the project increase is less than the PSD significant
threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant.

The change in emissions from the project exceeds the significant emission threshold for three
pollutants: PM10, PM2.5 and CO2e. Ash Grove elected to attempt to net out of a PSD major
modification for the remainder of the criteria pollutants.

Netting

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant
Upgrade Project and ends on the date the upgrade begins operation. Only PM10, PM2.5, CO2e are in
excess of SERs and therefore considered in the netting analysis.

Ash Grove estimated that the commencement of construction will be in December 2024. Therefore,
the contemporaneous period for this project is December 2019 through a projected date the project
upgrade begins operation. [Last updated January 21, 2025]

7. Comment regarding PSD applicability analysis cont.:
Contemporaneous Decreases

Ash Grove replaced an existing kiln emergency drive engine with a USEPA Tier 4 diesel engine in
2022. Concurrently, Ash Grove requested an increase in the capacity of 1L Cement. Additionally,
Ash Grove submitted a minor modification NOI air permit application on June 12, 2023, which
proposes replacing the shipping generator during the contemporaneous period. The kiln emergency
drive engine and shipping generator are both higher EPA tier ratings therefore result in decreases for
PM10 and PM2.5. These changes were approved in AO DAQE-AN103030033-24 issued March 21,
2024.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 45

Contemporaneous Increases

As stated above, the existing kiln emergency drive engine and shipping generator were permitted and
replaced in 2024. This resulted in an increase in emissions of CO2e.

The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout
in an effort to improve truck traffic at the loadout. The modification to add these dust collectors to
the loadout was included in DAQE-AN103030029-19. The baghouses are three (3) levels up in the
silos' enclosed space (approximately 40 feet). Both dust collectors vent directly into the interior of
the silo structure and are not vented into the atmosphere. Ash Grove requests to remove these
baghouses from its existing permitted emissions inventory. Therefore, these emissions have been
documented in the netting analysis as zero emissions.

Also included in DAQE-AN103030033-24 were two new natural gas-fired emergency generators
and increases in stockpiles, material handling and road emissions.

Could Have Been Accommodated Emissions

In calculating project emissions increase, USEPA allows the exclusion of existing
production/emissions rates that could have been accommodated during the baseline period. These
"could have been accommodated" emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as
follows:

". . . Shall exclude, in calculating any increase in emissions that results from the particular project,
that portion of the unit's emissions following the project that an existing unit could have
accommodated during the consecutive 24-month period used to establish the baseline actual
emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project,
including any increased utilization due to product demand growth;"

Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the
exclusion of existing production and emissions rates that could have been accommodated during the
baseline period, it has elected not to use this exclusion at this time. Therefore, calculation of the
"could have been" accommodated emissions have not been included in this application's
applicability analysis.

The increase from the project is added to the contemporaneous decreases and contemporaneous
increases. The resulting calculation is then compared to the PSD significance threshold to determine
if a significant net emissions increase has occurred. [Last updated January 14, 2025]

8. Comment regarding PSD applicability analysis cont.:
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2 e
Contemporaneous Inc. 1.61 0.45 0.41 0 0.27 0.07 51.74

Contemporaneous Dec. -1.54 -3.97 -0.48 -0.02 -0.27 -0.09 0

Change in Emissions 125.02 69.21 38.93 38.98 99.00 16.58 426,650

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes
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Page 46

The results of the netting analysis conclude that both a significant emissions increase and a
significant net emissions increase in both particulates (PM10 and PM2.5) and CO2e will occur from
this project. Thus, the project must be reviewed as a PSD major modification. [Last updated January
14, 2025]

9. Comment regarding emission calculations:
This engineering review includes updated potential emission totals for both criteria and HAP
emissions. The potential-to-emit (PTE) values were calculated using updated values for clinker
produced and raw material inputs. BACT emission factors and limitations were used where
appropriate. Certain emission totals (NOx, SO2 and CO) were set based on avoiding a significant
increase in emissions. Specifically, the projected actual increase was set at just under the baseline
actual emissions + the significance level. As these emissions are monitored by CEM, UDAQ agrees
with this approach. Please see the netting analysis for further details on calculation of projected
actual increase. The NOx hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project.

CO2e emissions were calculated using the GHG emission factor calculated from 40 CFR Part 98
Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in Subpart A Table
A-1.

To calculate the PTE tons per year, the maximum hours (i.e., 8760) per year and the source's
emissions rates were multiplied with the throughputs. The potential throughputs have been updated
at UDAQ's request so that PAE is equal to PTE and represents the equipment's maximum design
potential.

Additional emission calculations based on source testing and monitoring, and EPA's compilation of
air emission factors AP-42. [Last updated January 14, 2025]

10. Comment regarding requirements for PSD review:
In addition to the permitting requirements of R307-401-5 through R307-401-8, there are additional
requirements under PSD that must be addressed:

1. Calculation of ambient air increments (40 CFR 52.12(c)), ambient air ceilings ((40 CFR 52.12(d)),
source impact analysis (40 CFR 52.12(k)), air quality models (40 CFR 52.12(l)) - these items are
addressed in the modeling memo DAQE-MN103030032-24.

2. Stack heights (40 CFR 52.12(h)) - Ash Grove's stack heights have been reviewed with respect to
good engineering practice and operate in a vertical unrestricted manner.

3. Control technology review (40 CFR 52.12(j)) - this is addressed in the BACT analysis section of
this review document.

4. Air quality analysis: preapplication analysis (40 CFR 52.12(m)) - this is covered in the PSD
applicability and netting analysis sections of this review document, ambient monitoring and
background data collection is also included in the modeling memo DAQE-MN103030032-24.

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 47

grain loading limit included in II.B.1.j.1 represents the required post-construction monitoring.
6. Source information (40 CFR 52.12(n)) - this is addressed under the requirements of R307-401-5
and was submitted by Ash Grove as part of the NOI package.

7. Additional impact analysis (40 CFR 52.12(o)) - these requirements cover soils, vegetation, growth
and visibility concerns. They are discussed in the modeling memo DAQE-MN103030032-24.

8. Federal land manager review (40 CFR 52.12(p)) - UDAQ provided initial notification to all
federal land managers upon receipt of the original NOI package. The draft permit and engineering
review will also be provided to the federal land managers 60-days prior to initiation of public
comment for their further review.

9. Public participation (40 CFR 52.12(q)) - this project will have a 30-day public comment period.

10. Source obligation (40 CFR 52.12(r)) - this requirement discusses source compliance with other
parts of the CAA, which is addressed within UDAQ's permitting rules in R307.
[Last updated January 14, 2025]

11. Comment regarding changes in equipment list:
The equipment list is being updated for clarity as well as adding new pieces of equipment. The
following changes are taking place:

The naming scheme is being updated to remove the numerical code from the unit designation. This
code generally referred to the associated control device and not to the emitting unit itself. This can
cause confusion especially when the same code was applied to multiple pieces of equipment.
Instead, the control devices (typically baghouse dust collectors) will be identified in the description
along with the appropriate numerical code.

Specific changes are as follows:

1. The kiln description has been updated

2. Clinker Cooler description has been updated to include a larger pulse jet baghouse.

3. The clinker storage silos, east and west clinker belts, clinker belt transfer and clinker tunnel have
been consolidated to avoid confusion

4. The north and south cement loadout exhausts now vent internally into the cement storage silos

5. The dust shuttle system has been consolidated into one line item, most identifiers removed from
subsystem descriptions as only two baghouses serve as exhaust points.

6. A new finish mill with heater has been added. Included in the description are the thirteen total
baghouses for dust control (1 main stack, 2 transfer points, 10 nuisance dust filters)

7. A new clinker reclaim hopper has been added. Both reclaim hoppers are controlled by baghouses
with updated identifiers

8. A new rail and truck loading/unloading system with two baghouses has been added.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 48

[Last updated December 20, 2024]

12. Comment regarding changes in conditions:
As a result of this project, several conditions will be added or changed. This includes one new
general condition (I.8). Changes to the equipment list (section II.A) will be addressed in a separate
reviewer comment:

I.8 - Adding this general condition to cover the requirements of R307-401-18 Eighteen Month
Review. The status of construction/installation of the new equipment shall be reviewed after
18-months.

II.B.1.a - Clinker production increases to 1,155,000 tpy
Use of limestone bypass material increases to 215,260 tpy

II.B.1.b - The NOx limit on the kiln decreases to 1,223 tpy, CO emissions from the kiln decrease to
3,395 tpy,
Adding a new CO2e limit of 0.92 tons CO2e/ton of clinker produced
PM limit on the clinker cooler decreased to 0.02 lb PM (filterable)/ton of clinker
Rule reference updated to include 40 CFR 60 Subpart F, and R307-401-8

II.B.1.e - Initial testing on the clinker cooler is now required within 180 days of startup of the unit.
Monitoring of CO2 from the kiln will be by CEM.
Formatting changes on paragraph designated ++, improve clarity, include reference to CO2
monitoring, define CPMS

II.B.1.e.4 - Update to address general PM monitoring and reference R307-401-8

II.B.1.e.14 - New condition to address new or reconstructed emission units monitoring requirements,
applicable to the clinker cooler and new finish mill.

II.B.1.h - Adding references to Subpart OOO units (limestone processing) with updated opacity
limits.
Adding 20% opacity limit on coal transfer and storage
Adding property boundary opacity limit of 20%
Updating rule reference to include Subpart OOO

II.B.1.j - New condition to address outlet grain loading limits on new baghouses, One identical limit,
15 total new baghouses.

II.B.1.j.1 - Monitoring on new baghouses as per II.B.1.e.4, added an allowance to test less frequently
than annually with three successful tests.

II.B.3.a - Updating formatting to add clarity and include reference to CO2 CEM

II.B.5 - New conditions on emergency engines, diesel fuel sulfur limits, hour of operation
restrictions, non resettable hour meter

[Last updated December 20, 2024]
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 49

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 51

TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

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DAQE-MN103030032-24

M E M O R A N D U M

TO: John Jenks, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler
Dave Prey, Air Quality Modeler

DATE: December 12, 2024

SUBJECT: Modeling Analysis Review for the Ash Grove Cement Company – Leamington Plant,
located in Millard County, Utah
___________________________________________________________________________________
This is a Major Modification to a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Ash Grove Cement Company (Applicant) has submitted a Notice of Intent (NOI) air permit
application for a project referred to as the Leamington Upgrade Project (LUP). The proposed
upgrade project includes the construction and installation of new pollution control equipment, new
emission sources, and modifications to existing emission sources. Emission increases associated
with the LUP constitute a major modification to a Prevention of Significant Deterioration (PSD)
source subject to PSD permitting regulations. PSD regulations require the Applicant to include and
air quality impact analysis (AQIA) of the proposed projects impact on the EPA national ambient air
quality standards (NAAQS) and air quality related values (AQRV) as part of a complete NOI.

This report prepared by the New Source Review (NSR) modeling staff contains a review of the
Applicant’s Air Quality Impact Analysis (AQIA) including the methodology, data sources,
assumptions, and modeling results for comparison with State and Federal air quality standards. The
AQIA was reviewed and referenced in this report include the:
● Notice of Intent – Ash Grove Cement Leamington Plant PSD Notice of Intent Air Permit
Application, dated November 30, 2022.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

0 0
Jason Krebs

DP
DAQE-MN103030032-24
Page 2

II. APPLICABLE RULES AND ANALYSES

A Utah Air Quality Rules

The UDAQ has determined that the Applicant’s NOI is subject to the following rules for conducting an
AQIA:

R307-401 Permits: New and Modified Sources
R307-405 Permits: Major Sources Located in Attainment or Unclassified Area (PSD)
R307-406-2 Visibility – Source Review
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutant Impacts in Attainment Areas

B. Applicability

The proposed increases in emissions of PM10 and PM2.5 exceed the emission thresholds outlined in R307-
406-5 and R307-410-4. Therefore, an AQIA consistent with the requirements of R307-405-6, R307-406-
2, and R307-410-3 was submitted as part of the Applicant’s NOI. R307-410-3 establishes the U. S.
Environmental Protection Agency (US EPA) – Guideline on Air Quality Models as a formal basis for
defining the scope of the analysis, as well as the model’s construction. The results of the AQIA are
required to demonstrate the proposed project’s impact on state and federal air quality standards,
acceptable levels of impact, and action triggering thresholds referenced or listed in R307-401-6(2), R307-
401-6(3), R307-403-3(1), R307-403-5(1)(a), R307-405-4(1), R307-405-6. Annual emissions for criteria
pollutants requiring an AQIA are listed in Table 1.

Table 1: Ash Grove Leamington Proposed Net Emissions Increase

Criteria
Pollutants
Net Emission
Increase (TPY)
AQIA Trigger
Level (TPY) AQIA Required?
PM10 126.6 15 Yes
PM2.5 70.3 10 Yes

C. Required Analyses

R307-405 requires the Applicant to perform a pre-construction modeling analysis for all pollutants
emitted in a significant quantity. The purpose of the analysis is to determine if the extent of the source’s
impact is significant enough to warrant an on-site measurement of the ambient background concentration
levels. This data is included in the NAAQS analysis to represent the quality of the air prior to the
construction of the proposed project. The Applicant included a pre-construction modeling analysis for
PM10 and PM2.5 as part of the NOI. The pre-construction modeling analysis was also used to determine if
the proposed emissions would result in a significant impact to the environment, thereby triggering the
requirement for a cumulative analysis of the proposed project and other nearby existing sources.

R307-401-8 requires the Division to determine that the proposed project will comply with the NAAQS
prior to the issuance of an Approval Order (AO). R307-405(7) requires the Applicant to perform a
DAQE-MN103030032-24
Page 3
NAAQS analysis for all pollutants emitted in a significant quantity. The analysis is to include all
emissions at the proposed site under normal operating conditions using maximum anticipated short-term
release and annual release rates. Consistent with UDAQ policy, a cumulative analysis to include the
ambient background concentration and any contribution from other nearby sources is not required if the
proposed project’s impact does not exceed the PSD Class II Significant Impact Level (SIL).

R307-401-8 also requires the Division to determine that the proposed project will comply with PSD
increments prior to the issuance of an AO. Under R307-405(6), the Applicant is required to perform a
PSD Class I and II increment consumption analysis for all pollutants emitted in significant quantities.
The purpose of this analysis is to quantify any degradation in air quality since the major source baseline
date. The analysis is to include all increment consuming emissions at the proposed site under normal
operating conditions using maximum anticipated short-term and annual release rates. A cumulative
analysis to include contributions associated with growth and other increment consuming sources is not
required if the proposed project’s impact does not exceed the PSD Class I or II SIL.

R307-410-5 requires the Applicant to perform a HAPs analysis for any pollutant emitted above a
pollutant specific emission threshold value. This analysis is to include all emissions of the pollutants
resulting from the proposed modification under normal operating conditions using maximum anticipated
one-hour release rates. The Applicant did not trigger modeling for HAPs.

R307-406-2 requires the Applicant to perform a plume blight analysis. A plume blight analysis is required
to determine if plumes emanating from the proposed project would be visible inside any Class I area
within 50 kilometers of the source. The plume blight analysis is to include all emissions of NO2, SO4, and
PM10.

Under R307-405-16, an AQRV analysis is performed which evaluates regional haze and acid deposition
impacts at each of the Class I areas within 300 kilometers of the source. A regional haze analysis is
required to determine if the plumes would reduce the visual range of an observer inside the Class I area.
The regional haze analysis is to include all emissions of SO2, NOX and PM10. The deposition analysis
examines impacts from sulfur and nitrogen compounds at the Class I areas, and is based on all emissions
of SO2 and NOX. The Federal Land Managers use the Q/D approach to determine whether a PSD project
should provide detailed AQRV impact analyses, where: Q/D= [ H2SO4 + SO2 + NOx + PM10 emissions
(tpy)]/ distance (km). If Q/D is less than 10, no AQRV analysis is required.

R307-405 requires the Applicant to perform a soils and vegetation analysis. The analysis should quantify
the effects of pollutants on soils and vegetation near the highest impact location and in areas where
sensitive plant species may be impacted.

III. ON-SITE PRE-CONSTRUCTION MONITORING

A. Meteorological Data

Consistent with the US EPA - Meteorological Monitoring Guidance for Regulatory Modeling
Applications, one year of on-site data was collected using a 50-meter tower during the period October 1,
2021 through September 30, 2022. Parameters collected on-site included wind speed and direction,
temperature, delta-T, and solar radiation.

DAQE-MN103030032-24
Page 4

B. Ambient Pollutant Data

A preliminary analysis was conducted to determine the necessity for pre-construction ambient pollutant
monitoring. The results indicate that predicted concentrations of PM10 and PM2.5 exceed the monitoring
trigger level listing in the rule. A continuous PM10/PM2.5 monitor with filter based samplers was
installed near the northern edge of the Applicants property boundary, and collected particulate matter
from October 1, 2021 through September 30, 2022.

IV. MODEL SELECTION

The EPA-AERMOD dispersion modeling system is the preferred model specified in the US EPA –
Guideline on Air Quality Models to predict air pollutant concentrations in the near field (within 50
kilometers of the source). The US EPA - CALPUFF - Version 5.8 model is the preferred model to predict
concentrations in the far field (long range transport conditions beyond 50 kilometers from the source).

V. MODELING INPUTS AND ASSUMPTIONS

A. Technical Options

The regulatory default options were selected in AERMOD by the Applicant to quantify all concentrations.

B. Urban or Rural Area Designation

A review of the appropriate 7.5-minute quadrangles determined that the area should be classified as
“rural” for air modeling purposes.

C. Topography/Terrain

The Plant is at an elevation of 4,950 feet with nearby terrain features that have an effect on concentration
predictions.

a. Zone: 12
b. Location: UTM (NAD83): 397000 meters East, 4379850 meters North

D. Ambient Air

It was determined that the Plant boundary used in the AQIA meets the State’s definition of an ambient air
boundary.

E. Receptor and Terrain Elevations

The modeling domain has simple and complex terrain features in the near field. Therefore, receptor
points representing actual terrain elevations from the area were used in the analysis.

The far-field modeling domain consisted of a rectangular region covering all Class I areas within Utah,
and extending 50 kilometers beyond this area so that the model can account for re-circulation of the
plume.

DAQE-MN103030032-24
Page 5

F. Emission Rates and Release Parameters

The emission estimates and source parameters used in AERMOD for all proposed emission sources at the
site are presented in the NOI.

Speciated emission rates and source parameters used in the CALPUFF modeling are presented in Table 2.

Table 2: CALPUFF Emission Rates

Source
LCC Coordinates Modeled Emission Rates
Easting Northing SO2 SO4 NOX HNO3 NO3 SOA PMC SOIL EC
(m) (m) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr)
317.BF3 -1289410 -3738 52.81 5.03 307.58 0.00 0.00 5.03 2.60 2.90 0.11
419.BF1 -1289314 -3631 0.00 0.00 0.00 0.00 0.00 0.55 1.51 1.61 0.06
41B.BF2 -1289389 -3663 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.68 0.00
N1_FM2 -1289526 -3414 0.00 0.00 0.00 0.00 0.00 0.00 1.65 3.95 0.00
414.BF1N -1289407 -3683 0.00 0.00 0.00 0.00 0.00 0.00 0.10 0.25 0.00
2FM_HTR -1289528 -3415 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.08 0.00
514.BF1 -1289451 -3675 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.70 0.00
COMBO -1289424 -3668 0.00 0.00 0.00 0.00 0.00 0.00 1.37 5.72 0.00
FM2_CMB -1289454 -3439 0.00 0.00 0.00 0.00 0.00 0.00 0.50 1.21 0.00

Total Lb/hr 52.81 5.03 307.58 0.00 0.00 5.58 8.32 17.10 0.17
Hrs/Yr 8760 8760 8760 8760 8760 8760 8760 8760 8760
Ton/yr 231.3 22.0 1347.2 0.0 0.0 24.4 36.4 74.9 0.8

Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
317.BF3 POINT 4902.8 41.2 135.0 488 10.10 3.35
419.BF1 POINT 4891.2 18.3 60.0 388 6.36 2.90
41B.BF2 POINT 4895.2 68.6 224.9 294 17.83 0.74
N1_FM2 POINT 4832.0 49.7 163.0 363 40.08 1.40
414.BF1N POINT 4896.1 76.8 251.9 353 9.91 0.70
2FM_HTR POINT 4832.0 49.7 163.0 363 40.08 1.40
514.BF1 POINT 4889.5 39.6 130.0 294 11.86 0.91
COMBO POINT 4904.2 13.3 43.7 276 9.76 0.32
DAQE-MN103030032-24
Page 6
FM2_CMB POINT 4832.0 30.6 100.3 294 11.40 0.37

G. Building Downwash

The Applicant used the US EPA Building Profile Input Program (BPIP) to determine Good Engineering
Practice (GEP) stack heights and cross-sectional building dimensions for input into the model.

H. Ambient Background Concentrations

Millard County is in attainment for all criteria pollutants. The NAAQS analyses for PM2.5 and PM10 used
monitoring data collected on site during the pre-construction monitoring analysis. The background values
used in the NAAQS analysis are presented in Table 3.

Table 3: Background Concentrations

Pollutant Averaging
Period
Background
Concentration
(μg/m3)
PM10 24-hour 65.4
PM2.5 24-hour 10.2
Annual 4.2

I. Meteorological Data Processing

For the AERMOD model, on-site horizontal and vertical wind speed, direction, solar radiation and,
temperature data was combined with National Weather Service (NWS) upper air data collected at the Salt
Lake City International Airport (SLCIA) for the same period using the US EPA AERMET processing
system.

Meteorological data used for the CALPUFF modeling analysis consisted of 3 years (2018-2020) of data
developed by the Forest Service. The grid was 708 km (east-west) by 492 km (north-south) with a
resolution of 12 kilometers.

VI. RESULTS AND CONCLUSIONS

The Applicant performed a series of analyses to estimate the impact from the proposed project. Modeling
results and conclusions from the review of the analyses are outlined in detail below.

A. Pre-Construction Monitoring and Significant Impact Modeling

The Applicant performed a preliminary criteria pollutant analysis of the proposed modification. This
analysis indicated that increases in concentration levels of PM2.5 and PM10 were greater than the Class II
SIL, and therefore, a cumulative analysis for these pollutants was required.

DAQE-MN103030032-24
Page 7

B. NAAQS Analysis

The Applicant performed a modeling analysis to determine if the combined impact from the proposed
source, other industrial sources operating in the area, and ambient background would comply with the
NAAQS. The NAAQS analysis was reviewed by the Division and determined to be consistent with the
requirements of R307-410-3. Table 4 provides a comparison of the Applicant’s predicted air quality
concentrations and the NAAQS.

Table 4: Model Predicted NAAQS Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-hour 28.3 5 65.4 0 93.7 150 62.5%
PM2.5 24-hour 9.6 1.2 10.2 0 19.8 35 56.6%
Annual 4.4 0.3 4.2 0 8.6 9 95.6%
* Note: Only included other sources and background if source impact was above Class II SIL

C. PSD Class II Increments

The Applicant performed an analysis to determine if the impact from the proposed source would comply
with PSD Class II increments. The analysis was reviewed by the Division and determined to be
consistent with the requirements of R307-410-3. Table 5 provides a comparison of the predicted
concentrations and the PSD Class II increment.

Table 5: Model Predicted PSD Class II Increment Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Nearby
Sources*
Total Increment Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
PM10 Annual 8.1 1 0 8.1 25 32.4%
24-hour 28.3 5 0 28.3 30 94.3%
PM2.5 24-hour 6.1 1.2 0 6.1 9 67.8%
Annual 2.4 0.3 0 2.4 4 60.0%

D. Hazardous Air Pollutants

DAQE-MN103030032-24
Page 8
The Applicant performed an analysis to determine if HAP modeling is required. The analysis was
reviewed by the Division and determined to be consistent with the requirements of R307-410-3. The
analysis indicated that HAP modeling was not triggered by this modification, and therefore no HAP
modeling was performed.

E. PSD Class I Increment Consumption Analysis

The Applicant performed a CALPUFF analysis to determine if the impact from the proposed source along
with other increment consuming sources would comply with federal PSD Class I increments. The
analysis was reviewed by the Division and determined to be consistent with the requirements of R307-
410-3. The results for all Class I areas within 300 kilometers are provided in Table 6.

Table 6: Model Predicted PSD Class I Increment Concentrations

Air Period Prediction
Class I
Significant
Impact
Level
Other
Sources* Total Increment Percent
Pollutant (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
Capitol Reef
NO2 Annual 0.0018 0.1 2.5
SO2
3-Hour 0.0494 1 25
24-
Hour 0.0150 0.2 5
Annual 0.0008 0.1 2
PM2.5
24-
Hour 0.0430 0.27 2
Annual 0.0021 0.05 1
PM10
24-
Hour 0.0444 0.3 8
Annual 0.0021 0.2 4
Arches
NO2 Annual 0.0008 0.1 2.5
SO2
3-Hour 0.0408 1 25
24-
Hour 0.0102 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0522 0.27 2
Annual 0.0018 0.05 1
DAQE-MN103030032-24
Page 9
PM10
24-
Hour 0.0531 0.3 8
Annual 0.0019 0.2 4
Canyonlands
NO2 Annual 0.0010 0.1 2.5
SO2
3-Hour 0.0354 1 25
24-
Hour 0.0100 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0577 0.27 2
Annual 0.0019 0.05 1
PM10
24-
Hour 0.0591 0.3 8
Annual 0.0020 0.2 4
Bryce
NO2 Annual 0.0006 0.1 2.5
SO2
3-Hour 0.0369 1 25
24-
Hour 0.0082 0.2 5
Annual 0.0003 0.1 2
PM2.5
24-
Hour 0.0189 0.27 2
Annual 0.0010 0.05 1
PM10
24-
Hour 0.0194 0.3 8
Annual 0.0010 0.2 4
Zion
NO2 Annual 0.0011 0.1 2.5
SO2
3-Hour 0.0293 1 25
24-
Hour 0.0105 0.2 5
Annual 0.0005 0.1 2
PM2.5
24-
Hour 0.0266 0.27 2
Annual 0.0011 0.05 1
PM10 24-
Hour 0.0271 0.3 8
DAQE-MN103030032-24
Page 10
Annual 0.0012 0.2 4
* Note: Only included other increment consuming sources if source impact was above Class I SIL

Since the proposed project’s model predicted impacts at the Class I areas were less than the PSD Class I
significance levels, a cumulative analysis was not warranted.

DAQE-MN103030032-24
Page 11
F. Visibility – Plume Blight
Since the Class I areas are greater than 50 kilometers from the source, a plume blight analysis using
VISCREEN was not required.

G. Visibility – Regional Haze

The results of the Q/D analysis for the emissions increase was less than 10 but the FLMs wanted the
entire source included in the Q term. The results of including the total emissions resulted in a Q/D >10,
so an AQRV analysis was performed for visibility and acid deposition. The results shown in Table 7
indicate that the impacts are below the 0.5 Deciview (DV) threshold established by the National Park
Service, indicating that no further analysis is required.

Table 7: CALPUFF Visibility Results

Class I Area Year Maximum
Delta DV
98th
Percentile
change in
DV
#
Days
#
Days Threshold
(DV)
Below
Threshold
> 1 > 0.5
2018 0.248 0.06 0 0 0.5 Yes
Arches 2019 0.291 0.054 0 0 0.5 Yes
2020 0.216 0.106 0 0 0.5 Yes
2018 0.223 0.081 0 0 0.5 Yes
Canyonlands 2019 0.312 0.068 0 0 0.5 Yes
2020 0.186 0.085 0 0 0.5 Yes
2018 0.059 0.03 0 0 0.5 Yes
Bryce 2019 0.081 0.045 0 0 0.5 Yes
2020 0.071 0.03 0 0 0.5 Yes
2018 0.183 0.074 0 0 0.5 Yes
Capital Reef 2019 0.196 0.092 0 0 0.5 Yes
2020 0.126 0.078 0 0 0.5 Yes
2018 0.069 0.04 0 0 0.5 Yes
Zion 2019 0.123 0.039 0 0 0.5 Yes
2020 0.102 0.057 0 0 0.5 Yes

DAQE-MN103030032-24
Page 12

H. Acid Deposition

The Applicant performed a deposition analysis on impacts within the Class I areas. Results of the
analysis indicate that the impacts are below the deposition threshold (DAT) established by the National
Park Service, indicating that no further analysis is required

Table 8: CALPUFF Deposition Results for Highest Year

Class I Area
Total
Nitrate
Deposition
Total
Sulfate
Deposition
Deposition
Analysis
Threshold
(kg/ha/yr) (kg/ha/yr) (kg/ha/yr)
Canyonlands 0.0006 0.0003
0.005
Zion 0.0004 0.0002
Arches 0.0006 0.0003
Bryce 0.0006 0.0002
Capitol Reef 0.0011 0.0005

I. Soils and Vegetation Analysis

The Applicant performed an analysis to determine the extent of impacts from the proposed source on soil
and vegetation. Results of the analysis are presented in a supplemental document titled “Soil and
Vegetation Impact Analysis for the Leamington, UT Facility, June 29, 2023”. The analysis indicated that
predicted concentrations compared against the secondary NAAQS at several sensitive receptors would not
result in an adverse impact on soils and vegetation in the vicinity of the proposed project.

DP/JK:jg

DAQE-IN103030032-25

January 22, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Mr. Nelson:

Re: Intent to Approve: Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — ) A A v A ? A D @ A w D D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — ) A A v A ? A D @ A w D D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ash Grove Cement Company Ash Grove Cement Company - Leamington Cement Plant

Mailing Address Physical Address
P.O. Box 38069 Highway 132
Leamington, UT 84638 Leamington, UT 84638

Source Contact UTM Coordinates
Name: Cody Watkins 397000 m Easting
Phone: [phone] 4380100 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3241 (Cement, Hydraulic)

SOURCE INFORMATION
General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried on site),
are correctly proportioned, ground, and mixed and then fed into a rotating kiln. The kiln alters the
materials and recombines them into small stones called cement clinker. The clinker is cooled and ground
with gypsum and additional limestone into a fine powdered cement. The final product is stored on site for
later shipping. The major sources of air emissions are from the combustion of fuels for the kiln operation,
from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source of
emissions of PM2.5, PM10, NOx, CO, HAPs, and GHG. It is a minor source of SO2 emissions.
NSR Classification
Major PSD Modification

Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
DAQE-IN103030032-25
Page 4

Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

These changes result in increases in actual emissions but decreases in most potential emissions. There will
be an increase in the potential emissions of VOCs and greenhouse gases.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
DAQE-IN103030032-25
Page 5

Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
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I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, 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. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO 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. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
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II.A.4 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)
II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area, and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, stacker systems. II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit-specific requirements.
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total air flow controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter
area; 9,865 acfm total air flow, controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are
controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each
is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6). II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The
following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for
NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.
II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low-pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

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II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow through stack
E34.
II.A.18 Kiln Feed Alleviator A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the central material silo between the blending silos and the preheater. Raw feed is removed from the system near the top of the preheater tower.
II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The
coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter area;
1,700 acfm total air flow.
II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker
storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1): 1,800 acfm that discharges into the clinker tunnel.
II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
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II.A.27 Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during loading.
II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel, all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during loading. 512.BF3 (1,000 acfm) is located on top of the silo. II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement products. Dust generated
during milling is captured by a BHA pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).

II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates from stack G55 (finish mill stack).
II.A.32 Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4).
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1 thru 3).

II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total air flow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations.
II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This
baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

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II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.
II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023)
II.A.40 Dust Shuttle System A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides, surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the
fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

II.A.41 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons) Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
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II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)
THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)
CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)
PM: 0.02 lbs filterable PM per ton of clinker.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR 60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to approve alternative control measures, the permittee shall keep a copy of the submitted petition and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source
of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2).
[40 CFR 63 Subpart LLL]

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II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must 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 PM CPMS is not out of control. The owner/operator must 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 on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
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II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

II.B.1.e.3 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-165]
II.B.1.e.4 PM 40 CFR 60, Appendix A, Method 5, or 5I, or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three runs, with each
run at least 120 minutes in duration and each run collecting a sample of 60 dry standard cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 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. [R307-165]
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II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
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II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
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II.B.1.i 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 must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator 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 owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator 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 owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
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II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: Instances of water and/or chemical application to unpaved areas shall be recorded and maintained by the owner/operator. The ambient temperature shall be recorded any time water should be applied but cannot due to freezing conditions. [R307-401-8]
II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

The sprays shall operate whenever dry conditions warrant meeting the required opacity
limitations or as determined necessary by the Director. Water sprays shall not be required during
periods of freezing temperatures.

[R307-401-8]

DAQE-IN103030032-25
Page 18

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

C. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the kiln/raw mill stack

F. The owner/operator shall record the output of the system: including the quantity of NOx, CO, O2, THC, Hg, HCl, and CO2 emissions at the kiln stack

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an
affected source 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.

[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]
II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments, the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the results of the performance test demonstrating compliance with the filterable PM limit and using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust the SSOL developed in accordance with the results of the most recent PM performance test demonstrating compliance with the PM emission limit. The owner/operator shall use the PM CPMS to demonstrate continuous compliance with the SSOL in accordance with the requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

DAQE-IN103030032-25
Page 19

II.B.4 Fuel Limitations: II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke F. Fuel Oil
G. Used Oil Fuel

H. Synthetic Fuel
I. Wood
J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 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. [R307-401-8]
II.B.4.b.2 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 owner/operator 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 in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

DAQE-IN103030032-25
Page 20

II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight
A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation
C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit-no less than 1500oF for more than five minutes in any 60-minute period B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
DAQE-IN103030032-25
Page 21

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the Director. The calibration procedure and frequency shall be according to manufacturer's specifications. Use of factory-calibrated thermocouples for temperature measurement is approved. However, any other method of temperature measurement must be approved by the Director prior to use. The monitoring equipment for both temperature and oxygen content shall be located such that an inspector can at any time safely read the output. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall only operate the emergency engines for testing and maintenance purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency operation. [R307-401-8]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.5.b.2 To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From Source Submitted NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-IN103030032-25
Page 22

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-GN103030032I-25

January 22, 2025

Via Certified Mail 70190700000208349789

Lisa Devore
National Park Service
Intermountain Region
12795 West Alameda Parkway
Lakewood, CO 80225
[e-mail]

Dear Ms. Devore:

RE: Notice of Publication for Ash Grove Cement Company- Leamington Cement Plant – CDS A;
MACT (Part 63), Compliance Assurance Monitoring (CAM), Title V (Part 70) Major Source,
Major Criteria Source, Major HAP Source, Attainment Area, NSPS (Part 60),
Project Number: N103030032

On January 22, 2025, the Director has completed his review of a Prevention of Significant Deterioration
project submitted by Ash Grove Cement Company. Attached to this letter are the draft Approval Order
document (Intent to Approve) and the full engineering review. Following a 60-day review by the Federal
Land Managers, this project will be submitted for a 30-day public comment period. Written comments
received by the Division at this same address during these comment periods will be considered in making
the final decision on the approval/disapproval of the proposed Approval Order. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director at the Division in writing, a hearing
will be held in accordance with R307-401-7, UAC.

If you have any questions, please contact John Jenks, who may be reached at [phone].

Sincerely,

Jon L. Black, Manager
New Source Review Division

Enclosures: Engineering Review
Modeling Memo
Intent to Approve

JLB:JJ:jg
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

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State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
RN103030032
January 21, 2025
Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]
Dear Josh Nelson,
Re: Engineer Review:
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032
Please review and sign this letter and attached Engineer Review (ER) within 10 business days.
For this document to be considered as the application for a Title V administrative amendment, a
Title V Responsible Official must sign the next page.
Please contact John Jenks at [phone] if you have any questions or concerns about the ER.
If you accept the contents of this ER, please email this signed cover letter to John Jenks at
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 1

[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the
DAQ will consider any comments received and will issue the Approval Order.

If you do not respond to this letter within 10 business days, the project will move forward
without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue
an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 2

OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible
Official, as defined in R307-415-3, must sign the statement below. THIS IS STRICTLY
OPTIONAL.

If you do not want the Engineer Review to be considered as an application to administratively
amend your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will
require submittal of a separate Operating Permit Application to revise the Title V permit in
accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document:
Title V Operating Permit Application Due Dates clarifies the required due dates for Title V
operating permit applications and can be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality

“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate
and complete and request that this Approval Order be considered as an application
to administratively amend the Operating Permit.”

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 3

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N103030032
Owner Name Ash Grove Cement Company
Mailing Address P.O. Box 38069
Leamington, UT, 84638

Source Name Ash Grove Cement Company- Leamington Cement
Plant
Source Location Hwy 132
Leamington, UT 84638

UTM Projection 397000 m Easting, 4380100 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3241 (Cement, Hydraulic)

Source Contact Cody Watkins
Phone Number [phone]
Email [e-mail]

Billing Contact Cody Watkins
Phone Number 385.225.0615
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 30, 2022
Date of Accepted Application November 28, 2024

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 4

SOURCE DESCRIPTION

General Description
Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried
on site), are correctly proportioned, ground and mixed, and then fed into a rotating kiln. The kiln
alters the materials and recombines them into small stones called cement clinker. The clinker is
cooled and ground with gypsum and additional limestone into a fine powdered cement. The final
product is stored on site for later shipping. The major sources of air emissions are from the
combustion of fuels for the kiln operation, from the kiln, and from the clinker cooling process.
The Leamington cement plant is a major source for emissions of PM2.5, PM10, NOx, CO, HAPs
and GHG. It is a minor source of SO2 emissions.

NSR Classification:
Major PSD Modification

Source Classification
Located in Attainment Area,
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Proposal
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower, various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 6

These changes result in increases in actual emissions, but decreases in most potential emissions.
There will be an increase in the potential emissions of VOC and greenhouse gases.

EMISSION IMPACT ANALYSIS
The complete modeling review is located in DAQE-MN103030032-24. [Last updated January 14, 2025]

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 7

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 8

Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 9

Review of BACT for New/Modified Emission Units

1. BACT review regarding the Leamington Plant Upgrade Project
Any major stationary source or major modification subject to PSD review must undergo an
analysis to ensure the use of BACT. The requirement to conduct a BACT analysis is set forth in 40
CFR 52.21. Similarly, Utah requires the installation of BACT for all sources of air pollution under
R307-401-5(2)(d)), BACT is defined in 40 CFR 52.21 (and R307-401-2) as:

". . . best available control technology means an emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for each pollutant subject to regulation under
Act which would be emitted from any proposed major stationary source or major modification
which the Administrator, on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such source or modification
through application of production processes or available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion techniques for control of such
pollutant . . ."

Therefore, a BACT analysis is required for each new or physically modified emission unit for each
pollutant that exceeds an applicable PSD significant emission rate (SER). Since the PM10 and PM2.5
emissions from the proposed project exceed the applicable PSD SER, a BACT analysis is required
to assess the required levels of control for these pollutants. Because the CO2e emissions are subject
to regulation as a result of the proposed project resulting in an increase of 75,000 tons or more per
year CO2e, a BACT analysis is also required for that pollutant. Note that HAPs listed under CAA
Section 112(b)(1) are excluded from NSR (New Source Review) or PSD (i.e., BACT) review.

In a memorandum dated December 1, 1987, the United States Environmental Protection Agency
(EPA) stated its preference for a "top-down" BACT analysis. After determining if any New Source
Performance Standard (NSPS) is applicable, the first step in this approach is to determine, for the
emission unit in question, the most stringent control available for a similar or identical source or
source category. If it can be shown that this level of control is technically, environmentally, or
economically infeasible for the unit in question, then the next most stringent level of control is
determined and similarly evaluated. This process continues until the BACT level under
consideration cannot be eliminated by any substantial or unique technical, environmental, or
economic objections.

Presented below are the five basic steps of a top-down BACT review as identified by the EPA.
Step 1 - Identify All Control Technologies
Step 2 - Eliminate Technically Infeasible Options
Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Step 4 - Evaluate Most Effective Controls and Document Results
Step 5 - Select BACT

Ash Grove has elected to follow this methodology and based the BACT review on each individual
pollutant. The complete BACT analysis follows. [Last updated January 14, 2025]

2. BACT review regarding PM10 and PM2.5 Sources
PM10 and PM2.5 Modified Equipment
The existing kiln precalciner, preheater, and alleviator system are proposed to be modified, and the
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 10

kiln's ID fan and clinker cooler fans are proposed to be replaced, which will result in increased
airflow. Additionally, the clinker cooler baghouse will be converted from a plenum pulse to a pulse
jet baghouse. These modifications are projected to result in a net increase of potential PM10 and
PM2.5 emissions.

Kiln Upgrade BACT
The rotary cement kiln is the core of the cement manufacturing process, transforming the blended
raw materials or "rawmix" into clinker through pyro processing. Emissions from the kiln occur
from fuel combustion plus the physical and chemical reactions needed to transform the rawmix
into clinker. This project involves process and energy efficiency improvements and an increase in
kiln production, resulting in an increase of PM10 and PM2.5 emissions. This section specifically
addresses filterable PM10 and PM2.5. The condensable fraction is represented with the other
precursors as applicable to proposed emission increases.

The Leamington Plant's Kiln is subject to NSPS, Subpart F for particulate. Therefore, a BACT
analysis addresses applicability of the proposed changes to the kiln system to NSPS and review of
the RBLC. A summary of the resources reviewed include the following:

NSPS Subpart F - Standards of Performance for Portland Cement Plants establishes emission
standards for cement kiln operations. Specifically, kilns modified after June 16, 2008, are limited to
0.07 lbs PM/ton of clinker produced.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028) and
Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from kiln operations are as follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM emissions are most effectively controlled using a collection system with enclosures routed to
baghouses providing up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Ash Grove
has selected technology with the highest control efficiency, so there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 11

Step 5 - Select BACT
Ash Grove proposes that BACT for PM10 and PM2.5 emissions from the kiln consist of a collection
system routed to a baghouse or fabric filter that complies with NSPS Subpart F's emission standard
for a modified source. BACT for the Leamington Plant's kiln are 10% opacity and 0.07 lb of
PM/ton (NSPS Subpart F emission standard) of clinker.
[Last updated January 14, 2025]

3. BACT review regarding PM10 and PM2.5 sources cont.
Clinker Cooler Upgrade BACT
The clinker cooler reduces the temperature of the clinker exiting the kiln. It is necessary to reduce
clinker temperature before it enters the finish mill to maintain product quality and reduce wear and
tear on equipment. The clinker cooler is equipped with a heat exchanger that captures waste heat
and transfers it to the kiln preheater for process and energy efficiency. Emissions from the clinker
cooler are vented to a baghouse. The Leamington Plant's clinker cooler is also subject to NSPS
Subpart F for particulate. Ash Grove's proposed changes to the clinker cooler meet the definition of
a reconstruction under NSPS. Therefore, in order to meet the requirements of NSPS Subpart F, Ash
Grove will be required to meet a limit of 0.02 lb of PM/ton of clinker.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from clinker cooler operations are as
follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM10 and PM2.5 emissions are most effectively controlled using a collection system with enclosures
routed to a baghouse, which can achieve up to 99.9% control efficiency. Other technologies such as
wet scrubbers, cyclones and ESPs are feasible, but provide lower control efficiencies than a
baghouse. Because the most efficient control technology is proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for PM10 and PM2.5 emissions from the clinker cooler is a collection system routed to a
baghouse or fabric filter. In order to meet the requirements of NSPS Subpart F, Ash Grove will
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meet a reduced emission limit of 0.02 lb of PM/ton of clinker. A 10% opacity limit is also
applicable. [Last updated January 14, 2025]

4. BACT review regarding PM10 and PM2.5 sources cont.
New Finish Mill BACT
The proposed Plant upgrade include adding a second finish mill. The new finish mill will use an
energy efficient vertical roller mill assisted with a grinding aid. A total of five (5) point sources are
planned for the finish mill. In accordance with NSPS Subpart F, emissions from finish mill are
restricted to 10% opacity. Ash Grove has reviewed the following sources to identify available
control technologies.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);12 and

Region 8 General Permit for Concrete Batch Plants.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 emissions from plant material handling operations are as
follows:
Baghouse / Fabric Filter;
Best Management & Operational Practices;
Cyclone;
ESP;
Enclosure;
Water Application (Watering); and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
With the exception of water application, all options are technically feasible. Water application is
eliminated as clinker exiting the kiln along with additives in the finish mill must remain dry to
maintain product quality. Therefore, it is technically infeasible to water material in the finish mill.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Enclosure 50-90%
5. Cyclone 20-70%
6. Best Management & Operational Practices varies

Step 4 - Evaluate Most Effective Controls and Document Results
Baghouses provide the highest emission control efficiency, controlling up to 99.9% of PM
emissions from finish mill equipment. After baghouses, using a wet scrubber or ESP provides
similar PM control. Notably, baghouses, scrubbers, and ESPs require enclosures to aid in capturing
emissions and ducting to the control. Therefore, optimal PM emission control can be achieved
through implementing both baghouses and enclosures where feasible. Plant material sizing and
handling is currently done using a series of buildings and enclosures routed to baghouse controls.
Various silos storing material inputs are also equipped with fabric filters. As the highest ranked
technology is applied, there are no adverse energy, environmental or cost impacts to consider with
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the use of these control technologies. Thus, no further analysis is required under EPA's top-down
BACT approach.

Step 5 - Select BACT
BACT for finish mill PM10 emissions is compliance with NSPS Subpart F, Standards of
Performance for Portland Cement Manufacturing where applicable. Ash Grove will achieve BACT
for PM10 emissions from finish mill equipment through the implementation of enclosures,
baghouses, and best management practices. All baghouses at the finish mill will have a 10%
opacity limitation and a grain loading of 0.005 grains/dscf. [Last updated January 14, 2025]

5. BACT review regarding PM10 and PM2.5 sources cont.
Material Transfer, Sizing, and Storage BACT
The Leamington Plant has sources of fugitive emissions through raw material transfer. Materials
transferred include limestone and other raw materials, coal, clinker, and cement. These materials
are transferred by conveyor belt, screw conveyor, elevator, pneumatic conveyance or chutes via
gravity. At the Leamington Plant the fugitive emissions are enclosed at their transfer points and
routed to baghouses.

The following emission units are included in this category:
Limestone Crushing, Sizing, and Material Transfer;
Raw Material Transfer;
Coal Sizing and Transfer;
Existing Finish Mill;
Clinker Storage and Transfer;
Cement Storage and Truck and Rail Cement Loadout;
New Rail Loading and Loadout; and
New Clinker Reclaim Hopper Baghouse.

Generally, controls for these units have not changed or they are similar to current existing controls.
A full BACT analysis of each unit is included in Ash Grove's NOI and additional submitted
information. However, given that most controls remain unaltered, only the results of Step 5 -
Select BACT will be included here.

Limestone Crushing, Sizing, and Material Transfer
Subject to NSPS Subpart OOO opacity limits for existing sources.
Existing baghouses. No change from bag manufacturer's specifications.

Raw Material Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Coal Storage and Transfer
Existing Equipment. No change from bag manufacturer's specifications
20% Opacity

Clinker Storage and Transfer
Subject to NSPS Subpart F opacity limits:
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10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Existing Finish Mill Grinding, Storage and Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Cement Storage and Truck and Rail Cement Loadout, New Rail Loadout
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

New Rail Loadout, controlled by baghouse
Emissions Limit - 0.005 gr/dscfm

New Clinker Reclaim Hopper, controlled by baghouse
Subject to NSPS Subpart F opacity limits:
10% opacity
Emissions Limit - 0.005 gr/dscfm [Last updated January 14, 2025]

6. BACT review regarding PM10 and PM2.5 sources cont.
PM10 and PM2.5 Fugitive Emissions
The following fugitive emissions sources will increase emissions of PM10 and PM2.5 as a result of
the Leamington Plant's proposed throughput increase. The sources addressed in the following
BACT analyses are primarily in the quarry, but also include emissions from roads and dumping of
raw materials within the plant boundary.

The sources evaluated are listed below:
Roads;
Loading and Unloading;
Stockpiles;
Bulldozing and Grading;
Disturbed Areas; and
Drilling and Blasting.

Ash Grove currently controls emissions from these processes, and generally, controls for these
units have not changed. A full BACT analysis of each unit is included in Ash Grove's NOI and
additional submitted information. However, given that most controls remain unaltered, only the
results of Step 5 - Select BACT will be included here.

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
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Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

Stockpiles BACT
BACT shall consist of restricting fugitive emissions to the opacity standard of 20% opacity at the
property boundary. BACT for stockpiles will be achieved through applying good management
practices through its fugitive dust plan as appropriate.

Bulldozing and Grading BACT
BACT shall consist of restricting fugitive emissions from bulldozing and grading activities to no
more than 20% opacity, and that emissions are controlled with periodic watering of the disturbed
surface. The frequency of water application will depend on ambient weather conditions and
inherent moisture content of the material being moved.

Disturbed Areas BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. BACT for
disturbed areas will be achieved through best management practices, watering, scarification, and
revegetation.

Drilling and Blasting BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. This is achievable
through best management practices, shrouds, watering, and dust collection. [Last updated January
14, 2025]

7. BACT review regarding kiln system NOx emissions
Kiln System (Kiln, Raw Mill, and Coal Mill) - NOx BACT
Although there are physical changes to the kiln system, these changes are primarily related to
particulate emissions. NOx emissions are generated from the combustion of fuel - and no changes
in NOx emissions are expected from the kiln (hourly capacity to emit). The kiln NOx emissions will
remain the same as a result of upgrades to the SNCR system. The replacement of the various
components of the kiln system and portions of the preheater tower, along with new injection points,
will ensure that increased mixing of ammonia is achieved to enhance the SNCR system's ability to
reduce NOx and minimize ammonia slip. This will allow the Leamington Plant to maintain the NOx
hourly capacity to emit unchanged from current levels Leamington Plant Upgrade Project. At
present Ash Grove has no restriction on the amount of fuel combusted, only a limit on total NOx
generated, and with this project the allowed NOx PTE is decreasing from 1,352 tpy to 1,226 tpy.

Additional ammonia will be used in the existing SNCR system. While the SNCR system has
adequate capacity to accommodate the additional ammonia demand resulting from the system
upgrades, more ammonia ports are proposed to be added with the kiln system's proposed changes
of the equipment. The changes proposed to the kiln system will increase residence time and
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temperature which will improve the SNCR system's effectiveness to control NOx emissions and
minimize ammonia slip emissions to the atmosphere. No additional review of NOx BACT for the
kiln system is required under this proposal. [Last updated January 14, 2025]

8. BACT review regarding new finish mill heater emissions
Finish Mill Heater
The proposed finish mill will include a process heater to maintain a minimum temperature during
milling. The proposed heater will run on natural gas and is rated at 10 MMBtu/hr. Startup and
shutdown emissions from the heater are anticipated to be no greater than normal operation as the
process is simply a matter of bringing the heater to operating temperature. Emissions evaluated in
the BACT analysis for the finish mill heater include NOx, SO2, CO, and VOCs, PM10, and PM2.5.
Pollutants with identical control technologies are grouped together in the analysis.

NOx - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for NOx from units of this size range are as follows:
Ultra-Low-NOx Burners (ULNB);
Low NOx Burners;
Selective Catalytic Reduction (SCR);
Selective Noncatalytic Reduction (SNCR);
Good Combustion Practices; and
Use of Natural Gas.

Step 2 - Eliminate Technically Infeasible Options
Low exit temperatures render the use of SCR and SNCR ineffective. Particulate entrainment within
the finish mill could potentially foul (plug) the nozzles of ULNB. Low-NOx burners, the use of
natural gas as fuel and good combustion practices are all considered technically feasible.

Step 3 and Step 4 - Rank Remaining Control Technologies by Control Effectiveness and Evaluate
Most Effective Controls and Document Results
Since the three feasible control technologies are proposed for the finish mill heater, no detailed
economic, energy, and environmental impact evaluations were conducted. No ranking of control
effectiveness is required as all three controls are proposed.

Step 5 - Select BACT
BACT for NOx is the use of natural gas as fuel, good combustion practices and the use of Low NOx
burners.

CO, SO2, and VOC - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for CO, SO2, and VOC from units of this size are as follows:
Good Combustion Practices
Use of Natural Gas

The finish mill heater combusts natural gas. Related natural gas combustion emissions are
anticipated to be minimal.

Step 2 - Eliminate Technically Infeasible Options
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Both control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Both technologies offer intrinsic emission reductions from combustion. Since the technologies do
not compete, both technologies can and will be used simultaneously.

Step 4 - Evaluate Most Effective Controls and Document Results
Because both control technologies identified in Step 1 are proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for CO, SO2, and VOC are good combustion practices and the use of natural gas.

PM10 and PM2.5 BACT for the finish mill has been addressed in the PM10/PM2.5 sources section.
[Last updated January 14, 2025]

9. BACT review regarding SO2, VOC, and Lead Sources
The following BACT analysis is grouped by pollutants that will experience an increase in potential
emissions and the associated technically feasible control technologies. As such, the BACT analysis
is separated into SO2, VOC, and lead respectively with organic HAPs addressed with VOCs.

SO2 - Cement Kiln BACT
NSPS Subpart F - Standards of Performance for Portland Cement Plants, establishes emission
standards for cement kiln operations. Specifically, kilns constructed or reconstructed after June 16,
2008, are limited to 0.4 lbs SO2/ton clinker on a 30-day rolling average respectively. This limit is
an existing emission limit in the Leamington Plant's approval order and Title V. Ash Grove will
continue to achieve this emission limitation while achieving BACT for the kiln operations. Ash
Grove has reviewed the following sources to identify available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019); and

NSPS Subpart F as an affected emissions facility in 40 CFR 60.62(a)(4);

Portland Cement Association's Formation and Techniques for Control of Sulfur Dioxide and Other
Sulfur Compounds in Portland Cement Kiln Systems.

SO2 emissions are a result of oxidation of sulfur compounds in the rawmix and/or the coal used to
fire the kiln. However, the alkaline nature of the cement provides for direct absorption of SO2 into
the product, thereby mitigating the quantity of SO2 emissions in the exhaust stream.

Step 1 - Identify All Control Technologies
Control technologies identified for SO2 emissions from coal-fired kiln operations are as follows:
Baghouse or fabric filter;
Dry reagent injection prior to baghouse;
Wet scrubber;
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Process optimization; and
Good combustion practices.

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below:

1. Process Optimization 99%
2. Wet Scrubber 99%
3. Dry Reagent Injection 60%
4. Good Combustion Practices 30%
5. Baghouse Variable

Step 4 - Evaluate Most Effective Controls and Document Results
SO2 emissions are most effectively controlled by optimizing the process and utilizing the inherent
SO2 scrubbing properties of the kiln system itself. Although wet scrubbers alone can achieve equal
control efficiencies as process optimization, additional capital and operational expenses are
required for water consumption and wastewater discharge. Whereas process optimization achieves
the same control effectiveness and has the added benefit of reduced operational costs. Ash Grove
optimizes the kiln process by routing the exhaust from the kiln to a preheater and raw mill to
interact with the raw mix, thus creating an atmosphere similar to a dry scrubber system. Good
combustion practices also reduce SO2 formation with the added benefit of energy efficiency.

Step 5 - Select BACT
BACT for control of SO2 emissions from kiln operations shall consist of process optimization by
routing kiln exhaust to the preheater and raw mill, good combustion practices, and use of a
baghouse prior to exhausting to the atmosphere. As a modification of the kiln, 40 CFR 60.62(a)(4)
requires an emission limit of 0.4 pounds of sulfur dioxide (SO2) per ton of clinker on a
30-operating day rolling average. [Last updated January 14, 2025]

10. BACT review regarding SO2, VOC, and Lead Sources cont.
VOC - Cement Kiln BACT
VOCs are generated by incomplete combustion in the kiln. 40 CFR 63 Subpart LLL - NESHAP
from the Portland Cement Industry limits total hydrocarbon and total organic HAP emissions to 24
and 12 ppmv at 7% oxygen. Ash Grove will achieve or exceed these emission limitations while
achieving BACT for the kiln operations. Ash Grove has reviewed the following sources to identify
available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028); and

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for VOC emissions from coal fired kiln operations are as follows:
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Process optimization,
Good combustion practices

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below.

1. Process Optimization Variable
2. Good Combustion Practices Variable

Step 4 - Evaluate Most Effective Controls and Document Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove optimizes the
kiln process by capturing waste heat from the clinker cooler and routing to a kiln preheater. Good
combustion practices also reduce VOC formation with the added benefit of energy efficiency.
There are no adverse energy, environmental or cost impacts to consider with the use of this control
technology.

Step 5 - Select BACT
BACT for control of VOC emissions from kiln operations shall consist of process optimization by
routing kiln heat to the preheater and good combustion practices. An emission limit of 24 ppmv
VOC @ 7% O2 is imposed by NESHAP Subpart LLL.

VOC - Grinding Aid BACT
A grinding aid containing VOC is added to the new finish mill to disperse particles within the mill
and expose more surface area to grinding. An increase in grinding aid usage proportionally
increases potential VOC emissions because volatiles from the grinding aid are not combusted in
the kiln.

There is only one identified control option for limiting the VOC emissions from the grinding aid.
Process optimization is technically feasible. VOC emissions are most effectively controlled by
optimizing the process. Ash Grove proposes to install a vertical finish mill with this project. Due to
the new modern mill's efficiency, it is anticipated that a reduced amount of grinding aid will be
required for each ton of clinker ground. Ash Grove estimates total VOC emissions from the
grinding aid at 2.37 tpy.

Lead Emissions
The lead emissions are anticipated to increase as a result of the proposed increase in clinker
throughput with the Leamington Plant upgrade project. Lead emissions result from residual
amounts of lead in raw materials and fuel. Lead emissions will be controlled the same as PM,
therefore a separate top-down BACT analysis has not been conducted as the Leamington Plant has
applied the most effective controls. [Last updated January 14, 2025]

11. BACT review regarding Greenhouse Gases
GHG Background
On October 9, 2009, the mandatory GHG reporting regulation, referred to as 40 CFR 98, was
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published in the Federal Register. Through 40 CFR 98, the U.S. EPA established the GHG
Reporting Rule, which requires the annual reporting of GHG data and other relevant information
from large sources and suppliers in the United States. Monitoring through the GHG Reporting
Program (GHGRP) began in 2010, with the first reports due by March 31, 2011. Per 40 CFR
98.2(a)(1), any facility associated with cement production is subject to the GHGRP and must report
CO2e emissions. The CO2e is the sum of equivalent GHG emissions from CO2, CH4, and N2O,
with their respective global warming potentials (GWP) applied. Ash Grove's facility is subject to
GHG Reporting Rule and monitors CO2 emissions from its kiln with a continuous emissions
monitoring system (CEMs). On June 23, 2014, the U.S. Supreme Court held that required PSD
permits (based on emissions of non-GHG pollutants) may continue to require limitations on GHG
emissions based on the application of BACT as an "anyway source". The Leamington Plant
modification project is a major source for PSD for both PM10 and PM2.5, and GHGs are estimated
to be greater than 75,000 tpy and greater than zero on a mass basis; therefore, GHGs are evaluated
for BACT as an anyway source.

Cement Manufacturing GHG BACT
A BACT analysis has been conducted for CO2e emissions from the kiln system. For this GHG
BACT analysis, various control technologies or combinations of technologies were identified using
the RACT/BACT/LAER Clearinghouse, available literature including guidance published by EPA
and South Coast Air Quality Management District (SCAQMD), current air regulations, other
regulatory organizations, and engineering experience. In March 2011, EPA published GHG
permitting guidance, as well as a white paper on available and emerging technologies for reducing
GHG emissions from the Portland cement industry in October 2010. Additionally, EPA published a
series of videos on GHG permit training in December 2010. The SCAQMD published GHG BACT
guidance in 2021. Additional sources of information were reviewed and documented based on
publications from trade organizations and other governmental committees with GHG or carbon
reduction guidelines and/or recommendations.

EPA has defined in 40 CFR 86.1818-12(a) GHGs as a group of six gases: CO2, nitrous oxide
(N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF6). GHG emissions from the kiln result from calcination and fuel combustion.
Since the primary GHG emitted by a kiln is CO2, the BACT analysis focuses on CO2 emissions
from the kiln. Emissions of CH4 and N2O are minimal from cement kilns. Per EPA guidance, GHG
control technologies for consideration in a BACT analysis for Portland Cement Manufacturing
include:

Source-wide energy efficiency strategies;
Raw material substitution;
Blended cements;
Carbon capture utilization and storage; and
Fuel switching.
Other emerging technologies [Last updated January 14, 2025]

12. BACT review regarding Greenhouse Gases cont.
Step 1: Identify All Control Technologies
The CO2 emissions from a cement kiln are generated by the calcination process (conversion of the
calcium carbonate in limestone to calcium oxide) and by combustion of fuel in the kiln. Potential
control technologies to reduce these CO2 emissions for a cement kiln are addressed in EPA's white
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paper on Available and Emerging Technologies for Reducing GHG Emissions from the Portland
Cement Industry.

These technologies fall into three categories:
Energy Efficiency Improvements for the Clinker Production Process
Fuel Substitution
Carbon Capture and Sequestration

Step 2: Eliminate Technically Infeasible Options
Several potential energy efficiency improvements are technically feasible: Pre-heater/Pre-calciner
Kiln Process, Kiln Seal Management Program, Refractory Selection (Kiln Insulation), and Energy
Recovery from the Clinker Cooler. The use of alternative fuels such as natural gas, whole tires and
biofuel) is also technically feasible. Other control options, such as Use of Fluxes and Mineralizers,
Heat Recovery for Power - Cogeneration, Carbon Sequestration, Oxyfuel combustion, and
Post-combustion Capture have been deemed infeasible.

Step 3: Rank Remaining Control Technologies by Control Effectiveness
All four remaining control techniques are currently implemented at the Leamington Plant. This
permitting project incorporates energy efficiency improvements. Ash Grove has had a fuel
substitution program in place for several years, and this program is continually reviewed and
updated as new sources and types of fuel are identified.

Step 4: Evaluate Most Effective Controls and Document Results
Since all technically feasible energy efficiency improvements and changes to product composition
will be implemented, this section will focus on economic and environmental considerations of fuel
substitution to operate exclusively on natural gas.

Firing natural gas as the primary kiln fuel can reduce CO2 emissions from fuel combustion by as
much as 40%. However, studies have shown that use of natural gas as primary kiln fuel can result
in three times more NOx emissions than NOx emissions from coal firing. Creating more NOx to
reduce GHG emissions is undesirable as it is a precursor to both ozone and PM2.5. Fuel substitution
essentially trades emissions of one regulated pollutant for another. Estimated capital cost to switch
to natural gas fuel exceeds $25M. Implementing natural gas technology would provide incremental
public health and welfare benefit globally by reducing CO2 emissions, while increasing NOx
emissions and negatively impacting public health and welfare locally. Switching fuels to another
fossil fuel has finite potential to mitigate CO2 emissions.

Step 5: Select BACT
In addition to the proposed energy efficiency improvements addressed elsewhere in this BACT
analysis, BACT is a limit of 0.92-ton CO2e/ton clinker. Ash Grove will use a continuous emission
monitoring system (CEMS) for CO2 to demonstrate compliance with this limit. [Last updated
January 14, 2025]

13. BACT review regarding Leamington Plant Upgrade Project conclusion
The control processes and techniques covered in this BACT analysis have been reviewed by the
NSR Section of the UDAQ. Ash Groves proposed controls and associated emission limitations
represent BACT. Any emission limitations not expressed in an associated NSPS or NESHAP will
be included in the terms and conditions of this AO. A listing of all associated NSPS and NESHAP
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programs is also included in the Source Information section of this document under Applicable
Federal Programs. [Last updated December 13, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
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.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date
of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
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proper credit when notifying the Director, send the documentation to the Director, attn.: NSR
Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

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

II.A.3
NEW
Stockpiles
Coal storage
Area: 1 acre
Annual throughput 20,000 tpy

AF and ARM stockpiles
Area: 0.25 acre
Annual throughput 8,000 tpy

II.A.4 Stationary Crusher
Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction
of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000
acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)

II.A.5 Raw Material Transfer
Crushed material is transported to raw material storage by belt B8. The raw material transfers
at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor
transfer point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total
filter area & water sprays. (pre-1983)

II.A.6 Material Handling
Conveyor belt systems, secondary feeders and screens, stacker system

II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit specific requirements

II.A.8 Belt Conveyor Transfer Baghouse
Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area
and 1,800 acfm total air flow, controls emissions from the conveyor belt that transfers the
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stacked material to the raw material silos.

II.A.9 Raw Material Silos
Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The
four silos are equipped with one common Fuller, plenum pulse baghouse (315.BF1) - 1,689 ft2
filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage).

II.A.10 Fifth Component Silo
Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse
(315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw
mill feed. This system includes vibrating feeders, a conveyor system, and surge bin.
Emissions are controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3,
316.BF4, 316.BF5) - each is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1
A/C ratio.

II.A.12 Cross-Belt Analyzer
Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6)

II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom
of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw
materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38).
The following equipment is installed: low-NOx burner, selective non-catalytic reduction
(SNCR) for NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued
mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric
monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct
for mercury adsorption capacity. The carbon injection system is not an emission point as it is
in an enclosed building.

II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

II.A.16 Two Kiln Feed Blending Silos
Raw material is blended in one of two blending silos prior to feeding the kiln. The blending
silos are controlled by one common Fuller, plenum pulse baghouse (411.BF1) - 1,351 ft2 filter
area; 7,160 acfm total air flow.

II.A.17 Blending Silo Elevators (2)
Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped
with a Fuller, pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow
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through stack E34.

II.A.18 Kiln Feed Alleviator
A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the
central material silo between the blending silos and the preheater. Raw feed is removed from
the system near the top of the preheater tower.

II.A.19 Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner.
The coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter
area; 1,700 acfm total air flow.

II.A.20 Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in
the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2):
19,500 acfm rated airflow with 3.75:1 A/C ratio

II.A.21 Clinker Cooler and Baghouse
Reconstructed grate type cooler used for cooling clinker from the kiln prior to transfer to
clinker storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) -
173,869 acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter
monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two
clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse
(419.BF8). The exhaust is routed to the clinker cooler stack.

II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions
generated when loading the east and west clinker silos and the out-of-spec silo are controlled
by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1):
1,800 acfm, that discharges into the clinker tunnel.

II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm, that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2)
Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers.
Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses
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(511.HP1 and new 511.HP2): 1,800 acfm each.

II.A.27 Gypsum Silo
Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2
total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust
during loading.

II.A.28 Clinker Tunnel Exitway
The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse
(511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel all discharge in the clinker tunnel.
Emissions are vented through the tunnel exitway.

II.A.29 Limestone Silo
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust
during loading. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement product. Dust
generated during milling is captured by a BHA, pulse jet baghouse (514.BF2) - 6,080 ft2 filter
area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding
stack).

II.A.31 Finish Mill (Ball Mill) Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized
cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA, pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow
controlling particulates from stack G55 (finish mill stack).

II.A.32
NEW
Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The
stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4)
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1,
525.BF1 thru 3)

II.A.33 Finish Cement Storage Silos
There are six storage and two interstice silos where the finished cement product is stored. A
single common Fuller, plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm
total air flow through stack H7 is located on top of the silos and is used to control emissions
during loading and unloading operations.

II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail
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shipping. This baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out
The cement loadout system located on the South side of the silos (truck load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF2) during unloading from the silos for truck
shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement
conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed
space inside the silos.

II.A.36
NEW
Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

II.A.37 MHO: Materials Handling Operation
Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1
& 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4;
512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.

II.A.38 LBS: Limestone Bypass System
Additional limestone is added to the clinker and gypsum by the limestone bypass system
(LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays
at the screen and material handling drop points.

II.A.39 GEN: Emergency Generators
One diesel-fired emergency generator (new)
Rating: 762 hp
(Kiln, Tier 3, permitted 2022)

Two natural gas-fired emergency generators
Rating: 304 hp
(Main office and control room, permitted in 2023)

One diesel-fired emergency generator
Rating: 560 hp
(Shipping, permitted 2023).

II.A.40 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14 inch knife gate, 8 inch knife gate, 8 inch air
slides, surge bin), and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm)
on the fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

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II.A.41
NEW
Miscellaneous Storage Tanks
One diesel storage tank (<2,000 gallons)
One gasoline storage tank (500 gallons)
Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Requirements on the Cement Plant:
II.B.1.a
NEW
The following limits shall not be exceeded:

A. Clinker production - 1,155,000 tons per rolling 12-month period

B. Used oil consumption - 85,724 gallons per rolling 12-month period

C. Limestone bypass material processed - 216,260 tons per rolling 12-month period.
[R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 25th day of each month using data from the previous 12 months.
Records shall be kept for all periods when the plant is in operation. Consumption and
production shall be calculated through use of the plant's acquisition system. [R307-401-8]

II.B.1.b
NEW
Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations:

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

SO2: 0.4 lbs per ton of clinker (3-hr average)

CO: 3,395 tons per rolling 12-month period, and 6,600 lbs/hr

NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average, and 1,233 tons per rolling
12-month period

Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is
400oF or less.

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Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)

THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)

CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)

PM: 0.02 lbs filterable PM per ton of clinker. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL,
R307-401-8]

II.B.1.c
NEW
A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR
60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust
emissions control plan shall be monitored to demonstrate that appropriate control measures are
being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of
the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall
be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in
the plan and that the source is operating in accordance with the submitted plan. For petitions
to approve alternative control measures, the permittee shall keep a copy of the submitted
petition and any approvals received. [40 CFR 60 Subpart Y]

II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area
source of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2). [40 CFR
63 Subpart LLL]

II.B.1.e
NEW
Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b
and II.B.1.d shall be performed as specified below:

A. Kiln/Raw Mill Stack
Pollutant Test Status Test Frequency
PM * #

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

B. Clinker Cooler (F31)
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Pollutant Test Status Test Frequency
PM + #

C. Testing Status (To be applied above)
* The initial testing has already been performed.

** The SO2 initial performance test was conducted on August 26, 2013.

*** The initial compliance test shall be conducted within the first 30 operating days of
operation in which the affected source operates using a CEMS.

# Test once every year. If performance testing would be required less than 15 operating days
after the Kiln has completed Startup after being down for more than 24 hours, then
performance testing may be deferred up to 15 operating days after completion of the Startup.
The Director may require testing at any time.

## Test at least once every two years. The Director may require testing at any time.

+ Initial testing is required within 180 days of startup of the reconstructed equipment

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must 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 PM CPMS is not out-of-control. The owner/operator must
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 on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

+++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.e.1
NEW
Notification
The Director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The notification requirements for performance tests subject to 40
CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-165]

II.B.1.e.2
NEW
Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational
Safety and Health Administration (OSHA)- or Mine Safety and Health Administration
(MSHA)-approved access shall be provided to the test location. [R307-165]

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II.B.1.e.4
NEW
PM
40 CFR 60, Appendix A, Method 5 or 5I or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three (3) runs with
each run at least 120 minutes in duration and each run collecting a sample of 60 dry standard
cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.3
NEW
Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2. [R307-165]

II.B.1.e.5
NEW
Carbon Monoxide (CO)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.6
NEW
Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.7
NEW
Sulfur Dioxide (SO2)
40 CFR 60, Method 6 or 6C of Appendix A-4 or other EPA-approved method as acceptable to
the Director. [R307-165]

II.B.1.e.8
NEW
Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]

II.B.1.e.9
NEW
Total Hydrocarbons (THC)
Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL]

II.B.1.e.10
NEW
Mercury (Hg)
Continuous Emission or integrated sorbent trap monitoring (See Condition II.B.3.a). [40 CFR
63 Subpart LLL]

II.B.1.e.11
NEW
HCl
Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other
EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]

II.B.1.e.12
NEW
Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.13
NEW
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. [R307-165]

II.B.1.e.14
NEW
Existing Source Operation
For an existing source/emission point, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three years.
[R307-165]

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II.B.1.e.15
NEW
New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the maximum production rate listed in this AO. If the maximum AO
allowable production rate has not been achieved at the time of the test, the following
procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This new
allowable maximum production rate shall remain in effect until successfully tested at a higher
rate.

3) The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate (110%
of the new rate) will then be allowed if the test is successful. This process may be repeated
until the maximum AO production rate is achieved. [R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL.
[40 CFR 63 Subpart LLL]

II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times
of Dust Shuttle System operation to assist in the capture of Mercury emission. [R307-401-8]

II.B.1.h
NEW
Visible emissions from the following emission points shall not exceed the following values:

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

L. All baghouses - 10% opacity
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M. Fugitive dust - 20% opacity

N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y,
R307-401-8]

II.B.1.i 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 must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

If any partially enclosed or unenclosed conveying system transfer point is located in a
building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to
40 CFR 60, according to the following:

(i) The owner/operator must conduct a monthly ten-minute visible emissions test of each
affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The
performance test must be conducted while the affected source is in operation.

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator 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 owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iii) If no visible emissions are observed during the semi-annual test for any affected source,
the owner/operator 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 owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iv) If visible emissions are observed during any Method 22 performance test, of Appendix
A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations,
recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60.
The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour
of any observation of visible emissions.

(v) If visible emissions from a building are monitored, the requirements of paragraphs (i)
through (iv) of this Condition apply to the monitoring of the building, and the owner/operator
must also test visible emissions from each side, roof, and vent of the building for at least ten
minutes. [R307-401]

II.B.1.j
NEW
Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed
0.005 gr/dscf:

520.BF1
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520.BF2
520.BF3
520.BF4
521.BF2
521.BF1
524.BF1
524.BF2
524.BF4
524.BF3
525.BF1
525.BF2
525.BF3
511.HP2
NRL_UPR
NRL_LWR. [R307-401-8]

II.B.1.j.1
NEW
To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration
through at least three (3) annual tests that the PM limits are not being exceeded, the
owner/operator may request approval from the Director to conduct stack testing less
frequently than annually. [R307-401-8]

II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive
dusts as dry conditions warrant or as determined necessary by the Director to maintain opacity
limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated to control fugitive dust. The application of
water or chemical treatment shall be used. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a damp/moist condition unless it is below freezing.
If chemical treatment is to be used, the plan must be approved by the Director. Records of
water and/or chemical treatment shall be kept for all periods when the plant is in operation.
The records shall include the following items: Instances of water and/or chemical application
to unpaved areas shall be recorded and maintained by the owner/operator. The ambient
temperature shall be recorded any time water should be applied but cannot due to freezing
conditions. [R307-401-8]

II.B.2.c
NEW
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

The sprays shall operate whenever dry conditions warrant meeting the required opacity
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limitations or as determined necessary by the Director. Water sprays shall not be required
during periods of freezing temperatures. [R307-401-8]

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation
of fugitive dusts as dry conditions warrant or as determined necessary by the Director.
[R307-401-8]

II.B.2.e
NEW
The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5
PM. [R307-401-8]

II.B.3 Continuous Emission Monitoring Requirements:
II.B.3.a
NEW
The owner/operator shall install, calibrate, maintain and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler.

A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the
missing data substitution procedures used by the UDAQ or the missing data substitution
procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate by the UDAQ.

B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period
including during each startup, shutdown, or malfunction.

C. The monitoring system shall comply with all applicable sections of R307-170, UAC; and
40 CFR 60, Appendix B.

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be
installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the
kiln/raw mill stack.

F. The owner/operator shall record the output of the system: including the quantity of NOx,
CO, O2 THC, Hg, HCl, and CO2 emissions at the kiln stack.

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source 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.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker
cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except
during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments,
the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a
PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the
results of the performance test demonstrating compliance with the filterable PM limit and
using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust
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the SSOL developed in accordance with the results of the most recent PM performance test
demonstrating compliance with the PM emission limit. The owner/operator shall use the PM
CPMS to demonstrate continuous compliance with the SSOL in accordance with the
requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

II.B.4 Fuel Limitations:
II.B.4.a
NEW
The owner/operator shall use only the following fuels in the kiln and pre-calciner:

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.

If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b
NEW
Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the
Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the
results of suitable tests giving data similar to a Proximate and Ultimate analysis of the
proposed coal additive. [R307-401-8]

II.B.4.b.1 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. [R307-401-8]

II.B.4.b.2 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 owner/operator 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 in Condition
II.B.4.b. [R307-401-8]

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II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel burning or process
installation not covered by New Source Performance Standards for sulfur emissions or
covered elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross
Btu heat input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input
for any oil except used oil. The sulfur content shall comply with all applicable sections of
UAC R307-203. [R307-203, R307-401-8]

II.B.4.c.1
NEW
Certification of fuels shall be either by the owner/operator's own testing or test reports from
the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be
available onsite. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials, UAC R307-203-1 (4)

A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be
used.

B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be
used.

C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85 are to be used. [R307-203]

II.B.4.d
NEW
The concentration/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight
3) Cadmium 2 ppm by weight
4) Chromium. 10 ppm by weight
5) Lead 100 ppm by weight
6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be
tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the burn tank and burned. [R307-401-8]

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II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned
in the rotary kiln:

A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than
five minutes in any 60-minute period

B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes
in any 60-minute period. [R307-401-8]

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the
Director. The calibration procedure and frequency shall be according to manufacturer's
specifications. Use of factory-calibrated thermocouples for temperature measurement is
approved. However, any other method of temperature measurement must be approved by the
Director prior to use. The monitoring equipment for both temperature and oxygen content
shall be located such that an inspector can at any time safely read the output. [R307-401-8]

II.B.5
NEW
Emergency Engine Requirements
II.B.5.a
NEW
The owner/operator shall only operate the emergency engines for testing and maintenance
purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency
operation. [R307-401-8]

II.B.5.b
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each emergency engine. [R307-401-8]

II.B.5.b.1
NEW
The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.5.b.2
NEW
To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN103030035-24 dated November 27, 2024
Is Derived From Source Submitted NOI dated November 30, 2022
Incorporates Additional Information Received dated April 26, 2023
Incorporates Additional Information Received dated September 26, 2023
Incorporates Additional Information Received dated July 23, 2024
Incorporates Additional Information Received dated October 25, 2024
Incorporates Additional Information Received dated November 25, 2024

REVIEWER COMMENTS

1. Comment regarding applicability of federal requirements:
New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable
by the best demonstrated technology as specified in the applicable provisions. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.

40 CFR 60, Subpart A (General Provisions)
All affected facilities subject to a source-specific NSPS are subject to the general provisions of
NSPS, Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires
initial notification, performance testing, recordkeeping, and monitoring, provides reference methods,
and mandates general control device requirements for all other subparts.

40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of
performance for affected facilities in Portland Cement Plants which have been constructed or
modified after August 17, 1971.

40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart
F: Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and
unloading systems. The Leamington coal mill is an in-line coal mill and considered an integral part
of the Leamington kiln. In-line coal mills are not subject to NSPS Subpart Y. Therefore, the coal mill
is addressed under NSPS Subpart F as part of the kiln system. The coal silos and conveying system
are subject to NSPS Subpart Y.

Ash Grove's proposed changes to the kiln system must be evaluated as to whether they trigger new
NSPS Subpart F obligations based on whether the proposed project is either a modification or a
reconstruction, as those terms are defined in NSPS Subpart A.

Ash Grove's proposed changes to the kiln system do not meet the definition of a reconstruction, nor
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Page 40

do they meet the definition of a modification for NOx. However, the changes meet the definition of a
modification for PM and SO2. Therefore, Ash Grove will comply with all relevant emission
standards; testing requirements; monitoring, recordkeeping, and reporting obligations that apply to
the Leamington kiln system as an existing source under NSPS Subpart F. Under NSPS Subpart A
and F, the clinker cooler is considered a reconstructed unit. Thus new limits will apply to this unit.
[Last updated January 14, 2025]

2. Comment regarding applicability of federal requirements cont.:
NSPS Subpart Y - Standards of Performance for Coal Preparation and Processing Plants
This subpart provides standards of performance for affected facilities in coal preparation and
processing plants that process more than 200 tons of coal per day.

The Leamington plant's coal silo and coal conveying system are existing affected facilities under
NSPS Subpart Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses
controlling affected facilities subject to match the limit in NSPS Subpart Y from 0.016 gr/dscf to
0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade Project. Since there are no proposed
modifications or reconstruction to the coal silo and coal conveying system, nothing about the
proposed upgrade project affects the existing applicability of NSPS Subpart Y.

NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
This subpart provides standards of performance for affected facilities located at fixed or portable
nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August
31, 1983, with additional requirements applicable to sources constructed on or after April 22, 2008.

As the crushing and screening system is controlled by baghouses and an increase in PM10 actual
emissions on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS.
Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the
Leamington Plant Upgrade Project.

Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1),
60.676(f), and 60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO
monitoring and recordkeeping requirements.

[Last updated January 14, 2025]

3. Comment regarding applicability of federal requirements cont.:
National Emission Standards for Hazardous Pollutants (NESHAPs)
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or
greater than 10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as
specified by each subpart. NESHAP apply to sources in specifically regulated industrial source
classifications (CAA Section 112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities
not regulated as a specific industrial source type. The Ash Grove Leamington Plant is a major source
of HAPs and thus is subject to certain NESHAP standards.

Subpart A - General Provisions
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All affected sources are subject to the general provisions of Subpart A unless otherwise specified by
the source-specific NESHAP. Subpart A generally requires initial notification and performance
testing, recordkeeping, monitoring, provides reference methods, and mandates general control device
requirements for all other subparts as applicable.

Subpart LLL - Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry
This subpart establishes process/source specific emission limits for PM, VOC (expressed as total
hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and
gaseous HAP compounds by limiting PM and THC emissions because portions of such emissions
are USEPA-listed HAPs. Subpart LLL requires compliance with applicable emissions limits on and
after the initial startup of cement production. To further reduce emissions, Subpart LLL also
establishes operational requirements for the use of cement kiln dust (CKD), fly ash, fuel and control
equipment. Subpart LLL also specifies process/source specific emissions testing, monitoring,
recordkeeping, reporting, and compliance demonstration requirements. The compliance requirements
for the site are detailed in Approval Order Condition II.B.1.b. Ash Grove will continue to comply
with the requirements of Subpart LLL to demonstrate compliance. This cement kiln will remain an
existing source with respect to the kiln emission standards in Subpart LLL as this project does not
trigger the definition of a new source in Subpart LLL. New source standards apply only to affected
sources that were constructed or reconstructed after May 6, 2009.
[Last updated December 20, 2024]

4. Comment regarding PSD applicability analysis:
Ash Grove is proposing to increase the throughput of limestone from the quarry to supply the New
Finish Mill to increase the amount of low-carbon cement from the Leamington Plant. Additionally,
along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
modified, and the clinker cooler will be reconstructed. These changes are anticipated to result in an
increase in clinker production. Emission calculations for this project have been completed assuming
an increase in clinker production capacity while utilizing current fuel types. This will result in an
increase in the throughput of fuel.

The Leamington Plant is considered an existing major source under PSD based on potential
emissions of PM10, PM2.5, NOx, CO, SO2, and CO2e. If a major source undergoes a physical or
operational change, the facility must determine whether the project will be considered a major
modification. Per 40 CFR 52.21(b)(2)(i), in order to be a major modification, the project must result
in a significant emissions increase, and a significant net emissions increase.

As defined at 40 CFR 52.21(b)(40): Significant emissions increase means, for a regulated NSR
pollutant, an increase in emissions that is significant for that pollutant. Significant is further defined
to mean, in reference to a net emissions increase or the potential of a source to emit any of the
following pollutants, a rate of emissions that would equal or exceed the values outlined in 40 CFR
52.21(b)(23). If the increase in emissions from the project are not significant, a major modification
has not occurred.

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
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increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

For all pollutants, the project emissions increase was calculated as the difference between the
projected actual emissions (PAE) after the proposed project and the actual emissions prior to the
project (baseline actual emissions or BAE).

Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
". . . projected actual emissions means the maximum annual rate, in tons per year, at which an
existing emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years
(12-month period) following the date the unit resumes regular operation after the project, or in any
one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit of that regulated NSR pollutant and full utilization of the unit would
result in a significant emissions increase or a significant net emissions increase at the major
stationary source." [Last updated January 14, 2025]

5. Comment regarding PSD applicability analysis cont.:
Ash Grove estimates that the projected actual production capacity following the project will be
1,155,000 tons of clinker per year and 1,341,266 tons of limestone per year. These capacities were
used to calculate projected actual emissions from the project using representative emission factors.
Additionally, to estimate emissions from material transfer baghouses, the actual flow rates and actual
projected hours were used as a basis for projected actual emissions.

Project Emission Calculations

Project emission increases from the kiln and coal mill systems are calculated for all criteria
pollutants based on emission factors that are derived from stack testing, CEMS data, or emission
factors (i.e., VOCs and Lead), and the associated projected incremental clinker increase.

NOx emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain
hourly capacity to emit and annual potential to emit at current levels. The kiln's NOx emissions rate
will not change as a result of the physical modifications proposed by the project.

Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission
factor and multiplied by the incremental increase in clinker production. The emission factor was
selected based on the average of the 24-month consecutive month emissions for 2020 and 2021. The
CO emissions will increase.

The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing
conducted at the plant. The SO2 emissions will increase.

VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production. VOC emissions will increase.

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 43

can be found in the original NOI and subsequent addendums submitted to UDAQ.

As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from
the proposed project, each increase of emissions from both existing and new sources shall be
summed together and compared to the PSD permitting thresholds. The increase of emissions is the
"positive" difference between the projected actual emissions and baseline actual emissions (projected
minus baseline).

New Emissions Sources

The actual to projected actuals calculation is not available to new emission units. For new emission
units, the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected
emissions are based on the new sources' potentials to emit. (40 CFR § 52.21(a)(2)(iv)(f)).

The new equipment proposed includes the New Finish Mill, a new rail and truck loading/loadout,
one (1) new clinker reclaim loading hopper with a dust collector and one (1) existing clinker reclaim
hopper with a dust collector, a new Clinker Cooler to replace the existing one, and a new kiln feed
alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions:

The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;

The finish mill heater was calculated based on its maximum firing capacity and flow rates; and

The fugitive emissions were calculated based on the projected annual throughput of the New Finish
Mill, the rail loadout, and clinker production. [Last updated January 14, 2025]

6. Comment regarding PSD applicability analysis cont.:
Existing Emission Sources

For the existing sources, the projected actual emissions are the maximum annual rates in tons per
year projected to occur during the next five (5) to ten (10) years if the existing sources' design
capacities increase. Ash Grove Leamington projected the actual emissions for the next five (5) years
based on the new kiln system producing an annual average of 3,250 tons of clinker per day.

Baseline actual emissions (BAE) are defined at 40 CFR 52.21(b)(48)(ii) as:

". . . baseline actual emissions means the average rate, in tons per year, at which the emissions unit
actually emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the 10-year period immediately preceding either the date the owner or operator
begins actual construction of the project, or the date a complete permit application is received by the
Administrator."

Ash Grove has selected to use the years 2020 and 2021 for each pollutant as the representative
baseline years.

In its NOI, Ash Grove calculated the emission increase from the project as being divided into two
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 44

phases. Phased construction projects are discussed in two sections of the federal PSD regulations -
40 CFR 52.21(j)(4) and 40 CFr 52.21(r)(2). UDAQ is not processing this project as a phased
construction project, nor did Ash Grove request such a determination. Therefore, Ash Grove
provided a summary table outlining the final change in emissions from this project:

Projected Actual Increase Compared to PSD threshold (tons per year)
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2e
BAE 76.64 39.64 1,187 6.87 3,315 55.47 641,385
PAE 203.15 113.47 1,226 45.87 3,414 72.07 1,067,984

Change in Emissions 126.51 73.83 39.00 39.00 99.00 16.59 426,598

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes

If the emissions increase is greater than the PSD significance threshold for a particular pollutant, Ash
Grove has the option of conducting a PSD review or continuing through the rest of the steps to
determine if it can "net" out of a PSD review. If the project increase is less than the PSD significant
threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant.

The change in emissions from the project exceeds the significant emission threshold for three
pollutants: PM10, PM2.5 and CO2e. Ash Grove elected to attempt to net out of a PSD major
modification for the remainder of the criteria pollutants.

Netting

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant
Upgrade Project and ends on the date the upgrade begins operation. Only PM10, PM2.5, CO2e are in
excess of SERs and therefore considered in the netting analysis.

Ash Grove estimated that the commencement of construction will be in December 2024. Therefore,
the contemporaneous period for this project is December 2019 through a projected date the project
upgrade begins operation. [Last updated January 21, 2025]

7. Comment regarding PSD applicability analysis cont.:
Contemporaneous Decreases

Ash Grove replaced an existing kiln emergency drive engine with a USEPA Tier 4 diesel engine in
2022. Concurrently, Ash Grove requested an increase in the capacity of 1L Cement. Additionally,
Ash Grove submitted a minor modification NOI air permit application on June 12, 2023, which
proposes replacing the shipping generator during the contemporaneous period. The kiln emergency
drive engine and shipping generator are both higher EPA tier ratings therefore result in decreases for
PM10 and PM2.5. These changes were approved in AO DAQE-AN103030033-24 issued March 21,
2024.

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Page 45

Contemporaneous Increases

As stated above, the existing kiln emergency drive engine and shipping generator were permitted and
replaced in 2024. This resulted in an increase in emissions of CO2e.

The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout
in an effort to improve truck traffic at the loadout. The modification to add these dust collectors to
the loadout was included in DAQE-AN103030029-19. The baghouses are three (3) levels up in the
silos' enclosed space (approximately 40 feet). Both dust collectors vent directly into the interior of
the silo structure and are not vented into the atmosphere. Ash Grove requests to remove these
baghouses from its existing permitted emissions inventory. Therefore, these emissions have been
documented in the netting analysis as zero emissions.

Also included in DAQE-AN103030033-24 were two new natural gas-fired emergency generators
and increases in stockpiles, material handling and road emissions.

Could Have Been Accommodated Emissions

In calculating project emissions increase, USEPA allows the exclusion of existing
production/emissions rates that could have been accommodated during the baseline period. These
"could have been accommodated" emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as
follows:

". . . Shall exclude, in calculating any increase in emissions that results from the particular project,
that portion of the unit's emissions following the project that an existing unit could have
accommodated during the consecutive 24-month period used to establish the baseline actual
emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project,
including any increased utilization due to product demand growth;"

Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the
exclusion of existing production and emissions rates that could have been accommodated during the
baseline period, it has elected not to use this exclusion at this time. Therefore, calculation of the
"could have been" accommodated emissions have not been included in this application's
applicability analysis.

The increase from the project is added to the contemporaneous decreases and contemporaneous
increases. The resulting calculation is then compared to the PSD significance threshold to determine
if a significant net emissions increase has occurred. [Last updated January 14, 2025]

8. Comment regarding PSD applicability analysis cont.:
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2 e
Contemporaneous Inc. 1.61 0.45 0.41 0 0.27 0.07 51.74

Contemporaneous Dec. -1.54 -3.97 -0.48 -0.02 -0.27 -0.09 0

Change in Emissions 125.02 69.21 38.93 38.98 99.00 16.58 426,650

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes
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Page 46

The results of the netting analysis conclude that both a significant emissions increase and a
significant net emissions increase in both particulates (PM10 and PM2.5) and CO2e will occur from
this project. Thus, the project must be reviewed as a PSD major modification. [Last updated January
14, 2025]

9. Comment regarding emission calculations:
This engineering review includes updated potential emission totals for both criteria and HAP
emissions. The potential-to-emit (PTE) values were calculated using updated values for clinker
produced and raw material inputs. BACT emission factors and limitations were used where
appropriate. Certain emission totals (NOx, SO2 and CO) were set based on avoiding a significant
increase in emissions. Specifically, the projected actual increase was set at just under the baseline
actual emissions + the significance level. As these emissions are monitored by CEM, UDAQ agrees
with this approach. Please see the netting analysis for further details on calculation of projected
actual increase. The NOx hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project.

CO2e emissions were calculated using the GHG emission factor calculated from 40 CFR Part 98
Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in Subpart A Table
A-1.

To calculate the PTE tons per year, the maximum hours (i.e., 8760) per year and the source's
emissions rates were multiplied with the throughputs. The potential throughputs have been updated
at UDAQ's request so that PAE is equal to PTE and represents the equipment's maximum design
potential.

Additional emission calculations based on source testing and monitoring, and EPA's compilation of
air emission factors AP-42. [Last updated January 14, 2025]

10. Comment regarding requirements for PSD review:
In addition to the permitting requirements of R307-401-5 through R307-401-8, there are additional
requirements under PSD that must be addressed:

1. Calculation of ambient air increments (40 CFR 52.12(c)), ambient air ceilings ((40 CFR 52.12(d)),
source impact analysis (40 CFR 52.12(k)), air quality models (40 CFR 52.12(l)) - these items are
addressed in the modeling memo DAQE-MN103030032-24.

2. Stack heights (40 CFR 52.12(h)) - Ash Grove's stack heights have been reviewed with respect to
good engineering practice and operate in a vertical unrestricted manner.

3. Control technology review (40 CFR 52.12(j)) - this is addressed in the BACT analysis section of
this review document.

4. Air quality analysis: preapplication analysis (40 CFR 52.12(m)) - this is covered in the PSD
applicability and netting analysis sections of this review document, ambient monitoring and
background data collection is also included in the modeling memo DAQE-MN103030032-24.

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 47

grain loading limit included in II.B.1.j.1 represents the required post-construction monitoring.
6. Source information (40 CFR 52.12(n)) - this is addressed under the requirements of R307-401-5
and was submitted by Ash Grove as part of the NOI package.

7. Additional impact analysis (40 CFR 52.12(o)) - these requirements cover soils, vegetation, growth
and visibility concerns. They are discussed in the modeling memo DAQE-MN103030032-24.

8. Federal land manager review (40 CFR 52.12(p)) - UDAQ provided initial notification to all
federal land managers upon receipt of the original NOI package. The draft permit and engineering
review will also be provided to the federal land managers 60-days prior to initiation of public
comment for their further review.

9. Public participation (40 CFR 52.12(q)) - this project will have a 30-day public comment period.

10. Source obligation (40 CFR 52.12(r)) - this requirement discusses source compliance with other
parts of the CAA, which is addressed within UDAQ's permitting rules in R307.
[Last updated January 14, 2025]

11. Comment regarding changes in equipment list:
The equipment list is being updated for clarity as well as adding new pieces of equipment. The
following changes are taking place:

The naming scheme is being updated to remove the numerical code from the unit designation. This
code generally referred to the associated control device and not to the emitting unit itself. This can
cause confusion especially when the same code was applied to multiple pieces of equipment.
Instead, the control devices (typically baghouse dust collectors) will be identified in the description
along with the appropriate numerical code.

Specific changes are as follows:

1. The kiln description has been updated

2. Clinker Cooler description has been updated to include a larger pulse jet baghouse.

3. The clinker storage silos, east and west clinker belts, clinker belt transfer and clinker tunnel have
been consolidated to avoid confusion

4. The north and south cement loadout exhausts now vent internally into the cement storage silos

5. The dust shuttle system has been consolidated into one line item, most identifiers removed from
subsystem descriptions as only two baghouses serve as exhaust points.

6. A new finish mill with heater has been added. Included in the description are the thirteen total
baghouses for dust control (1 main stack, 2 transfer points, 10 nuisance dust filters)

7. A new clinker reclaim hopper has been added. Both reclaim hoppers are controlled by baghouses
with updated identifiers

8. A new rail and truck loading/unloading system with two baghouses has been added.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 48

[Last updated December 20, 2024]

12. Comment regarding changes in conditions:
As a result of this project, several conditions will be added or changed. This includes one new
general condition (I.8). Changes to the equipment list (section II.A) will be addressed in a separate
reviewer comment:

I.8 - Adding this general condition to cover the requirements of R307-401-18 Eighteen Month
Review. The status of construction/installation of the new equipment shall be reviewed after
18-months.

II.B.1.a - Clinker production increases to 1,155,000 tpy
Use of limestone bypass material increases to 215,260 tpy

II.B.1.b - The NOx limit on the kiln decreases to 1,223 tpy, CO emissions from the kiln decrease to
3,395 tpy,
Adding a new CO2e limit of 0.92 tons CO2e/ton of clinker produced
PM limit on the clinker cooler decreased to 0.02 lb PM (filterable)/ton of clinker
Rule reference updated to include 40 CFR 60 Subpart F, and R307-401-8

II.B.1.e - Initial testing on the clinker cooler is now required within 180 days of startup of the unit.
Monitoring of CO2 from the kiln will be by CEM.
Formatting changes on paragraph designated ++, improve clarity, include reference to CO2
monitoring, define CPMS

II.B.1.e.4 - Update to address general PM monitoring and reference R307-401-8

II.B.1.e.14 - New condition to address new or reconstructed emission units monitoring requirements,
applicable to the clinker cooler and new finish mill.

II.B.1.h - Adding references to Subpart OOO units (limestone processing) with updated opacity
limits.
Adding 20% opacity limit on coal transfer and storage
Adding property boundary opacity limit of 20%
Updating rule reference to include Subpart OOO

II.B.1.j - New condition to address outlet grain loading limits on new baghouses, One identical limit,
15 total new baghouses.

II.B.1.j.1 - Monitoring on new baghouses as per II.B.1.e.4, added an allowance to test less frequently
than annually with three successful tests.

II.B.3.a - Updating formatting to add clarity and include reference to CO2 CEM

II.B.5 - New conditions on emergency engines, diesel fuel sulfur limits, hour of operation
restrictions, non resettable hour meter

[Last updated December 20, 2024]
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 49

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 51

TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 52

DAQE-MN103030032-24

M E M O R A N D U M

TO: John Jenks, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler
Dave Prey, Air Quality Modeler

DATE: December 12, 2024

SUBJECT: Modeling Analysis Review for the Ash Grove Cement Company – Leamington Plant,
located in Millard County, Utah
___________________________________________________________________________________
This is a Major Modification to a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Ash Grove Cement Company (Applicant) has submitted a Notice of Intent (NOI) air permit
application for a project referred to as the Leamington Upgrade Project (LUP). The proposed
upgrade project includes the construction and installation of new pollution control equipment, new
emission sources, and modifications to existing emission sources. Emission increases associated
with the LUP constitute a major modification to a Prevention of Significant Deterioration (PSD)
source subject to PSD permitting regulations. PSD regulations require the Applicant to include and
air quality impact analysis (AQIA) of the proposed projects impact on the EPA national ambient air
quality standards (NAAQS) and air quality related values (AQRV) as part of a complete NOI.

This report prepared by the New Source Review (NSR) modeling staff contains a review of the
Applicant’s Air Quality Impact Analysis (AQIA) including the methodology, data sources,
assumptions, and modeling results for comparison with State and Federal air quality standards. The
AQIA was reviewed and referenced in this report include the:
● Notice of Intent – Ash Grove Cement Leamington Plant PSD Notice of Intent Air Permit
Application, dated November 30, 2022.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

0 0
Jason Krebs

DP
DAQE-MN103030032-24
Page 2

II. APPLICABLE RULES AND ANALYSES

A Utah Air Quality Rules

The UDAQ has determined that the Applicant’s NOI is subject to the following rules for conducting an
AQIA:

R307-401 Permits: New and Modified Sources
R307-405 Permits: Major Sources Located in Attainment or Unclassified Area (PSD)
R307-406-2 Visibility – Source Review
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutant Impacts in Attainment Areas

B. Applicability

The proposed increases in emissions of PM10 and PM2.5 exceed the emission thresholds outlined in R307-
406-5 and R307-410-4. Therefore, an AQIA consistent with the requirements of R307-405-6, R307-406-
2, and R307-410-3 was submitted as part of the Applicant’s NOI. R307-410-3 establishes the U. S.
Environmental Protection Agency (US EPA) – Guideline on Air Quality Models as a formal basis for
defining the scope of the analysis, as well as the model’s construction. The results of the AQIA are
required to demonstrate the proposed project’s impact on state and federal air quality standards,
acceptable levels of impact, and action triggering thresholds referenced or listed in R307-401-6(2), R307-
401-6(3), R307-403-3(1), R307-403-5(1)(a), R307-405-4(1), R307-405-6. Annual emissions for criteria
pollutants requiring an AQIA are listed in Table 1.

Table 1: Ash Grove Leamington Proposed Net Emissions Increase

Criteria
Pollutants
Net Emission
Increase (TPY)
AQIA Trigger
Level (TPY) AQIA Required?
PM10 126.6 15 Yes
PM2.5 70.3 10 Yes

C. Required Analyses

R307-405 requires the Applicant to perform a pre-construction modeling analysis for all pollutants
emitted in a significant quantity. The purpose of the analysis is to determine if the extent of the source’s
impact is significant enough to warrant an on-site measurement of the ambient background concentration
levels. This data is included in the NAAQS analysis to represent the quality of the air prior to the
construction of the proposed project. The Applicant included a pre-construction modeling analysis for
PM10 and PM2.5 as part of the NOI. The pre-construction modeling analysis was also used to determine if
the proposed emissions would result in a significant impact to the environment, thereby triggering the
requirement for a cumulative analysis of the proposed project and other nearby existing sources.

R307-401-8 requires the Division to determine that the proposed project will comply with the NAAQS
prior to the issuance of an Approval Order (AO). R307-405(7) requires the Applicant to perform a
DAQE-MN103030032-24
Page 3
NAAQS analysis for all pollutants emitted in a significant quantity. The analysis is to include all
emissions at the proposed site under normal operating conditions using maximum anticipated short-term
release and annual release rates. Consistent with UDAQ policy, a cumulative analysis to include the
ambient background concentration and any contribution from other nearby sources is not required if the
proposed project’s impact does not exceed the PSD Class II Significant Impact Level (SIL).

R307-401-8 also requires the Division to determine that the proposed project will comply with PSD
increments prior to the issuance of an AO. Under R307-405(6), the Applicant is required to perform a
PSD Class I and II increment consumption analysis for all pollutants emitted in significant quantities.
The purpose of this analysis is to quantify any degradation in air quality since the major source baseline
date. The analysis is to include all increment consuming emissions at the proposed site under normal
operating conditions using maximum anticipated short-term and annual release rates. A cumulative
analysis to include contributions associated with growth and other increment consuming sources is not
required if the proposed project’s impact does not exceed the PSD Class I or II SIL.

R307-410-5 requires the Applicant to perform a HAPs analysis for any pollutant emitted above a
pollutant specific emission threshold value. This analysis is to include all emissions of the pollutants
resulting from the proposed modification under normal operating conditions using maximum anticipated
one-hour release rates. The Applicant did not trigger modeling for HAPs.

R307-406-2 requires the Applicant to perform a plume blight analysis. A plume blight analysis is required
to determine if plumes emanating from the proposed project would be visible inside any Class I area
within 50 kilometers of the source. The plume blight analysis is to include all emissions of NO2, SO4, and
PM10.

Under R307-405-16, an AQRV analysis is performed which evaluates regional haze and acid deposition
impacts at each of the Class I areas within 300 kilometers of the source. A regional haze analysis is
required to determine if the plumes would reduce the visual range of an observer inside the Class I area.
The regional haze analysis is to include all emissions of SO2, NOX and PM10. The deposition analysis
examines impacts from sulfur and nitrogen compounds at the Class I areas, and is based on all emissions
of SO2 and NOX. The Federal Land Managers use the Q/D approach to determine whether a PSD project
should provide detailed AQRV impact analyses, where: Q/D= [ H2SO4 + SO2 + NOx + PM10 emissions
(tpy)]/ distance (km). If Q/D is less than 10, no AQRV analysis is required.

R307-405 requires the Applicant to perform a soils and vegetation analysis. The analysis should quantify
the effects of pollutants on soils and vegetation near the highest impact location and in areas where
sensitive plant species may be impacted.

III. ON-SITE PRE-CONSTRUCTION MONITORING

A. Meteorological Data

Consistent with the US EPA - Meteorological Monitoring Guidance for Regulatory Modeling
Applications, one year of on-site data was collected using a 50-meter tower during the period October 1,
2021 through September 30, 2022. Parameters collected on-site included wind speed and direction,
temperature, delta-T, and solar radiation.

DAQE-MN103030032-24
Page 4

B. Ambient Pollutant Data

A preliminary analysis was conducted to determine the necessity for pre-construction ambient pollutant
monitoring. The results indicate that predicted concentrations of PM10 and PM2.5 exceed the monitoring
trigger level listing in the rule. A continuous PM10/PM2.5 monitor with filter based samplers was
installed near the northern edge of the Applicants property boundary, and collected particulate matter
from October 1, 2021 through September 30, 2022.

IV. MODEL SELECTION

The EPA-AERMOD dispersion modeling system is the preferred model specified in the US EPA –
Guideline on Air Quality Models to predict air pollutant concentrations in the near field (within 50
kilometers of the source). The US EPA - CALPUFF - Version 5.8 model is the preferred model to predict
concentrations in the far field (long range transport conditions beyond 50 kilometers from the source).

V. MODELING INPUTS AND ASSUMPTIONS

A. Technical Options

The regulatory default options were selected in AERMOD by the Applicant to quantify all concentrations.

B. Urban or Rural Area Designation

A review of the appropriate 7.5-minute quadrangles determined that the area should be classified as
“rural” for air modeling purposes.

C. Topography/Terrain

The Plant is at an elevation of 4,950 feet with nearby terrain features that have an effect on concentration
predictions.

a. Zone: 12
b. Location: UTM (NAD83): 397000 meters East, 4379850 meters North

D. Ambient Air

It was determined that the Plant boundary used in the AQIA meets the State’s definition of an ambient air
boundary.

E. Receptor and Terrain Elevations

The modeling domain has simple and complex terrain features in the near field. Therefore, receptor
points representing actual terrain elevations from the area were used in the analysis.

The far-field modeling domain consisted of a rectangular region covering all Class I areas within Utah,
and extending 50 kilometers beyond this area so that the model can account for re-circulation of the
plume.

DAQE-MN103030032-24
Page 5

F. Emission Rates and Release Parameters

The emission estimates and source parameters used in AERMOD for all proposed emission sources at the
site are presented in the NOI.

Speciated emission rates and source parameters used in the CALPUFF modeling are presented in Table 2.

Table 2: CALPUFF Emission Rates

Source
LCC Coordinates Modeled Emission Rates
Easting Northing SO2 SO4 NOX HNO3 NO3 SOA PMC SOIL EC
(m) (m) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr)
317.BF3 -1289410 -3738 52.81 5.03 307.58 0.00 0.00 5.03 2.60 2.90 0.11
419.BF1 -1289314 -3631 0.00 0.00 0.00 0.00 0.00 0.55 1.51 1.61 0.06
41B.BF2 -1289389 -3663 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.68 0.00
N1_FM2 -1289526 -3414 0.00 0.00 0.00 0.00 0.00 0.00 1.65 3.95 0.00
414.BF1N -1289407 -3683 0.00 0.00 0.00 0.00 0.00 0.00 0.10 0.25 0.00
2FM_HTR -1289528 -3415 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.08 0.00
514.BF1 -1289451 -3675 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.70 0.00
COMBO -1289424 -3668 0.00 0.00 0.00 0.00 0.00 0.00 1.37 5.72 0.00
FM2_CMB -1289454 -3439 0.00 0.00 0.00 0.00 0.00 0.00 0.50 1.21 0.00

Total Lb/hr 52.81 5.03 307.58 0.00 0.00 5.58 8.32 17.10 0.17
Hrs/Yr 8760 8760 8760 8760 8760 8760 8760 8760 8760
Ton/yr 231.3 22.0 1347.2 0.0 0.0 24.4 36.4 74.9 0.8

Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
317.BF3 POINT 4902.8 41.2 135.0 488 10.10 3.35
419.BF1 POINT 4891.2 18.3 60.0 388 6.36 2.90
41B.BF2 POINT 4895.2 68.6 224.9 294 17.83 0.74
N1_FM2 POINT 4832.0 49.7 163.0 363 40.08 1.40
414.BF1N POINT 4896.1 76.8 251.9 353 9.91 0.70
2FM_HTR POINT 4832.0 49.7 163.0 363 40.08 1.40
514.BF1 POINT 4889.5 39.6 130.0 294 11.86 0.91
COMBO POINT 4904.2 13.3 43.7 276 9.76 0.32
DAQE-MN103030032-24
Page 6
FM2_CMB POINT 4832.0 30.6 100.3 294 11.40 0.37

G. Building Downwash

The Applicant used the US EPA Building Profile Input Program (BPIP) to determine Good Engineering
Practice (GEP) stack heights and cross-sectional building dimensions for input into the model.

H. Ambient Background Concentrations

Millard County is in attainment for all criteria pollutants. The NAAQS analyses for PM2.5 and PM10 used
monitoring data collected on site during the pre-construction monitoring analysis. The background values
used in the NAAQS analysis are presented in Table 3.

Table 3: Background Concentrations

Pollutant Averaging
Period
Background
Concentration
(μg/m3)
PM10 24-hour 65.4
PM2.5 24-hour 10.2
Annual 4.2

I. Meteorological Data Processing

For the AERMOD model, on-site horizontal and vertical wind speed, direction, solar radiation and,
temperature data was combined with National Weather Service (NWS) upper air data collected at the Salt
Lake City International Airport (SLCIA) for the same period using the US EPA AERMET processing
system.

Meteorological data used for the CALPUFF modeling analysis consisted of 3 years (2018-2020) of data
developed by the Forest Service. The grid was 708 km (east-west) by 492 km (north-south) with a
resolution of 12 kilometers.

VI. RESULTS AND CONCLUSIONS

The Applicant performed a series of analyses to estimate the impact from the proposed project. Modeling
results and conclusions from the review of the analyses are outlined in detail below.

A. Pre-Construction Monitoring and Significant Impact Modeling

The Applicant performed a preliminary criteria pollutant analysis of the proposed modification. This
analysis indicated that increases in concentration levels of PM2.5 and PM10 were greater than the Class II
SIL, and therefore, a cumulative analysis for these pollutants was required.

DAQE-MN103030032-24
Page 7

B. NAAQS Analysis

The Applicant performed a modeling analysis to determine if the combined impact from the proposed
source, other industrial sources operating in the area, and ambient background would comply with the
NAAQS. The NAAQS analysis was reviewed by the Division and determined to be consistent with the
requirements of R307-410-3. Table 4 provides a comparison of the Applicant’s predicted air quality
concentrations and the NAAQS.

Table 4: Model Predicted NAAQS Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-hour 28.3 5 65.4 0 93.7 150 62.5%
PM2.5 24-hour 9.6 1.2 10.2 0 19.8 35 56.6%
Annual 4.4 0.3 4.2 0 8.6 9 95.6%
* Note: Only included other sources and background if source impact was above Class II SIL

C. PSD Class II Increments

The Applicant performed an analysis to determine if the impact from the proposed source would comply
with PSD Class II increments. The analysis was reviewed by the Division and determined to be
consistent with the requirements of R307-410-3. Table 5 provides a comparison of the predicted
concentrations and the PSD Class II increment.

Table 5: Model Predicted PSD Class II Increment Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Nearby
Sources*
Total Increment Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
PM10 Annual 8.1 1 0 8.1 25 32.4%
24-hour 28.3 5 0 28.3 30 94.3%
PM2.5 24-hour 6.1 1.2 0 6.1 9 67.8%
Annual 2.4 0.3 0 2.4 4 60.0%

D. Hazardous Air Pollutants

DAQE-MN103030032-24
Page 8
The Applicant performed an analysis to determine if HAP modeling is required. The analysis was
reviewed by the Division and determined to be consistent with the requirements of R307-410-3. The
analysis indicated that HAP modeling was not triggered by this modification, and therefore no HAP
modeling was performed.

E. PSD Class I Increment Consumption Analysis

The Applicant performed a CALPUFF analysis to determine if the impact from the proposed source along
with other increment consuming sources would comply with federal PSD Class I increments. The
analysis was reviewed by the Division and determined to be consistent with the requirements of R307-
410-3. The results for all Class I areas within 300 kilometers are provided in Table 6.

Table 6: Model Predicted PSD Class I Increment Concentrations

Air Period Prediction
Class I
Significant
Impact
Level
Other
Sources* Total Increment Percent
Pollutant (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
Capitol Reef
NO2 Annual 0.0018 0.1 2.5
SO2
3-Hour 0.0494 1 25
24-
Hour 0.0150 0.2 5
Annual 0.0008 0.1 2
PM2.5
24-
Hour 0.0430 0.27 2
Annual 0.0021 0.05 1
PM10
24-
Hour 0.0444 0.3 8
Annual 0.0021 0.2 4
Arches
NO2 Annual 0.0008 0.1 2.5
SO2
3-Hour 0.0408 1 25
24-
Hour 0.0102 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0522 0.27 2
Annual 0.0018 0.05 1
DAQE-MN103030032-24
Page 9
PM10
24-
Hour 0.0531 0.3 8
Annual 0.0019 0.2 4
Canyonlands
NO2 Annual 0.0010 0.1 2.5
SO2
3-Hour 0.0354 1 25
24-
Hour 0.0100 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0577 0.27 2
Annual 0.0019 0.05 1
PM10
24-
Hour 0.0591 0.3 8
Annual 0.0020 0.2 4
Bryce
NO2 Annual 0.0006 0.1 2.5
SO2
3-Hour 0.0369 1 25
24-
Hour 0.0082 0.2 5
Annual 0.0003 0.1 2
PM2.5
24-
Hour 0.0189 0.27 2
Annual 0.0010 0.05 1
PM10
24-
Hour 0.0194 0.3 8
Annual 0.0010 0.2 4
Zion
NO2 Annual 0.0011 0.1 2.5
SO2
3-Hour 0.0293 1 25
24-
Hour 0.0105 0.2 5
Annual 0.0005 0.1 2
PM2.5
24-
Hour 0.0266 0.27 2
Annual 0.0011 0.05 1
PM10 24-
Hour 0.0271 0.3 8
DAQE-MN103030032-24
Page 10
Annual 0.0012 0.2 4
* Note: Only included other increment consuming sources if source impact was above Class I SIL

Since the proposed project’s model predicted impacts at the Class I areas were less than the PSD Class I
significance levels, a cumulative analysis was not warranted.

DAQE-MN103030032-24
Page 11
F. Visibility – Plume Blight
Since the Class I areas are greater than 50 kilometers from the source, a plume blight analysis using
VISCREEN was not required.

G. Visibility – Regional Haze

The results of the Q/D analysis for the emissions increase was less than 10 but the FLMs wanted the
entire source included in the Q term. The results of including the total emissions resulted in a Q/D >10,
so an AQRV analysis was performed for visibility and acid deposition. The results shown in Table 7
indicate that the impacts are below the 0.5 Deciview (DV) threshold established by the National Park
Service, indicating that no further analysis is required.

Table 7: CALPUFF Visibility Results

Class I Area Year Maximum
Delta DV
98th
Percentile
change in
DV
#
Days
#
Days Threshold
(DV)
Below
Threshold
> 1 > 0.5
2018 0.248 0.06 0 0 0.5 Yes
Arches 2019 0.291 0.054 0 0 0.5 Yes
2020 0.216 0.106 0 0 0.5 Yes
2018 0.223 0.081 0 0 0.5 Yes
Canyonlands 2019 0.312 0.068 0 0 0.5 Yes
2020 0.186 0.085 0 0 0.5 Yes
2018 0.059 0.03 0 0 0.5 Yes
Bryce 2019 0.081 0.045 0 0 0.5 Yes
2020 0.071 0.03 0 0 0.5 Yes
2018 0.183 0.074 0 0 0.5 Yes
Capital Reef 2019 0.196 0.092 0 0 0.5 Yes
2020 0.126 0.078 0 0 0.5 Yes
2018 0.069 0.04 0 0 0.5 Yes
Zion 2019 0.123 0.039 0 0 0.5 Yes
2020 0.102 0.057 0 0 0.5 Yes

DAQE-MN103030032-24
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H. Acid Deposition

The Applicant performed a deposition analysis on impacts within the Class I areas. Results of the
analysis indicate that the impacts are below the deposition threshold (DAT) established by the National
Park Service, indicating that no further analysis is required

Table 8: CALPUFF Deposition Results for Highest Year

Class I Area
Total
Nitrate
Deposition
Total
Sulfate
Deposition
Deposition
Analysis
Threshold
(kg/ha/yr) (kg/ha/yr) (kg/ha/yr)
Canyonlands 0.0006 0.0003
0.005
Zion 0.0004 0.0002
Arches 0.0006 0.0003
Bryce 0.0006 0.0002
Capitol Reef 0.0011 0.0005

I. Soils and Vegetation Analysis

The Applicant performed an analysis to determine the extent of impacts from the proposed source on soil
and vegetation. Results of the analysis are presented in a supplemental document titled “Soil and
Vegetation Impact Analysis for the Leamington, UT Facility, June 29, 2023”. The analysis indicated that
predicted concentrations compared against the secondary NAAQS at several sensitive receptors would not
result in an adverse impact on soils and vegetation in the vicinity of the proposed project.

DP/JK:jg

DAQE-IN103030032-25

January 22, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Mr. Nelson:

Re: Intent to Approve: Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — ) A A v A ? A D @ A w D D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — ) A A v A ? A D @ A w D D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ash Grove Cement Company Ash Grove Cement Company - Leamington Cement Plant

Mailing Address Physical Address
P.O. Box 38069 Highway 132
Leamington, UT 84638 Leamington, UT 84638

Source Contact UTM Coordinates
Name: Cody Watkins 397000 m Easting
Phone: [phone] 4380100 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3241 (Cement, Hydraulic)

SOURCE INFORMATION
General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried on site),
are correctly proportioned, ground, and mixed and then fed into a rotating kiln. The kiln alters the
materials and recombines them into small stones called cement clinker. The clinker is cooled and ground
with gypsum and additional limestone into a fine powdered cement. The final product is stored on site for
later shipping. The major sources of air emissions are from the combustion of fuels for the kiln operation,
from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source of
emissions of PM2.5, PM10, NOx, CO, HAPs, and GHG. It is a minor source of SO2 emissions.
NSR Classification
Major PSD Modification

Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
DAQE-IN103030032-25
Page 4

Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

These changes result in increases in actual emissions but decreases in most potential emissions. There will
be an increase in the potential emissions of VOCs and greenhouse gases.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
DAQE-IN103030032-25
Page 5

Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
DAQE-IN103030032-25
Page 6

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, 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. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO 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. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
DAQE-IN103030032-25
Page 7

II.A.4 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)
II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area, and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, stacker systems. II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit-specific requirements.
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total air flow controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter
area; 9,865 acfm total air flow, controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are
controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each
is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6). II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The
following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for
NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.
II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low-pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

DAQE-IN103030032-25
Page 8

II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow through stack
E34.
II.A.18 Kiln Feed Alleviator A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the central material silo between the blending silos and the preheater. Raw feed is removed from the system near the top of the preheater tower.
II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The
coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter area;
1,700 acfm total air flow.
II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker
storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1): 1,800 acfm that discharges into the clinker tunnel.
II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
DAQE-IN103030032-25
Page 9

II.A.27 Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during loading.
II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel, all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during loading. 512.BF3 (1,000 acfm) is located on top of the silo. II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement products. Dust generated
during milling is captured by a BHA pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).

II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates from stack G55 (finish mill stack).
II.A.32 Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4).
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1 thru 3).

II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total air flow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations.
II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This
baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

DAQE-IN103030032-25
Page 10

II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.
II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023)
II.A.40 Dust Shuttle System A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides, surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the
fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

II.A.41 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons) Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
DAQE-IN103030032-25
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II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)
THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)
CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)
PM: 0.02 lbs filterable PM per ton of clinker.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR 60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to approve alternative control measures, the permittee shall keep a copy of the submitted petition and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source
of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2).
[40 CFR 63 Subpart LLL]

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II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must 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 PM CPMS is not out of control. The owner/operator must 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 on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
DAQE-IN103030032-25
Page 13

II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

II.B.1.e.3 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-165]
II.B.1.e.4 PM 40 CFR 60, Appendix A, Method 5, or 5I, or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three runs, with each
run at least 120 minutes in duration and each run collecting a sample of 60 dry standard cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 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. [R307-165]
DAQE-IN103030032-25
Page 14

II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
DAQE-IN103030032-25
Page 15

II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
DAQE-IN103030032-25
Page 16

II.B.1.i 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 must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator 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 owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator 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 owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
DAQE-IN103030032-25
Page 17

II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: Instances of water and/or chemical application to unpaved areas shall be recorded and maintained by the owner/operator. The ambient temperature shall be recorded any time water should be applied but cannot due to freezing conditions. [R307-401-8]
II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

The sprays shall operate whenever dry conditions warrant meeting the required opacity
limitations or as determined necessary by the Director. Water sprays shall not be required during
periods of freezing temperatures.

[R307-401-8]

DAQE-IN103030032-25
Page 18

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

C. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the kiln/raw mill stack

F. The owner/operator shall record the output of the system: including the quantity of NOx, CO, O2, THC, Hg, HCl, and CO2 emissions at the kiln stack

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an
affected source 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.

[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]
II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments, the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the results of the performance test demonstrating compliance with the filterable PM limit and using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust the SSOL developed in accordance with the results of the most recent PM performance test demonstrating compliance with the PM emission limit. The owner/operator shall use the PM CPMS to demonstrate continuous compliance with the SSOL in accordance with the requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

DAQE-IN103030032-25
Page 19

II.B.4 Fuel Limitations: II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke F. Fuel Oil
G. Used Oil Fuel

H. Synthetic Fuel
I. Wood
J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 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. [R307-401-8]
II.B.4.b.2 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 owner/operator 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 in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

DAQE-IN103030032-25
Page 20

II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight
A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation
C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit-no less than 1500oF for more than five minutes in any 60-minute period B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
DAQE-IN103030032-25
Page 21

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the Director. The calibration procedure and frequency shall be according to manufacturer's specifications. Use of factory-calibrated thermocouples for temperature measurement is approved. However, any other method of temperature measurement must be approved by the Director prior to use. The monitoring equipment for both temperature and oxygen content shall be located such that an inspector can at any time safely read the output. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall only operate the emergency engines for testing and maintenance purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency operation. [R307-401-8]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.5.b.2 To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From Source Submitted NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-IN103030032-25
Page 22

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-GN103030032J-25
January 22, 2025
Via Certified Mail 70190700000208349765
DJ Law
EPA Region 8
1595 Wynkoop Street
Denver, Colorado 80202-1129
[e-mail]
Dear Mr. Law:
RE: Notice of Publication for Ash Grove Cement Company- Leamington Cement Plant – CDS A;
MACT (Part 63), Compliance Assurance Monitoring (CAM), Title V (Part 70) Major Source,
Major Criteria Source, Major HAP Source, Attainment Area, NSPS (Part 60),
Project Number: N103030032
On January 22, 2025, the Director has completed his review of a Prevention of Significant Deterioration
project submitted by Ash Grove Cement Company. Attached to this letter are the draft Approval Order
document (Intent to Approve) and the full engineering review. Following a 60-day review by the Federal
Land Managers, this project will be submitted for a 30-day public comment period. Written comments
received by the Division at this same address during these comment periods will be considered in making
the final decision on the approval/disapproval of the proposed Approval Order. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director at the Division in writing, a hearing
will be held in accordance with R307-401-7, UAC.
If you have any questions, please contact John Jenks, who may be reached at [phone].
Sincerely,
Jon L. Black, Manager
New Source Review Division
Enclosures: Engineering Review
Modeling Memo
Intent to Approve
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
Jon Black (Jan 22, 2025 14:59 MST)
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
RN103030032
January 21, 2025
Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]
Dear Josh Nelson,
Re: Engineer Review:
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032
Please review and sign this letter and attached Engineer Review (ER) within 10 business days.
For this document to be considered as the application for a Title V administrative amendment, a
Title V Responsible Official must sign the next page.
Please contact John Jenks at [phone] if you have any questions or concerns about the ER.
If you accept the contents of this ER, please email this signed cover letter to John Jenks at
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 1

[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the
DAQ will consider any comments received and will issue the Approval Order.

If you do not respond to this letter within 10 business days, the project will move forward
without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue
an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 2

OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible
Official, as defined in R307-415-3, must sign the statement below. THIS IS STRICTLY
OPTIONAL.

If you do not want the Engineer Review to be considered as an application to administratively
amend your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will
require submittal of a separate Operating Permit Application to revise the Title V permit in
accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document:
Title V Operating Permit Application Due Dates clarifies the required due dates for Title V
operating permit applications and can be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality

“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate
and complete and request that this Approval Order be considered as an application
to administratively amend the Operating Permit.”

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 3

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N103030032
Owner Name Ash Grove Cement Company
Mailing Address P.O. Box 38069
Leamington, UT, 84638

Source Name Ash Grove Cement Company- Leamington Cement
Plant
Source Location Hwy 132
Leamington, UT 84638

UTM Projection 397000 m Easting, 4380100 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3241 (Cement, Hydraulic)

Source Contact Cody Watkins
Phone Number [phone]
Email [e-mail]

Billing Contact Cody Watkins
Phone Number 385.225.0615
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 30, 2022
Date of Accepted Application November 28, 2024

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 4

SOURCE DESCRIPTION

General Description
Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried
on site), are correctly proportioned, ground and mixed, and then fed into a rotating kiln. The kiln
alters the materials and recombines them into small stones called cement clinker. The clinker is
cooled and ground with gypsum and additional limestone into a fine powdered cement. The final
product is stored on site for later shipping. The major sources of air emissions are from the
combustion of fuels for the kiln operation, from the kiln, and from the clinker cooling process.
The Leamington cement plant is a major source for emissions of PM2.5, PM10, NOx, CO, HAPs
and GHG. It is a minor source of SO2 emissions.

NSR Classification:
Major PSD Modification

Source Classification
Located in Attainment Area,
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Proposal
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower, various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 6

These changes result in increases in actual emissions, but decreases in most potential emissions.
There will be an increase in the potential emissions of VOC and greenhouse gases.

EMISSION IMPACT ANALYSIS
The complete modeling review is located in DAQE-MN103030032-24. [Last updated January 14, 2025]

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 7

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
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Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

Note: Change in emissions indicates the difference between previous AO and proposed modification.

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Review of BACT for New/Modified Emission Units

1. BACT review regarding the Leamington Plant Upgrade Project
Any major stationary source or major modification subject to PSD review must undergo an
analysis to ensure the use of BACT. The requirement to conduct a BACT analysis is set forth in 40
CFR 52.21. Similarly, Utah requires the installation of BACT for all sources of air pollution under
R307-401-5(2)(d)), BACT is defined in 40 CFR 52.21 (and R307-401-2) as:

". . . best available control technology means an emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for each pollutant subject to regulation under
Act which would be emitted from any proposed major stationary source or major modification
which the Administrator, on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such source or modification
through application of production processes or available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion techniques for control of such
pollutant . . ."

Therefore, a BACT analysis is required for each new or physically modified emission unit for each
pollutant that exceeds an applicable PSD significant emission rate (SER). Since the PM10 and PM2.5
emissions from the proposed project exceed the applicable PSD SER, a BACT analysis is required
to assess the required levels of control for these pollutants. Because the CO2e emissions are subject
to regulation as a result of the proposed project resulting in an increase of 75,000 tons or more per
year CO2e, a BACT analysis is also required for that pollutant. Note that HAPs listed under CAA
Section 112(b)(1) are excluded from NSR (New Source Review) or PSD (i.e., BACT) review.

In a memorandum dated December 1, 1987, the United States Environmental Protection Agency
(EPA) stated its preference for a "top-down" BACT analysis. After determining if any New Source
Performance Standard (NSPS) is applicable, the first step in this approach is to determine, for the
emission unit in question, the most stringent control available for a similar or identical source or
source category. If it can be shown that this level of control is technically, environmentally, or
economically infeasible for the unit in question, then the next most stringent level of control is
determined and similarly evaluated. This process continues until the BACT level under
consideration cannot be eliminated by any substantial or unique technical, environmental, or
economic objections.

Presented below are the five basic steps of a top-down BACT review as identified by the EPA.
Step 1 - Identify All Control Technologies
Step 2 - Eliminate Technically Infeasible Options
Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Step 4 - Evaluate Most Effective Controls and Document Results
Step 5 - Select BACT

Ash Grove has elected to follow this methodology and based the BACT review on each individual
pollutant. The complete BACT analysis follows. [Last updated January 14, 2025]

2. BACT review regarding PM10 and PM2.5 Sources
PM10 and PM2.5 Modified Equipment
The existing kiln precalciner, preheater, and alleviator system are proposed to be modified, and the
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kiln's ID fan and clinker cooler fans are proposed to be replaced, which will result in increased
airflow. Additionally, the clinker cooler baghouse will be converted from a plenum pulse to a pulse
jet baghouse. These modifications are projected to result in a net increase of potential PM10 and
PM2.5 emissions.

Kiln Upgrade BACT
The rotary cement kiln is the core of the cement manufacturing process, transforming the blended
raw materials or "rawmix" into clinker through pyro processing. Emissions from the kiln occur
from fuel combustion plus the physical and chemical reactions needed to transform the rawmix
into clinker. This project involves process and energy efficiency improvements and an increase in
kiln production, resulting in an increase of PM10 and PM2.5 emissions. This section specifically
addresses filterable PM10 and PM2.5. The condensable fraction is represented with the other
precursors as applicable to proposed emission increases.

The Leamington Plant's Kiln is subject to NSPS, Subpart F for particulate. Therefore, a BACT
analysis addresses applicability of the proposed changes to the kiln system to NSPS and review of
the RBLC. A summary of the resources reviewed include the following:

NSPS Subpart F - Standards of Performance for Portland Cement Plants establishes emission
standards for cement kiln operations. Specifically, kilns modified after June 16, 2008, are limited to
0.07 lbs PM/ton of clinker produced.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028) and
Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from kiln operations are as follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM emissions are most effectively controlled using a collection system with enclosures routed to
baghouses providing up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Ash Grove
has selected technology with the highest control efficiency, so there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.
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Step 5 - Select BACT
Ash Grove proposes that BACT for PM10 and PM2.5 emissions from the kiln consist of a collection
system routed to a baghouse or fabric filter that complies with NSPS Subpart F's emission standard
for a modified source. BACT for the Leamington Plant's kiln are 10% opacity and 0.07 lb of
PM/ton (NSPS Subpart F emission standard) of clinker.
[Last updated January 14, 2025]

3. BACT review regarding PM10 and PM2.5 sources cont.
Clinker Cooler Upgrade BACT
The clinker cooler reduces the temperature of the clinker exiting the kiln. It is necessary to reduce
clinker temperature before it enters the finish mill to maintain product quality and reduce wear and
tear on equipment. The clinker cooler is equipped with a heat exchanger that captures waste heat
and transfers it to the kiln preheater for process and energy efficiency. Emissions from the clinker
cooler are vented to a baghouse. The Leamington Plant's clinker cooler is also subject to NSPS
Subpart F for particulate. Ash Grove's proposed changes to the clinker cooler meet the definition of
a reconstruction under NSPS. Therefore, in order to meet the requirements of NSPS Subpart F, Ash
Grove will be required to meet a limit of 0.02 lb of PM/ton of clinker.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from clinker cooler operations are as
follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM10 and PM2.5 emissions are most effectively controlled using a collection system with enclosures
routed to a baghouse, which can achieve up to 99.9% control efficiency. Other technologies such as
wet scrubbers, cyclones and ESPs are feasible, but provide lower control efficiencies than a
baghouse. Because the most efficient control technology is proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for PM10 and PM2.5 emissions from the clinker cooler is a collection system routed to a
baghouse or fabric filter. In order to meet the requirements of NSPS Subpart F, Ash Grove will
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meet a reduced emission limit of 0.02 lb of PM/ton of clinker. A 10% opacity limit is also
applicable. [Last updated January 14, 2025]

4. BACT review regarding PM10 and PM2.5 sources cont.
New Finish Mill BACT
The proposed Plant upgrade include adding a second finish mill. The new finish mill will use an
energy efficient vertical roller mill assisted with a grinding aid. A total of five (5) point sources are
planned for the finish mill. In accordance with NSPS Subpart F, emissions from finish mill are
restricted to 10% opacity. Ash Grove has reviewed the following sources to identify available
control technologies.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);12 and

Region 8 General Permit for Concrete Batch Plants.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 emissions from plant material handling operations are as
follows:
Baghouse / Fabric Filter;
Best Management & Operational Practices;
Cyclone;
ESP;
Enclosure;
Water Application (Watering); and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
With the exception of water application, all options are technically feasible. Water application is
eliminated as clinker exiting the kiln along with additives in the finish mill must remain dry to
maintain product quality. Therefore, it is technically infeasible to water material in the finish mill.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Enclosure 50-90%
5. Cyclone 20-70%
6. Best Management & Operational Practices varies

Step 4 - Evaluate Most Effective Controls and Document Results
Baghouses provide the highest emission control efficiency, controlling up to 99.9% of PM
emissions from finish mill equipment. After baghouses, using a wet scrubber or ESP provides
similar PM control. Notably, baghouses, scrubbers, and ESPs require enclosures to aid in capturing
emissions and ducting to the control. Therefore, optimal PM emission control can be achieved
through implementing both baghouses and enclosures where feasible. Plant material sizing and
handling is currently done using a series of buildings and enclosures routed to baghouse controls.
Various silos storing material inputs are also equipped with fabric filters. As the highest ranked
technology is applied, there are no adverse energy, environmental or cost impacts to consider with
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the use of these control technologies. Thus, no further analysis is required under EPA's top-down
BACT approach.

Step 5 - Select BACT
BACT for finish mill PM10 emissions is compliance with NSPS Subpart F, Standards of
Performance for Portland Cement Manufacturing where applicable. Ash Grove will achieve BACT
for PM10 emissions from finish mill equipment through the implementation of enclosures,
baghouses, and best management practices. All baghouses at the finish mill will have a 10%
opacity limitation and a grain loading of 0.005 grains/dscf. [Last updated January 14, 2025]

5. BACT review regarding PM10 and PM2.5 sources cont.
Material Transfer, Sizing, and Storage BACT
The Leamington Plant has sources of fugitive emissions through raw material transfer. Materials
transferred include limestone and other raw materials, coal, clinker, and cement. These materials
are transferred by conveyor belt, screw conveyor, elevator, pneumatic conveyance or chutes via
gravity. At the Leamington Plant the fugitive emissions are enclosed at their transfer points and
routed to baghouses.

The following emission units are included in this category:
Limestone Crushing, Sizing, and Material Transfer;
Raw Material Transfer;
Coal Sizing and Transfer;
Existing Finish Mill;
Clinker Storage and Transfer;
Cement Storage and Truck and Rail Cement Loadout;
New Rail Loading and Loadout; and
New Clinker Reclaim Hopper Baghouse.

Generally, controls for these units have not changed or they are similar to current existing controls.
A full BACT analysis of each unit is included in Ash Grove's NOI and additional submitted
information. However, given that most controls remain unaltered, only the results of Step 5 -
Select BACT will be included here.

Limestone Crushing, Sizing, and Material Transfer
Subject to NSPS Subpart OOO opacity limits for existing sources.
Existing baghouses. No change from bag manufacturer's specifications.

Raw Material Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Coal Storage and Transfer
Existing Equipment. No change from bag manufacturer's specifications
20% Opacity

Clinker Storage and Transfer
Subject to NSPS Subpart F opacity limits:
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10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Existing Finish Mill Grinding, Storage and Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Cement Storage and Truck and Rail Cement Loadout, New Rail Loadout
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

New Rail Loadout, controlled by baghouse
Emissions Limit - 0.005 gr/dscfm

New Clinker Reclaim Hopper, controlled by baghouse
Subject to NSPS Subpart F opacity limits:
10% opacity
Emissions Limit - 0.005 gr/dscfm [Last updated January 14, 2025]

6. BACT review regarding PM10 and PM2.5 sources cont.
PM10 and PM2.5 Fugitive Emissions
The following fugitive emissions sources will increase emissions of PM10 and PM2.5 as a result of
the Leamington Plant's proposed throughput increase. The sources addressed in the following
BACT analyses are primarily in the quarry, but also include emissions from roads and dumping of
raw materials within the plant boundary.

The sources evaluated are listed below:
Roads;
Loading and Unloading;
Stockpiles;
Bulldozing and Grading;
Disturbed Areas; and
Drilling and Blasting.

Ash Grove currently controls emissions from these processes, and generally, controls for these
units have not changed. A full BACT analysis of each unit is included in Ash Grove's NOI and
additional submitted information. However, given that most controls remain unaltered, only the
results of Step 5 - Select BACT will be included here.

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
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Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

Stockpiles BACT
BACT shall consist of restricting fugitive emissions to the opacity standard of 20% opacity at the
property boundary. BACT for stockpiles will be achieved through applying good management
practices through its fugitive dust plan as appropriate.

Bulldozing and Grading BACT
BACT shall consist of restricting fugitive emissions from bulldozing and grading activities to no
more than 20% opacity, and that emissions are controlled with periodic watering of the disturbed
surface. The frequency of water application will depend on ambient weather conditions and
inherent moisture content of the material being moved.

Disturbed Areas BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. BACT for
disturbed areas will be achieved through best management practices, watering, scarification, and
revegetation.

Drilling and Blasting BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. This is achievable
through best management practices, shrouds, watering, and dust collection. [Last updated January
14, 2025]

7. BACT review regarding kiln system NOx emissions
Kiln System (Kiln, Raw Mill, and Coal Mill) - NOx BACT
Although there are physical changes to the kiln system, these changes are primarily related to
particulate emissions. NOx emissions are generated from the combustion of fuel - and no changes
in NOx emissions are expected from the kiln (hourly capacity to emit). The kiln NOx emissions will
remain the same as a result of upgrades to the SNCR system. The replacement of the various
components of the kiln system and portions of the preheater tower, along with new injection points,
will ensure that increased mixing of ammonia is achieved to enhance the SNCR system's ability to
reduce NOx and minimize ammonia slip. This will allow the Leamington Plant to maintain the NOx
hourly capacity to emit unchanged from current levels Leamington Plant Upgrade Project. At
present Ash Grove has no restriction on the amount of fuel combusted, only a limit on total NOx
generated, and with this project the allowed NOx PTE is decreasing from 1,352 tpy to 1,226 tpy.

Additional ammonia will be used in the existing SNCR system. While the SNCR system has
adequate capacity to accommodate the additional ammonia demand resulting from the system
upgrades, more ammonia ports are proposed to be added with the kiln system's proposed changes
of the equipment. The changes proposed to the kiln system will increase residence time and
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temperature which will improve the SNCR system's effectiveness to control NOx emissions and
minimize ammonia slip emissions to the atmosphere. No additional review of NOx BACT for the
kiln system is required under this proposal. [Last updated January 14, 2025]

8. BACT review regarding new finish mill heater emissions
Finish Mill Heater
The proposed finish mill will include a process heater to maintain a minimum temperature during
milling. The proposed heater will run on natural gas and is rated at 10 MMBtu/hr. Startup and
shutdown emissions from the heater are anticipated to be no greater than normal operation as the
process is simply a matter of bringing the heater to operating temperature. Emissions evaluated in
the BACT analysis for the finish mill heater include NOx, SO2, CO, and VOCs, PM10, and PM2.5.
Pollutants with identical control technologies are grouped together in the analysis.

NOx - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for NOx from units of this size range are as follows:
Ultra-Low-NOx Burners (ULNB);
Low NOx Burners;
Selective Catalytic Reduction (SCR);
Selective Noncatalytic Reduction (SNCR);
Good Combustion Practices; and
Use of Natural Gas.

Step 2 - Eliminate Technically Infeasible Options
Low exit temperatures render the use of SCR and SNCR ineffective. Particulate entrainment within
the finish mill could potentially foul (plug) the nozzles of ULNB. Low-NOx burners, the use of
natural gas as fuel and good combustion practices are all considered technically feasible.

Step 3 and Step 4 - Rank Remaining Control Technologies by Control Effectiveness and Evaluate
Most Effective Controls and Document Results
Since the three feasible control technologies are proposed for the finish mill heater, no detailed
economic, energy, and environmental impact evaluations were conducted. No ranking of control
effectiveness is required as all three controls are proposed.

Step 5 - Select BACT
BACT for NOx is the use of natural gas as fuel, good combustion practices and the use of Low NOx
burners.

CO, SO2, and VOC - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for CO, SO2, and VOC from units of this size are as follows:
Good Combustion Practices
Use of Natural Gas

The finish mill heater combusts natural gas. Related natural gas combustion emissions are
anticipated to be minimal.

Step 2 - Eliminate Technically Infeasible Options
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Both control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Both technologies offer intrinsic emission reductions from combustion. Since the technologies do
not compete, both technologies can and will be used simultaneously.

Step 4 - Evaluate Most Effective Controls and Document Results
Because both control technologies identified in Step 1 are proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for CO, SO2, and VOC are good combustion practices and the use of natural gas.

PM10 and PM2.5 BACT for the finish mill has been addressed in the PM10/PM2.5 sources section.
[Last updated January 14, 2025]

9. BACT review regarding SO2, VOC, and Lead Sources
The following BACT analysis is grouped by pollutants that will experience an increase in potential
emissions and the associated technically feasible control technologies. As such, the BACT analysis
is separated into SO2, VOC, and lead respectively with organic HAPs addressed with VOCs.

SO2 - Cement Kiln BACT
NSPS Subpart F - Standards of Performance for Portland Cement Plants, establishes emission
standards for cement kiln operations. Specifically, kilns constructed or reconstructed after June 16,
2008, are limited to 0.4 lbs SO2/ton clinker on a 30-day rolling average respectively. This limit is
an existing emission limit in the Leamington Plant's approval order and Title V. Ash Grove will
continue to achieve this emission limitation while achieving BACT for the kiln operations. Ash
Grove has reviewed the following sources to identify available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019); and

NSPS Subpart F as an affected emissions facility in 40 CFR 60.62(a)(4);

Portland Cement Association's Formation and Techniques for Control of Sulfur Dioxide and Other
Sulfur Compounds in Portland Cement Kiln Systems.

SO2 emissions are a result of oxidation of sulfur compounds in the rawmix and/or the coal used to
fire the kiln. However, the alkaline nature of the cement provides for direct absorption of SO2 into
the product, thereby mitigating the quantity of SO2 emissions in the exhaust stream.

Step 1 - Identify All Control Technologies
Control technologies identified for SO2 emissions from coal-fired kiln operations are as follows:
Baghouse or fabric filter;
Dry reagent injection prior to baghouse;
Wet scrubber;
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Process optimization; and
Good combustion practices.

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below:

1. Process Optimization 99%
2. Wet Scrubber 99%
3. Dry Reagent Injection 60%
4. Good Combustion Practices 30%
5. Baghouse Variable

Step 4 - Evaluate Most Effective Controls and Document Results
SO2 emissions are most effectively controlled by optimizing the process and utilizing the inherent
SO2 scrubbing properties of the kiln system itself. Although wet scrubbers alone can achieve equal
control efficiencies as process optimization, additional capital and operational expenses are
required for water consumption and wastewater discharge. Whereas process optimization achieves
the same control effectiveness and has the added benefit of reduced operational costs. Ash Grove
optimizes the kiln process by routing the exhaust from the kiln to a preheater and raw mill to
interact with the raw mix, thus creating an atmosphere similar to a dry scrubber system. Good
combustion practices also reduce SO2 formation with the added benefit of energy efficiency.

Step 5 - Select BACT
BACT for control of SO2 emissions from kiln operations shall consist of process optimization by
routing kiln exhaust to the preheater and raw mill, good combustion practices, and use of a
baghouse prior to exhausting to the atmosphere. As a modification of the kiln, 40 CFR 60.62(a)(4)
requires an emission limit of 0.4 pounds of sulfur dioxide (SO2) per ton of clinker on a
30-operating day rolling average. [Last updated January 14, 2025]

10. BACT review regarding SO2, VOC, and Lead Sources cont.
VOC - Cement Kiln BACT
VOCs are generated by incomplete combustion in the kiln. 40 CFR 63 Subpart LLL - NESHAP
from the Portland Cement Industry limits total hydrocarbon and total organic HAP emissions to 24
and 12 ppmv at 7% oxygen. Ash Grove will achieve or exceed these emission limitations while
achieving BACT for the kiln operations. Ash Grove has reviewed the following sources to identify
available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028); and

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for VOC emissions from coal fired kiln operations are as follows:
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Process optimization,
Good combustion practices

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below.

1. Process Optimization Variable
2. Good Combustion Practices Variable

Step 4 - Evaluate Most Effective Controls and Document Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove optimizes the
kiln process by capturing waste heat from the clinker cooler and routing to a kiln preheater. Good
combustion practices also reduce VOC formation with the added benefit of energy efficiency.
There are no adverse energy, environmental or cost impacts to consider with the use of this control
technology.

Step 5 - Select BACT
BACT for control of VOC emissions from kiln operations shall consist of process optimization by
routing kiln heat to the preheater and good combustion practices. An emission limit of 24 ppmv
VOC @ 7% O2 is imposed by NESHAP Subpart LLL.

VOC - Grinding Aid BACT
A grinding aid containing VOC is added to the new finish mill to disperse particles within the mill
and expose more surface area to grinding. An increase in grinding aid usage proportionally
increases potential VOC emissions because volatiles from the grinding aid are not combusted in
the kiln.

There is only one identified control option for limiting the VOC emissions from the grinding aid.
Process optimization is technically feasible. VOC emissions are most effectively controlled by
optimizing the process. Ash Grove proposes to install a vertical finish mill with this project. Due to
the new modern mill's efficiency, it is anticipated that a reduced amount of grinding aid will be
required for each ton of clinker ground. Ash Grove estimates total VOC emissions from the
grinding aid at 2.37 tpy.

Lead Emissions
The lead emissions are anticipated to increase as a result of the proposed increase in clinker
throughput with the Leamington Plant upgrade project. Lead emissions result from residual
amounts of lead in raw materials and fuel. Lead emissions will be controlled the same as PM,
therefore a separate top-down BACT analysis has not been conducted as the Leamington Plant has
applied the most effective controls. [Last updated January 14, 2025]

11. BACT review regarding Greenhouse Gases
GHG Background
On October 9, 2009, the mandatory GHG reporting regulation, referred to as 40 CFR 98, was
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Page 20

published in the Federal Register. Through 40 CFR 98, the U.S. EPA established the GHG
Reporting Rule, which requires the annual reporting of GHG data and other relevant information
from large sources and suppliers in the United States. Monitoring through the GHG Reporting
Program (GHGRP) began in 2010, with the first reports due by March 31, 2011. Per 40 CFR
98.2(a)(1), any facility associated with cement production is subject to the GHGRP and must report
CO2e emissions. The CO2e is the sum of equivalent GHG emissions from CO2, CH4, and N2O,
with their respective global warming potentials (GWP) applied. Ash Grove's facility is subject to
GHG Reporting Rule and monitors CO2 emissions from its kiln with a continuous emissions
monitoring system (CEMs). On June 23, 2014, the U.S. Supreme Court held that required PSD
permits (based on emissions of non-GHG pollutants) may continue to require limitations on GHG
emissions based on the application of BACT as an "anyway source". The Leamington Plant
modification project is a major source for PSD for both PM10 and PM2.5, and GHGs are estimated
to be greater than 75,000 tpy and greater than zero on a mass basis; therefore, GHGs are evaluated
for BACT as an anyway source.

Cement Manufacturing GHG BACT
A BACT analysis has been conducted for CO2e emissions from the kiln system. For this GHG
BACT analysis, various control technologies or combinations of technologies were identified using
the RACT/BACT/LAER Clearinghouse, available literature including guidance published by EPA
and South Coast Air Quality Management District (SCAQMD), current air regulations, other
regulatory organizations, and engineering experience. In March 2011, EPA published GHG
permitting guidance, as well as a white paper on available and emerging technologies for reducing
GHG emissions from the Portland cement industry in October 2010. Additionally, EPA published a
series of videos on GHG permit training in December 2010. The SCAQMD published GHG BACT
guidance in 2021. Additional sources of information were reviewed and documented based on
publications from trade organizations and other governmental committees with GHG or carbon
reduction guidelines and/or recommendations.

EPA has defined in 40 CFR 86.1818-12(a) GHGs as a group of six gases: CO2, nitrous oxide
(N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF6). GHG emissions from the kiln result from calcination and fuel combustion.
Since the primary GHG emitted by a kiln is CO2, the BACT analysis focuses on CO2 emissions
from the kiln. Emissions of CH4 and N2O are minimal from cement kilns. Per EPA guidance, GHG
control technologies for consideration in a BACT analysis for Portland Cement Manufacturing
include:

Source-wide energy efficiency strategies;
Raw material substitution;
Blended cements;
Carbon capture utilization and storage; and
Fuel switching.
Other emerging technologies [Last updated January 14, 2025]

12. BACT review regarding Greenhouse Gases cont.
Step 1: Identify All Control Technologies
The CO2 emissions from a cement kiln are generated by the calcination process (conversion of the
calcium carbonate in limestone to calcium oxide) and by combustion of fuel in the kiln. Potential
control technologies to reduce these CO2 emissions for a cement kiln are addressed in EPA's white
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paper on Available and Emerging Technologies for Reducing GHG Emissions from the Portland
Cement Industry.

These technologies fall into three categories:
Energy Efficiency Improvements for the Clinker Production Process
Fuel Substitution
Carbon Capture and Sequestration

Step 2: Eliminate Technically Infeasible Options
Several potential energy efficiency improvements are technically feasible: Pre-heater/Pre-calciner
Kiln Process, Kiln Seal Management Program, Refractory Selection (Kiln Insulation), and Energy
Recovery from the Clinker Cooler. The use of alternative fuels such as natural gas, whole tires and
biofuel) is also technically feasible. Other control options, such as Use of Fluxes and Mineralizers,
Heat Recovery for Power - Cogeneration, Carbon Sequestration, Oxyfuel combustion, and
Post-combustion Capture have been deemed infeasible.

Step 3: Rank Remaining Control Technologies by Control Effectiveness
All four remaining control techniques are currently implemented at the Leamington Plant. This
permitting project incorporates energy efficiency improvements. Ash Grove has had a fuel
substitution program in place for several years, and this program is continually reviewed and
updated as new sources and types of fuel are identified.

Step 4: Evaluate Most Effective Controls and Document Results
Since all technically feasible energy efficiency improvements and changes to product composition
will be implemented, this section will focus on economic and environmental considerations of fuel
substitution to operate exclusively on natural gas.

Firing natural gas as the primary kiln fuel can reduce CO2 emissions from fuel combustion by as
much as 40%. However, studies have shown that use of natural gas as primary kiln fuel can result
in three times more NOx emissions than NOx emissions from coal firing. Creating more NOx to
reduce GHG emissions is undesirable as it is a precursor to both ozone and PM2.5. Fuel substitution
essentially trades emissions of one regulated pollutant for another. Estimated capital cost to switch
to natural gas fuel exceeds $25M. Implementing natural gas technology would provide incremental
public health and welfare benefit globally by reducing CO2 emissions, while increasing NOx
emissions and negatively impacting public health and welfare locally. Switching fuels to another
fossil fuel has finite potential to mitigate CO2 emissions.

Step 5: Select BACT
In addition to the proposed energy efficiency improvements addressed elsewhere in this BACT
analysis, BACT is a limit of 0.92-ton CO2e/ton clinker. Ash Grove will use a continuous emission
monitoring system (CEMS) for CO2 to demonstrate compliance with this limit. [Last updated
January 14, 2025]

13. BACT review regarding Leamington Plant Upgrade Project conclusion
The control processes and techniques covered in this BACT analysis have been reviewed by the
NSR Section of the UDAQ. Ash Groves proposed controls and associated emission limitations
represent BACT. Any emission limitations not expressed in an associated NSPS or NESHAP will
be included in the terms and conditions of this AO. A listing of all associated NSPS and NESHAP
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Page 22

programs is also included in the Source Information section of this document under Applicable
Federal Programs. [Last updated December 13, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
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.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date
of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
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proper credit when notifying the Director, send the documentation to the Director, attn.: NSR
Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

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

II.A.3
NEW
Stockpiles
Coal storage
Area: 1 acre
Annual throughput 20,000 tpy

AF and ARM stockpiles
Area: 0.25 acre
Annual throughput 8,000 tpy

II.A.4 Stationary Crusher
Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction
of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000
acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)

II.A.5 Raw Material Transfer
Crushed material is transported to raw material storage by belt B8. The raw material transfers
at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor
transfer point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total
filter area & water sprays. (pre-1983)

II.A.6 Material Handling
Conveyor belt systems, secondary feeders and screens, stacker system

II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit specific requirements

II.A.8 Belt Conveyor Transfer Baghouse
Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area
and 1,800 acfm total air flow, controls emissions from the conveyor belt that transfers the
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stacked material to the raw material silos.

II.A.9 Raw Material Silos
Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The
four silos are equipped with one common Fuller, plenum pulse baghouse (315.BF1) - 1,689 ft2
filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage).

II.A.10 Fifth Component Silo
Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse
(315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw
mill feed. This system includes vibrating feeders, a conveyor system, and surge bin.
Emissions are controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3,
316.BF4, 316.BF5) - each is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1
A/C ratio.

II.A.12 Cross-Belt Analyzer
Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6)

II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom
of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw
materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38).
The following equipment is installed: low-NOx burner, selective non-catalytic reduction
(SNCR) for NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued
mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric
monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct
for mercury adsorption capacity. The carbon injection system is not an emission point as it is
in an enclosed building.

II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

II.A.16 Two Kiln Feed Blending Silos
Raw material is blended in one of two blending silos prior to feeding the kiln. The blending
silos are controlled by one common Fuller, plenum pulse baghouse (411.BF1) - 1,351 ft2 filter
area; 7,160 acfm total air flow.

II.A.17 Blending Silo Elevators (2)
Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped
with a Fuller, pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow
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through stack E34.

II.A.18 Kiln Feed Alleviator
A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the
central material silo between the blending silos and the preheater. Raw feed is removed from
the system near the top of the preheater tower.

II.A.19 Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner.
The coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter
area; 1,700 acfm total air flow.

II.A.20 Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in
the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2):
19,500 acfm rated airflow with 3.75:1 A/C ratio

II.A.21 Clinker Cooler and Baghouse
Reconstructed grate type cooler used for cooling clinker from the kiln prior to transfer to
clinker storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) -
173,869 acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter
monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two
clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse
(419.BF8). The exhaust is routed to the clinker cooler stack.

II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions
generated when loading the east and west clinker silos and the out-of-spec silo are controlled
by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1):
1,800 acfm, that discharges into the clinker tunnel.

II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm, that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2)
Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers.
Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses
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(511.HP1 and new 511.HP2): 1,800 acfm each.

II.A.27 Gypsum Silo
Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2
total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust
during loading.

II.A.28 Clinker Tunnel Exitway
The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse
(511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel all discharge in the clinker tunnel.
Emissions are vented through the tunnel exitway.

II.A.29 Limestone Silo
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust
during loading. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement product. Dust
generated during milling is captured by a BHA, pulse jet baghouse (514.BF2) - 6,080 ft2 filter
area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding
stack).

II.A.31 Finish Mill (Ball Mill) Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized
cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA, pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow
controlling particulates from stack G55 (finish mill stack).

II.A.32
NEW
Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The
stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4)
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1,
525.BF1 thru 3)

II.A.33 Finish Cement Storage Silos
There are six storage and two interstice silos where the finished cement product is stored. A
single common Fuller, plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm
total air flow through stack H7 is located on top of the silos and is used to control emissions
during loading and unloading operations.

II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail
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shipping. This baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out
The cement loadout system located on the South side of the silos (truck load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF2) during unloading from the silos for truck
shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement
conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed
space inside the silos.

II.A.36
NEW
Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

II.A.37 MHO: Materials Handling Operation
Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1
& 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4;
512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.

II.A.38 LBS: Limestone Bypass System
Additional limestone is added to the clinker and gypsum by the limestone bypass system
(LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays
at the screen and material handling drop points.

II.A.39 GEN: Emergency Generators
One diesel-fired emergency generator (new)
Rating: 762 hp
(Kiln, Tier 3, permitted 2022)

Two natural gas-fired emergency generators
Rating: 304 hp
(Main office and control room, permitted in 2023)

One diesel-fired emergency generator
Rating: 560 hp
(Shipping, permitted 2023).

II.A.40 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14 inch knife gate, 8 inch knife gate, 8 inch air
slides, surge bin), and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm)
on the fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

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II.A.41
NEW
Miscellaneous Storage Tanks
One diesel storage tank (<2,000 gallons)
One gasoline storage tank (500 gallons)
Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Requirements on the Cement Plant:
II.B.1.a
NEW
The following limits shall not be exceeded:

A. Clinker production - 1,155,000 tons per rolling 12-month period

B. Used oil consumption - 85,724 gallons per rolling 12-month period

C. Limestone bypass material processed - 216,260 tons per rolling 12-month period.
[R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 25th day of each month using data from the previous 12 months.
Records shall be kept for all periods when the plant is in operation. Consumption and
production shall be calculated through use of the plant's acquisition system. [R307-401-8]

II.B.1.b
NEW
Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations:

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

SO2: 0.4 lbs per ton of clinker (3-hr average)

CO: 3,395 tons per rolling 12-month period, and 6,600 lbs/hr

NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average, and 1,233 tons per rolling
12-month period

Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is
400oF or less.

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Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)

THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)

CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)

PM: 0.02 lbs filterable PM per ton of clinker. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL,
R307-401-8]

II.B.1.c
NEW
A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR
60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust
emissions control plan shall be monitored to demonstrate that appropriate control measures are
being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of
the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall
be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in
the plan and that the source is operating in accordance with the submitted plan. For petitions
to approve alternative control measures, the permittee shall keep a copy of the submitted
petition and any approvals received. [40 CFR 60 Subpart Y]

II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area
source of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2). [40 CFR
63 Subpart LLL]

II.B.1.e
NEW
Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b
and II.B.1.d shall be performed as specified below:

A. Kiln/Raw Mill Stack
Pollutant Test Status Test Frequency
PM * #

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

B. Clinker Cooler (F31)
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Pollutant Test Status Test Frequency
PM + #

C. Testing Status (To be applied above)
* The initial testing has already been performed.

** The SO2 initial performance test was conducted on August 26, 2013.

*** The initial compliance test shall be conducted within the first 30 operating days of
operation in which the affected source operates using a CEMS.

# Test once every year. If performance testing would be required less than 15 operating days
after the Kiln has completed Startup after being down for more than 24 hours, then
performance testing may be deferred up to 15 operating days after completion of the Startup.
The Director may require testing at any time.

## Test at least once every two years. The Director may require testing at any time.

+ Initial testing is required within 180 days of startup of the reconstructed equipment

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must 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 PM CPMS is not out-of-control. The owner/operator must
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 on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

+++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.e.1
NEW
Notification
The Director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The notification requirements for performance tests subject to 40
CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-165]

II.B.1.e.2
NEW
Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational
Safety and Health Administration (OSHA)- or Mine Safety and Health Administration
(MSHA)-approved access shall be provided to the test location. [R307-165]

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II.B.1.e.4
NEW
PM
40 CFR 60, Appendix A, Method 5 or 5I or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three (3) runs with
each run at least 120 minutes in duration and each run collecting a sample of 60 dry standard
cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.3
NEW
Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2. [R307-165]

II.B.1.e.5
NEW
Carbon Monoxide (CO)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.6
NEW
Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.7
NEW
Sulfur Dioxide (SO2)
40 CFR 60, Method 6 or 6C of Appendix A-4 or other EPA-approved method as acceptable to
the Director. [R307-165]

II.B.1.e.8
NEW
Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]

II.B.1.e.9
NEW
Total Hydrocarbons (THC)
Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL]

II.B.1.e.10
NEW
Mercury (Hg)
Continuous Emission or integrated sorbent trap monitoring (See Condition II.B.3.a). [40 CFR
63 Subpart LLL]

II.B.1.e.11
NEW
HCl
Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other
EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]

II.B.1.e.12
NEW
Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.13
NEW
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. [R307-165]

II.B.1.e.14
NEW
Existing Source Operation
For an existing source/emission point, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three years.
[R307-165]

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II.B.1.e.15
NEW
New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the maximum production rate listed in this AO. If the maximum AO
allowable production rate has not been achieved at the time of the test, the following
procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This new
allowable maximum production rate shall remain in effect until successfully tested at a higher
rate.

3) The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate (110%
of the new rate) will then be allowed if the test is successful. This process may be repeated
until the maximum AO production rate is achieved. [R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL.
[40 CFR 63 Subpart LLL]

II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times
of Dust Shuttle System operation to assist in the capture of Mercury emission. [R307-401-8]

II.B.1.h
NEW
Visible emissions from the following emission points shall not exceed the following values:

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

L. All baghouses - 10% opacity
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M. Fugitive dust - 20% opacity

N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y,
R307-401-8]

II.B.1.i 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 must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

If any partially enclosed or unenclosed conveying system transfer point is located in a
building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to
40 CFR 60, according to the following:

(i) The owner/operator must conduct a monthly ten-minute visible emissions test of each
affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The
performance test must be conducted while the affected source is in operation.

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator 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 owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iii) If no visible emissions are observed during the semi-annual test for any affected source,
the owner/operator 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 owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iv) If visible emissions are observed during any Method 22 performance test, of Appendix
A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations,
recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60.
The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour
of any observation of visible emissions.

(v) If visible emissions from a building are monitored, the requirements of paragraphs (i)
through (iv) of this Condition apply to the monitoring of the building, and the owner/operator
must also test visible emissions from each side, roof, and vent of the building for at least ten
minutes. [R307-401]

II.B.1.j
NEW
Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed
0.005 gr/dscf:

520.BF1
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520.BF2
520.BF3
520.BF4
521.BF2
521.BF1
524.BF1
524.BF2
524.BF4
524.BF3
525.BF1
525.BF2
525.BF3
511.HP2
NRL_UPR
NRL_LWR. [R307-401-8]

II.B.1.j.1
NEW
To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration
through at least three (3) annual tests that the PM limits are not being exceeded, the
owner/operator may request approval from the Director to conduct stack testing less
frequently than annually. [R307-401-8]

II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive
dusts as dry conditions warrant or as determined necessary by the Director to maintain opacity
limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated to control fugitive dust. The application of
water or chemical treatment shall be used. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a damp/moist condition unless it is below freezing.
If chemical treatment is to be used, the plan must be approved by the Director. Records of
water and/or chemical treatment shall be kept for all periods when the plant is in operation.
The records shall include the following items: Instances of water and/or chemical application
to unpaved areas shall be recorded and maintained by the owner/operator. The ambient
temperature shall be recorded any time water should be applied but cannot due to freezing
conditions. [R307-401-8]

II.B.2.c
NEW
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

The sprays shall operate whenever dry conditions warrant meeting the required opacity
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limitations or as determined necessary by the Director. Water sprays shall not be required
during periods of freezing temperatures. [R307-401-8]

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation
of fugitive dusts as dry conditions warrant or as determined necessary by the Director.
[R307-401-8]

II.B.2.e
NEW
The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5
PM. [R307-401-8]

II.B.3 Continuous Emission Monitoring Requirements:
II.B.3.a
NEW
The owner/operator shall install, calibrate, maintain and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler.

A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the
missing data substitution procedures used by the UDAQ or the missing data substitution
procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate by the UDAQ.

B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period
including during each startup, shutdown, or malfunction.

C. The monitoring system shall comply with all applicable sections of R307-170, UAC; and
40 CFR 60, Appendix B.

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be
installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the
kiln/raw mill stack.

F. The owner/operator shall record the output of the system: including the quantity of NOx,
CO, O2 THC, Hg, HCl, and CO2 emissions at the kiln stack.

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source 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.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker
cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except
during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments,
the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a
PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the
results of the performance test demonstrating compliance with the filterable PM limit and
using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust
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the SSOL developed in accordance with the results of the most recent PM performance test
demonstrating compliance with the PM emission limit. The owner/operator shall use the PM
CPMS to demonstrate continuous compliance with the SSOL in accordance with the
requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

II.B.4 Fuel Limitations:
II.B.4.a
NEW
The owner/operator shall use only the following fuels in the kiln and pre-calciner:

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.

If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b
NEW
Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the
Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the
results of suitable tests giving data similar to a Proximate and Ultimate analysis of the
proposed coal additive. [R307-401-8]

II.B.4.b.1 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. [R307-401-8]

II.B.4.b.2 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 owner/operator 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 in Condition
II.B.4.b. [R307-401-8]

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II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel burning or process
installation not covered by New Source Performance Standards for sulfur emissions or
covered elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross
Btu heat input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input
for any oil except used oil. The sulfur content shall comply with all applicable sections of
UAC R307-203. [R307-203, R307-401-8]

II.B.4.c.1
NEW
Certification of fuels shall be either by the owner/operator's own testing or test reports from
the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be
available onsite. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials, UAC R307-203-1 (4)

A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be
used.

B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be
used.

C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85 are to be used. [R307-203]

II.B.4.d
NEW
The concentration/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight
3) Cadmium 2 ppm by weight
4) Chromium. 10 ppm by weight
5) Lead 100 ppm by weight
6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be
tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the burn tank and burned. [R307-401-8]

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II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned
in the rotary kiln:

A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than
five minutes in any 60-minute period

B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes
in any 60-minute period. [R307-401-8]

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the
Director. The calibration procedure and frequency shall be according to manufacturer's
specifications. Use of factory-calibrated thermocouples for temperature measurement is
approved. However, any other method of temperature measurement must be approved by the
Director prior to use. The monitoring equipment for both temperature and oxygen content
shall be located such that an inspector can at any time safely read the output. [R307-401-8]

II.B.5
NEW
Emergency Engine Requirements
II.B.5.a
NEW
The owner/operator shall only operate the emergency engines for testing and maintenance
purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency
operation. [R307-401-8]

II.B.5.b
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each emergency engine. [R307-401-8]

II.B.5.b.1
NEW
The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.5.b.2
NEW
To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN103030035-24 dated November 27, 2024
Is Derived From Source Submitted NOI dated November 30, 2022
Incorporates Additional Information Received dated April 26, 2023
Incorporates Additional Information Received dated September 26, 2023
Incorporates Additional Information Received dated July 23, 2024
Incorporates Additional Information Received dated October 25, 2024
Incorporates Additional Information Received dated November 25, 2024

REVIEWER COMMENTS

1. Comment regarding applicability of federal requirements:
New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable
by the best demonstrated technology as specified in the applicable provisions. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.

40 CFR 60, Subpart A (General Provisions)
All affected facilities subject to a source-specific NSPS are subject to the general provisions of
NSPS, Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires
initial notification, performance testing, recordkeeping, and monitoring, provides reference methods,
and mandates general control device requirements for all other subparts.

40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of
performance for affected facilities in Portland Cement Plants which have been constructed or
modified after August 17, 1971.

40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart
F: Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and
unloading systems. The Leamington coal mill is an in-line coal mill and considered an integral part
of the Leamington kiln. In-line coal mills are not subject to NSPS Subpart Y. Therefore, the coal mill
is addressed under NSPS Subpart F as part of the kiln system. The coal silos and conveying system
are subject to NSPS Subpart Y.

Ash Grove's proposed changes to the kiln system must be evaluated as to whether they trigger new
NSPS Subpart F obligations based on whether the proposed project is either a modification or a
reconstruction, as those terms are defined in NSPS Subpart A.

Ash Grove's proposed changes to the kiln system do not meet the definition of a reconstruction, nor
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Page 40

do they meet the definition of a modification for NOx. However, the changes meet the definition of a
modification for PM and SO2. Therefore, Ash Grove will comply with all relevant emission
standards; testing requirements; monitoring, recordkeeping, and reporting obligations that apply to
the Leamington kiln system as an existing source under NSPS Subpart F. Under NSPS Subpart A
and F, the clinker cooler is considered a reconstructed unit. Thus new limits will apply to this unit.
[Last updated January 14, 2025]

2. Comment regarding applicability of federal requirements cont.:
NSPS Subpart Y - Standards of Performance for Coal Preparation and Processing Plants
This subpart provides standards of performance for affected facilities in coal preparation and
processing plants that process more than 200 tons of coal per day.

The Leamington plant's coal silo and coal conveying system are existing affected facilities under
NSPS Subpart Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses
controlling affected facilities subject to match the limit in NSPS Subpart Y from 0.016 gr/dscf to
0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade Project. Since there are no proposed
modifications or reconstruction to the coal silo and coal conveying system, nothing about the
proposed upgrade project affects the existing applicability of NSPS Subpart Y.

NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
This subpart provides standards of performance for affected facilities located at fixed or portable
nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August
31, 1983, with additional requirements applicable to sources constructed on or after April 22, 2008.

As the crushing and screening system is controlled by baghouses and an increase in PM10 actual
emissions on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS.
Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the
Leamington Plant Upgrade Project.

Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1),
60.676(f), and 60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO
monitoring and recordkeeping requirements.

[Last updated January 14, 2025]

3. Comment regarding applicability of federal requirements cont.:
National Emission Standards for Hazardous Pollutants (NESHAPs)
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or
greater than 10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as
specified by each subpart. NESHAP apply to sources in specifically regulated industrial source
classifications (CAA Section 112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities
not regulated as a specific industrial source type. The Ash Grove Leamington Plant is a major source
of HAPs and thus is subject to certain NESHAP standards.

Subpart A - General Provisions
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All affected sources are subject to the general provisions of Subpart A unless otherwise specified by
the source-specific NESHAP. Subpart A generally requires initial notification and performance
testing, recordkeeping, monitoring, provides reference methods, and mandates general control device
requirements for all other subparts as applicable.

Subpart LLL - Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry
This subpart establishes process/source specific emission limits for PM, VOC (expressed as total
hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and
gaseous HAP compounds by limiting PM and THC emissions because portions of such emissions
are USEPA-listed HAPs. Subpart LLL requires compliance with applicable emissions limits on and
after the initial startup of cement production. To further reduce emissions, Subpart LLL also
establishes operational requirements for the use of cement kiln dust (CKD), fly ash, fuel and control
equipment. Subpart LLL also specifies process/source specific emissions testing, monitoring,
recordkeeping, reporting, and compliance demonstration requirements. The compliance requirements
for the site are detailed in Approval Order Condition II.B.1.b. Ash Grove will continue to comply
with the requirements of Subpart LLL to demonstrate compliance. This cement kiln will remain an
existing source with respect to the kiln emission standards in Subpart LLL as this project does not
trigger the definition of a new source in Subpart LLL. New source standards apply only to affected
sources that were constructed or reconstructed after May 6, 2009.
[Last updated December 20, 2024]

4. Comment regarding PSD applicability analysis:
Ash Grove is proposing to increase the throughput of limestone from the quarry to supply the New
Finish Mill to increase the amount of low-carbon cement from the Leamington Plant. Additionally,
along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
modified, and the clinker cooler will be reconstructed. These changes are anticipated to result in an
increase in clinker production. Emission calculations for this project have been completed assuming
an increase in clinker production capacity while utilizing current fuel types. This will result in an
increase in the throughput of fuel.

The Leamington Plant is considered an existing major source under PSD based on potential
emissions of PM10, PM2.5, NOx, CO, SO2, and CO2e. If a major source undergoes a physical or
operational change, the facility must determine whether the project will be considered a major
modification. Per 40 CFR 52.21(b)(2)(i), in order to be a major modification, the project must result
in a significant emissions increase, and a significant net emissions increase.

As defined at 40 CFR 52.21(b)(40): Significant emissions increase means, for a regulated NSR
pollutant, an increase in emissions that is significant for that pollutant. Significant is further defined
to mean, in reference to a net emissions increase or the potential of a source to emit any of the
following pollutants, a rate of emissions that would equal or exceed the values outlined in 40 CFR
52.21(b)(23). If the increase in emissions from the project are not significant, a major modification
has not occurred.

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
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increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

For all pollutants, the project emissions increase was calculated as the difference between the
projected actual emissions (PAE) after the proposed project and the actual emissions prior to the
project (baseline actual emissions or BAE).

Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
". . . projected actual emissions means the maximum annual rate, in tons per year, at which an
existing emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years
(12-month period) following the date the unit resumes regular operation after the project, or in any
one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit of that regulated NSR pollutant and full utilization of the unit would
result in a significant emissions increase or a significant net emissions increase at the major
stationary source." [Last updated January 14, 2025]

5. Comment regarding PSD applicability analysis cont.:
Ash Grove estimates that the projected actual production capacity following the project will be
1,155,000 tons of clinker per year and 1,341,266 tons of limestone per year. These capacities were
used to calculate projected actual emissions from the project using representative emission factors.
Additionally, to estimate emissions from material transfer baghouses, the actual flow rates and actual
projected hours were used as a basis for projected actual emissions.

Project Emission Calculations

Project emission increases from the kiln and coal mill systems are calculated for all criteria
pollutants based on emission factors that are derived from stack testing, CEMS data, or emission
factors (i.e., VOCs and Lead), and the associated projected incremental clinker increase.

NOx emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain
hourly capacity to emit and annual potential to emit at current levels. The kiln's NOx emissions rate
will not change as a result of the physical modifications proposed by the project.

Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission
factor and multiplied by the incremental increase in clinker production. The emission factor was
selected based on the average of the 24-month consecutive month emissions for 2020 and 2021. The
CO emissions will increase.

The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing
conducted at the plant. The SO2 emissions will increase.

VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production. VOC emissions will increase.

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
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Page 43

can be found in the original NOI and subsequent addendums submitted to UDAQ.

As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from
the proposed project, each increase of emissions from both existing and new sources shall be
summed together and compared to the PSD permitting thresholds. The increase of emissions is the
"positive" difference between the projected actual emissions and baseline actual emissions (projected
minus baseline).

New Emissions Sources

The actual to projected actuals calculation is not available to new emission units. For new emission
units, the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected
emissions are based on the new sources' potentials to emit. (40 CFR § 52.21(a)(2)(iv)(f)).

The new equipment proposed includes the New Finish Mill, a new rail and truck loading/loadout,
one (1) new clinker reclaim loading hopper with a dust collector and one (1) existing clinker reclaim
hopper with a dust collector, a new Clinker Cooler to replace the existing one, and a new kiln feed
alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions:

The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;

The finish mill heater was calculated based on its maximum firing capacity and flow rates; and

The fugitive emissions were calculated based on the projected annual throughput of the New Finish
Mill, the rail loadout, and clinker production. [Last updated January 14, 2025]

6. Comment regarding PSD applicability analysis cont.:
Existing Emission Sources

For the existing sources, the projected actual emissions are the maximum annual rates in tons per
year projected to occur during the next five (5) to ten (10) years if the existing sources' design
capacities increase. Ash Grove Leamington projected the actual emissions for the next five (5) years
based on the new kiln system producing an annual average of 3,250 tons of clinker per day.

Baseline actual emissions (BAE) are defined at 40 CFR 52.21(b)(48)(ii) as:

". . . baseline actual emissions means the average rate, in tons per year, at which the emissions unit
actually emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the 10-year period immediately preceding either the date the owner or operator
begins actual construction of the project, or the date a complete permit application is received by the
Administrator."

Ash Grove has selected to use the years 2020 and 2021 for each pollutant as the representative
baseline years.

In its NOI, Ash Grove calculated the emission increase from the project as being divided into two
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 44

phases. Phased construction projects are discussed in two sections of the federal PSD regulations -
40 CFR 52.21(j)(4) and 40 CFr 52.21(r)(2). UDAQ is not processing this project as a phased
construction project, nor did Ash Grove request such a determination. Therefore, Ash Grove
provided a summary table outlining the final change in emissions from this project:

Projected Actual Increase Compared to PSD threshold (tons per year)
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2e
BAE 76.64 39.64 1,187 6.87 3,315 55.47 641,385
PAE 203.15 113.47 1,226 45.87 3,414 72.07 1,067,984

Change in Emissions 126.51 73.83 39.00 39.00 99.00 16.59 426,598

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes

If the emissions increase is greater than the PSD significance threshold for a particular pollutant, Ash
Grove has the option of conducting a PSD review or continuing through the rest of the steps to
determine if it can "net" out of a PSD review. If the project increase is less than the PSD significant
threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant.

The change in emissions from the project exceeds the significant emission threshold for three
pollutants: PM10, PM2.5 and CO2e. Ash Grove elected to attempt to net out of a PSD major
modification for the remainder of the criteria pollutants.

Netting

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant
Upgrade Project and ends on the date the upgrade begins operation. Only PM10, PM2.5, CO2e are in
excess of SERs and therefore considered in the netting analysis.

Ash Grove estimated that the commencement of construction will be in December 2024. Therefore,
the contemporaneous period for this project is December 2019 through a projected date the project
upgrade begins operation. [Last updated January 21, 2025]

7. Comment regarding PSD applicability analysis cont.:
Contemporaneous Decreases

Ash Grove replaced an existing kiln emergency drive engine with a USEPA Tier 4 diesel engine in
2022. Concurrently, Ash Grove requested an increase in the capacity of 1L Cement. Additionally,
Ash Grove submitted a minor modification NOI air permit application on June 12, 2023, which
proposes replacing the shipping generator during the contemporaneous period. The kiln emergency
drive engine and shipping generator are both higher EPA tier ratings therefore result in decreases for
PM10 and PM2.5. These changes were approved in AO DAQE-AN103030033-24 issued March 21,
2024.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 45

Contemporaneous Increases

As stated above, the existing kiln emergency drive engine and shipping generator were permitted and
replaced in 2024. This resulted in an increase in emissions of CO2e.

The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout
in an effort to improve truck traffic at the loadout. The modification to add these dust collectors to
the loadout was included in DAQE-AN103030029-19. The baghouses are three (3) levels up in the
silos' enclosed space (approximately 40 feet). Both dust collectors vent directly into the interior of
the silo structure and are not vented into the atmosphere. Ash Grove requests to remove these
baghouses from its existing permitted emissions inventory. Therefore, these emissions have been
documented in the netting analysis as zero emissions.

Also included in DAQE-AN103030033-24 were two new natural gas-fired emergency generators
and increases in stockpiles, material handling and road emissions.

Could Have Been Accommodated Emissions

In calculating project emissions increase, USEPA allows the exclusion of existing
production/emissions rates that could have been accommodated during the baseline period. These
"could have been accommodated" emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as
follows:

". . . Shall exclude, in calculating any increase in emissions that results from the particular project,
that portion of the unit's emissions following the project that an existing unit could have
accommodated during the consecutive 24-month period used to establish the baseline actual
emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project,
including any increased utilization due to product demand growth;"

Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the
exclusion of existing production and emissions rates that could have been accommodated during the
baseline period, it has elected not to use this exclusion at this time. Therefore, calculation of the
"could have been" accommodated emissions have not been included in this application's
applicability analysis.

The increase from the project is added to the contemporaneous decreases and contemporaneous
increases. The resulting calculation is then compared to the PSD significance threshold to determine
if a significant net emissions increase has occurred. [Last updated January 14, 2025]

8. Comment regarding PSD applicability analysis cont.:
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2 e
Contemporaneous Inc. 1.61 0.45 0.41 0 0.27 0.07 51.74

Contemporaneous Dec. -1.54 -3.97 -0.48 -0.02 -0.27 -0.09 0

Change in Emissions 125.02 69.21 38.93 38.98 99.00 16.58 426,650

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 46

The results of the netting analysis conclude that both a significant emissions increase and a
significant net emissions increase in both particulates (PM10 and PM2.5) and CO2e will occur from
this project. Thus, the project must be reviewed as a PSD major modification. [Last updated January
14, 2025]

9. Comment regarding emission calculations:
This engineering review includes updated potential emission totals for both criteria and HAP
emissions. The potential-to-emit (PTE) values were calculated using updated values for clinker
produced and raw material inputs. BACT emission factors and limitations were used where
appropriate. Certain emission totals (NOx, SO2 and CO) were set based on avoiding a significant
increase in emissions. Specifically, the projected actual increase was set at just under the baseline
actual emissions + the significance level. As these emissions are monitored by CEM, UDAQ agrees
with this approach. Please see the netting analysis for further details on calculation of projected
actual increase. The NOx hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project.

CO2e emissions were calculated using the GHG emission factor calculated from 40 CFR Part 98
Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in Subpart A Table
A-1.

To calculate the PTE tons per year, the maximum hours (i.e., 8760) per year and the source's
emissions rates were multiplied with the throughputs. The potential throughputs have been updated
at UDAQ's request so that PAE is equal to PTE and represents the equipment's maximum design
potential.

Additional emission calculations based on source testing and monitoring, and EPA's compilation of
air emission factors AP-42. [Last updated January 14, 2025]

10. Comment regarding requirements for PSD review:
In addition to the permitting requirements of R307-401-5 through R307-401-8, there are additional
requirements under PSD that must be addressed:

1. Calculation of ambient air increments (40 CFR 52.12(c)), ambient air ceilings ((40 CFR 52.12(d)),
source impact analysis (40 CFR 52.12(k)), air quality models (40 CFR 52.12(l)) - these items are
addressed in the modeling memo DAQE-MN103030032-24.

2. Stack heights (40 CFR 52.12(h)) - Ash Grove's stack heights have been reviewed with respect to
good engineering practice and operate in a vertical unrestricted manner.

3. Control technology review (40 CFR 52.12(j)) - this is addressed in the BACT analysis section of
this review document.

4. Air quality analysis: preapplication analysis (40 CFR 52.12(m)) - this is covered in the PSD
applicability and netting analysis sections of this review document, ambient monitoring and
background data collection is also included in the modeling memo DAQE-MN103030032-24.

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 47

grain loading limit included in II.B.1.j.1 represents the required post-construction monitoring.
6. Source information (40 CFR 52.12(n)) - this is addressed under the requirements of R307-401-5
and was submitted by Ash Grove as part of the NOI package.

7. Additional impact analysis (40 CFR 52.12(o)) - these requirements cover soils, vegetation, growth
and visibility concerns. They are discussed in the modeling memo DAQE-MN103030032-24.

8. Federal land manager review (40 CFR 52.12(p)) - UDAQ provided initial notification to all
federal land managers upon receipt of the original NOI package. The draft permit and engineering
review will also be provided to the federal land managers 60-days prior to initiation of public
comment for their further review.

9. Public participation (40 CFR 52.12(q)) - this project will have a 30-day public comment period.

10. Source obligation (40 CFR 52.12(r)) - this requirement discusses source compliance with other
parts of the CAA, which is addressed within UDAQ's permitting rules in R307.
[Last updated January 14, 2025]

11. Comment regarding changes in equipment list:
The equipment list is being updated for clarity as well as adding new pieces of equipment. The
following changes are taking place:

The naming scheme is being updated to remove the numerical code from the unit designation. This
code generally referred to the associated control device and not to the emitting unit itself. This can
cause confusion especially when the same code was applied to multiple pieces of equipment.
Instead, the control devices (typically baghouse dust collectors) will be identified in the description
along with the appropriate numerical code.

Specific changes are as follows:

1. The kiln description has been updated

2. Clinker Cooler description has been updated to include a larger pulse jet baghouse.

3. The clinker storage silos, east and west clinker belts, clinker belt transfer and clinker tunnel have
been consolidated to avoid confusion

4. The north and south cement loadout exhausts now vent internally into the cement storage silos

5. The dust shuttle system has been consolidated into one line item, most identifiers removed from
subsystem descriptions as only two baghouses serve as exhaust points.

6. A new finish mill with heater has been added. Included in the description are the thirteen total
baghouses for dust control (1 main stack, 2 transfer points, 10 nuisance dust filters)

7. A new clinker reclaim hopper has been added. Both reclaim hoppers are controlled by baghouses
with updated identifiers

8. A new rail and truck loading/unloading system with two baghouses has been added.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 48

[Last updated December 20, 2024]

12. Comment regarding changes in conditions:
As a result of this project, several conditions will be added or changed. This includes one new
general condition (I.8). Changes to the equipment list (section II.A) will be addressed in a separate
reviewer comment:

I.8 - Adding this general condition to cover the requirements of R307-401-18 Eighteen Month
Review. The status of construction/installation of the new equipment shall be reviewed after
18-months.

II.B.1.a - Clinker production increases to 1,155,000 tpy
Use of limestone bypass material increases to 215,260 tpy

II.B.1.b - The NOx limit on the kiln decreases to 1,223 tpy, CO emissions from the kiln decrease to
3,395 tpy,
Adding a new CO2e limit of 0.92 tons CO2e/ton of clinker produced
PM limit on the clinker cooler decreased to 0.02 lb PM (filterable)/ton of clinker
Rule reference updated to include 40 CFR 60 Subpart F, and R307-401-8

II.B.1.e - Initial testing on the clinker cooler is now required within 180 days of startup of the unit.
Monitoring of CO2 from the kiln will be by CEM.
Formatting changes on paragraph designated ++, improve clarity, include reference to CO2
monitoring, define CPMS

II.B.1.e.4 - Update to address general PM monitoring and reference R307-401-8

II.B.1.e.14 - New condition to address new or reconstructed emission units monitoring requirements,
applicable to the clinker cooler and new finish mill.

II.B.1.h - Adding references to Subpart OOO units (limestone processing) with updated opacity
limits.
Adding 20% opacity limit on coal transfer and storage
Adding property boundary opacity limit of 20%
Updating rule reference to include Subpart OOO

II.B.1.j - New condition to address outlet grain loading limits on new baghouses, One identical limit,
15 total new baghouses.

II.B.1.j.1 - Monitoring on new baghouses as per II.B.1.e.4, added an allowance to test less frequently
than annually with three successful tests.

II.B.3.a - Updating formatting to add clarity and include reference to CO2 CEM

II.B.5 - New conditions on emergency engines, diesel fuel sulfur limits, hour of operation
restrictions, non resettable hour meter

[Last updated December 20, 2024]
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 49

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 51

TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 52

DAQE-MN103030032-24

M E M O R A N D U M

TO: John Jenks, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler
Dave Prey, Air Quality Modeler

DATE: December 12, 2024

SUBJECT: Modeling Analysis Review for the Ash Grove Cement Company – Leamington Plant,
located in Millard County, Utah
___________________________________________________________________________________
This is a Major Modification to a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Ash Grove Cement Company (Applicant) has submitted a Notice of Intent (NOI) air permit
application for a project referred to as the Leamington Upgrade Project (LUP). The proposed
upgrade project includes the construction and installation of new pollution control equipment, new
emission sources, and modifications to existing emission sources. Emission increases associated
with the LUP constitute a major modification to a Prevention of Significant Deterioration (PSD)
source subject to PSD permitting regulations. PSD regulations require the Applicant to include and
air quality impact analysis (AQIA) of the proposed projects impact on the EPA national ambient air
quality standards (NAAQS) and air quality related values (AQRV) as part of a complete NOI.

This report prepared by the New Source Review (NSR) modeling staff contains a review of the
Applicant’s Air Quality Impact Analysis (AQIA) including the methodology, data sources,
assumptions, and modeling results for comparison with State and Federal air quality standards. The
AQIA was reviewed and referenced in this report include the:
● Notice of Intent – Ash Grove Cement Leamington Plant PSD Notice of Intent Air Permit
Application, dated November 30, 2022.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

0 0
Jason Krebs

DP
DAQE-MN103030032-24
Page 2

II. APPLICABLE RULES AND ANALYSES

A Utah Air Quality Rules

The UDAQ has determined that the Applicant’s NOI is subject to the following rules for conducting an
AQIA:

R307-401 Permits: New and Modified Sources
R307-405 Permits: Major Sources Located in Attainment or Unclassified Area (PSD)
R307-406-2 Visibility – Source Review
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutant Impacts in Attainment Areas

B. Applicability

The proposed increases in emissions of PM10 and PM2.5 exceed the emission thresholds outlined in R307-
406-5 and R307-410-4. Therefore, an AQIA consistent with the requirements of R307-405-6, R307-406-
2, and R307-410-3 was submitted as part of the Applicant’s NOI. R307-410-3 establishes the U. S.
Environmental Protection Agency (US EPA) – Guideline on Air Quality Models as a formal basis for
defining the scope of the analysis, as well as the model’s construction. The results of the AQIA are
required to demonstrate the proposed project’s impact on state and federal air quality standards,
acceptable levels of impact, and action triggering thresholds referenced or listed in R307-401-6(2), R307-
401-6(3), R307-403-3(1), R307-403-5(1)(a), R307-405-4(1), R307-405-6. Annual emissions for criteria
pollutants requiring an AQIA are listed in Table 1.

Table 1: Ash Grove Leamington Proposed Net Emissions Increase

Criteria
Pollutants
Net Emission
Increase (TPY)
AQIA Trigger
Level (TPY) AQIA Required?
PM10 126.6 15 Yes
PM2.5 70.3 10 Yes

C. Required Analyses

R307-405 requires the Applicant to perform a pre-construction modeling analysis for all pollutants
emitted in a significant quantity. The purpose of the analysis is to determine if the extent of the source’s
impact is significant enough to warrant an on-site measurement of the ambient background concentration
levels. This data is included in the NAAQS analysis to represent the quality of the air prior to the
construction of the proposed project. The Applicant included a pre-construction modeling analysis for
PM10 and PM2.5 as part of the NOI. The pre-construction modeling analysis was also used to determine if
the proposed emissions would result in a significant impact to the environment, thereby triggering the
requirement for a cumulative analysis of the proposed project and other nearby existing sources.

R307-401-8 requires the Division to determine that the proposed project will comply with the NAAQS
prior to the issuance of an Approval Order (AO). R307-405(7) requires the Applicant to perform a
DAQE-MN103030032-24
Page 3
NAAQS analysis for all pollutants emitted in a significant quantity. The analysis is to include all
emissions at the proposed site under normal operating conditions using maximum anticipated short-term
release and annual release rates. Consistent with UDAQ policy, a cumulative analysis to include the
ambient background concentration and any contribution from other nearby sources is not required if the
proposed project’s impact does not exceed the PSD Class II Significant Impact Level (SIL).

R307-401-8 also requires the Division to determine that the proposed project will comply with PSD
increments prior to the issuance of an AO. Under R307-405(6), the Applicant is required to perform a
PSD Class I and II increment consumption analysis for all pollutants emitted in significant quantities.
The purpose of this analysis is to quantify any degradation in air quality since the major source baseline
date. The analysis is to include all increment consuming emissions at the proposed site under normal
operating conditions using maximum anticipated short-term and annual release rates. A cumulative
analysis to include contributions associated with growth and other increment consuming sources is not
required if the proposed project’s impact does not exceed the PSD Class I or II SIL.

R307-410-5 requires the Applicant to perform a HAPs analysis for any pollutant emitted above a
pollutant specific emission threshold value. This analysis is to include all emissions of the pollutants
resulting from the proposed modification under normal operating conditions using maximum anticipated
one-hour release rates. The Applicant did not trigger modeling for HAPs.

R307-406-2 requires the Applicant to perform a plume blight analysis. A plume blight analysis is required
to determine if plumes emanating from the proposed project would be visible inside any Class I area
within 50 kilometers of the source. The plume blight analysis is to include all emissions of NO2, SO4, and
PM10.

Under R307-405-16, an AQRV analysis is performed which evaluates regional haze and acid deposition
impacts at each of the Class I areas within 300 kilometers of the source. A regional haze analysis is
required to determine if the plumes would reduce the visual range of an observer inside the Class I area.
The regional haze analysis is to include all emissions of SO2, NOX and PM10. The deposition analysis
examines impacts from sulfur and nitrogen compounds at the Class I areas, and is based on all emissions
of SO2 and NOX. The Federal Land Managers use the Q/D approach to determine whether a PSD project
should provide detailed AQRV impact analyses, where: Q/D= [ H2SO4 + SO2 + NOx + PM10 emissions
(tpy)]/ distance (km). If Q/D is less than 10, no AQRV analysis is required.

R307-405 requires the Applicant to perform a soils and vegetation analysis. The analysis should quantify
the effects of pollutants on soils and vegetation near the highest impact location and in areas where
sensitive plant species may be impacted.

III. ON-SITE PRE-CONSTRUCTION MONITORING

A. Meteorological Data

Consistent with the US EPA - Meteorological Monitoring Guidance for Regulatory Modeling
Applications, one year of on-site data was collected using a 50-meter tower during the period October 1,
2021 through September 30, 2022. Parameters collected on-site included wind speed and direction,
temperature, delta-T, and solar radiation.

DAQE-MN103030032-24
Page 4

B. Ambient Pollutant Data

A preliminary analysis was conducted to determine the necessity for pre-construction ambient pollutant
monitoring. The results indicate that predicted concentrations of PM10 and PM2.5 exceed the monitoring
trigger level listing in the rule. A continuous PM10/PM2.5 monitor with filter based samplers was
installed near the northern edge of the Applicants property boundary, and collected particulate matter
from October 1, 2021 through September 30, 2022.

IV. MODEL SELECTION

The EPA-AERMOD dispersion modeling system is the preferred model specified in the US EPA –
Guideline on Air Quality Models to predict air pollutant concentrations in the near field (within 50
kilometers of the source). The US EPA - CALPUFF - Version 5.8 model is the preferred model to predict
concentrations in the far field (long range transport conditions beyond 50 kilometers from the source).

V. MODELING INPUTS AND ASSUMPTIONS

A. Technical Options

The regulatory default options were selected in AERMOD by the Applicant to quantify all concentrations.

B. Urban or Rural Area Designation

A review of the appropriate 7.5-minute quadrangles determined that the area should be classified as
“rural” for air modeling purposes.

C. Topography/Terrain

The Plant is at an elevation of 4,950 feet with nearby terrain features that have an effect on concentration
predictions.

a. Zone: 12
b. Location: UTM (NAD83): 397000 meters East, 4379850 meters North

D. Ambient Air

It was determined that the Plant boundary used in the AQIA meets the State’s definition of an ambient air
boundary.

E. Receptor and Terrain Elevations

The modeling domain has simple and complex terrain features in the near field. Therefore, receptor
points representing actual terrain elevations from the area were used in the analysis.

The far-field modeling domain consisted of a rectangular region covering all Class I areas within Utah,
and extending 50 kilometers beyond this area so that the model can account for re-circulation of the
plume.

DAQE-MN103030032-24
Page 5

F. Emission Rates and Release Parameters

The emission estimates and source parameters used in AERMOD for all proposed emission sources at the
site are presented in the NOI.

Speciated emission rates and source parameters used in the CALPUFF modeling are presented in Table 2.

Table 2: CALPUFF Emission Rates

Source
LCC Coordinates Modeled Emission Rates
Easting Northing SO2 SO4 NOX HNO3 NO3 SOA PMC SOIL EC
(m) (m) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr)
317.BF3 -1289410 -3738 52.81 5.03 307.58 0.00 0.00 5.03 2.60 2.90 0.11
419.BF1 -1289314 -3631 0.00 0.00 0.00 0.00 0.00 0.55 1.51 1.61 0.06
41B.BF2 -1289389 -3663 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.68 0.00
N1_FM2 -1289526 -3414 0.00 0.00 0.00 0.00 0.00 0.00 1.65 3.95 0.00
414.BF1N -1289407 -3683 0.00 0.00 0.00 0.00 0.00 0.00 0.10 0.25 0.00
2FM_HTR -1289528 -3415 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.08 0.00
514.BF1 -1289451 -3675 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.70 0.00
COMBO -1289424 -3668 0.00 0.00 0.00 0.00 0.00 0.00 1.37 5.72 0.00
FM2_CMB -1289454 -3439 0.00 0.00 0.00 0.00 0.00 0.00 0.50 1.21 0.00

Total Lb/hr 52.81 5.03 307.58 0.00 0.00 5.58 8.32 17.10 0.17
Hrs/Yr 8760 8760 8760 8760 8760 8760 8760 8760 8760
Ton/yr 231.3 22.0 1347.2 0.0 0.0 24.4 36.4 74.9 0.8

Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
317.BF3 POINT 4902.8 41.2 135.0 488 10.10 3.35
419.BF1 POINT 4891.2 18.3 60.0 388 6.36 2.90
41B.BF2 POINT 4895.2 68.6 224.9 294 17.83 0.74
N1_FM2 POINT 4832.0 49.7 163.0 363 40.08 1.40
414.BF1N POINT 4896.1 76.8 251.9 353 9.91 0.70
2FM_HTR POINT 4832.0 49.7 163.0 363 40.08 1.40
514.BF1 POINT 4889.5 39.6 130.0 294 11.86 0.91
COMBO POINT 4904.2 13.3 43.7 276 9.76 0.32
DAQE-MN103030032-24
Page 6
FM2_CMB POINT 4832.0 30.6 100.3 294 11.40 0.37

G. Building Downwash

The Applicant used the US EPA Building Profile Input Program (BPIP) to determine Good Engineering
Practice (GEP) stack heights and cross-sectional building dimensions for input into the model.

H. Ambient Background Concentrations

Millard County is in attainment for all criteria pollutants. The NAAQS analyses for PM2.5 and PM10 used
monitoring data collected on site during the pre-construction monitoring analysis. The background values
used in the NAAQS analysis are presented in Table 3.

Table 3: Background Concentrations

Pollutant Averaging
Period
Background
Concentration
(μg/m3)
PM10 24-hour 65.4
PM2.5 24-hour 10.2
Annual 4.2

I. Meteorological Data Processing

For the AERMOD model, on-site horizontal and vertical wind speed, direction, solar radiation and,
temperature data was combined with National Weather Service (NWS) upper air data collected at the Salt
Lake City International Airport (SLCIA) for the same period using the US EPA AERMET processing
system.

Meteorological data used for the CALPUFF modeling analysis consisted of 3 years (2018-2020) of data
developed by the Forest Service. The grid was 708 km (east-west) by 492 km (north-south) with a
resolution of 12 kilometers.

VI. RESULTS AND CONCLUSIONS

The Applicant performed a series of analyses to estimate the impact from the proposed project. Modeling
results and conclusions from the review of the analyses are outlined in detail below.

A. Pre-Construction Monitoring and Significant Impact Modeling

The Applicant performed a preliminary criteria pollutant analysis of the proposed modification. This
analysis indicated that increases in concentration levels of PM2.5 and PM10 were greater than the Class II
SIL, and therefore, a cumulative analysis for these pollutants was required.

DAQE-MN103030032-24
Page 7

B. NAAQS Analysis

The Applicant performed a modeling analysis to determine if the combined impact from the proposed
source, other industrial sources operating in the area, and ambient background would comply with the
NAAQS. The NAAQS analysis was reviewed by the Division and determined to be consistent with the
requirements of R307-410-3. Table 4 provides a comparison of the Applicant’s predicted air quality
concentrations and the NAAQS.

Table 4: Model Predicted NAAQS Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-hour 28.3 5 65.4 0 93.7 150 62.5%
PM2.5 24-hour 9.6 1.2 10.2 0 19.8 35 56.6%
Annual 4.4 0.3 4.2 0 8.6 9 95.6%
* Note: Only included other sources and background if source impact was above Class II SIL

C. PSD Class II Increments

The Applicant performed an analysis to determine if the impact from the proposed source would comply
with PSD Class II increments. The analysis was reviewed by the Division and determined to be
consistent with the requirements of R307-410-3. Table 5 provides a comparison of the predicted
concentrations and the PSD Class II increment.

Table 5: Model Predicted PSD Class II Increment Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Nearby
Sources*
Total Increment Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
PM10 Annual 8.1 1 0 8.1 25 32.4%
24-hour 28.3 5 0 28.3 30 94.3%
PM2.5 24-hour 6.1 1.2 0 6.1 9 67.8%
Annual 2.4 0.3 0 2.4 4 60.0%

D. Hazardous Air Pollutants

DAQE-MN103030032-24
Page 8
The Applicant performed an analysis to determine if HAP modeling is required. The analysis was
reviewed by the Division and determined to be consistent with the requirements of R307-410-3. The
analysis indicated that HAP modeling was not triggered by this modification, and therefore no HAP
modeling was performed.

E. PSD Class I Increment Consumption Analysis

The Applicant performed a CALPUFF analysis to determine if the impact from the proposed source along
with other increment consuming sources would comply with federal PSD Class I increments. The
analysis was reviewed by the Division and determined to be consistent with the requirements of R307-
410-3. The results for all Class I areas within 300 kilometers are provided in Table 6.

Table 6: Model Predicted PSD Class I Increment Concentrations

Air Period Prediction
Class I
Significant
Impact
Level
Other
Sources* Total Increment Percent
Pollutant (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
Capitol Reef
NO2 Annual 0.0018 0.1 2.5
SO2
3-Hour 0.0494 1 25
24-
Hour 0.0150 0.2 5
Annual 0.0008 0.1 2
PM2.5
24-
Hour 0.0430 0.27 2
Annual 0.0021 0.05 1
PM10
24-
Hour 0.0444 0.3 8
Annual 0.0021 0.2 4
Arches
NO2 Annual 0.0008 0.1 2.5
SO2
3-Hour 0.0408 1 25
24-
Hour 0.0102 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0522 0.27 2
Annual 0.0018 0.05 1
DAQE-MN103030032-24
Page 9
PM10
24-
Hour 0.0531 0.3 8
Annual 0.0019 0.2 4
Canyonlands
NO2 Annual 0.0010 0.1 2.5
SO2
3-Hour 0.0354 1 25
24-
Hour 0.0100 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0577 0.27 2
Annual 0.0019 0.05 1
PM10
24-
Hour 0.0591 0.3 8
Annual 0.0020 0.2 4
Bryce
NO2 Annual 0.0006 0.1 2.5
SO2
3-Hour 0.0369 1 25
24-
Hour 0.0082 0.2 5
Annual 0.0003 0.1 2
PM2.5
24-
Hour 0.0189 0.27 2
Annual 0.0010 0.05 1
PM10
24-
Hour 0.0194 0.3 8
Annual 0.0010 0.2 4
Zion
NO2 Annual 0.0011 0.1 2.5
SO2
3-Hour 0.0293 1 25
24-
Hour 0.0105 0.2 5
Annual 0.0005 0.1 2
PM2.5
24-
Hour 0.0266 0.27 2
Annual 0.0011 0.05 1
PM10 24-
Hour 0.0271 0.3 8
DAQE-MN103030032-24
Page 10
Annual 0.0012 0.2 4
* Note: Only included other increment consuming sources if source impact was above Class I SIL

Since the proposed project’s model predicted impacts at the Class I areas were less than the PSD Class I
significance levels, a cumulative analysis was not warranted.

DAQE-MN103030032-24
Page 11
F. Visibility – Plume Blight
Since the Class I areas are greater than 50 kilometers from the source, a plume blight analysis using
VISCREEN was not required.

G. Visibility – Regional Haze

The results of the Q/D analysis for the emissions increase was less than 10 but the FLMs wanted the
entire source included in the Q term. The results of including the total emissions resulted in a Q/D >10,
so an AQRV analysis was performed for visibility and acid deposition. The results shown in Table 7
indicate that the impacts are below the 0.5 Deciview (DV) threshold established by the National Park
Service, indicating that no further analysis is required.

Table 7: CALPUFF Visibility Results

Class I Area Year Maximum
Delta DV
98th
Percentile
change in
DV
#
Days
#
Days Threshold
(DV)
Below
Threshold
> 1 > 0.5
2018 0.248 0.06 0 0 0.5 Yes
Arches 2019 0.291 0.054 0 0 0.5 Yes
2020 0.216 0.106 0 0 0.5 Yes
2018 0.223 0.081 0 0 0.5 Yes
Canyonlands 2019 0.312 0.068 0 0 0.5 Yes
2020 0.186 0.085 0 0 0.5 Yes
2018 0.059 0.03 0 0 0.5 Yes
Bryce 2019 0.081 0.045 0 0 0.5 Yes
2020 0.071 0.03 0 0 0.5 Yes
2018 0.183 0.074 0 0 0.5 Yes
Capital Reef 2019 0.196 0.092 0 0 0.5 Yes
2020 0.126 0.078 0 0 0.5 Yes
2018 0.069 0.04 0 0 0.5 Yes
Zion 2019 0.123 0.039 0 0 0.5 Yes
2020 0.102 0.057 0 0 0.5 Yes

DAQE-MN103030032-24
Page 12

H. Acid Deposition

The Applicant performed a deposition analysis on impacts within the Class I areas. Results of the
analysis indicate that the impacts are below the deposition threshold (DAT) established by the National
Park Service, indicating that no further analysis is required

Table 8: CALPUFF Deposition Results for Highest Year

Class I Area
Total
Nitrate
Deposition
Total
Sulfate
Deposition
Deposition
Analysis
Threshold
(kg/ha/yr) (kg/ha/yr) (kg/ha/yr)
Canyonlands 0.0006 0.0003
0.005
Zion 0.0004 0.0002
Arches 0.0006 0.0003
Bryce 0.0006 0.0002
Capitol Reef 0.0011 0.0005

I. Soils and Vegetation Analysis

The Applicant performed an analysis to determine the extent of impacts from the proposed source on soil
and vegetation. Results of the analysis are presented in a supplemental document titled “Soil and
Vegetation Impact Analysis for the Leamington, UT Facility, June 29, 2023”. The analysis indicated that
predicted concentrations compared against the secondary NAAQS at several sensitive receptors would not
result in an adverse impact on soils and vegetation in the vicinity of the proposed project.

DP/JK:jg

DAQE-IN103030032-25

January 22, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Mr. Nelson:

Re: Intent to Approve: Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — ) A A v A ? A D @ A w D D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — ) A A v A ? A D @ A w D D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ash Grove Cement Company Ash Grove Cement Company - Leamington Cement Plant

Mailing Address Physical Address
P.O. Box 38069 Highway 132
Leamington, UT 84638 Leamington, UT 84638

Source Contact UTM Coordinates
Name: Cody Watkins 397000 m Easting
Phone: [phone] 4380100 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3241 (Cement, Hydraulic)

SOURCE INFORMATION
General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried on site),
are correctly proportioned, ground, and mixed and then fed into a rotating kiln. The kiln alters the
materials and recombines them into small stones called cement clinker. The clinker is cooled and ground
with gypsum and additional limestone into a fine powdered cement. The final product is stored on site for
later shipping. The major sources of air emissions are from the combustion of fuels for the kiln operation,
from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source of
emissions of PM2.5, PM10, NOx, CO, HAPs, and GHG. It is a minor source of SO2 emissions.
NSR Classification
Major PSD Modification

Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
DAQE-IN103030032-25
Page 4

Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

These changes result in increases in actual emissions but decreases in most potential emissions. There will
be an increase in the potential emissions of VOCs and greenhouse gases.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
DAQE-IN103030032-25
Page 5

Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
DAQE-IN103030032-25
Page 6

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, 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. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO 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. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
DAQE-IN103030032-25
Page 7

II.A.4 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)
II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area, and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, stacker systems. II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit-specific requirements.
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total air flow controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter
area; 9,865 acfm total air flow, controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are
controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each
is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6). II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The
following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for
NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.
II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low-pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

DAQE-IN103030032-25
Page 8

II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow through stack
E34.
II.A.18 Kiln Feed Alleviator A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the central material silo between the blending silos and the preheater. Raw feed is removed from the system near the top of the preheater tower.
II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The
coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter area;
1,700 acfm total air flow.
II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker
storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1): 1,800 acfm that discharges into the clinker tunnel.
II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
DAQE-IN103030032-25
Page 9

II.A.27 Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during loading.
II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel, all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during loading. 512.BF3 (1,000 acfm) is located on top of the silo. II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement products. Dust generated
during milling is captured by a BHA pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).

II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates from stack G55 (finish mill stack).
II.A.32 Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4).
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1 thru 3).

II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total air flow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations.
II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This
baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

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II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.
II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023)
II.A.40 Dust Shuttle System A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides, surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the
fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

II.A.41 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons) Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
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II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)
THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)
CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)
PM: 0.02 lbs filterable PM per ton of clinker.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR 60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to approve alternative control measures, the permittee shall keep a copy of the submitted petition and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source
of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2).
[40 CFR 63 Subpart LLL]

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II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must 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 PM CPMS is not out of control. The owner/operator must 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 on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
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II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

II.B.1.e.3 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-165]
II.B.1.e.4 PM 40 CFR 60, Appendix A, Method 5, or 5I, or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three runs, with each
run at least 120 minutes in duration and each run collecting a sample of 60 dry standard cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 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. [R307-165]
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II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
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II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
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II.B.1.i 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 must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator 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 owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator 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 owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
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II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: Instances of water and/or chemical application to unpaved areas shall be recorded and maintained by the owner/operator. The ambient temperature shall be recorded any time water should be applied but cannot due to freezing conditions. [R307-401-8]
II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

The sprays shall operate whenever dry conditions warrant meeting the required opacity
limitations or as determined necessary by the Director. Water sprays shall not be required during
periods of freezing temperatures.

[R307-401-8]

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II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

C. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the kiln/raw mill stack

F. The owner/operator shall record the output of the system: including the quantity of NOx, CO, O2, THC, Hg, HCl, and CO2 emissions at the kiln stack

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an
affected source 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.

[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]
II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments, the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the results of the performance test demonstrating compliance with the filterable PM limit and using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust the SSOL developed in accordance with the results of the most recent PM performance test demonstrating compliance with the PM emission limit. The owner/operator shall use the PM CPMS to demonstrate continuous compliance with the SSOL in accordance with the requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

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II.B.4 Fuel Limitations: II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke F. Fuel Oil
G. Used Oil Fuel

H. Synthetic Fuel
I. Wood
J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 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. [R307-401-8]
II.B.4.b.2 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 owner/operator 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 in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

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II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight
A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation
C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit-no less than 1500oF for more than five minutes in any 60-minute period B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
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II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the Director. The calibration procedure and frequency shall be according to manufacturer's specifications. Use of factory-calibrated thermocouples for temperature measurement is approved. However, any other method of temperature measurement must be approved by the Director prior to use. The monitoring equipment for both temperature and oxygen content shall be located such that an inspector can at any time safely read the output. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall only operate the emergency engines for testing and maintenance purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency operation. [R307-401-8]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.5.b.2 To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From Source Submitted NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-IN103030032-25
Page 22

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds