DAQ-2024-011862

DAQE-AN103030035-24

{{$d1 }}

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

Dear Mr. Nelson:

Re: Approval Order: Modification of Approval Order DAQE-AN103030033-24 to Increase
Alternative Fuel Allowances
Project Number: N103030035

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on February
4, 2024. Ash Grove Cement Company must comply with the requirements of this AO, all applicable state
requirements (R307), and Federal Standards.

The project engineer for this action is John Jenks, who can be contacted at [phone] or
[e-mail]. Future correspondence on this AO should include the engineer's name as well as the
DAQE number shown on the upper right-hand corner of this letter. No public comments were received on
this action.

Sincerely,

{{$s }}

Bryce C. Bird
Director

BCB: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

November 27, 2024

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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APPROVAL ORDER
DAQE-AN103030035-24
Modification of Approval Order DAQE-AN103030033-24 to
Increase Alternative Fuel Allowances

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

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
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Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

November 27, 2024
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
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 5
SECTION II: SPECIAL PROVISIONS ..................................................................................... 9
PERMIT HISTORY ................................................................................................................... 18
ACRONYMS ............................................................................................................................... 19

DAQE-AN103030035-24
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
Millard 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, SO2, CO, HAPs, and GHG.
NSR Classification
Minor Modification at Major Source

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
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
DAQE-AN103030035-24
Page 4

NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Major Source

Project Description
Ash Grove submitted two separate requests to increase the potential use of alternative fuels. Tire-derived
fuel (TDF) is currently limited to 15% of total energy supplied to the kiln. As part of Ash Grove's tire
recycling efforts, they have requested this value be increased to 25% of total energy input. Ash Grove has
also requested the possible use of process engineered fuel (PEF) be increased. PEF is currently approved
as a coal additive. Utah Division of Air Quality (UDAQ) has reviewed the requests and opted to grant
TDF and PEF the same fuel use as any other listed approved fuel (see condition II.B.4.a). There will be
no change in emissions as a result of this change.

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 0 1.00
Carbon Monoxide 0 13045.00
Lead Compounds 0 0.04
Nitrogen Dioxide 0 1351.44
Particulate Matter - PM10 0 236.36
Particulate Matter - PM2.5 0 230.74
Sulfur Dioxide 0 192.40
Volatile Organic Compounds 0 59.38

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 1500
Beryllium (TSP) (CAS #7440417) 0 1
Chromium Compounds (CAS #CMJ500) 0 135
Dioxin/Furan Toxic Equivalents: 2,3,7,8-Tetrachlorodibenzo-P-
Dioxin (CAS #1746016)
0 2
Formaldehyde (CAS #50000) 0 18755
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 0 41640
Lead Compounds (CAS #LCT000) 0 72
Mercury (TSP) (CAS #7439976) 0 53
Naphthalene (CAS #91203) 0 1600
Selenium (TSP) (CAS #7782492) 0 200
Change (TPY) Total (TPY)
Total HAPs 0 31.98
DAQE-AN103030035-24
Page 5

SECTION I: GENERAL PROVISIONS

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 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]

SECTION II: PERMITTED EQUIPMENT

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-AN103030035-24
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II.A.4 211.BF1: Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse and with water sprays on the feed hopper. (pre-1983)
II.A.5 211.BF2: Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse 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.8 311.BC1: Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (141 ft2 filter area; 1,800 acfm total air flow) controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 315.SX1 thru 4: Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse - 1,689 ft2 filter area; 9,865
acfm total air flow, controlling particulates from stack C125 (raw storage) .
II.A.10 315.BF2: Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 316.BF1 thru 5: 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.12 316.BF6: Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse. II.A.13 317.BF3: Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a baghouse on the main stack (D38). The following equipment is
installed: low-NOx burner, selective non-catalytic reduction (SNCR) for NOx control; NOx, CO,
total hydrocarbons, and oxygen 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 ranging from
360,000 to 435,000 acfm controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

DAQE-AN103030035-24
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II.A.16 411.BF1 and 2: 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 - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 412.BF1 and 2: Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse - 676 ft2 filter area; 2,800 acfm total air flow through stack E34.

II.A.18 414.BF1: Kiln Feed Alleviator A pulse jet baghouse - 1,144 ft2 filter area; 1,672 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 41B.BF1: Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The coal storage silo is equipped with a Unifilter shaker baghouse - 1,508 ft2 filter area; 1,700 acfm
total air flow.

II.A.20 41B.BF2: Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse, 19,500 acfm rated airflow with 3.75:1 A/C ratio baghouse.
II.A.21 419.BF1: Clinker Cooler and Baghouse
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 Fuller plenum pulse baghouse - 32,426 ft2 filter area;
202,414 acfm total air flow on the clinker cooler stack (F31). A PM CPMS is installed.

II.A.22 419.BF8 and 419.BF10: Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. Particulates from outside the clinker belt are controlled by one Fuller plenum pulse baghouse - 1,351 ft2 filter area; 4,700 acfm total air flow. The conveyor and transfer points are controlled by a second, similar baghouse - 1,351 ft2 filter area; 6,500 acfm total air flow through stack F73. II.A.23 419.BF9: Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a baghouse.

II.A.24 419.BF9: East Clinker Belt Clinker from the clinker cooler is transferred into the East clinker silo by conveyor belt. The discharge from the belt is controlled by a baghouse.
II.A.25 419.BF9: West Clinker Belt
Clinker from the clinker cooler is transferred into the West clinker silo by conveyor belt. The
discharge from the belt is controlled by a baghouse.

II.A.26 419.BF9 - Pulse Jet Baghouse One General Electric, pulse jet baghouse - 11,880 acfm total air flow controlling particulates from east and west clinker storage silos and from the out of specification silo
II.A.27 511.BF1: East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (1,800 acfm)
that discharges into the clinker tunnel.

DAQE-AN103030035-24
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II.A.28 511.BF2: West Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (1,800 acfm) that discharges into the clinker tunnel.
II.A.29 511.BF3: Clinker Reclaim Hopper Imported clinker is fed to the clinker tunnel conveyor belt by the outside clinker hopper. Emissions during transfer of clinker to the conveyor are controlled by a BHA baghouse (1,800
acfm) that discharges into the clinker tunnel.
II.A.30 511.BF4: Gypsum Silo Discharge Gypsum is fed to the clinker tunnel conveyor belt from the gypsum storage silo. Emissions during transfer of gypsum to the conveyor are controlled by a BHA baghouse (1,800 acfm) that discharges into the clinker tunnel.
II.A.31 511.BF1 thru 4: Clinker Tunnel Exitway The clinker reclaim hopper baghouse (511.BF3), east clinker silo discharge baghouse (511.BF1),
west clinker silo discharge baghouse (511.BF2), and gypsum silo discharge baghouse (511.BF4)
all discharge in the clinker tunnel. Emissions are discharged through the tunnel exitway.
II.A.32 512.SX1: Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse is installed on the gypsum storage silo to control dust during loading.
II.A.33 512.BF2 and 3: Limestone Silo & Belt
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. Emissions from the silo and conveyor are controlled by two BHA baghouses. 512.BF2
(1800 acfm) discharges in the clinker tunnel. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.34 514.BF2: 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 - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).
II.A.35 514.BF1: Finish Mill Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA pulse jet baghouse - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates
from stack G55 (finish mill stack).
II.A.36 611.BF1: 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 - 1,351 ft2 filter area; 8,000 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.37 611.BF3: North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled
by a Fuller pulse jet baghouse - with 676 ft2 filter area; 2,800 acfm air flow during unloading
from the silos for rail shipping.

II.A.38 611.BF2, 611.BF4, 611.BF5: South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse - 676 ft2 filter area; 2,800 acfm air flow (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5; both 2,825 acfm and 682 ft2 filter area) control emissions from the cement conveyor fluidslides and truck loading chutes.
DAQE-AN103030035-24
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II.A.39 MHO: Materials Handling Operation Includes the following emission units: 315.SX1 thru 4; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.SX1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.40 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.41 GEN: Emergency Generators One diesel-fired emergency generator Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators (new) Rating: 304 hp (Main office and control room, installed 2023) One diesel-fired emergency generator (new) Rating: 762 hp (Shipping, installed 2023).
II.A.42 Dust Shuttle System
A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The system includes the following equipment: elevator from baghouse (317.BE1), pneumatic air slide
(317.AS12), alkali silo (413.BN1), pug mill (413.MZ1), pug mill loadout (wetted material),
fringe bin (Finish Mill) (514.BN1), 14-inch knife gate (317.GA2), 8-inch knife gate (317.GA4), 8-inch air slides (317.AS21, 317.AS22, 317.AS23), surge bin (317.BN1), and pneumatic blower
system (413.BL2).

II.A.43 Dust shuttle sys continued Emissions from the dust shuttle system 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.44 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
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 - 962,265 tons per rolling 12-month period
B. Used oil consumption - 85,724 gallons per rolling 12-month period
C. Limestone bypass material processed - 150,000 tons per rolling 12-month period. [R307-401-8]

DAQE-AN103030035-24
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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: 13,045 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 1,347.2 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
THC: 24 ppmvd (corrected to 7% O2)
Source: Clinker Cooler Stack (F31)

PM: 0.07 lbs filterable PM per ton of clinker.
[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 *** ++ 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. ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a. The PM10 initial performance test shall be performed in accordance with 40 CFR 63.1349 and compliance shall be demonstrated 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 63 Subpart LLL, R307-401-8]
DAQE-AN103030035-24
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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 be performed using Method 5 or
5I and consist of three one-hr tests. [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 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.13 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]
DAQE-AN103030035-24
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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 Visible emissions from the following emission points shall not exceed the following values: A. All crushers - 15% opacity B. All screens - 10% opacity C. Conveyor transfer points - 10% opacity D. All stacking conveyors - 10% opacity E. Bins and trap feeder - 10% opacity F. All diesel engines - 20% opacity G. All support equipment - 20% opacity H. All baghouses - 10% opacity I. Fugitive dust - 20% opacity J. All other points, except for blasting - 20% opacity. [R307-401-8]
DAQE-AN103030035-24
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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] 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]

DAQE-AN103030035-24
Page 15

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] 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.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 1/raw mill stack and clinker cooler. The owner/operator shall record the output of the system, including the quantity of NOx and CO emissions at the kiln
stack. 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. 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. The monitoring system shall comply with all
applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B. A THC and Oxygen CEMs shall be installed on Kiln 1. A mercury (Hg) CEM or integrated sorbent trap monitoring system
shall be installed on Kiln 1. A HCl CEM shall be installed on Kiln 1. 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 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-AN103030035-24
Page 16

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 Material Safety Data Sheets (MSDS) or the results of suitable tests giving data similar to a Proximate and Ultimate analysis of the proposed coal additive. [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-AN103030035-24
Page 17

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]

DAQE-AN103030035-24
Page 18

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]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030033-24 dated March 21, 2024
Is Derived From Source Submitted NOI dated February 4, 2024
Incorporates Additional Information Received dated May 21, 2024

DAQE-AN103030035-24
Page 19

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-IN103030035-24

October 10, 2024

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

Dear Mr. Nelson:

Re: Intent to Approve: Modification of Approval Order DAQE-AN103030033-24 to Increase
Alternative Fuel Allowances
Project Number: N103030035

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

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

INTENT TO APPROVE
DAQE-IN103030035-24
Modification of Approval Order DAQE-AN103030033-24 to
Increase Alternative Fuel Allowances

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

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
October 10, 2024

{{$s }}

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

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 ................................................................................................................... 19
ACRONYMS ............................................................................................................................... 20

DAQE-IN103030035-24
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
Millard 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, SO2, CO, HAPs, and GHG.
NSR Classification
Minor Modification at Major Source

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
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
DAQE-IN103030035-24
Page 4

NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
Title V (Part 70) Major Source

Project Description
Ash Grove submitted two separate requests to increase the potential use of alternative fuels. Tire-derived
fuel (TDF) is currently limited to 15% of total energy supplied to the kiln. As part of Ash Grove's tire
recycling efforts, they have requested this value be increased to 25% of total energy input. Ash Grove has
also requested the possible use of (PEF) be increased. PEF is currently approved as a coal additive. Utah
Division of Air Quality (UDAQ) has reviewed the requests and opted to grant TDF and PEF the same
fuel use as any other listed approved fuel (see condition II.B.4.a). There will be no change in emissions as
a result of this change.

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 0 1.00
Carbon Monoxide 0 13045.00
Lead Compounds 0 0.04
Nitrogen Dioxide 0 1351.44
Particulate Matter - PM10 0 236.36
Particulate Matter - PM2.5 0 230.74
Sulfur Dioxide 0 192.40
Volatile Organic Compounds 0 59.38

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 1500
Beryllium (TSP) (CAS #7440417) 0 1
Chromium Compounds (CAS #CMJ500) 0 135
Dioxin/Furan Toxic Equivalents: 2,3,7,8-Tetrachlorodibenzo-P-
Dioxin (CAS #1746016)
0 2
Formaldehyde (CAS #50000) 0 18755
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 0 41640
Lead Compounds (CAS #LCT000) 0 72
Mercury (TSP) (CAS #7439976) 0 53
Naphthalene (CAS #91203) 0 1600
Selenium (TSP) (CAS #7782492) 0 200
Change (TPY) Total (TPY)
Total HAPs 0 31.98
DAQE-IN103030035-24
Page 5

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 UAC R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress on October 16, 2024. 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]
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]
DAQE-IN103030035-24
Page 6

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
II.A.4 211.BF1: Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000 acfm baghouse and with water sprays on the feed hopper. (pre-1983) II.A.5 211.BF2: Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer point is equipped with a baghouse 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.8 311.BC1: Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (141 ft2 filter area; 1,800 acfm total air flow) controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 315.SX1 thru 4: Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four silos are equipped with one common Fuller, plenum pulse baghouse - 1,689 ft2 filter area; 9,865
acfm total air flow controlling particulates from stack C125 (raw storage) .
II.A.10 315.BF2: Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse - 844 ft2 filter area; 3,500 acfm total air flow.
DAQE-IN103030035-24
Page 7

II.A.11 316.BF1 thru 5: Raw Mill Recirculation Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are controlled by five equivalent baghouses (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.12 316.BF6: Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse.

II.A.13 317.BF3: Kiln & Pre-Calciner and Raw Mill Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a baghouse on the main stack (D38). The following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for NOx control; NOx, CO, total hydrocarbons, 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 ranging from 360,000 to 435,000 acfm, controlling particulates from stack D38 (raw mill/kiln stack 317.BF3) II.A.16 411.BF1 and 2: 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 - 1,351 ft2 filter area; 7,160 acfm total air flow.

II.A.17 412.BF1 and 2: Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller, pulse jet baghouse - 676 ft2 filter area; 2,800 acfm total air flow through stack E34.
II.A.18 414.BF1: Kiln Feed Alleviator A pulse jet baghouse - 1,144 ft2 filter area; 1,672 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 41B.BF1: Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The coal storage silo is equipped with a Unifilter, shaker baghouse - 1,508 ft2 filter area; 1,700 acfm total air flow.
II.A.20 41B.BF2: Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the
mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse, 19,500 acfm rated airflow with
3.75:1 A/C ratio baghouse.

II.A.21 419.BF1: Clinker Cooler and Baghouse 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 Fuller plenum pulse baghouse - 32,426 ft2 filter area; 202,414 acfm total air flow on the clinker cooler stack (F31). A PM CPMS is installed.
DAQE-IN103030035-24
Page 8

II.A.22 419.BF8 and 419.BF10: Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. Particulates from outside the clinker belt are controlled by one Fuller plenum pulse baghouse - 1,351 ft2 filter area; 4,700 acfm total air flow. The conveyor and transfer points are controlled by a second, similar baghouse - 1,351 ft2 filter area; 6,500 acfm total air flow through stack F73. II.A.23 419.BF9: Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated when loading the east and west clinker silos and the out-of-spec silo are controlled by a baghouse.

II.A.24 419.BF9: East Clinker Belt Clinker from the clinker cooler is transferred into the East clinker silo by conveyor belt. The discharge from the belt is controlled by a baghouse. II.A.25 419.BF9: West Clinker Belt
Clinker from the clinker cooler is transferred into the West clinker silo by conveyor belt. The
discharge from the belt is controlled by a baghouse.
II.A.26 419.BF9 - Pulse Jet Baghouse One General Electric, pulse jet baghouse - 11,880 acfm total air flow controlling particulates from east and west clinker storage silos and from the out of specification silo
II.A.27 511.BF1: East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (1,800 acfm)
that discharges into the clinker tunnel.

II.A.28 511.BF2: West Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (1,800 acfm) that discharges into the clinker tunnel.
II.A.29 511.BF3: Clinker Reclaim Hopper
Imported clinker is fed to the clinker tunnel conveyor belt by the outside clinker hopper. Emissions during transfer of clinker to the conveyor are controlled by a BHA baghouse (1,800
acfm) that discharges into the clinker tunnel.

II.A.30 511.BF4: Gypsum Silo Discharge Gypsum is fed to the clinker tunnel conveyor belt from the gypsum storage silo. Emissions during transfer of gypsum to the conveyor are controlled by a BHA baghouse (1,800 acfm) that discharges into the clinker tunnel.
II.A.31 511.BF1 thru 4: Clinker Tunnel Exitway
The clinker reclaim hopper baghouse (511.BF3), east clinker silo discharge baghouse (511.BF1),
west clinker silo discharge baghouse (511.BF2), and gypsum silo discharge baghouse (511.BF4)
all discharge in the clinker tunnel. Emissions are discharged through the tunnel exitway.

II.A.32 512.SX1: Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse is installed on the gypsum storage silo to control dust during loading.
II.A.33 512.BF2 and 3: Limestone Silo & Belt
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. Emissions from the silo and conveyor are controlled by two BHA baghouses. 512.BF2
(1800 acfm) discharges in the clinker tunnel. 512.BF3 (1,000 acfm) is located on top of the silo.

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II.A.34 514.BF2: 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 - 6,080 ft2 filter area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding stack).
II.A.35 514.BF1: Finish Mill Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA, pulse jet baghouse - 4,053 ft2 filter area; 20,000 acfm total air flow controlling particulates from stack G55 (finish mill stack).
II.A.36 611.BF1: 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 - 1,351 ft2 filter area; 8,000 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.37 611.BF3: North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller pulse jet baghouse - with 676 ft2 filter area; 2,800 acfm air flow during unloading
from the silos for rail shipping.

II.A.38 611.BF2, 611.BF4, 611.BF5: South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller, pulse jet baghouse - 676 ft2 filter area; 2,800 acfm air flow (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5; both 2,825 acfm and 682 ft2 filter area) control emissions from the cement conveyor fluidslides and truck loading chutes. II.A.39 MHO: Materials Handling Operation
Includes the following emission units: 315.SX1 thru 4; 315.BF2; 316.BF1 thru 5; 316.BF6;
411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.SX1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.

II.A.40 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.41 GEN: Emergency Generators
One diesel-fired emergency generator
Rating: 762 hp (Kiln, Tier 3, permitted 2022)

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

One diesel-fired emergency generator (new)
Rating: 762 hp
(Shipping, installed 2023)

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II.A.42 Dust Shuttle System A dust shuttling system is used intermittently to mitigate mercury emissions as required. The system includes the following equipment: elevator from baghouse (317.BE1), pneumatic air slide (317.AS12), alkali silo (413.BN1), pug mill (413.MZ1), pug mill loadout (wetted material), fringe bin (Finish Mill) (514.BN1), 14 inch knife gate (317.GA2), 8 inch knife gate (317.GA4), 8 inch air slides (317.AS21, 317.AS22, 317.AS23), surge bin (317.BN1), pneumatic blower system (413.BL2).
II.A.43 Dust shuttle systems continued Emissions from the dust shuttle system 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.44 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 - 962,265 tons per rolling 12-month period. B. Used oil consumption - 85,724 gallons per rolling 12-month period. C. Limestone bypass material processed - 150,000 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]
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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: 13,045 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 1,347.2 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 THC: 24 ppmvd (corrected to 7% O2) Source: Clinker Cooler Stack (F31) PM: 0.07 lbs filterable PM per ton of clinker. [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 *** ++ 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. ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a. The PM10 initial performance test shall be performed in accordance with 40 CFR 63.1349, and compliance shall be demonstrated 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 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 be performed using Method 5 or
5I and consist of three one-hr tests. [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 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.13 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.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 Visible emissions from the following emission points shall not exceed the following values: A. All crushers - 15% opacity. B. All screens - 10% opacity. C. Conveyor transfer points - 10% opacity. D. All stacking conveyors - 10% opacity. E. Bins and trap feeder - 10% opacity. F. All diesel engines - 20% opacity. G. All support equipment - 20% opacity. H. All baghouses - 10% opacity. I. Fugitive dust - 20% opacity. J. All other points, except for blasting - 20% opacity. [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] 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]

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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] 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.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 1/raw mill stack and clinker cooler. The owner/operator
shall record the output of the system, including the quantity of NOx and CO emissions at the kiln
stack. 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. 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. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B. A Total Hydrocarbons
(THC) and Oxygen (O2) CEMs shall be installed on Kiln 1. A mercury (Hg) CEM or integrated
sorbent trap monitoring system shall be installed on Kiln 1. A HCl CEM shall be installed on Kiln 1. 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 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 Material Safety Data Sheets (MSDS) or the results of suitable tests giving data similar to a Proximate and Ultimate analysis of the proposed coal additive. [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]
PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN103030033-24 dated March 21, 2024 Is Derived From Source Submitted NOI dated February 4, 2024 Incorporates Additional Information Received dated May 21, 2024

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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

Millard County Chronicle Progress
Publication Name:
Millard County Chronicle Progress
Publication URL:
Publication City and State:
Delta, UT
Publication County:
Millard
Notice Popular Keyword Category:
Notice Keywords:
ash grove
Notice Authentication Number:
202410171022059694322
1761527914
Notice URL:
Public Notice
Back
Notice Publish Date:
Wednesday, October 16, 2024
Notice Content
A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah Administrative Code (UAC), has been received for
consideration by the Director:
Company Name: Ash Grove Cement Company Location: Ash Grove Cement Company - Leamington Cement Plant – Hwy 132, Leamington,
UT
Project Description: Ash Grove Cement Company (Ash Grove) submitted two separate requests to increase the potential use of alternative
fuels. Tire-derived fuel (TDF) is currently limited to 15% of total energy supplied to the kiln. As part of Ash Grove's tire recycling efforts, they
have requested this value be increased to 25% of total energy input. Ash Grove has also requested the possible use of processengineered
fuel (PEF) be increased. PEF is currently approved as a coal additive. The Utah Division of Air Quality has reviewed the requests and opted to
grant TDF and PEF the same fuel use as any other listed approved fuel (see condition II.B.4.a). There will be no change in emissions as a
result of this change.
The completed engineering evaluation and air quality impact analysis showed the proposed project meets the requirements of federal air
quality regulations and the State air quality rules. The Director intends to issue an Approval Order pending a 30-day public comment period.
The project proposal, estimate of the effect on local air quality, and draft Approval Order are available for public inspection and comment at
the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments received by the Division at this same
address on or before November 15, 2024, will be considered in making the final decision on the approval/disapproval of the proposed project.
Email comments will also be accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of publication of
this notice, a hearing will be held in accordance with R307-401-7, UAC.
Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or argument during an adjudicatory
proceeding that was raised during the public comment period and was supported with sufficient information or documentation to enable the
Director to fully consider the substance and significance of the issue.
Published in the Millard County Chronicle Progress October 16, 2024.
Back

DAQE-NN103030035-24

October 10, 2024

Millard County Chronicle Progress
Legal Advertising Dept
P.O. Box 249
Delta (Millard), UT 84624

RE: Legal Notice of Intent to Approve

This letter will confirm the authorization to publish the attached NOTICE in the Millard County
Chronicle Progress on October 16, 2024.

Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at [phone].

Sincerely,

{{$s }}

Jeree Greenwood
Office Technician

Enclosure

cc: Six County Association of Governments
cc: Juab County

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

DAQE-NN103030035-24
Page 2
NOTICE

A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:

Company Name: Ash Grove Cement Company
Location: Ash Grove Cement Company - Leamington Cement Plant – Hwy 132,
Leamington, UT
Project Description: Ash Grove Cement Company (Ash Grove) submitted two separate requests to
increase the potential use of alternative fuels. Tire-derived fuel (TDF) is currently
limited to 15% of total energy supplied to the kiln. As part of Ash Grove's tire
recycling efforts, they have requested this value be increased to 25% of total
energy input. Ash Grove has also requested the possible use of process-
engineered fuel (PEF) be increased. PEF is currently approved as a coal additive.
The Utah Division of Air Quality has reviewed the requests and opted to grant
TDF and PEF the same fuel use as any other listed approved fuel (see condition
II.B.4.a). There will be no change in emissions as a result of this change.

The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality, and draft Approval Order are available for public inspection and comment at
the Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before November 15, 2024, will be considered in
making the final decision on the approval/disapproval of the proposed project. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director in writing within 15 days of
publication of this notice, a hearing will be held in accordance with R307-401-7, UAC.

Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.

Date of Notice: October 16, 2024

{{#s=Sig_es_:signer1:signature}}

DAQE-

RN103030035 September 24, 2024 Paul Pederson
Ash Grove Cement Company P.O. Box 38069 Leamington, UT 84638
[e-mail] Dear Paul Pederson,
Re: Engineer Review: Modification of Approval Order DAQE-AN103030033-24 to Increase Alternative Fuel Allowances Project Number: N103030035 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 [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)
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
Department of Environmental Quality
Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director
State of Utah
SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor

Engineer Review N103030035: Ash Grove Cement Company- Leamington Cement Plant September 24, 2024 Page 1
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 N103030035: Ash Grove Cement Company- Leamington Cement Plant September 24, 2024 Page 2
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION
Project Number N103030035 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 May 21, 2024 Date of Accepted Application August 28, 2024

Engineer Review N103030035: Ash Grove Cement Company- Leamington Cement Plant September 24, 2024 Page 3
SOURCE DESCRIPTION General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Millard 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, SO2, CO, HAPs and GHG. NSR Classification: Minor Modification at Major Source 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 NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion Engines NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines
MACT (Part 63), A: General Provisions MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing Industry MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines Title V (Part 70) Major Source Project Proposal
Modification of Approval Order DAQE-AN103030033-24 to Increase Alternative Fuel Allowances
Project Description Ash Grove submitted two separate requests to increase the potential use of alternative fuels. Tire derived fuel (TDF) is currently limited to 15% of total energy supplied to the kiln. As part of Ash
Grove's tire recycling efforts they have requested this value be increased to 25% of total energy input. Ash Grove has also requested the possible use of process engineered fuel (PEF) be increased. PEF is currently approved as a coal additive. UDAQ has reviewed the requests and
opted to grant TDF and PEF the same fuel use as any other listed approved fuel (see condition II.B.4.a). There will be no change in emissions as a result of this change.

Engineer Review N103030035: Ash Grove Cement Company- Leamington Cement Plant September 24, 2024 Page 4
EMISSION IMPACT ANALYSIS No modeling is required as no change in emissions is taking place. [Last updated September 11, 2024]

Engineer Review N103030035: Ash Grove Cement Company- Leamington Cement Plant September 24, 2024 Page 5
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 0 1.00 Carbon Monoxide 0 13045.00
Lead Compounds 0 0.04
Nitrogen Dioxide 0 1351.44
Particulate Matter - PM10 0 236.36
Particulate Matter - PM2.5 0 230.74
Sulfur Dioxide 0 192.40 Volatile Organic Compounds 0 59.38 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 1500
Beryllium (TSP) (CAS #7440417) 0 1
Chromium Compounds (CAS #CMJ500) 0 135
Dioxin/Furan Toxic Equivalents: 2,3,7,8-Tetrachlorodibenzo-P-Dioxin (CAS #1746016) 0 2
Formaldehyde (CAS #50000) 0 18755
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 0 41640 Lead Compounds (CAS #LCT000) 0 72 Mercury (TSP) (CAS #7439976) 0 53
Naphthalene (CAS #91203) 0 1600
Selenium (TSP) (CAS #7782492) 0 200
Change (TPY) Total (TPY)
Total HAPs 0 31.98 Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N103030035: Ash Grove Cement Company- Leamington Cement Plant September 24, 2024 Page 6
Review of BACT for New/Modified Emission Units 1. BACT review regarding no review of BACT required
This project addresses the use of two previously approved fuels TDF has been approved as a specifically listed fuel in Ash Grove's existing AO. PEF was previously approved as a coal additive as allowed under condition II.B.4.b. Ash Grove has requested that both alternative fuels
be approved for use at 25% of total heat input to the kiln and pre-calciner. This change does not require any physical changes to the plant. Total emissions will not increase above currently allowed levels. No review of BACT is required. [Last updated September 11, 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]

Engineer Review N103030035: Ash Grove Cement Company- Leamington Cement Plant September 24, 2024 Page 7

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 Stockpiles Coal storage
Area: 1 acre Annual throughput 20,000 tpy AF and ARM stockpiles (new) Area: 0.25 acre
Annual throughput 8,000 tpy II.A.4 211.BF1: Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000 acfm baghouse and with water sprays on the feed hopper. (pre-1983) II.A.5 211.BF2: Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer point is equipped with a baghouse 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.8 311.BC1: Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (141 ft2 filter area; 1,800 acfm total air flow) controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 315.SX1 thru 4: Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The
four silos are equipped with one common Fuller, plenum pulse baghouse - 1,689 ft2 filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage) .

Engineer Review N103030035: Ash Grove Cement Company- Leamington Cement Plant September 24, 2024 Page 8
II.A.10 315.BF2: Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 316.BF1 thru 5: Raw Mill Recirculation Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are controlled by five equivalent baghouses (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.12 316.BF6: Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse. II.A.13 317.BF3: Kiln & Pre-Calciner and Raw Mill Kiln burning process, calciner, and preheater tower off gases are directed through the bottom
of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a baghouse on the main stack (D38). The following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for NOx control; NOx, CO, total hydrocarbons, 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 ranging from 360,000 to 435,000 acfm controlling particulates from stack D38 (raw mill/kiln stack 317.BF3) II.A.16 411.BF1 and 2: 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 - 1,351 ft2 filter area; 7,160 acfm total air flow. II.A.17 412.BF1 and 2: Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller, pulse jet baghouse - 676 ft2 filter area; 2,800 acfm total air flow through stack E34.
II.A.18 414.BF1: Kiln Feed Alleviator
A pulse jet baghouse - 1,144 ft2 filter area; 1,672 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.

Engineer Review N103030035: Ash Grove Cement Company- Leamington Cement Plant September 24, 2024 Page 9
II.A.19 41B.BF1: Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The coal storage silo is equipped with a Unifilter, shaker baghouse - 1,508 ft2 filter area;
1,700 acfm total air flow. II.A.20 41B.BF2: Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse, 19,500 acfm rated airflow with 3.75:1 A/C ratio baghouse. II.A.21 419.BF1: Clinker Cooler and Baghouse 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 Fuller, plenum pulse baghouse - 32,426 ft2 filter area; 202,414 acfm total air flow on the clinker cooler stack (F31). A PM CPMS is installed.
II.A.22 419.BF8 and 419.BF10: Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. Particulates from outside the clinker belt are controlled by one Fuller, plenum pulse baghouse - 1,351 ft2 filter area; 4,700 acfm total air flow. The conveyor and transfer points are controlled by a second, similar baghouse - 1,351 ft2 filter area; 6,500 acfm total air flow through stack F73.
II.A.23 419.BF9: Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated when loading the east and west clinker silos and the out-of-spec silo are controlled by a baghouse.

II.A.24 419.BF9: East Clinker Belt Clinker from the clinker cooler is transferred into the East clinker silo by conveyor belt. The discharge from the belt is controlled by a baghouse.
II.A.25 419.BF9: West Clinker Belt Clinker from the clinker cooler is transferred into the West clinker silo by conveyor belt. The discharge from the belt is controlled by a baghouse.
II.A.26 419.BF9 - Pulse Jet Baghouse
One General Electric, pulse jet baghouse - 11,880 acfm total air flow controlling particulates from east and west clinker storage silos and from the out of specification silo
II.A.27 511.BF1: East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (1,800 acfm) that discharges into the clinker tunnel.

II.A.28 511.BF2: West Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (1,800
acfm) that discharges into the clinker tunnel.

Engineer Review N103030035: Ash Grove Cement Company- Leamington Cement Plant September 24, 2024 Page 10
II.A.29 511.BF3: Clinker Reclaim Hopper Imported clinker is fed to the clinker tunnel conveyor belt by the outside clinker hopper. Emissions during transfer of clinker to the conveyor are controlled by a BHA baghouse (1,800
acfm) that discharges into the clinker tunnel. II.A.30 511.BF4: Gypsum Silo Discharge Gypsum is fed to the clinker tunnel conveyor belt from the gypsum storage silo. Emissions during transfer of gypsum to the conveyor are controlled by a BHA baghouse (1,800 acfm) that discharges into the clinker tunnel. II.A.31 511.BF1 thru 4: Clinker Tunnel Exitway The clinker reclaim hopper baghouse (511.BF3), east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), and gypsum silo discharge baghouse (511.BF4) all discharge in the clinker tunnel. Emissions are discharged through the tunnel exitway.
II.A.32 512.SX1: Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse is installed on the gypsum storage silo to control dust during loading.
II.A.33 512.BF2 and 3: Limestone Silo & Belt Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. Emissions from the silo and conveyor are controlled by two BHA baghouses. 512.BF2
(1800 acfm) discharges in the clinker tunnel. 512.BF3 (1,000 acfm) is located on top of the silo.
II.A.34 514.BF2: 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 - 6,080 ft2 filter area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding stack).
II.A.35 514.BF1: Finish Mill Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA, pulse jet baghouse - 4,053 ft2 filter area; 20,000 acfm total air flow controlling particulates from stack G55 (finish mill stack). II.A.36 611.BF1: 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 - 1,351 ft2 filter area; 8,000 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.37 611.BF3: North Cement Load Out The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse - with 676 ft2 filter area; 2,800 acfm air flow during
unloading from the silos for rail shipping.

Engineer Review N103030035: Ash Grove Cement Company- Leamington Cement Plant September 24, 2024 Page 11
II.A.38 611.BF2, 611.BF4, 611.BF5: South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller, pulse jet baghouse - 676 ft2 filter area; 2,800 acfm air flow (611.BF2)
during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5; both 2,825 acfm and 682 ft2 filter area) control emissions from the cement conveyor fluidslides and truck loading chutes.

II.A.39 MHO: Materials Handling Operation Includes the following emission units: 315.SX1 thru 4; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.SX1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1. II.A.40 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.41 GEN: Emergency Generators One diesel-fired emergency generator Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators (new) Rating: 304 hp
(Main office and control room, installed 2023)
One diesel-fired emergency generator (new) Rating: 762 hp (Shipping, installed 2023).
II.A.42 Dust Shuttle System A dust shuttling system is used intermittently to mitigate mercury emissions as required. The system includes the following equipment: elevator from baghouse (317.BE1), pneumatic air slide (317.AS12), alkali silo (413.BN1), pug mill (413.MZ1), pug mill loadout (wetted
material), fringe bin (Finish Mill) (514.BN1), 14 inch knife gate (317.GA2), 8 inch knife gate (317.GA4), 8 inch air slides (317.AS21, 317.AS22, 317.AS23), surge bin (317.BN1), pneumatic blower system (413.BL2).
II.A.43 Dust shuttle sys continued Emissions from the dust shuttle system 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.44 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons)
Three ammonia storage tanks (8,000 gallons each)

Engineer Review N103030035: Ash Grove Cement Company- Leamington Cement Plant September 24, 2024 Page 12
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 The following limits shall not be exceeded:
A. Clinker production - 962,265 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 150,000 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 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: 13,045 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 1,347.2 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 THC: 24 ppmvd (corrected to 7% O2) Source: Clinker Cooler Stack (F31) PM: 0.07 lbs filterable PM per ton of clinker. [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

Engineer Review N103030035: Ash Grove Cement Company- Leamington Cement Plant September 24, 2024 Page 13
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 *** ++
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. ++ Compliance with the limits shall be demonstrated through use of a continuous emissions

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monitoring system as outlined in Condition II.B.3.a. The PM10 initial performance test shall be performed in accordance with 40 CFR 63.1349 and compliance shall be demonstrated 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 63 Subpart LLL, R307-401-8]
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 be performed using Method 5
or 5I and consist of three (3) one-hr tests. [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)

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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 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.13 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.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 Visible emissions from the following emission points shall not exceed the following values: A. All crushers - 15% opacity B. All screens - 10% opacity C. Conveyor transfer points - 10% opacity
D. All stacking conveyors - 10% opacity
E. Bins and trap feeder - 10% opacity
F. All diesel engines - 20% opacity G. All support equipment - 20% opacity H. All baghouses - 10% opacity I. Fugitive dust - 20% opacity
J. All other points, except for blasting - 20% opacity. [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

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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.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]

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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]
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.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 1/raw mill stack and clinker cooler. The owner/
operator shall record the output of the system: including the quantity of NOx and CO emissions at the kiln stack. 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. 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. The monitoring system shall comply with all applicable sections of R307-170, UAC; and 40 CFR 60, Appendix B. A Total Hydrocarbons (THC) and Oxygen (O2) CEMs shall be installed on Kiln 1. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on Kiln 1. A HCl CEM shall be installed on Kiln 1. 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 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] II.B.4 Fuel Limitations:
II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:

Engineer Review N103030035: Ash Grove Cement Company- Leamington Cement Plant September 24, 2024 Page 18
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 Material Safety Data Sheets (MSDS) or the results of suitable tests giving data similar to a Proximate and Ultimate analysis of the proposed coal additive. [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] 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

Engineer Review N103030035: Ash Grove Cement Company- Leamington Cement Plant September 24, 2024 Page 19
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]

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]

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Engineer Review N103030035: Ash Grove Cement Company- Leamington Cement Plant September 24, 2024 Page 21
PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the
following documents: Is Derived From Source Submitted NOI dated February 4, 2024
Incorporates Additional Information Received dated May 21, 2024 Supersedes DAQE-AN103030033-24 dated March 21, 2024
REVIEWER COMMENTS 1. Comment regarding project related AO changes: The only change in conditions from this project is the inclusion of PEF as a specifically listed fuel in condition II.B.4.a. Subparagraph J has been renumbered as K. The text of that subparagraph has also been updated - removing the restriction on TDF. This allows for all listed fuels to be used as desired. Coal additives are still specifically limited by conditions II.B.4.b, b.1 and b.2. [Last updated September 11, 2024] 2. Comment regarding no emission changes: There is no change in emissions from this project. Potential emissions are based on total hours of kiln operation and specific emission factors listed in II.B.1.e. These emission factors are verified by
stack tests and CEM. The emission factors are not changing as a result of this project. [Last updated September 11, 2024]

Engineer Review N103030035: Ash Grove Cement Company- Leamington Cement Plant September 24, 2024 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 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 TPY Tons per year
UAC Utah Administrative Code VOC Volatile organic compounds

DAQE-GN103030031-23

{{$d1 }}

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

Dear Mr. Pederson:

RE: Use of Processed Engineered Fuel as a Coal Additive
Project Number: N103030031

The Division of Air Quality (DAQ) has reviewed your request of November 22, 2022, requesting the use
of processed engineered fuel as a coal additive at your Leamington Cement Plant.

The use of alternative fuels as a coal additive is outlined in conditions II.B.4.a, II.B.4.b and II.B.4.b.1 of
Ash Grove's Approval Order (DAQE-AN103030030-22). Ash Grove has submitted information pursuant
to the test results listed in condition II.B.4.b. DAQ agrees that the proposed fuel meets the definition of a
coal additive. The average quantity of processed engineered fuel burned shall not be greater than 15% of
the total daily heat input of the kiln and precalciner. Ash Grove 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. No Approval Order change is
required. There will be no change in emission quality or quantity as a result of this change.

The charge for the review done in making this change is a flat fee plus a filing fee as authorized by the
Utah Legislature. You will receive an invoice for these charges shortly. If you have any questions,
please contact John Jenks who can be reached at [phone] or [e-mail].

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg
{{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#s=Sig_es_:signer1:signature}}
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 ? v A ? A B ? H w C F ˜
March 20, 2023