DAQ-2025-002558

DAQE-AN103030032-25

{{$d1 }}

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

Dear Mr. Nelson:

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

The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on
November 30, 2022. 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

Tim Davis
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

May 21, 2025

STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

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APPROVAL ORDER
DAQE-AN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

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

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
{{$d2 }}

Issued By

{{$s }}

Bryce C. Bird
Director
Division of Air Quality

May 21, 2025
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 .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-AN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

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

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

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

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

NSR Classification
Major PSD Modification

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

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
DAQE-AN103030032-25
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MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

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

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

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

SUMMARY OF EMISSIONS

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

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

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
DAQE-AN103030032-25
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Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

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]
DAQE-AN103030032-25
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I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]

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

SECTION II: PERMITTED EQUIPMENT
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 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983) II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, and stacker system II.A.7 Portable Crusher Portable unit, not a stationary source, no unit-specific requirements
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total airflow, controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
DAQE-AN103030032-25
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II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 Raw Mill Recirculation Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6).

II.A.13 Kiln & Pre-Calciner and Raw Mill Kiln-burning process, calciner, and preheater tower off-gases are directed through the bottom of the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;
II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric
monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for
mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.

II.A.15 Solios Low-Pressure Pulse Jet Baghouse One Solios low-pressure pulse jet baghouse - 173,712 ft2 filter area; airflow: 435,000 acfm controlling particulates from stack D38 (raw mill/kiln stack 317.BF3).
II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos
are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area;
7,160 acfm total airflow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total airflow through stack E34.
II.A.18 Kiln Feed Alleviator
A new pulse jet baghouse (414.BF1N) - 9,900 acfm total airflow controls particulate from the
central material silo between the blending silos and the preheater. Raw feed is removed from the
system near the top of the preheater tower.

II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The coal storage silo is equipped with a Unifilter shaker baghouse (41B.BF1) - 1,508 ft2 filter area; 1,700 acfm total air flow.
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II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total airflow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.
II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

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

II.A.26 Clinker Reclaim Hoppers (two) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
II.A.27 Gypsum Silo
Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during
loading.

II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4): 1,800 acfm, gypsum discharge into the clinker tunnel all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during
loading. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.30 Finish Mill (Ball Mill) The finish mill grinds clinker and gypsum to produce finished cement product. Dust generated during milling is captured by a BHA, pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total airflow controlling particulates from stack G105 (finish grinding stack).
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II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA, pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow controlling particulates from stack G55 (finish mill stack). II.A.32 Finish Mill and Separator (Vertical Mill) New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack
is controlled by a baghouse (524.BF3): 158,376 acfm. Two baghouses control conveyor transfer points (524.BF2 & 4) Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1
thru 3).
II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total airflow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations. II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled
by a Fuller pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.
II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS).
The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.

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II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023) II.A.40 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides,
surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

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

SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Site-Wide Requirements: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period. B. Used oil consumption - 85,724 gallons per rolling 12-month period. C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
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: 3,395 tons per rolling 12-month period and 6,600 lbs/hr NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-month period Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ) (corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less. Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average) THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average) CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average) Source: Clinker Cooler Stack (F31) PM: 0.02 lbs filterable PM per ton of clinker. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8] II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR
60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust
emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of
the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be
kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to
approve alternative control measures, the permittee shall keep a copy of the submitted petition
and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2). [40 CFR 63 Subpart LLL]
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II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment. ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a, and as follows: To determine continuous operating compliance, the owner/operator must record the PM CPMS output data for all periods when the process is operating and use all the PM CPMS data for calculations when the PM CPMS is not out of control. The owner/operator must demonstrate continuous compliance by using all quality-assured hourly average data collected by the PM CPMS for all operating hours to calculate the arithmetic average operating parameter in units of the operating limit on a 30-operating-day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
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II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL, are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

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

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or integrated sorbent trap monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.13 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director to give the results in the specified units of the emission limitation. [R307-165]
DAQE-AN103030032-25
Page 14

II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of Mercury emission. [R307-401-8]
DAQE-AN103030032-25
Page 15

II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
DAQE-AN103030032-25
Page 16

II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer point, is not required to conduct Method 22 visible emissions monitoring under this paragraph. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test of Appendix A-7 to 40 CFR 60 according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator may decrease the frequency of performance testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test of Appendix A-4 to 40 CFR 60 must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
DAQE-AN103030032-25
Page 17

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

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

A. Hopper at the primary crusher.

B. Material belt feeding the stacker.

C. Limestone bypass screen/ conveyor drops.

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

DAQE-AN103030032-25
Page 18

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

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

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

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

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

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

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

DAQE-AN103030032-25
Page 19

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

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

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]
II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a Proximate and Ultimate analysis of the proposed coal additive. [R307-401-8]
II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal additive. Approval is not required to change from one previously approved coal additive to another
previously approved coal additive. [R307-401-8]

II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily heat input of the kiln and precalciner. The owner/operator may increase the average quantity of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon approval by the Director in accordance with the approval process described in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel burning or process
installation not covered by New Source Performance Standards for sulfur emissions or covered elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

DAQE-AN103030032-25
Page 20

II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used. B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used. C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 % 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 contaminant content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than five minutes in any 60-minute period. B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
DAQE-AN103030032-25
Page 21

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

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-AN103030032-25
Page 22

ACRONYMS

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

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

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:
202504101000573327172
2892905420
Notice URL:
Public Notice: Ash Grove
Back
Notice Publish Date:
Wednesday, April 09, 2025
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: With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy efficiency in its kiln
system and throughout the plant to produce more low-carbon cement.
Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.
These changes result in increases in actual emissions but decreases in most potential emissions. There will be an increase in the potential
emissions of VOCs and greenhouse gases.
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 May 9, 2025, 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 April 9, 2025.
Back

DAQE-IN103030032-25

January 22, 2025

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

Dear Mr. Nelson:

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

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

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

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

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

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

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

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

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

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

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

TABLE OF CONTENTS

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

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

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

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

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

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

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

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

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

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

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

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

SUMMARY OF EMISSIONS

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

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

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
DAQE-IN103030032-25
Page 5

Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

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

SECTION I: GENERAL PROVISIONS

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

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

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

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

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

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

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

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

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

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

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

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

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

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

SECTION II: SPECIAL PROVISIONS

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

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

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

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

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

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

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

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
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II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
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II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer point, is not required to conduct Method 22 visible emissions monitoring under this paragraph. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator may decrease the frequency of performance testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
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II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

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

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

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

[R307-401-8]

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

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

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

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

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

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

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

DAQE-IN103030032-25
Page 19

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

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

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

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal additive.
Approval is not required to change from one previously approved coal additive to another
previously approved coal additive. [R307-401-8]
II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily heat input of the kiln and precalciner. The owner/operator may increase the average quantity of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon approval by the Director in accordance with the approval process described in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

DAQE-IN103030032-25
Page 20

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

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

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

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

PERMIT HISTORY

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

ACRONYMS

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

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

DAQE-NN103030032-25

April 3, 2025

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 April 9, 2025.

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

Tim Davis
Interim Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN103030032-25
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: With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase
fuel and energy efficiency in its kiln system and throughout the plant to produce
more low-carbon cement.

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

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

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 May 9, 2025, 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: April 9, 2025

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

State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Lieutenant Governor

Department of Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

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

RN103030032
January 21, 2025

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

Dear Josh Nelson,

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

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

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

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

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

Approval Signature _____________________________________________________________
(Signature & Date)

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

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

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

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

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

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

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

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

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

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

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

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

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

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

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

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

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

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

SOURCE DESCRIPTION

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

NSR Classification:
Major PSD Modification

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

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

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

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

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

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

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

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

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

SUMMARY OF EMISSIONS

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

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

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

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

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

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

Review of BACT for New/Modified Emission Units

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Step 4 - Evaluate Most Effective Controls and Document Results
PM emissions are most effectively controlled using a collection system with enclosures routed to
baghouses providing up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Ash Grove
has selected technology with the highest control efficiency, so there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 11

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

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

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

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

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

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

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

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

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

Region 8 General Permit for Concrete Batch Plants.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
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Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

1. Process Optimization Variable
2. Good Combustion Practices Variable

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

SECTION I: GENERAL PROVISIONS

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

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

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

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

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

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

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

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

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

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

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

II.B REQUIREMENTS AND LIMITATIONS

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

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

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

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

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

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

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

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

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

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

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

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

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

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

Source: Clinker Cooler Stack (F31)

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

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

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

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

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

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

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

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

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

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

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

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

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

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must record the PM
CPMS output data for all periods when the process is operating, and use all the PM CPMS
data for calculations when the PM CPMS is not out-of-control. The owner/operator must
demonstrate continuous compliance by using all quality-assured hourly average data collected
by the PM CPMS for all operating hours to calculate the arithmetic average operating
parameter in units of the operating limit on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

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

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

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

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

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

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

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

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

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

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

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

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

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

II.B.1.e.13
NEW
Calculations
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director, to give the results in the specified units of the
emission limitation. [R307-165]

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

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

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

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

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

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

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

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

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

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

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

II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer
point is not required to conduct Method 22 visible emissions monitoring under this paragraph.
The enclosures for these transfer points must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

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

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

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator may decrease the frequency of performance testing from monthly
to semi-annually for that affected source. If visible emissions are observed during any
semi-annual test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

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

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

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

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

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

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

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

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

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

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

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

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

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

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

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

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

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

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

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

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

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source shall
continuously operate all required continuous monitoring devices and shall meet minimum
frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

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

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

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

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

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

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

II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal
additive. Approval is not required to change from one previously-approved coal additive to
another previously-approved coal additive. [R307-401-8]

II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily
heat input of the kiln and precalciner. The owner/operator may increase the average quantity
of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon
approval by the Director in accordance with the approval process described in Condition
II.B.4.b. [R307-401-8]

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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PERMIT HISTORY

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

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

REVIEWER COMMENTS

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

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

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

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

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

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

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

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

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

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

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

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

[Last updated January 14, 2025]

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

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

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

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

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

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

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
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increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

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

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

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

Project Emission Calculations

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

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

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

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

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

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
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Page 43

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

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

New Emissions Sources

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Netting

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

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

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

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

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Page 45

Contemporaneous Increases

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

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

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

Could Have Been Accommodated Emissions

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
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Page 47

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

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

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

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

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

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

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

Specific changes are as follows:

1. The kiln description has been updated

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

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

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

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

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

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

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

[Last updated December 20, 2024]

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

DAQE-IN103030032-25

January 22, 2025

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

Dear Mr. Nelson:

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

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

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

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

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

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

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

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

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

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

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

TABLE OF CONTENTS

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

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

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

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

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

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

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

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

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

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

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

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

SUMMARY OF EMISSIONS

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

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

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
DAQE-IN103030032-25
Page 5

Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

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

SECTION I: GENERAL PROVISIONS

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

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
DAQE-IN103030032-25
Page 6

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
DAQE-IN103030032-25
Page 7

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

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

DAQE-IN103030032-25
Page 8

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

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

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

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
DAQE-IN103030032-25
Page 9

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

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

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

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

DAQE-IN103030032-25
Page 10

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

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

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
DAQE-IN103030032-25
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II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

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

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

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

DAQE-IN103030032-25
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II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must record the PM CPMS output data for all periods when the process is operating and use all the PM CPMS data for calculations when the PM CPMS is not out of control. The owner/operator must demonstrate continuous compliance by using all quality-assured hourly average data collected by the PM CPMS for all operating hours to calculate the arithmetic average operating parameter in units of the operating limit on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
DAQE-IN103030032-25
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II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

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

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165]
DAQE-IN103030032-25
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II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
DAQE-IN103030032-25
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II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
DAQE-IN103030032-25
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II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer point, is not required to conduct Method 22 visible emissions monitoring under this paragraph. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator may decrease the frequency of performance testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
DAQE-IN103030032-25
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II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

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

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

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

[R307-401-8]

DAQE-IN103030032-25
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II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

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

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

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

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

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

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

DAQE-IN103030032-25
Page 19

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

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

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

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal additive.
Approval is not required to change from one previously approved coal additive to another
previously approved coal additive. [R307-401-8]
II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily heat input of the kiln and precalciner. The owner/operator may increase the average quantity of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon approval by the Director in accordance with the approval process described in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

DAQE-IN103030032-25
Page 20

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

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

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

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

PERMIT HISTORY

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

ACRONYMS

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

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

DAQE-NN103030032-25

April 3, 2025

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 April 9, 2025.

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

Tim Davis
Interim Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

DAQE-NN103030032-25
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: With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase
fuel and energy efficiency in its kiln system and throughout the plant to produce
more low-carbon cement.

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

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

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 May 9, 2025, 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: April 9, 2025

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

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:
202504101000573327172
2892905420
Notice URL:
Public Notice: Ash Grove
Back
Notice Publish Date:
Wednesday, April 09, 2025
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: With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy efficiency in its kiln
system and throughout the plant to produce more low-carbon cement.
Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.
These changes result in increases in actual emissions but decreases in most potential emissions. There will be an increase in the potential
emissions of VOCs and greenhouse gases.
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 May 9, 2025, 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 April 9, 2025.
Back
Jeree Greenwood <[e-mail]>
Legal Notice to be published on April 9, 2025
Legal Notices <[e-mail]>Thu, Apr 3, 2025 at 10:46 AM
To: Jeree Greenwood <[e-mail]>
Received, thank you.
[Quoted text hidden]
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<DAQE-NN103030032-25.pdf>
4/3/25, 11:56 AM State of Utah Mail - Legal Notice to be published on April 9, 2025
https://mail.google.com/mail/u/0/?ik=b4fd0e1085&view=pt&search=all&permmsgid=msg-f:1828400687472716443&simpl=msg-f:1828400687472716443 1/1

DAQE-MN103030032-24

M E M O R A N D U M

TO: John Jenks, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler
Dave Prey, Air Quality Modeler

DATE: December 12, 2024

SUBJECT: Modeling Analysis Review for the Ash Grove Cement Company – Leamington Plant,
located in Millard County, Utah
___________________________________________________________________________________
This is a Major Modification to a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Ash Grove Cement Company (Applicant) has submitted a Notice of Intent (NOI) air permit
application for a project referred to as the Leamington Upgrade Project (LUP). The proposed
upgrade project includes the construction and installation of new pollution control equipment, new
emission sources, and modifications to existing emission sources. Emission increases associated
with the LUP constitute a major modification to a Prevention of Significant Deterioration (PSD)
source subject to PSD permitting regulations. PSD regulations require the Applicant to include and
air quality impact analysis (AQIA) of the proposed projects impact on the EPA national ambient air
quality standards (NAAQS) and air quality related values (AQRV) as part of a complete NOI.

This report prepared by the New Source Review (NSR) modeling staff contains a review of the
Applicant’s Air Quality Impact Analysis (AQIA) including the methodology, data sources,
assumptions, and modeling results for comparison with State and Federal air quality standards. The
AQIA was reviewed and referenced in this report include the:
● Notice of Intent – Ash Grove Cement Leamington Plant PSD Notice of Intent Air Permit
Application, dated November 30, 2022.

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

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

0 0
Jason Krebs

DP
DAQE-MN103030032-24
Page 2

II. APPLICABLE RULES AND ANALYSES

A Utah Air Quality Rules

The UDAQ has determined that the Applicant’s NOI is subject to the following rules for conducting an
AQIA:

R307-401 Permits: New and Modified Sources
R307-405 Permits: Major Sources Located in Attainment or Unclassified Area (PSD)
R307-406-2 Visibility – Source Review
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutant Impacts in Attainment Areas

B. Applicability

The proposed increases in emissions of PM10 and PM2.5 exceed the emission thresholds outlined in R307-
406-5 and R307-410-4. Therefore, an AQIA consistent with the requirements of R307-405-6, R307-406-
2, and R307-410-3 was submitted as part of the Applicant’s NOI. R307-410-3 establishes the U. S.
Environmental Protection Agency (US EPA) – Guideline on Air Quality Models as a formal basis for
defining the scope of the analysis, as well as the model’s construction. The results of the AQIA are
required to demonstrate the proposed project’s impact on state and federal air quality standards,
acceptable levels of impact, and action triggering thresholds referenced or listed in R307-401-6(2), R307-
401-6(3), R307-403-3(1), R307-403-5(1)(a), R307-405-4(1), R307-405-6. Annual emissions for criteria
pollutants requiring an AQIA are listed in Table 1.

Table 1: Ash Grove Leamington Proposed Net Emissions Increase

Criteria
Pollutants
Net Emission
Increase (TPY)
AQIA Trigger
Level (TPY) AQIA Required?
PM10 126.6 15 Yes
PM2.5 70.3 10 Yes

C. Required Analyses

R307-405 requires the Applicant to perform a pre-construction modeling analysis for all pollutants
emitted in a significant quantity. The purpose of the analysis is to determine if the extent of the source’s
impact is significant enough to warrant an on-site measurement of the ambient background concentration
levels. This data is included in the NAAQS analysis to represent the quality of the air prior to the
construction of the proposed project. The Applicant included a pre-construction modeling analysis for
PM10 and PM2.5 as part of the NOI. The pre-construction modeling analysis was also used to determine if
the proposed emissions would result in a significant impact to the environment, thereby triggering the
requirement for a cumulative analysis of the proposed project and other nearby existing sources.

R307-401-8 requires the Division to determine that the proposed project will comply with the NAAQS
prior to the issuance of an Approval Order (AO). R307-405(7) requires the Applicant to perform a
DAQE-MN103030032-24
Page 3
NAAQS analysis for all pollutants emitted in a significant quantity. The analysis is to include all
emissions at the proposed site under normal operating conditions using maximum anticipated short-term
release and annual release rates. Consistent with UDAQ policy, a cumulative analysis to include the
ambient background concentration and any contribution from other nearby sources is not required if the
proposed project’s impact does not exceed the PSD Class II Significant Impact Level (SIL).

R307-401-8 also requires the Division to determine that the proposed project will comply with PSD
increments prior to the issuance of an AO. Under R307-405(6), the Applicant is required to perform a
PSD Class I and II increment consumption analysis for all pollutants emitted in significant quantities.
The purpose of this analysis is to quantify any degradation in air quality since the major source baseline
date. The analysis is to include all increment consuming emissions at the proposed site under normal
operating conditions using maximum anticipated short-term and annual release rates. A cumulative
analysis to include contributions associated with growth and other increment consuming sources is not
required if the proposed project’s impact does not exceed the PSD Class I or II SIL.

R307-410-5 requires the Applicant to perform a HAPs analysis for any pollutant emitted above a
pollutant specific emission threshold value. This analysis is to include all emissions of the pollutants
resulting from the proposed modification under normal operating conditions using maximum anticipated
one-hour release rates. The Applicant did not trigger modeling for HAPs.

R307-406-2 requires the Applicant to perform a plume blight analysis. A plume blight analysis is required
to determine if plumes emanating from the proposed project would be visible inside any Class I area
within 50 kilometers of the source. The plume blight analysis is to include all emissions of NO2, SO4, and
PM10.

Under R307-405-16, an AQRV analysis is performed which evaluates regional haze and acid deposition
impacts at each of the Class I areas within 300 kilometers of the source. A regional haze analysis is
required to determine if the plumes would reduce the visual range of an observer inside the Class I area.
The regional haze analysis is to include all emissions of SO2, NOX and PM10. The deposition analysis
examines impacts from sulfur and nitrogen compounds at the Class I areas, and is based on all emissions
of SO2 and NOX. The Federal Land Managers use the Q/D approach to determine whether a PSD project
should provide detailed AQRV impact analyses, where: Q/D= [ H2SO4 + SO2 + NOx + PM10 emissions
(tpy)]/ distance (km). If Q/D is less than 10, no AQRV analysis is required.

R307-405 requires the Applicant to perform a soils and vegetation analysis. The analysis should quantify
the effects of pollutants on soils and vegetation near the highest impact location and in areas where
sensitive plant species may be impacted.

III. ON-SITE PRE-CONSTRUCTION MONITORING

A. Meteorological Data

Consistent with the US EPA - Meteorological Monitoring Guidance for Regulatory Modeling
Applications, one year of on-site data was collected using a 50-meter tower during the period October 1,
2021 through September 30, 2022. Parameters collected on-site included wind speed and direction,
temperature, delta-T, and solar radiation.

DAQE-MN103030032-24
Page 4

B. Ambient Pollutant Data

A preliminary analysis was conducted to determine the necessity for pre-construction ambient pollutant
monitoring. The results indicate that predicted concentrations of PM10 and PM2.5 exceed the monitoring
trigger level listing in the rule. A continuous PM10/PM2.5 monitor with filter based samplers was
installed near the northern edge of the Applicants property boundary, and collected particulate matter
from October 1, 2021 through September 30, 2022.

IV. MODEL SELECTION

The EPA-AERMOD dispersion modeling system is the preferred model specified in the US EPA –
Guideline on Air Quality Models to predict air pollutant concentrations in the near field (within 50
kilometers of the source). The US EPA - CALPUFF - Version 5.8 model is the preferred model to predict
concentrations in the far field (long range transport conditions beyond 50 kilometers from the source).

V. MODELING INPUTS AND ASSUMPTIONS

A. Technical Options

The regulatory default options were selected in AERMOD by the Applicant to quantify all concentrations.

B. Urban or Rural Area Designation

A review of the appropriate 7.5-minute quadrangles determined that the area should be classified as
“rural” for air modeling purposes.

C. Topography/Terrain

The Plant is at an elevation of 4,950 feet with nearby terrain features that have an effect on concentration
predictions.

a. Zone: 12
b. Location: UTM (NAD83): 397000 meters East, 4379850 meters North

D. Ambient Air

It was determined that the Plant boundary used in the AQIA meets the State’s definition of an ambient air
boundary.

E. Receptor and Terrain Elevations

The modeling domain has simple and complex terrain features in the near field. Therefore, receptor
points representing actual terrain elevations from the area were used in the analysis.

The far-field modeling domain consisted of a rectangular region covering all Class I areas within Utah,
and extending 50 kilometers beyond this area so that the model can account for re-circulation of the
plume.

DAQE-MN103030032-24
Page 5

F. Emission Rates and Release Parameters

The emission estimates and source parameters used in AERMOD for all proposed emission sources at the
site are presented in the NOI.

Speciated emission rates and source parameters used in the CALPUFF modeling are presented in Table 2.

Table 2: CALPUFF Emission Rates

Source
LCC Coordinates Modeled Emission Rates
Easting Northing SO2 SO4 NOX HNO3 NO3 SOA PMC SOIL EC
(m) (m) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr)
317.BF3 -1289410 -3738 52.81 5.03 307.58 0.00 0.00 5.03 2.60 2.90 0.11
419.BF1 -1289314 -3631 0.00 0.00 0.00 0.00 0.00 0.55 1.51 1.61 0.06
41B.BF2 -1289389 -3663 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.68 0.00
N1_FM2 -1289526 -3414 0.00 0.00 0.00 0.00 0.00 0.00 1.65 3.95 0.00
414.BF1N -1289407 -3683 0.00 0.00 0.00 0.00 0.00 0.00 0.10 0.25 0.00
2FM_HTR -1289528 -3415 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.08 0.00
514.BF1 -1289451 -3675 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.70 0.00
COMBO -1289424 -3668 0.00 0.00 0.00 0.00 0.00 0.00 1.37 5.72 0.00
FM2_CMB -1289454 -3439 0.00 0.00 0.00 0.00 0.00 0.00 0.50 1.21 0.00

Total Lb/hr 52.81 5.03 307.58 0.00 0.00 5.58 8.32 17.10 0.17
Hrs/Yr 8760 8760 8760 8760 8760 8760 8760 8760 8760
Ton/yr 231.3 22.0 1347.2 0.0 0.0 24.4 36.4 74.9 0.8

Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
317.BF3 POINT 4902.8 41.2 135.0 488 10.10 3.35
419.BF1 POINT 4891.2 18.3 60.0 388 6.36 2.90
41B.BF2 POINT 4895.2 68.6 224.9 294 17.83 0.74
N1_FM2 POINT 4832.0 49.7 163.0 363 40.08 1.40
414.BF1N POINT 4896.1 76.8 251.9 353 9.91 0.70
2FM_HTR POINT 4832.0 49.7 163.0 363 40.08 1.40
514.BF1 POINT 4889.5 39.6 130.0 294 11.86 0.91
COMBO POINT 4904.2 13.3 43.7 276 9.76 0.32
DAQE-MN103030032-24
Page 6
FM2_CMB POINT 4832.0 30.6 100.3 294 11.40 0.37

G. Building Downwash

The Applicant used the US EPA Building Profile Input Program (BPIP) to determine Good Engineering
Practice (GEP) stack heights and cross-sectional building dimensions for input into the model.

H. Ambient Background Concentrations

Millard County is in attainment for all criteria pollutants. The NAAQS analyses for PM2.5 and PM10 used
monitoring data collected on site during the pre-construction monitoring analysis. The background values
used in the NAAQS analysis are presented in Table 3.

Table 3: Background Concentrations

Pollutant Averaging
Period
Background
Concentration
(μg/m3)
PM10 24-hour 65.4
PM2.5 24-hour 10.2
Annual 4.2

I. Meteorological Data Processing

For the AERMOD model, on-site horizontal and vertical wind speed, direction, solar radiation and,
temperature data was combined with National Weather Service (NWS) upper air data collected at the Salt
Lake City International Airport (SLCIA) for the same period using the US EPA AERMET processing
system.

Meteorological data used for the CALPUFF modeling analysis consisted of 3 years (2018-2020) of data
developed by the Forest Service. The grid was 708 km (east-west) by 492 km (north-south) with a
resolution of 12 kilometers.

VI. RESULTS AND CONCLUSIONS

The Applicant performed a series of analyses to estimate the impact from the proposed project. Modeling
results and conclusions from the review of the analyses are outlined in detail below.

A. Pre-Construction Monitoring and Significant Impact Modeling

The Applicant performed a preliminary criteria pollutant analysis of the proposed modification. This
analysis indicated that increases in concentration levels of PM2.5 and PM10 were greater than the Class II
SIL, and therefore, a cumulative analysis for these pollutants was required.

DAQE-MN103030032-24
Page 7

B. NAAQS Analysis

The Applicant performed a modeling analysis to determine if the combined impact from the proposed
source, other industrial sources operating in the area, and ambient background would comply with the
NAAQS. The NAAQS analysis was reviewed by the Division and determined to be consistent with the
requirements of R307-410-3. Table 4 provides a comparison of the Applicant’s predicted air quality
concentrations and the NAAQS.

Table 4: Model Predicted NAAQS Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-hour 28.3 5 65.4 0 93.7 150 62.5%
PM2.5 24-hour 9.6 1.2 10.2 0 19.8 35 56.6%
Annual 4.4 0.3 4.2 0 8.6 9 95.6%
* Note: Only included other sources and background if source impact was above Class II SIL

C. PSD Class II Increments

The Applicant performed an analysis to determine if the impact from the proposed source would comply
with PSD Class II increments. The analysis was reviewed by the Division and determined to be
consistent with the requirements of R307-410-3. Table 5 provides a comparison of the predicted
concentrations and the PSD Class II increment.

Table 5: Model Predicted PSD Class II Increment Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Nearby
Sources*
Total Increment Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
PM10 Annual 8.1 1 0 8.1 25 32.4%
24-hour 28.3 5 0 28.3 30 94.3%
PM2.5 24-hour 6.1 1.2 0 6.1 9 67.8%
Annual 2.4 0.3 0 2.4 4 60.0%

D. Hazardous Air Pollutants

DAQE-MN103030032-24
Page 8
The Applicant performed an analysis to determine if HAP modeling is required. The analysis was
reviewed by the Division and determined to be consistent with the requirements of R307-410-3. The
analysis indicated that HAP modeling was not triggered by this modification, and therefore no HAP
modeling was performed.

E. PSD Class I Increment Consumption Analysis

The Applicant performed a CALPUFF analysis to determine if the impact from the proposed source along
with other increment consuming sources would comply with federal PSD Class I increments. The
analysis was reviewed by the Division and determined to be consistent with the requirements of R307-
410-3. The results for all Class I areas within 300 kilometers are provided in Table 6.

Table 6: Model Predicted PSD Class I Increment Concentrations

Air Period Prediction
Class I
Significant
Impact
Level
Other
Sources* Total Increment Percent
Pollutant (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
Capitol Reef
NO2 Annual 0.0018 0.1 2.5
SO2
3-Hour 0.0494 1 25
24-
Hour 0.0150 0.2 5
Annual 0.0008 0.1 2
PM2.5
24-
Hour 0.0430 0.27 2
Annual 0.0021 0.05 1
PM10
24-
Hour 0.0444 0.3 8
Annual 0.0021 0.2 4
Arches
NO2 Annual 0.0008 0.1 2.5
SO2
3-Hour 0.0408 1 25
24-
Hour 0.0102 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0522 0.27 2
Annual 0.0018 0.05 1
DAQE-MN103030032-24
Page 9
PM10
24-
Hour 0.0531 0.3 8
Annual 0.0019 0.2 4
Canyonlands
NO2 Annual 0.0010 0.1 2.5
SO2
3-Hour 0.0354 1 25
24-
Hour 0.0100 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0577 0.27 2
Annual 0.0019 0.05 1
PM10
24-
Hour 0.0591 0.3 8
Annual 0.0020 0.2 4
Bryce
NO2 Annual 0.0006 0.1 2.5
SO2
3-Hour 0.0369 1 25
24-
Hour 0.0082 0.2 5
Annual 0.0003 0.1 2
PM2.5
24-
Hour 0.0189 0.27 2
Annual 0.0010 0.05 1
PM10
24-
Hour 0.0194 0.3 8
Annual 0.0010 0.2 4
Zion
NO2 Annual 0.0011 0.1 2.5
SO2
3-Hour 0.0293 1 25
24-
Hour 0.0105 0.2 5
Annual 0.0005 0.1 2
PM2.5
24-
Hour 0.0266 0.27 2
Annual 0.0011 0.05 1
PM10 24-
Hour 0.0271 0.3 8
DAQE-MN103030032-24
Page 10
Annual 0.0012 0.2 4
* Note: Only included other increment consuming sources if source impact was above Class I SIL

Since the proposed project’s model predicted impacts at the Class I areas were less than the PSD Class I
significance levels, a cumulative analysis was not warranted.

DAQE-MN103030032-24
Page 11
F. Visibility – Plume Blight
Since the Class I areas are greater than 50 kilometers from the source, a plume blight analysis using
VISCREEN was not required.

G. Visibility – Regional Haze

The results of the Q/D analysis for the emissions increase was less than 10 but the FLMs wanted the
entire source included in the Q term. The results of including the total emissions resulted in a Q/D >10,
so an AQRV analysis was performed for visibility and acid deposition. The results shown in Table 7
indicate that the impacts are below the 0.5 Deciview (DV) threshold established by the National Park
Service, indicating that no further analysis is required.

Table 7: CALPUFF Visibility Results

Class I Area Year Maximum
Delta DV
98th
Percentile
change in
DV
#
Days
#
Days Threshold
(DV)
Below
Threshold
> 1 > 0.5
2018 0.248 0.06 0 0 0.5 Yes
Arches 2019 0.291 0.054 0 0 0.5 Yes
2020 0.216 0.106 0 0 0.5 Yes
2018 0.223 0.081 0 0 0.5 Yes
Canyonlands 2019 0.312 0.068 0 0 0.5 Yes
2020 0.186 0.085 0 0 0.5 Yes
2018 0.059 0.03 0 0 0.5 Yes
Bryce 2019 0.081 0.045 0 0 0.5 Yes
2020 0.071 0.03 0 0 0.5 Yes
2018 0.183 0.074 0 0 0.5 Yes
Capital Reef 2019 0.196 0.092 0 0 0.5 Yes
2020 0.126 0.078 0 0 0.5 Yes
2018 0.069 0.04 0 0 0.5 Yes
Zion 2019 0.123 0.039 0 0 0.5 Yes
2020 0.102 0.057 0 0 0.5 Yes

DAQE-MN103030032-24
Page 12

H. Acid Deposition

The Applicant performed a deposition analysis on impacts within the Class I areas. Results of the
analysis indicate that the impacts are below the deposition threshold (DAT) established by the National
Park Service, indicating that no further analysis is required

Table 8: CALPUFF Deposition Results for Highest Year

Class I Area
Total
Nitrate
Deposition
Total
Sulfate
Deposition
Deposition
Analysis
Threshold
(kg/ha/yr) (kg/ha/yr) (kg/ha/yr)
Canyonlands 0.0006 0.0003
0.005
Zion 0.0004 0.0002
Arches 0.0006 0.0003
Bryce 0.0006 0.0002
Capitol Reef 0.0011 0.0005

I. Soils and Vegetation Analysis

The Applicant performed an analysis to determine the extent of impacts from the proposed source on soil
and vegetation. Results of the analysis are presented in a supplemental document titled “Soil and
Vegetation Impact Analysis for the Leamington, UT Facility, June 29, 2023”. The analysis indicated that
predicted concentrations compared against the secondary NAAQS at several sensitive receptors would not
result in an adverse impact on soils and vegetation in the vicinity of the proposed project.

DP/JK:jg

State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Lieutenant Governor

Department of Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

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

RN103030032
January 21, 2025

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

Dear Josh Nelson,

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

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

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

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

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

Approval Signature _____________________________________________________________
(Signature & Date)

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

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

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

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

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

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

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

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

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

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

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

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

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

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

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

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

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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SOURCE DESCRIPTION

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

NSR Classification:
Major PSD Modification

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

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

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

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

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

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

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

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SUMMARY OF EMISSIONS

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

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

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

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

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Review of BACT for New/Modified Emission Units

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Region 8 General Permit for Concrete Batch Plants.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
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Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

1. Process Optimization Variable
2. Good Combustion Practices Variable

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

SECTION I: GENERAL PROVISIONS

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

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

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

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

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

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

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

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

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

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

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

II.B REQUIREMENTS AND LIMITATIONS

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

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

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

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

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

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

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

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

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

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

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

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

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

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

Source: Clinker Cooler Stack (F31)

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

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

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

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

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

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

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

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

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

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

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

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

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

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must record the PM
CPMS output data for all periods when the process is operating, and use all the PM CPMS
data for calculations when the PM CPMS is not out-of-control. The owner/operator must
demonstrate continuous compliance by using all quality-assured hourly average data collected
by the PM CPMS for all operating hours to calculate the arithmetic average operating
parameter in units of the operating limit on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

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

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

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

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

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

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

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

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

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

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

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

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

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

II.B.1.e.13
NEW
Calculations
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director, to give the results in the specified units of the
emission limitation. [R307-165]

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

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

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

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

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

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

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

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

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

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

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

II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer
point is not required to conduct Method 22 visible emissions monitoring under this paragraph.
The enclosures for these transfer points must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

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

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

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator may decrease the frequency of performance testing from monthly
to semi-annually for that affected source. If visible emissions are observed during any
semi-annual test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

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

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

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

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

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

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

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

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

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

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

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

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

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

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

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

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

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

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

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

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

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source shall
continuously operate all required continuous monitoring devices and shall meet minimum
frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

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

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

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

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

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

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

II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal
additive. Approval is not required to change from one previously-approved coal additive to
another previously-approved coal additive. [R307-401-8]

II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily
heat input of the kiln and precalciner. The owner/operator may increase the average quantity
of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon
approval by the Director in accordance with the approval process described in Condition
II.B.4.b. [R307-401-8]

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

II.B.4.c.1
NEW
Certification of fuels shall be either by the owner/operator's own testing or test reports from
the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be
available onsite. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials, UAC R307-203-1 (4)

A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be
used.

B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be
used.

C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85 are to be used. [R307-203]

II.B.4.d
NEW
The concentration/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight
3) Cadmium 2 ppm by weight
4) Chromium. 10 ppm by weight
5) Lead 100 ppm by weight
6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be
tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the burn tank and burned. [R307-401-8]

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II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned
in the rotary kiln:

A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than
five minutes in any 60-minute period

B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes
in any 60-minute period. [R307-401-8]

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the
Director. The calibration procedure and frequency shall be according to manufacturer's
specifications. Use of factory-calibrated thermocouples for temperature measurement is
approved. However, any other method of temperature measurement must be approved by the
Director prior to use. The monitoring equipment for both temperature and oxygen content
shall be located such that an inspector can at any time safely read the output. [R307-401-8]

II.B.5
NEW
Emergency Engine Requirements
II.B.5.a
NEW
The owner/operator shall only operate the emergency engines for testing and maintenance
purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency
operation. [R307-401-8]

II.B.5.b
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each emergency engine. [R307-401-8]

II.B.5.b.1
NEW
The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.5.b.2
NEW
To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN103030035-24 dated November 27, 2024
Is Derived From Source Submitted NOI dated November 30, 2022
Incorporates Additional Information Received dated April 26, 2023
Incorporates Additional Information Received dated September 26, 2023
Incorporates Additional Information Received dated July 23, 2024
Incorporates Additional Information Received dated October 25, 2024
Incorporates Additional Information Received dated November 25, 2024

REVIEWER COMMENTS

1. Comment regarding applicability of federal requirements:
New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable
by the best demonstrated technology as specified in the applicable provisions. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.

40 CFR 60, Subpart A (General Provisions)
All affected facilities subject to a source-specific NSPS are subject to the general provisions of
NSPS, Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires
initial notification, performance testing, recordkeeping, and monitoring, provides reference methods,
and mandates general control device requirements for all other subparts.

40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of
performance for affected facilities in Portland Cement Plants which have been constructed or
modified after August 17, 1971.

40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart
F: Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and
unloading systems. The Leamington coal mill is an in-line coal mill and considered an integral part
of the Leamington kiln. In-line coal mills are not subject to NSPS Subpart Y. Therefore, the coal mill
is addressed under NSPS Subpart F as part of the kiln system. The coal silos and conveying system
are subject to NSPS Subpart Y.

Ash Grove's proposed changes to the kiln system must be evaluated as to whether they trigger new
NSPS Subpart F obligations based on whether the proposed project is either a modification or a
reconstruction, as those terms are defined in NSPS Subpart A.

Ash Grove's proposed changes to the kiln system do not meet the definition of a reconstruction, nor
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Page 40

do they meet the definition of a modification for NOx. However, the changes meet the definition of a
modification for PM and SO2. Therefore, Ash Grove will comply with all relevant emission
standards; testing requirements; monitoring, recordkeeping, and reporting obligations that apply to
the Leamington kiln system as an existing source under NSPS Subpart F. Under NSPS Subpart A
and F, the clinker cooler is considered a reconstructed unit. Thus new limits will apply to this unit.
[Last updated January 14, 2025]

2. Comment regarding applicability of federal requirements cont.:
NSPS Subpart Y - Standards of Performance for Coal Preparation and Processing Plants
This subpart provides standards of performance for affected facilities in coal preparation and
processing plants that process more than 200 tons of coal per day.

The Leamington plant's coal silo and coal conveying system are existing affected facilities under
NSPS Subpart Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses
controlling affected facilities subject to match the limit in NSPS Subpart Y from 0.016 gr/dscf to
0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade Project. Since there are no proposed
modifications or reconstruction to the coal silo and coal conveying system, nothing about the
proposed upgrade project affects the existing applicability of NSPS Subpart Y.

NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
This subpart provides standards of performance for affected facilities located at fixed or portable
nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August
31, 1983, with additional requirements applicable to sources constructed on or after April 22, 2008.

As the crushing and screening system is controlled by baghouses and an increase in PM10 actual
emissions on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS.
Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the
Leamington Plant Upgrade Project.

Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1),
60.676(f), and 60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO
monitoring and recordkeeping requirements.

[Last updated January 14, 2025]

3. Comment regarding applicability of federal requirements cont.:
National Emission Standards for Hazardous Pollutants (NESHAPs)
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or
greater than 10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as
specified by each subpart. NESHAP apply to sources in specifically regulated industrial source
classifications (CAA Section 112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities
not regulated as a specific industrial source type. The Ash Grove Leamington Plant is a major source
of HAPs and thus is subject to certain NESHAP standards.

Subpart A - General Provisions
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All affected sources are subject to the general provisions of Subpart A unless otherwise specified by
the source-specific NESHAP. Subpart A generally requires initial notification and performance
testing, recordkeeping, monitoring, provides reference methods, and mandates general control device
requirements for all other subparts as applicable.

Subpart LLL - Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry
This subpart establishes process/source specific emission limits for PM, VOC (expressed as total
hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and
gaseous HAP compounds by limiting PM and THC emissions because portions of such emissions
are USEPA-listed HAPs. Subpart LLL requires compliance with applicable emissions limits on and
after the initial startup of cement production. To further reduce emissions, Subpart LLL also
establishes operational requirements for the use of cement kiln dust (CKD), fly ash, fuel and control
equipment. Subpart LLL also specifies process/source specific emissions testing, monitoring,
recordkeeping, reporting, and compliance demonstration requirements. The compliance requirements
for the site are detailed in Approval Order Condition II.B.1.b. Ash Grove will continue to comply
with the requirements of Subpart LLL to demonstrate compliance. This cement kiln will remain an
existing source with respect to the kiln emission standards in Subpart LLL as this project does not
trigger the definition of a new source in Subpart LLL. New source standards apply only to affected
sources that were constructed or reconstructed after May 6, 2009.
[Last updated December 20, 2024]

4. Comment regarding PSD applicability analysis:
Ash Grove is proposing to increase the throughput of limestone from the quarry to supply the New
Finish Mill to increase the amount of low-carbon cement from the Leamington Plant. Additionally,
along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
modified, and the clinker cooler will be reconstructed. These changes are anticipated to result in an
increase in clinker production. Emission calculations for this project have been completed assuming
an increase in clinker production capacity while utilizing current fuel types. This will result in an
increase in the throughput of fuel.

The Leamington Plant is considered an existing major source under PSD based on potential
emissions of PM10, PM2.5, NOx, CO, SO2, and CO2e. If a major source undergoes a physical or
operational change, the facility must determine whether the project will be considered a major
modification. Per 40 CFR 52.21(b)(2)(i), in order to be a major modification, the project must result
in a significant emissions increase, and a significant net emissions increase.

As defined at 40 CFR 52.21(b)(40): Significant emissions increase means, for a regulated NSR
pollutant, an increase in emissions that is significant for that pollutant. Significant is further defined
to mean, in reference to a net emissions increase or the potential of a source to emit any of the
following pollutants, a rate of emissions that would equal or exceed the values outlined in 40 CFR
52.21(b)(23). If the increase in emissions from the project are not significant, a major modification
has not occurred.

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 42

increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

For all pollutants, the project emissions increase was calculated as the difference between the
projected actual emissions (PAE) after the proposed project and the actual emissions prior to the
project (baseline actual emissions or BAE).

Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
". . . projected actual emissions means the maximum annual rate, in tons per year, at which an
existing emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years
(12-month period) following the date the unit resumes regular operation after the project, or in any
one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit of that regulated NSR pollutant and full utilization of the unit would
result in a significant emissions increase or a significant net emissions increase at the major
stationary source." [Last updated January 14, 2025]

5. Comment regarding PSD applicability analysis cont.:
Ash Grove estimates that the projected actual production capacity following the project will be
1,155,000 tons of clinker per year and 1,341,266 tons of limestone per year. These capacities were
used to calculate projected actual emissions from the project using representative emission factors.
Additionally, to estimate emissions from material transfer baghouses, the actual flow rates and actual
projected hours were used as a basis for projected actual emissions.

Project Emission Calculations

Project emission increases from the kiln and coal mill systems are calculated for all criteria
pollutants based on emission factors that are derived from stack testing, CEMS data, or emission
factors (i.e., VOCs and Lead), and the associated projected incremental clinker increase.

NOx emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain
hourly capacity to emit and annual potential to emit at current levels. The kiln's NOx emissions rate
will not change as a result of the physical modifications proposed by the project.

Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission
factor and multiplied by the incremental increase in clinker production. The emission factor was
selected based on the average of the 24-month consecutive month emissions for 2020 and 2021. The
CO emissions will increase.

The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing
conducted at the plant. The SO2 emissions will increase.

VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production. VOC emissions will increase.

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 43

can be found in the original NOI and subsequent addendums submitted to UDAQ.

As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from
the proposed project, each increase of emissions from both existing and new sources shall be
summed together and compared to the PSD permitting thresholds. The increase of emissions is the
"positive" difference between the projected actual emissions and baseline actual emissions (projected
minus baseline).

New Emissions Sources

The actual to projected actuals calculation is not available to new emission units. For new emission
units, the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected
emissions are based on the new sources' potentials to emit. (40 CFR § 52.21(a)(2)(iv)(f)).

The new equipment proposed includes the New Finish Mill, a new rail and truck loading/loadout,
one (1) new clinker reclaim loading hopper with a dust collector and one (1) existing clinker reclaim
hopper with a dust collector, a new Clinker Cooler to replace the existing one, and a new kiln feed
alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions:

The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;

The finish mill heater was calculated based on its maximum firing capacity and flow rates; and

The fugitive emissions were calculated based on the projected annual throughput of the New Finish
Mill, the rail loadout, and clinker production. [Last updated January 14, 2025]

6. Comment regarding PSD applicability analysis cont.:
Existing Emission Sources

For the existing sources, the projected actual emissions are the maximum annual rates in tons per
year projected to occur during the next five (5) to ten (10) years if the existing sources' design
capacities increase. Ash Grove Leamington projected the actual emissions for the next five (5) years
based on the new kiln system producing an annual average of 3,250 tons of clinker per day.

Baseline actual emissions (BAE) are defined at 40 CFR 52.21(b)(48)(ii) as:

". . . baseline actual emissions means the average rate, in tons per year, at which the emissions unit
actually emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the 10-year period immediately preceding either the date the owner or operator
begins actual construction of the project, or the date a complete permit application is received by the
Administrator."

Ash Grove has selected to use the years 2020 and 2021 for each pollutant as the representative
baseline years.

In its NOI, Ash Grove calculated the emission increase from the project as being divided into two
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 44

phases. Phased construction projects are discussed in two sections of the federal PSD regulations -
40 CFR 52.21(j)(4) and 40 CFr 52.21(r)(2). UDAQ is not processing this project as a phased
construction project, nor did Ash Grove request such a determination. Therefore, Ash Grove
provided a summary table outlining the final change in emissions from this project:

Projected Actual Increase Compared to PSD threshold (tons per year)
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2e
BAE 76.64 39.64 1,187 6.87 3,315 55.47 641,385
PAE 203.15 113.47 1,226 45.87 3,414 72.07 1,067,984

Change in Emissions 126.51 73.83 39.00 39.00 99.00 16.59 426,598

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes

If the emissions increase is greater than the PSD significance threshold for a particular pollutant, Ash
Grove has the option of conducting a PSD review or continuing through the rest of the steps to
determine if it can "net" out of a PSD review. If the project increase is less than the PSD significant
threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant.

The change in emissions from the project exceeds the significant emission threshold for three
pollutants: PM10, PM2.5 and CO2e. Ash Grove elected to attempt to net out of a PSD major
modification for the remainder of the criteria pollutants.

Netting

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant
Upgrade Project and ends on the date the upgrade begins operation. Only PM10, PM2.5, CO2e are in
excess of SERs and therefore considered in the netting analysis.

Ash Grove estimated that the commencement of construction will be in December 2024. Therefore,
the contemporaneous period for this project is December 2019 through a projected date the project
upgrade begins operation. [Last updated January 21, 2025]

7. Comment regarding PSD applicability analysis cont.:
Contemporaneous Decreases

Ash Grove replaced an existing kiln emergency drive engine with a USEPA Tier 4 diesel engine in
2022. Concurrently, Ash Grove requested an increase in the capacity of 1L Cement. Additionally,
Ash Grove submitted a minor modification NOI air permit application on June 12, 2023, which
proposes replacing the shipping generator during the contemporaneous period. The kiln emergency
drive engine and shipping generator are both higher EPA tier ratings therefore result in decreases for
PM10 and PM2.5. These changes were approved in AO DAQE-AN103030033-24 issued March 21,
2024.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 45

Contemporaneous Increases

As stated above, the existing kiln emergency drive engine and shipping generator were permitted and
replaced in 2024. This resulted in an increase in emissions of CO2e.

The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout
in an effort to improve truck traffic at the loadout. The modification to add these dust collectors to
the loadout was included in DAQE-AN103030029-19. The baghouses are three (3) levels up in the
silos' enclosed space (approximately 40 feet). Both dust collectors vent directly into the interior of
the silo structure and are not vented into the atmosphere. Ash Grove requests to remove these
baghouses from its existing permitted emissions inventory. Therefore, these emissions have been
documented in the netting analysis as zero emissions.

Also included in DAQE-AN103030033-24 were two new natural gas-fired emergency generators
and increases in stockpiles, material handling and road emissions.

Could Have Been Accommodated Emissions

In calculating project emissions increase, USEPA allows the exclusion of existing
production/emissions rates that could have been accommodated during the baseline period. These
"could have been accommodated" emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as
follows:

". . . Shall exclude, in calculating any increase in emissions that results from the particular project,
that portion of the unit's emissions following the project that an existing unit could have
accommodated during the consecutive 24-month period used to establish the baseline actual
emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project,
including any increased utilization due to product demand growth;"

Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the
exclusion of existing production and emissions rates that could have been accommodated during the
baseline period, it has elected not to use this exclusion at this time. Therefore, calculation of the
"could have been" accommodated emissions have not been included in this application's
applicability analysis.

The increase from the project is added to the contemporaneous decreases and contemporaneous
increases. The resulting calculation is then compared to the PSD significance threshold to determine
if a significant net emissions increase has occurred. [Last updated January 14, 2025]

8. Comment regarding PSD applicability analysis cont.:
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2 e
Contemporaneous Inc. 1.61 0.45 0.41 0 0.27 0.07 51.74

Contemporaneous Dec. -1.54 -3.97 -0.48 -0.02 -0.27 -0.09 0

Change in Emissions 125.02 69.21 38.93 38.98 99.00 16.58 426,650

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 46

The results of the netting analysis conclude that both a significant emissions increase and a
significant net emissions increase in both particulates (PM10 and PM2.5) and CO2e will occur from
this project. Thus, the project must be reviewed as a PSD major modification. [Last updated January
14, 2025]

9. Comment regarding emission calculations:
This engineering review includes updated potential emission totals for both criteria and HAP
emissions. The potential-to-emit (PTE) values were calculated using updated values for clinker
produced and raw material inputs. BACT emission factors and limitations were used where
appropriate. Certain emission totals (NOx, SO2 and CO) were set based on avoiding a significant
increase in emissions. Specifically, the projected actual increase was set at just under the baseline
actual emissions + the significance level. As these emissions are monitored by CEM, UDAQ agrees
with this approach. Please see the netting analysis for further details on calculation of projected
actual increase. The NOx hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project.

CO2e emissions were calculated using the GHG emission factor calculated from 40 CFR Part 98
Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in Subpart A Table
A-1.

To calculate the PTE tons per year, the maximum hours (i.e., 8760) per year and the source's
emissions rates were multiplied with the throughputs. The potential throughputs have been updated
at UDAQ's request so that PAE is equal to PTE and represents the equipment's maximum design
potential.

Additional emission calculations based on source testing and monitoring, and EPA's compilation of
air emission factors AP-42. [Last updated January 14, 2025]

10. Comment regarding requirements for PSD review:
In addition to the permitting requirements of R307-401-5 through R307-401-8, there are additional
requirements under PSD that must be addressed:

1. Calculation of ambient air increments (40 CFR 52.12(c)), ambient air ceilings ((40 CFR 52.12(d)),
source impact analysis (40 CFR 52.12(k)), air quality models (40 CFR 52.12(l)) - these items are
addressed in the modeling memo DAQE-MN103030032-24.

2. Stack heights (40 CFR 52.12(h)) - Ash Grove's stack heights have been reviewed with respect to
good engineering practice and operate in a vertical unrestricted manner.

3. Control technology review (40 CFR 52.12(j)) - this is addressed in the BACT analysis section of
this review document.

4. Air quality analysis: preapplication analysis (40 CFR 52.12(m)) - this is covered in the PSD
applicability and netting analysis sections of this review document, ambient monitoring and
background data collection is also included in the modeling memo DAQE-MN103030032-24.

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 47

grain loading limit included in II.B.1.j.1 represents the required post-construction monitoring.
6. Source information (40 CFR 52.12(n)) - this is addressed under the requirements of R307-401-5
and was submitted by Ash Grove as part of the NOI package.

7. Additional impact analysis (40 CFR 52.12(o)) - these requirements cover soils, vegetation, growth
and visibility concerns. They are discussed in the modeling memo DAQE-MN103030032-24.

8. Federal land manager review (40 CFR 52.12(p)) - UDAQ provided initial notification to all
federal land managers upon receipt of the original NOI package. The draft permit and engineering
review will also be provided to the federal land managers 60-days prior to initiation of public
comment for their further review.

9. Public participation (40 CFR 52.12(q)) - this project will have a 30-day public comment period.

10. Source obligation (40 CFR 52.12(r)) - this requirement discusses source compliance with other
parts of the CAA, which is addressed within UDAQ's permitting rules in R307.
[Last updated January 14, 2025]

11. Comment regarding changes in equipment list:
The equipment list is being updated for clarity as well as adding new pieces of equipment. The
following changes are taking place:

The naming scheme is being updated to remove the numerical code from the unit designation. This
code generally referred to the associated control device and not to the emitting unit itself. This can
cause confusion especially when the same code was applied to multiple pieces of equipment.
Instead, the control devices (typically baghouse dust collectors) will be identified in the description
along with the appropriate numerical code.

Specific changes are as follows:

1. The kiln description has been updated

2. Clinker Cooler description has been updated to include a larger pulse jet baghouse.

3. The clinker storage silos, east and west clinker belts, clinker belt transfer and clinker tunnel have
been consolidated to avoid confusion

4. The north and south cement loadout exhausts now vent internally into the cement storage silos

5. The dust shuttle system has been consolidated into one line item, most identifiers removed from
subsystem descriptions as only two baghouses serve as exhaust points.

6. A new finish mill with heater has been added. Included in the description are the thirteen total
baghouses for dust control (1 main stack, 2 transfer points, 10 nuisance dust filters)

7. A new clinker reclaim hopper has been added. Both reclaim hoppers are controlled by baghouses
with updated identifiers

8. A new rail and truck loading/unloading system with two baghouses has been added.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 48

[Last updated December 20, 2024]

12. Comment regarding changes in conditions:
As a result of this project, several conditions will be added or changed. This includes one new
general condition (I.8). Changes to the equipment list (section II.A) will be addressed in a separate
reviewer comment:

I.8 - Adding this general condition to cover the requirements of R307-401-18 Eighteen Month
Review. The status of construction/installation of the new equipment shall be reviewed after
18-months.

II.B.1.a - Clinker production increases to 1,155,000 tpy
Use of limestone bypass material increases to 215,260 tpy

II.B.1.b - The NOx limit on the kiln decreases to 1,223 tpy, CO emissions from the kiln decrease to
3,395 tpy,
Adding a new CO2e limit of 0.92 tons CO2e/ton of clinker produced
PM limit on the clinker cooler decreased to 0.02 lb PM (filterable)/ton of clinker
Rule reference updated to include 40 CFR 60 Subpart F, and R307-401-8

II.B.1.e - Initial testing on the clinker cooler is now required within 180 days of startup of the unit.
Monitoring of CO2 from the kiln will be by CEM.
Formatting changes on paragraph designated ++, improve clarity, include reference to CO2
monitoring, define CPMS

II.B.1.e.4 - Update to address general PM monitoring and reference R307-401-8

II.B.1.e.14 - New condition to address new or reconstructed emission units monitoring requirements,
applicable to the clinker cooler and new finish mill.

II.B.1.h - Adding references to Subpart OOO units (limestone processing) with updated opacity
limits.
Adding 20% opacity limit on coal transfer and storage
Adding property boundary opacity limit of 20%
Updating rule reference to include Subpart OOO

II.B.1.j - New condition to address outlet grain loading limits on new baghouses, One identical limit,
15 total new baghouses.

II.B.1.j.1 - Monitoring on new baghouses as per II.B.1.e.4, added an allowance to test less frequently
than annually with three successful tests.

II.B.3.a - Updating formatting to add clarity and include reference to CO2 CEM

II.B.5 - New conditions on emergency engines, diesel fuel sulfur limits, hour of operation
restrictions, non resettable hour meter

[Last updated December 20, 2024]
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 49

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 50

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 51

TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 52

DAQE-IN103030032-25

January 22, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Mr. Nelson:

Re: Intent to Approve: Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — ) A A v A ? A D @ A w D D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — ) A A v A ? A D @ A w D D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ash Grove Cement Company Ash Grove Cement Company - Leamington Cement Plant

Mailing Address Physical Address
P.O. Box 38069 Highway 132
Leamington, UT 84638 Leamington, UT 84638

Source Contact UTM Coordinates
Name: Cody Watkins 397000 m Easting
Phone: [phone] 4380100 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3241 (Cement, Hydraulic)

SOURCE INFORMATION
General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried on site),
are correctly proportioned, ground, and mixed and then fed into a rotating kiln. The kiln alters the
materials and recombines them into small stones called cement clinker. The clinker is cooled and ground
with gypsum and additional limestone into a fine powdered cement. The final product is stored on site for
later shipping. The major sources of air emissions are from the combustion of fuels for the kiln operation,
from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source of
emissions of PM2.5, PM10, NOx, CO, HAPs, and GHG. It is a minor source of SO2 emissions.
NSR Classification
Major PSD Modification

Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
DAQE-IN103030032-25
Page 4

Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

These changes result in increases in actual emissions but decreases in most potential emissions. There will
be an increase in the potential emissions of VOCs and greenhouse gases.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
DAQE-IN103030032-25
Page 5

Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
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I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
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II.A.4 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)
II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area, and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, stacker systems. II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit-specific requirements.
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total air flow controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter
area; 9,865 acfm total air flow, controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are
controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each
is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6). II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The
following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for
NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.
II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low-pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

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II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow through stack
E34.
II.A.18 Kiln Feed Alleviator A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the central material silo between the blending silos and the preheater. Raw feed is removed from the system near the top of the preheater tower.
II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The
coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter area;
1,700 acfm total air flow.
II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker
storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1): 1,800 acfm that discharges into the clinker tunnel.
II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
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II.A.27 Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during loading.
II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel, all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during loading. 512.BF3 (1,000 acfm) is located on top of the silo. II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement products. Dust generated
during milling is captured by a BHA pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).

II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates from stack G55 (finish mill stack).
II.A.32 Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4).
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1 thru 3).

II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total air flow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations.
II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This
baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

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II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.
II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023)
II.A.40 Dust Shuttle System A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides, surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the
fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

II.A.41 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons) Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
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II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)
THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)
CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)
PM: 0.02 lbs filterable PM per ton of clinker.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR 60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to approve alternative control measures, the permittee shall keep a copy of the submitted petition and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source
of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2).
[40 CFR 63 Subpart LLL]

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II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must record the PM CPMS output data for all periods when the process is operating and use all the PM CPMS data for calculations when the PM CPMS is not out of control. The owner/operator must demonstrate continuous compliance by using all quality-assured hourly average data collected by the PM CPMS for all operating hours to calculate the arithmetic average operating parameter in units of the operating limit on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
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II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

II.B.1.e.3 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-165]
II.B.1.e.4 PM 40 CFR 60, Appendix A, Method 5, or 5I, or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three runs, with each
run at least 120 minutes in duration and each run collecting a sample of 60 dry standard cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165]
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II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
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II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
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II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer point, is not required to conduct Method 22 visible emissions monitoring under this paragraph. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator may decrease the frequency of performance testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
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II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: Instances of water and/or chemical application to unpaved areas shall be recorded and maintained by the owner/operator. The ambient temperature shall be recorded any time water should be applied but cannot due to freezing conditions. [R307-401-8]
II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

The sprays shall operate whenever dry conditions warrant meeting the required opacity
limitations or as determined necessary by the Director. Water sprays shall not be required during
periods of freezing temperatures.

[R307-401-8]

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II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

C. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the kiln/raw mill stack

F. The owner/operator shall record the output of the system: including the quantity of NOx, CO, O2, THC, Hg, HCl, and CO2 emissions at the kiln stack

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an
affected source shall continuously operate all required continuous monitoring devices
and shall meet minimum frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.

[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]
II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments, the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the results of the performance test demonstrating compliance with the filterable PM limit and using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust the SSOL developed in accordance with the results of the most recent PM performance test demonstrating compliance with the PM emission limit. The owner/operator shall use the PM CPMS to demonstrate continuous compliance with the SSOL in accordance with the requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

DAQE-IN103030032-25
Page 19

II.B.4 Fuel Limitations: II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke F. Fuel Oil
G. Used Oil Fuel

H. Synthetic Fuel
I. Wood
J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal additive.
Approval is not required to change from one previously approved coal additive to another
previously approved coal additive. [R307-401-8]
II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily heat input of the kiln and precalciner. The owner/operator may increase the average quantity of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon approval by the Director in accordance with the approval process described in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

DAQE-IN103030032-25
Page 20

II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight
A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation
C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit-no less than 1500oF for more than five minutes in any 60-minute period B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
DAQE-IN103030032-25
Page 21

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the Director. The calibration procedure and frequency shall be according to manufacturer's specifications. Use of factory-calibrated thermocouples for temperature measurement is approved. However, any other method of temperature measurement must be approved by the Director prior to use. The monitoring equipment for both temperature and oxygen content shall be located such that an inspector can at any time safely read the output. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall only operate the emergency engines for testing and maintenance purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency operation. [R307-401-8]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.5.b.2 To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From Source Submitted NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-IN103030032-25
Page 22

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-GN103030032F-25

January 22, 2025

Via Certified Mail 70190700000208349796

Erik Vernon
Bureau of Land Management
440 West 200 South Suite 500
Salt Lake City, Utah 84101
[e-mail]

Dear Mr. Vernon:

RE: Notice of Publication for Ash Grove Cement Company - Leamington Cement Plant – CDS A;
MACT (Part 63), Compliance Assurance Monitoring (CAM), Title V (Part 70) Major Source,
Major Criteria Source, Major HAP Source, Attainment Area, NSPS (Part 60),
Project Number: N103030032

On January 22, 2025, the Director has completed his review of a Prevention of Significant Deterioration
project submitted by Ash Grove Cement Company. Attached to this letter are the draft Approval Order
document (Intent to Approve) and the full engineering review. Following a 60-day review by the Federal
Land Managers, this project will be submitted for a 30-day public comment period. Written comments
received by the Division at this same address during these comment periods will be considered in making
the final decision on the approval/disapproval of the proposed Approval Order. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director at the Division in writing, a hearing
will be held in accordance with R307-401-7, UAC.

If you have any questions, please contact John Jenks, who may be reached at [phone].

Sincerely,

Jon L. Black, Manager
New Source Review Division

Enclosures: Engineering Review
Modeling Memo
Intent to Approve

JLB:JJ:jg
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

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State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
RN103030032
January 21, 2025
Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]
Dear Josh Nelson,
Re: Engineer Review:
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032
Please review and sign this letter and attached Engineer Review (ER) within 10 business days.
For this document to be considered as the application for a Title V administrative amendment, a
Title V Responsible Official must sign the next page.
Please contact John Jenks at [phone] if you have any questions or concerns about the ER.
If you accept the contents of this ER, please email this signed cover letter to John Jenks at
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 1

[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the
DAQ will consider any comments received and will issue the Approval Order.

If you do not respond to this letter within 10 business days, the project will move forward
without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue
an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 2

OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible
Official, as defined in R307-415-3, must sign the statement below. THIS IS STRICTLY
OPTIONAL.

If you do not want the Engineer Review to be considered as an application to administratively
amend your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will
require submittal of a separate Operating Permit Application to revise the Title V permit in
accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document:
Title V Operating Permit Application Due Dates clarifies the required due dates for Title V
operating permit applications and can be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality

“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate
and complete and request that this Approval Order be considered as an application
to administratively amend the Operating Permit.”

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 3

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N103030032
Owner Name Ash Grove Cement Company
Mailing Address P.O. Box 38069
Leamington, UT, 84638

Source Name Ash Grove Cement Company- Leamington Cement
Plant
Source Location Hwy 132
Leamington, UT 84638

UTM Projection 397000 m Easting, 4380100 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3241 (Cement, Hydraulic)

Source Contact Cody Watkins
Phone Number [phone]
Email [e-mail]

Billing Contact Cody Watkins
Phone Number 385.225.0615
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 30, 2022
Date of Accepted Application November 28, 2024

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 4

SOURCE DESCRIPTION

General Description
Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried
on site), are correctly proportioned, ground and mixed, and then fed into a rotating kiln. The kiln
alters the materials and recombines them into small stones called cement clinker. The clinker is
cooled and ground with gypsum and additional limestone into a fine powdered cement. The final
product is stored on site for later shipping. The major sources of air emissions are from the
combustion of fuels for the kiln operation, from the kiln, and from the clinker cooling process.
The Leamington cement plant is a major source for emissions of PM2.5, PM10, NOx, CO, HAPs
and GHG. It is a minor source of SO2 emissions.

NSR Classification:
Major PSD Modification

Source Classification
Located in Attainment Area,
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Proposal
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower, various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 6

These changes result in increases in actual emissions, but decreases in most potential emissions.
There will be an increase in the potential emissions of VOC and greenhouse gases.

EMISSION IMPACT ANALYSIS
The complete modeling review is located in DAQE-MN103030032-24. [Last updated January 14, 2025]

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 7

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 8

Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 9

Review of BACT for New/Modified Emission Units

1. BACT review regarding the Leamington Plant Upgrade Project
Any major stationary source or major modification subject to PSD review must undergo an
analysis to ensure the use of BACT. The requirement to conduct a BACT analysis is set forth in 40
CFR 52.21. Similarly, Utah requires the installation of BACT for all sources of air pollution under
R307-401-5(2)(d)), BACT is defined in 40 CFR 52.21 (and R307-401-2) as:

". . . best available control technology means an emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for each pollutant subject to regulation under
Act which would be emitted from any proposed major stationary source or major modification
which the Administrator, on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such source or modification
through application of production processes or available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion techniques for control of such
pollutant . . ."

Therefore, a BACT analysis is required for each new or physically modified emission unit for each
pollutant that exceeds an applicable PSD significant emission rate (SER). Since the PM10 and PM2.5
emissions from the proposed project exceed the applicable PSD SER, a BACT analysis is required
to assess the required levels of control for these pollutants. Because the CO2e emissions are subject
to regulation as a result of the proposed project resulting in an increase of 75,000 tons or more per
year CO2e, a BACT analysis is also required for that pollutant. Note that HAPs listed under CAA
Section 112(b)(1) are excluded from NSR (New Source Review) or PSD (i.e., BACT) review.

In a memorandum dated December 1, 1987, the United States Environmental Protection Agency
(EPA) stated its preference for a "top-down" BACT analysis. After determining if any New Source
Performance Standard (NSPS) is applicable, the first step in this approach is to determine, for the
emission unit in question, the most stringent control available for a similar or identical source or
source category. If it can be shown that this level of control is technically, environmentally, or
economically infeasible for the unit in question, then the next most stringent level of control is
determined and similarly evaluated. This process continues until the BACT level under
consideration cannot be eliminated by any substantial or unique technical, environmental, or
economic objections.

Presented below are the five basic steps of a top-down BACT review as identified by the EPA.
Step 1 - Identify All Control Technologies
Step 2 - Eliminate Technically Infeasible Options
Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Step 4 - Evaluate Most Effective Controls and Document Results
Step 5 - Select BACT

Ash Grove has elected to follow this methodology and based the BACT review on each individual
pollutant. The complete BACT analysis follows. [Last updated January 14, 2025]

2. BACT review regarding PM10 and PM2.5 Sources
PM10 and PM2.5 Modified Equipment
The existing kiln precalciner, preheater, and alleviator system are proposed to be modified, and the
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 10

kiln's ID fan and clinker cooler fans are proposed to be replaced, which will result in increased
airflow. Additionally, the clinker cooler baghouse will be converted from a plenum pulse to a pulse
jet baghouse. These modifications are projected to result in a net increase of potential PM10 and
PM2.5 emissions.

Kiln Upgrade BACT
The rotary cement kiln is the core of the cement manufacturing process, transforming the blended
raw materials or "rawmix" into clinker through pyro processing. Emissions from the kiln occur
from fuel combustion plus the physical and chemical reactions needed to transform the rawmix
into clinker. This project involves process and energy efficiency improvements and an increase in
kiln production, resulting in an increase of PM10 and PM2.5 emissions. This section specifically
addresses filterable PM10 and PM2.5. The condensable fraction is represented with the other
precursors as applicable to proposed emission increases.

The Leamington Plant's Kiln is subject to NSPS, Subpart F for particulate. Therefore, a BACT
analysis addresses applicability of the proposed changes to the kiln system to NSPS and review of
the RBLC. A summary of the resources reviewed include the following:

NSPS Subpart F - Standards of Performance for Portland Cement Plants establishes emission
standards for cement kiln operations. Specifically, kilns modified after June 16, 2008, are limited to
0.07 lbs PM/ton of clinker produced.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028) and
Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from kiln operations are as follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM emissions are most effectively controlled using a collection system with enclosures routed to
baghouses providing up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Ash Grove
has selected technology with the highest control efficiency, so there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 11

Step 5 - Select BACT
Ash Grove proposes that BACT for PM10 and PM2.5 emissions from the kiln consist of a collection
system routed to a baghouse or fabric filter that complies with NSPS Subpart F's emission standard
for a modified source. BACT for the Leamington Plant's kiln are 10% opacity and 0.07 lb of
PM/ton (NSPS Subpart F emission standard) of clinker.
[Last updated January 14, 2025]

3. BACT review regarding PM10 and PM2.5 sources cont.
Clinker Cooler Upgrade BACT
The clinker cooler reduces the temperature of the clinker exiting the kiln. It is necessary to reduce
clinker temperature before it enters the finish mill to maintain product quality and reduce wear and
tear on equipment. The clinker cooler is equipped with a heat exchanger that captures waste heat
and transfers it to the kiln preheater for process and energy efficiency. Emissions from the clinker
cooler are vented to a baghouse. The Leamington Plant's clinker cooler is also subject to NSPS
Subpart F for particulate. Ash Grove's proposed changes to the clinker cooler meet the definition of
a reconstruction under NSPS. Therefore, in order to meet the requirements of NSPS Subpart F, Ash
Grove will be required to meet a limit of 0.02 lb of PM/ton of clinker.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from clinker cooler operations are as
follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM10 and PM2.5 emissions are most effectively controlled using a collection system with enclosures
routed to a baghouse, which can achieve up to 99.9% control efficiency. Other technologies such as
wet scrubbers, cyclones and ESPs are feasible, but provide lower control efficiencies than a
baghouse. Because the most efficient control technology is proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for PM10 and PM2.5 emissions from the clinker cooler is a collection system routed to a
baghouse or fabric filter. In order to meet the requirements of NSPS Subpart F, Ash Grove will
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meet a reduced emission limit of 0.02 lb of PM/ton of clinker. A 10% opacity limit is also
applicable. [Last updated January 14, 2025]

4. BACT review regarding PM10 and PM2.5 sources cont.
New Finish Mill BACT
The proposed Plant upgrade include adding a second finish mill. The new finish mill will use an
energy efficient vertical roller mill assisted with a grinding aid. A total of five (5) point sources are
planned for the finish mill. In accordance with NSPS Subpart F, emissions from finish mill are
restricted to 10% opacity. Ash Grove has reviewed the following sources to identify available
control technologies.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);12 and

Region 8 General Permit for Concrete Batch Plants.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 emissions from plant material handling operations are as
follows:
Baghouse / Fabric Filter;
Best Management & Operational Practices;
Cyclone;
ESP;
Enclosure;
Water Application (Watering); and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
With the exception of water application, all options are technically feasible. Water application is
eliminated as clinker exiting the kiln along with additives in the finish mill must remain dry to
maintain product quality. Therefore, it is technically infeasible to water material in the finish mill.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Enclosure 50-90%
5. Cyclone 20-70%
6. Best Management & Operational Practices varies

Step 4 - Evaluate Most Effective Controls and Document Results
Baghouses provide the highest emission control efficiency, controlling up to 99.9% of PM
emissions from finish mill equipment. After baghouses, using a wet scrubber or ESP provides
similar PM control. Notably, baghouses, scrubbers, and ESPs require enclosures to aid in capturing
emissions and ducting to the control. Therefore, optimal PM emission control can be achieved
through implementing both baghouses and enclosures where feasible. Plant material sizing and
handling is currently done using a series of buildings and enclosures routed to baghouse controls.
Various silos storing material inputs are also equipped with fabric filters. As the highest ranked
technology is applied, there are no adverse energy, environmental or cost impacts to consider with
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the use of these control technologies. Thus, no further analysis is required under EPA's top-down
BACT approach.

Step 5 - Select BACT
BACT for finish mill PM10 emissions is compliance with NSPS Subpart F, Standards of
Performance for Portland Cement Manufacturing where applicable. Ash Grove will achieve BACT
for PM10 emissions from finish mill equipment through the implementation of enclosures,
baghouses, and best management practices. All baghouses at the finish mill will have a 10%
opacity limitation and a grain loading of 0.005 grains/dscf. [Last updated January 14, 2025]

5. BACT review regarding PM10 and PM2.5 sources cont.
Material Transfer, Sizing, and Storage BACT
The Leamington Plant has sources of fugitive emissions through raw material transfer. Materials
transferred include limestone and other raw materials, coal, clinker, and cement. These materials
are transferred by conveyor belt, screw conveyor, elevator, pneumatic conveyance or chutes via
gravity. At the Leamington Plant the fugitive emissions are enclosed at their transfer points and
routed to baghouses.

The following emission units are included in this category:
Limestone Crushing, Sizing, and Material Transfer;
Raw Material Transfer;
Coal Sizing and Transfer;
Existing Finish Mill;
Clinker Storage and Transfer;
Cement Storage and Truck and Rail Cement Loadout;
New Rail Loading and Loadout; and
New Clinker Reclaim Hopper Baghouse.

Generally, controls for these units have not changed or they are similar to current existing controls.
A full BACT analysis of each unit is included in Ash Grove's NOI and additional submitted
information. However, given that most controls remain unaltered, only the results of Step 5 -
Select BACT will be included here.

Limestone Crushing, Sizing, and Material Transfer
Subject to NSPS Subpart OOO opacity limits for existing sources.
Existing baghouses. No change from bag manufacturer's specifications.

Raw Material Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Coal Storage and Transfer
Existing Equipment. No change from bag manufacturer's specifications
20% Opacity

Clinker Storage and Transfer
Subject to NSPS Subpart F opacity limits:
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10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Existing Finish Mill Grinding, Storage and Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Cement Storage and Truck and Rail Cement Loadout, New Rail Loadout
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

New Rail Loadout, controlled by baghouse
Emissions Limit - 0.005 gr/dscfm

New Clinker Reclaim Hopper, controlled by baghouse
Subject to NSPS Subpart F opacity limits:
10% opacity
Emissions Limit - 0.005 gr/dscfm [Last updated January 14, 2025]

6. BACT review regarding PM10 and PM2.5 sources cont.
PM10 and PM2.5 Fugitive Emissions
The following fugitive emissions sources will increase emissions of PM10 and PM2.5 as a result of
the Leamington Plant's proposed throughput increase. The sources addressed in the following
BACT analyses are primarily in the quarry, but also include emissions from roads and dumping of
raw materials within the plant boundary.

The sources evaluated are listed below:
Roads;
Loading and Unloading;
Stockpiles;
Bulldozing and Grading;
Disturbed Areas; and
Drilling and Blasting.

Ash Grove currently controls emissions from these processes, and generally, controls for these
units have not changed. A full BACT analysis of each unit is included in Ash Grove's NOI and
additional submitted information. However, given that most controls remain unaltered, only the
results of Step 5 - Select BACT will be included here.

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
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Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

Stockpiles BACT
BACT shall consist of restricting fugitive emissions to the opacity standard of 20% opacity at the
property boundary. BACT for stockpiles will be achieved through applying good management
practices through its fugitive dust plan as appropriate.

Bulldozing and Grading BACT
BACT shall consist of restricting fugitive emissions from bulldozing and grading activities to no
more than 20% opacity, and that emissions are controlled with periodic watering of the disturbed
surface. The frequency of water application will depend on ambient weather conditions and
inherent moisture content of the material being moved.

Disturbed Areas BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. BACT for
disturbed areas will be achieved through best management practices, watering, scarification, and
revegetation.

Drilling and Blasting BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. This is achievable
through best management practices, shrouds, watering, and dust collection. [Last updated January
14, 2025]

7. BACT review regarding kiln system NOx emissions
Kiln System (Kiln, Raw Mill, and Coal Mill) - NOx BACT
Although there are physical changes to the kiln system, these changes are primarily related to
particulate emissions. NOx emissions are generated from the combustion of fuel - and no changes
in NOx emissions are expected from the kiln (hourly capacity to emit). The kiln NOx emissions will
remain the same as a result of upgrades to the SNCR system. The replacement of the various
components of the kiln system and portions of the preheater tower, along with new injection points,
will ensure that increased mixing of ammonia is achieved to enhance the SNCR system's ability to
reduce NOx and minimize ammonia slip. This will allow the Leamington Plant to maintain the NOx
hourly capacity to emit unchanged from current levels Leamington Plant Upgrade Project. At
present Ash Grove has no restriction on the amount of fuel combusted, only a limit on total NOx
generated, and with this project the allowed NOx PTE is decreasing from 1,352 tpy to 1,226 tpy.

Additional ammonia will be used in the existing SNCR system. While the SNCR system has
adequate capacity to accommodate the additional ammonia demand resulting from the system
upgrades, more ammonia ports are proposed to be added with the kiln system's proposed changes
of the equipment. The changes proposed to the kiln system will increase residence time and
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temperature which will improve the SNCR system's effectiveness to control NOx emissions and
minimize ammonia slip emissions to the atmosphere. No additional review of NOx BACT for the
kiln system is required under this proposal. [Last updated January 14, 2025]

8. BACT review regarding new finish mill heater emissions
Finish Mill Heater
The proposed finish mill will include a process heater to maintain a minimum temperature during
milling. The proposed heater will run on natural gas and is rated at 10 MMBtu/hr. Startup and
shutdown emissions from the heater are anticipated to be no greater than normal operation as the
process is simply a matter of bringing the heater to operating temperature. Emissions evaluated in
the BACT analysis for the finish mill heater include NOx, SO2, CO, and VOCs, PM10, and PM2.5.
Pollutants with identical control technologies are grouped together in the analysis.

NOx - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for NOx from units of this size range are as follows:
Ultra-Low-NOx Burners (ULNB);
Low NOx Burners;
Selective Catalytic Reduction (SCR);
Selective Noncatalytic Reduction (SNCR);
Good Combustion Practices; and
Use of Natural Gas.

Step 2 - Eliminate Technically Infeasible Options
Low exit temperatures render the use of SCR and SNCR ineffective. Particulate entrainment within
the finish mill could potentially foul (plug) the nozzles of ULNB. Low-NOx burners, the use of
natural gas as fuel and good combustion practices are all considered technically feasible.

Step 3 and Step 4 - Rank Remaining Control Technologies by Control Effectiveness and Evaluate
Most Effective Controls and Document Results
Since the three feasible control technologies are proposed for the finish mill heater, no detailed
economic, energy, and environmental impact evaluations were conducted. No ranking of control
effectiveness is required as all three controls are proposed.

Step 5 - Select BACT
BACT for NOx is the use of natural gas as fuel, good combustion practices and the use of Low NOx
burners.

CO, SO2, and VOC - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for CO, SO2, and VOC from units of this size are as follows:
Good Combustion Practices
Use of Natural Gas

The finish mill heater combusts natural gas. Related natural gas combustion emissions are
anticipated to be minimal.

Step 2 - Eliminate Technically Infeasible Options
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Both control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Both technologies offer intrinsic emission reductions from combustion. Since the technologies do
not compete, both technologies can and will be used simultaneously.

Step 4 - Evaluate Most Effective Controls and Document Results
Because both control technologies identified in Step 1 are proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for CO, SO2, and VOC are good combustion practices and the use of natural gas.

PM10 and PM2.5 BACT for the finish mill has been addressed in the PM10/PM2.5 sources section.
[Last updated January 14, 2025]

9. BACT review regarding SO2, VOC, and Lead Sources
The following BACT analysis is grouped by pollutants that will experience an increase in potential
emissions and the associated technically feasible control technologies. As such, the BACT analysis
is separated into SO2, VOC, and lead respectively with organic HAPs addressed with VOCs.

SO2 - Cement Kiln BACT
NSPS Subpart F - Standards of Performance for Portland Cement Plants, establishes emission
standards for cement kiln operations. Specifically, kilns constructed or reconstructed after June 16,
2008, are limited to 0.4 lbs SO2/ton clinker on a 30-day rolling average respectively. This limit is
an existing emission limit in the Leamington Plant's approval order and Title V. Ash Grove will
continue to achieve this emission limitation while achieving BACT for the kiln operations. Ash
Grove has reviewed the following sources to identify available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019); and

NSPS Subpart F as an affected emissions facility in 40 CFR 60.62(a)(4);

Portland Cement Association's Formation and Techniques for Control of Sulfur Dioxide and Other
Sulfur Compounds in Portland Cement Kiln Systems.

SO2 emissions are a result of oxidation of sulfur compounds in the rawmix and/or the coal used to
fire the kiln. However, the alkaline nature of the cement provides for direct absorption of SO2 into
the product, thereby mitigating the quantity of SO2 emissions in the exhaust stream.

Step 1 - Identify All Control Technologies
Control technologies identified for SO2 emissions from coal-fired kiln operations are as follows:
Baghouse or fabric filter;
Dry reagent injection prior to baghouse;
Wet scrubber;
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Process optimization; and
Good combustion practices.

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below:

1. Process Optimization 99%
2. Wet Scrubber 99%
3. Dry Reagent Injection 60%
4. Good Combustion Practices 30%
5. Baghouse Variable

Step 4 - Evaluate Most Effective Controls and Document Results
SO2 emissions are most effectively controlled by optimizing the process and utilizing the inherent
SO2 scrubbing properties of the kiln system itself. Although wet scrubbers alone can achieve equal
control efficiencies as process optimization, additional capital and operational expenses are
required for water consumption and wastewater discharge. Whereas process optimization achieves
the same control effectiveness and has the added benefit of reduced operational costs. Ash Grove
optimizes the kiln process by routing the exhaust from the kiln to a preheater and raw mill to
interact with the raw mix, thus creating an atmosphere similar to a dry scrubber system. Good
combustion practices also reduce SO2 formation with the added benefit of energy efficiency.

Step 5 - Select BACT
BACT for control of SO2 emissions from kiln operations shall consist of process optimization by
routing kiln exhaust to the preheater and raw mill, good combustion practices, and use of a
baghouse prior to exhausting to the atmosphere. As a modification of the kiln, 40 CFR 60.62(a)(4)
requires an emission limit of 0.4 pounds of sulfur dioxide (SO2) per ton of clinker on a
30-operating day rolling average. [Last updated January 14, 2025]

10. BACT review regarding SO2, VOC, and Lead Sources cont.
VOC - Cement Kiln BACT
VOCs are generated by incomplete combustion in the kiln. 40 CFR 63 Subpart LLL - NESHAP
from the Portland Cement Industry limits total hydrocarbon and total organic HAP emissions to 24
and 12 ppmv at 7% oxygen. Ash Grove will achieve or exceed these emission limitations while
achieving BACT for the kiln operations. Ash Grove has reviewed the following sources to identify
available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028); and

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for VOC emissions from coal fired kiln operations are as follows:
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Process optimization,
Good combustion practices

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below.

1. Process Optimization Variable
2. Good Combustion Practices Variable

Step 4 - Evaluate Most Effective Controls and Document Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove optimizes the
kiln process by capturing waste heat from the clinker cooler and routing to a kiln preheater. Good
combustion practices also reduce VOC formation with the added benefit of energy efficiency.
There are no adverse energy, environmental or cost impacts to consider with the use of this control
technology.

Step 5 - Select BACT
BACT for control of VOC emissions from kiln operations shall consist of process optimization by
routing kiln heat to the preheater and good combustion practices. An emission limit of 24 ppmv
VOC @ 7% O2 is imposed by NESHAP Subpart LLL.

VOC - Grinding Aid BACT
A grinding aid containing VOC is added to the new finish mill to disperse particles within the mill
and expose more surface area to grinding. An increase in grinding aid usage proportionally
increases potential VOC emissions because volatiles from the grinding aid are not combusted in
the kiln.

There is only one identified control option for limiting the VOC emissions from the grinding aid.
Process optimization is technically feasible. VOC emissions are most effectively controlled by
optimizing the process. Ash Grove proposes to install a vertical finish mill with this project. Due to
the new modern mill's efficiency, it is anticipated that a reduced amount of grinding aid will be
required for each ton of clinker ground. Ash Grove estimates total VOC emissions from the
grinding aid at 2.37 tpy.

Lead Emissions
The lead emissions are anticipated to increase as a result of the proposed increase in clinker
throughput with the Leamington Plant upgrade project. Lead emissions result from residual
amounts of lead in raw materials and fuel. Lead emissions will be controlled the same as PM,
therefore a separate top-down BACT analysis has not been conducted as the Leamington Plant has
applied the most effective controls. [Last updated January 14, 2025]

11. BACT review regarding Greenhouse Gases
GHG Background
On October 9, 2009, the mandatory GHG reporting regulation, referred to as 40 CFR 98, was
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published in the Federal Register. Through 40 CFR 98, the U.S. EPA established the GHG
Reporting Rule, which requires the annual reporting of GHG data and other relevant information
from large sources and suppliers in the United States. Monitoring through the GHG Reporting
Program (GHGRP) began in 2010, with the first reports due by March 31, 2011. Per 40 CFR
98.2(a)(1), any facility associated with cement production is subject to the GHGRP and must report
CO2e emissions. The CO2e is the sum of equivalent GHG emissions from CO2, CH4, and N2O,
with their respective global warming potentials (GWP) applied. Ash Grove's facility is subject to
GHG Reporting Rule and monitors CO2 emissions from its kiln with a continuous emissions
monitoring system (CEMs). On June 23, 2014, the U.S. Supreme Court held that required PSD
permits (based on emissions of non-GHG pollutants) may continue to require limitations on GHG
emissions based on the application of BACT as an "anyway source". The Leamington Plant
modification project is a major source for PSD for both PM10 and PM2.5, and GHGs are estimated
to be greater than 75,000 tpy and greater than zero on a mass basis; therefore, GHGs are evaluated
for BACT as an anyway source.

Cement Manufacturing GHG BACT
A BACT analysis has been conducted for CO2e emissions from the kiln system. For this GHG
BACT analysis, various control technologies or combinations of technologies were identified using
the RACT/BACT/LAER Clearinghouse, available literature including guidance published by EPA
and South Coast Air Quality Management District (SCAQMD), current air regulations, other
regulatory organizations, and engineering experience. In March 2011, EPA published GHG
permitting guidance, as well as a white paper on available and emerging technologies for reducing
GHG emissions from the Portland cement industry in October 2010. Additionally, EPA published a
series of videos on GHG permit training in December 2010. The SCAQMD published GHG BACT
guidance in 2021. Additional sources of information were reviewed and documented based on
publications from trade organizations and other governmental committees with GHG or carbon
reduction guidelines and/or recommendations.

EPA has defined in 40 CFR 86.1818-12(a) GHGs as a group of six gases: CO2, nitrous oxide
(N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF6). GHG emissions from the kiln result from calcination and fuel combustion.
Since the primary GHG emitted by a kiln is CO2, the BACT analysis focuses on CO2 emissions
from the kiln. Emissions of CH4 and N2O are minimal from cement kilns. Per EPA guidance, GHG
control technologies for consideration in a BACT analysis for Portland Cement Manufacturing
include:

Source-wide energy efficiency strategies;
Raw material substitution;
Blended cements;
Carbon capture utilization and storage; and
Fuel switching.
Other emerging technologies [Last updated January 14, 2025]

12. BACT review regarding Greenhouse Gases cont.
Step 1: Identify All Control Technologies
The CO2 emissions from a cement kiln are generated by the calcination process (conversion of the
calcium carbonate in limestone to calcium oxide) and by combustion of fuel in the kiln. Potential
control technologies to reduce these CO2 emissions for a cement kiln are addressed in EPA's white
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paper on Available and Emerging Technologies for Reducing GHG Emissions from the Portland
Cement Industry.

These technologies fall into three categories:
Energy Efficiency Improvements for the Clinker Production Process
Fuel Substitution
Carbon Capture and Sequestration

Step 2: Eliminate Technically Infeasible Options
Several potential energy efficiency improvements are technically feasible: Pre-heater/Pre-calciner
Kiln Process, Kiln Seal Management Program, Refractory Selection (Kiln Insulation), and Energy
Recovery from the Clinker Cooler. The use of alternative fuels such as natural gas, whole tires and
biofuel) is also technically feasible. Other control options, such as Use of Fluxes and Mineralizers,
Heat Recovery for Power - Cogeneration, Carbon Sequestration, Oxyfuel combustion, and
Post-combustion Capture have been deemed infeasible.

Step 3: Rank Remaining Control Technologies by Control Effectiveness
All four remaining control techniques are currently implemented at the Leamington Plant. This
permitting project incorporates energy efficiency improvements. Ash Grove has had a fuel
substitution program in place for several years, and this program is continually reviewed and
updated as new sources and types of fuel are identified.

Step 4: Evaluate Most Effective Controls and Document Results
Since all technically feasible energy efficiency improvements and changes to product composition
will be implemented, this section will focus on economic and environmental considerations of fuel
substitution to operate exclusively on natural gas.

Firing natural gas as the primary kiln fuel can reduce CO2 emissions from fuel combustion by as
much as 40%. However, studies have shown that use of natural gas as primary kiln fuel can result
in three times more NOx emissions than NOx emissions from coal firing. Creating more NOx to
reduce GHG emissions is undesirable as it is a precursor to both ozone and PM2.5. Fuel substitution
essentially trades emissions of one regulated pollutant for another. Estimated capital cost to switch
to natural gas fuel exceeds $25M. Implementing natural gas technology would provide incremental
public health and welfare benefit globally by reducing CO2 emissions, while increasing NOx
emissions and negatively impacting public health and welfare locally. Switching fuels to another
fossil fuel has finite potential to mitigate CO2 emissions.

Step 5: Select BACT
In addition to the proposed energy efficiency improvements addressed elsewhere in this BACT
analysis, BACT is a limit of 0.92-ton CO2e/ton clinker. Ash Grove will use a continuous emission
monitoring system (CEMS) for CO2 to demonstrate compliance with this limit. [Last updated
January 14, 2025]

13. BACT review regarding Leamington Plant Upgrade Project conclusion
The control processes and techniques covered in this BACT analysis have been reviewed by the
NSR Section of the UDAQ. Ash Groves proposed controls and associated emission limitations
represent BACT. Any emission limitations not expressed in an associated NSPS or NESHAP will
be included in the terms and conditions of this AO. A listing of all associated NSPS and NESHAP
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programs is also included in the Source Information section of this document under Applicable
Federal Programs. [Last updated December 13, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date
of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
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proper credit when notifying the Director, send the documentation to the Director, attn.: NSR
Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.

II.A.3
NEW
Stockpiles
Coal storage
Area: 1 acre
Annual throughput 20,000 tpy

AF and ARM stockpiles
Area: 0.25 acre
Annual throughput 8,000 tpy

II.A.4 Stationary Crusher
Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction
of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000
acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)

II.A.5 Raw Material Transfer
Crushed material is transported to raw material storage by belt B8. The raw material transfers
at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor
transfer point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total
filter area & water sprays. (pre-1983)

II.A.6 Material Handling
Conveyor belt systems, secondary feeders and screens, stacker system

II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit specific requirements

II.A.8 Belt Conveyor Transfer Baghouse
Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area
and 1,800 acfm total air flow, controls emissions from the conveyor belt that transfers the
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stacked material to the raw material silos.

II.A.9 Raw Material Silos
Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The
four silos are equipped with one common Fuller, plenum pulse baghouse (315.BF1) - 1,689 ft2
filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage).

II.A.10 Fifth Component Silo
Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse
(315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw
mill feed. This system includes vibrating feeders, a conveyor system, and surge bin.
Emissions are controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3,
316.BF4, 316.BF5) - each is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1
A/C ratio.

II.A.12 Cross-Belt Analyzer
Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6)

II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom
of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw
materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38).
The following equipment is installed: low-NOx burner, selective non-catalytic reduction
(SNCR) for NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued
mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric
monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct
for mercury adsorption capacity. The carbon injection system is not an emission point as it is
in an enclosed building.

II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

II.A.16 Two Kiln Feed Blending Silos
Raw material is blended in one of two blending silos prior to feeding the kiln. The blending
silos are controlled by one common Fuller, plenum pulse baghouse (411.BF1) - 1,351 ft2 filter
area; 7,160 acfm total air flow.

II.A.17 Blending Silo Elevators (2)
Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped
with a Fuller, pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow
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through stack E34.

II.A.18 Kiln Feed Alleviator
A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the
central material silo between the blending silos and the preheater. Raw feed is removed from
the system near the top of the preheater tower.

II.A.19 Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner.
The coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter
area; 1,700 acfm total air flow.

II.A.20 Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in
the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2):
19,500 acfm rated airflow with 3.75:1 A/C ratio

II.A.21 Clinker Cooler and Baghouse
Reconstructed grate type cooler used for cooling clinker from the kiln prior to transfer to
clinker storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) -
173,869 acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter
monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two
clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse
(419.BF8). The exhaust is routed to the clinker cooler stack.

II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions
generated when loading the east and west clinker silos and the out-of-spec silo are controlled
by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1):
1,800 acfm, that discharges into the clinker tunnel.

II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm, that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2)
Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers.
Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses
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(511.HP1 and new 511.HP2): 1,800 acfm each.

II.A.27 Gypsum Silo
Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2
total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust
during loading.

II.A.28 Clinker Tunnel Exitway
The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse
(511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel all discharge in the clinker tunnel.
Emissions are vented through the tunnel exitway.

II.A.29 Limestone Silo
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust
during loading. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement product. Dust
generated during milling is captured by a BHA, pulse jet baghouse (514.BF2) - 6,080 ft2 filter
area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding
stack).

II.A.31 Finish Mill (Ball Mill) Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized
cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA, pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow
controlling particulates from stack G55 (finish mill stack).

II.A.32
NEW
Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The
stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4)
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1,
525.BF1 thru 3)

II.A.33 Finish Cement Storage Silos
There are six storage and two interstice silos where the finished cement product is stored. A
single common Fuller, plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm
total air flow through stack H7 is located on top of the silos and is used to control emissions
during loading and unloading operations.

II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail
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shipping. This baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out
The cement loadout system located on the South side of the silos (truck load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF2) during unloading from the silos for truck
shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement
conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed
space inside the silos.

II.A.36
NEW
Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

II.A.37 MHO: Materials Handling Operation
Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1
& 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4;
512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.

II.A.38 LBS: Limestone Bypass System
Additional limestone is added to the clinker and gypsum by the limestone bypass system
(LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays
at the screen and material handling drop points.

II.A.39 GEN: Emergency Generators
One diesel-fired emergency generator (new)
Rating: 762 hp
(Kiln, Tier 3, permitted 2022)

Two natural gas-fired emergency generators
Rating: 304 hp
(Main office and control room, permitted in 2023)

One diesel-fired emergency generator
Rating: 560 hp
(Shipping, permitted 2023).

II.A.40 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14 inch knife gate, 8 inch knife gate, 8 inch air
slides, surge bin), and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm)
on the fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

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II.A.41
NEW
Miscellaneous Storage Tanks
One diesel storage tank (<2,000 gallons)
One gasoline storage tank (500 gallons)
Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Requirements on the Cement Plant:
II.B.1.a
NEW
The following limits shall not be exceeded:

A. Clinker production - 1,155,000 tons per rolling 12-month period

B. Used oil consumption - 85,724 gallons per rolling 12-month period

C. Limestone bypass material processed - 216,260 tons per rolling 12-month period.
[R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 25th day of each month using data from the previous 12 months.
Records shall be kept for all periods when the plant is in operation. Consumption and
production shall be calculated through use of the plant's acquisition system. [R307-401-8]

II.B.1.b
NEW
Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations:

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

SO2: 0.4 lbs per ton of clinker (3-hr average)

CO: 3,395 tons per rolling 12-month period, and 6,600 lbs/hr

NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average, and 1,233 tons per rolling
12-month period

Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is
400oF or less.

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Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)

THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)

CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)

PM: 0.02 lbs filterable PM per ton of clinker. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL,
R307-401-8]

II.B.1.c
NEW
A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR
60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust
emissions control plan shall be monitored to demonstrate that appropriate control measures are
being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of
the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall
be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in
the plan and that the source is operating in accordance with the submitted plan. For petitions
to approve alternative control measures, the permittee shall keep a copy of the submitted
petition and any approvals received. [40 CFR 60 Subpart Y]

II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area
source of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2). [40 CFR
63 Subpart LLL]

II.B.1.e
NEW
Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b
and II.B.1.d shall be performed as specified below:

A. Kiln/Raw Mill Stack
Pollutant Test Status Test Frequency
PM * #

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

B. Clinker Cooler (F31)
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Pollutant Test Status Test Frequency
PM + #

C. Testing Status (To be applied above)
* The initial testing has already been performed.

** The SO2 initial performance test was conducted on August 26, 2013.

*** The initial compliance test shall be conducted within the first 30 operating days of
operation in which the affected source operates using a CEMS.

# Test once every year. If performance testing would be required less than 15 operating days
after the Kiln has completed Startup after being down for more than 24 hours, then
performance testing may be deferred up to 15 operating days after completion of the Startup.
The Director may require testing at any time.

## Test at least once every two years. The Director may require testing at any time.

+ Initial testing is required within 180 days of startup of the reconstructed equipment

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must record the PM
CPMS output data for all periods when the process is operating, and use all the PM CPMS
data for calculations when the PM CPMS is not out-of-control. The owner/operator must
demonstrate continuous compliance by using all quality-assured hourly average data collected
by the PM CPMS for all operating hours to calculate the arithmetic average operating
parameter in units of the operating limit on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

+++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.e.1
NEW
Notification
The Director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The notification requirements for performance tests subject to 40
CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-165]

II.B.1.e.2
NEW
Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational
Safety and Health Administration (OSHA)- or Mine Safety and Health Administration
(MSHA)-approved access shall be provided to the test location. [R307-165]

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II.B.1.e.4
NEW
PM
40 CFR 60, Appendix A, Method 5 or 5I or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three (3) runs with
each run at least 120 minutes in duration and each run collecting a sample of 60 dry standard
cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.3
NEW
Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2. [R307-165]

II.B.1.e.5
NEW
Carbon Monoxide (CO)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.6
NEW
Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.7
NEW
Sulfur Dioxide (SO2)
40 CFR 60, Method 6 or 6C of Appendix A-4 or other EPA-approved method as acceptable to
the Director. [R307-165]

II.B.1.e.8
NEW
Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]

II.B.1.e.9
NEW
Total Hydrocarbons (THC)
Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL]

II.B.1.e.10
NEW
Mercury (Hg)
Continuous Emission or integrated sorbent trap monitoring (See Condition II.B.3.a). [40 CFR
63 Subpart LLL]

II.B.1.e.11
NEW
HCl
Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other
EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]

II.B.1.e.12
NEW
Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.13
NEW
Calculations
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director, to give the results in the specified units of the
emission limitation. [R307-165]

II.B.1.e.14
NEW
Existing Source Operation
For an existing source/emission point, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three years.
[R307-165]

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Page 32

II.B.1.e.15
NEW
New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the maximum production rate listed in this AO. If the maximum AO
allowable production rate has not been achieved at the time of the test, the following
procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This new
allowable maximum production rate shall remain in effect until successfully tested at a higher
rate.

3) The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate (110%
of the new rate) will then be allowed if the test is successful. This process may be repeated
until the maximum AO production rate is achieved. [R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL.
[40 CFR 63 Subpart LLL]

II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times
of Dust Shuttle System operation to assist in the capture of Mercury emission. [R307-401-8]

II.B.1.h
NEW
Visible emissions from the following emission points shall not exceed the following values:

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

L. All baghouses - 10% opacity
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M. Fugitive dust - 20% opacity

N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y,
R307-401-8]

II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer
point is not required to conduct Method 22 visible emissions monitoring under this paragraph.
The enclosures for these transfer points must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

If any partially enclosed or unenclosed conveying system transfer point is located in a
building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to
40 CFR 60, according to the following:

(i) The owner/operator must conduct a monthly ten-minute visible emissions test of each
affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The
performance test must be conducted while the affected source is in operation.

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator may decrease the frequency of performance testing from monthly
to semi-annually for that affected source. If visible emissions are observed during any
semi-annual test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iii) If no visible emissions are observed during the semi-annual test for any affected source,
the owner/operator may decrease the frequency of performance testing from semi- annually to
annually for that affected source. If visible emissions are observed during any annual
performance test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iv) If visible emissions are observed during any Method 22 performance test, of Appendix
A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations,
recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60.
The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour
of any observation of visible emissions.

(v) If visible emissions from a building are monitored, the requirements of paragraphs (i)
through (iv) of this Condition apply to the monitoring of the building, and the owner/operator
must also test visible emissions from each side, roof, and vent of the building for at least ten
minutes. [R307-401]

II.B.1.j
NEW
Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed
0.005 gr/dscf:

520.BF1
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520.BF2
520.BF3
520.BF4
521.BF2
521.BF1
524.BF1
524.BF2
524.BF4
524.BF3
525.BF1
525.BF2
525.BF3
511.HP2
NRL_UPR
NRL_LWR. [R307-401-8]

II.B.1.j.1
NEW
To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration
through at least three (3) annual tests that the PM limits are not being exceeded, the
owner/operator may request approval from the Director to conduct stack testing less
frequently than annually. [R307-401-8]

II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive
dusts as dry conditions warrant or as determined necessary by the Director to maintain opacity
limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated to control fugitive dust. The application of
water or chemical treatment shall be used. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a damp/moist condition unless it is below freezing.
If chemical treatment is to be used, the plan must be approved by the Director. Records of
water and/or chemical treatment shall be kept for all periods when the plant is in operation.
The records shall include the following items: Instances of water and/or chemical application
to unpaved areas shall be recorded and maintained by the owner/operator. The ambient
temperature shall be recorded any time water should be applied but cannot due to freezing
conditions. [R307-401-8]

II.B.2.c
NEW
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

The sprays shall operate whenever dry conditions warrant meeting the required opacity
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limitations or as determined necessary by the Director. Water sprays shall not be required
during periods of freezing temperatures. [R307-401-8]

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation
of fugitive dusts as dry conditions warrant or as determined necessary by the Director.
[R307-401-8]

II.B.2.e
NEW
The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5
PM. [R307-401-8]

II.B.3 Continuous Emission Monitoring Requirements:
II.B.3.a
NEW
The owner/operator shall install, calibrate, maintain and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler.

A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the
missing data substitution procedures used by the UDAQ or the missing data substitution
procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate by the UDAQ.

B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period
including during each startup, shutdown, or malfunction.

C. The monitoring system shall comply with all applicable sections of R307-170, UAC; and
40 CFR 60, Appendix B.

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be
installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the
kiln/raw mill stack.

F. The owner/operator shall record the output of the system: including the quantity of NOx,
CO, O2 THC, Hg, HCl, and CO2 emissions at the kiln stack.

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source shall
continuously operate all required continuous monitoring devices and shall meet minimum
frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker
cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except
during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments,
the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a
PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the
results of the performance test demonstrating compliance with the filterable PM limit and
using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust
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the SSOL developed in accordance with the results of the most recent PM performance test
demonstrating compliance with the PM emission limit. The owner/operator shall use the PM
CPMS to demonstrate continuous compliance with the SSOL in accordance with the
requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

II.B.4 Fuel Limitations:
II.B.4.a
NEW
The owner/operator shall use only the following fuels in the kiln and pre-calciner:

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.

If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b
NEW
Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the
Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the
results of suitable tests giving data similar to a Proximate and Ultimate analysis of the
proposed coal additive. [R307-401-8]

II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal
additive. Approval is not required to change from one previously-approved coal additive to
another previously-approved coal additive. [R307-401-8]

II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily
heat input of the kiln and precalciner. The owner/operator may increase the average quantity
of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon
approval by the Director in accordance with the approval process described in Condition
II.B.4.b. [R307-401-8]

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II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel burning or process
installation not covered by New Source Performance Standards for sulfur emissions or
covered elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross
Btu heat input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input
for any oil except used oil. The sulfur content shall comply with all applicable sections of
UAC R307-203. [R307-203, R307-401-8]

II.B.4.c.1
NEW
Certification of fuels shall be either by the owner/operator's own testing or test reports from
the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be
available onsite. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials, UAC R307-203-1 (4)

A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be
used.

B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be
used.

C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85 are to be used. [R307-203]

II.B.4.d
NEW
The concentration/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight
3) Cadmium 2 ppm by weight
4) Chromium. 10 ppm by weight
5) Lead 100 ppm by weight
6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be
tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the burn tank and burned. [R307-401-8]

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II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned
in the rotary kiln:

A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than
five minutes in any 60-minute period

B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes
in any 60-minute period. [R307-401-8]

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the
Director. The calibration procedure and frequency shall be according to manufacturer's
specifications. Use of factory-calibrated thermocouples for temperature measurement is
approved. However, any other method of temperature measurement must be approved by the
Director prior to use. The monitoring equipment for both temperature and oxygen content
shall be located such that an inspector can at any time safely read the output. [R307-401-8]

II.B.5
NEW
Emergency Engine Requirements
II.B.5.a
NEW
The owner/operator shall only operate the emergency engines for testing and maintenance
purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency
operation. [R307-401-8]

II.B.5.b
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each emergency engine. [R307-401-8]

II.B.5.b.1
NEW
The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.5.b.2
NEW
To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN103030035-24 dated November 27, 2024
Is Derived From Source Submitted NOI dated November 30, 2022
Incorporates Additional Information Received dated April 26, 2023
Incorporates Additional Information Received dated September 26, 2023
Incorporates Additional Information Received dated July 23, 2024
Incorporates Additional Information Received dated October 25, 2024
Incorporates Additional Information Received dated November 25, 2024

REVIEWER COMMENTS

1. Comment regarding applicability of federal requirements:
New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable
by the best demonstrated technology as specified in the applicable provisions. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.

40 CFR 60, Subpart A (General Provisions)
All affected facilities subject to a source-specific NSPS are subject to the general provisions of
NSPS, Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires
initial notification, performance testing, recordkeeping, and monitoring, provides reference methods,
and mandates general control device requirements for all other subparts.

40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of
performance for affected facilities in Portland Cement Plants which have been constructed or
modified after August 17, 1971.

40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart
F: Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and
unloading systems. The Leamington coal mill is an in-line coal mill and considered an integral part
of the Leamington kiln. In-line coal mills are not subject to NSPS Subpart Y. Therefore, the coal mill
is addressed under NSPS Subpart F as part of the kiln system. The coal silos and conveying system
are subject to NSPS Subpart Y.

Ash Grove's proposed changes to the kiln system must be evaluated as to whether they trigger new
NSPS Subpart F obligations based on whether the proposed project is either a modification or a
reconstruction, as those terms are defined in NSPS Subpart A.

Ash Grove's proposed changes to the kiln system do not meet the definition of a reconstruction, nor
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Page 40

do they meet the definition of a modification for NOx. However, the changes meet the definition of a
modification for PM and SO2. Therefore, Ash Grove will comply with all relevant emission
standards; testing requirements; monitoring, recordkeeping, and reporting obligations that apply to
the Leamington kiln system as an existing source under NSPS Subpart F. Under NSPS Subpart A
and F, the clinker cooler is considered a reconstructed unit. Thus new limits will apply to this unit.
[Last updated January 14, 2025]

2. Comment regarding applicability of federal requirements cont.:
NSPS Subpart Y - Standards of Performance for Coal Preparation and Processing Plants
This subpart provides standards of performance for affected facilities in coal preparation and
processing plants that process more than 200 tons of coal per day.

The Leamington plant's coal silo and coal conveying system are existing affected facilities under
NSPS Subpart Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses
controlling affected facilities subject to match the limit in NSPS Subpart Y from 0.016 gr/dscf to
0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade Project. Since there are no proposed
modifications or reconstruction to the coal silo and coal conveying system, nothing about the
proposed upgrade project affects the existing applicability of NSPS Subpart Y.

NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
This subpart provides standards of performance for affected facilities located at fixed or portable
nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August
31, 1983, with additional requirements applicable to sources constructed on or after April 22, 2008.

As the crushing and screening system is controlled by baghouses and an increase in PM10 actual
emissions on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS.
Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the
Leamington Plant Upgrade Project.

Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1),
60.676(f), and 60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO
monitoring and recordkeeping requirements.

[Last updated January 14, 2025]

3. Comment regarding applicability of federal requirements cont.:
National Emission Standards for Hazardous Pollutants (NESHAPs)
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or
greater than 10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as
specified by each subpart. NESHAP apply to sources in specifically regulated industrial source
classifications (CAA Section 112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities
not regulated as a specific industrial source type. The Ash Grove Leamington Plant is a major source
of HAPs and thus is subject to certain NESHAP standards.

Subpart A - General Provisions
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All affected sources are subject to the general provisions of Subpart A unless otherwise specified by
the source-specific NESHAP. Subpart A generally requires initial notification and performance
testing, recordkeeping, monitoring, provides reference methods, and mandates general control device
requirements for all other subparts as applicable.

Subpart LLL - Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry
This subpart establishes process/source specific emission limits for PM, VOC (expressed as total
hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and
gaseous HAP compounds by limiting PM and THC emissions because portions of such emissions
are USEPA-listed HAPs. Subpart LLL requires compliance with applicable emissions limits on and
after the initial startup of cement production. To further reduce emissions, Subpart LLL also
establishes operational requirements for the use of cement kiln dust (CKD), fly ash, fuel and control
equipment. Subpart LLL also specifies process/source specific emissions testing, monitoring,
recordkeeping, reporting, and compliance demonstration requirements. The compliance requirements
for the site are detailed in Approval Order Condition II.B.1.b. Ash Grove will continue to comply
with the requirements of Subpart LLL to demonstrate compliance. This cement kiln will remain an
existing source with respect to the kiln emission standards in Subpart LLL as this project does not
trigger the definition of a new source in Subpart LLL. New source standards apply only to affected
sources that were constructed or reconstructed after May 6, 2009.
[Last updated December 20, 2024]

4. Comment regarding PSD applicability analysis:
Ash Grove is proposing to increase the throughput of limestone from the quarry to supply the New
Finish Mill to increase the amount of low-carbon cement from the Leamington Plant. Additionally,
along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
modified, and the clinker cooler will be reconstructed. These changes are anticipated to result in an
increase in clinker production. Emission calculations for this project have been completed assuming
an increase in clinker production capacity while utilizing current fuel types. This will result in an
increase in the throughput of fuel.

The Leamington Plant is considered an existing major source under PSD based on potential
emissions of PM10, PM2.5, NOx, CO, SO2, and CO2e. If a major source undergoes a physical or
operational change, the facility must determine whether the project will be considered a major
modification. Per 40 CFR 52.21(b)(2)(i), in order to be a major modification, the project must result
in a significant emissions increase, and a significant net emissions increase.

As defined at 40 CFR 52.21(b)(40): Significant emissions increase means, for a regulated NSR
pollutant, an increase in emissions that is significant for that pollutant. Significant is further defined
to mean, in reference to a net emissions increase or the potential of a source to emit any of the
following pollutants, a rate of emissions that would equal or exceed the values outlined in 40 CFR
52.21(b)(23). If the increase in emissions from the project are not significant, a major modification
has not occurred.

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
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increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

For all pollutants, the project emissions increase was calculated as the difference between the
projected actual emissions (PAE) after the proposed project and the actual emissions prior to the
project (baseline actual emissions or BAE).

Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
". . . projected actual emissions means the maximum annual rate, in tons per year, at which an
existing emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years
(12-month period) following the date the unit resumes regular operation after the project, or in any
one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit of that regulated NSR pollutant and full utilization of the unit would
result in a significant emissions increase or a significant net emissions increase at the major
stationary source." [Last updated January 14, 2025]

5. Comment regarding PSD applicability analysis cont.:
Ash Grove estimates that the projected actual production capacity following the project will be
1,155,000 tons of clinker per year and 1,341,266 tons of limestone per year. These capacities were
used to calculate projected actual emissions from the project using representative emission factors.
Additionally, to estimate emissions from material transfer baghouses, the actual flow rates and actual
projected hours were used as a basis for projected actual emissions.

Project Emission Calculations

Project emission increases from the kiln and coal mill systems are calculated for all criteria
pollutants based on emission factors that are derived from stack testing, CEMS data, or emission
factors (i.e., VOCs and Lead), and the associated projected incremental clinker increase.

NOx emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain
hourly capacity to emit and annual potential to emit at current levels. The kiln's NOx emissions rate
will not change as a result of the physical modifications proposed by the project.

Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission
factor and multiplied by the incremental increase in clinker production. The emission factor was
selected based on the average of the 24-month consecutive month emissions for 2020 and 2021. The
CO emissions will increase.

The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing
conducted at the plant. The SO2 emissions will increase.

VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production. VOC emissions will increase.

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
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can be found in the original NOI and subsequent addendums submitted to UDAQ.

As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from
the proposed project, each increase of emissions from both existing and new sources shall be
summed together and compared to the PSD permitting thresholds. The increase of emissions is the
"positive" difference between the projected actual emissions and baseline actual emissions (projected
minus baseline).

New Emissions Sources

The actual to projected actuals calculation is not available to new emission units. For new emission
units, the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected
emissions are based on the new sources' potentials to emit. (40 CFR § 52.21(a)(2)(iv)(f)).

The new equipment proposed includes the New Finish Mill, a new rail and truck loading/loadout,
one (1) new clinker reclaim loading hopper with a dust collector and one (1) existing clinker reclaim
hopper with a dust collector, a new Clinker Cooler to replace the existing one, and a new kiln feed
alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions:

The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;

The finish mill heater was calculated based on its maximum firing capacity and flow rates; and

The fugitive emissions were calculated based on the projected annual throughput of the New Finish
Mill, the rail loadout, and clinker production. [Last updated January 14, 2025]

6. Comment regarding PSD applicability analysis cont.:
Existing Emission Sources

For the existing sources, the projected actual emissions are the maximum annual rates in tons per
year projected to occur during the next five (5) to ten (10) years if the existing sources' design
capacities increase. Ash Grove Leamington projected the actual emissions for the next five (5) years
based on the new kiln system producing an annual average of 3,250 tons of clinker per day.

Baseline actual emissions (BAE) are defined at 40 CFR 52.21(b)(48)(ii) as:

". . . baseline actual emissions means the average rate, in tons per year, at which the emissions unit
actually emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the 10-year period immediately preceding either the date the owner or operator
begins actual construction of the project, or the date a complete permit application is received by the
Administrator."

Ash Grove has selected to use the years 2020 and 2021 for each pollutant as the representative
baseline years.

In its NOI, Ash Grove calculated the emission increase from the project as being divided into two
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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phases. Phased construction projects are discussed in two sections of the federal PSD regulations -
40 CFR 52.21(j)(4) and 40 CFr 52.21(r)(2). UDAQ is not processing this project as a phased
construction project, nor did Ash Grove request such a determination. Therefore, Ash Grove
provided a summary table outlining the final change in emissions from this project:

Projected Actual Increase Compared to PSD threshold (tons per year)
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2e
BAE 76.64 39.64 1,187 6.87 3,315 55.47 641,385
PAE 203.15 113.47 1,226 45.87 3,414 72.07 1,067,984

Change in Emissions 126.51 73.83 39.00 39.00 99.00 16.59 426,598

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes

If the emissions increase is greater than the PSD significance threshold for a particular pollutant, Ash
Grove has the option of conducting a PSD review or continuing through the rest of the steps to
determine if it can "net" out of a PSD review. If the project increase is less than the PSD significant
threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant.

The change in emissions from the project exceeds the significant emission threshold for three
pollutants: PM10, PM2.5 and CO2e. Ash Grove elected to attempt to net out of a PSD major
modification for the remainder of the criteria pollutants.

Netting

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant
Upgrade Project and ends on the date the upgrade begins operation. Only PM10, PM2.5, CO2e are in
excess of SERs and therefore considered in the netting analysis.

Ash Grove estimated that the commencement of construction will be in December 2024. Therefore,
the contemporaneous period for this project is December 2019 through a projected date the project
upgrade begins operation. [Last updated January 21, 2025]

7. Comment regarding PSD applicability analysis cont.:
Contemporaneous Decreases

Ash Grove replaced an existing kiln emergency drive engine with a USEPA Tier 4 diesel engine in
2022. Concurrently, Ash Grove requested an increase in the capacity of 1L Cement. Additionally,
Ash Grove submitted a minor modification NOI air permit application on June 12, 2023, which
proposes replacing the shipping generator during the contemporaneous period. The kiln emergency
drive engine and shipping generator are both higher EPA tier ratings therefore result in decreases for
PM10 and PM2.5. These changes were approved in AO DAQE-AN103030033-24 issued March 21,
2024.

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Page 45

Contemporaneous Increases

As stated above, the existing kiln emergency drive engine and shipping generator were permitted and
replaced in 2024. This resulted in an increase in emissions of CO2e.

The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout
in an effort to improve truck traffic at the loadout. The modification to add these dust collectors to
the loadout was included in DAQE-AN103030029-19. The baghouses are three (3) levels up in the
silos' enclosed space (approximately 40 feet). Both dust collectors vent directly into the interior of
the silo structure and are not vented into the atmosphere. Ash Grove requests to remove these
baghouses from its existing permitted emissions inventory. Therefore, these emissions have been
documented in the netting analysis as zero emissions.

Also included in DAQE-AN103030033-24 were two new natural gas-fired emergency generators
and increases in stockpiles, material handling and road emissions.

Could Have Been Accommodated Emissions

In calculating project emissions increase, USEPA allows the exclusion of existing
production/emissions rates that could have been accommodated during the baseline period. These
"could have been accommodated" emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as
follows:

". . . Shall exclude, in calculating any increase in emissions that results from the particular project,
that portion of the unit's emissions following the project that an existing unit could have
accommodated during the consecutive 24-month period used to establish the baseline actual
emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project,
including any increased utilization due to product demand growth;"

Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the
exclusion of existing production and emissions rates that could have been accommodated during the
baseline period, it has elected not to use this exclusion at this time. Therefore, calculation of the
"could have been" accommodated emissions have not been included in this application's
applicability analysis.

The increase from the project is added to the contemporaneous decreases and contemporaneous
increases. The resulting calculation is then compared to the PSD significance threshold to determine
if a significant net emissions increase has occurred. [Last updated January 14, 2025]

8. Comment regarding PSD applicability analysis cont.:
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2 e
Contemporaneous Inc. 1.61 0.45 0.41 0 0.27 0.07 51.74

Contemporaneous Dec. -1.54 -3.97 -0.48 -0.02 -0.27 -0.09 0

Change in Emissions 125.02 69.21 38.93 38.98 99.00 16.58 426,650

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes
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Page 46

The results of the netting analysis conclude that both a significant emissions increase and a
significant net emissions increase in both particulates (PM10 and PM2.5) and CO2e will occur from
this project. Thus, the project must be reviewed as a PSD major modification. [Last updated January
14, 2025]

9. Comment regarding emission calculations:
This engineering review includes updated potential emission totals for both criteria and HAP
emissions. The potential-to-emit (PTE) values were calculated using updated values for clinker
produced and raw material inputs. BACT emission factors and limitations were used where
appropriate. Certain emission totals (NOx, SO2 and CO) were set based on avoiding a significant
increase in emissions. Specifically, the projected actual increase was set at just under the baseline
actual emissions + the significance level. As these emissions are monitored by CEM, UDAQ agrees
with this approach. Please see the netting analysis for further details on calculation of projected
actual increase. The NOx hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project.

CO2e emissions were calculated using the GHG emission factor calculated from 40 CFR Part 98
Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in Subpart A Table
A-1.

To calculate the PTE tons per year, the maximum hours (i.e., 8760) per year and the source's
emissions rates were multiplied with the throughputs. The potential throughputs have been updated
at UDAQ's request so that PAE is equal to PTE and represents the equipment's maximum design
potential.

Additional emission calculations based on source testing and monitoring, and EPA's compilation of
air emission factors AP-42. [Last updated January 14, 2025]

10. Comment regarding requirements for PSD review:
In addition to the permitting requirements of R307-401-5 through R307-401-8, there are additional
requirements under PSD that must be addressed:

1. Calculation of ambient air increments (40 CFR 52.12(c)), ambient air ceilings ((40 CFR 52.12(d)),
source impact analysis (40 CFR 52.12(k)), air quality models (40 CFR 52.12(l)) - these items are
addressed in the modeling memo DAQE-MN103030032-24.

2. Stack heights (40 CFR 52.12(h)) - Ash Grove's stack heights have been reviewed with respect to
good engineering practice and operate in a vertical unrestricted manner.

3. Control technology review (40 CFR 52.12(j)) - this is addressed in the BACT analysis section of
this review document.

4. Air quality analysis: preapplication analysis (40 CFR 52.12(m)) - this is covered in the PSD
applicability and netting analysis sections of this review document, ambient monitoring and
background data collection is also included in the modeling memo DAQE-MN103030032-24.

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
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Page 47

grain loading limit included in II.B.1.j.1 represents the required post-construction monitoring.
6. Source information (40 CFR 52.12(n)) - this is addressed under the requirements of R307-401-5
and was submitted by Ash Grove as part of the NOI package.

7. Additional impact analysis (40 CFR 52.12(o)) - these requirements cover soils, vegetation, growth
and visibility concerns. They are discussed in the modeling memo DAQE-MN103030032-24.

8. Federal land manager review (40 CFR 52.12(p)) - UDAQ provided initial notification to all
federal land managers upon receipt of the original NOI package. The draft permit and engineering
review will also be provided to the federal land managers 60-days prior to initiation of public
comment for their further review.

9. Public participation (40 CFR 52.12(q)) - this project will have a 30-day public comment period.

10. Source obligation (40 CFR 52.12(r)) - this requirement discusses source compliance with other
parts of the CAA, which is addressed within UDAQ's permitting rules in R307.
[Last updated January 14, 2025]

11. Comment regarding changes in equipment list:
The equipment list is being updated for clarity as well as adding new pieces of equipment. The
following changes are taking place:

The naming scheme is being updated to remove the numerical code from the unit designation. This
code generally referred to the associated control device and not to the emitting unit itself. This can
cause confusion especially when the same code was applied to multiple pieces of equipment.
Instead, the control devices (typically baghouse dust collectors) will be identified in the description
along with the appropriate numerical code.

Specific changes are as follows:

1. The kiln description has been updated

2. Clinker Cooler description has been updated to include a larger pulse jet baghouse.

3. The clinker storage silos, east and west clinker belts, clinker belt transfer and clinker tunnel have
been consolidated to avoid confusion

4. The north and south cement loadout exhausts now vent internally into the cement storage silos

5. The dust shuttle system has been consolidated into one line item, most identifiers removed from
subsystem descriptions as only two baghouses serve as exhaust points.

6. A new finish mill with heater has been added. Included in the description are the thirteen total
baghouses for dust control (1 main stack, 2 transfer points, 10 nuisance dust filters)

7. A new clinker reclaim hopper has been added. Both reclaim hoppers are controlled by baghouses
with updated identifiers

8. A new rail and truck loading/unloading system with two baghouses has been added.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 48

[Last updated December 20, 2024]

12. Comment regarding changes in conditions:
As a result of this project, several conditions will be added or changed. This includes one new
general condition (I.8). Changes to the equipment list (section II.A) will be addressed in a separate
reviewer comment:

I.8 - Adding this general condition to cover the requirements of R307-401-18 Eighteen Month
Review. The status of construction/installation of the new equipment shall be reviewed after
18-months.

II.B.1.a - Clinker production increases to 1,155,000 tpy
Use of limestone bypass material increases to 215,260 tpy

II.B.1.b - The NOx limit on the kiln decreases to 1,223 tpy, CO emissions from the kiln decrease to
3,395 tpy,
Adding a new CO2e limit of 0.92 tons CO2e/ton of clinker produced
PM limit on the clinker cooler decreased to 0.02 lb PM (filterable)/ton of clinker
Rule reference updated to include 40 CFR 60 Subpart F, and R307-401-8

II.B.1.e - Initial testing on the clinker cooler is now required within 180 days of startup of the unit.
Monitoring of CO2 from the kiln will be by CEM.
Formatting changes on paragraph designated ++, improve clarity, include reference to CO2
monitoring, define CPMS

II.B.1.e.4 - Update to address general PM monitoring and reference R307-401-8

II.B.1.e.14 - New condition to address new or reconstructed emission units monitoring requirements,
applicable to the clinker cooler and new finish mill.

II.B.1.h - Adding references to Subpart OOO units (limestone processing) with updated opacity
limits.
Adding 20% opacity limit on coal transfer and storage
Adding property boundary opacity limit of 20%
Updating rule reference to include Subpart OOO

II.B.1.j - New condition to address outlet grain loading limits on new baghouses, One identical limit,
15 total new baghouses.

II.B.1.j.1 - Monitoring on new baghouses as per II.B.1.e.4, added an allowance to test less frequently
than annually with three successful tests.

II.B.3.a - Updating formatting to add clarity and include reference to CO2 CEM

II.B.5 - New conditions on emergency engines, diesel fuel sulfur limits, hour of operation
restrictions, non resettable hour meter

[Last updated December 20, 2024]
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 49

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 51

TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 52

DAQE-MN103030032-24

M E M O R A N D U M

TO: John Jenks, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler
Dave Prey, Air Quality Modeler

DATE: December 12, 2024

SUBJECT: Modeling Analysis Review for the Ash Grove Cement Company – Leamington Plant,
located in Millard County, Utah
___________________________________________________________________________________
This is a Major Modification to a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Ash Grove Cement Company (Applicant) has submitted a Notice of Intent (NOI) air permit
application for a project referred to as the Leamington Upgrade Project (LUP). The proposed
upgrade project includes the construction and installation of new pollution control equipment, new
emission sources, and modifications to existing emission sources. Emission increases associated
with the LUP constitute a major modification to a Prevention of Significant Deterioration (PSD)
source subject to PSD permitting regulations. PSD regulations require the Applicant to include and
air quality impact analysis (AQIA) of the proposed projects impact on the EPA national ambient air
quality standards (NAAQS) and air quality related values (AQRV) as part of a complete NOI.

This report prepared by the New Source Review (NSR) modeling staff contains a review of the
Applicant’s Air Quality Impact Analysis (AQIA) including the methodology, data sources,
assumptions, and modeling results for comparison with State and Federal air quality standards. The
AQIA was reviewed and referenced in this report include the:
● Notice of Intent – Ash Grove Cement Leamington Plant PSD Notice of Intent Air Permit
Application, dated November 30, 2022.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

0 0
Jason Krebs

DP
DAQE-MN103030032-24
Page 2

II. APPLICABLE RULES AND ANALYSES

A Utah Air Quality Rules

The UDAQ has determined that the Applicant’s NOI is subject to the following rules for conducting an
AQIA:

R307-401 Permits: New and Modified Sources
R307-405 Permits: Major Sources Located in Attainment or Unclassified Area (PSD)
R307-406-2 Visibility – Source Review
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutant Impacts in Attainment Areas

B. Applicability

The proposed increases in emissions of PM10 and PM2.5 exceed the emission thresholds outlined in R307-
406-5 and R307-410-4. Therefore, an AQIA consistent with the requirements of R307-405-6, R307-406-
2, and R307-410-3 was submitted as part of the Applicant’s NOI. R307-410-3 establishes the U. S.
Environmental Protection Agency (US EPA) – Guideline on Air Quality Models as a formal basis for
defining the scope of the analysis, as well as the model’s construction. The results of the AQIA are
required to demonstrate the proposed project’s impact on state and federal air quality standards,
acceptable levels of impact, and action triggering thresholds referenced or listed in R307-401-6(2), R307-
401-6(3), R307-403-3(1), R307-403-5(1)(a), R307-405-4(1), R307-405-6. Annual emissions for criteria
pollutants requiring an AQIA are listed in Table 1.

Table 1: Ash Grove Leamington Proposed Net Emissions Increase

Criteria
Pollutants
Net Emission
Increase (TPY)
AQIA Trigger
Level (TPY) AQIA Required?
PM10 126.6 15 Yes
PM2.5 70.3 10 Yes

C. Required Analyses

R307-405 requires the Applicant to perform a pre-construction modeling analysis for all pollutants
emitted in a significant quantity. The purpose of the analysis is to determine if the extent of the source’s
impact is significant enough to warrant an on-site measurement of the ambient background concentration
levels. This data is included in the NAAQS analysis to represent the quality of the air prior to the
construction of the proposed project. The Applicant included a pre-construction modeling analysis for
PM10 and PM2.5 as part of the NOI. The pre-construction modeling analysis was also used to determine if
the proposed emissions would result in a significant impact to the environment, thereby triggering the
requirement for a cumulative analysis of the proposed project and other nearby existing sources.

R307-401-8 requires the Division to determine that the proposed project will comply with the NAAQS
prior to the issuance of an Approval Order (AO). R307-405(7) requires the Applicant to perform a
DAQE-MN103030032-24
Page 3
NAAQS analysis for all pollutants emitted in a significant quantity. The analysis is to include all
emissions at the proposed site under normal operating conditions using maximum anticipated short-term
release and annual release rates. Consistent with UDAQ policy, a cumulative analysis to include the
ambient background concentration and any contribution from other nearby sources is not required if the
proposed project’s impact does not exceed the PSD Class II Significant Impact Level (SIL).

R307-401-8 also requires the Division to determine that the proposed project will comply with PSD
increments prior to the issuance of an AO. Under R307-405(6), the Applicant is required to perform a
PSD Class I and II increment consumption analysis for all pollutants emitted in significant quantities.
The purpose of this analysis is to quantify any degradation in air quality since the major source baseline
date. The analysis is to include all increment consuming emissions at the proposed site under normal
operating conditions using maximum anticipated short-term and annual release rates. A cumulative
analysis to include contributions associated with growth and other increment consuming sources is not
required if the proposed project’s impact does not exceed the PSD Class I or II SIL.

R307-410-5 requires the Applicant to perform a HAPs analysis for any pollutant emitted above a
pollutant specific emission threshold value. This analysis is to include all emissions of the pollutants
resulting from the proposed modification under normal operating conditions using maximum anticipated
one-hour release rates. The Applicant did not trigger modeling for HAPs.

R307-406-2 requires the Applicant to perform a plume blight analysis. A plume blight analysis is required
to determine if plumes emanating from the proposed project would be visible inside any Class I area
within 50 kilometers of the source. The plume blight analysis is to include all emissions of NO2, SO4, and
PM10.

Under R307-405-16, an AQRV analysis is performed which evaluates regional haze and acid deposition
impacts at each of the Class I areas within 300 kilometers of the source. A regional haze analysis is
required to determine if the plumes would reduce the visual range of an observer inside the Class I area.
The regional haze analysis is to include all emissions of SO2, NOX and PM10. The deposition analysis
examines impacts from sulfur and nitrogen compounds at the Class I areas, and is based on all emissions
of SO2 and NOX. The Federal Land Managers use the Q/D approach to determine whether a PSD project
should provide detailed AQRV impact analyses, where: Q/D= [ H2SO4 + SO2 + NOx + PM10 emissions
(tpy)]/ distance (km). If Q/D is less than 10, no AQRV analysis is required.

R307-405 requires the Applicant to perform a soils and vegetation analysis. The analysis should quantify
the effects of pollutants on soils and vegetation near the highest impact location and in areas where
sensitive plant species may be impacted.

III. ON-SITE PRE-CONSTRUCTION MONITORING

A. Meteorological Data

Consistent with the US EPA - Meteorological Monitoring Guidance for Regulatory Modeling
Applications, one year of on-site data was collected using a 50-meter tower during the period October 1,
2021 through September 30, 2022. Parameters collected on-site included wind speed and direction,
temperature, delta-T, and solar radiation.

DAQE-MN103030032-24
Page 4

B. Ambient Pollutant Data

A preliminary analysis was conducted to determine the necessity for pre-construction ambient pollutant
monitoring. The results indicate that predicted concentrations of PM10 and PM2.5 exceed the monitoring
trigger level listing in the rule. A continuous PM10/PM2.5 monitor with filter based samplers was
installed near the northern edge of the Applicants property boundary, and collected particulate matter
from October 1, 2021 through September 30, 2022.

IV. MODEL SELECTION

The EPA-AERMOD dispersion modeling system is the preferred model specified in the US EPA –
Guideline on Air Quality Models to predict air pollutant concentrations in the near field (within 50
kilometers of the source). The US EPA - CALPUFF - Version 5.8 model is the preferred model to predict
concentrations in the far field (long range transport conditions beyond 50 kilometers from the source).

V. MODELING INPUTS AND ASSUMPTIONS

A. Technical Options

The regulatory default options were selected in AERMOD by the Applicant to quantify all concentrations.

B. Urban or Rural Area Designation

A review of the appropriate 7.5-minute quadrangles determined that the area should be classified as
“rural” for air modeling purposes.

C. Topography/Terrain

The Plant is at an elevation of 4,950 feet with nearby terrain features that have an effect on concentration
predictions.

a. Zone: 12
b. Location: UTM (NAD83): 397000 meters East, 4379850 meters North

D. Ambient Air

It was determined that the Plant boundary used in the AQIA meets the State’s definition of an ambient air
boundary.

E. Receptor and Terrain Elevations

The modeling domain has simple and complex terrain features in the near field. Therefore, receptor
points representing actual terrain elevations from the area were used in the analysis.

The far-field modeling domain consisted of a rectangular region covering all Class I areas within Utah,
and extending 50 kilometers beyond this area so that the model can account for re-circulation of the
plume.

DAQE-MN103030032-24
Page 5

F. Emission Rates and Release Parameters

The emission estimates and source parameters used in AERMOD for all proposed emission sources at the
site are presented in the NOI.

Speciated emission rates and source parameters used in the CALPUFF modeling are presented in Table 2.

Table 2: CALPUFF Emission Rates

Source
LCC Coordinates Modeled Emission Rates
Easting Northing SO2 SO4 NOX HNO3 NO3 SOA PMC SOIL EC
(m) (m) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr)
317.BF3 -1289410 -3738 52.81 5.03 307.58 0.00 0.00 5.03 2.60 2.90 0.11
419.BF1 -1289314 -3631 0.00 0.00 0.00 0.00 0.00 0.55 1.51 1.61 0.06
41B.BF2 -1289389 -3663 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.68 0.00
N1_FM2 -1289526 -3414 0.00 0.00 0.00 0.00 0.00 0.00 1.65 3.95 0.00
414.BF1N -1289407 -3683 0.00 0.00 0.00 0.00 0.00 0.00 0.10 0.25 0.00
2FM_HTR -1289528 -3415 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.08 0.00
514.BF1 -1289451 -3675 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.70 0.00
COMBO -1289424 -3668 0.00 0.00 0.00 0.00 0.00 0.00 1.37 5.72 0.00
FM2_CMB -1289454 -3439 0.00 0.00 0.00 0.00 0.00 0.00 0.50 1.21 0.00

Total Lb/hr 52.81 5.03 307.58 0.00 0.00 5.58 8.32 17.10 0.17
Hrs/Yr 8760 8760 8760 8760 8760 8760 8760 8760 8760
Ton/yr 231.3 22.0 1347.2 0.0 0.0 24.4 36.4 74.9 0.8

Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
317.BF3 POINT 4902.8 41.2 135.0 488 10.10 3.35
419.BF1 POINT 4891.2 18.3 60.0 388 6.36 2.90
41B.BF2 POINT 4895.2 68.6 224.9 294 17.83 0.74
N1_FM2 POINT 4832.0 49.7 163.0 363 40.08 1.40
414.BF1N POINT 4896.1 76.8 251.9 353 9.91 0.70
2FM_HTR POINT 4832.0 49.7 163.0 363 40.08 1.40
514.BF1 POINT 4889.5 39.6 130.0 294 11.86 0.91
COMBO POINT 4904.2 13.3 43.7 276 9.76 0.32
DAQE-MN103030032-24
Page 6
FM2_CMB POINT 4832.0 30.6 100.3 294 11.40 0.37

G. Building Downwash

The Applicant used the US EPA Building Profile Input Program (BPIP) to determine Good Engineering
Practice (GEP) stack heights and cross-sectional building dimensions for input into the model.

H. Ambient Background Concentrations

Millard County is in attainment for all criteria pollutants. The NAAQS analyses for PM2.5 and PM10 used
monitoring data collected on site during the pre-construction monitoring analysis. The background values
used in the NAAQS analysis are presented in Table 3.

Table 3: Background Concentrations

Pollutant Averaging
Period
Background
Concentration
(μg/m3)
PM10 24-hour 65.4
PM2.5 24-hour 10.2
Annual 4.2

I. Meteorological Data Processing

For the AERMOD model, on-site horizontal and vertical wind speed, direction, solar radiation and,
temperature data was combined with National Weather Service (NWS) upper air data collected at the Salt
Lake City International Airport (SLCIA) for the same period using the US EPA AERMET processing
system.

Meteorological data used for the CALPUFF modeling analysis consisted of 3 years (2018-2020) of data
developed by the Forest Service. The grid was 708 km (east-west) by 492 km (north-south) with a
resolution of 12 kilometers.

VI. RESULTS AND CONCLUSIONS

The Applicant performed a series of analyses to estimate the impact from the proposed project. Modeling
results and conclusions from the review of the analyses are outlined in detail below.

A. Pre-Construction Monitoring and Significant Impact Modeling

The Applicant performed a preliminary criteria pollutant analysis of the proposed modification. This
analysis indicated that increases in concentration levels of PM2.5 and PM10 were greater than the Class II
SIL, and therefore, a cumulative analysis for these pollutants was required.

DAQE-MN103030032-24
Page 7

B. NAAQS Analysis

The Applicant performed a modeling analysis to determine if the combined impact from the proposed
source, other industrial sources operating in the area, and ambient background would comply with the
NAAQS. The NAAQS analysis was reviewed by the Division and determined to be consistent with the
requirements of R307-410-3. Table 4 provides a comparison of the Applicant’s predicted air quality
concentrations and the NAAQS.

Table 4: Model Predicted NAAQS Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-hour 28.3 5 65.4 0 93.7 150 62.5%
PM2.5 24-hour 9.6 1.2 10.2 0 19.8 35 56.6%
Annual 4.4 0.3 4.2 0 8.6 9 95.6%
* Note: Only included other sources and background if source impact was above Class II SIL

C. PSD Class II Increments

The Applicant performed an analysis to determine if the impact from the proposed source would comply
with PSD Class II increments. The analysis was reviewed by the Division and determined to be
consistent with the requirements of R307-410-3. Table 5 provides a comparison of the predicted
concentrations and the PSD Class II increment.

Table 5: Model Predicted PSD Class II Increment Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Nearby
Sources*
Total Increment Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
PM10 Annual 8.1 1 0 8.1 25 32.4%
24-hour 28.3 5 0 28.3 30 94.3%
PM2.5 24-hour 6.1 1.2 0 6.1 9 67.8%
Annual 2.4 0.3 0 2.4 4 60.0%

D. Hazardous Air Pollutants

DAQE-MN103030032-24
Page 8
The Applicant performed an analysis to determine if HAP modeling is required. The analysis was
reviewed by the Division and determined to be consistent with the requirements of R307-410-3. The
analysis indicated that HAP modeling was not triggered by this modification, and therefore no HAP
modeling was performed.

E. PSD Class I Increment Consumption Analysis

The Applicant performed a CALPUFF analysis to determine if the impact from the proposed source along
with other increment consuming sources would comply with federal PSD Class I increments. The
analysis was reviewed by the Division and determined to be consistent with the requirements of R307-
410-3. The results for all Class I areas within 300 kilometers are provided in Table 6.

Table 6: Model Predicted PSD Class I Increment Concentrations

Air Period Prediction
Class I
Significant
Impact
Level
Other
Sources* Total Increment Percent
Pollutant (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
Capitol Reef
NO2 Annual 0.0018 0.1 2.5
SO2
3-Hour 0.0494 1 25
24-
Hour 0.0150 0.2 5
Annual 0.0008 0.1 2
PM2.5
24-
Hour 0.0430 0.27 2
Annual 0.0021 0.05 1
PM10
24-
Hour 0.0444 0.3 8
Annual 0.0021 0.2 4
Arches
NO2 Annual 0.0008 0.1 2.5
SO2
3-Hour 0.0408 1 25
24-
Hour 0.0102 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0522 0.27 2
Annual 0.0018 0.05 1
DAQE-MN103030032-24
Page 9
PM10
24-
Hour 0.0531 0.3 8
Annual 0.0019 0.2 4
Canyonlands
NO2 Annual 0.0010 0.1 2.5
SO2
3-Hour 0.0354 1 25
24-
Hour 0.0100 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0577 0.27 2
Annual 0.0019 0.05 1
PM10
24-
Hour 0.0591 0.3 8
Annual 0.0020 0.2 4
Bryce
NO2 Annual 0.0006 0.1 2.5
SO2
3-Hour 0.0369 1 25
24-
Hour 0.0082 0.2 5
Annual 0.0003 0.1 2
PM2.5
24-
Hour 0.0189 0.27 2
Annual 0.0010 0.05 1
PM10
24-
Hour 0.0194 0.3 8
Annual 0.0010 0.2 4
Zion
NO2 Annual 0.0011 0.1 2.5
SO2
3-Hour 0.0293 1 25
24-
Hour 0.0105 0.2 5
Annual 0.0005 0.1 2
PM2.5
24-
Hour 0.0266 0.27 2
Annual 0.0011 0.05 1
PM10 24-
Hour 0.0271 0.3 8
DAQE-MN103030032-24
Page 10
Annual 0.0012 0.2 4
* Note: Only included other increment consuming sources if source impact was above Class I SIL

Since the proposed project’s model predicted impacts at the Class I areas were less than the PSD Class I
significance levels, a cumulative analysis was not warranted.

DAQE-MN103030032-24
Page 11
F. Visibility – Plume Blight
Since the Class I areas are greater than 50 kilometers from the source, a plume blight analysis using
VISCREEN was not required.

G. Visibility – Regional Haze

The results of the Q/D analysis for the emissions increase was less than 10 but the FLMs wanted the
entire source included in the Q term. The results of including the total emissions resulted in a Q/D >10,
so an AQRV analysis was performed for visibility and acid deposition. The results shown in Table 7
indicate that the impacts are below the 0.5 Deciview (DV) threshold established by the National Park
Service, indicating that no further analysis is required.

Table 7: CALPUFF Visibility Results

Class I Area Year Maximum
Delta DV
98th
Percentile
change in
DV
#
Days
#
Days Threshold
(DV)
Below
Threshold
> 1 > 0.5
2018 0.248 0.06 0 0 0.5 Yes
Arches 2019 0.291 0.054 0 0 0.5 Yes
2020 0.216 0.106 0 0 0.5 Yes
2018 0.223 0.081 0 0 0.5 Yes
Canyonlands 2019 0.312 0.068 0 0 0.5 Yes
2020 0.186 0.085 0 0 0.5 Yes
2018 0.059 0.03 0 0 0.5 Yes
Bryce 2019 0.081 0.045 0 0 0.5 Yes
2020 0.071 0.03 0 0 0.5 Yes
2018 0.183 0.074 0 0 0.5 Yes
Capital Reef 2019 0.196 0.092 0 0 0.5 Yes
2020 0.126 0.078 0 0 0.5 Yes
2018 0.069 0.04 0 0 0.5 Yes
Zion 2019 0.123 0.039 0 0 0.5 Yes
2020 0.102 0.057 0 0 0.5 Yes

DAQE-MN103030032-24
Page 12

H. Acid Deposition

The Applicant performed a deposition analysis on impacts within the Class I areas. Results of the
analysis indicate that the impacts are below the deposition threshold (DAT) established by the National
Park Service, indicating that no further analysis is required

Table 8: CALPUFF Deposition Results for Highest Year

Class I Area
Total
Nitrate
Deposition
Total
Sulfate
Deposition
Deposition
Analysis
Threshold
(kg/ha/yr) (kg/ha/yr) (kg/ha/yr)
Canyonlands 0.0006 0.0003
0.005
Zion 0.0004 0.0002
Arches 0.0006 0.0003
Bryce 0.0006 0.0002
Capitol Reef 0.0011 0.0005

I. Soils and Vegetation Analysis

The Applicant performed an analysis to determine the extent of impacts from the proposed source on soil
and vegetation. Results of the analysis are presented in a supplemental document titled “Soil and
Vegetation Impact Analysis for the Leamington, UT Facility, June 29, 2023”. The analysis indicated that
predicted concentrations compared against the secondary NAAQS at several sensitive receptors would not
result in an adverse impact on soils and vegetation in the vicinity of the proposed project.

DP/JK:jg

DAQE-IN103030032-25

January 22, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Mr. Nelson:

Re: Intent to Approve: Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — ) A A v A ? A D @ A w D D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — ) A A v A ? A D @ A w D D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ash Grove Cement Company Ash Grove Cement Company - Leamington Cement Plant

Mailing Address Physical Address
P.O. Box 38069 Highway 132
Leamington, UT 84638 Leamington, UT 84638

Source Contact UTM Coordinates
Name: Cody Watkins 397000 m Easting
Phone: [phone] 4380100 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3241 (Cement, Hydraulic)

SOURCE INFORMATION
General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried on site),
are correctly proportioned, ground, and mixed and then fed into a rotating kiln. The kiln alters the
materials and recombines them into small stones called cement clinker. The clinker is cooled and ground
with gypsum and additional limestone into a fine powdered cement. The final product is stored on site for
later shipping. The major sources of air emissions are from the combustion of fuels for the kiln operation,
from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source of
emissions of PM2.5, PM10, NOx, CO, HAPs, and GHG. It is a minor source of SO2 emissions.
NSR Classification
Major PSD Modification

Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
DAQE-IN103030032-25
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Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

These changes result in increases in actual emissions but decreases in most potential emissions. There will
be an increase in the potential emissions of VOCs and greenhouse gases.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
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Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
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I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
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II.A.4 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)
II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area, and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, stacker systems. II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit-specific requirements.
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total air flow controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter
area; 9,865 acfm total air flow, controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are
controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each
is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6). II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The
following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for
NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.
II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low-pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

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II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow through stack
E34.
II.A.18 Kiln Feed Alleviator A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the central material silo between the blending silos and the preheater. Raw feed is removed from the system near the top of the preheater tower.
II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The
coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter area;
1,700 acfm total air flow.
II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker
storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1): 1,800 acfm that discharges into the clinker tunnel.
II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
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II.A.27 Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during loading.
II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel, all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during loading. 512.BF3 (1,000 acfm) is located on top of the silo. II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement products. Dust generated
during milling is captured by a BHA pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).

II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates from stack G55 (finish mill stack).
II.A.32 Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4).
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1 thru 3).

II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total air flow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations.
II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This
baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

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II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.
II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023)
II.A.40 Dust Shuttle System A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides, surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the
fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

II.A.41 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons) Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
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II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)
THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)
CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)
PM: 0.02 lbs filterable PM per ton of clinker.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR 60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to approve alternative control measures, the permittee shall keep a copy of the submitted petition and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source
of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2).
[40 CFR 63 Subpart LLL]

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II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must record the PM CPMS output data for all periods when the process is operating and use all the PM CPMS data for calculations when the PM CPMS is not out of control. The owner/operator must demonstrate continuous compliance by using all quality-assured hourly average data collected by the PM CPMS for all operating hours to calculate the arithmetic average operating parameter in units of the operating limit on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
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II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

II.B.1.e.3 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-165]
II.B.1.e.4 PM 40 CFR 60, Appendix A, Method 5, or 5I, or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three runs, with each
run at least 120 minutes in duration and each run collecting a sample of 60 dry standard cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165]
DAQE-IN103030032-25
Page 14

II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
DAQE-IN103030032-25
Page 15

II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
DAQE-IN103030032-25
Page 16

II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer point, is not required to conduct Method 22 visible emissions monitoring under this paragraph. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator may decrease the frequency of performance testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
DAQE-IN103030032-25
Page 17

II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: Instances of water and/or chemical application to unpaved areas shall be recorded and maintained by the owner/operator. The ambient temperature shall be recorded any time water should be applied but cannot due to freezing conditions. [R307-401-8]
II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

The sprays shall operate whenever dry conditions warrant meeting the required opacity
limitations or as determined necessary by the Director. Water sprays shall not be required during
periods of freezing temperatures.

[R307-401-8]

DAQE-IN103030032-25
Page 18

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

C. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the kiln/raw mill stack

F. The owner/operator shall record the output of the system: including the quantity of NOx, CO, O2, THC, Hg, HCl, and CO2 emissions at the kiln stack

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an
affected source shall continuously operate all required continuous monitoring devices
and shall meet minimum frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.

[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]
II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments, the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the results of the performance test demonstrating compliance with the filterable PM limit and using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust the SSOL developed in accordance with the results of the most recent PM performance test demonstrating compliance with the PM emission limit. The owner/operator shall use the PM CPMS to demonstrate continuous compliance with the SSOL in accordance with the requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

DAQE-IN103030032-25
Page 19

II.B.4 Fuel Limitations: II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke F. Fuel Oil
G. Used Oil Fuel

H. Synthetic Fuel
I. Wood
J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal additive.
Approval is not required to change from one previously approved coal additive to another
previously approved coal additive. [R307-401-8]
II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily heat input of the kiln and precalciner. The owner/operator may increase the average quantity of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon approval by the Director in accordance with the approval process described in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

DAQE-IN103030032-25
Page 20

II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight
A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation
C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit-no less than 1500oF for more than five minutes in any 60-minute period B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
DAQE-IN103030032-25
Page 21

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the Director. The calibration procedure and frequency shall be according to manufacturer's specifications. Use of factory-calibrated thermocouples for temperature measurement is approved. However, any other method of temperature measurement must be approved by the Director prior to use. The monitoring equipment for both temperature and oxygen content shall be located such that an inspector can at any time safely read the output. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall only operate the emergency engines for testing and maintenance purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency operation. [R307-401-8]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.5.b.2 To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From Source Submitted NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-IN103030032-25
Page 22

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-GN103030032G-25
January 22, 2025
Via Certified Mail 70190700000208349758
Pleasant McNeel
Regional Air Program Manager
USDA Forest Service Intermountain Region
324 25th Street
Ogden, UT 84401
[e-mail]
Dear Ms. McNeel:
RE: Notice of Publication for Ash Grove Cement Company- Leamington Cement Plant – CDS A;
MACT (Part 63), Compliance Assurance Monitoring (CAM), Title V (Part 70) Major Source,
Major Criteria Source, Major HAP Source, Attainment Area, NSPS (Part 60),
Project Number: N103030032
On January 22, 2025, the Director has completed his review of a Prevention of Significant Deterioration
project submitted by Ash Grove Cement Company. Attached to this letter are the draft Approval Order
document (Intent to Approve) and the full engineering review. Following a 60-day review by the Federal
Land Managers, this project will be submitted for a 30-day public comment period. Written comments
received by the Division at this same address during these comment periods will be considered in making
the final decision on the approval/disapproval of the proposed Approval Order. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director at the Division in writing, a hearing
will be held in accordance with R307-401-7, UAC.
If you have any questions, please contact John Jenks, who may be reached at [phone].
Sincerely,
Jon L. Black, Manager
New Source Review Division
Enclosures: Engineering Review
Modeling Memo
Intent to Approve
JLB:JJ:jg
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
Jon Black (Jan 22, 2025 15:44 MST)
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
RN103030032
January 21, 2025
Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]
Dear Josh Nelson,
Re: Engineer Review:
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032
Please review and sign this letter and attached Engineer Review (ER) within 10 business days.
For this document to be considered as the application for a Title V administrative amendment, a
Title V Responsible Official must sign the next page.
Please contact John Jenks at [phone] if you have any questions or concerns about the ER.
If you accept the contents of this ER, please email this signed cover letter to John Jenks at
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 1

[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the
DAQ will consider any comments received and will issue the Approval Order.

If you do not respond to this letter within 10 business days, the project will move forward
without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue
an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 2

OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible
Official, as defined in R307-415-3, must sign the statement below. THIS IS STRICTLY
OPTIONAL.

If you do not want the Engineer Review to be considered as an application to administratively
amend your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will
require submittal of a separate Operating Permit Application to revise the Title V permit in
accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document:
Title V Operating Permit Application Due Dates clarifies the required due dates for Title V
operating permit applications and can be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality

“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate
and complete and request that this Approval Order be considered as an application
to administratively amend the Operating Permit.”

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 3

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N103030032
Owner Name Ash Grove Cement Company
Mailing Address P.O. Box 38069
Leamington, UT, 84638

Source Name Ash Grove Cement Company- Leamington Cement
Plant
Source Location Hwy 132
Leamington, UT 84638

UTM Projection 397000 m Easting, 4380100 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3241 (Cement, Hydraulic)

Source Contact Cody Watkins
Phone Number [phone]
Email [e-mail]

Billing Contact Cody Watkins
Phone Number 385.225.0615
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 30, 2022
Date of Accepted Application November 28, 2024

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 4

SOURCE DESCRIPTION

General Description
Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried
on site), are correctly proportioned, ground and mixed, and then fed into a rotating kiln. The kiln
alters the materials and recombines them into small stones called cement clinker. The clinker is
cooled and ground with gypsum and additional limestone into a fine powdered cement. The final
product is stored on site for later shipping. The major sources of air emissions are from the
combustion of fuels for the kiln operation, from the kiln, and from the clinker cooling process.
The Leamington cement plant is a major source for emissions of PM2.5, PM10, NOx, CO, HAPs
and GHG. It is a minor source of SO2 emissions.

NSR Classification:
Major PSD Modification

Source Classification
Located in Attainment Area,
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Proposal
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower, various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 6

These changes result in increases in actual emissions, but decreases in most potential emissions.
There will be an increase in the potential emissions of VOC and greenhouse gases.

EMISSION IMPACT ANALYSIS
The complete modeling review is located in DAQE-MN103030032-24. [Last updated January 14, 2025]

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 7

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
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Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

Note: Change in emissions indicates the difference between previous AO and proposed modification.

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Review of BACT for New/Modified Emission Units

1. BACT review regarding the Leamington Plant Upgrade Project
Any major stationary source or major modification subject to PSD review must undergo an
analysis to ensure the use of BACT. The requirement to conduct a BACT analysis is set forth in 40
CFR 52.21. Similarly, Utah requires the installation of BACT for all sources of air pollution under
R307-401-5(2)(d)), BACT is defined in 40 CFR 52.21 (and R307-401-2) as:

". . . best available control technology means an emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for each pollutant subject to regulation under
Act which would be emitted from any proposed major stationary source or major modification
which the Administrator, on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such source or modification
through application of production processes or available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion techniques for control of such
pollutant . . ."

Therefore, a BACT analysis is required for each new or physically modified emission unit for each
pollutant that exceeds an applicable PSD significant emission rate (SER). Since the PM10 and PM2.5
emissions from the proposed project exceed the applicable PSD SER, a BACT analysis is required
to assess the required levels of control for these pollutants. Because the CO2e emissions are subject
to regulation as a result of the proposed project resulting in an increase of 75,000 tons or more per
year CO2e, a BACT analysis is also required for that pollutant. Note that HAPs listed under CAA
Section 112(b)(1) are excluded from NSR (New Source Review) or PSD (i.e., BACT) review.

In a memorandum dated December 1, 1987, the United States Environmental Protection Agency
(EPA) stated its preference for a "top-down" BACT analysis. After determining if any New Source
Performance Standard (NSPS) is applicable, the first step in this approach is to determine, for the
emission unit in question, the most stringent control available for a similar or identical source or
source category. If it can be shown that this level of control is technically, environmentally, or
economically infeasible for the unit in question, then the next most stringent level of control is
determined and similarly evaluated. This process continues until the BACT level under
consideration cannot be eliminated by any substantial or unique technical, environmental, or
economic objections.

Presented below are the five basic steps of a top-down BACT review as identified by the EPA.
Step 1 - Identify All Control Technologies
Step 2 - Eliminate Technically Infeasible Options
Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Step 4 - Evaluate Most Effective Controls and Document Results
Step 5 - Select BACT

Ash Grove has elected to follow this methodology and based the BACT review on each individual
pollutant. The complete BACT analysis follows. [Last updated January 14, 2025]

2. BACT review regarding PM10 and PM2.5 Sources
PM10 and PM2.5 Modified Equipment
The existing kiln precalciner, preheater, and alleviator system are proposed to be modified, and the
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kiln's ID fan and clinker cooler fans are proposed to be replaced, which will result in increased
airflow. Additionally, the clinker cooler baghouse will be converted from a plenum pulse to a pulse
jet baghouse. These modifications are projected to result in a net increase of potential PM10 and
PM2.5 emissions.

Kiln Upgrade BACT
The rotary cement kiln is the core of the cement manufacturing process, transforming the blended
raw materials or "rawmix" into clinker through pyro processing. Emissions from the kiln occur
from fuel combustion plus the physical and chemical reactions needed to transform the rawmix
into clinker. This project involves process and energy efficiency improvements and an increase in
kiln production, resulting in an increase of PM10 and PM2.5 emissions. This section specifically
addresses filterable PM10 and PM2.5. The condensable fraction is represented with the other
precursors as applicable to proposed emission increases.

The Leamington Plant's Kiln is subject to NSPS, Subpart F for particulate. Therefore, a BACT
analysis addresses applicability of the proposed changes to the kiln system to NSPS and review of
the RBLC. A summary of the resources reviewed include the following:

NSPS Subpart F - Standards of Performance for Portland Cement Plants establishes emission
standards for cement kiln operations. Specifically, kilns modified after June 16, 2008, are limited to
0.07 lbs PM/ton of clinker produced.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028) and
Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from kiln operations are as follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM emissions are most effectively controlled using a collection system with enclosures routed to
baghouses providing up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Ash Grove
has selected technology with the highest control efficiency, so there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.
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Step 5 - Select BACT
Ash Grove proposes that BACT for PM10 and PM2.5 emissions from the kiln consist of a collection
system routed to a baghouse or fabric filter that complies with NSPS Subpart F's emission standard
for a modified source. BACT for the Leamington Plant's kiln are 10% opacity and 0.07 lb of
PM/ton (NSPS Subpart F emission standard) of clinker.
[Last updated January 14, 2025]

3. BACT review regarding PM10 and PM2.5 sources cont.
Clinker Cooler Upgrade BACT
The clinker cooler reduces the temperature of the clinker exiting the kiln. It is necessary to reduce
clinker temperature before it enters the finish mill to maintain product quality and reduce wear and
tear on equipment. The clinker cooler is equipped with a heat exchanger that captures waste heat
and transfers it to the kiln preheater for process and energy efficiency. Emissions from the clinker
cooler are vented to a baghouse. The Leamington Plant's clinker cooler is also subject to NSPS
Subpart F for particulate. Ash Grove's proposed changes to the clinker cooler meet the definition of
a reconstruction under NSPS. Therefore, in order to meet the requirements of NSPS Subpart F, Ash
Grove will be required to meet a limit of 0.02 lb of PM/ton of clinker.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from clinker cooler operations are as
follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM10 and PM2.5 emissions are most effectively controlled using a collection system with enclosures
routed to a baghouse, which can achieve up to 99.9% control efficiency. Other technologies such as
wet scrubbers, cyclones and ESPs are feasible, but provide lower control efficiencies than a
baghouse. Because the most efficient control technology is proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for PM10 and PM2.5 emissions from the clinker cooler is a collection system routed to a
baghouse or fabric filter. In order to meet the requirements of NSPS Subpart F, Ash Grove will
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meet a reduced emission limit of 0.02 lb of PM/ton of clinker. A 10% opacity limit is also
applicable. [Last updated January 14, 2025]

4. BACT review regarding PM10 and PM2.5 sources cont.
New Finish Mill BACT
The proposed Plant upgrade include adding a second finish mill. The new finish mill will use an
energy efficient vertical roller mill assisted with a grinding aid. A total of five (5) point sources are
planned for the finish mill. In accordance with NSPS Subpart F, emissions from finish mill are
restricted to 10% opacity. Ash Grove has reviewed the following sources to identify available
control technologies.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);12 and

Region 8 General Permit for Concrete Batch Plants.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 emissions from plant material handling operations are as
follows:
Baghouse / Fabric Filter;
Best Management & Operational Practices;
Cyclone;
ESP;
Enclosure;
Water Application (Watering); and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
With the exception of water application, all options are technically feasible. Water application is
eliminated as clinker exiting the kiln along with additives in the finish mill must remain dry to
maintain product quality. Therefore, it is technically infeasible to water material in the finish mill.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Enclosure 50-90%
5. Cyclone 20-70%
6. Best Management & Operational Practices varies

Step 4 - Evaluate Most Effective Controls and Document Results
Baghouses provide the highest emission control efficiency, controlling up to 99.9% of PM
emissions from finish mill equipment. After baghouses, using a wet scrubber or ESP provides
similar PM control. Notably, baghouses, scrubbers, and ESPs require enclosures to aid in capturing
emissions and ducting to the control. Therefore, optimal PM emission control can be achieved
through implementing both baghouses and enclosures where feasible. Plant material sizing and
handling is currently done using a series of buildings and enclosures routed to baghouse controls.
Various silos storing material inputs are also equipped with fabric filters. As the highest ranked
technology is applied, there are no adverse energy, environmental or cost impacts to consider with
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the use of these control technologies. Thus, no further analysis is required under EPA's top-down
BACT approach.

Step 5 - Select BACT
BACT for finish mill PM10 emissions is compliance with NSPS Subpart F, Standards of
Performance for Portland Cement Manufacturing where applicable. Ash Grove will achieve BACT
for PM10 emissions from finish mill equipment through the implementation of enclosures,
baghouses, and best management practices. All baghouses at the finish mill will have a 10%
opacity limitation and a grain loading of 0.005 grains/dscf. [Last updated January 14, 2025]

5. BACT review regarding PM10 and PM2.5 sources cont.
Material Transfer, Sizing, and Storage BACT
The Leamington Plant has sources of fugitive emissions through raw material transfer. Materials
transferred include limestone and other raw materials, coal, clinker, and cement. These materials
are transferred by conveyor belt, screw conveyor, elevator, pneumatic conveyance or chutes via
gravity. At the Leamington Plant the fugitive emissions are enclosed at their transfer points and
routed to baghouses.

The following emission units are included in this category:
Limestone Crushing, Sizing, and Material Transfer;
Raw Material Transfer;
Coal Sizing and Transfer;
Existing Finish Mill;
Clinker Storage and Transfer;
Cement Storage and Truck and Rail Cement Loadout;
New Rail Loading and Loadout; and
New Clinker Reclaim Hopper Baghouse.

Generally, controls for these units have not changed or they are similar to current existing controls.
A full BACT analysis of each unit is included in Ash Grove's NOI and additional submitted
information. However, given that most controls remain unaltered, only the results of Step 5 -
Select BACT will be included here.

Limestone Crushing, Sizing, and Material Transfer
Subject to NSPS Subpart OOO opacity limits for existing sources.
Existing baghouses. No change from bag manufacturer's specifications.

Raw Material Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Coal Storage and Transfer
Existing Equipment. No change from bag manufacturer's specifications
20% Opacity

Clinker Storage and Transfer
Subject to NSPS Subpart F opacity limits:
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10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Existing Finish Mill Grinding, Storage and Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Cement Storage and Truck and Rail Cement Loadout, New Rail Loadout
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

New Rail Loadout, controlled by baghouse
Emissions Limit - 0.005 gr/dscfm

New Clinker Reclaim Hopper, controlled by baghouse
Subject to NSPS Subpart F opacity limits:
10% opacity
Emissions Limit - 0.005 gr/dscfm [Last updated January 14, 2025]

6. BACT review regarding PM10 and PM2.5 sources cont.
PM10 and PM2.5 Fugitive Emissions
The following fugitive emissions sources will increase emissions of PM10 and PM2.5 as a result of
the Leamington Plant's proposed throughput increase. The sources addressed in the following
BACT analyses are primarily in the quarry, but also include emissions from roads and dumping of
raw materials within the plant boundary.

The sources evaluated are listed below:
Roads;
Loading and Unloading;
Stockpiles;
Bulldozing and Grading;
Disturbed Areas; and
Drilling and Blasting.

Ash Grove currently controls emissions from these processes, and generally, controls for these
units have not changed. A full BACT analysis of each unit is included in Ash Grove's NOI and
additional submitted information. However, given that most controls remain unaltered, only the
results of Step 5 - Select BACT will be included here.

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
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Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

Stockpiles BACT
BACT shall consist of restricting fugitive emissions to the opacity standard of 20% opacity at the
property boundary. BACT for stockpiles will be achieved through applying good management
practices through its fugitive dust plan as appropriate.

Bulldozing and Grading BACT
BACT shall consist of restricting fugitive emissions from bulldozing and grading activities to no
more than 20% opacity, and that emissions are controlled with periodic watering of the disturbed
surface. The frequency of water application will depend on ambient weather conditions and
inherent moisture content of the material being moved.

Disturbed Areas BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. BACT for
disturbed areas will be achieved through best management practices, watering, scarification, and
revegetation.

Drilling and Blasting BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. This is achievable
through best management practices, shrouds, watering, and dust collection. [Last updated January
14, 2025]

7. BACT review regarding kiln system NOx emissions
Kiln System (Kiln, Raw Mill, and Coal Mill) - NOx BACT
Although there are physical changes to the kiln system, these changes are primarily related to
particulate emissions. NOx emissions are generated from the combustion of fuel - and no changes
in NOx emissions are expected from the kiln (hourly capacity to emit). The kiln NOx emissions will
remain the same as a result of upgrades to the SNCR system. The replacement of the various
components of the kiln system and portions of the preheater tower, along with new injection points,
will ensure that increased mixing of ammonia is achieved to enhance the SNCR system's ability to
reduce NOx and minimize ammonia slip. This will allow the Leamington Plant to maintain the NOx
hourly capacity to emit unchanged from current levels Leamington Plant Upgrade Project. At
present Ash Grove has no restriction on the amount of fuel combusted, only a limit on total NOx
generated, and with this project the allowed NOx PTE is decreasing from 1,352 tpy to 1,226 tpy.

Additional ammonia will be used in the existing SNCR system. While the SNCR system has
adequate capacity to accommodate the additional ammonia demand resulting from the system
upgrades, more ammonia ports are proposed to be added with the kiln system's proposed changes
of the equipment. The changes proposed to the kiln system will increase residence time and
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temperature which will improve the SNCR system's effectiveness to control NOx emissions and
minimize ammonia slip emissions to the atmosphere. No additional review of NOx BACT for the
kiln system is required under this proposal. [Last updated January 14, 2025]

8. BACT review regarding new finish mill heater emissions
Finish Mill Heater
The proposed finish mill will include a process heater to maintain a minimum temperature during
milling. The proposed heater will run on natural gas and is rated at 10 MMBtu/hr. Startup and
shutdown emissions from the heater are anticipated to be no greater than normal operation as the
process is simply a matter of bringing the heater to operating temperature. Emissions evaluated in
the BACT analysis for the finish mill heater include NOx, SO2, CO, and VOCs, PM10, and PM2.5.
Pollutants with identical control technologies are grouped together in the analysis.

NOx - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for NOx from units of this size range are as follows:
Ultra-Low-NOx Burners (ULNB);
Low NOx Burners;
Selective Catalytic Reduction (SCR);
Selective Noncatalytic Reduction (SNCR);
Good Combustion Practices; and
Use of Natural Gas.

Step 2 - Eliminate Technically Infeasible Options
Low exit temperatures render the use of SCR and SNCR ineffective. Particulate entrainment within
the finish mill could potentially foul (plug) the nozzles of ULNB. Low-NOx burners, the use of
natural gas as fuel and good combustion practices are all considered technically feasible.

Step 3 and Step 4 - Rank Remaining Control Technologies by Control Effectiveness and Evaluate
Most Effective Controls and Document Results
Since the three feasible control technologies are proposed for the finish mill heater, no detailed
economic, energy, and environmental impact evaluations were conducted. No ranking of control
effectiveness is required as all three controls are proposed.

Step 5 - Select BACT
BACT for NOx is the use of natural gas as fuel, good combustion practices and the use of Low NOx
burners.

CO, SO2, and VOC - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for CO, SO2, and VOC from units of this size are as follows:
Good Combustion Practices
Use of Natural Gas

The finish mill heater combusts natural gas. Related natural gas combustion emissions are
anticipated to be minimal.

Step 2 - Eliminate Technically Infeasible Options
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Both control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Both technologies offer intrinsic emission reductions from combustion. Since the technologies do
not compete, both technologies can and will be used simultaneously.

Step 4 - Evaluate Most Effective Controls and Document Results
Because both control technologies identified in Step 1 are proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for CO, SO2, and VOC are good combustion practices and the use of natural gas.

PM10 and PM2.5 BACT for the finish mill has been addressed in the PM10/PM2.5 sources section.
[Last updated January 14, 2025]

9. BACT review regarding SO2, VOC, and Lead Sources
The following BACT analysis is grouped by pollutants that will experience an increase in potential
emissions and the associated technically feasible control technologies. As such, the BACT analysis
is separated into SO2, VOC, and lead respectively with organic HAPs addressed with VOCs.

SO2 - Cement Kiln BACT
NSPS Subpart F - Standards of Performance for Portland Cement Plants, establishes emission
standards for cement kiln operations. Specifically, kilns constructed or reconstructed after June 16,
2008, are limited to 0.4 lbs SO2/ton clinker on a 30-day rolling average respectively. This limit is
an existing emission limit in the Leamington Plant's approval order and Title V. Ash Grove will
continue to achieve this emission limitation while achieving BACT for the kiln operations. Ash
Grove has reviewed the following sources to identify available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019); and

NSPS Subpart F as an affected emissions facility in 40 CFR 60.62(a)(4);

Portland Cement Association's Formation and Techniques for Control of Sulfur Dioxide and Other
Sulfur Compounds in Portland Cement Kiln Systems.

SO2 emissions are a result of oxidation of sulfur compounds in the rawmix and/or the coal used to
fire the kiln. However, the alkaline nature of the cement provides for direct absorption of SO2 into
the product, thereby mitigating the quantity of SO2 emissions in the exhaust stream.

Step 1 - Identify All Control Technologies
Control technologies identified for SO2 emissions from coal-fired kiln operations are as follows:
Baghouse or fabric filter;
Dry reagent injection prior to baghouse;
Wet scrubber;
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Process optimization; and
Good combustion practices.

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below:

1. Process Optimization 99%
2. Wet Scrubber 99%
3. Dry Reagent Injection 60%
4. Good Combustion Practices 30%
5. Baghouse Variable

Step 4 - Evaluate Most Effective Controls and Document Results
SO2 emissions are most effectively controlled by optimizing the process and utilizing the inherent
SO2 scrubbing properties of the kiln system itself. Although wet scrubbers alone can achieve equal
control efficiencies as process optimization, additional capital and operational expenses are
required for water consumption and wastewater discharge. Whereas process optimization achieves
the same control effectiveness and has the added benefit of reduced operational costs. Ash Grove
optimizes the kiln process by routing the exhaust from the kiln to a preheater and raw mill to
interact with the raw mix, thus creating an atmosphere similar to a dry scrubber system. Good
combustion practices also reduce SO2 formation with the added benefit of energy efficiency.

Step 5 - Select BACT
BACT for control of SO2 emissions from kiln operations shall consist of process optimization by
routing kiln exhaust to the preheater and raw mill, good combustion practices, and use of a
baghouse prior to exhausting to the atmosphere. As a modification of the kiln, 40 CFR 60.62(a)(4)
requires an emission limit of 0.4 pounds of sulfur dioxide (SO2) per ton of clinker on a
30-operating day rolling average. [Last updated January 14, 2025]

10. BACT review regarding SO2, VOC, and Lead Sources cont.
VOC - Cement Kiln BACT
VOCs are generated by incomplete combustion in the kiln. 40 CFR 63 Subpart LLL - NESHAP
from the Portland Cement Industry limits total hydrocarbon and total organic HAP emissions to 24
and 12 ppmv at 7% oxygen. Ash Grove will achieve or exceed these emission limitations while
achieving BACT for the kiln operations. Ash Grove has reviewed the following sources to identify
available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028); and

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for VOC emissions from coal fired kiln operations are as follows:
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Process optimization,
Good combustion practices

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below.

1. Process Optimization Variable
2. Good Combustion Practices Variable

Step 4 - Evaluate Most Effective Controls and Document Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove optimizes the
kiln process by capturing waste heat from the clinker cooler and routing to a kiln preheater. Good
combustion practices also reduce VOC formation with the added benefit of energy efficiency.
There are no adverse energy, environmental or cost impacts to consider with the use of this control
technology.

Step 5 - Select BACT
BACT for control of VOC emissions from kiln operations shall consist of process optimization by
routing kiln heat to the preheater and good combustion practices. An emission limit of 24 ppmv
VOC @ 7% O2 is imposed by NESHAP Subpart LLL.

VOC - Grinding Aid BACT
A grinding aid containing VOC is added to the new finish mill to disperse particles within the mill
and expose more surface area to grinding. An increase in grinding aid usage proportionally
increases potential VOC emissions because volatiles from the grinding aid are not combusted in
the kiln.

There is only one identified control option for limiting the VOC emissions from the grinding aid.
Process optimization is technically feasible. VOC emissions are most effectively controlled by
optimizing the process. Ash Grove proposes to install a vertical finish mill with this project. Due to
the new modern mill's efficiency, it is anticipated that a reduced amount of grinding aid will be
required for each ton of clinker ground. Ash Grove estimates total VOC emissions from the
grinding aid at 2.37 tpy.

Lead Emissions
The lead emissions are anticipated to increase as a result of the proposed increase in clinker
throughput with the Leamington Plant upgrade project. Lead emissions result from residual
amounts of lead in raw materials and fuel. Lead emissions will be controlled the same as PM,
therefore a separate top-down BACT analysis has not been conducted as the Leamington Plant has
applied the most effective controls. [Last updated January 14, 2025]

11. BACT review regarding Greenhouse Gases
GHG Background
On October 9, 2009, the mandatory GHG reporting regulation, referred to as 40 CFR 98, was
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Page 20

published in the Federal Register. Through 40 CFR 98, the U.S. EPA established the GHG
Reporting Rule, which requires the annual reporting of GHG data and other relevant information
from large sources and suppliers in the United States. Monitoring through the GHG Reporting
Program (GHGRP) began in 2010, with the first reports due by March 31, 2011. Per 40 CFR
98.2(a)(1), any facility associated with cement production is subject to the GHGRP and must report
CO2e emissions. The CO2e is the sum of equivalent GHG emissions from CO2, CH4, and N2O,
with their respective global warming potentials (GWP) applied. Ash Grove's facility is subject to
GHG Reporting Rule and monitors CO2 emissions from its kiln with a continuous emissions
monitoring system (CEMs). On June 23, 2014, the U.S. Supreme Court held that required PSD
permits (based on emissions of non-GHG pollutants) may continue to require limitations on GHG
emissions based on the application of BACT as an "anyway source". The Leamington Plant
modification project is a major source for PSD for both PM10 and PM2.5, and GHGs are estimated
to be greater than 75,000 tpy and greater than zero on a mass basis; therefore, GHGs are evaluated
for BACT as an anyway source.

Cement Manufacturing GHG BACT
A BACT analysis has been conducted for CO2e emissions from the kiln system. For this GHG
BACT analysis, various control technologies or combinations of technologies were identified using
the RACT/BACT/LAER Clearinghouse, available literature including guidance published by EPA
and South Coast Air Quality Management District (SCAQMD), current air regulations, other
regulatory organizations, and engineering experience. In March 2011, EPA published GHG
permitting guidance, as well as a white paper on available and emerging technologies for reducing
GHG emissions from the Portland cement industry in October 2010. Additionally, EPA published a
series of videos on GHG permit training in December 2010. The SCAQMD published GHG BACT
guidance in 2021. Additional sources of information were reviewed and documented based on
publications from trade organizations and other governmental committees with GHG or carbon
reduction guidelines and/or recommendations.

EPA has defined in 40 CFR 86.1818-12(a) GHGs as a group of six gases: CO2, nitrous oxide
(N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF6). GHG emissions from the kiln result from calcination and fuel combustion.
Since the primary GHG emitted by a kiln is CO2, the BACT analysis focuses on CO2 emissions
from the kiln. Emissions of CH4 and N2O are minimal from cement kilns. Per EPA guidance, GHG
control technologies for consideration in a BACT analysis for Portland Cement Manufacturing
include:

Source-wide energy efficiency strategies;
Raw material substitution;
Blended cements;
Carbon capture utilization and storage; and
Fuel switching.
Other emerging technologies [Last updated January 14, 2025]

12. BACT review regarding Greenhouse Gases cont.
Step 1: Identify All Control Technologies
The CO2 emissions from a cement kiln are generated by the calcination process (conversion of the
calcium carbonate in limestone to calcium oxide) and by combustion of fuel in the kiln. Potential
control technologies to reduce these CO2 emissions for a cement kiln are addressed in EPA's white
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paper on Available and Emerging Technologies for Reducing GHG Emissions from the Portland
Cement Industry.

These technologies fall into three categories:
Energy Efficiency Improvements for the Clinker Production Process
Fuel Substitution
Carbon Capture and Sequestration

Step 2: Eliminate Technically Infeasible Options
Several potential energy efficiency improvements are technically feasible: Pre-heater/Pre-calciner
Kiln Process, Kiln Seal Management Program, Refractory Selection (Kiln Insulation), and Energy
Recovery from the Clinker Cooler. The use of alternative fuels such as natural gas, whole tires and
biofuel) is also technically feasible. Other control options, such as Use of Fluxes and Mineralizers,
Heat Recovery for Power - Cogeneration, Carbon Sequestration, Oxyfuel combustion, and
Post-combustion Capture have been deemed infeasible.

Step 3: Rank Remaining Control Technologies by Control Effectiveness
All four remaining control techniques are currently implemented at the Leamington Plant. This
permitting project incorporates energy efficiency improvements. Ash Grove has had a fuel
substitution program in place for several years, and this program is continually reviewed and
updated as new sources and types of fuel are identified.

Step 4: Evaluate Most Effective Controls and Document Results
Since all technically feasible energy efficiency improvements and changes to product composition
will be implemented, this section will focus on economic and environmental considerations of fuel
substitution to operate exclusively on natural gas.

Firing natural gas as the primary kiln fuel can reduce CO2 emissions from fuel combustion by as
much as 40%. However, studies have shown that use of natural gas as primary kiln fuel can result
in three times more NOx emissions than NOx emissions from coal firing. Creating more NOx to
reduce GHG emissions is undesirable as it is a precursor to both ozone and PM2.5. Fuel substitution
essentially trades emissions of one regulated pollutant for another. Estimated capital cost to switch
to natural gas fuel exceeds $25M. Implementing natural gas technology would provide incremental
public health and welfare benefit globally by reducing CO2 emissions, while increasing NOx
emissions and negatively impacting public health and welfare locally. Switching fuels to another
fossil fuel has finite potential to mitigate CO2 emissions.

Step 5: Select BACT
In addition to the proposed energy efficiency improvements addressed elsewhere in this BACT
analysis, BACT is a limit of 0.92-ton CO2e/ton clinker. Ash Grove will use a continuous emission
monitoring system (CEMS) for CO2 to demonstrate compliance with this limit. [Last updated
January 14, 2025]

13. BACT review regarding Leamington Plant Upgrade Project conclusion
The control processes and techniques covered in this BACT analysis have been reviewed by the
NSR Section of the UDAQ. Ash Groves proposed controls and associated emission limitations
represent BACT. Any emission limitations not expressed in an associated NSPS or NESHAP will
be included in the terms and conditions of this AO. A listing of all associated NSPS and NESHAP
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programs is also included in the Source Information section of this document under Applicable
Federal Programs. [Last updated December 13, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date
of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
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proper credit when notifying the Director, send the documentation to the Director, attn.: NSR
Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.

II.A.3
NEW
Stockpiles
Coal storage
Area: 1 acre
Annual throughput 20,000 tpy

AF and ARM stockpiles
Area: 0.25 acre
Annual throughput 8,000 tpy

II.A.4 Stationary Crusher
Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction
of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000
acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)

II.A.5 Raw Material Transfer
Crushed material is transported to raw material storage by belt B8. The raw material transfers
at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor
transfer point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total
filter area & water sprays. (pre-1983)

II.A.6 Material Handling
Conveyor belt systems, secondary feeders and screens, stacker system

II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit specific requirements

II.A.8 Belt Conveyor Transfer Baghouse
Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area
and 1,800 acfm total air flow, controls emissions from the conveyor belt that transfers the
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stacked material to the raw material silos.

II.A.9 Raw Material Silos
Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The
four silos are equipped with one common Fuller, plenum pulse baghouse (315.BF1) - 1,689 ft2
filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage).

II.A.10 Fifth Component Silo
Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse
(315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw
mill feed. This system includes vibrating feeders, a conveyor system, and surge bin.
Emissions are controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3,
316.BF4, 316.BF5) - each is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1
A/C ratio.

II.A.12 Cross-Belt Analyzer
Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6)

II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom
of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw
materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38).
The following equipment is installed: low-NOx burner, selective non-catalytic reduction
(SNCR) for NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued
mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric
monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct
for mercury adsorption capacity. The carbon injection system is not an emission point as it is
in an enclosed building.

II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

II.A.16 Two Kiln Feed Blending Silos
Raw material is blended in one of two blending silos prior to feeding the kiln. The blending
silos are controlled by one common Fuller, plenum pulse baghouse (411.BF1) - 1,351 ft2 filter
area; 7,160 acfm total air flow.

II.A.17 Blending Silo Elevators (2)
Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped
with a Fuller, pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow
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through stack E34.

II.A.18 Kiln Feed Alleviator
A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the
central material silo between the blending silos and the preheater. Raw feed is removed from
the system near the top of the preheater tower.

II.A.19 Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner.
The coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter
area; 1,700 acfm total air flow.

II.A.20 Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in
the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2):
19,500 acfm rated airflow with 3.75:1 A/C ratio

II.A.21 Clinker Cooler and Baghouse
Reconstructed grate type cooler used for cooling clinker from the kiln prior to transfer to
clinker storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) -
173,869 acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter
monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two
clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse
(419.BF8). The exhaust is routed to the clinker cooler stack.

II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions
generated when loading the east and west clinker silos and the out-of-spec silo are controlled
by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1):
1,800 acfm, that discharges into the clinker tunnel.

II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm, that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2)
Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers.
Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses
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(511.HP1 and new 511.HP2): 1,800 acfm each.

II.A.27 Gypsum Silo
Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2
total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust
during loading.

II.A.28 Clinker Tunnel Exitway
The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse
(511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel all discharge in the clinker tunnel.
Emissions are vented through the tunnel exitway.

II.A.29 Limestone Silo
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust
during loading. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement product. Dust
generated during milling is captured by a BHA, pulse jet baghouse (514.BF2) - 6,080 ft2 filter
area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding
stack).

II.A.31 Finish Mill (Ball Mill) Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized
cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA, pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow
controlling particulates from stack G55 (finish mill stack).

II.A.32
NEW
Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The
stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4)
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1,
525.BF1 thru 3)

II.A.33 Finish Cement Storage Silos
There are six storage and two interstice silos where the finished cement product is stored. A
single common Fuller, plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm
total air flow through stack H7 is located on top of the silos and is used to control emissions
during loading and unloading operations.

II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail
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shipping. This baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out
The cement loadout system located on the South side of the silos (truck load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF2) during unloading from the silos for truck
shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement
conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed
space inside the silos.

II.A.36
NEW
Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

II.A.37 MHO: Materials Handling Operation
Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1
& 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4;
512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.

II.A.38 LBS: Limestone Bypass System
Additional limestone is added to the clinker and gypsum by the limestone bypass system
(LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays
at the screen and material handling drop points.

II.A.39 GEN: Emergency Generators
One diesel-fired emergency generator (new)
Rating: 762 hp
(Kiln, Tier 3, permitted 2022)

Two natural gas-fired emergency generators
Rating: 304 hp
(Main office and control room, permitted in 2023)

One diesel-fired emergency generator
Rating: 560 hp
(Shipping, permitted 2023).

II.A.40 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14 inch knife gate, 8 inch knife gate, 8 inch air
slides, surge bin), and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm)
on the fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

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II.A.41
NEW
Miscellaneous Storage Tanks
One diesel storage tank (<2,000 gallons)
One gasoline storage tank (500 gallons)
Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Requirements on the Cement Plant:
II.B.1.a
NEW
The following limits shall not be exceeded:

A. Clinker production - 1,155,000 tons per rolling 12-month period

B. Used oil consumption - 85,724 gallons per rolling 12-month period

C. Limestone bypass material processed - 216,260 tons per rolling 12-month period.
[R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 25th day of each month using data from the previous 12 months.
Records shall be kept for all periods when the plant is in operation. Consumption and
production shall be calculated through use of the plant's acquisition system. [R307-401-8]

II.B.1.b
NEW
Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations:

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

SO2: 0.4 lbs per ton of clinker (3-hr average)

CO: 3,395 tons per rolling 12-month period, and 6,600 lbs/hr

NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average, and 1,233 tons per rolling
12-month period

Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is
400oF or less.

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Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)

THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)

CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)

PM: 0.02 lbs filterable PM per ton of clinker. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL,
R307-401-8]

II.B.1.c
NEW
A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR
60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust
emissions control plan shall be monitored to demonstrate that appropriate control measures are
being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of
the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall
be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in
the plan and that the source is operating in accordance with the submitted plan. For petitions
to approve alternative control measures, the permittee shall keep a copy of the submitted
petition and any approvals received. [40 CFR 60 Subpart Y]

II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area
source of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2). [40 CFR
63 Subpart LLL]

II.B.1.e
NEW
Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b
and II.B.1.d shall be performed as specified below:

A. Kiln/Raw Mill Stack
Pollutant Test Status Test Frequency
PM * #

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

B. Clinker Cooler (F31)
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Pollutant Test Status Test Frequency
PM + #

C. Testing Status (To be applied above)
* The initial testing has already been performed.

** The SO2 initial performance test was conducted on August 26, 2013.

*** The initial compliance test shall be conducted within the first 30 operating days of
operation in which the affected source operates using a CEMS.

# Test once every year. If performance testing would be required less than 15 operating days
after the Kiln has completed Startup after being down for more than 24 hours, then
performance testing may be deferred up to 15 operating days after completion of the Startup.
The Director may require testing at any time.

## Test at least once every two years. The Director may require testing at any time.

+ Initial testing is required within 180 days of startup of the reconstructed equipment

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must record the PM
CPMS output data for all periods when the process is operating, and use all the PM CPMS
data for calculations when the PM CPMS is not out-of-control. The owner/operator must
demonstrate continuous compliance by using all quality-assured hourly average data collected
by the PM CPMS for all operating hours to calculate the arithmetic average operating
parameter in units of the operating limit on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

+++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.e.1
NEW
Notification
The Director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The notification requirements for performance tests subject to 40
CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-165]

II.B.1.e.2
NEW
Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational
Safety and Health Administration (OSHA)- or Mine Safety and Health Administration
(MSHA)-approved access shall be provided to the test location. [R307-165]

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II.B.1.e.4
NEW
PM
40 CFR 60, Appendix A, Method 5 or 5I or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three (3) runs with
each run at least 120 minutes in duration and each run collecting a sample of 60 dry standard
cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.3
NEW
Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2. [R307-165]

II.B.1.e.5
NEW
Carbon Monoxide (CO)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.6
NEW
Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.7
NEW
Sulfur Dioxide (SO2)
40 CFR 60, Method 6 or 6C of Appendix A-4 or other EPA-approved method as acceptable to
the Director. [R307-165]

II.B.1.e.8
NEW
Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]

II.B.1.e.9
NEW
Total Hydrocarbons (THC)
Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL]

II.B.1.e.10
NEW
Mercury (Hg)
Continuous Emission or integrated sorbent trap monitoring (See Condition II.B.3.a). [40 CFR
63 Subpart LLL]

II.B.1.e.11
NEW
HCl
Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other
EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]

II.B.1.e.12
NEW
Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.13
NEW
Calculations
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director, to give the results in the specified units of the
emission limitation. [R307-165]

II.B.1.e.14
NEW
Existing Source Operation
For an existing source/emission point, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three years.
[R307-165]

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II.B.1.e.15
NEW
New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the maximum production rate listed in this AO. If the maximum AO
allowable production rate has not been achieved at the time of the test, the following
procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This new
allowable maximum production rate shall remain in effect until successfully tested at a higher
rate.

3) The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate (110%
of the new rate) will then be allowed if the test is successful. This process may be repeated
until the maximum AO production rate is achieved. [R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL.
[40 CFR 63 Subpart LLL]

II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times
of Dust Shuttle System operation to assist in the capture of Mercury emission. [R307-401-8]

II.B.1.h
NEW
Visible emissions from the following emission points shall not exceed the following values:

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

L. All baghouses - 10% opacity
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M. Fugitive dust - 20% opacity

N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y,
R307-401-8]

II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer
point is not required to conduct Method 22 visible emissions monitoring under this paragraph.
The enclosures for these transfer points must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

If any partially enclosed or unenclosed conveying system transfer point is located in a
building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to
40 CFR 60, according to the following:

(i) The owner/operator must conduct a monthly ten-minute visible emissions test of each
affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The
performance test must be conducted while the affected source is in operation.

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator may decrease the frequency of performance testing from monthly
to semi-annually for that affected source. If visible emissions are observed during any
semi-annual test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iii) If no visible emissions are observed during the semi-annual test for any affected source,
the owner/operator may decrease the frequency of performance testing from semi- annually to
annually for that affected source. If visible emissions are observed during any annual
performance test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iv) If visible emissions are observed during any Method 22 performance test, of Appendix
A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations,
recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60.
The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour
of any observation of visible emissions.

(v) If visible emissions from a building are monitored, the requirements of paragraphs (i)
through (iv) of this Condition apply to the monitoring of the building, and the owner/operator
must also test visible emissions from each side, roof, and vent of the building for at least ten
minutes. [R307-401]

II.B.1.j
NEW
Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed
0.005 gr/dscf:

520.BF1
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520.BF2
520.BF3
520.BF4
521.BF2
521.BF1
524.BF1
524.BF2
524.BF4
524.BF3
525.BF1
525.BF2
525.BF3
511.HP2
NRL_UPR
NRL_LWR. [R307-401-8]

II.B.1.j.1
NEW
To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration
through at least three (3) annual tests that the PM limits are not being exceeded, the
owner/operator may request approval from the Director to conduct stack testing less
frequently than annually. [R307-401-8]

II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive
dusts as dry conditions warrant or as determined necessary by the Director to maintain opacity
limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated to control fugitive dust. The application of
water or chemical treatment shall be used. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a damp/moist condition unless it is below freezing.
If chemical treatment is to be used, the plan must be approved by the Director. Records of
water and/or chemical treatment shall be kept for all periods when the plant is in operation.
The records shall include the following items: Instances of water and/or chemical application
to unpaved areas shall be recorded and maintained by the owner/operator. The ambient
temperature shall be recorded any time water should be applied but cannot due to freezing
conditions. [R307-401-8]

II.B.2.c
NEW
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

The sprays shall operate whenever dry conditions warrant meeting the required opacity
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limitations or as determined necessary by the Director. Water sprays shall not be required
during periods of freezing temperatures. [R307-401-8]

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation
of fugitive dusts as dry conditions warrant or as determined necessary by the Director.
[R307-401-8]

II.B.2.e
NEW
The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5
PM. [R307-401-8]

II.B.3 Continuous Emission Monitoring Requirements:
II.B.3.a
NEW
The owner/operator shall install, calibrate, maintain and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler.

A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the
missing data substitution procedures used by the UDAQ or the missing data substitution
procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate by the UDAQ.

B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period
including during each startup, shutdown, or malfunction.

C. The monitoring system shall comply with all applicable sections of R307-170, UAC; and
40 CFR 60, Appendix B.

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be
installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the
kiln/raw mill stack.

F. The owner/operator shall record the output of the system: including the quantity of NOx,
CO, O2 THC, Hg, HCl, and CO2 emissions at the kiln stack.

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source shall
continuously operate all required continuous monitoring devices and shall meet minimum
frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker
cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except
during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments,
the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a
PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the
results of the performance test demonstrating compliance with the filterable PM limit and
using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust
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the SSOL developed in accordance with the results of the most recent PM performance test
demonstrating compliance with the PM emission limit. The owner/operator shall use the PM
CPMS to demonstrate continuous compliance with the SSOL in accordance with the
requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

II.B.4 Fuel Limitations:
II.B.4.a
NEW
The owner/operator shall use only the following fuels in the kiln and pre-calciner:

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.

If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b
NEW
Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the
Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the
results of suitable tests giving data similar to a Proximate and Ultimate analysis of the
proposed coal additive. [R307-401-8]

II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal
additive. Approval is not required to change from one previously-approved coal additive to
another previously-approved coal additive. [R307-401-8]

II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily
heat input of the kiln and precalciner. The owner/operator may increase the average quantity
of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon
approval by the Director in accordance with the approval process described in Condition
II.B.4.b. [R307-401-8]

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II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel burning or process
installation not covered by New Source Performance Standards for sulfur emissions or
covered elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross
Btu heat input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input
for any oil except used oil. The sulfur content shall comply with all applicable sections of
UAC R307-203. [R307-203, R307-401-8]

II.B.4.c.1
NEW
Certification of fuels shall be either by the owner/operator's own testing or test reports from
the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be
available onsite. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials, UAC R307-203-1 (4)

A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be
used.

B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be
used.

C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85 are to be used. [R307-203]

II.B.4.d
NEW
The concentration/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight
3) Cadmium 2 ppm by weight
4) Chromium. 10 ppm by weight
5) Lead 100 ppm by weight
6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be
tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the burn tank and burned. [R307-401-8]

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II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned
in the rotary kiln:

A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than
five minutes in any 60-minute period

B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes
in any 60-minute period. [R307-401-8]

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the
Director. The calibration procedure and frequency shall be according to manufacturer's
specifications. Use of factory-calibrated thermocouples for temperature measurement is
approved. However, any other method of temperature measurement must be approved by the
Director prior to use. The monitoring equipment for both temperature and oxygen content
shall be located such that an inspector can at any time safely read the output. [R307-401-8]

II.B.5
NEW
Emergency Engine Requirements
II.B.5.a
NEW
The owner/operator shall only operate the emergency engines for testing and maintenance
purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency
operation. [R307-401-8]

II.B.5.b
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each emergency engine. [R307-401-8]

II.B.5.b.1
NEW
The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.5.b.2
NEW
To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN103030035-24 dated November 27, 2024
Is Derived From Source Submitted NOI dated November 30, 2022
Incorporates Additional Information Received dated April 26, 2023
Incorporates Additional Information Received dated September 26, 2023
Incorporates Additional Information Received dated July 23, 2024
Incorporates Additional Information Received dated October 25, 2024
Incorporates Additional Information Received dated November 25, 2024

REVIEWER COMMENTS

1. Comment regarding applicability of federal requirements:
New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable
by the best demonstrated technology as specified in the applicable provisions. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.

40 CFR 60, Subpart A (General Provisions)
All affected facilities subject to a source-specific NSPS are subject to the general provisions of
NSPS, Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires
initial notification, performance testing, recordkeeping, and monitoring, provides reference methods,
and mandates general control device requirements for all other subparts.

40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of
performance for affected facilities in Portland Cement Plants which have been constructed or
modified after August 17, 1971.

40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart
F: Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and
unloading systems. The Leamington coal mill is an in-line coal mill and considered an integral part
of the Leamington kiln. In-line coal mills are not subject to NSPS Subpart Y. Therefore, the coal mill
is addressed under NSPS Subpart F as part of the kiln system. The coal silos and conveying system
are subject to NSPS Subpart Y.

Ash Grove's proposed changes to the kiln system must be evaluated as to whether they trigger new
NSPS Subpart F obligations based on whether the proposed project is either a modification or a
reconstruction, as those terms are defined in NSPS Subpart A.

Ash Grove's proposed changes to the kiln system do not meet the definition of a reconstruction, nor
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Page 40

do they meet the definition of a modification for NOx. However, the changes meet the definition of a
modification for PM and SO2. Therefore, Ash Grove will comply with all relevant emission
standards; testing requirements; monitoring, recordkeeping, and reporting obligations that apply to
the Leamington kiln system as an existing source under NSPS Subpart F. Under NSPS Subpart A
and F, the clinker cooler is considered a reconstructed unit. Thus new limits will apply to this unit.
[Last updated January 14, 2025]

2. Comment regarding applicability of federal requirements cont.:
NSPS Subpart Y - Standards of Performance for Coal Preparation and Processing Plants
This subpart provides standards of performance for affected facilities in coal preparation and
processing plants that process more than 200 tons of coal per day.

The Leamington plant's coal silo and coal conveying system are existing affected facilities under
NSPS Subpart Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses
controlling affected facilities subject to match the limit in NSPS Subpart Y from 0.016 gr/dscf to
0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade Project. Since there are no proposed
modifications or reconstruction to the coal silo and coal conveying system, nothing about the
proposed upgrade project affects the existing applicability of NSPS Subpart Y.

NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
This subpart provides standards of performance for affected facilities located at fixed or portable
nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August
31, 1983, with additional requirements applicable to sources constructed on or after April 22, 2008.

As the crushing and screening system is controlled by baghouses and an increase in PM10 actual
emissions on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS.
Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the
Leamington Plant Upgrade Project.

Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1),
60.676(f), and 60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO
monitoring and recordkeeping requirements.

[Last updated January 14, 2025]

3. Comment regarding applicability of federal requirements cont.:
National Emission Standards for Hazardous Pollutants (NESHAPs)
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or
greater than 10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as
specified by each subpart. NESHAP apply to sources in specifically regulated industrial source
classifications (CAA Section 112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities
not regulated as a specific industrial source type. The Ash Grove Leamington Plant is a major source
of HAPs and thus is subject to certain NESHAP standards.

Subpart A - General Provisions
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All affected sources are subject to the general provisions of Subpart A unless otherwise specified by
the source-specific NESHAP. Subpart A generally requires initial notification and performance
testing, recordkeeping, monitoring, provides reference methods, and mandates general control device
requirements for all other subparts as applicable.

Subpart LLL - Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry
This subpart establishes process/source specific emission limits for PM, VOC (expressed as total
hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and
gaseous HAP compounds by limiting PM and THC emissions because portions of such emissions
are USEPA-listed HAPs. Subpart LLL requires compliance with applicable emissions limits on and
after the initial startup of cement production. To further reduce emissions, Subpart LLL also
establishes operational requirements for the use of cement kiln dust (CKD), fly ash, fuel and control
equipment. Subpart LLL also specifies process/source specific emissions testing, monitoring,
recordkeeping, reporting, and compliance demonstration requirements. The compliance requirements
for the site are detailed in Approval Order Condition II.B.1.b. Ash Grove will continue to comply
with the requirements of Subpart LLL to demonstrate compliance. This cement kiln will remain an
existing source with respect to the kiln emission standards in Subpart LLL as this project does not
trigger the definition of a new source in Subpart LLL. New source standards apply only to affected
sources that were constructed or reconstructed after May 6, 2009.
[Last updated December 20, 2024]

4. Comment regarding PSD applicability analysis:
Ash Grove is proposing to increase the throughput of limestone from the quarry to supply the New
Finish Mill to increase the amount of low-carbon cement from the Leamington Plant. Additionally,
along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
modified, and the clinker cooler will be reconstructed. These changes are anticipated to result in an
increase in clinker production. Emission calculations for this project have been completed assuming
an increase in clinker production capacity while utilizing current fuel types. This will result in an
increase in the throughput of fuel.

The Leamington Plant is considered an existing major source under PSD based on potential
emissions of PM10, PM2.5, NOx, CO, SO2, and CO2e. If a major source undergoes a physical or
operational change, the facility must determine whether the project will be considered a major
modification. Per 40 CFR 52.21(b)(2)(i), in order to be a major modification, the project must result
in a significant emissions increase, and a significant net emissions increase.

As defined at 40 CFR 52.21(b)(40): Significant emissions increase means, for a regulated NSR
pollutant, an increase in emissions that is significant for that pollutant. Significant is further defined
to mean, in reference to a net emissions increase or the potential of a source to emit any of the
following pollutants, a rate of emissions that would equal or exceed the values outlined in 40 CFR
52.21(b)(23). If the increase in emissions from the project are not significant, a major modification
has not occurred.

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
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increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

For all pollutants, the project emissions increase was calculated as the difference between the
projected actual emissions (PAE) after the proposed project and the actual emissions prior to the
project (baseline actual emissions or BAE).

Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
". . . projected actual emissions means the maximum annual rate, in tons per year, at which an
existing emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years
(12-month period) following the date the unit resumes regular operation after the project, or in any
one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit of that regulated NSR pollutant and full utilization of the unit would
result in a significant emissions increase or a significant net emissions increase at the major
stationary source." [Last updated January 14, 2025]

5. Comment regarding PSD applicability analysis cont.:
Ash Grove estimates that the projected actual production capacity following the project will be
1,155,000 tons of clinker per year and 1,341,266 tons of limestone per year. These capacities were
used to calculate projected actual emissions from the project using representative emission factors.
Additionally, to estimate emissions from material transfer baghouses, the actual flow rates and actual
projected hours were used as a basis for projected actual emissions.

Project Emission Calculations

Project emission increases from the kiln and coal mill systems are calculated for all criteria
pollutants based on emission factors that are derived from stack testing, CEMS data, or emission
factors (i.e., VOCs and Lead), and the associated projected incremental clinker increase.

NOx emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain
hourly capacity to emit and annual potential to emit at current levels. The kiln's NOx emissions rate
will not change as a result of the physical modifications proposed by the project.

Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission
factor and multiplied by the incremental increase in clinker production. The emission factor was
selected based on the average of the 24-month consecutive month emissions for 2020 and 2021. The
CO emissions will increase.

The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing
conducted at the plant. The SO2 emissions will increase.

VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production. VOC emissions will increase.

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
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Page 43

can be found in the original NOI and subsequent addendums submitted to UDAQ.

As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from
the proposed project, each increase of emissions from both existing and new sources shall be
summed together and compared to the PSD permitting thresholds. The increase of emissions is the
"positive" difference between the projected actual emissions and baseline actual emissions (projected
minus baseline).

New Emissions Sources

The actual to projected actuals calculation is not available to new emission units. For new emission
units, the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected
emissions are based on the new sources' potentials to emit. (40 CFR § 52.21(a)(2)(iv)(f)).

The new equipment proposed includes the New Finish Mill, a new rail and truck loading/loadout,
one (1) new clinker reclaim loading hopper with a dust collector and one (1) existing clinker reclaim
hopper with a dust collector, a new Clinker Cooler to replace the existing one, and a new kiln feed
alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions:

The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;

The finish mill heater was calculated based on its maximum firing capacity and flow rates; and

The fugitive emissions were calculated based on the projected annual throughput of the New Finish
Mill, the rail loadout, and clinker production. [Last updated January 14, 2025]

6. Comment regarding PSD applicability analysis cont.:
Existing Emission Sources

For the existing sources, the projected actual emissions are the maximum annual rates in tons per
year projected to occur during the next five (5) to ten (10) years if the existing sources' design
capacities increase. Ash Grove Leamington projected the actual emissions for the next five (5) years
based on the new kiln system producing an annual average of 3,250 tons of clinker per day.

Baseline actual emissions (BAE) are defined at 40 CFR 52.21(b)(48)(ii) as:

". . . baseline actual emissions means the average rate, in tons per year, at which the emissions unit
actually emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the 10-year period immediately preceding either the date the owner or operator
begins actual construction of the project, or the date a complete permit application is received by the
Administrator."

Ash Grove has selected to use the years 2020 and 2021 for each pollutant as the representative
baseline years.

In its NOI, Ash Grove calculated the emission increase from the project as being divided into two
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 44

phases. Phased construction projects are discussed in two sections of the federal PSD regulations -
40 CFR 52.21(j)(4) and 40 CFr 52.21(r)(2). UDAQ is not processing this project as a phased
construction project, nor did Ash Grove request such a determination. Therefore, Ash Grove
provided a summary table outlining the final change in emissions from this project:

Projected Actual Increase Compared to PSD threshold (tons per year)
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2e
BAE 76.64 39.64 1,187 6.87 3,315 55.47 641,385
PAE 203.15 113.47 1,226 45.87 3,414 72.07 1,067,984

Change in Emissions 126.51 73.83 39.00 39.00 99.00 16.59 426,598

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes

If the emissions increase is greater than the PSD significance threshold for a particular pollutant, Ash
Grove has the option of conducting a PSD review or continuing through the rest of the steps to
determine if it can "net" out of a PSD review. If the project increase is less than the PSD significant
threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant.

The change in emissions from the project exceeds the significant emission threshold for three
pollutants: PM10, PM2.5 and CO2e. Ash Grove elected to attempt to net out of a PSD major
modification for the remainder of the criteria pollutants.

Netting

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant
Upgrade Project and ends on the date the upgrade begins operation. Only PM10, PM2.5, CO2e are in
excess of SERs and therefore considered in the netting analysis.

Ash Grove estimated that the commencement of construction will be in December 2024. Therefore,
the contemporaneous period for this project is December 2019 through a projected date the project
upgrade begins operation. [Last updated January 21, 2025]

7. Comment regarding PSD applicability analysis cont.:
Contemporaneous Decreases

Ash Grove replaced an existing kiln emergency drive engine with a USEPA Tier 4 diesel engine in
2022. Concurrently, Ash Grove requested an increase in the capacity of 1L Cement. Additionally,
Ash Grove submitted a minor modification NOI air permit application on June 12, 2023, which
proposes replacing the shipping generator during the contemporaneous period. The kiln emergency
drive engine and shipping generator are both higher EPA tier ratings therefore result in decreases for
PM10 and PM2.5. These changes were approved in AO DAQE-AN103030033-24 issued March 21,
2024.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 45

Contemporaneous Increases

As stated above, the existing kiln emergency drive engine and shipping generator were permitted and
replaced in 2024. This resulted in an increase in emissions of CO2e.

The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout
in an effort to improve truck traffic at the loadout. The modification to add these dust collectors to
the loadout was included in DAQE-AN103030029-19. The baghouses are three (3) levels up in the
silos' enclosed space (approximately 40 feet). Both dust collectors vent directly into the interior of
the silo structure and are not vented into the atmosphere. Ash Grove requests to remove these
baghouses from its existing permitted emissions inventory. Therefore, these emissions have been
documented in the netting analysis as zero emissions.

Also included in DAQE-AN103030033-24 were two new natural gas-fired emergency generators
and increases in stockpiles, material handling and road emissions.

Could Have Been Accommodated Emissions

In calculating project emissions increase, USEPA allows the exclusion of existing
production/emissions rates that could have been accommodated during the baseline period. These
"could have been accommodated" emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as
follows:

". . . Shall exclude, in calculating any increase in emissions that results from the particular project,
that portion of the unit's emissions following the project that an existing unit could have
accommodated during the consecutive 24-month period used to establish the baseline actual
emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project,
including any increased utilization due to product demand growth;"

Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the
exclusion of existing production and emissions rates that could have been accommodated during the
baseline period, it has elected not to use this exclusion at this time. Therefore, calculation of the
"could have been" accommodated emissions have not been included in this application's
applicability analysis.

The increase from the project is added to the contemporaneous decreases and contemporaneous
increases. The resulting calculation is then compared to the PSD significance threshold to determine
if a significant net emissions increase has occurred. [Last updated January 14, 2025]

8. Comment regarding PSD applicability analysis cont.:
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2 e
Contemporaneous Inc. 1.61 0.45 0.41 0 0.27 0.07 51.74

Contemporaneous Dec. -1.54 -3.97 -0.48 -0.02 -0.27 -0.09 0

Change in Emissions 125.02 69.21 38.93 38.98 99.00 16.58 426,650

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 46

The results of the netting analysis conclude that both a significant emissions increase and a
significant net emissions increase in both particulates (PM10 and PM2.5) and CO2e will occur from
this project. Thus, the project must be reviewed as a PSD major modification. [Last updated January
14, 2025]

9. Comment regarding emission calculations:
This engineering review includes updated potential emission totals for both criteria and HAP
emissions. The potential-to-emit (PTE) values were calculated using updated values for clinker
produced and raw material inputs. BACT emission factors and limitations were used where
appropriate. Certain emission totals (NOx, SO2 and CO) were set based on avoiding a significant
increase in emissions. Specifically, the projected actual increase was set at just under the baseline
actual emissions + the significance level. As these emissions are monitored by CEM, UDAQ agrees
with this approach. Please see the netting analysis for further details on calculation of projected
actual increase. The NOx hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project.

CO2e emissions were calculated using the GHG emission factor calculated from 40 CFR Part 98
Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in Subpart A Table
A-1.

To calculate the PTE tons per year, the maximum hours (i.e., 8760) per year and the source's
emissions rates were multiplied with the throughputs. The potential throughputs have been updated
at UDAQ's request so that PAE is equal to PTE and represents the equipment's maximum design
potential.

Additional emission calculations based on source testing and monitoring, and EPA's compilation of
air emission factors AP-42. [Last updated January 14, 2025]

10. Comment regarding requirements for PSD review:
In addition to the permitting requirements of R307-401-5 through R307-401-8, there are additional
requirements under PSD that must be addressed:

1. Calculation of ambient air increments (40 CFR 52.12(c)), ambient air ceilings ((40 CFR 52.12(d)),
source impact analysis (40 CFR 52.12(k)), air quality models (40 CFR 52.12(l)) - these items are
addressed in the modeling memo DAQE-MN103030032-24.

2. Stack heights (40 CFR 52.12(h)) - Ash Grove's stack heights have been reviewed with respect to
good engineering practice and operate in a vertical unrestricted manner.

3. Control technology review (40 CFR 52.12(j)) - this is addressed in the BACT analysis section of
this review document.

4. Air quality analysis: preapplication analysis (40 CFR 52.12(m)) - this is covered in the PSD
applicability and netting analysis sections of this review document, ambient monitoring and
background data collection is also included in the modeling memo DAQE-MN103030032-24.

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 47

grain loading limit included in II.B.1.j.1 represents the required post-construction monitoring.
6. Source information (40 CFR 52.12(n)) - this is addressed under the requirements of R307-401-5
and was submitted by Ash Grove as part of the NOI package.

7. Additional impact analysis (40 CFR 52.12(o)) - these requirements cover soils, vegetation, growth
and visibility concerns. They are discussed in the modeling memo DAQE-MN103030032-24.

8. Federal land manager review (40 CFR 52.12(p)) - UDAQ provided initial notification to all
federal land managers upon receipt of the original NOI package. The draft permit and engineering
review will also be provided to the federal land managers 60-days prior to initiation of public
comment for their further review.

9. Public participation (40 CFR 52.12(q)) - this project will have a 30-day public comment period.

10. Source obligation (40 CFR 52.12(r)) - this requirement discusses source compliance with other
parts of the CAA, which is addressed within UDAQ's permitting rules in R307.
[Last updated January 14, 2025]

11. Comment regarding changes in equipment list:
The equipment list is being updated for clarity as well as adding new pieces of equipment. The
following changes are taking place:

The naming scheme is being updated to remove the numerical code from the unit designation. This
code generally referred to the associated control device and not to the emitting unit itself. This can
cause confusion especially when the same code was applied to multiple pieces of equipment.
Instead, the control devices (typically baghouse dust collectors) will be identified in the description
along with the appropriate numerical code.

Specific changes are as follows:

1. The kiln description has been updated

2. Clinker Cooler description has been updated to include a larger pulse jet baghouse.

3. The clinker storage silos, east and west clinker belts, clinker belt transfer and clinker tunnel have
been consolidated to avoid confusion

4. The north and south cement loadout exhausts now vent internally into the cement storage silos

5. The dust shuttle system has been consolidated into one line item, most identifiers removed from
subsystem descriptions as only two baghouses serve as exhaust points.

6. A new finish mill with heater has been added. Included in the description are the thirteen total
baghouses for dust control (1 main stack, 2 transfer points, 10 nuisance dust filters)

7. A new clinker reclaim hopper has been added. Both reclaim hoppers are controlled by baghouses
with updated identifiers

8. A new rail and truck loading/unloading system with two baghouses has been added.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 48

[Last updated December 20, 2024]

12. Comment regarding changes in conditions:
As a result of this project, several conditions will be added or changed. This includes one new
general condition (I.8). Changes to the equipment list (section II.A) will be addressed in a separate
reviewer comment:

I.8 - Adding this general condition to cover the requirements of R307-401-18 Eighteen Month
Review. The status of construction/installation of the new equipment shall be reviewed after
18-months.

II.B.1.a - Clinker production increases to 1,155,000 tpy
Use of limestone bypass material increases to 215,260 tpy

II.B.1.b - The NOx limit on the kiln decreases to 1,223 tpy, CO emissions from the kiln decrease to
3,395 tpy,
Adding a new CO2e limit of 0.92 tons CO2e/ton of clinker produced
PM limit on the clinker cooler decreased to 0.02 lb PM (filterable)/ton of clinker
Rule reference updated to include 40 CFR 60 Subpart F, and R307-401-8

II.B.1.e - Initial testing on the clinker cooler is now required within 180 days of startup of the unit.
Monitoring of CO2 from the kiln will be by CEM.
Formatting changes on paragraph designated ++, improve clarity, include reference to CO2
monitoring, define CPMS

II.B.1.e.4 - Update to address general PM monitoring and reference R307-401-8

II.B.1.e.14 - New condition to address new or reconstructed emission units monitoring requirements,
applicable to the clinker cooler and new finish mill.

II.B.1.h - Adding references to Subpart OOO units (limestone processing) with updated opacity
limits.
Adding 20% opacity limit on coal transfer and storage
Adding property boundary opacity limit of 20%
Updating rule reference to include Subpart OOO

II.B.1.j - New condition to address outlet grain loading limits on new baghouses, One identical limit,
15 total new baghouses.

II.B.1.j.1 - Monitoring on new baghouses as per II.B.1.e.4, added an allowance to test less frequently
than annually with three successful tests.

II.B.3.a - Updating formatting to add clarity and include reference to CO2 CEM

II.B.5 - New conditions on emergency engines, diesel fuel sulfur limits, hour of operation
restrictions, non resettable hour meter

[Last updated December 20, 2024]
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 49

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 51

TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 52

DAQE-MN103030032-24

M E M O R A N D U M

TO: John Jenks, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler
Dave Prey, Air Quality Modeler

DATE: December 12, 2024

SUBJECT: Modeling Analysis Review for the Ash Grove Cement Company – Leamington Plant,
located in Millard County, Utah
___________________________________________________________________________________
This is a Major Modification to a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Ash Grove Cement Company (Applicant) has submitted a Notice of Intent (NOI) air permit
application for a project referred to as the Leamington Upgrade Project (LUP). The proposed
upgrade project includes the construction and installation of new pollution control equipment, new
emission sources, and modifications to existing emission sources. Emission increases associated
with the LUP constitute a major modification to a Prevention of Significant Deterioration (PSD)
source subject to PSD permitting regulations. PSD regulations require the Applicant to include and
air quality impact analysis (AQIA) of the proposed projects impact on the EPA national ambient air
quality standards (NAAQS) and air quality related values (AQRV) as part of a complete NOI.

This report prepared by the New Source Review (NSR) modeling staff contains a review of the
Applicant’s Air Quality Impact Analysis (AQIA) including the methodology, data sources,
assumptions, and modeling results for comparison with State and Federal air quality standards. The
AQIA was reviewed and referenced in this report include the:
● Notice of Intent – Ash Grove Cement Leamington Plant PSD Notice of Intent Air Permit
Application, dated November 30, 2022.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

0 0
Jason Krebs

DP
DAQE-MN103030032-24
Page 2

II. APPLICABLE RULES AND ANALYSES

A Utah Air Quality Rules

The UDAQ has determined that the Applicant’s NOI is subject to the following rules for conducting an
AQIA:

R307-401 Permits: New and Modified Sources
R307-405 Permits: Major Sources Located in Attainment or Unclassified Area (PSD)
R307-406-2 Visibility – Source Review
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutant Impacts in Attainment Areas

B. Applicability

The proposed increases in emissions of PM10 and PM2.5 exceed the emission thresholds outlined in R307-
406-5 and R307-410-4. Therefore, an AQIA consistent with the requirements of R307-405-6, R307-406-
2, and R307-410-3 was submitted as part of the Applicant’s NOI. R307-410-3 establishes the U. S.
Environmental Protection Agency (US EPA) – Guideline on Air Quality Models as a formal basis for
defining the scope of the analysis, as well as the model’s construction. The results of the AQIA are
required to demonstrate the proposed project’s impact on state and federal air quality standards,
acceptable levels of impact, and action triggering thresholds referenced or listed in R307-401-6(2), R307-
401-6(3), R307-403-3(1), R307-403-5(1)(a), R307-405-4(1), R307-405-6. Annual emissions for criteria
pollutants requiring an AQIA are listed in Table 1.

Table 1: Ash Grove Leamington Proposed Net Emissions Increase

Criteria
Pollutants
Net Emission
Increase (TPY)
AQIA Trigger
Level (TPY) AQIA Required?
PM10 126.6 15 Yes
PM2.5 70.3 10 Yes

C. Required Analyses

R307-405 requires the Applicant to perform a pre-construction modeling analysis for all pollutants
emitted in a significant quantity. The purpose of the analysis is to determine if the extent of the source’s
impact is significant enough to warrant an on-site measurement of the ambient background concentration
levels. This data is included in the NAAQS analysis to represent the quality of the air prior to the
construction of the proposed project. The Applicant included a pre-construction modeling analysis for
PM10 and PM2.5 as part of the NOI. The pre-construction modeling analysis was also used to determine if
the proposed emissions would result in a significant impact to the environment, thereby triggering the
requirement for a cumulative analysis of the proposed project and other nearby existing sources.

R307-401-8 requires the Division to determine that the proposed project will comply with the NAAQS
prior to the issuance of an Approval Order (AO). R307-405(7) requires the Applicant to perform a
DAQE-MN103030032-24
Page 3
NAAQS analysis for all pollutants emitted in a significant quantity. The analysis is to include all
emissions at the proposed site under normal operating conditions using maximum anticipated short-term
release and annual release rates. Consistent with UDAQ policy, a cumulative analysis to include the
ambient background concentration and any contribution from other nearby sources is not required if the
proposed project’s impact does not exceed the PSD Class II Significant Impact Level (SIL).

R307-401-8 also requires the Division to determine that the proposed project will comply with PSD
increments prior to the issuance of an AO. Under R307-405(6), the Applicant is required to perform a
PSD Class I and II increment consumption analysis for all pollutants emitted in significant quantities.
The purpose of this analysis is to quantify any degradation in air quality since the major source baseline
date. The analysis is to include all increment consuming emissions at the proposed site under normal
operating conditions using maximum anticipated short-term and annual release rates. A cumulative
analysis to include contributions associated with growth and other increment consuming sources is not
required if the proposed project’s impact does not exceed the PSD Class I or II SIL.

R307-410-5 requires the Applicant to perform a HAPs analysis for any pollutant emitted above a
pollutant specific emission threshold value. This analysis is to include all emissions of the pollutants
resulting from the proposed modification under normal operating conditions using maximum anticipated
one-hour release rates. The Applicant did not trigger modeling for HAPs.

R307-406-2 requires the Applicant to perform a plume blight analysis. A plume blight analysis is required
to determine if plumes emanating from the proposed project would be visible inside any Class I area
within 50 kilometers of the source. The plume blight analysis is to include all emissions of NO2, SO4, and
PM10.

Under R307-405-16, an AQRV analysis is performed which evaluates regional haze and acid deposition
impacts at each of the Class I areas within 300 kilometers of the source. A regional haze analysis is
required to determine if the plumes would reduce the visual range of an observer inside the Class I area.
The regional haze analysis is to include all emissions of SO2, NOX and PM10. The deposition analysis
examines impacts from sulfur and nitrogen compounds at the Class I areas, and is based on all emissions
of SO2 and NOX. The Federal Land Managers use the Q/D approach to determine whether a PSD project
should provide detailed AQRV impact analyses, where: Q/D= [ H2SO4 + SO2 + NOx + PM10 emissions
(tpy)]/ distance (km). If Q/D is less than 10, no AQRV analysis is required.

R307-405 requires the Applicant to perform a soils and vegetation analysis. The analysis should quantify
the effects of pollutants on soils and vegetation near the highest impact location and in areas where
sensitive plant species may be impacted.

III. ON-SITE PRE-CONSTRUCTION MONITORING

A. Meteorological Data

Consistent with the US EPA - Meteorological Monitoring Guidance for Regulatory Modeling
Applications, one year of on-site data was collected using a 50-meter tower during the period October 1,
2021 through September 30, 2022. Parameters collected on-site included wind speed and direction,
temperature, delta-T, and solar radiation.

DAQE-MN103030032-24
Page 4

B. Ambient Pollutant Data

A preliminary analysis was conducted to determine the necessity for pre-construction ambient pollutant
monitoring. The results indicate that predicted concentrations of PM10 and PM2.5 exceed the monitoring
trigger level listing in the rule. A continuous PM10/PM2.5 monitor with filter based samplers was
installed near the northern edge of the Applicants property boundary, and collected particulate matter
from October 1, 2021 through September 30, 2022.

IV. MODEL SELECTION

The EPA-AERMOD dispersion modeling system is the preferred model specified in the US EPA –
Guideline on Air Quality Models to predict air pollutant concentrations in the near field (within 50
kilometers of the source). The US EPA - CALPUFF - Version 5.8 model is the preferred model to predict
concentrations in the far field (long range transport conditions beyond 50 kilometers from the source).

V. MODELING INPUTS AND ASSUMPTIONS

A. Technical Options

The regulatory default options were selected in AERMOD by the Applicant to quantify all concentrations.

B. Urban or Rural Area Designation

A review of the appropriate 7.5-minute quadrangles determined that the area should be classified as
“rural” for air modeling purposes.

C. Topography/Terrain

The Plant is at an elevation of 4,950 feet with nearby terrain features that have an effect on concentration
predictions.

a. Zone: 12
b. Location: UTM (NAD83): 397000 meters East, 4379850 meters North

D. Ambient Air

It was determined that the Plant boundary used in the AQIA meets the State’s definition of an ambient air
boundary.

E. Receptor and Terrain Elevations

The modeling domain has simple and complex terrain features in the near field. Therefore, receptor
points representing actual terrain elevations from the area were used in the analysis.

The far-field modeling domain consisted of a rectangular region covering all Class I areas within Utah,
and extending 50 kilometers beyond this area so that the model can account for re-circulation of the
plume.

DAQE-MN103030032-24
Page 5

F. Emission Rates and Release Parameters

The emission estimates and source parameters used in AERMOD for all proposed emission sources at the
site are presented in the NOI.

Speciated emission rates and source parameters used in the CALPUFF modeling are presented in Table 2.

Table 2: CALPUFF Emission Rates

Source
LCC Coordinates Modeled Emission Rates
Easting Northing SO2 SO4 NOX HNO3 NO3 SOA PMC SOIL EC
(m) (m) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr)
317.BF3 -1289410 -3738 52.81 5.03 307.58 0.00 0.00 5.03 2.60 2.90 0.11
419.BF1 -1289314 -3631 0.00 0.00 0.00 0.00 0.00 0.55 1.51 1.61 0.06
41B.BF2 -1289389 -3663 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.68 0.00
N1_FM2 -1289526 -3414 0.00 0.00 0.00 0.00 0.00 0.00 1.65 3.95 0.00
414.BF1N -1289407 -3683 0.00 0.00 0.00 0.00 0.00 0.00 0.10 0.25 0.00
2FM_HTR -1289528 -3415 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.08 0.00
514.BF1 -1289451 -3675 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.70 0.00
COMBO -1289424 -3668 0.00 0.00 0.00 0.00 0.00 0.00 1.37 5.72 0.00
FM2_CMB -1289454 -3439 0.00 0.00 0.00 0.00 0.00 0.00 0.50 1.21 0.00

Total Lb/hr 52.81 5.03 307.58 0.00 0.00 5.58 8.32 17.10 0.17
Hrs/Yr 8760 8760 8760 8760 8760 8760 8760 8760 8760
Ton/yr 231.3 22.0 1347.2 0.0 0.0 24.4 36.4 74.9 0.8

Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
317.BF3 POINT 4902.8 41.2 135.0 488 10.10 3.35
419.BF1 POINT 4891.2 18.3 60.0 388 6.36 2.90
41B.BF2 POINT 4895.2 68.6 224.9 294 17.83 0.74
N1_FM2 POINT 4832.0 49.7 163.0 363 40.08 1.40
414.BF1N POINT 4896.1 76.8 251.9 353 9.91 0.70
2FM_HTR POINT 4832.0 49.7 163.0 363 40.08 1.40
514.BF1 POINT 4889.5 39.6 130.0 294 11.86 0.91
COMBO POINT 4904.2 13.3 43.7 276 9.76 0.32
DAQE-MN103030032-24
Page 6
FM2_CMB POINT 4832.0 30.6 100.3 294 11.40 0.37

G. Building Downwash

The Applicant used the US EPA Building Profile Input Program (BPIP) to determine Good Engineering
Practice (GEP) stack heights and cross-sectional building dimensions for input into the model.

H. Ambient Background Concentrations

Millard County is in attainment for all criteria pollutants. The NAAQS analyses for PM2.5 and PM10 used
monitoring data collected on site during the pre-construction monitoring analysis. The background values
used in the NAAQS analysis are presented in Table 3.

Table 3: Background Concentrations

Pollutant Averaging
Period
Background
Concentration
(μg/m3)
PM10 24-hour 65.4
PM2.5 24-hour 10.2
Annual 4.2

I. Meteorological Data Processing

For the AERMOD model, on-site horizontal and vertical wind speed, direction, solar radiation and,
temperature data was combined with National Weather Service (NWS) upper air data collected at the Salt
Lake City International Airport (SLCIA) for the same period using the US EPA AERMET processing
system.

Meteorological data used for the CALPUFF modeling analysis consisted of 3 years (2018-2020) of data
developed by the Forest Service. The grid was 708 km (east-west) by 492 km (north-south) with a
resolution of 12 kilometers.

VI. RESULTS AND CONCLUSIONS

The Applicant performed a series of analyses to estimate the impact from the proposed project. Modeling
results and conclusions from the review of the analyses are outlined in detail below.

A. Pre-Construction Monitoring and Significant Impact Modeling

The Applicant performed a preliminary criteria pollutant analysis of the proposed modification. This
analysis indicated that increases in concentration levels of PM2.5 and PM10 were greater than the Class II
SIL, and therefore, a cumulative analysis for these pollutants was required.

DAQE-MN103030032-24
Page 7

B. NAAQS Analysis

The Applicant performed a modeling analysis to determine if the combined impact from the proposed
source, other industrial sources operating in the area, and ambient background would comply with the
NAAQS. The NAAQS analysis was reviewed by the Division and determined to be consistent with the
requirements of R307-410-3. Table 4 provides a comparison of the Applicant’s predicted air quality
concentrations and the NAAQS.

Table 4: Model Predicted NAAQS Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-hour 28.3 5 65.4 0 93.7 150 62.5%
PM2.5 24-hour 9.6 1.2 10.2 0 19.8 35 56.6%
Annual 4.4 0.3 4.2 0 8.6 9 95.6%
* Note: Only included other sources and background if source impact was above Class II SIL

C. PSD Class II Increments

The Applicant performed an analysis to determine if the impact from the proposed source would comply
with PSD Class II increments. The analysis was reviewed by the Division and determined to be
consistent with the requirements of R307-410-3. Table 5 provides a comparison of the predicted
concentrations and the PSD Class II increment.

Table 5: Model Predicted PSD Class II Increment Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Nearby
Sources*
Total Increment Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
PM10 Annual 8.1 1 0 8.1 25 32.4%
24-hour 28.3 5 0 28.3 30 94.3%
PM2.5 24-hour 6.1 1.2 0 6.1 9 67.8%
Annual 2.4 0.3 0 2.4 4 60.0%

D. Hazardous Air Pollutants

DAQE-MN103030032-24
Page 8
The Applicant performed an analysis to determine if HAP modeling is required. The analysis was
reviewed by the Division and determined to be consistent with the requirements of R307-410-3. The
analysis indicated that HAP modeling was not triggered by this modification, and therefore no HAP
modeling was performed.

E. PSD Class I Increment Consumption Analysis

The Applicant performed a CALPUFF analysis to determine if the impact from the proposed source along
with other increment consuming sources would comply with federal PSD Class I increments. The
analysis was reviewed by the Division and determined to be consistent with the requirements of R307-
410-3. The results for all Class I areas within 300 kilometers are provided in Table 6.

Table 6: Model Predicted PSD Class I Increment Concentrations

Air Period Prediction
Class I
Significant
Impact
Level
Other
Sources* Total Increment Percent
Pollutant (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
Capitol Reef
NO2 Annual 0.0018 0.1 2.5
SO2
3-Hour 0.0494 1 25
24-
Hour 0.0150 0.2 5
Annual 0.0008 0.1 2
PM2.5
24-
Hour 0.0430 0.27 2
Annual 0.0021 0.05 1
PM10
24-
Hour 0.0444 0.3 8
Annual 0.0021 0.2 4
Arches
NO2 Annual 0.0008 0.1 2.5
SO2
3-Hour 0.0408 1 25
24-
Hour 0.0102 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0522 0.27 2
Annual 0.0018 0.05 1
DAQE-MN103030032-24
Page 9
PM10
24-
Hour 0.0531 0.3 8
Annual 0.0019 0.2 4
Canyonlands
NO2 Annual 0.0010 0.1 2.5
SO2
3-Hour 0.0354 1 25
24-
Hour 0.0100 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0577 0.27 2
Annual 0.0019 0.05 1
PM10
24-
Hour 0.0591 0.3 8
Annual 0.0020 0.2 4
Bryce
NO2 Annual 0.0006 0.1 2.5
SO2
3-Hour 0.0369 1 25
24-
Hour 0.0082 0.2 5
Annual 0.0003 0.1 2
PM2.5
24-
Hour 0.0189 0.27 2
Annual 0.0010 0.05 1
PM10
24-
Hour 0.0194 0.3 8
Annual 0.0010 0.2 4
Zion
NO2 Annual 0.0011 0.1 2.5
SO2
3-Hour 0.0293 1 25
24-
Hour 0.0105 0.2 5
Annual 0.0005 0.1 2
PM2.5
24-
Hour 0.0266 0.27 2
Annual 0.0011 0.05 1
PM10 24-
Hour 0.0271 0.3 8
DAQE-MN103030032-24
Page 10
Annual 0.0012 0.2 4
* Note: Only included other increment consuming sources if source impact was above Class I SIL

Since the proposed project’s model predicted impacts at the Class I areas were less than the PSD Class I
significance levels, a cumulative analysis was not warranted.

DAQE-MN103030032-24
Page 11
F. Visibility – Plume Blight
Since the Class I areas are greater than 50 kilometers from the source, a plume blight analysis using
VISCREEN was not required.

G. Visibility – Regional Haze

The results of the Q/D analysis for the emissions increase was less than 10 but the FLMs wanted the
entire source included in the Q term. The results of including the total emissions resulted in a Q/D >10,
so an AQRV analysis was performed for visibility and acid deposition. The results shown in Table 7
indicate that the impacts are below the 0.5 Deciview (DV) threshold established by the National Park
Service, indicating that no further analysis is required.

Table 7: CALPUFF Visibility Results

Class I Area Year Maximum
Delta DV
98th
Percentile
change in
DV
#
Days
#
Days Threshold
(DV)
Below
Threshold
> 1 > 0.5
2018 0.248 0.06 0 0 0.5 Yes
Arches 2019 0.291 0.054 0 0 0.5 Yes
2020 0.216 0.106 0 0 0.5 Yes
2018 0.223 0.081 0 0 0.5 Yes
Canyonlands 2019 0.312 0.068 0 0 0.5 Yes
2020 0.186 0.085 0 0 0.5 Yes
2018 0.059 0.03 0 0 0.5 Yes
Bryce 2019 0.081 0.045 0 0 0.5 Yes
2020 0.071 0.03 0 0 0.5 Yes
2018 0.183 0.074 0 0 0.5 Yes
Capital Reef 2019 0.196 0.092 0 0 0.5 Yes
2020 0.126 0.078 0 0 0.5 Yes
2018 0.069 0.04 0 0 0.5 Yes
Zion 2019 0.123 0.039 0 0 0.5 Yes
2020 0.102 0.057 0 0 0.5 Yes

DAQE-MN103030032-24
Page 12

H. Acid Deposition

The Applicant performed a deposition analysis on impacts within the Class I areas. Results of the
analysis indicate that the impacts are below the deposition threshold (DAT) established by the National
Park Service, indicating that no further analysis is required

Table 8: CALPUFF Deposition Results for Highest Year

Class I Area
Total
Nitrate
Deposition
Total
Sulfate
Deposition
Deposition
Analysis
Threshold
(kg/ha/yr) (kg/ha/yr) (kg/ha/yr)
Canyonlands 0.0006 0.0003
0.005
Zion 0.0004 0.0002
Arches 0.0006 0.0003
Bryce 0.0006 0.0002
Capitol Reef 0.0011 0.0005

I. Soils and Vegetation Analysis

The Applicant performed an analysis to determine the extent of impacts from the proposed source on soil
and vegetation. Results of the analysis are presented in a supplemental document titled “Soil and
Vegetation Impact Analysis for the Leamington, UT Facility, June 29, 2023”. The analysis indicated that
predicted concentrations compared against the secondary NAAQS at several sensitive receptors would not
result in an adverse impact on soils and vegetation in the vicinity of the proposed project.

DP/JK:jg

DAQE-IN103030032-25

January 22, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Mr. Nelson:

Re: Intent to Approve: Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — ) A A v A ? A D @ A w D D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — ) A A v A ? A D @ A w D D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ash Grove Cement Company Ash Grove Cement Company - Leamington Cement Plant

Mailing Address Physical Address
P.O. Box 38069 Highway 132
Leamington, UT 84638 Leamington, UT 84638

Source Contact UTM Coordinates
Name: Cody Watkins 397000 m Easting
Phone: [phone] 4380100 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3241 (Cement, Hydraulic)

SOURCE INFORMATION
General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried on site),
are correctly proportioned, ground, and mixed and then fed into a rotating kiln. The kiln alters the
materials and recombines them into small stones called cement clinker. The clinker is cooled and ground
with gypsum and additional limestone into a fine powdered cement. The final product is stored on site for
later shipping. The major sources of air emissions are from the combustion of fuels for the kiln operation,
from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source of
emissions of PM2.5, PM10, NOx, CO, HAPs, and GHG. It is a minor source of SO2 emissions.
NSR Classification
Major PSD Modification

Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
DAQE-IN103030032-25
Page 4

Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

These changes result in increases in actual emissions but decreases in most potential emissions. There will
be an increase in the potential emissions of VOCs and greenhouse gases.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
DAQE-IN103030032-25
Page 5

Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
DAQE-IN103030032-25
Page 6

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
DAQE-IN103030032-25
Page 7

II.A.4 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)
II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area, and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, stacker systems. II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit-specific requirements.
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total air flow controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter
area; 9,865 acfm total air flow, controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are
controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each
is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6). II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The
following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for
NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.
II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low-pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

DAQE-IN103030032-25
Page 8

II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow through stack
E34.
II.A.18 Kiln Feed Alleviator A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the central material silo between the blending silos and the preheater. Raw feed is removed from the system near the top of the preheater tower.
II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The
coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter area;
1,700 acfm total air flow.
II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker
storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1): 1,800 acfm that discharges into the clinker tunnel.
II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
DAQE-IN103030032-25
Page 9

II.A.27 Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during loading.
II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel, all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during loading. 512.BF3 (1,000 acfm) is located on top of the silo. II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement products. Dust generated
during milling is captured by a BHA pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).

II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates from stack G55 (finish mill stack).
II.A.32 Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4).
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1 thru 3).

II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total air flow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations.
II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This
baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

DAQE-IN103030032-25
Page 10

II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.
II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023)
II.A.40 Dust Shuttle System A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides, surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the
fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

II.A.41 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons) Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
DAQE-IN103030032-25
Page 11

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)
THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)
CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)
PM: 0.02 lbs filterable PM per ton of clinker.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR 60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to approve alternative control measures, the permittee shall keep a copy of the submitted petition and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source
of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2).
[40 CFR 63 Subpart LLL]

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Page 12

II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must record the PM CPMS output data for all periods when the process is operating and use all the PM CPMS data for calculations when the PM CPMS is not out of control. The owner/operator must demonstrate continuous compliance by using all quality-assured hourly average data collected by the PM CPMS for all operating hours to calculate the arithmetic average operating parameter in units of the operating limit on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
DAQE-IN103030032-25
Page 13

II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

II.B.1.e.3 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-165]
II.B.1.e.4 PM 40 CFR 60, Appendix A, Method 5, or 5I, or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three runs, with each
run at least 120 minutes in duration and each run collecting a sample of 60 dry standard cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165]
DAQE-IN103030032-25
Page 14

II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
DAQE-IN103030032-25
Page 15

II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
DAQE-IN103030032-25
Page 16

II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer point, is not required to conduct Method 22 visible emissions monitoring under this paragraph. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator may decrease the frequency of performance testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
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II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: Instances of water and/or chemical application to unpaved areas shall be recorded and maintained by the owner/operator. The ambient temperature shall be recorded any time water should be applied but cannot due to freezing conditions. [R307-401-8]
II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

The sprays shall operate whenever dry conditions warrant meeting the required opacity
limitations or as determined necessary by the Director. Water sprays shall not be required during
periods of freezing temperatures.

[R307-401-8]

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II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

C. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the kiln/raw mill stack

F. The owner/operator shall record the output of the system: including the quantity of NOx, CO, O2, THC, Hg, HCl, and CO2 emissions at the kiln stack

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an
affected source shall continuously operate all required continuous monitoring devices
and shall meet minimum frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.

[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]
II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments, the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the results of the performance test demonstrating compliance with the filterable PM limit and using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust the SSOL developed in accordance with the results of the most recent PM performance test demonstrating compliance with the PM emission limit. The owner/operator shall use the PM CPMS to demonstrate continuous compliance with the SSOL in accordance with the requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

DAQE-IN103030032-25
Page 19

II.B.4 Fuel Limitations: II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke F. Fuel Oil
G. Used Oil Fuel

H. Synthetic Fuel
I. Wood
J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal additive.
Approval is not required to change from one previously approved coal additive to another
previously approved coal additive. [R307-401-8]
II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily heat input of the kiln and precalciner. The owner/operator may increase the average quantity of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon approval by the Director in accordance with the approval process described in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

DAQE-IN103030032-25
Page 20

II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight
A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation
C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit-no less than 1500oF for more than five minutes in any 60-minute period B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
DAQE-IN103030032-25
Page 21

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the Director. The calibration procedure and frequency shall be according to manufacturer's specifications. Use of factory-calibrated thermocouples for temperature measurement is approved. However, any other method of temperature measurement must be approved by the Director prior to use. The monitoring equipment for both temperature and oxygen content shall be located such that an inspector can at any time safely read the output. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall only operate the emergency engines for testing and maintenance purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency operation. [R307-401-8]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.5.b.2 To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From Source Submitted NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-IN103030032-25
Page 22

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-GN103030032H-25

January 22, 2025

Via Certified Mail 70190700000208349772

Don Shepherd
National Park Service
Air Resources Division
7333 W Jefferson Ave
Lakewood, CO 80235
[e-mail]

Dear Mr. Shepherd:

RE: Notice of Publication for Ash Grove Cement Company - Leamington Cement Plant – CDS A;
MACT (Part 63), Compliance Assurance Monitoring (CAM), Title V (Part 70) Major Source,
Major Criteria Source, Major HAP Source, Attainment Area, NSPS (Part 60),
Project Number: N103030032

On January 22, 2025, the Director has completed his review of a Prevention of Significant Deterioration
project submitted by Ash Grove Cement Company. Attached to this letter are the draft Approval Order
document (Intent to Approve) and the full engineering review. Following a 60-day review by the Federal
Land Managers, this project will be submitted for a 30-day public comment period. Written comments
received by the Division at this same address during these comment periods will be considered in making
the final decision on the approval/disapproval of the proposed Approval Order. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director at the Division in writing, a hearing
will be held in accordance with R307-401-7, UAC.

If you have any questions, please contact John Jenks, who may be reached at [phone].

Sincerely,

Jon L. Black, Manager
New Source Review Division

Enclosures: Engineering Review
Modeling Memo
Intent to Approve

JLB:JJ:jg
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

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State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
RN103030032
January 21, 2025
Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]
Dear Josh Nelson,
Re: Engineer Review:
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032
Please review and sign this letter and attached Engineer Review (ER) within 10 business days.
For this document to be considered as the application for a Title V administrative amendment, a
Title V Responsible Official must sign the next page.
Please contact John Jenks at [phone] if you have any questions or concerns about the ER.
If you accept the contents of this ER, please email this signed cover letter to John Jenks at
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 1

[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the
DAQ will consider any comments received and will issue the Approval Order.

If you do not respond to this letter within 10 business days, the project will move forward
without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue
an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 2

OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible
Official, as defined in R307-415-3, must sign the statement below. THIS IS STRICTLY
OPTIONAL.

If you do not want the Engineer Review to be considered as an application to administratively
amend your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will
require submittal of a separate Operating Permit Application to revise the Title V permit in
accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document:
Title V Operating Permit Application Due Dates clarifies the required due dates for Title V
operating permit applications and can be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality

“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate
and complete and request that this Approval Order be considered as an application
to administratively amend the Operating Permit.”

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 3

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N103030032
Owner Name Ash Grove Cement Company
Mailing Address P.O. Box 38069
Leamington, UT, 84638

Source Name Ash Grove Cement Company- Leamington Cement
Plant
Source Location Hwy 132
Leamington, UT 84638

UTM Projection 397000 m Easting, 4380100 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3241 (Cement, Hydraulic)

Source Contact Cody Watkins
Phone Number [phone]
Email [e-mail]

Billing Contact Cody Watkins
Phone Number 385.225.0615
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 30, 2022
Date of Accepted Application November 28, 2024

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 4

SOURCE DESCRIPTION

General Description
Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried
on site), are correctly proportioned, ground and mixed, and then fed into a rotating kiln. The kiln
alters the materials and recombines them into small stones called cement clinker. The clinker is
cooled and ground with gypsum and additional limestone into a fine powdered cement. The final
product is stored on site for later shipping. The major sources of air emissions are from the
combustion of fuels for the kiln operation, from the kiln, and from the clinker cooling process.
The Leamington cement plant is a major source for emissions of PM2.5, PM10, NOx, CO, HAPs
and GHG. It is a minor source of SO2 emissions.

NSR Classification:
Major PSD Modification

Source Classification
Located in Attainment Area,
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Proposal
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower, various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 6

These changes result in increases in actual emissions, but decreases in most potential emissions.
There will be an increase in the potential emissions of VOC and greenhouse gases.

EMISSION IMPACT ANALYSIS
The complete modeling review is located in DAQE-MN103030032-24. [Last updated January 14, 2025]

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 7

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 8

Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 9

Review of BACT for New/Modified Emission Units

1. BACT review regarding the Leamington Plant Upgrade Project
Any major stationary source or major modification subject to PSD review must undergo an
analysis to ensure the use of BACT. The requirement to conduct a BACT analysis is set forth in 40
CFR 52.21. Similarly, Utah requires the installation of BACT for all sources of air pollution under
R307-401-5(2)(d)), BACT is defined in 40 CFR 52.21 (and R307-401-2) as:

". . . best available control technology means an emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for each pollutant subject to regulation under
Act which would be emitted from any proposed major stationary source or major modification
which the Administrator, on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such source or modification
through application of production processes or available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion techniques for control of such
pollutant . . ."

Therefore, a BACT analysis is required for each new or physically modified emission unit for each
pollutant that exceeds an applicable PSD significant emission rate (SER). Since the PM10 and PM2.5
emissions from the proposed project exceed the applicable PSD SER, a BACT analysis is required
to assess the required levels of control for these pollutants. Because the CO2e emissions are subject
to regulation as a result of the proposed project resulting in an increase of 75,000 tons or more per
year CO2e, a BACT analysis is also required for that pollutant. Note that HAPs listed under CAA
Section 112(b)(1) are excluded from NSR (New Source Review) or PSD (i.e., BACT) review.

In a memorandum dated December 1, 1987, the United States Environmental Protection Agency
(EPA) stated its preference for a "top-down" BACT analysis. After determining if any New Source
Performance Standard (NSPS) is applicable, the first step in this approach is to determine, for the
emission unit in question, the most stringent control available for a similar or identical source or
source category. If it can be shown that this level of control is technically, environmentally, or
economically infeasible for the unit in question, then the next most stringent level of control is
determined and similarly evaluated. This process continues until the BACT level under
consideration cannot be eliminated by any substantial or unique technical, environmental, or
economic objections.

Presented below are the five basic steps of a top-down BACT review as identified by the EPA.
Step 1 - Identify All Control Technologies
Step 2 - Eliminate Technically Infeasible Options
Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Step 4 - Evaluate Most Effective Controls and Document Results
Step 5 - Select BACT

Ash Grove has elected to follow this methodology and based the BACT review on each individual
pollutant. The complete BACT analysis follows. [Last updated January 14, 2025]

2. BACT review regarding PM10 and PM2.5 Sources
PM10 and PM2.5 Modified Equipment
The existing kiln precalciner, preheater, and alleviator system are proposed to be modified, and the
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 10

kiln's ID fan and clinker cooler fans are proposed to be replaced, which will result in increased
airflow. Additionally, the clinker cooler baghouse will be converted from a plenum pulse to a pulse
jet baghouse. These modifications are projected to result in a net increase of potential PM10 and
PM2.5 emissions.

Kiln Upgrade BACT
The rotary cement kiln is the core of the cement manufacturing process, transforming the blended
raw materials or "rawmix" into clinker through pyro processing. Emissions from the kiln occur
from fuel combustion plus the physical and chemical reactions needed to transform the rawmix
into clinker. This project involves process and energy efficiency improvements and an increase in
kiln production, resulting in an increase of PM10 and PM2.5 emissions. This section specifically
addresses filterable PM10 and PM2.5. The condensable fraction is represented with the other
precursors as applicable to proposed emission increases.

The Leamington Plant's Kiln is subject to NSPS, Subpart F for particulate. Therefore, a BACT
analysis addresses applicability of the proposed changes to the kiln system to NSPS and review of
the RBLC. A summary of the resources reviewed include the following:

NSPS Subpart F - Standards of Performance for Portland Cement Plants establishes emission
standards for cement kiln operations. Specifically, kilns modified after June 16, 2008, are limited to
0.07 lbs PM/ton of clinker produced.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028) and
Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from kiln operations are as follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM emissions are most effectively controlled using a collection system with enclosures routed to
baghouses providing up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Ash Grove
has selected technology with the highest control efficiency, so there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 11

Step 5 - Select BACT
Ash Grove proposes that BACT for PM10 and PM2.5 emissions from the kiln consist of a collection
system routed to a baghouse or fabric filter that complies with NSPS Subpart F's emission standard
for a modified source. BACT for the Leamington Plant's kiln are 10% opacity and 0.07 lb of
PM/ton (NSPS Subpart F emission standard) of clinker.
[Last updated January 14, 2025]

3. BACT review regarding PM10 and PM2.5 sources cont.
Clinker Cooler Upgrade BACT
The clinker cooler reduces the temperature of the clinker exiting the kiln. It is necessary to reduce
clinker temperature before it enters the finish mill to maintain product quality and reduce wear and
tear on equipment. The clinker cooler is equipped with a heat exchanger that captures waste heat
and transfers it to the kiln preheater for process and energy efficiency. Emissions from the clinker
cooler are vented to a baghouse. The Leamington Plant's clinker cooler is also subject to NSPS
Subpart F for particulate. Ash Grove's proposed changes to the clinker cooler meet the definition of
a reconstruction under NSPS. Therefore, in order to meet the requirements of NSPS Subpart F, Ash
Grove will be required to meet a limit of 0.02 lb of PM/ton of clinker.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from clinker cooler operations are as
follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM10 and PM2.5 emissions are most effectively controlled using a collection system with enclosures
routed to a baghouse, which can achieve up to 99.9% control efficiency. Other technologies such as
wet scrubbers, cyclones and ESPs are feasible, but provide lower control efficiencies than a
baghouse. Because the most efficient control technology is proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for PM10 and PM2.5 emissions from the clinker cooler is a collection system routed to a
baghouse or fabric filter. In order to meet the requirements of NSPS Subpart F, Ash Grove will
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 12

meet a reduced emission limit of 0.02 lb of PM/ton of clinker. A 10% opacity limit is also
applicable. [Last updated January 14, 2025]

4. BACT review regarding PM10 and PM2.5 sources cont.
New Finish Mill BACT
The proposed Plant upgrade include adding a second finish mill. The new finish mill will use an
energy efficient vertical roller mill assisted with a grinding aid. A total of five (5) point sources are
planned for the finish mill. In accordance with NSPS Subpart F, emissions from finish mill are
restricted to 10% opacity. Ash Grove has reviewed the following sources to identify available
control technologies.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);12 and

Region 8 General Permit for Concrete Batch Plants.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 emissions from plant material handling operations are as
follows:
Baghouse / Fabric Filter;
Best Management & Operational Practices;
Cyclone;
ESP;
Enclosure;
Water Application (Watering); and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
With the exception of water application, all options are technically feasible. Water application is
eliminated as clinker exiting the kiln along with additives in the finish mill must remain dry to
maintain product quality. Therefore, it is technically infeasible to water material in the finish mill.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Enclosure 50-90%
5. Cyclone 20-70%
6. Best Management & Operational Practices varies

Step 4 - Evaluate Most Effective Controls and Document Results
Baghouses provide the highest emission control efficiency, controlling up to 99.9% of PM
emissions from finish mill equipment. After baghouses, using a wet scrubber or ESP provides
similar PM control. Notably, baghouses, scrubbers, and ESPs require enclosures to aid in capturing
emissions and ducting to the control. Therefore, optimal PM emission control can be achieved
through implementing both baghouses and enclosures where feasible. Plant material sizing and
handling is currently done using a series of buildings and enclosures routed to baghouse controls.
Various silos storing material inputs are also equipped with fabric filters. As the highest ranked
technology is applied, there are no adverse energy, environmental or cost impacts to consider with
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 13

the use of these control technologies. Thus, no further analysis is required under EPA's top-down
BACT approach.

Step 5 - Select BACT
BACT for finish mill PM10 emissions is compliance with NSPS Subpart F, Standards of
Performance for Portland Cement Manufacturing where applicable. Ash Grove will achieve BACT
for PM10 emissions from finish mill equipment through the implementation of enclosures,
baghouses, and best management practices. All baghouses at the finish mill will have a 10%
opacity limitation and a grain loading of 0.005 grains/dscf. [Last updated January 14, 2025]

5. BACT review regarding PM10 and PM2.5 sources cont.
Material Transfer, Sizing, and Storage BACT
The Leamington Plant has sources of fugitive emissions through raw material transfer. Materials
transferred include limestone and other raw materials, coal, clinker, and cement. These materials
are transferred by conveyor belt, screw conveyor, elevator, pneumatic conveyance or chutes via
gravity. At the Leamington Plant the fugitive emissions are enclosed at their transfer points and
routed to baghouses.

The following emission units are included in this category:
Limestone Crushing, Sizing, and Material Transfer;
Raw Material Transfer;
Coal Sizing and Transfer;
Existing Finish Mill;
Clinker Storage and Transfer;
Cement Storage and Truck and Rail Cement Loadout;
New Rail Loading and Loadout; and
New Clinker Reclaim Hopper Baghouse.

Generally, controls for these units have not changed or they are similar to current existing controls.
A full BACT analysis of each unit is included in Ash Grove's NOI and additional submitted
information. However, given that most controls remain unaltered, only the results of Step 5 -
Select BACT will be included here.

Limestone Crushing, Sizing, and Material Transfer
Subject to NSPS Subpart OOO opacity limits for existing sources.
Existing baghouses. No change from bag manufacturer's specifications.

Raw Material Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Coal Storage and Transfer
Existing Equipment. No change from bag manufacturer's specifications
20% Opacity

Clinker Storage and Transfer
Subject to NSPS Subpart F opacity limits:
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Page 14

10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Existing Finish Mill Grinding, Storage and Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Cement Storage and Truck and Rail Cement Loadout, New Rail Loadout
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

New Rail Loadout, controlled by baghouse
Emissions Limit - 0.005 gr/dscfm

New Clinker Reclaim Hopper, controlled by baghouse
Subject to NSPS Subpart F opacity limits:
10% opacity
Emissions Limit - 0.005 gr/dscfm [Last updated January 14, 2025]

6. BACT review regarding PM10 and PM2.5 sources cont.
PM10 and PM2.5 Fugitive Emissions
The following fugitive emissions sources will increase emissions of PM10 and PM2.5 as a result of
the Leamington Plant's proposed throughput increase. The sources addressed in the following
BACT analyses are primarily in the quarry, but also include emissions from roads and dumping of
raw materials within the plant boundary.

The sources evaluated are listed below:
Roads;
Loading and Unloading;
Stockpiles;
Bulldozing and Grading;
Disturbed Areas; and
Drilling and Blasting.

Ash Grove currently controls emissions from these processes, and generally, controls for these
units have not changed. A full BACT analysis of each unit is included in Ash Grove's NOI and
additional submitted information. However, given that most controls remain unaltered, only the
results of Step 5 - Select BACT will be included here.

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 15

Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

Stockpiles BACT
BACT shall consist of restricting fugitive emissions to the opacity standard of 20% opacity at the
property boundary. BACT for stockpiles will be achieved through applying good management
practices through its fugitive dust plan as appropriate.

Bulldozing and Grading BACT
BACT shall consist of restricting fugitive emissions from bulldozing and grading activities to no
more than 20% opacity, and that emissions are controlled with periodic watering of the disturbed
surface. The frequency of water application will depend on ambient weather conditions and
inherent moisture content of the material being moved.

Disturbed Areas BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. BACT for
disturbed areas will be achieved through best management practices, watering, scarification, and
revegetation.

Drilling and Blasting BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. This is achievable
through best management practices, shrouds, watering, and dust collection. [Last updated January
14, 2025]

7. BACT review regarding kiln system NOx emissions
Kiln System (Kiln, Raw Mill, and Coal Mill) - NOx BACT
Although there are physical changes to the kiln system, these changes are primarily related to
particulate emissions. NOx emissions are generated from the combustion of fuel - and no changes
in NOx emissions are expected from the kiln (hourly capacity to emit). The kiln NOx emissions will
remain the same as a result of upgrades to the SNCR system. The replacement of the various
components of the kiln system and portions of the preheater tower, along with new injection points,
will ensure that increased mixing of ammonia is achieved to enhance the SNCR system's ability to
reduce NOx and minimize ammonia slip. This will allow the Leamington Plant to maintain the NOx
hourly capacity to emit unchanged from current levels Leamington Plant Upgrade Project. At
present Ash Grove has no restriction on the amount of fuel combusted, only a limit on total NOx
generated, and with this project the allowed NOx PTE is decreasing from 1,352 tpy to 1,226 tpy.

Additional ammonia will be used in the existing SNCR system. While the SNCR system has
adequate capacity to accommodate the additional ammonia demand resulting from the system
upgrades, more ammonia ports are proposed to be added with the kiln system's proposed changes
of the equipment. The changes proposed to the kiln system will increase residence time and
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January 21, 2025
Page 16

temperature which will improve the SNCR system's effectiveness to control NOx emissions and
minimize ammonia slip emissions to the atmosphere. No additional review of NOx BACT for the
kiln system is required under this proposal. [Last updated January 14, 2025]

8. BACT review regarding new finish mill heater emissions
Finish Mill Heater
The proposed finish mill will include a process heater to maintain a minimum temperature during
milling. The proposed heater will run on natural gas and is rated at 10 MMBtu/hr. Startup and
shutdown emissions from the heater are anticipated to be no greater than normal operation as the
process is simply a matter of bringing the heater to operating temperature. Emissions evaluated in
the BACT analysis for the finish mill heater include NOx, SO2, CO, and VOCs, PM10, and PM2.5.
Pollutants with identical control technologies are grouped together in the analysis.

NOx - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for NOx from units of this size range are as follows:
Ultra-Low-NOx Burners (ULNB);
Low NOx Burners;
Selective Catalytic Reduction (SCR);
Selective Noncatalytic Reduction (SNCR);
Good Combustion Practices; and
Use of Natural Gas.

Step 2 - Eliminate Technically Infeasible Options
Low exit temperatures render the use of SCR and SNCR ineffective. Particulate entrainment within
the finish mill could potentially foul (plug) the nozzles of ULNB. Low-NOx burners, the use of
natural gas as fuel and good combustion practices are all considered technically feasible.

Step 3 and Step 4 - Rank Remaining Control Technologies by Control Effectiveness and Evaluate
Most Effective Controls and Document Results
Since the three feasible control technologies are proposed for the finish mill heater, no detailed
economic, energy, and environmental impact evaluations were conducted. No ranking of control
effectiveness is required as all three controls are proposed.

Step 5 - Select BACT
BACT for NOx is the use of natural gas as fuel, good combustion practices and the use of Low NOx
burners.

CO, SO2, and VOC - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for CO, SO2, and VOC from units of this size are as follows:
Good Combustion Practices
Use of Natural Gas

The finish mill heater combusts natural gas. Related natural gas combustion emissions are
anticipated to be minimal.

Step 2 - Eliminate Technically Infeasible Options
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January 21, 2025
Page 17

Both control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Both technologies offer intrinsic emission reductions from combustion. Since the technologies do
not compete, both technologies can and will be used simultaneously.

Step 4 - Evaluate Most Effective Controls and Document Results
Because both control technologies identified in Step 1 are proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for CO, SO2, and VOC are good combustion practices and the use of natural gas.

PM10 and PM2.5 BACT for the finish mill has been addressed in the PM10/PM2.5 sources section.
[Last updated January 14, 2025]

9. BACT review regarding SO2, VOC, and Lead Sources
The following BACT analysis is grouped by pollutants that will experience an increase in potential
emissions and the associated technically feasible control technologies. As such, the BACT analysis
is separated into SO2, VOC, and lead respectively with organic HAPs addressed with VOCs.

SO2 - Cement Kiln BACT
NSPS Subpart F - Standards of Performance for Portland Cement Plants, establishes emission
standards for cement kiln operations. Specifically, kilns constructed or reconstructed after June 16,
2008, are limited to 0.4 lbs SO2/ton clinker on a 30-day rolling average respectively. This limit is
an existing emission limit in the Leamington Plant's approval order and Title V. Ash Grove will
continue to achieve this emission limitation while achieving BACT for the kiln operations. Ash
Grove has reviewed the following sources to identify available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019); and

NSPS Subpart F as an affected emissions facility in 40 CFR 60.62(a)(4);

Portland Cement Association's Formation and Techniques for Control of Sulfur Dioxide and Other
Sulfur Compounds in Portland Cement Kiln Systems.

SO2 emissions are a result of oxidation of sulfur compounds in the rawmix and/or the coal used to
fire the kiln. However, the alkaline nature of the cement provides for direct absorption of SO2 into
the product, thereby mitigating the quantity of SO2 emissions in the exhaust stream.

Step 1 - Identify All Control Technologies
Control technologies identified for SO2 emissions from coal-fired kiln operations are as follows:
Baghouse or fabric filter;
Dry reagent injection prior to baghouse;
Wet scrubber;
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Process optimization; and
Good combustion practices.

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below:

1. Process Optimization 99%
2. Wet Scrubber 99%
3. Dry Reagent Injection 60%
4. Good Combustion Practices 30%
5. Baghouse Variable

Step 4 - Evaluate Most Effective Controls and Document Results
SO2 emissions are most effectively controlled by optimizing the process and utilizing the inherent
SO2 scrubbing properties of the kiln system itself. Although wet scrubbers alone can achieve equal
control efficiencies as process optimization, additional capital and operational expenses are
required for water consumption and wastewater discharge. Whereas process optimization achieves
the same control effectiveness and has the added benefit of reduced operational costs. Ash Grove
optimizes the kiln process by routing the exhaust from the kiln to a preheater and raw mill to
interact with the raw mix, thus creating an atmosphere similar to a dry scrubber system. Good
combustion practices also reduce SO2 formation with the added benefit of energy efficiency.

Step 5 - Select BACT
BACT for control of SO2 emissions from kiln operations shall consist of process optimization by
routing kiln exhaust to the preheater and raw mill, good combustion practices, and use of a
baghouse prior to exhausting to the atmosphere. As a modification of the kiln, 40 CFR 60.62(a)(4)
requires an emission limit of 0.4 pounds of sulfur dioxide (SO2) per ton of clinker on a
30-operating day rolling average. [Last updated January 14, 2025]

10. BACT review regarding SO2, VOC, and Lead Sources cont.
VOC - Cement Kiln BACT
VOCs are generated by incomplete combustion in the kiln. 40 CFR 63 Subpart LLL - NESHAP
from the Portland Cement Industry limits total hydrocarbon and total organic HAP emissions to 24
and 12 ppmv at 7% oxygen. Ash Grove will achieve or exceed these emission limitations while
achieving BACT for the kiln operations. Ash Grove has reviewed the following sources to identify
available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028); and

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for VOC emissions from coal fired kiln operations are as follows:
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Process optimization,
Good combustion practices

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below.

1. Process Optimization Variable
2. Good Combustion Practices Variable

Step 4 - Evaluate Most Effective Controls and Document Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove optimizes the
kiln process by capturing waste heat from the clinker cooler and routing to a kiln preheater. Good
combustion practices also reduce VOC formation with the added benefit of energy efficiency.
There are no adverse energy, environmental or cost impacts to consider with the use of this control
technology.

Step 5 - Select BACT
BACT for control of VOC emissions from kiln operations shall consist of process optimization by
routing kiln heat to the preheater and good combustion practices. An emission limit of 24 ppmv
VOC @ 7% O2 is imposed by NESHAP Subpart LLL.

VOC - Grinding Aid BACT
A grinding aid containing VOC is added to the new finish mill to disperse particles within the mill
and expose more surface area to grinding. An increase in grinding aid usage proportionally
increases potential VOC emissions because volatiles from the grinding aid are not combusted in
the kiln.

There is only one identified control option for limiting the VOC emissions from the grinding aid.
Process optimization is technically feasible. VOC emissions are most effectively controlled by
optimizing the process. Ash Grove proposes to install a vertical finish mill with this project. Due to
the new modern mill's efficiency, it is anticipated that a reduced amount of grinding aid will be
required for each ton of clinker ground. Ash Grove estimates total VOC emissions from the
grinding aid at 2.37 tpy.

Lead Emissions
The lead emissions are anticipated to increase as a result of the proposed increase in clinker
throughput with the Leamington Plant upgrade project. Lead emissions result from residual
amounts of lead in raw materials and fuel. Lead emissions will be controlled the same as PM,
therefore a separate top-down BACT analysis has not been conducted as the Leamington Plant has
applied the most effective controls. [Last updated January 14, 2025]

11. BACT review regarding Greenhouse Gases
GHG Background
On October 9, 2009, the mandatory GHG reporting regulation, referred to as 40 CFR 98, was
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published in the Federal Register. Through 40 CFR 98, the U.S. EPA established the GHG
Reporting Rule, which requires the annual reporting of GHG data and other relevant information
from large sources and suppliers in the United States. Monitoring through the GHG Reporting
Program (GHGRP) began in 2010, with the first reports due by March 31, 2011. Per 40 CFR
98.2(a)(1), any facility associated with cement production is subject to the GHGRP and must report
CO2e emissions. The CO2e is the sum of equivalent GHG emissions from CO2, CH4, and N2O,
with their respective global warming potentials (GWP) applied. Ash Grove's facility is subject to
GHG Reporting Rule and monitors CO2 emissions from its kiln with a continuous emissions
monitoring system (CEMs). On June 23, 2014, the U.S. Supreme Court held that required PSD
permits (based on emissions of non-GHG pollutants) may continue to require limitations on GHG
emissions based on the application of BACT as an "anyway source". The Leamington Plant
modification project is a major source for PSD for both PM10 and PM2.5, and GHGs are estimated
to be greater than 75,000 tpy and greater than zero on a mass basis; therefore, GHGs are evaluated
for BACT as an anyway source.

Cement Manufacturing GHG BACT
A BACT analysis has been conducted for CO2e emissions from the kiln system. For this GHG
BACT analysis, various control technologies or combinations of technologies were identified using
the RACT/BACT/LAER Clearinghouse, available literature including guidance published by EPA
and South Coast Air Quality Management District (SCAQMD), current air regulations, other
regulatory organizations, and engineering experience. In March 2011, EPA published GHG
permitting guidance, as well as a white paper on available and emerging technologies for reducing
GHG emissions from the Portland cement industry in October 2010. Additionally, EPA published a
series of videos on GHG permit training in December 2010. The SCAQMD published GHG BACT
guidance in 2021. Additional sources of information were reviewed and documented based on
publications from trade organizations and other governmental committees with GHG or carbon
reduction guidelines and/or recommendations.

EPA has defined in 40 CFR 86.1818-12(a) GHGs as a group of six gases: CO2, nitrous oxide
(N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF6). GHG emissions from the kiln result from calcination and fuel combustion.
Since the primary GHG emitted by a kiln is CO2, the BACT analysis focuses on CO2 emissions
from the kiln. Emissions of CH4 and N2O are minimal from cement kilns. Per EPA guidance, GHG
control technologies for consideration in a BACT analysis for Portland Cement Manufacturing
include:

Source-wide energy efficiency strategies;
Raw material substitution;
Blended cements;
Carbon capture utilization and storage; and
Fuel switching.
Other emerging technologies [Last updated January 14, 2025]

12. BACT review regarding Greenhouse Gases cont.
Step 1: Identify All Control Technologies
The CO2 emissions from a cement kiln are generated by the calcination process (conversion of the
calcium carbonate in limestone to calcium oxide) and by combustion of fuel in the kiln. Potential
control technologies to reduce these CO2 emissions for a cement kiln are addressed in EPA's white
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paper on Available and Emerging Technologies for Reducing GHG Emissions from the Portland
Cement Industry.

These technologies fall into three categories:
Energy Efficiency Improvements for the Clinker Production Process
Fuel Substitution
Carbon Capture and Sequestration

Step 2: Eliminate Technically Infeasible Options
Several potential energy efficiency improvements are technically feasible: Pre-heater/Pre-calciner
Kiln Process, Kiln Seal Management Program, Refractory Selection (Kiln Insulation), and Energy
Recovery from the Clinker Cooler. The use of alternative fuels such as natural gas, whole tires and
biofuel) is also technically feasible. Other control options, such as Use of Fluxes and Mineralizers,
Heat Recovery for Power - Cogeneration, Carbon Sequestration, Oxyfuel combustion, and
Post-combustion Capture have been deemed infeasible.

Step 3: Rank Remaining Control Technologies by Control Effectiveness
All four remaining control techniques are currently implemented at the Leamington Plant. This
permitting project incorporates energy efficiency improvements. Ash Grove has had a fuel
substitution program in place for several years, and this program is continually reviewed and
updated as new sources and types of fuel are identified.

Step 4: Evaluate Most Effective Controls and Document Results
Since all technically feasible energy efficiency improvements and changes to product composition
will be implemented, this section will focus on economic and environmental considerations of fuel
substitution to operate exclusively on natural gas.

Firing natural gas as the primary kiln fuel can reduce CO2 emissions from fuel combustion by as
much as 40%. However, studies have shown that use of natural gas as primary kiln fuel can result
in three times more NOx emissions than NOx emissions from coal firing. Creating more NOx to
reduce GHG emissions is undesirable as it is a precursor to both ozone and PM2.5. Fuel substitution
essentially trades emissions of one regulated pollutant for another. Estimated capital cost to switch
to natural gas fuel exceeds $25M. Implementing natural gas technology would provide incremental
public health and welfare benefit globally by reducing CO2 emissions, while increasing NOx
emissions and negatively impacting public health and welfare locally. Switching fuels to another
fossil fuel has finite potential to mitigate CO2 emissions.

Step 5: Select BACT
In addition to the proposed energy efficiency improvements addressed elsewhere in this BACT
analysis, BACT is a limit of 0.92-ton CO2e/ton clinker. Ash Grove will use a continuous emission
monitoring system (CEMS) for CO2 to demonstrate compliance with this limit. [Last updated
January 14, 2025]

13. BACT review regarding Leamington Plant Upgrade Project conclusion
The control processes and techniques covered in this BACT analysis have been reviewed by the
NSR Section of the UDAQ. Ash Groves proposed controls and associated emission limitations
represent BACT. Any emission limitations not expressed in an associated NSPS or NESHAP will
be included in the terms and conditions of this AO. A listing of all associated NSPS and NESHAP
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programs is also included in the Source Information section of this document under Applicable
Federal Programs. [Last updated December 13, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date
of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
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proper credit when notifying the Director, send the documentation to the Director, attn.: NSR
Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.

II.A.3
NEW
Stockpiles
Coal storage
Area: 1 acre
Annual throughput 20,000 tpy

AF and ARM stockpiles
Area: 0.25 acre
Annual throughput 8,000 tpy

II.A.4 Stationary Crusher
Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction
of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000
acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)

II.A.5 Raw Material Transfer
Crushed material is transported to raw material storage by belt B8. The raw material transfers
at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor
transfer point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total
filter area & water sprays. (pre-1983)

II.A.6 Material Handling
Conveyor belt systems, secondary feeders and screens, stacker system

II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit specific requirements

II.A.8 Belt Conveyor Transfer Baghouse
Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area
and 1,800 acfm total air flow, controls emissions from the conveyor belt that transfers the
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stacked material to the raw material silos.

II.A.9 Raw Material Silos
Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The
four silos are equipped with one common Fuller, plenum pulse baghouse (315.BF1) - 1,689 ft2
filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage).

II.A.10 Fifth Component Silo
Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse
(315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw
mill feed. This system includes vibrating feeders, a conveyor system, and surge bin.
Emissions are controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3,
316.BF4, 316.BF5) - each is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1
A/C ratio.

II.A.12 Cross-Belt Analyzer
Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6)

II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom
of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw
materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38).
The following equipment is installed: low-NOx burner, selective non-catalytic reduction
(SNCR) for NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued
mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric
monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct
for mercury adsorption capacity. The carbon injection system is not an emission point as it is
in an enclosed building.

II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

II.A.16 Two Kiln Feed Blending Silos
Raw material is blended in one of two blending silos prior to feeding the kiln. The blending
silos are controlled by one common Fuller, plenum pulse baghouse (411.BF1) - 1,351 ft2 filter
area; 7,160 acfm total air flow.

II.A.17 Blending Silo Elevators (2)
Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped
with a Fuller, pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow
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through stack E34.

II.A.18 Kiln Feed Alleviator
A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the
central material silo between the blending silos and the preheater. Raw feed is removed from
the system near the top of the preheater tower.

II.A.19 Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner.
The coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter
area; 1,700 acfm total air flow.

II.A.20 Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in
the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2):
19,500 acfm rated airflow with 3.75:1 A/C ratio

II.A.21 Clinker Cooler and Baghouse
Reconstructed grate type cooler used for cooling clinker from the kiln prior to transfer to
clinker storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) -
173,869 acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter
monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two
clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse
(419.BF8). The exhaust is routed to the clinker cooler stack.

II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions
generated when loading the east and west clinker silos and the out-of-spec silo are controlled
by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1):
1,800 acfm, that discharges into the clinker tunnel.

II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm, that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2)
Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers.
Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses
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(511.HP1 and new 511.HP2): 1,800 acfm each.

II.A.27 Gypsum Silo
Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2
total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust
during loading.

II.A.28 Clinker Tunnel Exitway
The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse
(511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel all discharge in the clinker tunnel.
Emissions are vented through the tunnel exitway.

II.A.29 Limestone Silo
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust
during loading. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement product. Dust
generated during milling is captured by a BHA, pulse jet baghouse (514.BF2) - 6,080 ft2 filter
area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding
stack).

II.A.31 Finish Mill (Ball Mill) Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized
cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA, pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow
controlling particulates from stack G55 (finish mill stack).

II.A.32
NEW
Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The
stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4)
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1,
525.BF1 thru 3)

II.A.33 Finish Cement Storage Silos
There are six storage and two interstice silos where the finished cement product is stored. A
single common Fuller, plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm
total air flow through stack H7 is located on top of the silos and is used to control emissions
during loading and unloading operations.

II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail
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shipping. This baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out
The cement loadout system located on the South side of the silos (truck load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF2) during unloading from the silos for truck
shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement
conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed
space inside the silos.

II.A.36
NEW
Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

II.A.37 MHO: Materials Handling Operation
Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1
& 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4;
512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.

II.A.38 LBS: Limestone Bypass System
Additional limestone is added to the clinker and gypsum by the limestone bypass system
(LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays
at the screen and material handling drop points.

II.A.39 GEN: Emergency Generators
One diesel-fired emergency generator (new)
Rating: 762 hp
(Kiln, Tier 3, permitted 2022)

Two natural gas-fired emergency generators
Rating: 304 hp
(Main office and control room, permitted in 2023)

One diesel-fired emergency generator
Rating: 560 hp
(Shipping, permitted 2023).

II.A.40 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14 inch knife gate, 8 inch knife gate, 8 inch air
slides, surge bin), and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm)
on the fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

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II.A.41
NEW
Miscellaneous Storage Tanks
One diesel storage tank (<2,000 gallons)
One gasoline storage tank (500 gallons)
Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Requirements on the Cement Plant:
II.B.1.a
NEW
The following limits shall not be exceeded:

A. Clinker production - 1,155,000 tons per rolling 12-month period

B. Used oil consumption - 85,724 gallons per rolling 12-month period

C. Limestone bypass material processed - 216,260 tons per rolling 12-month period.
[R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 25th day of each month using data from the previous 12 months.
Records shall be kept for all periods when the plant is in operation. Consumption and
production shall be calculated through use of the plant's acquisition system. [R307-401-8]

II.B.1.b
NEW
Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations:

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

SO2: 0.4 lbs per ton of clinker (3-hr average)

CO: 3,395 tons per rolling 12-month period, and 6,600 lbs/hr

NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average, and 1,233 tons per rolling
12-month period

Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is
400oF or less.

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Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)

THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)

CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)

PM: 0.02 lbs filterable PM per ton of clinker. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL,
R307-401-8]

II.B.1.c
NEW
A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR
60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust
emissions control plan shall be monitored to demonstrate that appropriate control measures are
being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of
the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall
be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in
the plan and that the source is operating in accordance with the submitted plan. For petitions
to approve alternative control measures, the permittee shall keep a copy of the submitted
petition and any approvals received. [40 CFR 60 Subpart Y]

II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area
source of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2). [40 CFR
63 Subpart LLL]

II.B.1.e
NEW
Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b
and II.B.1.d shall be performed as specified below:

A. Kiln/Raw Mill Stack
Pollutant Test Status Test Frequency
PM * #

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

B. Clinker Cooler (F31)
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Pollutant Test Status Test Frequency
PM + #

C. Testing Status (To be applied above)
* The initial testing has already been performed.

** The SO2 initial performance test was conducted on August 26, 2013.

*** The initial compliance test shall be conducted within the first 30 operating days of
operation in which the affected source operates using a CEMS.

# Test once every year. If performance testing would be required less than 15 operating days
after the Kiln has completed Startup after being down for more than 24 hours, then
performance testing may be deferred up to 15 operating days after completion of the Startup.
The Director may require testing at any time.

## Test at least once every two years. The Director may require testing at any time.

+ Initial testing is required within 180 days of startup of the reconstructed equipment

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must record the PM
CPMS output data for all periods when the process is operating, and use all the PM CPMS
data for calculations when the PM CPMS is not out-of-control. The owner/operator must
demonstrate continuous compliance by using all quality-assured hourly average data collected
by the PM CPMS for all operating hours to calculate the arithmetic average operating
parameter in units of the operating limit on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

+++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.e.1
NEW
Notification
The Director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The notification requirements for performance tests subject to 40
CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-165]

II.B.1.e.2
NEW
Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational
Safety and Health Administration (OSHA)- or Mine Safety and Health Administration
(MSHA)-approved access shall be provided to the test location. [R307-165]

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II.B.1.e.4
NEW
PM
40 CFR 60, Appendix A, Method 5 or 5I or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three (3) runs with
each run at least 120 minutes in duration and each run collecting a sample of 60 dry standard
cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.3
NEW
Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2. [R307-165]

II.B.1.e.5
NEW
Carbon Monoxide (CO)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.6
NEW
Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.7
NEW
Sulfur Dioxide (SO2)
40 CFR 60, Method 6 or 6C of Appendix A-4 or other EPA-approved method as acceptable to
the Director. [R307-165]

II.B.1.e.8
NEW
Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]

II.B.1.e.9
NEW
Total Hydrocarbons (THC)
Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL]

II.B.1.e.10
NEW
Mercury (Hg)
Continuous Emission or integrated sorbent trap monitoring (See Condition II.B.3.a). [40 CFR
63 Subpart LLL]

II.B.1.e.11
NEW
HCl
Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other
EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]

II.B.1.e.12
NEW
Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.13
NEW
Calculations
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director, to give the results in the specified units of the
emission limitation. [R307-165]

II.B.1.e.14
NEW
Existing Source Operation
For an existing source/emission point, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three years.
[R307-165]

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II.B.1.e.15
NEW
New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the maximum production rate listed in this AO. If the maximum AO
allowable production rate has not been achieved at the time of the test, the following
procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This new
allowable maximum production rate shall remain in effect until successfully tested at a higher
rate.

3) The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate (110%
of the new rate) will then be allowed if the test is successful. This process may be repeated
until the maximum AO production rate is achieved. [R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL.
[40 CFR 63 Subpart LLL]

II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times
of Dust Shuttle System operation to assist in the capture of Mercury emission. [R307-401-8]

II.B.1.h
NEW
Visible emissions from the following emission points shall not exceed the following values:

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

L. All baghouses - 10% opacity
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M. Fugitive dust - 20% opacity

N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y,
R307-401-8]

II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer
point is not required to conduct Method 22 visible emissions monitoring under this paragraph.
The enclosures for these transfer points must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

If any partially enclosed or unenclosed conveying system transfer point is located in a
building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to
40 CFR 60, according to the following:

(i) The owner/operator must conduct a monthly ten-minute visible emissions test of each
affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The
performance test must be conducted while the affected source is in operation.

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator may decrease the frequency of performance testing from monthly
to semi-annually for that affected source. If visible emissions are observed during any
semi-annual test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iii) If no visible emissions are observed during the semi-annual test for any affected source,
the owner/operator may decrease the frequency of performance testing from semi- annually to
annually for that affected source. If visible emissions are observed during any annual
performance test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iv) If visible emissions are observed during any Method 22 performance test, of Appendix
A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations,
recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60.
The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour
of any observation of visible emissions.

(v) If visible emissions from a building are monitored, the requirements of paragraphs (i)
through (iv) of this Condition apply to the monitoring of the building, and the owner/operator
must also test visible emissions from each side, roof, and vent of the building for at least ten
minutes. [R307-401]

II.B.1.j
NEW
Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed
0.005 gr/dscf:

520.BF1
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520.BF2
520.BF3
520.BF4
521.BF2
521.BF1
524.BF1
524.BF2
524.BF4
524.BF3
525.BF1
525.BF2
525.BF3
511.HP2
NRL_UPR
NRL_LWR. [R307-401-8]

II.B.1.j.1
NEW
To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration
through at least three (3) annual tests that the PM limits are not being exceeded, the
owner/operator may request approval from the Director to conduct stack testing less
frequently than annually. [R307-401-8]

II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive
dusts as dry conditions warrant or as determined necessary by the Director to maintain opacity
limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated to control fugitive dust. The application of
water or chemical treatment shall be used. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a damp/moist condition unless it is below freezing.
If chemical treatment is to be used, the plan must be approved by the Director. Records of
water and/or chemical treatment shall be kept for all periods when the plant is in operation.
The records shall include the following items: Instances of water and/or chemical application
to unpaved areas shall be recorded and maintained by the owner/operator. The ambient
temperature shall be recorded any time water should be applied but cannot due to freezing
conditions. [R307-401-8]

II.B.2.c
NEW
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

The sprays shall operate whenever dry conditions warrant meeting the required opacity
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limitations or as determined necessary by the Director. Water sprays shall not be required
during periods of freezing temperatures. [R307-401-8]

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation
of fugitive dusts as dry conditions warrant or as determined necessary by the Director.
[R307-401-8]

II.B.2.e
NEW
The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5
PM. [R307-401-8]

II.B.3 Continuous Emission Monitoring Requirements:
II.B.3.a
NEW
The owner/operator shall install, calibrate, maintain and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler.

A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the
missing data substitution procedures used by the UDAQ or the missing data substitution
procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate by the UDAQ.

B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period
including during each startup, shutdown, or malfunction.

C. The monitoring system shall comply with all applicable sections of R307-170, UAC; and
40 CFR 60, Appendix B.

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be
installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the
kiln/raw mill stack.

F. The owner/operator shall record the output of the system: including the quantity of NOx,
CO, O2 THC, Hg, HCl, and CO2 emissions at the kiln stack.

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source shall
continuously operate all required continuous monitoring devices and shall meet minimum
frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker
cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except
during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments,
the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a
PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the
results of the performance test demonstrating compliance with the filterable PM limit and
using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust
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the SSOL developed in accordance with the results of the most recent PM performance test
demonstrating compliance with the PM emission limit. The owner/operator shall use the PM
CPMS to demonstrate continuous compliance with the SSOL in accordance with the
requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

II.B.4 Fuel Limitations:
II.B.4.a
NEW
The owner/operator shall use only the following fuels in the kiln and pre-calciner:

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.

If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b
NEW
Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the
Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the
results of suitable tests giving data similar to a Proximate and Ultimate analysis of the
proposed coal additive. [R307-401-8]

II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal
additive. Approval is not required to change from one previously-approved coal additive to
another previously-approved coal additive. [R307-401-8]

II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily
heat input of the kiln and precalciner. The owner/operator may increase the average quantity
of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon
approval by the Director in accordance with the approval process described in Condition
II.B.4.b. [R307-401-8]

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II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel burning or process
installation not covered by New Source Performance Standards for sulfur emissions or
covered elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross
Btu heat input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input
for any oil except used oil. The sulfur content shall comply with all applicable sections of
UAC R307-203. [R307-203, R307-401-8]

II.B.4.c.1
NEW
Certification of fuels shall be either by the owner/operator's own testing or test reports from
the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be
available onsite. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials, UAC R307-203-1 (4)

A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be
used.

B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be
used.

C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85 are to be used. [R307-203]

II.B.4.d
NEW
The concentration/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight
3) Cadmium 2 ppm by weight
4) Chromium. 10 ppm by weight
5) Lead 100 ppm by weight
6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be
tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the burn tank and burned. [R307-401-8]

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II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned
in the rotary kiln:

A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than
five minutes in any 60-minute period

B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes
in any 60-minute period. [R307-401-8]

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the
Director. The calibration procedure and frequency shall be according to manufacturer's
specifications. Use of factory-calibrated thermocouples for temperature measurement is
approved. However, any other method of temperature measurement must be approved by the
Director prior to use. The monitoring equipment for both temperature and oxygen content
shall be located such that an inspector can at any time safely read the output. [R307-401-8]

II.B.5
NEW
Emergency Engine Requirements
II.B.5.a
NEW
The owner/operator shall only operate the emergency engines for testing and maintenance
purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency
operation. [R307-401-8]

II.B.5.b
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each emergency engine. [R307-401-8]

II.B.5.b.1
NEW
The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.5.b.2
NEW
To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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Page 39

PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN103030035-24 dated November 27, 2024
Is Derived From Source Submitted NOI dated November 30, 2022
Incorporates Additional Information Received dated April 26, 2023
Incorporates Additional Information Received dated September 26, 2023
Incorporates Additional Information Received dated July 23, 2024
Incorporates Additional Information Received dated October 25, 2024
Incorporates Additional Information Received dated November 25, 2024

REVIEWER COMMENTS

1. Comment regarding applicability of federal requirements:
New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable
by the best demonstrated technology as specified in the applicable provisions. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.

40 CFR 60, Subpart A (General Provisions)
All affected facilities subject to a source-specific NSPS are subject to the general provisions of
NSPS, Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires
initial notification, performance testing, recordkeeping, and monitoring, provides reference methods,
and mandates general control device requirements for all other subparts.

40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of
performance for affected facilities in Portland Cement Plants which have been constructed or
modified after August 17, 1971.

40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart
F: Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and
unloading systems. The Leamington coal mill is an in-line coal mill and considered an integral part
of the Leamington kiln. In-line coal mills are not subject to NSPS Subpart Y. Therefore, the coal mill
is addressed under NSPS Subpart F as part of the kiln system. The coal silos and conveying system
are subject to NSPS Subpart Y.

Ash Grove's proposed changes to the kiln system must be evaluated as to whether they trigger new
NSPS Subpart F obligations based on whether the proposed project is either a modification or a
reconstruction, as those terms are defined in NSPS Subpart A.

Ash Grove's proposed changes to the kiln system do not meet the definition of a reconstruction, nor
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 40

do they meet the definition of a modification for NOx. However, the changes meet the definition of a
modification for PM and SO2. Therefore, Ash Grove will comply with all relevant emission
standards; testing requirements; monitoring, recordkeeping, and reporting obligations that apply to
the Leamington kiln system as an existing source under NSPS Subpart F. Under NSPS Subpart A
and F, the clinker cooler is considered a reconstructed unit. Thus new limits will apply to this unit.
[Last updated January 14, 2025]

2. Comment regarding applicability of federal requirements cont.:
NSPS Subpart Y - Standards of Performance for Coal Preparation and Processing Plants
This subpart provides standards of performance for affected facilities in coal preparation and
processing plants that process more than 200 tons of coal per day.

The Leamington plant's coal silo and coal conveying system are existing affected facilities under
NSPS Subpart Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses
controlling affected facilities subject to match the limit in NSPS Subpart Y from 0.016 gr/dscf to
0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade Project. Since there are no proposed
modifications or reconstruction to the coal silo and coal conveying system, nothing about the
proposed upgrade project affects the existing applicability of NSPS Subpart Y.

NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
This subpart provides standards of performance for affected facilities located at fixed or portable
nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August
31, 1983, with additional requirements applicable to sources constructed on or after April 22, 2008.

As the crushing and screening system is controlled by baghouses and an increase in PM10 actual
emissions on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS.
Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the
Leamington Plant Upgrade Project.

Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1),
60.676(f), and 60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO
monitoring and recordkeeping requirements.

[Last updated January 14, 2025]

3. Comment regarding applicability of federal requirements cont.:
National Emission Standards for Hazardous Pollutants (NESHAPs)
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or
greater than 10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as
specified by each subpart. NESHAP apply to sources in specifically regulated industrial source
classifications (CAA Section 112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities
not regulated as a specific industrial source type. The Ash Grove Leamington Plant is a major source
of HAPs and thus is subject to certain NESHAP standards.

Subpart A - General Provisions
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Page 41

All affected sources are subject to the general provisions of Subpart A unless otherwise specified by
the source-specific NESHAP. Subpart A generally requires initial notification and performance
testing, recordkeeping, monitoring, provides reference methods, and mandates general control device
requirements for all other subparts as applicable.

Subpart LLL - Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry
This subpart establishes process/source specific emission limits for PM, VOC (expressed as total
hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and
gaseous HAP compounds by limiting PM and THC emissions because portions of such emissions
are USEPA-listed HAPs. Subpart LLL requires compliance with applicable emissions limits on and
after the initial startup of cement production. To further reduce emissions, Subpart LLL also
establishes operational requirements for the use of cement kiln dust (CKD), fly ash, fuel and control
equipment. Subpart LLL also specifies process/source specific emissions testing, monitoring,
recordkeeping, reporting, and compliance demonstration requirements. The compliance requirements
for the site are detailed in Approval Order Condition II.B.1.b. Ash Grove will continue to comply
with the requirements of Subpart LLL to demonstrate compliance. This cement kiln will remain an
existing source with respect to the kiln emission standards in Subpart LLL as this project does not
trigger the definition of a new source in Subpart LLL. New source standards apply only to affected
sources that were constructed or reconstructed after May 6, 2009.
[Last updated December 20, 2024]

4. Comment regarding PSD applicability analysis:
Ash Grove is proposing to increase the throughput of limestone from the quarry to supply the New
Finish Mill to increase the amount of low-carbon cement from the Leamington Plant. Additionally,
along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
modified, and the clinker cooler will be reconstructed. These changes are anticipated to result in an
increase in clinker production. Emission calculations for this project have been completed assuming
an increase in clinker production capacity while utilizing current fuel types. This will result in an
increase in the throughput of fuel.

The Leamington Plant is considered an existing major source under PSD based on potential
emissions of PM10, PM2.5, NOx, CO, SO2, and CO2e. If a major source undergoes a physical or
operational change, the facility must determine whether the project will be considered a major
modification. Per 40 CFR 52.21(b)(2)(i), in order to be a major modification, the project must result
in a significant emissions increase, and a significant net emissions increase.

As defined at 40 CFR 52.21(b)(40): Significant emissions increase means, for a regulated NSR
pollutant, an increase in emissions that is significant for that pollutant. Significant is further defined
to mean, in reference to a net emissions increase or the potential of a source to emit any of the
following pollutants, a rate of emissions that would equal or exceed the values outlined in 40 CFR
52.21(b)(23). If the increase in emissions from the project are not significant, a major modification
has not occurred.

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 42

increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

For all pollutants, the project emissions increase was calculated as the difference between the
projected actual emissions (PAE) after the proposed project and the actual emissions prior to the
project (baseline actual emissions or BAE).

Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
". . . projected actual emissions means the maximum annual rate, in tons per year, at which an
existing emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years
(12-month period) following the date the unit resumes regular operation after the project, or in any
one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit of that regulated NSR pollutant and full utilization of the unit would
result in a significant emissions increase or a significant net emissions increase at the major
stationary source." [Last updated January 14, 2025]

5. Comment regarding PSD applicability analysis cont.:
Ash Grove estimates that the projected actual production capacity following the project will be
1,155,000 tons of clinker per year and 1,341,266 tons of limestone per year. These capacities were
used to calculate projected actual emissions from the project using representative emission factors.
Additionally, to estimate emissions from material transfer baghouses, the actual flow rates and actual
projected hours were used as a basis for projected actual emissions.

Project Emission Calculations

Project emission increases from the kiln and coal mill systems are calculated for all criteria
pollutants based on emission factors that are derived from stack testing, CEMS data, or emission
factors (i.e., VOCs and Lead), and the associated projected incremental clinker increase.

NOx emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain
hourly capacity to emit and annual potential to emit at current levels. The kiln's NOx emissions rate
will not change as a result of the physical modifications proposed by the project.

Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission
factor and multiplied by the incremental increase in clinker production. The emission factor was
selected based on the average of the 24-month consecutive month emissions for 2020 and 2021. The
CO emissions will increase.

The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing
conducted at the plant. The SO2 emissions will increase.

VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production. VOC emissions will increase.

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 43

can be found in the original NOI and subsequent addendums submitted to UDAQ.

As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from
the proposed project, each increase of emissions from both existing and new sources shall be
summed together and compared to the PSD permitting thresholds. The increase of emissions is the
"positive" difference between the projected actual emissions and baseline actual emissions (projected
minus baseline).

New Emissions Sources

The actual to projected actuals calculation is not available to new emission units. For new emission
units, the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected
emissions are based on the new sources' potentials to emit. (40 CFR § 52.21(a)(2)(iv)(f)).

The new equipment proposed includes the New Finish Mill, a new rail and truck loading/loadout,
one (1) new clinker reclaim loading hopper with a dust collector and one (1) existing clinker reclaim
hopper with a dust collector, a new Clinker Cooler to replace the existing one, and a new kiln feed
alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions:

The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;

The finish mill heater was calculated based on its maximum firing capacity and flow rates; and

The fugitive emissions were calculated based on the projected annual throughput of the New Finish
Mill, the rail loadout, and clinker production. [Last updated January 14, 2025]

6. Comment regarding PSD applicability analysis cont.:
Existing Emission Sources

For the existing sources, the projected actual emissions are the maximum annual rates in tons per
year projected to occur during the next five (5) to ten (10) years if the existing sources' design
capacities increase. Ash Grove Leamington projected the actual emissions for the next five (5) years
based on the new kiln system producing an annual average of 3,250 tons of clinker per day.

Baseline actual emissions (BAE) are defined at 40 CFR 52.21(b)(48)(ii) as:

". . . baseline actual emissions means the average rate, in tons per year, at which the emissions unit
actually emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the 10-year period immediately preceding either the date the owner or operator
begins actual construction of the project, or the date a complete permit application is received by the
Administrator."

Ash Grove has selected to use the years 2020 and 2021 for each pollutant as the representative
baseline years.

In its NOI, Ash Grove calculated the emission increase from the project as being divided into two
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 44

phases. Phased construction projects are discussed in two sections of the federal PSD regulations -
40 CFR 52.21(j)(4) and 40 CFr 52.21(r)(2). UDAQ is not processing this project as a phased
construction project, nor did Ash Grove request such a determination. Therefore, Ash Grove
provided a summary table outlining the final change in emissions from this project:

Projected Actual Increase Compared to PSD threshold (tons per year)
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2e
BAE 76.64 39.64 1,187 6.87 3,315 55.47 641,385
PAE 203.15 113.47 1,226 45.87 3,414 72.07 1,067,984

Change in Emissions 126.51 73.83 39.00 39.00 99.00 16.59 426,598

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes

If the emissions increase is greater than the PSD significance threshold for a particular pollutant, Ash
Grove has the option of conducting a PSD review or continuing through the rest of the steps to
determine if it can "net" out of a PSD review. If the project increase is less than the PSD significant
threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant.

The change in emissions from the project exceeds the significant emission threshold for three
pollutants: PM10, PM2.5 and CO2e. Ash Grove elected to attempt to net out of a PSD major
modification for the remainder of the criteria pollutants.

Netting

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant
Upgrade Project and ends on the date the upgrade begins operation. Only PM10, PM2.5, CO2e are in
excess of SERs and therefore considered in the netting analysis.

Ash Grove estimated that the commencement of construction will be in December 2024. Therefore,
the contemporaneous period for this project is December 2019 through a projected date the project
upgrade begins operation. [Last updated January 21, 2025]

7. Comment regarding PSD applicability analysis cont.:
Contemporaneous Decreases

Ash Grove replaced an existing kiln emergency drive engine with a USEPA Tier 4 diesel engine in
2022. Concurrently, Ash Grove requested an increase in the capacity of 1L Cement. Additionally,
Ash Grove submitted a minor modification NOI air permit application on June 12, 2023, which
proposes replacing the shipping generator during the contemporaneous period. The kiln emergency
drive engine and shipping generator are both higher EPA tier ratings therefore result in decreases for
PM10 and PM2.5. These changes were approved in AO DAQE-AN103030033-24 issued March 21,
2024.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 45

Contemporaneous Increases

As stated above, the existing kiln emergency drive engine and shipping generator were permitted and
replaced in 2024. This resulted in an increase in emissions of CO2e.

The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout
in an effort to improve truck traffic at the loadout. The modification to add these dust collectors to
the loadout was included in DAQE-AN103030029-19. The baghouses are three (3) levels up in the
silos' enclosed space (approximately 40 feet). Both dust collectors vent directly into the interior of
the silo structure and are not vented into the atmosphere. Ash Grove requests to remove these
baghouses from its existing permitted emissions inventory. Therefore, these emissions have been
documented in the netting analysis as zero emissions.

Also included in DAQE-AN103030033-24 were two new natural gas-fired emergency generators
and increases in stockpiles, material handling and road emissions.

Could Have Been Accommodated Emissions

In calculating project emissions increase, USEPA allows the exclusion of existing
production/emissions rates that could have been accommodated during the baseline period. These
"could have been accommodated" emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as
follows:

". . . Shall exclude, in calculating any increase in emissions that results from the particular project,
that portion of the unit's emissions following the project that an existing unit could have
accommodated during the consecutive 24-month period used to establish the baseline actual
emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project,
including any increased utilization due to product demand growth;"

Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the
exclusion of existing production and emissions rates that could have been accommodated during the
baseline period, it has elected not to use this exclusion at this time. Therefore, calculation of the
"could have been" accommodated emissions have not been included in this application's
applicability analysis.

The increase from the project is added to the contemporaneous decreases and contemporaneous
increases. The resulting calculation is then compared to the PSD significance threshold to determine
if a significant net emissions increase has occurred. [Last updated January 14, 2025]

8. Comment regarding PSD applicability analysis cont.:
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2 e
Contemporaneous Inc. 1.61 0.45 0.41 0 0.27 0.07 51.74

Contemporaneous Dec. -1.54 -3.97 -0.48 -0.02 -0.27 -0.09 0

Change in Emissions 125.02 69.21 38.93 38.98 99.00 16.58 426,650

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 46

The results of the netting analysis conclude that both a significant emissions increase and a
significant net emissions increase in both particulates (PM10 and PM2.5) and CO2e will occur from
this project. Thus, the project must be reviewed as a PSD major modification. [Last updated January
14, 2025]

9. Comment regarding emission calculations:
This engineering review includes updated potential emission totals for both criteria and HAP
emissions. The potential-to-emit (PTE) values were calculated using updated values for clinker
produced and raw material inputs. BACT emission factors and limitations were used where
appropriate. Certain emission totals (NOx, SO2 and CO) were set based on avoiding a significant
increase in emissions. Specifically, the projected actual increase was set at just under the baseline
actual emissions + the significance level. As these emissions are monitored by CEM, UDAQ agrees
with this approach. Please see the netting analysis for further details on calculation of projected
actual increase. The NOx hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project.

CO2e emissions were calculated using the GHG emission factor calculated from 40 CFR Part 98
Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in Subpart A Table
A-1.

To calculate the PTE tons per year, the maximum hours (i.e., 8760) per year and the source's
emissions rates were multiplied with the throughputs. The potential throughputs have been updated
at UDAQ's request so that PAE is equal to PTE and represents the equipment's maximum design
potential.

Additional emission calculations based on source testing and monitoring, and EPA's compilation of
air emission factors AP-42. [Last updated January 14, 2025]

10. Comment regarding requirements for PSD review:
In addition to the permitting requirements of R307-401-5 through R307-401-8, there are additional
requirements under PSD that must be addressed:

1. Calculation of ambient air increments (40 CFR 52.12(c)), ambient air ceilings ((40 CFR 52.12(d)),
source impact analysis (40 CFR 52.12(k)), air quality models (40 CFR 52.12(l)) - these items are
addressed in the modeling memo DAQE-MN103030032-24.

2. Stack heights (40 CFR 52.12(h)) - Ash Grove's stack heights have been reviewed with respect to
good engineering practice and operate in a vertical unrestricted manner.

3. Control technology review (40 CFR 52.12(j)) - this is addressed in the BACT analysis section of
this review document.

4. Air quality analysis: preapplication analysis (40 CFR 52.12(m)) - this is covered in the PSD
applicability and netting analysis sections of this review document, ambient monitoring and
background data collection is also included in the modeling memo DAQE-MN103030032-24.

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 47

grain loading limit included in II.B.1.j.1 represents the required post-construction monitoring.
6. Source information (40 CFR 52.12(n)) - this is addressed under the requirements of R307-401-5
and was submitted by Ash Grove as part of the NOI package.

7. Additional impact analysis (40 CFR 52.12(o)) - these requirements cover soils, vegetation, growth
and visibility concerns. They are discussed in the modeling memo DAQE-MN103030032-24.

8. Federal land manager review (40 CFR 52.12(p)) - UDAQ provided initial notification to all
federal land managers upon receipt of the original NOI package. The draft permit and engineering
review will also be provided to the federal land managers 60-days prior to initiation of public
comment for their further review.

9. Public participation (40 CFR 52.12(q)) - this project will have a 30-day public comment period.

10. Source obligation (40 CFR 52.12(r)) - this requirement discusses source compliance with other
parts of the CAA, which is addressed within UDAQ's permitting rules in R307.
[Last updated January 14, 2025]

11. Comment regarding changes in equipment list:
The equipment list is being updated for clarity as well as adding new pieces of equipment. The
following changes are taking place:

The naming scheme is being updated to remove the numerical code from the unit designation. This
code generally referred to the associated control device and not to the emitting unit itself. This can
cause confusion especially when the same code was applied to multiple pieces of equipment.
Instead, the control devices (typically baghouse dust collectors) will be identified in the description
along with the appropriate numerical code.

Specific changes are as follows:

1. The kiln description has been updated

2. Clinker Cooler description has been updated to include a larger pulse jet baghouse.

3. The clinker storage silos, east and west clinker belts, clinker belt transfer and clinker tunnel have
been consolidated to avoid confusion

4. The north and south cement loadout exhausts now vent internally into the cement storage silos

5. The dust shuttle system has been consolidated into one line item, most identifiers removed from
subsystem descriptions as only two baghouses serve as exhaust points.

6. A new finish mill with heater has been added. Included in the description are the thirteen total
baghouses for dust control (1 main stack, 2 transfer points, 10 nuisance dust filters)

7. A new clinker reclaim hopper has been added. Both reclaim hoppers are controlled by baghouses
with updated identifiers

8. A new rail and truck loading/unloading system with two baghouses has been added.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 48

[Last updated December 20, 2024]

12. Comment regarding changes in conditions:
As a result of this project, several conditions will be added or changed. This includes one new
general condition (I.8). Changes to the equipment list (section II.A) will be addressed in a separate
reviewer comment:

I.8 - Adding this general condition to cover the requirements of R307-401-18 Eighteen Month
Review. The status of construction/installation of the new equipment shall be reviewed after
18-months.

II.B.1.a - Clinker production increases to 1,155,000 tpy
Use of limestone bypass material increases to 215,260 tpy

II.B.1.b - The NOx limit on the kiln decreases to 1,223 tpy, CO emissions from the kiln decrease to
3,395 tpy,
Adding a new CO2e limit of 0.92 tons CO2e/ton of clinker produced
PM limit on the clinker cooler decreased to 0.02 lb PM (filterable)/ton of clinker
Rule reference updated to include 40 CFR 60 Subpart F, and R307-401-8

II.B.1.e - Initial testing on the clinker cooler is now required within 180 days of startup of the unit.
Monitoring of CO2 from the kiln will be by CEM.
Formatting changes on paragraph designated ++, improve clarity, include reference to CO2
monitoring, define CPMS

II.B.1.e.4 - Update to address general PM monitoring and reference R307-401-8

II.B.1.e.14 - New condition to address new or reconstructed emission units monitoring requirements,
applicable to the clinker cooler and new finish mill.

II.B.1.h - Adding references to Subpart OOO units (limestone processing) with updated opacity
limits.
Adding 20% opacity limit on coal transfer and storage
Adding property boundary opacity limit of 20%
Updating rule reference to include Subpart OOO

II.B.1.j - New condition to address outlet grain loading limits on new baghouses, One identical limit,
15 total new baghouses.

II.B.1.j.1 - Monitoring on new baghouses as per II.B.1.e.4, added an allowance to test less frequently
than annually with three successful tests.

II.B.3.a - Updating formatting to add clarity and include reference to CO2 CEM

II.B.5 - New conditions on emergency engines, diesel fuel sulfur limits, hour of operation
restrictions, non resettable hour meter

[Last updated December 20, 2024]
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 49

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 51

TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 52

DAQE-MN103030032-24

M E M O R A N D U M

TO: John Jenks, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler
Dave Prey, Air Quality Modeler

DATE: December 12, 2024

SUBJECT: Modeling Analysis Review for the Ash Grove Cement Company – Leamington Plant,
located in Millard County, Utah
___________________________________________________________________________________
This is a Major Modification to a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Ash Grove Cement Company (Applicant) has submitted a Notice of Intent (NOI) air permit
application for a project referred to as the Leamington Upgrade Project (LUP). The proposed
upgrade project includes the construction and installation of new pollution control equipment, new
emission sources, and modifications to existing emission sources. Emission increases associated
with the LUP constitute a major modification to a Prevention of Significant Deterioration (PSD)
source subject to PSD permitting regulations. PSD regulations require the Applicant to include and
air quality impact analysis (AQIA) of the proposed projects impact on the EPA national ambient air
quality standards (NAAQS) and air quality related values (AQRV) as part of a complete NOI.

This report prepared by the New Source Review (NSR) modeling staff contains a review of the
Applicant’s Air Quality Impact Analysis (AQIA) including the methodology, data sources,
assumptions, and modeling results for comparison with State and Federal air quality standards. The
AQIA was reviewed and referenced in this report include the:
● Notice of Intent – Ash Grove Cement Leamington Plant PSD Notice of Intent Air Permit
Application, dated November 30, 2022.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

0 0
Jason Krebs

DP
DAQE-MN103030032-24
Page 2

II. APPLICABLE RULES AND ANALYSES

A Utah Air Quality Rules

The UDAQ has determined that the Applicant’s NOI is subject to the following rules for conducting an
AQIA:

R307-401 Permits: New and Modified Sources
R307-405 Permits: Major Sources Located in Attainment or Unclassified Area (PSD)
R307-406-2 Visibility – Source Review
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutant Impacts in Attainment Areas

B. Applicability

The proposed increases in emissions of PM10 and PM2.5 exceed the emission thresholds outlined in R307-
406-5 and R307-410-4. Therefore, an AQIA consistent with the requirements of R307-405-6, R307-406-
2, and R307-410-3 was submitted as part of the Applicant’s NOI. R307-410-3 establishes the U. S.
Environmental Protection Agency (US EPA) – Guideline on Air Quality Models as a formal basis for
defining the scope of the analysis, as well as the model’s construction. The results of the AQIA are
required to demonstrate the proposed project’s impact on state and federal air quality standards,
acceptable levels of impact, and action triggering thresholds referenced or listed in R307-401-6(2), R307-
401-6(3), R307-403-3(1), R307-403-5(1)(a), R307-405-4(1), R307-405-6. Annual emissions for criteria
pollutants requiring an AQIA are listed in Table 1.

Table 1: Ash Grove Leamington Proposed Net Emissions Increase

Criteria
Pollutants
Net Emission
Increase (TPY)
AQIA Trigger
Level (TPY) AQIA Required?
PM10 126.6 15 Yes
PM2.5 70.3 10 Yes

C. Required Analyses

R307-405 requires the Applicant to perform a pre-construction modeling analysis for all pollutants
emitted in a significant quantity. The purpose of the analysis is to determine if the extent of the source’s
impact is significant enough to warrant an on-site measurement of the ambient background concentration
levels. This data is included in the NAAQS analysis to represent the quality of the air prior to the
construction of the proposed project. The Applicant included a pre-construction modeling analysis for
PM10 and PM2.5 as part of the NOI. The pre-construction modeling analysis was also used to determine if
the proposed emissions would result in a significant impact to the environment, thereby triggering the
requirement for a cumulative analysis of the proposed project and other nearby existing sources.

R307-401-8 requires the Division to determine that the proposed project will comply with the NAAQS
prior to the issuance of an Approval Order (AO). R307-405(7) requires the Applicant to perform a
DAQE-MN103030032-24
Page 3
NAAQS analysis for all pollutants emitted in a significant quantity. The analysis is to include all
emissions at the proposed site under normal operating conditions using maximum anticipated short-term
release and annual release rates. Consistent with UDAQ policy, a cumulative analysis to include the
ambient background concentration and any contribution from other nearby sources is not required if the
proposed project’s impact does not exceed the PSD Class II Significant Impact Level (SIL).

R307-401-8 also requires the Division to determine that the proposed project will comply with PSD
increments prior to the issuance of an AO. Under R307-405(6), the Applicant is required to perform a
PSD Class I and II increment consumption analysis for all pollutants emitted in significant quantities.
The purpose of this analysis is to quantify any degradation in air quality since the major source baseline
date. The analysis is to include all increment consuming emissions at the proposed site under normal
operating conditions using maximum anticipated short-term and annual release rates. A cumulative
analysis to include contributions associated with growth and other increment consuming sources is not
required if the proposed project’s impact does not exceed the PSD Class I or II SIL.

R307-410-5 requires the Applicant to perform a HAPs analysis for any pollutant emitted above a
pollutant specific emission threshold value. This analysis is to include all emissions of the pollutants
resulting from the proposed modification under normal operating conditions using maximum anticipated
one-hour release rates. The Applicant did not trigger modeling for HAPs.

R307-406-2 requires the Applicant to perform a plume blight analysis. A plume blight analysis is required
to determine if plumes emanating from the proposed project would be visible inside any Class I area
within 50 kilometers of the source. The plume blight analysis is to include all emissions of NO2, SO4, and
PM10.

Under R307-405-16, an AQRV analysis is performed which evaluates regional haze and acid deposition
impacts at each of the Class I areas within 300 kilometers of the source. A regional haze analysis is
required to determine if the plumes would reduce the visual range of an observer inside the Class I area.
The regional haze analysis is to include all emissions of SO2, NOX and PM10. The deposition analysis
examines impacts from sulfur and nitrogen compounds at the Class I areas, and is based on all emissions
of SO2 and NOX. The Federal Land Managers use the Q/D approach to determine whether a PSD project
should provide detailed AQRV impact analyses, where: Q/D= [ H2SO4 + SO2 + NOx + PM10 emissions
(tpy)]/ distance (km). If Q/D is less than 10, no AQRV analysis is required.

R307-405 requires the Applicant to perform a soils and vegetation analysis. The analysis should quantify
the effects of pollutants on soils and vegetation near the highest impact location and in areas where
sensitive plant species may be impacted.

III. ON-SITE PRE-CONSTRUCTION MONITORING

A. Meteorological Data

Consistent with the US EPA - Meteorological Monitoring Guidance for Regulatory Modeling
Applications, one year of on-site data was collected using a 50-meter tower during the period October 1,
2021 through September 30, 2022. Parameters collected on-site included wind speed and direction,
temperature, delta-T, and solar radiation.

DAQE-MN103030032-24
Page 4

B. Ambient Pollutant Data

A preliminary analysis was conducted to determine the necessity for pre-construction ambient pollutant
monitoring. The results indicate that predicted concentrations of PM10 and PM2.5 exceed the monitoring
trigger level listing in the rule. A continuous PM10/PM2.5 monitor with filter based samplers was
installed near the northern edge of the Applicants property boundary, and collected particulate matter
from October 1, 2021 through September 30, 2022.

IV. MODEL SELECTION

The EPA-AERMOD dispersion modeling system is the preferred model specified in the US EPA –
Guideline on Air Quality Models to predict air pollutant concentrations in the near field (within 50
kilometers of the source). The US EPA - CALPUFF - Version 5.8 model is the preferred model to predict
concentrations in the far field (long range transport conditions beyond 50 kilometers from the source).

V. MODELING INPUTS AND ASSUMPTIONS

A. Technical Options

The regulatory default options were selected in AERMOD by the Applicant to quantify all concentrations.

B. Urban or Rural Area Designation

A review of the appropriate 7.5-minute quadrangles determined that the area should be classified as
“rural” for air modeling purposes.

C. Topography/Terrain

The Plant is at an elevation of 4,950 feet with nearby terrain features that have an effect on concentration
predictions.

a. Zone: 12
b. Location: UTM (NAD83): 397000 meters East, 4379850 meters North

D. Ambient Air

It was determined that the Plant boundary used in the AQIA meets the State’s definition of an ambient air
boundary.

E. Receptor and Terrain Elevations

The modeling domain has simple and complex terrain features in the near field. Therefore, receptor
points representing actual terrain elevations from the area were used in the analysis.

The far-field modeling domain consisted of a rectangular region covering all Class I areas within Utah,
and extending 50 kilometers beyond this area so that the model can account for re-circulation of the
plume.

DAQE-MN103030032-24
Page 5

F. Emission Rates and Release Parameters

The emission estimates and source parameters used in AERMOD for all proposed emission sources at the
site are presented in the NOI.

Speciated emission rates and source parameters used in the CALPUFF modeling are presented in Table 2.

Table 2: CALPUFF Emission Rates

Source
LCC Coordinates Modeled Emission Rates
Easting Northing SO2 SO4 NOX HNO3 NO3 SOA PMC SOIL EC
(m) (m) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr)
317.BF3 -1289410 -3738 52.81 5.03 307.58 0.00 0.00 5.03 2.60 2.90 0.11
419.BF1 -1289314 -3631 0.00 0.00 0.00 0.00 0.00 0.55 1.51 1.61 0.06
41B.BF2 -1289389 -3663 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.68 0.00
N1_FM2 -1289526 -3414 0.00 0.00 0.00 0.00 0.00 0.00 1.65 3.95 0.00
414.BF1N -1289407 -3683 0.00 0.00 0.00 0.00 0.00 0.00 0.10 0.25 0.00
2FM_HTR -1289528 -3415 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.08 0.00
514.BF1 -1289451 -3675 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.70 0.00
COMBO -1289424 -3668 0.00 0.00 0.00 0.00 0.00 0.00 1.37 5.72 0.00
FM2_CMB -1289454 -3439 0.00 0.00 0.00 0.00 0.00 0.00 0.50 1.21 0.00

Total Lb/hr 52.81 5.03 307.58 0.00 0.00 5.58 8.32 17.10 0.17
Hrs/Yr 8760 8760 8760 8760 8760 8760 8760 8760 8760
Ton/yr 231.3 22.0 1347.2 0.0 0.0 24.4 36.4 74.9 0.8

Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
317.BF3 POINT 4902.8 41.2 135.0 488 10.10 3.35
419.BF1 POINT 4891.2 18.3 60.0 388 6.36 2.90
41B.BF2 POINT 4895.2 68.6 224.9 294 17.83 0.74
N1_FM2 POINT 4832.0 49.7 163.0 363 40.08 1.40
414.BF1N POINT 4896.1 76.8 251.9 353 9.91 0.70
2FM_HTR POINT 4832.0 49.7 163.0 363 40.08 1.40
514.BF1 POINT 4889.5 39.6 130.0 294 11.86 0.91
COMBO POINT 4904.2 13.3 43.7 276 9.76 0.32
DAQE-MN103030032-24
Page 6
FM2_CMB POINT 4832.0 30.6 100.3 294 11.40 0.37

G. Building Downwash

The Applicant used the US EPA Building Profile Input Program (BPIP) to determine Good Engineering
Practice (GEP) stack heights and cross-sectional building dimensions for input into the model.

H. Ambient Background Concentrations

Millard County is in attainment for all criteria pollutants. The NAAQS analyses for PM2.5 and PM10 used
monitoring data collected on site during the pre-construction monitoring analysis. The background values
used in the NAAQS analysis are presented in Table 3.

Table 3: Background Concentrations

Pollutant Averaging
Period
Background
Concentration
(μg/m3)
PM10 24-hour 65.4
PM2.5 24-hour 10.2
Annual 4.2

I. Meteorological Data Processing

For the AERMOD model, on-site horizontal and vertical wind speed, direction, solar radiation and,
temperature data was combined with National Weather Service (NWS) upper air data collected at the Salt
Lake City International Airport (SLCIA) for the same period using the US EPA AERMET processing
system.

Meteorological data used for the CALPUFF modeling analysis consisted of 3 years (2018-2020) of data
developed by the Forest Service. The grid was 708 km (east-west) by 492 km (north-south) with a
resolution of 12 kilometers.

VI. RESULTS AND CONCLUSIONS

The Applicant performed a series of analyses to estimate the impact from the proposed project. Modeling
results and conclusions from the review of the analyses are outlined in detail below.

A. Pre-Construction Monitoring and Significant Impact Modeling

The Applicant performed a preliminary criteria pollutant analysis of the proposed modification. This
analysis indicated that increases in concentration levels of PM2.5 and PM10 were greater than the Class II
SIL, and therefore, a cumulative analysis for these pollutants was required.

DAQE-MN103030032-24
Page 7

B. NAAQS Analysis

The Applicant performed a modeling analysis to determine if the combined impact from the proposed
source, other industrial sources operating in the area, and ambient background would comply with the
NAAQS. The NAAQS analysis was reviewed by the Division and determined to be consistent with the
requirements of R307-410-3. Table 4 provides a comparison of the Applicant’s predicted air quality
concentrations and the NAAQS.

Table 4: Model Predicted NAAQS Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-hour 28.3 5 65.4 0 93.7 150 62.5%
PM2.5 24-hour 9.6 1.2 10.2 0 19.8 35 56.6%
Annual 4.4 0.3 4.2 0 8.6 9 95.6%
* Note: Only included other sources and background if source impact was above Class II SIL

C. PSD Class II Increments

The Applicant performed an analysis to determine if the impact from the proposed source would comply
with PSD Class II increments. The analysis was reviewed by the Division and determined to be
consistent with the requirements of R307-410-3. Table 5 provides a comparison of the predicted
concentrations and the PSD Class II increment.

Table 5: Model Predicted PSD Class II Increment Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Nearby
Sources*
Total Increment Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
PM10 Annual 8.1 1 0 8.1 25 32.4%
24-hour 28.3 5 0 28.3 30 94.3%
PM2.5 24-hour 6.1 1.2 0 6.1 9 67.8%
Annual 2.4 0.3 0 2.4 4 60.0%

D. Hazardous Air Pollutants

DAQE-MN103030032-24
Page 8
The Applicant performed an analysis to determine if HAP modeling is required. The analysis was
reviewed by the Division and determined to be consistent with the requirements of R307-410-3. The
analysis indicated that HAP modeling was not triggered by this modification, and therefore no HAP
modeling was performed.

E. PSD Class I Increment Consumption Analysis

The Applicant performed a CALPUFF analysis to determine if the impact from the proposed source along
with other increment consuming sources would comply with federal PSD Class I increments. The
analysis was reviewed by the Division and determined to be consistent with the requirements of R307-
410-3. The results for all Class I areas within 300 kilometers are provided in Table 6.

Table 6: Model Predicted PSD Class I Increment Concentrations

Air Period Prediction
Class I
Significant
Impact
Level
Other
Sources* Total Increment Percent
Pollutant (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
Capitol Reef
NO2 Annual 0.0018 0.1 2.5
SO2
3-Hour 0.0494 1 25
24-
Hour 0.0150 0.2 5
Annual 0.0008 0.1 2
PM2.5
24-
Hour 0.0430 0.27 2
Annual 0.0021 0.05 1
PM10
24-
Hour 0.0444 0.3 8
Annual 0.0021 0.2 4
Arches
NO2 Annual 0.0008 0.1 2.5
SO2
3-Hour 0.0408 1 25
24-
Hour 0.0102 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0522 0.27 2
Annual 0.0018 0.05 1
DAQE-MN103030032-24
Page 9
PM10
24-
Hour 0.0531 0.3 8
Annual 0.0019 0.2 4
Canyonlands
NO2 Annual 0.0010 0.1 2.5
SO2
3-Hour 0.0354 1 25
24-
Hour 0.0100 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0577 0.27 2
Annual 0.0019 0.05 1
PM10
24-
Hour 0.0591 0.3 8
Annual 0.0020 0.2 4
Bryce
NO2 Annual 0.0006 0.1 2.5
SO2
3-Hour 0.0369 1 25
24-
Hour 0.0082 0.2 5
Annual 0.0003 0.1 2
PM2.5
24-
Hour 0.0189 0.27 2
Annual 0.0010 0.05 1
PM10
24-
Hour 0.0194 0.3 8
Annual 0.0010 0.2 4
Zion
NO2 Annual 0.0011 0.1 2.5
SO2
3-Hour 0.0293 1 25
24-
Hour 0.0105 0.2 5
Annual 0.0005 0.1 2
PM2.5
24-
Hour 0.0266 0.27 2
Annual 0.0011 0.05 1
PM10 24-
Hour 0.0271 0.3 8
DAQE-MN103030032-24
Page 10
Annual 0.0012 0.2 4
* Note: Only included other increment consuming sources if source impact was above Class I SIL

Since the proposed project’s model predicted impacts at the Class I areas were less than the PSD Class I
significance levels, a cumulative analysis was not warranted.

DAQE-MN103030032-24
Page 11
F. Visibility – Plume Blight
Since the Class I areas are greater than 50 kilometers from the source, a plume blight analysis using
VISCREEN was not required.

G. Visibility – Regional Haze

The results of the Q/D analysis for the emissions increase was less than 10 but the FLMs wanted the
entire source included in the Q term. The results of including the total emissions resulted in a Q/D >10,
so an AQRV analysis was performed for visibility and acid deposition. The results shown in Table 7
indicate that the impacts are below the 0.5 Deciview (DV) threshold established by the National Park
Service, indicating that no further analysis is required.

Table 7: CALPUFF Visibility Results

Class I Area Year Maximum
Delta DV
98th
Percentile
change in
DV
#
Days
#
Days Threshold
(DV)
Below
Threshold
> 1 > 0.5
2018 0.248 0.06 0 0 0.5 Yes
Arches 2019 0.291 0.054 0 0 0.5 Yes
2020 0.216 0.106 0 0 0.5 Yes
2018 0.223 0.081 0 0 0.5 Yes
Canyonlands 2019 0.312 0.068 0 0 0.5 Yes
2020 0.186 0.085 0 0 0.5 Yes
2018 0.059 0.03 0 0 0.5 Yes
Bryce 2019 0.081 0.045 0 0 0.5 Yes
2020 0.071 0.03 0 0 0.5 Yes
2018 0.183 0.074 0 0 0.5 Yes
Capital Reef 2019 0.196 0.092 0 0 0.5 Yes
2020 0.126 0.078 0 0 0.5 Yes
2018 0.069 0.04 0 0 0.5 Yes
Zion 2019 0.123 0.039 0 0 0.5 Yes
2020 0.102 0.057 0 0 0.5 Yes

DAQE-MN103030032-24
Page 12

H. Acid Deposition

The Applicant performed a deposition analysis on impacts within the Class I areas. Results of the
analysis indicate that the impacts are below the deposition threshold (DAT) established by the National
Park Service, indicating that no further analysis is required

Table 8: CALPUFF Deposition Results for Highest Year

Class I Area
Total
Nitrate
Deposition
Total
Sulfate
Deposition
Deposition
Analysis
Threshold
(kg/ha/yr) (kg/ha/yr) (kg/ha/yr)
Canyonlands 0.0006 0.0003
0.005
Zion 0.0004 0.0002
Arches 0.0006 0.0003
Bryce 0.0006 0.0002
Capitol Reef 0.0011 0.0005

I. Soils and Vegetation Analysis

The Applicant performed an analysis to determine the extent of impacts from the proposed source on soil
and vegetation. Results of the analysis are presented in a supplemental document titled “Soil and
Vegetation Impact Analysis for the Leamington, UT Facility, June 29, 2023”. The analysis indicated that
predicted concentrations compared against the secondary NAAQS at several sensitive receptors would not
result in an adverse impact on soils and vegetation in the vicinity of the proposed project.

DP/JK:jg

DAQE-IN103030032-25

January 22, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Mr. Nelson:

Re: Intent to Approve: Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — ) A A v A ? A D @ A w D D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — ) A A v A ? A D @ A w D D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ash Grove Cement Company Ash Grove Cement Company - Leamington Cement Plant

Mailing Address Physical Address
P.O. Box 38069 Highway 132
Leamington, UT 84638 Leamington, UT 84638

Source Contact UTM Coordinates
Name: Cody Watkins 397000 m Easting
Phone: [phone] 4380100 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3241 (Cement, Hydraulic)

SOURCE INFORMATION
General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried on site),
are correctly proportioned, ground, and mixed and then fed into a rotating kiln. The kiln alters the
materials and recombines them into small stones called cement clinker. The clinker is cooled and ground
with gypsum and additional limestone into a fine powdered cement. The final product is stored on site for
later shipping. The major sources of air emissions are from the combustion of fuels for the kiln operation,
from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source of
emissions of PM2.5, PM10, NOx, CO, HAPs, and GHG. It is a minor source of SO2 emissions.
NSR Classification
Major PSD Modification

Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
DAQE-IN103030032-25
Page 4

Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

These changes result in increases in actual emissions but decreases in most potential emissions. There will
be an increase in the potential emissions of VOCs and greenhouse gases.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
DAQE-IN103030032-25
Page 5

Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
DAQE-IN103030032-25
Page 6

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
DAQE-IN103030032-25
Page 7

II.A.4 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)
II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area, and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, stacker systems. II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit-specific requirements.
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total air flow controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter
area; 9,865 acfm total air flow, controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are
controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each
is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6). II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The
following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for
NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.
II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low-pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

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II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow through stack
E34.
II.A.18 Kiln Feed Alleviator A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the central material silo between the blending silos and the preheater. Raw feed is removed from the system near the top of the preheater tower.
II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The
coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter area;
1,700 acfm total air flow.
II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker
storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1): 1,800 acfm that discharges into the clinker tunnel.
II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
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II.A.27 Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during loading.
II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel, all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during loading. 512.BF3 (1,000 acfm) is located on top of the silo. II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement products. Dust generated
during milling is captured by a BHA pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).

II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates from stack G55 (finish mill stack).
II.A.32 Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4).
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1 thru 3).

II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total air flow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations.
II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This
baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

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II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.
II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023)
II.A.40 Dust Shuttle System A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides, surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the
fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

II.A.41 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons) Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
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II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)
THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)
CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)
PM: 0.02 lbs filterable PM per ton of clinker.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR 60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to approve alternative control measures, the permittee shall keep a copy of the submitted petition and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source
of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2).
[40 CFR 63 Subpart LLL]

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II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must record the PM CPMS output data for all periods when the process is operating and use all the PM CPMS data for calculations when the PM CPMS is not out of control. The owner/operator must demonstrate continuous compliance by using all quality-assured hourly average data collected by the PM CPMS for all operating hours to calculate the arithmetic average operating parameter in units of the operating limit on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
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II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

II.B.1.e.3 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-165]
II.B.1.e.4 PM 40 CFR 60, Appendix A, Method 5, or 5I, or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three runs, with each
run at least 120 minutes in duration and each run collecting a sample of 60 dry standard cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165]
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II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
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II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
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II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer point, is not required to conduct Method 22 visible emissions monitoring under this paragraph. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator may decrease the frequency of performance testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
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II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: Instances of water and/or chemical application to unpaved areas shall be recorded and maintained by the owner/operator. The ambient temperature shall be recorded any time water should be applied but cannot due to freezing conditions. [R307-401-8]
II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

The sprays shall operate whenever dry conditions warrant meeting the required opacity
limitations or as determined necessary by the Director. Water sprays shall not be required during
periods of freezing temperatures.

[R307-401-8]

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II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

C. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the kiln/raw mill stack

F. The owner/operator shall record the output of the system: including the quantity of NOx, CO, O2, THC, Hg, HCl, and CO2 emissions at the kiln stack

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an
affected source shall continuously operate all required continuous monitoring devices
and shall meet minimum frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.

[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]
II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments, the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the results of the performance test demonstrating compliance with the filterable PM limit and using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust the SSOL developed in accordance with the results of the most recent PM performance test demonstrating compliance with the PM emission limit. The owner/operator shall use the PM CPMS to demonstrate continuous compliance with the SSOL in accordance with the requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

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II.B.4 Fuel Limitations: II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke F. Fuel Oil
G. Used Oil Fuel

H. Synthetic Fuel
I. Wood
J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal additive.
Approval is not required to change from one previously approved coal additive to another
previously approved coal additive. [R307-401-8]
II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily heat input of the kiln and precalciner. The owner/operator may increase the average quantity of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon approval by the Director in accordance with the approval process described in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

DAQE-IN103030032-25
Page 20

II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight
A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation
C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit-no less than 1500oF for more than five minutes in any 60-minute period B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
DAQE-IN103030032-25
Page 21

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the Director. The calibration procedure and frequency shall be according to manufacturer's specifications. Use of factory-calibrated thermocouples for temperature measurement is approved. However, any other method of temperature measurement must be approved by the Director prior to use. The monitoring equipment for both temperature and oxygen content shall be located such that an inspector can at any time safely read the output. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall only operate the emergency engines for testing and maintenance purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency operation. [R307-401-8]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.5.b.2 To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From Source Submitted NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-IN103030032-25
Page 22

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-GN103030032I-25

January 22, 2025

Via Certified Mail 70190700000208349789

Lisa Devore
National Park Service
Intermountain Region
12795 West Alameda Parkway
Lakewood, CO 80225
[e-mail]

Dear Ms. Devore:

RE: Notice of Publication for Ash Grove Cement Company- Leamington Cement Plant – CDS A;
MACT (Part 63), Compliance Assurance Monitoring (CAM), Title V (Part 70) Major Source,
Major Criteria Source, Major HAP Source, Attainment Area, NSPS (Part 60),
Project Number: N103030032

On January 22, 2025, the Director has completed his review of a Prevention of Significant Deterioration
project submitted by Ash Grove Cement Company. Attached to this letter are the draft Approval Order
document (Intent to Approve) and the full engineering review. Following a 60-day review by the Federal
Land Managers, this project will be submitted for a 30-day public comment period. Written comments
received by the Division at this same address during these comment periods will be considered in making
the final decision on the approval/disapproval of the proposed Approval Order. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director at the Division in writing, a hearing
will be held in accordance with R307-401-7, UAC.

If you have any questions, please contact John Jenks, who may be reached at [phone].

Sincerely,

Jon L. Black, Manager
New Source Review Division

Enclosures: Engineering Review
Modeling Memo
Intent to Approve

JLB:JJ:jg
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

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State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
RN103030032
January 21, 2025
Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]
Dear Josh Nelson,
Re: Engineer Review:
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032
Please review and sign this letter and attached Engineer Review (ER) within 10 business days.
For this document to be considered as the application for a Title V administrative amendment, a
Title V Responsible Official must sign the next page.
Please contact John Jenks at [phone] if you have any questions or concerns about the ER.
If you accept the contents of this ER, please email this signed cover letter to John Jenks at
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 1

[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the
DAQ will consider any comments received and will issue the Approval Order.

If you do not respond to this letter within 10 business days, the project will move forward
without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue
an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 2

OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible
Official, as defined in R307-415-3, must sign the statement below. THIS IS STRICTLY
OPTIONAL.

If you do not want the Engineer Review to be considered as an application to administratively
amend your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will
require submittal of a separate Operating Permit Application to revise the Title V permit in
accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document:
Title V Operating Permit Application Due Dates clarifies the required due dates for Title V
operating permit applications and can be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality

“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate
and complete and request that this Approval Order be considered as an application
to administratively amend the Operating Permit.”

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 3

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N103030032
Owner Name Ash Grove Cement Company
Mailing Address P.O. Box 38069
Leamington, UT, 84638

Source Name Ash Grove Cement Company- Leamington Cement
Plant
Source Location Hwy 132
Leamington, UT 84638

UTM Projection 397000 m Easting, 4380100 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3241 (Cement, Hydraulic)

Source Contact Cody Watkins
Phone Number [phone]
Email [e-mail]

Billing Contact Cody Watkins
Phone Number 385.225.0615
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 30, 2022
Date of Accepted Application November 28, 2024

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 4

SOURCE DESCRIPTION

General Description
Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried
on site), are correctly proportioned, ground and mixed, and then fed into a rotating kiln. The kiln
alters the materials and recombines them into small stones called cement clinker. The clinker is
cooled and ground with gypsum and additional limestone into a fine powdered cement. The final
product is stored on site for later shipping. The major sources of air emissions are from the
combustion of fuels for the kiln operation, from the kiln, and from the clinker cooling process.
The Leamington cement plant is a major source for emissions of PM2.5, PM10, NOx, CO, HAPs
and GHG. It is a minor source of SO2 emissions.

NSR Classification:
Major PSD Modification

Source Classification
Located in Attainment Area,
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Proposal
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower, various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 6

These changes result in increases in actual emissions, but decreases in most potential emissions.
There will be an increase in the potential emissions of VOC and greenhouse gases.

EMISSION IMPACT ANALYSIS
The complete modeling review is located in DAQE-MN103030032-24. [Last updated January 14, 2025]

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 7

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 8

Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 9

Review of BACT for New/Modified Emission Units

1. BACT review regarding the Leamington Plant Upgrade Project
Any major stationary source or major modification subject to PSD review must undergo an
analysis to ensure the use of BACT. The requirement to conduct a BACT analysis is set forth in 40
CFR 52.21. Similarly, Utah requires the installation of BACT for all sources of air pollution under
R307-401-5(2)(d)), BACT is defined in 40 CFR 52.21 (and R307-401-2) as:

". . . best available control technology means an emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for each pollutant subject to regulation under
Act which would be emitted from any proposed major stationary source or major modification
which the Administrator, on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such source or modification
through application of production processes or available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion techniques for control of such
pollutant . . ."

Therefore, a BACT analysis is required for each new or physically modified emission unit for each
pollutant that exceeds an applicable PSD significant emission rate (SER). Since the PM10 and PM2.5
emissions from the proposed project exceed the applicable PSD SER, a BACT analysis is required
to assess the required levels of control for these pollutants. Because the CO2e emissions are subject
to regulation as a result of the proposed project resulting in an increase of 75,000 tons or more per
year CO2e, a BACT analysis is also required for that pollutant. Note that HAPs listed under CAA
Section 112(b)(1) are excluded from NSR (New Source Review) or PSD (i.e., BACT) review.

In a memorandum dated December 1, 1987, the United States Environmental Protection Agency
(EPA) stated its preference for a "top-down" BACT analysis. After determining if any New Source
Performance Standard (NSPS) is applicable, the first step in this approach is to determine, for the
emission unit in question, the most stringent control available for a similar or identical source or
source category. If it can be shown that this level of control is technically, environmentally, or
economically infeasible for the unit in question, then the next most stringent level of control is
determined and similarly evaluated. This process continues until the BACT level under
consideration cannot be eliminated by any substantial or unique technical, environmental, or
economic objections.

Presented below are the five basic steps of a top-down BACT review as identified by the EPA.
Step 1 - Identify All Control Technologies
Step 2 - Eliminate Technically Infeasible Options
Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Step 4 - Evaluate Most Effective Controls and Document Results
Step 5 - Select BACT

Ash Grove has elected to follow this methodology and based the BACT review on each individual
pollutant. The complete BACT analysis follows. [Last updated January 14, 2025]

2. BACT review regarding PM10 and PM2.5 Sources
PM10 and PM2.5 Modified Equipment
The existing kiln precalciner, preheater, and alleviator system are proposed to be modified, and the
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 10

kiln's ID fan and clinker cooler fans are proposed to be replaced, which will result in increased
airflow. Additionally, the clinker cooler baghouse will be converted from a plenum pulse to a pulse
jet baghouse. These modifications are projected to result in a net increase of potential PM10 and
PM2.5 emissions.

Kiln Upgrade BACT
The rotary cement kiln is the core of the cement manufacturing process, transforming the blended
raw materials or "rawmix" into clinker through pyro processing. Emissions from the kiln occur
from fuel combustion plus the physical and chemical reactions needed to transform the rawmix
into clinker. This project involves process and energy efficiency improvements and an increase in
kiln production, resulting in an increase of PM10 and PM2.5 emissions. This section specifically
addresses filterable PM10 and PM2.5. The condensable fraction is represented with the other
precursors as applicable to proposed emission increases.

The Leamington Plant's Kiln is subject to NSPS, Subpart F for particulate. Therefore, a BACT
analysis addresses applicability of the proposed changes to the kiln system to NSPS and review of
the RBLC. A summary of the resources reviewed include the following:

NSPS Subpart F - Standards of Performance for Portland Cement Plants establishes emission
standards for cement kiln operations. Specifically, kilns modified after June 16, 2008, are limited to
0.07 lbs PM/ton of clinker produced.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028) and
Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from kiln operations are as follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM emissions are most effectively controlled using a collection system with enclosures routed to
baghouses providing up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Ash Grove
has selected technology with the highest control efficiency, so there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 11

Step 5 - Select BACT
Ash Grove proposes that BACT for PM10 and PM2.5 emissions from the kiln consist of a collection
system routed to a baghouse or fabric filter that complies with NSPS Subpart F's emission standard
for a modified source. BACT for the Leamington Plant's kiln are 10% opacity and 0.07 lb of
PM/ton (NSPS Subpart F emission standard) of clinker.
[Last updated January 14, 2025]

3. BACT review regarding PM10 and PM2.5 sources cont.
Clinker Cooler Upgrade BACT
The clinker cooler reduces the temperature of the clinker exiting the kiln. It is necessary to reduce
clinker temperature before it enters the finish mill to maintain product quality and reduce wear and
tear on equipment. The clinker cooler is equipped with a heat exchanger that captures waste heat
and transfers it to the kiln preheater for process and energy efficiency. Emissions from the clinker
cooler are vented to a baghouse. The Leamington Plant's clinker cooler is also subject to NSPS
Subpart F for particulate. Ash Grove's proposed changes to the clinker cooler meet the definition of
a reconstruction under NSPS. Therefore, in order to meet the requirements of NSPS Subpart F, Ash
Grove will be required to meet a limit of 0.02 lb of PM/ton of clinker.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from clinker cooler operations are as
follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM10 and PM2.5 emissions are most effectively controlled using a collection system with enclosures
routed to a baghouse, which can achieve up to 99.9% control efficiency. Other technologies such as
wet scrubbers, cyclones and ESPs are feasible, but provide lower control efficiencies than a
baghouse. Because the most efficient control technology is proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for PM10 and PM2.5 emissions from the clinker cooler is a collection system routed to a
baghouse or fabric filter. In order to meet the requirements of NSPS Subpart F, Ash Grove will
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 12

meet a reduced emission limit of 0.02 lb of PM/ton of clinker. A 10% opacity limit is also
applicable. [Last updated January 14, 2025]

4. BACT review regarding PM10 and PM2.5 sources cont.
New Finish Mill BACT
The proposed Plant upgrade include adding a second finish mill. The new finish mill will use an
energy efficient vertical roller mill assisted with a grinding aid. A total of five (5) point sources are
planned for the finish mill. In accordance with NSPS Subpart F, emissions from finish mill are
restricted to 10% opacity. Ash Grove has reviewed the following sources to identify available
control technologies.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);12 and

Region 8 General Permit for Concrete Batch Plants.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 emissions from plant material handling operations are as
follows:
Baghouse / Fabric Filter;
Best Management & Operational Practices;
Cyclone;
ESP;
Enclosure;
Water Application (Watering); and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
With the exception of water application, all options are technically feasible. Water application is
eliminated as clinker exiting the kiln along with additives in the finish mill must remain dry to
maintain product quality. Therefore, it is technically infeasible to water material in the finish mill.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Enclosure 50-90%
5. Cyclone 20-70%
6. Best Management & Operational Practices varies

Step 4 - Evaluate Most Effective Controls and Document Results
Baghouses provide the highest emission control efficiency, controlling up to 99.9% of PM
emissions from finish mill equipment. After baghouses, using a wet scrubber or ESP provides
similar PM control. Notably, baghouses, scrubbers, and ESPs require enclosures to aid in capturing
emissions and ducting to the control. Therefore, optimal PM emission control can be achieved
through implementing both baghouses and enclosures where feasible. Plant material sizing and
handling is currently done using a series of buildings and enclosures routed to baghouse controls.
Various silos storing material inputs are also equipped with fabric filters. As the highest ranked
technology is applied, there are no adverse energy, environmental or cost impacts to consider with
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 13

the use of these control technologies. Thus, no further analysis is required under EPA's top-down
BACT approach.

Step 5 - Select BACT
BACT for finish mill PM10 emissions is compliance with NSPS Subpart F, Standards of
Performance for Portland Cement Manufacturing where applicable. Ash Grove will achieve BACT
for PM10 emissions from finish mill equipment through the implementation of enclosures,
baghouses, and best management practices. All baghouses at the finish mill will have a 10%
opacity limitation and a grain loading of 0.005 grains/dscf. [Last updated January 14, 2025]

5. BACT review regarding PM10 and PM2.5 sources cont.
Material Transfer, Sizing, and Storage BACT
The Leamington Plant has sources of fugitive emissions through raw material transfer. Materials
transferred include limestone and other raw materials, coal, clinker, and cement. These materials
are transferred by conveyor belt, screw conveyor, elevator, pneumatic conveyance or chutes via
gravity. At the Leamington Plant the fugitive emissions are enclosed at their transfer points and
routed to baghouses.

The following emission units are included in this category:
Limestone Crushing, Sizing, and Material Transfer;
Raw Material Transfer;
Coal Sizing and Transfer;
Existing Finish Mill;
Clinker Storage and Transfer;
Cement Storage and Truck and Rail Cement Loadout;
New Rail Loading and Loadout; and
New Clinker Reclaim Hopper Baghouse.

Generally, controls for these units have not changed or they are similar to current existing controls.
A full BACT analysis of each unit is included in Ash Grove's NOI and additional submitted
information. However, given that most controls remain unaltered, only the results of Step 5 -
Select BACT will be included here.

Limestone Crushing, Sizing, and Material Transfer
Subject to NSPS Subpart OOO opacity limits for existing sources.
Existing baghouses. No change from bag manufacturer's specifications.

Raw Material Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Coal Storage and Transfer
Existing Equipment. No change from bag manufacturer's specifications
20% Opacity

Clinker Storage and Transfer
Subject to NSPS Subpart F opacity limits:
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10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Existing Finish Mill Grinding, Storage and Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Cement Storage and Truck and Rail Cement Loadout, New Rail Loadout
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

New Rail Loadout, controlled by baghouse
Emissions Limit - 0.005 gr/dscfm

New Clinker Reclaim Hopper, controlled by baghouse
Subject to NSPS Subpart F opacity limits:
10% opacity
Emissions Limit - 0.005 gr/dscfm [Last updated January 14, 2025]

6. BACT review regarding PM10 and PM2.5 sources cont.
PM10 and PM2.5 Fugitive Emissions
The following fugitive emissions sources will increase emissions of PM10 and PM2.5 as a result of
the Leamington Plant's proposed throughput increase. The sources addressed in the following
BACT analyses are primarily in the quarry, but also include emissions from roads and dumping of
raw materials within the plant boundary.

The sources evaluated are listed below:
Roads;
Loading and Unloading;
Stockpiles;
Bulldozing and Grading;
Disturbed Areas; and
Drilling and Blasting.

Ash Grove currently controls emissions from these processes, and generally, controls for these
units have not changed. A full BACT analysis of each unit is included in Ash Grove's NOI and
additional submitted information. However, given that most controls remain unaltered, only the
results of Step 5 - Select BACT will be included here.

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
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Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

Stockpiles BACT
BACT shall consist of restricting fugitive emissions to the opacity standard of 20% opacity at the
property boundary. BACT for stockpiles will be achieved through applying good management
practices through its fugitive dust plan as appropriate.

Bulldozing and Grading BACT
BACT shall consist of restricting fugitive emissions from bulldozing and grading activities to no
more than 20% opacity, and that emissions are controlled with periodic watering of the disturbed
surface. The frequency of water application will depend on ambient weather conditions and
inherent moisture content of the material being moved.

Disturbed Areas BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. BACT for
disturbed areas will be achieved through best management practices, watering, scarification, and
revegetation.

Drilling and Blasting BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. This is achievable
through best management practices, shrouds, watering, and dust collection. [Last updated January
14, 2025]

7. BACT review regarding kiln system NOx emissions
Kiln System (Kiln, Raw Mill, and Coal Mill) - NOx BACT
Although there are physical changes to the kiln system, these changes are primarily related to
particulate emissions. NOx emissions are generated from the combustion of fuel - and no changes
in NOx emissions are expected from the kiln (hourly capacity to emit). The kiln NOx emissions will
remain the same as a result of upgrades to the SNCR system. The replacement of the various
components of the kiln system and portions of the preheater tower, along with new injection points,
will ensure that increased mixing of ammonia is achieved to enhance the SNCR system's ability to
reduce NOx and minimize ammonia slip. This will allow the Leamington Plant to maintain the NOx
hourly capacity to emit unchanged from current levels Leamington Plant Upgrade Project. At
present Ash Grove has no restriction on the amount of fuel combusted, only a limit on total NOx
generated, and with this project the allowed NOx PTE is decreasing from 1,352 tpy to 1,226 tpy.

Additional ammonia will be used in the existing SNCR system. While the SNCR system has
adequate capacity to accommodate the additional ammonia demand resulting from the system
upgrades, more ammonia ports are proposed to be added with the kiln system's proposed changes
of the equipment. The changes proposed to the kiln system will increase residence time and
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temperature which will improve the SNCR system's effectiveness to control NOx emissions and
minimize ammonia slip emissions to the atmosphere. No additional review of NOx BACT for the
kiln system is required under this proposal. [Last updated January 14, 2025]

8. BACT review regarding new finish mill heater emissions
Finish Mill Heater
The proposed finish mill will include a process heater to maintain a minimum temperature during
milling. The proposed heater will run on natural gas and is rated at 10 MMBtu/hr. Startup and
shutdown emissions from the heater are anticipated to be no greater than normal operation as the
process is simply a matter of bringing the heater to operating temperature. Emissions evaluated in
the BACT analysis for the finish mill heater include NOx, SO2, CO, and VOCs, PM10, and PM2.5.
Pollutants with identical control technologies are grouped together in the analysis.

NOx - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for NOx from units of this size range are as follows:
Ultra-Low-NOx Burners (ULNB);
Low NOx Burners;
Selective Catalytic Reduction (SCR);
Selective Noncatalytic Reduction (SNCR);
Good Combustion Practices; and
Use of Natural Gas.

Step 2 - Eliminate Technically Infeasible Options
Low exit temperatures render the use of SCR and SNCR ineffective. Particulate entrainment within
the finish mill could potentially foul (plug) the nozzles of ULNB. Low-NOx burners, the use of
natural gas as fuel and good combustion practices are all considered technically feasible.

Step 3 and Step 4 - Rank Remaining Control Technologies by Control Effectiveness and Evaluate
Most Effective Controls and Document Results
Since the three feasible control technologies are proposed for the finish mill heater, no detailed
economic, energy, and environmental impact evaluations were conducted. No ranking of control
effectiveness is required as all three controls are proposed.

Step 5 - Select BACT
BACT for NOx is the use of natural gas as fuel, good combustion practices and the use of Low NOx
burners.

CO, SO2, and VOC - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for CO, SO2, and VOC from units of this size are as follows:
Good Combustion Practices
Use of Natural Gas

The finish mill heater combusts natural gas. Related natural gas combustion emissions are
anticipated to be minimal.

Step 2 - Eliminate Technically Infeasible Options
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Both control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Both technologies offer intrinsic emission reductions from combustion. Since the technologies do
not compete, both technologies can and will be used simultaneously.

Step 4 - Evaluate Most Effective Controls and Document Results
Because both control technologies identified in Step 1 are proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for CO, SO2, and VOC are good combustion practices and the use of natural gas.

PM10 and PM2.5 BACT for the finish mill has been addressed in the PM10/PM2.5 sources section.
[Last updated January 14, 2025]

9. BACT review regarding SO2, VOC, and Lead Sources
The following BACT analysis is grouped by pollutants that will experience an increase in potential
emissions and the associated technically feasible control technologies. As such, the BACT analysis
is separated into SO2, VOC, and lead respectively with organic HAPs addressed with VOCs.

SO2 - Cement Kiln BACT
NSPS Subpart F - Standards of Performance for Portland Cement Plants, establishes emission
standards for cement kiln operations. Specifically, kilns constructed or reconstructed after June 16,
2008, are limited to 0.4 lbs SO2/ton clinker on a 30-day rolling average respectively. This limit is
an existing emission limit in the Leamington Plant's approval order and Title V. Ash Grove will
continue to achieve this emission limitation while achieving BACT for the kiln operations. Ash
Grove has reviewed the following sources to identify available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019); and

NSPS Subpart F as an affected emissions facility in 40 CFR 60.62(a)(4);

Portland Cement Association's Formation and Techniques for Control of Sulfur Dioxide and Other
Sulfur Compounds in Portland Cement Kiln Systems.

SO2 emissions are a result of oxidation of sulfur compounds in the rawmix and/or the coal used to
fire the kiln. However, the alkaline nature of the cement provides for direct absorption of SO2 into
the product, thereby mitigating the quantity of SO2 emissions in the exhaust stream.

Step 1 - Identify All Control Technologies
Control technologies identified for SO2 emissions from coal-fired kiln operations are as follows:
Baghouse or fabric filter;
Dry reagent injection prior to baghouse;
Wet scrubber;
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Process optimization; and
Good combustion practices.

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below:

1. Process Optimization 99%
2. Wet Scrubber 99%
3. Dry Reagent Injection 60%
4. Good Combustion Practices 30%
5. Baghouse Variable

Step 4 - Evaluate Most Effective Controls and Document Results
SO2 emissions are most effectively controlled by optimizing the process and utilizing the inherent
SO2 scrubbing properties of the kiln system itself. Although wet scrubbers alone can achieve equal
control efficiencies as process optimization, additional capital and operational expenses are
required for water consumption and wastewater discharge. Whereas process optimization achieves
the same control effectiveness and has the added benefit of reduced operational costs. Ash Grove
optimizes the kiln process by routing the exhaust from the kiln to a preheater and raw mill to
interact with the raw mix, thus creating an atmosphere similar to a dry scrubber system. Good
combustion practices also reduce SO2 formation with the added benefit of energy efficiency.

Step 5 - Select BACT
BACT for control of SO2 emissions from kiln operations shall consist of process optimization by
routing kiln exhaust to the preheater and raw mill, good combustion practices, and use of a
baghouse prior to exhausting to the atmosphere. As a modification of the kiln, 40 CFR 60.62(a)(4)
requires an emission limit of 0.4 pounds of sulfur dioxide (SO2) per ton of clinker on a
30-operating day rolling average. [Last updated January 14, 2025]

10. BACT review regarding SO2, VOC, and Lead Sources cont.
VOC - Cement Kiln BACT
VOCs are generated by incomplete combustion in the kiln. 40 CFR 63 Subpart LLL - NESHAP
from the Portland Cement Industry limits total hydrocarbon and total organic HAP emissions to 24
and 12 ppmv at 7% oxygen. Ash Grove will achieve or exceed these emission limitations while
achieving BACT for the kiln operations. Ash Grove has reviewed the following sources to identify
available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028); and

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for VOC emissions from coal fired kiln operations are as follows:
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Process optimization,
Good combustion practices

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below.

1. Process Optimization Variable
2. Good Combustion Practices Variable

Step 4 - Evaluate Most Effective Controls and Document Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove optimizes the
kiln process by capturing waste heat from the clinker cooler and routing to a kiln preheater. Good
combustion practices also reduce VOC formation with the added benefit of energy efficiency.
There are no adverse energy, environmental or cost impacts to consider with the use of this control
technology.

Step 5 - Select BACT
BACT for control of VOC emissions from kiln operations shall consist of process optimization by
routing kiln heat to the preheater and good combustion practices. An emission limit of 24 ppmv
VOC @ 7% O2 is imposed by NESHAP Subpart LLL.

VOC - Grinding Aid BACT
A grinding aid containing VOC is added to the new finish mill to disperse particles within the mill
and expose more surface area to grinding. An increase in grinding aid usage proportionally
increases potential VOC emissions because volatiles from the grinding aid are not combusted in
the kiln.

There is only one identified control option for limiting the VOC emissions from the grinding aid.
Process optimization is technically feasible. VOC emissions are most effectively controlled by
optimizing the process. Ash Grove proposes to install a vertical finish mill with this project. Due to
the new modern mill's efficiency, it is anticipated that a reduced amount of grinding aid will be
required for each ton of clinker ground. Ash Grove estimates total VOC emissions from the
grinding aid at 2.37 tpy.

Lead Emissions
The lead emissions are anticipated to increase as a result of the proposed increase in clinker
throughput with the Leamington Plant upgrade project. Lead emissions result from residual
amounts of lead in raw materials and fuel. Lead emissions will be controlled the same as PM,
therefore a separate top-down BACT analysis has not been conducted as the Leamington Plant has
applied the most effective controls. [Last updated January 14, 2025]

11. BACT review regarding Greenhouse Gases
GHG Background
On October 9, 2009, the mandatory GHG reporting regulation, referred to as 40 CFR 98, was
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published in the Federal Register. Through 40 CFR 98, the U.S. EPA established the GHG
Reporting Rule, which requires the annual reporting of GHG data and other relevant information
from large sources and suppliers in the United States. Monitoring through the GHG Reporting
Program (GHGRP) began in 2010, with the first reports due by March 31, 2011. Per 40 CFR
98.2(a)(1), any facility associated with cement production is subject to the GHGRP and must report
CO2e emissions. The CO2e is the sum of equivalent GHG emissions from CO2, CH4, and N2O,
with their respective global warming potentials (GWP) applied. Ash Grove's facility is subject to
GHG Reporting Rule and monitors CO2 emissions from its kiln with a continuous emissions
monitoring system (CEMs). On June 23, 2014, the U.S. Supreme Court held that required PSD
permits (based on emissions of non-GHG pollutants) may continue to require limitations on GHG
emissions based on the application of BACT as an "anyway source". The Leamington Plant
modification project is a major source for PSD for both PM10 and PM2.5, and GHGs are estimated
to be greater than 75,000 tpy and greater than zero on a mass basis; therefore, GHGs are evaluated
for BACT as an anyway source.

Cement Manufacturing GHG BACT
A BACT analysis has been conducted for CO2e emissions from the kiln system. For this GHG
BACT analysis, various control technologies or combinations of technologies were identified using
the RACT/BACT/LAER Clearinghouse, available literature including guidance published by EPA
and South Coast Air Quality Management District (SCAQMD), current air regulations, other
regulatory organizations, and engineering experience. In March 2011, EPA published GHG
permitting guidance, as well as a white paper on available and emerging technologies for reducing
GHG emissions from the Portland cement industry in October 2010. Additionally, EPA published a
series of videos on GHG permit training in December 2010. The SCAQMD published GHG BACT
guidance in 2021. Additional sources of information were reviewed and documented based on
publications from trade organizations and other governmental committees with GHG or carbon
reduction guidelines and/or recommendations.

EPA has defined in 40 CFR 86.1818-12(a) GHGs as a group of six gases: CO2, nitrous oxide
(N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF6). GHG emissions from the kiln result from calcination and fuel combustion.
Since the primary GHG emitted by a kiln is CO2, the BACT analysis focuses on CO2 emissions
from the kiln. Emissions of CH4 and N2O are minimal from cement kilns. Per EPA guidance, GHG
control technologies for consideration in a BACT analysis for Portland Cement Manufacturing
include:

Source-wide energy efficiency strategies;
Raw material substitution;
Blended cements;
Carbon capture utilization and storage; and
Fuel switching.
Other emerging technologies [Last updated January 14, 2025]

12. BACT review regarding Greenhouse Gases cont.
Step 1: Identify All Control Technologies
The CO2 emissions from a cement kiln are generated by the calcination process (conversion of the
calcium carbonate in limestone to calcium oxide) and by combustion of fuel in the kiln. Potential
control technologies to reduce these CO2 emissions for a cement kiln are addressed in EPA's white
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paper on Available and Emerging Technologies for Reducing GHG Emissions from the Portland
Cement Industry.

These technologies fall into three categories:
Energy Efficiency Improvements for the Clinker Production Process
Fuel Substitution
Carbon Capture and Sequestration

Step 2: Eliminate Technically Infeasible Options
Several potential energy efficiency improvements are technically feasible: Pre-heater/Pre-calciner
Kiln Process, Kiln Seal Management Program, Refractory Selection (Kiln Insulation), and Energy
Recovery from the Clinker Cooler. The use of alternative fuels such as natural gas, whole tires and
biofuel) is also technically feasible. Other control options, such as Use of Fluxes and Mineralizers,
Heat Recovery for Power - Cogeneration, Carbon Sequestration, Oxyfuel combustion, and
Post-combustion Capture have been deemed infeasible.

Step 3: Rank Remaining Control Technologies by Control Effectiveness
All four remaining control techniques are currently implemented at the Leamington Plant. This
permitting project incorporates energy efficiency improvements. Ash Grove has had a fuel
substitution program in place for several years, and this program is continually reviewed and
updated as new sources and types of fuel are identified.

Step 4: Evaluate Most Effective Controls and Document Results
Since all technically feasible energy efficiency improvements and changes to product composition
will be implemented, this section will focus on economic and environmental considerations of fuel
substitution to operate exclusively on natural gas.

Firing natural gas as the primary kiln fuel can reduce CO2 emissions from fuel combustion by as
much as 40%. However, studies have shown that use of natural gas as primary kiln fuel can result
in three times more NOx emissions than NOx emissions from coal firing. Creating more NOx to
reduce GHG emissions is undesirable as it is a precursor to both ozone and PM2.5. Fuel substitution
essentially trades emissions of one regulated pollutant for another. Estimated capital cost to switch
to natural gas fuel exceeds $25M. Implementing natural gas technology would provide incremental
public health and welfare benefit globally by reducing CO2 emissions, while increasing NOx
emissions and negatively impacting public health and welfare locally. Switching fuels to another
fossil fuel has finite potential to mitigate CO2 emissions.

Step 5: Select BACT
In addition to the proposed energy efficiency improvements addressed elsewhere in this BACT
analysis, BACT is a limit of 0.92-ton CO2e/ton clinker. Ash Grove will use a continuous emission
monitoring system (CEMS) for CO2 to demonstrate compliance with this limit. [Last updated
January 14, 2025]

13. BACT review regarding Leamington Plant Upgrade Project conclusion
The control processes and techniques covered in this BACT analysis have been reviewed by the
NSR Section of the UDAQ. Ash Groves proposed controls and associated emission limitations
represent BACT. Any emission limitations not expressed in an associated NSPS or NESHAP will
be included in the terms and conditions of this AO. A listing of all associated NSPS and NESHAP
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programs is also included in the Source Information section of this document under Applicable
Federal Programs. [Last updated December 13, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date
of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
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proper credit when notifying the Director, send the documentation to the Director, attn.: NSR
Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.

II.A.3
NEW
Stockpiles
Coal storage
Area: 1 acre
Annual throughput 20,000 tpy

AF and ARM stockpiles
Area: 0.25 acre
Annual throughput 8,000 tpy

II.A.4 Stationary Crusher
Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction
of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000
acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)

II.A.5 Raw Material Transfer
Crushed material is transported to raw material storage by belt B8. The raw material transfers
at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor
transfer point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total
filter area & water sprays. (pre-1983)

II.A.6 Material Handling
Conveyor belt systems, secondary feeders and screens, stacker system

II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit specific requirements

II.A.8 Belt Conveyor Transfer Baghouse
Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area
and 1,800 acfm total air flow, controls emissions from the conveyor belt that transfers the
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stacked material to the raw material silos.

II.A.9 Raw Material Silos
Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The
four silos are equipped with one common Fuller, plenum pulse baghouse (315.BF1) - 1,689 ft2
filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage).

II.A.10 Fifth Component Silo
Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse
(315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw
mill feed. This system includes vibrating feeders, a conveyor system, and surge bin.
Emissions are controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3,
316.BF4, 316.BF5) - each is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1
A/C ratio.

II.A.12 Cross-Belt Analyzer
Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6)

II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom
of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw
materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38).
The following equipment is installed: low-NOx burner, selective non-catalytic reduction
(SNCR) for NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued
mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric
monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct
for mercury adsorption capacity. The carbon injection system is not an emission point as it is
in an enclosed building.

II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

II.A.16 Two Kiln Feed Blending Silos
Raw material is blended in one of two blending silos prior to feeding the kiln. The blending
silos are controlled by one common Fuller, plenum pulse baghouse (411.BF1) - 1,351 ft2 filter
area; 7,160 acfm total air flow.

II.A.17 Blending Silo Elevators (2)
Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped
with a Fuller, pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow
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through stack E34.

II.A.18 Kiln Feed Alleviator
A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the
central material silo between the blending silos and the preheater. Raw feed is removed from
the system near the top of the preheater tower.

II.A.19 Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner.
The coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter
area; 1,700 acfm total air flow.

II.A.20 Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in
the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2):
19,500 acfm rated airflow with 3.75:1 A/C ratio

II.A.21 Clinker Cooler and Baghouse
Reconstructed grate type cooler used for cooling clinker from the kiln prior to transfer to
clinker storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) -
173,869 acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter
monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two
clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse
(419.BF8). The exhaust is routed to the clinker cooler stack.

II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions
generated when loading the east and west clinker silos and the out-of-spec silo are controlled
by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1):
1,800 acfm, that discharges into the clinker tunnel.

II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm, that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2)
Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers.
Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses
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(511.HP1 and new 511.HP2): 1,800 acfm each.

II.A.27 Gypsum Silo
Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2
total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust
during loading.

II.A.28 Clinker Tunnel Exitway
The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse
(511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel all discharge in the clinker tunnel.
Emissions are vented through the tunnel exitway.

II.A.29 Limestone Silo
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust
during loading. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement product. Dust
generated during milling is captured by a BHA, pulse jet baghouse (514.BF2) - 6,080 ft2 filter
area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding
stack).

II.A.31 Finish Mill (Ball Mill) Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized
cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA, pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow
controlling particulates from stack G55 (finish mill stack).

II.A.32
NEW
Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The
stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4)
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1,
525.BF1 thru 3)

II.A.33 Finish Cement Storage Silos
There are six storage and two interstice silos where the finished cement product is stored. A
single common Fuller, plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm
total air flow through stack H7 is located on top of the silos and is used to control emissions
during loading and unloading operations.

II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail
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shipping. This baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out
The cement loadout system located on the South side of the silos (truck load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF2) during unloading from the silos for truck
shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement
conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed
space inside the silos.

II.A.36
NEW
Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

II.A.37 MHO: Materials Handling Operation
Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1
& 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4;
512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.

II.A.38 LBS: Limestone Bypass System
Additional limestone is added to the clinker and gypsum by the limestone bypass system
(LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays
at the screen and material handling drop points.

II.A.39 GEN: Emergency Generators
One diesel-fired emergency generator (new)
Rating: 762 hp
(Kiln, Tier 3, permitted 2022)

Two natural gas-fired emergency generators
Rating: 304 hp
(Main office and control room, permitted in 2023)

One diesel-fired emergency generator
Rating: 560 hp
(Shipping, permitted 2023).

II.A.40 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14 inch knife gate, 8 inch knife gate, 8 inch air
slides, surge bin), and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm)
on the fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

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II.A.41
NEW
Miscellaneous Storage Tanks
One diesel storage tank (<2,000 gallons)
One gasoline storage tank (500 gallons)
Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Requirements on the Cement Plant:
II.B.1.a
NEW
The following limits shall not be exceeded:

A. Clinker production - 1,155,000 tons per rolling 12-month period

B. Used oil consumption - 85,724 gallons per rolling 12-month period

C. Limestone bypass material processed - 216,260 tons per rolling 12-month period.
[R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 25th day of each month using data from the previous 12 months.
Records shall be kept for all periods when the plant is in operation. Consumption and
production shall be calculated through use of the plant's acquisition system. [R307-401-8]

II.B.1.b
NEW
Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations:

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

SO2: 0.4 lbs per ton of clinker (3-hr average)

CO: 3,395 tons per rolling 12-month period, and 6,600 lbs/hr

NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average, and 1,233 tons per rolling
12-month period

Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is
400oF or less.

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Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)

THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)

CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)

PM: 0.02 lbs filterable PM per ton of clinker. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL,
R307-401-8]

II.B.1.c
NEW
A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR
60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust
emissions control plan shall be monitored to demonstrate that appropriate control measures are
being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of
the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall
be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in
the plan and that the source is operating in accordance with the submitted plan. For petitions
to approve alternative control measures, the permittee shall keep a copy of the submitted
petition and any approvals received. [40 CFR 60 Subpart Y]

II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area
source of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2). [40 CFR
63 Subpart LLL]

II.B.1.e
NEW
Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b
and II.B.1.d shall be performed as specified below:

A. Kiln/Raw Mill Stack
Pollutant Test Status Test Frequency
PM * #

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

B. Clinker Cooler (F31)
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Pollutant Test Status Test Frequency
PM + #

C. Testing Status (To be applied above)
* The initial testing has already been performed.

** The SO2 initial performance test was conducted on August 26, 2013.

*** The initial compliance test shall be conducted within the first 30 operating days of
operation in which the affected source operates using a CEMS.

# Test once every year. If performance testing would be required less than 15 operating days
after the Kiln has completed Startup after being down for more than 24 hours, then
performance testing may be deferred up to 15 operating days after completion of the Startup.
The Director may require testing at any time.

## Test at least once every two years. The Director may require testing at any time.

+ Initial testing is required within 180 days of startup of the reconstructed equipment

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must record the PM
CPMS output data for all periods when the process is operating, and use all the PM CPMS
data for calculations when the PM CPMS is not out-of-control. The owner/operator must
demonstrate continuous compliance by using all quality-assured hourly average data collected
by the PM CPMS for all operating hours to calculate the arithmetic average operating
parameter in units of the operating limit on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

+++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.e.1
NEW
Notification
The Director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The notification requirements for performance tests subject to 40
CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-165]

II.B.1.e.2
NEW
Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational
Safety and Health Administration (OSHA)- or Mine Safety and Health Administration
(MSHA)-approved access shall be provided to the test location. [R307-165]

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II.B.1.e.4
NEW
PM
40 CFR 60, Appendix A, Method 5 or 5I or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three (3) runs with
each run at least 120 minutes in duration and each run collecting a sample of 60 dry standard
cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.3
NEW
Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2. [R307-165]

II.B.1.e.5
NEW
Carbon Monoxide (CO)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.6
NEW
Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.7
NEW
Sulfur Dioxide (SO2)
40 CFR 60, Method 6 or 6C of Appendix A-4 or other EPA-approved method as acceptable to
the Director. [R307-165]

II.B.1.e.8
NEW
Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]

II.B.1.e.9
NEW
Total Hydrocarbons (THC)
Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL]

II.B.1.e.10
NEW
Mercury (Hg)
Continuous Emission or integrated sorbent trap monitoring (See Condition II.B.3.a). [40 CFR
63 Subpart LLL]

II.B.1.e.11
NEW
HCl
Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other
EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]

II.B.1.e.12
NEW
Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.13
NEW
Calculations
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director, to give the results in the specified units of the
emission limitation. [R307-165]

II.B.1.e.14
NEW
Existing Source Operation
For an existing source/emission point, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three years.
[R307-165]

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II.B.1.e.15
NEW
New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the maximum production rate listed in this AO. If the maximum AO
allowable production rate has not been achieved at the time of the test, the following
procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This new
allowable maximum production rate shall remain in effect until successfully tested at a higher
rate.

3) The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate (110%
of the new rate) will then be allowed if the test is successful. This process may be repeated
until the maximum AO production rate is achieved. [R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL.
[40 CFR 63 Subpart LLL]

II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times
of Dust Shuttle System operation to assist in the capture of Mercury emission. [R307-401-8]

II.B.1.h
NEW
Visible emissions from the following emission points shall not exceed the following values:

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

L. All baghouses - 10% opacity
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M. Fugitive dust - 20% opacity

N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y,
R307-401-8]

II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer
point is not required to conduct Method 22 visible emissions monitoring under this paragraph.
The enclosures for these transfer points must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

If any partially enclosed or unenclosed conveying system transfer point is located in a
building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to
40 CFR 60, according to the following:

(i) The owner/operator must conduct a monthly ten-minute visible emissions test of each
affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The
performance test must be conducted while the affected source is in operation.

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator may decrease the frequency of performance testing from monthly
to semi-annually for that affected source. If visible emissions are observed during any
semi-annual test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iii) If no visible emissions are observed during the semi-annual test for any affected source,
the owner/operator may decrease the frequency of performance testing from semi- annually to
annually for that affected source. If visible emissions are observed during any annual
performance test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iv) If visible emissions are observed during any Method 22 performance test, of Appendix
A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations,
recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60.
The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour
of any observation of visible emissions.

(v) If visible emissions from a building are monitored, the requirements of paragraphs (i)
through (iv) of this Condition apply to the monitoring of the building, and the owner/operator
must also test visible emissions from each side, roof, and vent of the building for at least ten
minutes. [R307-401]

II.B.1.j
NEW
Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed
0.005 gr/dscf:

520.BF1
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520.BF2
520.BF3
520.BF4
521.BF2
521.BF1
524.BF1
524.BF2
524.BF4
524.BF3
525.BF1
525.BF2
525.BF3
511.HP2
NRL_UPR
NRL_LWR. [R307-401-8]

II.B.1.j.1
NEW
To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration
through at least three (3) annual tests that the PM limits are not being exceeded, the
owner/operator may request approval from the Director to conduct stack testing less
frequently than annually. [R307-401-8]

II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive
dusts as dry conditions warrant or as determined necessary by the Director to maintain opacity
limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated to control fugitive dust. The application of
water or chemical treatment shall be used. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a damp/moist condition unless it is below freezing.
If chemical treatment is to be used, the plan must be approved by the Director. Records of
water and/or chemical treatment shall be kept for all periods when the plant is in operation.
The records shall include the following items: Instances of water and/or chemical application
to unpaved areas shall be recorded and maintained by the owner/operator. The ambient
temperature shall be recorded any time water should be applied but cannot due to freezing
conditions. [R307-401-8]

II.B.2.c
NEW
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

The sprays shall operate whenever dry conditions warrant meeting the required opacity
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limitations or as determined necessary by the Director. Water sprays shall not be required
during periods of freezing temperatures. [R307-401-8]

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation
of fugitive dusts as dry conditions warrant or as determined necessary by the Director.
[R307-401-8]

II.B.2.e
NEW
The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5
PM. [R307-401-8]

II.B.3 Continuous Emission Monitoring Requirements:
II.B.3.a
NEW
The owner/operator shall install, calibrate, maintain and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler.

A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the
missing data substitution procedures used by the UDAQ or the missing data substitution
procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate by the UDAQ.

B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period
including during each startup, shutdown, or malfunction.

C. The monitoring system shall comply with all applicable sections of R307-170, UAC; and
40 CFR 60, Appendix B.

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be
installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the
kiln/raw mill stack.

F. The owner/operator shall record the output of the system: including the quantity of NOx,
CO, O2 THC, Hg, HCl, and CO2 emissions at the kiln stack.

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source shall
continuously operate all required continuous monitoring devices and shall meet minimum
frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker
cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except
during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments,
the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a
PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the
results of the performance test demonstrating compliance with the filterable PM limit and
using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust
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the SSOL developed in accordance with the results of the most recent PM performance test
demonstrating compliance with the PM emission limit. The owner/operator shall use the PM
CPMS to demonstrate continuous compliance with the SSOL in accordance with the
requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

II.B.4 Fuel Limitations:
II.B.4.a
NEW
The owner/operator shall use only the following fuels in the kiln and pre-calciner:

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.

If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b
NEW
Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the
Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the
results of suitable tests giving data similar to a Proximate and Ultimate analysis of the
proposed coal additive. [R307-401-8]

II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal
additive. Approval is not required to change from one previously-approved coal additive to
another previously-approved coal additive. [R307-401-8]

II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily
heat input of the kiln and precalciner. The owner/operator may increase the average quantity
of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon
approval by the Director in accordance with the approval process described in Condition
II.B.4.b. [R307-401-8]

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II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel burning or process
installation not covered by New Source Performance Standards for sulfur emissions or
covered elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross
Btu heat input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input
for any oil except used oil. The sulfur content shall comply with all applicable sections of
UAC R307-203. [R307-203, R307-401-8]

II.B.4.c.1
NEW
Certification of fuels shall be either by the owner/operator's own testing or test reports from
the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be
available onsite. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials, UAC R307-203-1 (4)

A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be
used.

B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be
used.

C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85 are to be used. [R307-203]

II.B.4.d
NEW
The concentration/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight
3) Cadmium 2 ppm by weight
4) Chromium. 10 ppm by weight
5) Lead 100 ppm by weight
6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be
tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the burn tank and burned. [R307-401-8]

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II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned
in the rotary kiln:

A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than
five minutes in any 60-minute period

B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes
in any 60-minute period. [R307-401-8]

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the
Director. The calibration procedure and frequency shall be according to manufacturer's
specifications. Use of factory-calibrated thermocouples for temperature measurement is
approved. However, any other method of temperature measurement must be approved by the
Director prior to use. The monitoring equipment for both temperature and oxygen content
shall be located such that an inspector can at any time safely read the output. [R307-401-8]

II.B.5
NEW
Emergency Engine Requirements
II.B.5.a
NEW
The owner/operator shall only operate the emergency engines for testing and maintenance
purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency
operation. [R307-401-8]

II.B.5.b
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each emergency engine. [R307-401-8]

II.B.5.b.1
NEW
The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.5.b.2
NEW
To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN103030035-24 dated November 27, 2024
Is Derived From Source Submitted NOI dated November 30, 2022
Incorporates Additional Information Received dated April 26, 2023
Incorporates Additional Information Received dated September 26, 2023
Incorporates Additional Information Received dated July 23, 2024
Incorporates Additional Information Received dated October 25, 2024
Incorporates Additional Information Received dated November 25, 2024

REVIEWER COMMENTS

1. Comment regarding applicability of federal requirements:
New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable
by the best demonstrated technology as specified in the applicable provisions. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.

40 CFR 60, Subpart A (General Provisions)
All affected facilities subject to a source-specific NSPS are subject to the general provisions of
NSPS, Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires
initial notification, performance testing, recordkeeping, and monitoring, provides reference methods,
and mandates general control device requirements for all other subparts.

40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of
performance for affected facilities in Portland Cement Plants which have been constructed or
modified after August 17, 1971.

40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart
F: Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and
unloading systems. The Leamington coal mill is an in-line coal mill and considered an integral part
of the Leamington kiln. In-line coal mills are not subject to NSPS Subpart Y. Therefore, the coal mill
is addressed under NSPS Subpart F as part of the kiln system. The coal silos and conveying system
are subject to NSPS Subpart Y.

Ash Grove's proposed changes to the kiln system must be evaluated as to whether they trigger new
NSPS Subpart F obligations based on whether the proposed project is either a modification or a
reconstruction, as those terms are defined in NSPS Subpart A.

Ash Grove's proposed changes to the kiln system do not meet the definition of a reconstruction, nor
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January 21, 2025
Page 40

do they meet the definition of a modification for NOx. However, the changes meet the definition of a
modification for PM and SO2. Therefore, Ash Grove will comply with all relevant emission
standards; testing requirements; monitoring, recordkeeping, and reporting obligations that apply to
the Leamington kiln system as an existing source under NSPS Subpart F. Under NSPS Subpart A
and F, the clinker cooler is considered a reconstructed unit. Thus new limits will apply to this unit.
[Last updated January 14, 2025]

2. Comment regarding applicability of federal requirements cont.:
NSPS Subpart Y - Standards of Performance for Coal Preparation and Processing Plants
This subpart provides standards of performance for affected facilities in coal preparation and
processing plants that process more than 200 tons of coal per day.

The Leamington plant's coal silo and coal conveying system are existing affected facilities under
NSPS Subpart Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses
controlling affected facilities subject to match the limit in NSPS Subpart Y from 0.016 gr/dscf to
0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade Project. Since there are no proposed
modifications or reconstruction to the coal silo and coal conveying system, nothing about the
proposed upgrade project affects the existing applicability of NSPS Subpart Y.

NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
This subpart provides standards of performance for affected facilities located at fixed or portable
nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August
31, 1983, with additional requirements applicable to sources constructed on or after April 22, 2008.

As the crushing and screening system is controlled by baghouses and an increase in PM10 actual
emissions on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS.
Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the
Leamington Plant Upgrade Project.

Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1),
60.676(f), and 60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO
monitoring and recordkeeping requirements.

[Last updated January 14, 2025]

3. Comment regarding applicability of federal requirements cont.:
National Emission Standards for Hazardous Pollutants (NESHAPs)
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or
greater than 10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as
specified by each subpart. NESHAP apply to sources in specifically regulated industrial source
classifications (CAA Section 112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities
not regulated as a specific industrial source type. The Ash Grove Leamington Plant is a major source
of HAPs and thus is subject to certain NESHAP standards.

Subpart A - General Provisions
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All affected sources are subject to the general provisions of Subpart A unless otherwise specified by
the source-specific NESHAP. Subpart A generally requires initial notification and performance
testing, recordkeeping, monitoring, provides reference methods, and mandates general control device
requirements for all other subparts as applicable.

Subpart LLL - Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry
This subpart establishes process/source specific emission limits for PM, VOC (expressed as total
hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and
gaseous HAP compounds by limiting PM and THC emissions because portions of such emissions
are USEPA-listed HAPs. Subpart LLL requires compliance with applicable emissions limits on and
after the initial startup of cement production. To further reduce emissions, Subpart LLL also
establishes operational requirements for the use of cement kiln dust (CKD), fly ash, fuel and control
equipment. Subpart LLL also specifies process/source specific emissions testing, monitoring,
recordkeeping, reporting, and compliance demonstration requirements. The compliance requirements
for the site are detailed in Approval Order Condition II.B.1.b. Ash Grove will continue to comply
with the requirements of Subpart LLL to demonstrate compliance. This cement kiln will remain an
existing source with respect to the kiln emission standards in Subpart LLL as this project does not
trigger the definition of a new source in Subpart LLL. New source standards apply only to affected
sources that were constructed or reconstructed after May 6, 2009.
[Last updated December 20, 2024]

4. Comment regarding PSD applicability analysis:
Ash Grove is proposing to increase the throughput of limestone from the quarry to supply the New
Finish Mill to increase the amount of low-carbon cement from the Leamington Plant. Additionally,
along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
modified, and the clinker cooler will be reconstructed. These changes are anticipated to result in an
increase in clinker production. Emission calculations for this project have been completed assuming
an increase in clinker production capacity while utilizing current fuel types. This will result in an
increase in the throughput of fuel.

The Leamington Plant is considered an existing major source under PSD based on potential
emissions of PM10, PM2.5, NOx, CO, SO2, and CO2e. If a major source undergoes a physical or
operational change, the facility must determine whether the project will be considered a major
modification. Per 40 CFR 52.21(b)(2)(i), in order to be a major modification, the project must result
in a significant emissions increase, and a significant net emissions increase.

As defined at 40 CFR 52.21(b)(40): Significant emissions increase means, for a regulated NSR
pollutant, an increase in emissions that is significant for that pollutant. Significant is further defined
to mean, in reference to a net emissions increase or the potential of a source to emit any of the
following pollutants, a rate of emissions that would equal or exceed the values outlined in 40 CFR
52.21(b)(23). If the increase in emissions from the project are not significant, a major modification
has not occurred.

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
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increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

For all pollutants, the project emissions increase was calculated as the difference between the
projected actual emissions (PAE) after the proposed project and the actual emissions prior to the
project (baseline actual emissions or BAE).

Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
". . . projected actual emissions means the maximum annual rate, in tons per year, at which an
existing emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years
(12-month period) following the date the unit resumes regular operation after the project, or in any
one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit of that regulated NSR pollutant and full utilization of the unit would
result in a significant emissions increase or a significant net emissions increase at the major
stationary source." [Last updated January 14, 2025]

5. Comment regarding PSD applicability analysis cont.:
Ash Grove estimates that the projected actual production capacity following the project will be
1,155,000 tons of clinker per year and 1,341,266 tons of limestone per year. These capacities were
used to calculate projected actual emissions from the project using representative emission factors.
Additionally, to estimate emissions from material transfer baghouses, the actual flow rates and actual
projected hours were used as a basis for projected actual emissions.

Project Emission Calculations

Project emission increases from the kiln and coal mill systems are calculated for all criteria
pollutants based on emission factors that are derived from stack testing, CEMS data, or emission
factors (i.e., VOCs and Lead), and the associated projected incremental clinker increase.

NOx emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain
hourly capacity to emit and annual potential to emit at current levels. The kiln's NOx emissions rate
will not change as a result of the physical modifications proposed by the project.

Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission
factor and multiplied by the incremental increase in clinker production. The emission factor was
selected based on the average of the 24-month consecutive month emissions for 2020 and 2021. The
CO emissions will increase.

The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing
conducted at the plant. The SO2 emissions will increase.

VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production. VOC emissions will increase.

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 43

can be found in the original NOI and subsequent addendums submitted to UDAQ.

As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from
the proposed project, each increase of emissions from both existing and new sources shall be
summed together and compared to the PSD permitting thresholds. The increase of emissions is the
"positive" difference between the projected actual emissions and baseline actual emissions (projected
minus baseline).

New Emissions Sources

The actual to projected actuals calculation is not available to new emission units. For new emission
units, the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected
emissions are based on the new sources' potentials to emit. (40 CFR § 52.21(a)(2)(iv)(f)).

The new equipment proposed includes the New Finish Mill, a new rail and truck loading/loadout,
one (1) new clinker reclaim loading hopper with a dust collector and one (1) existing clinker reclaim
hopper with a dust collector, a new Clinker Cooler to replace the existing one, and a new kiln feed
alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions:

The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;

The finish mill heater was calculated based on its maximum firing capacity and flow rates; and

The fugitive emissions were calculated based on the projected annual throughput of the New Finish
Mill, the rail loadout, and clinker production. [Last updated January 14, 2025]

6. Comment regarding PSD applicability analysis cont.:
Existing Emission Sources

For the existing sources, the projected actual emissions are the maximum annual rates in tons per
year projected to occur during the next five (5) to ten (10) years if the existing sources' design
capacities increase. Ash Grove Leamington projected the actual emissions for the next five (5) years
based on the new kiln system producing an annual average of 3,250 tons of clinker per day.

Baseline actual emissions (BAE) are defined at 40 CFR 52.21(b)(48)(ii) as:

". . . baseline actual emissions means the average rate, in tons per year, at which the emissions unit
actually emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the 10-year period immediately preceding either the date the owner or operator
begins actual construction of the project, or the date a complete permit application is received by the
Administrator."

Ash Grove has selected to use the years 2020 and 2021 for each pollutant as the representative
baseline years.

In its NOI, Ash Grove calculated the emission increase from the project as being divided into two
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 44

phases. Phased construction projects are discussed in two sections of the federal PSD regulations -
40 CFR 52.21(j)(4) and 40 CFr 52.21(r)(2). UDAQ is not processing this project as a phased
construction project, nor did Ash Grove request such a determination. Therefore, Ash Grove
provided a summary table outlining the final change in emissions from this project:

Projected Actual Increase Compared to PSD threshold (tons per year)
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2e
BAE 76.64 39.64 1,187 6.87 3,315 55.47 641,385
PAE 203.15 113.47 1,226 45.87 3,414 72.07 1,067,984

Change in Emissions 126.51 73.83 39.00 39.00 99.00 16.59 426,598

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes

If the emissions increase is greater than the PSD significance threshold for a particular pollutant, Ash
Grove has the option of conducting a PSD review or continuing through the rest of the steps to
determine if it can "net" out of a PSD review. If the project increase is less than the PSD significant
threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant.

The change in emissions from the project exceeds the significant emission threshold for three
pollutants: PM10, PM2.5 and CO2e. Ash Grove elected to attempt to net out of a PSD major
modification for the remainder of the criteria pollutants.

Netting

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant
Upgrade Project and ends on the date the upgrade begins operation. Only PM10, PM2.5, CO2e are in
excess of SERs and therefore considered in the netting analysis.

Ash Grove estimated that the commencement of construction will be in December 2024. Therefore,
the contemporaneous period for this project is December 2019 through a projected date the project
upgrade begins operation. [Last updated January 21, 2025]

7. Comment regarding PSD applicability analysis cont.:
Contemporaneous Decreases

Ash Grove replaced an existing kiln emergency drive engine with a USEPA Tier 4 diesel engine in
2022. Concurrently, Ash Grove requested an increase in the capacity of 1L Cement. Additionally,
Ash Grove submitted a minor modification NOI air permit application on June 12, 2023, which
proposes replacing the shipping generator during the contemporaneous period. The kiln emergency
drive engine and shipping generator are both higher EPA tier ratings therefore result in decreases for
PM10 and PM2.5. These changes were approved in AO DAQE-AN103030033-24 issued March 21,
2024.

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Page 45

Contemporaneous Increases

As stated above, the existing kiln emergency drive engine and shipping generator were permitted and
replaced in 2024. This resulted in an increase in emissions of CO2e.

The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout
in an effort to improve truck traffic at the loadout. The modification to add these dust collectors to
the loadout was included in DAQE-AN103030029-19. The baghouses are three (3) levels up in the
silos' enclosed space (approximately 40 feet). Both dust collectors vent directly into the interior of
the silo structure and are not vented into the atmosphere. Ash Grove requests to remove these
baghouses from its existing permitted emissions inventory. Therefore, these emissions have been
documented in the netting analysis as zero emissions.

Also included in DAQE-AN103030033-24 were two new natural gas-fired emergency generators
and increases in stockpiles, material handling and road emissions.

Could Have Been Accommodated Emissions

In calculating project emissions increase, USEPA allows the exclusion of existing
production/emissions rates that could have been accommodated during the baseline period. These
"could have been accommodated" emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as
follows:

". . . Shall exclude, in calculating any increase in emissions that results from the particular project,
that portion of the unit's emissions following the project that an existing unit could have
accommodated during the consecutive 24-month period used to establish the baseline actual
emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project,
including any increased utilization due to product demand growth;"

Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the
exclusion of existing production and emissions rates that could have been accommodated during the
baseline period, it has elected not to use this exclusion at this time. Therefore, calculation of the
"could have been" accommodated emissions have not been included in this application's
applicability analysis.

The increase from the project is added to the contemporaneous decreases and contemporaneous
increases. The resulting calculation is then compared to the PSD significance threshold to determine
if a significant net emissions increase has occurred. [Last updated January 14, 2025]

8. Comment regarding PSD applicability analysis cont.:
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2 e
Contemporaneous Inc. 1.61 0.45 0.41 0 0.27 0.07 51.74

Contemporaneous Dec. -1.54 -3.97 -0.48 -0.02 -0.27 -0.09 0

Change in Emissions 125.02 69.21 38.93 38.98 99.00 16.58 426,650

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes
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Page 46

The results of the netting analysis conclude that both a significant emissions increase and a
significant net emissions increase in both particulates (PM10 and PM2.5) and CO2e will occur from
this project. Thus, the project must be reviewed as a PSD major modification. [Last updated January
14, 2025]

9. Comment regarding emission calculations:
This engineering review includes updated potential emission totals for both criteria and HAP
emissions. The potential-to-emit (PTE) values were calculated using updated values for clinker
produced and raw material inputs. BACT emission factors and limitations were used where
appropriate. Certain emission totals (NOx, SO2 and CO) were set based on avoiding a significant
increase in emissions. Specifically, the projected actual increase was set at just under the baseline
actual emissions + the significance level. As these emissions are monitored by CEM, UDAQ agrees
with this approach. Please see the netting analysis for further details on calculation of projected
actual increase. The NOx hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project.

CO2e emissions were calculated using the GHG emission factor calculated from 40 CFR Part 98
Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in Subpart A Table
A-1.

To calculate the PTE tons per year, the maximum hours (i.e., 8760) per year and the source's
emissions rates were multiplied with the throughputs. The potential throughputs have been updated
at UDAQ's request so that PAE is equal to PTE and represents the equipment's maximum design
potential.

Additional emission calculations based on source testing and monitoring, and EPA's compilation of
air emission factors AP-42. [Last updated January 14, 2025]

10. Comment regarding requirements for PSD review:
In addition to the permitting requirements of R307-401-5 through R307-401-8, there are additional
requirements under PSD that must be addressed:

1. Calculation of ambient air increments (40 CFR 52.12(c)), ambient air ceilings ((40 CFR 52.12(d)),
source impact analysis (40 CFR 52.12(k)), air quality models (40 CFR 52.12(l)) - these items are
addressed in the modeling memo DAQE-MN103030032-24.

2. Stack heights (40 CFR 52.12(h)) - Ash Grove's stack heights have been reviewed with respect to
good engineering practice and operate in a vertical unrestricted manner.

3. Control technology review (40 CFR 52.12(j)) - this is addressed in the BACT analysis section of
this review document.

4. Air quality analysis: preapplication analysis (40 CFR 52.12(m)) - this is covered in the PSD
applicability and netting analysis sections of this review document, ambient monitoring and
background data collection is also included in the modeling memo DAQE-MN103030032-24.

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
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Page 47

grain loading limit included in II.B.1.j.1 represents the required post-construction monitoring.
6. Source information (40 CFR 52.12(n)) - this is addressed under the requirements of R307-401-5
and was submitted by Ash Grove as part of the NOI package.

7. Additional impact analysis (40 CFR 52.12(o)) - these requirements cover soils, vegetation, growth
and visibility concerns. They are discussed in the modeling memo DAQE-MN103030032-24.

8. Federal land manager review (40 CFR 52.12(p)) - UDAQ provided initial notification to all
federal land managers upon receipt of the original NOI package. The draft permit and engineering
review will also be provided to the federal land managers 60-days prior to initiation of public
comment for their further review.

9. Public participation (40 CFR 52.12(q)) - this project will have a 30-day public comment period.

10. Source obligation (40 CFR 52.12(r)) - this requirement discusses source compliance with other
parts of the CAA, which is addressed within UDAQ's permitting rules in R307.
[Last updated January 14, 2025]

11. Comment regarding changes in equipment list:
The equipment list is being updated for clarity as well as adding new pieces of equipment. The
following changes are taking place:

The naming scheme is being updated to remove the numerical code from the unit designation. This
code generally referred to the associated control device and not to the emitting unit itself. This can
cause confusion especially when the same code was applied to multiple pieces of equipment.
Instead, the control devices (typically baghouse dust collectors) will be identified in the description
along with the appropriate numerical code.

Specific changes are as follows:

1. The kiln description has been updated

2. Clinker Cooler description has been updated to include a larger pulse jet baghouse.

3. The clinker storage silos, east and west clinker belts, clinker belt transfer and clinker tunnel have
been consolidated to avoid confusion

4. The north and south cement loadout exhausts now vent internally into the cement storage silos

5. The dust shuttle system has been consolidated into one line item, most identifiers removed from
subsystem descriptions as only two baghouses serve as exhaust points.

6. A new finish mill with heater has been added. Included in the description are the thirteen total
baghouses for dust control (1 main stack, 2 transfer points, 10 nuisance dust filters)

7. A new clinker reclaim hopper has been added. Both reclaim hoppers are controlled by baghouses
with updated identifiers

8. A new rail and truck loading/unloading system with two baghouses has been added.
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Page 48

[Last updated December 20, 2024]

12. Comment regarding changes in conditions:
As a result of this project, several conditions will be added or changed. This includes one new
general condition (I.8). Changes to the equipment list (section II.A) will be addressed in a separate
reviewer comment:

I.8 - Adding this general condition to cover the requirements of R307-401-18 Eighteen Month
Review. The status of construction/installation of the new equipment shall be reviewed after
18-months.

II.B.1.a - Clinker production increases to 1,155,000 tpy
Use of limestone bypass material increases to 215,260 tpy

II.B.1.b - The NOx limit on the kiln decreases to 1,223 tpy, CO emissions from the kiln decrease to
3,395 tpy,
Adding a new CO2e limit of 0.92 tons CO2e/ton of clinker produced
PM limit on the clinker cooler decreased to 0.02 lb PM (filterable)/ton of clinker
Rule reference updated to include 40 CFR 60 Subpart F, and R307-401-8

II.B.1.e - Initial testing on the clinker cooler is now required within 180 days of startup of the unit.
Monitoring of CO2 from the kiln will be by CEM.
Formatting changes on paragraph designated ++, improve clarity, include reference to CO2
monitoring, define CPMS

II.B.1.e.4 - Update to address general PM monitoring and reference R307-401-8

II.B.1.e.14 - New condition to address new or reconstructed emission units monitoring requirements,
applicable to the clinker cooler and new finish mill.

II.B.1.h - Adding references to Subpart OOO units (limestone processing) with updated opacity
limits.
Adding 20% opacity limit on coal transfer and storage
Adding property boundary opacity limit of 20%
Updating rule reference to include Subpart OOO

II.B.1.j - New condition to address outlet grain loading limits on new baghouses, One identical limit,
15 total new baghouses.

II.B.1.j.1 - Monitoring on new baghouses as per II.B.1.e.4, added an allowance to test less frequently
than annually with three successful tests.

II.B.3.a - Updating formatting to add clarity and include reference to CO2 CEM

II.B.5 - New conditions on emergency engines, diesel fuel sulfur limits, hour of operation
restrictions, non resettable hour meter

[Last updated December 20, 2024]
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 49

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 51

TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 52

DAQE-MN103030032-24

M E M O R A N D U M

TO: John Jenks, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler
Dave Prey, Air Quality Modeler

DATE: December 12, 2024

SUBJECT: Modeling Analysis Review for the Ash Grove Cement Company – Leamington Plant,
located in Millard County, Utah
___________________________________________________________________________________
This is a Major Modification to a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Ash Grove Cement Company (Applicant) has submitted a Notice of Intent (NOI) air permit
application for a project referred to as the Leamington Upgrade Project (LUP). The proposed
upgrade project includes the construction and installation of new pollution control equipment, new
emission sources, and modifications to existing emission sources. Emission increases associated
with the LUP constitute a major modification to a Prevention of Significant Deterioration (PSD)
source subject to PSD permitting regulations. PSD regulations require the Applicant to include and
air quality impact analysis (AQIA) of the proposed projects impact on the EPA national ambient air
quality standards (NAAQS) and air quality related values (AQRV) as part of a complete NOI.

This report prepared by the New Source Review (NSR) modeling staff contains a review of the
Applicant’s Air Quality Impact Analysis (AQIA) including the methodology, data sources,
assumptions, and modeling results for comparison with State and Federal air quality standards. The
AQIA was reviewed and referenced in this report include the:
● Notice of Intent – Ash Grove Cement Leamington Plant PSD Notice of Intent Air Permit
Application, dated November 30, 2022.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

0 0
Jason Krebs

DP
DAQE-MN103030032-24
Page 2

II. APPLICABLE RULES AND ANALYSES

A Utah Air Quality Rules

The UDAQ has determined that the Applicant’s NOI is subject to the following rules for conducting an
AQIA:

R307-401 Permits: New and Modified Sources
R307-405 Permits: Major Sources Located in Attainment or Unclassified Area (PSD)
R307-406-2 Visibility – Source Review
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutant Impacts in Attainment Areas

B. Applicability

The proposed increases in emissions of PM10 and PM2.5 exceed the emission thresholds outlined in R307-
406-5 and R307-410-4. Therefore, an AQIA consistent with the requirements of R307-405-6, R307-406-
2, and R307-410-3 was submitted as part of the Applicant’s NOI. R307-410-3 establishes the U. S.
Environmental Protection Agency (US EPA) – Guideline on Air Quality Models as a formal basis for
defining the scope of the analysis, as well as the model’s construction. The results of the AQIA are
required to demonstrate the proposed project’s impact on state and federal air quality standards,
acceptable levels of impact, and action triggering thresholds referenced or listed in R307-401-6(2), R307-
401-6(3), R307-403-3(1), R307-403-5(1)(a), R307-405-4(1), R307-405-6. Annual emissions for criteria
pollutants requiring an AQIA are listed in Table 1.

Table 1: Ash Grove Leamington Proposed Net Emissions Increase

Criteria
Pollutants
Net Emission
Increase (TPY)
AQIA Trigger
Level (TPY) AQIA Required?
PM10 126.6 15 Yes
PM2.5 70.3 10 Yes

C. Required Analyses

R307-405 requires the Applicant to perform a pre-construction modeling analysis for all pollutants
emitted in a significant quantity. The purpose of the analysis is to determine if the extent of the source’s
impact is significant enough to warrant an on-site measurement of the ambient background concentration
levels. This data is included in the NAAQS analysis to represent the quality of the air prior to the
construction of the proposed project. The Applicant included a pre-construction modeling analysis for
PM10 and PM2.5 as part of the NOI. The pre-construction modeling analysis was also used to determine if
the proposed emissions would result in a significant impact to the environment, thereby triggering the
requirement for a cumulative analysis of the proposed project and other nearby existing sources.

R307-401-8 requires the Division to determine that the proposed project will comply with the NAAQS
prior to the issuance of an Approval Order (AO). R307-405(7) requires the Applicant to perform a
DAQE-MN103030032-24
Page 3
NAAQS analysis for all pollutants emitted in a significant quantity. The analysis is to include all
emissions at the proposed site under normal operating conditions using maximum anticipated short-term
release and annual release rates. Consistent with UDAQ policy, a cumulative analysis to include the
ambient background concentration and any contribution from other nearby sources is not required if the
proposed project’s impact does not exceed the PSD Class II Significant Impact Level (SIL).

R307-401-8 also requires the Division to determine that the proposed project will comply with PSD
increments prior to the issuance of an AO. Under R307-405(6), the Applicant is required to perform a
PSD Class I and II increment consumption analysis for all pollutants emitted in significant quantities.
The purpose of this analysis is to quantify any degradation in air quality since the major source baseline
date. The analysis is to include all increment consuming emissions at the proposed site under normal
operating conditions using maximum anticipated short-term and annual release rates. A cumulative
analysis to include contributions associated with growth and other increment consuming sources is not
required if the proposed project’s impact does not exceed the PSD Class I or II SIL.

R307-410-5 requires the Applicant to perform a HAPs analysis for any pollutant emitted above a
pollutant specific emission threshold value. This analysis is to include all emissions of the pollutants
resulting from the proposed modification under normal operating conditions using maximum anticipated
one-hour release rates. The Applicant did not trigger modeling for HAPs.

R307-406-2 requires the Applicant to perform a plume blight analysis. A plume blight analysis is required
to determine if plumes emanating from the proposed project would be visible inside any Class I area
within 50 kilometers of the source. The plume blight analysis is to include all emissions of NO2, SO4, and
PM10.

Under R307-405-16, an AQRV analysis is performed which evaluates regional haze and acid deposition
impacts at each of the Class I areas within 300 kilometers of the source. A regional haze analysis is
required to determine if the plumes would reduce the visual range of an observer inside the Class I area.
The regional haze analysis is to include all emissions of SO2, NOX and PM10. The deposition analysis
examines impacts from sulfur and nitrogen compounds at the Class I areas, and is based on all emissions
of SO2 and NOX. The Federal Land Managers use the Q/D approach to determine whether a PSD project
should provide detailed AQRV impact analyses, where: Q/D= [ H2SO4 + SO2 + NOx + PM10 emissions
(tpy)]/ distance (km). If Q/D is less than 10, no AQRV analysis is required.

R307-405 requires the Applicant to perform a soils and vegetation analysis. The analysis should quantify
the effects of pollutants on soils and vegetation near the highest impact location and in areas where
sensitive plant species may be impacted.

III. ON-SITE PRE-CONSTRUCTION MONITORING

A. Meteorological Data

Consistent with the US EPA - Meteorological Monitoring Guidance for Regulatory Modeling
Applications, one year of on-site data was collected using a 50-meter tower during the period October 1,
2021 through September 30, 2022. Parameters collected on-site included wind speed and direction,
temperature, delta-T, and solar radiation.

DAQE-MN103030032-24
Page 4

B. Ambient Pollutant Data

A preliminary analysis was conducted to determine the necessity for pre-construction ambient pollutant
monitoring. The results indicate that predicted concentrations of PM10 and PM2.5 exceed the monitoring
trigger level listing in the rule. A continuous PM10/PM2.5 monitor with filter based samplers was
installed near the northern edge of the Applicants property boundary, and collected particulate matter
from October 1, 2021 through September 30, 2022.

IV. MODEL SELECTION

The EPA-AERMOD dispersion modeling system is the preferred model specified in the US EPA –
Guideline on Air Quality Models to predict air pollutant concentrations in the near field (within 50
kilometers of the source). The US EPA - CALPUFF - Version 5.8 model is the preferred model to predict
concentrations in the far field (long range transport conditions beyond 50 kilometers from the source).

V. MODELING INPUTS AND ASSUMPTIONS

A. Technical Options

The regulatory default options were selected in AERMOD by the Applicant to quantify all concentrations.

B. Urban or Rural Area Designation

A review of the appropriate 7.5-minute quadrangles determined that the area should be classified as
“rural” for air modeling purposes.

C. Topography/Terrain

The Plant is at an elevation of 4,950 feet with nearby terrain features that have an effect on concentration
predictions.

a. Zone: 12
b. Location: UTM (NAD83): 397000 meters East, 4379850 meters North

D. Ambient Air

It was determined that the Plant boundary used in the AQIA meets the State’s definition of an ambient air
boundary.

E. Receptor and Terrain Elevations

The modeling domain has simple and complex terrain features in the near field. Therefore, receptor
points representing actual terrain elevations from the area were used in the analysis.

The far-field modeling domain consisted of a rectangular region covering all Class I areas within Utah,
and extending 50 kilometers beyond this area so that the model can account for re-circulation of the
plume.

DAQE-MN103030032-24
Page 5

F. Emission Rates and Release Parameters

The emission estimates and source parameters used in AERMOD for all proposed emission sources at the
site are presented in the NOI.

Speciated emission rates and source parameters used in the CALPUFF modeling are presented in Table 2.

Table 2: CALPUFF Emission Rates

Source
LCC Coordinates Modeled Emission Rates
Easting Northing SO2 SO4 NOX HNO3 NO3 SOA PMC SOIL EC
(m) (m) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr)
317.BF3 -1289410 -3738 52.81 5.03 307.58 0.00 0.00 5.03 2.60 2.90 0.11
419.BF1 -1289314 -3631 0.00 0.00 0.00 0.00 0.00 0.55 1.51 1.61 0.06
41B.BF2 -1289389 -3663 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.68 0.00
N1_FM2 -1289526 -3414 0.00 0.00 0.00 0.00 0.00 0.00 1.65 3.95 0.00
414.BF1N -1289407 -3683 0.00 0.00 0.00 0.00 0.00 0.00 0.10 0.25 0.00
2FM_HTR -1289528 -3415 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.08 0.00
514.BF1 -1289451 -3675 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.70 0.00
COMBO -1289424 -3668 0.00 0.00 0.00 0.00 0.00 0.00 1.37 5.72 0.00
FM2_CMB -1289454 -3439 0.00 0.00 0.00 0.00 0.00 0.00 0.50 1.21 0.00

Total Lb/hr 52.81 5.03 307.58 0.00 0.00 5.58 8.32 17.10 0.17
Hrs/Yr 8760 8760 8760 8760 8760 8760 8760 8760 8760
Ton/yr 231.3 22.0 1347.2 0.0 0.0 24.4 36.4 74.9 0.8

Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
317.BF3 POINT 4902.8 41.2 135.0 488 10.10 3.35
419.BF1 POINT 4891.2 18.3 60.0 388 6.36 2.90
41B.BF2 POINT 4895.2 68.6 224.9 294 17.83 0.74
N1_FM2 POINT 4832.0 49.7 163.0 363 40.08 1.40
414.BF1N POINT 4896.1 76.8 251.9 353 9.91 0.70
2FM_HTR POINT 4832.0 49.7 163.0 363 40.08 1.40
514.BF1 POINT 4889.5 39.6 130.0 294 11.86 0.91
COMBO POINT 4904.2 13.3 43.7 276 9.76 0.32
DAQE-MN103030032-24
Page 6
FM2_CMB POINT 4832.0 30.6 100.3 294 11.40 0.37

G. Building Downwash

The Applicant used the US EPA Building Profile Input Program (BPIP) to determine Good Engineering
Practice (GEP) stack heights and cross-sectional building dimensions for input into the model.

H. Ambient Background Concentrations

Millard County is in attainment for all criteria pollutants. The NAAQS analyses for PM2.5 and PM10 used
monitoring data collected on site during the pre-construction monitoring analysis. The background values
used in the NAAQS analysis are presented in Table 3.

Table 3: Background Concentrations

Pollutant Averaging
Period
Background
Concentration
(μg/m3)
PM10 24-hour 65.4
PM2.5 24-hour 10.2
Annual 4.2

I. Meteorological Data Processing

For the AERMOD model, on-site horizontal and vertical wind speed, direction, solar radiation and,
temperature data was combined with National Weather Service (NWS) upper air data collected at the Salt
Lake City International Airport (SLCIA) for the same period using the US EPA AERMET processing
system.

Meteorological data used for the CALPUFF modeling analysis consisted of 3 years (2018-2020) of data
developed by the Forest Service. The grid was 708 km (east-west) by 492 km (north-south) with a
resolution of 12 kilometers.

VI. RESULTS AND CONCLUSIONS

The Applicant performed a series of analyses to estimate the impact from the proposed project. Modeling
results and conclusions from the review of the analyses are outlined in detail below.

A. Pre-Construction Monitoring and Significant Impact Modeling

The Applicant performed a preliminary criteria pollutant analysis of the proposed modification. This
analysis indicated that increases in concentration levels of PM2.5 and PM10 were greater than the Class II
SIL, and therefore, a cumulative analysis for these pollutants was required.

DAQE-MN103030032-24
Page 7

B. NAAQS Analysis

The Applicant performed a modeling analysis to determine if the combined impact from the proposed
source, other industrial sources operating in the area, and ambient background would comply with the
NAAQS. The NAAQS analysis was reviewed by the Division and determined to be consistent with the
requirements of R307-410-3. Table 4 provides a comparison of the Applicant’s predicted air quality
concentrations and the NAAQS.

Table 4: Model Predicted NAAQS Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-hour 28.3 5 65.4 0 93.7 150 62.5%
PM2.5 24-hour 9.6 1.2 10.2 0 19.8 35 56.6%
Annual 4.4 0.3 4.2 0 8.6 9 95.6%
* Note: Only included other sources and background if source impact was above Class II SIL

C. PSD Class II Increments

The Applicant performed an analysis to determine if the impact from the proposed source would comply
with PSD Class II increments. The analysis was reviewed by the Division and determined to be
consistent with the requirements of R307-410-3. Table 5 provides a comparison of the predicted
concentrations and the PSD Class II increment.

Table 5: Model Predicted PSD Class II Increment Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Nearby
Sources*
Total Increment Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
PM10 Annual 8.1 1 0 8.1 25 32.4%
24-hour 28.3 5 0 28.3 30 94.3%
PM2.5 24-hour 6.1 1.2 0 6.1 9 67.8%
Annual 2.4 0.3 0 2.4 4 60.0%

D. Hazardous Air Pollutants

DAQE-MN103030032-24
Page 8
The Applicant performed an analysis to determine if HAP modeling is required. The analysis was
reviewed by the Division and determined to be consistent with the requirements of R307-410-3. The
analysis indicated that HAP modeling was not triggered by this modification, and therefore no HAP
modeling was performed.

E. PSD Class I Increment Consumption Analysis

The Applicant performed a CALPUFF analysis to determine if the impact from the proposed source along
with other increment consuming sources would comply with federal PSD Class I increments. The
analysis was reviewed by the Division and determined to be consistent with the requirements of R307-
410-3. The results for all Class I areas within 300 kilometers are provided in Table 6.

Table 6: Model Predicted PSD Class I Increment Concentrations

Air Period Prediction
Class I
Significant
Impact
Level
Other
Sources* Total Increment Percent
Pollutant (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
Capitol Reef
NO2 Annual 0.0018 0.1 2.5
SO2
3-Hour 0.0494 1 25
24-
Hour 0.0150 0.2 5
Annual 0.0008 0.1 2
PM2.5
24-
Hour 0.0430 0.27 2
Annual 0.0021 0.05 1
PM10
24-
Hour 0.0444 0.3 8
Annual 0.0021 0.2 4
Arches
NO2 Annual 0.0008 0.1 2.5
SO2
3-Hour 0.0408 1 25
24-
Hour 0.0102 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0522 0.27 2
Annual 0.0018 0.05 1
DAQE-MN103030032-24
Page 9
PM10
24-
Hour 0.0531 0.3 8
Annual 0.0019 0.2 4
Canyonlands
NO2 Annual 0.0010 0.1 2.5
SO2
3-Hour 0.0354 1 25
24-
Hour 0.0100 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0577 0.27 2
Annual 0.0019 0.05 1
PM10
24-
Hour 0.0591 0.3 8
Annual 0.0020 0.2 4
Bryce
NO2 Annual 0.0006 0.1 2.5
SO2
3-Hour 0.0369 1 25
24-
Hour 0.0082 0.2 5
Annual 0.0003 0.1 2
PM2.5
24-
Hour 0.0189 0.27 2
Annual 0.0010 0.05 1
PM10
24-
Hour 0.0194 0.3 8
Annual 0.0010 0.2 4
Zion
NO2 Annual 0.0011 0.1 2.5
SO2
3-Hour 0.0293 1 25
24-
Hour 0.0105 0.2 5
Annual 0.0005 0.1 2
PM2.5
24-
Hour 0.0266 0.27 2
Annual 0.0011 0.05 1
PM10 24-
Hour 0.0271 0.3 8
DAQE-MN103030032-24
Page 10
Annual 0.0012 0.2 4
* Note: Only included other increment consuming sources if source impact was above Class I SIL

Since the proposed project’s model predicted impacts at the Class I areas were less than the PSD Class I
significance levels, a cumulative analysis was not warranted.

DAQE-MN103030032-24
Page 11
F. Visibility – Plume Blight
Since the Class I areas are greater than 50 kilometers from the source, a plume blight analysis using
VISCREEN was not required.

G. Visibility – Regional Haze

The results of the Q/D analysis for the emissions increase was less than 10 but the FLMs wanted the
entire source included in the Q term. The results of including the total emissions resulted in a Q/D >10,
so an AQRV analysis was performed for visibility and acid deposition. The results shown in Table 7
indicate that the impacts are below the 0.5 Deciview (DV) threshold established by the National Park
Service, indicating that no further analysis is required.

Table 7: CALPUFF Visibility Results

Class I Area Year Maximum
Delta DV
98th
Percentile
change in
DV
#
Days
#
Days Threshold
(DV)
Below
Threshold
> 1 > 0.5
2018 0.248 0.06 0 0 0.5 Yes
Arches 2019 0.291 0.054 0 0 0.5 Yes
2020 0.216 0.106 0 0 0.5 Yes
2018 0.223 0.081 0 0 0.5 Yes
Canyonlands 2019 0.312 0.068 0 0 0.5 Yes
2020 0.186 0.085 0 0 0.5 Yes
2018 0.059 0.03 0 0 0.5 Yes
Bryce 2019 0.081 0.045 0 0 0.5 Yes
2020 0.071 0.03 0 0 0.5 Yes
2018 0.183 0.074 0 0 0.5 Yes
Capital Reef 2019 0.196 0.092 0 0 0.5 Yes
2020 0.126 0.078 0 0 0.5 Yes
2018 0.069 0.04 0 0 0.5 Yes
Zion 2019 0.123 0.039 0 0 0.5 Yes
2020 0.102 0.057 0 0 0.5 Yes

DAQE-MN103030032-24
Page 12

H. Acid Deposition

The Applicant performed a deposition analysis on impacts within the Class I areas. Results of the
analysis indicate that the impacts are below the deposition threshold (DAT) established by the National
Park Service, indicating that no further analysis is required

Table 8: CALPUFF Deposition Results for Highest Year

Class I Area
Total
Nitrate
Deposition
Total
Sulfate
Deposition
Deposition
Analysis
Threshold
(kg/ha/yr) (kg/ha/yr) (kg/ha/yr)
Canyonlands 0.0006 0.0003
0.005
Zion 0.0004 0.0002
Arches 0.0006 0.0003
Bryce 0.0006 0.0002
Capitol Reef 0.0011 0.0005

I. Soils and Vegetation Analysis

The Applicant performed an analysis to determine the extent of impacts from the proposed source on soil
and vegetation. Results of the analysis are presented in a supplemental document titled “Soil and
Vegetation Impact Analysis for the Leamington, UT Facility, June 29, 2023”. The analysis indicated that
predicted concentrations compared against the secondary NAAQS at several sensitive receptors would not
result in an adverse impact on soils and vegetation in the vicinity of the proposed project.

DP/JK:jg

DAQE-IN103030032-25

January 22, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Mr. Nelson:

Re: Intent to Approve: Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — ) A A v A ? A D @ A w D D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — ) A A v A ? A D @ A w D D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ash Grove Cement Company Ash Grove Cement Company - Leamington Cement Plant

Mailing Address Physical Address
P.O. Box 38069 Highway 132
Leamington, UT 84638 Leamington, UT 84638

Source Contact UTM Coordinates
Name: Cody Watkins 397000 m Easting
Phone: [phone] 4380100 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3241 (Cement, Hydraulic)

SOURCE INFORMATION
General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried on site),
are correctly proportioned, ground, and mixed and then fed into a rotating kiln. The kiln alters the
materials and recombines them into small stones called cement clinker. The clinker is cooled and ground
with gypsum and additional limestone into a fine powdered cement. The final product is stored on site for
later shipping. The major sources of air emissions are from the combustion of fuels for the kiln operation,
from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source of
emissions of PM2.5, PM10, NOx, CO, HAPs, and GHG. It is a minor source of SO2 emissions.
NSR Classification
Major PSD Modification

Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
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Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

These changes result in increases in actual emissions but decreases in most potential emissions. There will
be an increase in the potential emissions of VOCs and greenhouse gases.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
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Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
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I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
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II.A.4 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)
II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area, and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, stacker systems. II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit-specific requirements.
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total air flow controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter
area; 9,865 acfm total air flow, controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are
controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each
is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6). II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The
following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for
NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.
II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low-pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

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II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow through stack
E34.
II.A.18 Kiln Feed Alleviator A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the central material silo between the blending silos and the preheater. Raw feed is removed from the system near the top of the preheater tower.
II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The
coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter area;
1,700 acfm total air flow.
II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker
storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1): 1,800 acfm that discharges into the clinker tunnel.
II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
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II.A.27 Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during loading.
II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel, all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during loading. 512.BF3 (1,000 acfm) is located on top of the silo. II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement products. Dust generated
during milling is captured by a BHA pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).

II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates from stack G55 (finish mill stack).
II.A.32 Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4).
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1 thru 3).

II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total air flow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations.
II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This
baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

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II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.
II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023)
II.A.40 Dust Shuttle System A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides, surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the
fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

II.A.41 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons) Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
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II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)
THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)
CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)
PM: 0.02 lbs filterable PM per ton of clinker.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR 60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to approve alternative control measures, the permittee shall keep a copy of the submitted petition and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source
of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2).
[40 CFR 63 Subpart LLL]

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II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must record the PM CPMS output data for all periods when the process is operating and use all the PM CPMS data for calculations when the PM CPMS is not out of control. The owner/operator must demonstrate continuous compliance by using all quality-assured hourly average data collected by the PM CPMS for all operating hours to calculate the arithmetic average operating parameter in units of the operating limit on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
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II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

II.B.1.e.3 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-165]
II.B.1.e.4 PM 40 CFR 60, Appendix A, Method 5, or 5I, or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three runs, with each
run at least 120 minutes in duration and each run collecting a sample of 60 dry standard cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165]
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II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
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II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
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II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer point, is not required to conduct Method 22 visible emissions monitoring under this paragraph. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator may decrease the frequency of performance testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
DAQE-IN103030032-25
Page 17

II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: Instances of water and/or chemical application to unpaved areas shall be recorded and maintained by the owner/operator. The ambient temperature shall be recorded any time water should be applied but cannot due to freezing conditions. [R307-401-8]
II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

The sprays shall operate whenever dry conditions warrant meeting the required opacity
limitations or as determined necessary by the Director. Water sprays shall not be required during
periods of freezing temperatures.

[R307-401-8]

DAQE-IN103030032-25
Page 18

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

C. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the kiln/raw mill stack

F. The owner/operator shall record the output of the system: including the quantity of NOx, CO, O2, THC, Hg, HCl, and CO2 emissions at the kiln stack

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an
affected source shall continuously operate all required continuous monitoring devices
and shall meet minimum frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.

[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]
II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments, the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the results of the performance test demonstrating compliance with the filterable PM limit and using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust the SSOL developed in accordance with the results of the most recent PM performance test demonstrating compliance with the PM emission limit. The owner/operator shall use the PM CPMS to demonstrate continuous compliance with the SSOL in accordance with the requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

DAQE-IN103030032-25
Page 19

II.B.4 Fuel Limitations: II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke F. Fuel Oil
G. Used Oil Fuel

H. Synthetic Fuel
I. Wood
J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal additive.
Approval is not required to change from one previously approved coal additive to another
previously approved coal additive. [R307-401-8]
II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily heat input of the kiln and precalciner. The owner/operator may increase the average quantity of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon approval by the Director in accordance with the approval process described in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

DAQE-IN103030032-25
Page 20

II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight
A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation
C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit-no less than 1500oF for more than five minutes in any 60-minute period B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
DAQE-IN103030032-25
Page 21

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the Director. The calibration procedure and frequency shall be according to manufacturer's specifications. Use of factory-calibrated thermocouples for temperature measurement is approved. However, any other method of temperature measurement must be approved by the Director prior to use. The monitoring equipment for both temperature and oxygen content shall be located such that an inspector can at any time safely read the output. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall only operate the emergency engines for testing and maintenance purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency operation. [R307-401-8]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.5.b.2 To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From Source Submitted NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-IN103030032-25
Page 22

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-GN103030032J-25
January 22, 2025
Via Certified Mail 70190700000208349765
DJ Law
EPA Region 8
1595 Wynkoop Street
Denver, Colorado 80202-1129
[e-mail]
Dear Mr. Law:
RE: Notice of Publication for Ash Grove Cement Company- Leamington Cement Plant – CDS A;
MACT (Part 63), Compliance Assurance Monitoring (CAM), Title V (Part 70) Major Source,
Major Criteria Source, Major HAP Source, Attainment Area, NSPS (Part 60),
Project Number: N103030032
On January 22, 2025, the Director has completed his review of a Prevention of Significant Deterioration
project submitted by Ash Grove Cement Company. Attached to this letter are the draft Approval Order
document (Intent to Approve) and the full engineering review. Following a 60-day review by the Federal
Land Managers, this project will be submitted for a 30-day public comment period. Written comments
received by the Division at this same address during these comment periods will be considered in making
the final decision on the approval/disapproval of the proposed Approval Order. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director at the Division in writing, a hearing
will be held in accordance with R307-401-7, UAC.
If you have any questions, please contact John Jenks, who may be reached at [phone].
Sincerely,
Jon L. Black, Manager
New Source Review Division
Enclosures: Engineering Review
Modeling Memo
Intent to Approve
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
Jon Black (Jan 22, 2025 14:59 MST)
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
RN103030032
January 21, 2025
Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]
Dear Josh Nelson,
Re: Engineer Review:
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032
Please review and sign this letter and attached Engineer Review (ER) within 10 business days.
For this document to be considered as the application for a Title V administrative amendment, a
Title V Responsible Official must sign the next page.
Please contact John Jenks at [phone] if you have any questions or concerns about the ER.
If you accept the contents of this ER, please email this signed cover letter to John Jenks at
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 1

[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the
DAQ will consider any comments received and will issue the Approval Order.

If you do not respond to this letter within 10 business days, the project will move forward
without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue
an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 2

OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible
Official, as defined in R307-415-3, must sign the statement below. THIS IS STRICTLY
OPTIONAL.

If you do not want the Engineer Review to be considered as an application to administratively
amend your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will
require submittal of a separate Operating Permit Application to revise the Title V permit in
accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document:
Title V Operating Permit Application Due Dates clarifies the required due dates for Title V
operating permit applications and can be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality

“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate
and complete and request that this Approval Order be considered as an application
to administratively amend the Operating Permit.”

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 3

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N103030032
Owner Name Ash Grove Cement Company
Mailing Address P.O. Box 38069
Leamington, UT, 84638

Source Name Ash Grove Cement Company- Leamington Cement
Plant
Source Location Hwy 132
Leamington, UT 84638

UTM Projection 397000 m Easting, 4380100 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3241 (Cement, Hydraulic)

Source Contact Cody Watkins
Phone Number [phone]
Email [e-mail]

Billing Contact Cody Watkins
Phone Number 385.225.0615
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 30, 2022
Date of Accepted Application November 28, 2024

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 4

SOURCE DESCRIPTION

General Description
Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried
on site), are correctly proportioned, ground and mixed, and then fed into a rotating kiln. The kiln
alters the materials and recombines them into small stones called cement clinker. The clinker is
cooled and ground with gypsum and additional limestone into a fine powdered cement. The final
product is stored on site for later shipping. The major sources of air emissions are from the
combustion of fuels for the kiln operation, from the kiln, and from the clinker cooling process.
The Leamington cement plant is a major source for emissions of PM2.5, PM10, NOx, CO, HAPs
and GHG. It is a minor source of SO2 emissions.

NSR Classification:
Major PSD Modification

Source Classification
Located in Attainment Area,
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Proposal
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower, various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 6

These changes result in increases in actual emissions, but decreases in most potential emissions.
There will be an increase in the potential emissions of VOC and greenhouse gases.

EMISSION IMPACT ANALYSIS
The complete modeling review is located in DAQE-MN103030032-24. [Last updated January 14, 2025]

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 7

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 8

Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 9

Review of BACT for New/Modified Emission Units

1. BACT review regarding the Leamington Plant Upgrade Project
Any major stationary source or major modification subject to PSD review must undergo an
analysis to ensure the use of BACT. The requirement to conduct a BACT analysis is set forth in 40
CFR 52.21. Similarly, Utah requires the installation of BACT for all sources of air pollution under
R307-401-5(2)(d)), BACT is defined in 40 CFR 52.21 (and R307-401-2) as:

". . . best available control technology means an emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for each pollutant subject to regulation under
Act which would be emitted from any proposed major stationary source or major modification
which the Administrator, on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such source or modification
through application of production processes or available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion techniques for control of such
pollutant . . ."

Therefore, a BACT analysis is required for each new or physically modified emission unit for each
pollutant that exceeds an applicable PSD significant emission rate (SER). Since the PM10 and PM2.5
emissions from the proposed project exceed the applicable PSD SER, a BACT analysis is required
to assess the required levels of control for these pollutants. Because the CO2e emissions are subject
to regulation as a result of the proposed project resulting in an increase of 75,000 tons or more per
year CO2e, a BACT analysis is also required for that pollutant. Note that HAPs listed under CAA
Section 112(b)(1) are excluded from NSR (New Source Review) or PSD (i.e., BACT) review.

In a memorandum dated December 1, 1987, the United States Environmental Protection Agency
(EPA) stated its preference for a "top-down" BACT analysis. After determining if any New Source
Performance Standard (NSPS) is applicable, the first step in this approach is to determine, for the
emission unit in question, the most stringent control available for a similar or identical source or
source category. If it can be shown that this level of control is technically, environmentally, or
economically infeasible for the unit in question, then the next most stringent level of control is
determined and similarly evaluated. This process continues until the BACT level under
consideration cannot be eliminated by any substantial or unique technical, environmental, or
economic objections.

Presented below are the five basic steps of a top-down BACT review as identified by the EPA.
Step 1 - Identify All Control Technologies
Step 2 - Eliminate Technically Infeasible Options
Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Step 4 - Evaluate Most Effective Controls and Document Results
Step 5 - Select BACT

Ash Grove has elected to follow this methodology and based the BACT review on each individual
pollutant. The complete BACT analysis follows. [Last updated January 14, 2025]

2. BACT review regarding PM10 and PM2.5 Sources
PM10 and PM2.5 Modified Equipment
The existing kiln precalciner, preheater, and alleviator system are proposed to be modified, and the
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 10

kiln's ID fan and clinker cooler fans are proposed to be replaced, which will result in increased
airflow. Additionally, the clinker cooler baghouse will be converted from a plenum pulse to a pulse
jet baghouse. These modifications are projected to result in a net increase of potential PM10 and
PM2.5 emissions.

Kiln Upgrade BACT
The rotary cement kiln is the core of the cement manufacturing process, transforming the blended
raw materials or "rawmix" into clinker through pyro processing. Emissions from the kiln occur
from fuel combustion plus the physical and chemical reactions needed to transform the rawmix
into clinker. This project involves process and energy efficiency improvements and an increase in
kiln production, resulting in an increase of PM10 and PM2.5 emissions. This section specifically
addresses filterable PM10 and PM2.5. The condensable fraction is represented with the other
precursors as applicable to proposed emission increases.

The Leamington Plant's Kiln is subject to NSPS, Subpart F for particulate. Therefore, a BACT
analysis addresses applicability of the proposed changes to the kiln system to NSPS and review of
the RBLC. A summary of the resources reviewed include the following:

NSPS Subpart F - Standards of Performance for Portland Cement Plants establishes emission
standards for cement kiln operations. Specifically, kilns modified after June 16, 2008, are limited to
0.07 lbs PM/ton of clinker produced.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028) and
Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from kiln operations are as follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM emissions are most effectively controlled using a collection system with enclosures routed to
baghouses providing up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Ash Grove
has selected technology with the highest control efficiency, so there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.
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Step 5 - Select BACT
Ash Grove proposes that BACT for PM10 and PM2.5 emissions from the kiln consist of a collection
system routed to a baghouse or fabric filter that complies with NSPS Subpart F's emission standard
for a modified source. BACT for the Leamington Plant's kiln are 10% opacity and 0.07 lb of
PM/ton (NSPS Subpart F emission standard) of clinker.
[Last updated January 14, 2025]

3. BACT review regarding PM10 and PM2.5 sources cont.
Clinker Cooler Upgrade BACT
The clinker cooler reduces the temperature of the clinker exiting the kiln. It is necessary to reduce
clinker temperature before it enters the finish mill to maintain product quality and reduce wear and
tear on equipment. The clinker cooler is equipped with a heat exchanger that captures waste heat
and transfers it to the kiln preheater for process and energy efficiency. Emissions from the clinker
cooler are vented to a baghouse. The Leamington Plant's clinker cooler is also subject to NSPS
Subpart F for particulate. Ash Grove's proposed changes to the clinker cooler meet the definition of
a reconstruction under NSPS. Therefore, in order to meet the requirements of NSPS Subpart F, Ash
Grove will be required to meet a limit of 0.02 lb of PM/ton of clinker.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from clinker cooler operations are as
follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM10 and PM2.5 emissions are most effectively controlled using a collection system with enclosures
routed to a baghouse, which can achieve up to 99.9% control efficiency. Other technologies such as
wet scrubbers, cyclones and ESPs are feasible, but provide lower control efficiencies than a
baghouse. Because the most efficient control technology is proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for PM10 and PM2.5 emissions from the clinker cooler is a collection system routed to a
baghouse or fabric filter. In order to meet the requirements of NSPS Subpart F, Ash Grove will
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meet a reduced emission limit of 0.02 lb of PM/ton of clinker. A 10% opacity limit is also
applicable. [Last updated January 14, 2025]

4. BACT review regarding PM10 and PM2.5 sources cont.
New Finish Mill BACT
The proposed Plant upgrade include adding a second finish mill. The new finish mill will use an
energy efficient vertical roller mill assisted with a grinding aid. A total of five (5) point sources are
planned for the finish mill. In accordance with NSPS Subpart F, emissions from finish mill are
restricted to 10% opacity. Ash Grove has reviewed the following sources to identify available
control technologies.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);12 and

Region 8 General Permit for Concrete Batch Plants.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 emissions from plant material handling operations are as
follows:
Baghouse / Fabric Filter;
Best Management & Operational Practices;
Cyclone;
ESP;
Enclosure;
Water Application (Watering); and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
With the exception of water application, all options are technically feasible. Water application is
eliminated as clinker exiting the kiln along with additives in the finish mill must remain dry to
maintain product quality. Therefore, it is technically infeasible to water material in the finish mill.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Enclosure 50-90%
5. Cyclone 20-70%
6. Best Management & Operational Practices varies

Step 4 - Evaluate Most Effective Controls and Document Results
Baghouses provide the highest emission control efficiency, controlling up to 99.9% of PM
emissions from finish mill equipment. After baghouses, using a wet scrubber or ESP provides
similar PM control. Notably, baghouses, scrubbers, and ESPs require enclosures to aid in capturing
emissions and ducting to the control. Therefore, optimal PM emission control can be achieved
through implementing both baghouses and enclosures where feasible. Plant material sizing and
handling is currently done using a series of buildings and enclosures routed to baghouse controls.
Various silos storing material inputs are also equipped with fabric filters. As the highest ranked
technology is applied, there are no adverse energy, environmental or cost impacts to consider with
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the use of these control technologies. Thus, no further analysis is required under EPA's top-down
BACT approach.

Step 5 - Select BACT
BACT for finish mill PM10 emissions is compliance with NSPS Subpart F, Standards of
Performance for Portland Cement Manufacturing where applicable. Ash Grove will achieve BACT
for PM10 emissions from finish mill equipment through the implementation of enclosures,
baghouses, and best management practices. All baghouses at the finish mill will have a 10%
opacity limitation and a grain loading of 0.005 grains/dscf. [Last updated January 14, 2025]

5. BACT review regarding PM10 and PM2.5 sources cont.
Material Transfer, Sizing, and Storage BACT
The Leamington Plant has sources of fugitive emissions through raw material transfer. Materials
transferred include limestone and other raw materials, coal, clinker, and cement. These materials
are transferred by conveyor belt, screw conveyor, elevator, pneumatic conveyance or chutes via
gravity. At the Leamington Plant the fugitive emissions are enclosed at their transfer points and
routed to baghouses.

The following emission units are included in this category:
Limestone Crushing, Sizing, and Material Transfer;
Raw Material Transfer;
Coal Sizing and Transfer;
Existing Finish Mill;
Clinker Storage and Transfer;
Cement Storage and Truck and Rail Cement Loadout;
New Rail Loading and Loadout; and
New Clinker Reclaim Hopper Baghouse.

Generally, controls for these units have not changed or they are similar to current existing controls.
A full BACT analysis of each unit is included in Ash Grove's NOI and additional submitted
information. However, given that most controls remain unaltered, only the results of Step 5 -
Select BACT will be included here.

Limestone Crushing, Sizing, and Material Transfer
Subject to NSPS Subpart OOO opacity limits for existing sources.
Existing baghouses. No change from bag manufacturer's specifications.

Raw Material Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Coal Storage and Transfer
Existing Equipment. No change from bag manufacturer's specifications
20% Opacity

Clinker Storage and Transfer
Subject to NSPS Subpart F opacity limits:
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10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Existing Finish Mill Grinding, Storage and Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Cement Storage and Truck and Rail Cement Loadout, New Rail Loadout
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

New Rail Loadout, controlled by baghouse
Emissions Limit - 0.005 gr/dscfm

New Clinker Reclaim Hopper, controlled by baghouse
Subject to NSPS Subpart F opacity limits:
10% opacity
Emissions Limit - 0.005 gr/dscfm [Last updated January 14, 2025]

6. BACT review regarding PM10 and PM2.5 sources cont.
PM10 and PM2.5 Fugitive Emissions
The following fugitive emissions sources will increase emissions of PM10 and PM2.5 as a result of
the Leamington Plant's proposed throughput increase. The sources addressed in the following
BACT analyses are primarily in the quarry, but also include emissions from roads and dumping of
raw materials within the plant boundary.

The sources evaluated are listed below:
Roads;
Loading and Unloading;
Stockpiles;
Bulldozing and Grading;
Disturbed Areas; and
Drilling and Blasting.

Ash Grove currently controls emissions from these processes, and generally, controls for these
units have not changed. A full BACT analysis of each unit is included in Ash Grove's NOI and
additional submitted information. However, given that most controls remain unaltered, only the
results of Step 5 - Select BACT will be included here.

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
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Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

Stockpiles BACT
BACT shall consist of restricting fugitive emissions to the opacity standard of 20% opacity at the
property boundary. BACT for stockpiles will be achieved through applying good management
practices through its fugitive dust plan as appropriate.

Bulldozing and Grading BACT
BACT shall consist of restricting fugitive emissions from bulldozing and grading activities to no
more than 20% opacity, and that emissions are controlled with periodic watering of the disturbed
surface. The frequency of water application will depend on ambient weather conditions and
inherent moisture content of the material being moved.

Disturbed Areas BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. BACT for
disturbed areas will be achieved through best management practices, watering, scarification, and
revegetation.

Drilling and Blasting BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. This is achievable
through best management practices, shrouds, watering, and dust collection. [Last updated January
14, 2025]

7. BACT review regarding kiln system NOx emissions
Kiln System (Kiln, Raw Mill, and Coal Mill) - NOx BACT
Although there are physical changes to the kiln system, these changes are primarily related to
particulate emissions. NOx emissions are generated from the combustion of fuel - and no changes
in NOx emissions are expected from the kiln (hourly capacity to emit). The kiln NOx emissions will
remain the same as a result of upgrades to the SNCR system. The replacement of the various
components of the kiln system and portions of the preheater tower, along with new injection points,
will ensure that increased mixing of ammonia is achieved to enhance the SNCR system's ability to
reduce NOx and minimize ammonia slip. This will allow the Leamington Plant to maintain the NOx
hourly capacity to emit unchanged from current levels Leamington Plant Upgrade Project. At
present Ash Grove has no restriction on the amount of fuel combusted, only a limit on total NOx
generated, and with this project the allowed NOx PTE is decreasing from 1,352 tpy to 1,226 tpy.

Additional ammonia will be used in the existing SNCR system. While the SNCR system has
adequate capacity to accommodate the additional ammonia demand resulting from the system
upgrades, more ammonia ports are proposed to be added with the kiln system's proposed changes
of the equipment. The changes proposed to the kiln system will increase residence time and
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temperature which will improve the SNCR system's effectiveness to control NOx emissions and
minimize ammonia slip emissions to the atmosphere. No additional review of NOx BACT for the
kiln system is required under this proposal. [Last updated January 14, 2025]

8. BACT review regarding new finish mill heater emissions
Finish Mill Heater
The proposed finish mill will include a process heater to maintain a minimum temperature during
milling. The proposed heater will run on natural gas and is rated at 10 MMBtu/hr. Startup and
shutdown emissions from the heater are anticipated to be no greater than normal operation as the
process is simply a matter of bringing the heater to operating temperature. Emissions evaluated in
the BACT analysis for the finish mill heater include NOx, SO2, CO, and VOCs, PM10, and PM2.5.
Pollutants with identical control technologies are grouped together in the analysis.

NOx - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for NOx from units of this size range are as follows:
Ultra-Low-NOx Burners (ULNB);
Low NOx Burners;
Selective Catalytic Reduction (SCR);
Selective Noncatalytic Reduction (SNCR);
Good Combustion Practices; and
Use of Natural Gas.

Step 2 - Eliminate Technically Infeasible Options
Low exit temperatures render the use of SCR and SNCR ineffective. Particulate entrainment within
the finish mill could potentially foul (plug) the nozzles of ULNB. Low-NOx burners, the use of
natural gas as fuel and good combustion practices are all considered technically feasible.

Step 3 and Step 4 - Rank Remaining Control Technologies by Control Effectiveness and Evaluate
Most Effective Controls and Document Results
Since the three feasible control technologies are proposed for the finish mill heater, no detailed
economic, energy, and environmental impact evaluations were conducted. No ranking of control
effectiveness is required as all three controls are proposed.

Step 5 - Select BACT
BACT for NOx is the use of natural gas as fuel, good combustion practices and the use of Low NOx
burners.

CO, SO2, and VOC - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for CO, SO2, and VOC from units of this size are as follows:
Good Combustion Practices
Use of Natural Gas

The finish mill heater combusts natural gas. Related natural gas combustion emissions are
anticipated to be minimal.

Step 2 - Eliminate Technically Infeasible Options
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Both control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Both technologies offer intrinsic emission reductions from combustion. Since the technologies do
not compete, both technologies can and will be used simultaneously.

Step 4 - Evaluate Most Effective Controls and Document Results
Because both control technologies identified in Step 1 are proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for CO, SO2, and VOC are good combustion practices and the use of natural gas.

PM10 and PM2.5 BACT for the finish mill has been addressed in the PM10/PM2.5 sources section.
[Last updated January 14, 2025]

9. BACT review regarding SO2, VOC, and Lead Sources
The following BACT analysis is grouped by pollutants that will experience an increase in potential
emissions and the associated technically feasible control technologies. As such, the BACT analysis
is separated into SO2, VOC, and lead respectively with organic HAPs addressed with VOCs.

SO2 - Cement Kiln BACT
NSPS Subpart F - Standards of Performance for Portland Cement Plants, establishes emission
standards for cement kiln operations. Specifically, kilns constructed or reconstructed after June 16,
2008, are limited to 0.4 lbs SO2/ton clinker on a 30-day rolling average respectively. This limit is
an existing emission limit in the Leamington Plant's approval order and Title V. Ash Grove will
continue to achieve this emission limitation while achieving BACT for the kiln operations. Ash
Grove has reviewed the following sources to identify available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019); and

NSPS Subpart F as an affected emissions facility in 40 CFR 60.62(a)(4);

Portland Cement Association's Formation and Techniques for Control of Sulfur Dioxide and Other
Sulfur Compounds in Portland Cement Kiln Systems.

SO2 emissions are a result of oxidation of sulfur compounds in the rawmix and/or the coal used to
fire the kiln. However, the alkaline nature of the cement provides for direct absorption of SO2 into
the product, thereby mitigating the quantity of SO2 emissions in the exhaust stream.

Step 1 - Identify All Control Technologies
Control technologies identified for SO2 emissions from coal-fired kiln operations are as follows:
Baghouse or fabric filter;
Dry reagent injection prior to baghouse;
Wet scrubber;
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Process optimization; and
Good combustion practices.

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below:

1. Process Optimization 99%
2. Wet Scrubber 99%
3. Dry Reagent Injection 60%
4. Good Combustion Practices 30%
5. Baghouse Variable

Step 4 - Evaluate Most Effective Controls and Document Results
SO2 emissions are most effectively controlled by optimizing the process and utilizing the inherent
SO2 scrubbing properties of the kiln system itself. Although wet scrubbers alone can achieve equal
control efficiencies as process optimization, additional capital and operational expenses are
required for water consumption and wastewater discharge. Whereas process optimization achieves
the same control effectiveness and has the added benefit of reduced operational costs. Ash Grove
optimizes the kiln process by routing the exhaust from the kiln to a preheater and raw mill to
interact with the raw mix, thus creating an atmosphere similar to a dry scrubber system. Good
combustion practices also reduce SO2 formation with the added benefit of energy efficiency.

Step 5 - Select BACT
BACT for control of SO2 emissions from kiln operations shall consist of process optimization by
routing kiln exhaust to the preheater and raw mill, good combustion practices, and use of a
baghouse prior to exhausting to the atmosphere. As a modification of the kiln, 40 CFR 60.62(a)(4)
requires an emission limit of 0.4 pounds of sulfur dioxide (SO2) per ton of clinker on a
30-operating day rolling average. [Last updated January 14, 2025]

10. BACT review regarding SO2, VOC, and Lead Sources cont.
VOC - Cement Kiln BACT
VOCs are generated by incomplete combustion in the kiln. 40 CFR 63 Subpart LLL - NESHAP
from the Portland Cement Industry limits total hydrocarbon and total organic HAP emissions to 24
and 12 ppmv at 7% oxygen. Ash Grove will achieve or exceed these emission limitations while
achieving BACT for the kiln operations. Ash Grove has reviewed the following sources to identify
available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028); and

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for VOC emissions from coal fired kiln operations are as follows:
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Process optimization,
Good combustion practices

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below.

1. Process Optimization Variable
2. Good Combustion Practices Variable

Step 4 - Evaluate Most Effective Controls and Document Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove optimizes the
kiln process by capturing waste heat from the clinker cooler and routing to a kiln preheater. Good
combustion practices also reduce VOC formation with the added benefit of energy efficiency.
There are no adverse energy, environmental or cost impacts to consider with the use of this control
technology.

Step 5 - Select BACT
BACT for control of VOC emissions from kiln operations shall consist of process optimization by
routing kiln heat to the preheater and good combustion practices. An emission limit of 24 ppmv
VOC @ 7% O2 is imposed by NESHAP Subpart LLL.

VOC - Grinding Aid BACT
A grinding aid containing VOC is added to the new finish mill to disperse particles within the mill
and expose more surface area to grinding. An increase in grinding aid usage proportionally
increases potential VOC emissions because volatiles from the grinding aid are not combusted in
the kiln.

There is only one identified control option for limiting the VOC emissions from the grinding aid.
Process optimization is technically feasible. VOC emissions are most effectively controlled by
optimizing the process. Ash Grove proposes to install a vertical finish mill with this project. Due to
the new modern mill's efficiency, it is anticipated that a reduced amount of grinding aid will be
required for each ton of clinker ground. Ash Grove estimates total VOC emissions from the
grinding aid at 2.37 tpy.

Lead Emissions
The lead emissions are anticipated to increase as a result of the proposed increase in clinker
throughput with the Leamington Plant upgrade project. Lead emissions result from residual
amounts of lead in raw materials and fuel. Lead emissions will be controlled the same as PM,
therefore a separate top-down BACT analysis has not been conducted as the Leamington Plant has
applied the most effective controls. [Last updated January 14, 2025]

11. BACT review regarding Greenhouse Gases
GHG Background
On October 9, 2009, the mandatory GHG reporting regulation, referred to as 40 CFR 98, was
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published in the Federal Register. Through 40 CFR 98, the U.S. EPA established the GHG
Reporting Rule, which requires the annual reporting of GHG data and other relevant information
from large sources and suppliers in the United States. Monitoring through the GHG Reporting
Program (GHGRP) began in 2010, with the first reports due by March 31, 2011. Per 40 CFR
98.2(a)(1), any facility associated with cement production is subject to the GHGRP and must report
CO2e emissions. The CO2e is the sum of equivalent GHG emissions from CO2, CH4, and N2O,
with their respective global warming potentials (GWP) applied. Ash Grove's facility is subject to
GHG Reporting Rule and monitors CO2 emissions from its kiln with a continuous emissions
monitoring system (CEMs). On June 23, 2014, the U.S. Supreme Court held that required PSD
permits (based on emissions of non-GHG pollutants) may continue to require limitations on GHG
emissions based on the application of BACT as an "anyway source". The Leamington Plant
modification project is a major source for PSD for both PM10 and PM2.5, and GHGs are estimated
to be greater than 75,000 tpy and greater than zero on a mass basis; therefore, GHGs are evaluated
for BACT as an anyway source.

Cement Manufacturing GHG BACT
A BACT analysis has been conducted for CO2e emissions from the kiln system. For this GHG
BACT analysis, various control technologies or combinations of technologies were identified using
the RACT/BACT/LAER Clearinghouse, available literature including guidance published by EPA
and South Coast Air Quality Management District (SCAQMD), current air regulations, other
regulatory organizations, and engineering experience. In March 2011, EPA published GHG
permitting guidance, as well as a white paper on available and emerging technologies for reducing
GHG emissions from the Portland cement industry in October 2010. Additionally, EPA published a
series of videos on GHG permit training in December 2010. The SCAQMD published GHG BACT
guidance in 2021. Additional sources of information were reviewed and documented based on
publications from trade organizations and other governmental committees with GHG or carbon
reduction guidelines and/or recommendations.

EPA has defined in 40 CFR 86.1818-12(a) GHGs as a group of six gases: CO2, nitrous oxide
(N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF6). GHG emissions from the kiln result from calcination and fuel combustion.
Since the primary GHG emitted by a kiln is CO2, the BACT analysis focuses on CO2 emissions
from the kiln. Emissions of CH4 and N2O are minimal from cement kilns. Per EPA guidance, GHG
control technologies for consideration in a BACT analysis for Portland Cement Manufacturing
include:

Source-wide energy efficiency strategies;
Raw material substitution;
Blended cements;
Carbon capture utilization and storage; and
Fuel switching.
Other emerging technologies [Last updated January 14, 2025]

12. BACT review regarding Greenhouse Gases cont.
Step 1: Identify All Control Technologies
The CO2 emissions from a cement kiln are generated by the calcination process (conversion of the
calcium carbonate in limestone to calcium oxide) and by combustion of fuel in the kiln. Potential
control technologies to reduce these CO2 emissions for a cement kiln are addressed in EPA's white
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paper on Available and Emerging Technologies for Reducing GHG Emissions from the Portland
Cement Industry.

These technologies fall into three categories:
Energy Efficiency Improvements for the Clinker Production Process
Fuel Substitution
Carbon Capture and Sequestration

Step 2: Eliminate Technically Infeasible Options
Several potential energy efficiency improvements are technically feasible: Pre-heater/Pre-calciner
Kiln Process, Kiln Seal Management Program, Refractory Selection (Kiln Insulation), and Energy
Recovery from the Clinker Cooler. The use of alternative fuels such as natural gas, whole tires and
biofuel) is also technically feasible. Other control options, such as Use of Fluxes and Mineralizers,
Heat Recovery for Power - Cogeneration, Carbon Sequestration, Oxyfuel combustion, and
Post-combustion Capture have been deemed infeasible.

Step 3: Rank Remaining Control Technologies by Control Effectiveness
All four remaining control techniques are currently implemented at the Leamington Plant. This
permitting project incorporates energy efficiency improvements. Ash Grove has had a fuel
substitution program in place for several years, and this program is continually reviewed and
updated as new sources and types of fuel are identified.

Step 4: Evaluate Most Effective Controls and Document Results
Since all technically feasible energy efficiency improvements and changes to product composition
will be implemented, this section will focus on economic and environmental considerations of fuel
substitution to operate exclusively on natural gas.

Firing natural gas as the primary kiln fuel can reduce CO2 emissions from fuel combustion by as
much as 40%. However, studies have shown that use of natural gas as primary kiln fuel can result
in three times more NOx emissions than NOx emissions from coal firing. Creating more NOx to
reduce GHG emissions is undesirable as it is a precursor to both ozone and PM2.5. Fuel substitution
essentially trades emissions of one regulated pollutant for another. Estimated capital cost to switch
to natural gas fuel exceeds $25M. Implementing natural gas technology would provide incremental
public health and welfare benefit globally by reducing CO2 emissions, while increasing NOx
emissions and negatively impacting public health and welfare locally. Switching fuels to another
fossil fuel has finite potential to mitigate CO2 emissions.

Step 5: Select BACT
In addition to the proposed energy efficiency improvements addressed elsewhere in this BACT
analysis, BACT is a limit of 0.92-ton CO2e/ton clinker. Ash Grove will use a continuous emission
monitoring system (CEMS) for CO2 to demonstrate compliance with this limit. [Last updated
January 14, 2025]

13. BACT review regarding Leamington Plant Upgrade Project conclusion
The control processes and techniques covered in this BACT analysis have been reviewed by the
NSR Section of the UDAQ. Ash Groves proposed controls and associated emission limitations
represent BACT. Any emission limitations not expressed in an associated NSPS or NESHAP will
be included in the terms and conditions of this AO. A listing of all associated NSPS and NESHAP
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programs is also included in the Source Information section of this document under Applicable
Federal Programs. [Last updated December 13, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date
of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
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proper credit when notifying the Director, send the documentation to the Director, attn.: NSR
Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.

II.A.3
NEW
Stockpiles
Coal storage
Area: 1 acre
Annual throughput 20,000 tpy

AF and ARM stockpiles
Area: 0.25 acre
Annual throughput 8,000 tpy

II.A.4 Stationary Crusher
Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction
of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000
acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)

II.A.5 Raw Material Transfer
Crushed material is transported to raw material storage by belt B8. The raw material transfers
at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor
transfer point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total
filter area & water sprays. (pre-1983)

II.A.6 Material Handling
Conveyor belt systems, secondary feeders and screens, stacker system

II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit specific requirements

II.A.8 Belt Conveyor Transfer Baghouse
Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area
and 1,800 acfm total air flow, controls emissions from the conveyor belt that transfers the
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stacked material to the raw material silos.

II.A.9 Raw Material Silos
Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The
four silos are equipped with one common Fuller, plenum pulse baghouse (315.BF1) - 1,689 ft2
filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage).

II.A.10 Fifth Component Silo
Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse
(315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw
mill feed. This system includes vibrating feeders, a conveyor system, and surge bin.
Emissions are controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3,
316.BF4, 316.BF5) - each is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1
A/C ratio.

II.A.12 Cross-Belt Analyzer
Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6)

II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom
of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw
materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38).
The following equipment is installed: low-NOx burner, selective non-catalytic reduction
(SNCR) for NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued
mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric
monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct
for mercury adsorption capacity. The carbon injection system is not an emission point as it is
in an enclosed building.

II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

II.A.16 Two Kiln Feed Blending Silos
Raw material is blended in one of two blending silos prior to feeding the kiln. The blending
silos are controlled by one common Fuller, plenum pulse baghouse (411.BF1) - 1,351 ft2 filter
area; 7,160 acfm total air flow.

II.A.17 Blending Silo Elevators (2)
Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped
with a Fuller, pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow
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through stack E34.

II.A.18 Kiln Feed Alleviator
A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the
central material silo between the blending silos and the preheater. Raw feed is removed from
the system near the top of the preheater tower.

II.A.19 Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner.
The coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter
area; 1,700 acfm total air flow.

II.A.20 Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in
the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2):
19,500 acfm rated airflow with 3.75:1 A/C ratio

II.A.21 Clinker Cooler and Baghouse
Reconstructed grate type cooler used for cooling clinker from the kiln prior to transfer to
clinker storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) -
173,869 acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter
monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two
clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse
(419.BF8). The exhaust is routed to the clinker cooler stack.

II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions
generated when loading the east and west clinker silos and the out-of-spec silo are controlled
by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1):
1,800 acfm, that discharges into the clinker tunnel.

II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm, that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2)
Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers.
Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses
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(511.HP1 and new 511.HP2): 1,800 acfm each.

II.A.27 Gypsum Silo
Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2
total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust
during loading.

II.A.28 Clinker Tunnel Exitway
The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse
(511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel all discharge in the clinker tunnel.
Emissions are vented through the tunnel exitway.

II.A.29 Limestone Silo
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust
during loading. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement product. Dust
generated during milling is captured by a BHA, pulse jet baghouse (514.BF2) - 6,080 ft2 filter
area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding
stack).

II.A.31 Finish Mill (Ball Mill) Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized
cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA, pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow
controlling particulates from stack G55 (finish mill stack).

II.A.32
NEW
Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The
stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4)
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1,
525.BF1 thru 3)

II.A.33 Finish Cement Storage Silos
There are six storage and two interstice silos where the finished cement product is stored. A
single common Fuller, plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm
total air flow through stack H7 is located on top of the silos and is used to control emissions
during loading and unloading operations.

II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail
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shipping. This baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out
The cement loadout system located on the South side of the silos (truck load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF2) during unloading from the silos for truck
shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement
conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed
space inside the silos.

II.A.36
NEW
Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

II.A.37 MHO: Materials Handling Operation
Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1
& 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4;
512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.

II.A.38 LBS: Limestone Bypass System
Additional limestone is added to the clinker and gypsum by the limestone bypass system
(LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays
at the screen and material handling drop points.

II.A.39 GEN: Emergency Generators
One diesel-fired emergency generator (new)
Rating: 762 hp
(Kiln, Tier 3, permitted 2022)

Two natural gas-fired emergency generators
Rating: 304 hp
(Main office and control room, permitted in 2023)

One diesel-fired emergency generator
Rating: 560 hp
(Shipping, permitted 2023).

II.A.40 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14 inch knife gate, 8 inch knife gate, 8 inch air
slides, surge bin), and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm)
on the fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

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II.A.41
NEW
Miscellaneous Storage Tanks
One diesel storage tank (<2,000 gallons)
One gasoline storage tank (500 gallons)
Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Requirements on the Cement Plant:
II.B.1.a
NEW
The following limits shall not be exceeded:

A. Clinker production - 1,155,000 tons per rolling 12-month period

B. Used oil consumption - 85,724 gallons per rolling 12-month period

C. Limestone bypass material processed - 216,260 tons per rolling 12-month period.
[R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 25th day of each month using data from the previous 12 months.
Records shall be kept for all periods when the plant is in operation. Consumption and
production shall be calculated through use of the plant's acquisition system. [R307-401-8]

II.B.1.b
NEW
Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations:

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

SO2: 0.4 lbs per ton of clinker (3-hr average)

CO: 3,395 tons per rolling 12-month period, and 6,600 lbs/hr

NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average, and 1,233 tons per rolling
12-month period

Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is
400oF or less.

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Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)

THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)

CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)

PM: 0.02 lbs filterable PM per ton of clinker. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL,
R307-401-8]

II.B.1.c
NEW
A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR
60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust
emissions control plan shall be monitored to demonstrate that appropriate control measures are
being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of
the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall
be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in
the plan and that the source is operating in accordance with the submitted plan. For petitions
to approve alternative control measures, the permittee shall keep a copy of the submitted
petition and any approvals received. [40 CFR 60 Subpart Y]

II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area
source of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2). [40 CFR
63 Subpart LLL]

II.B.1.e
NEW
Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b
and II.B.1.d shall be performed as specified below:

A. Kiln/Raw Mill Stack
Pollutant Test Status Test Frequency
PM * #

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

B. Clinker Cooler (F31)
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Pollutant Test Status Test Frequency
PM + #

C. Testing Status (To be applied above)
* The initial testing has already been performed.

** The SO2 initial performance test was conducted on August 26, 2013.

*** The initial compliance test shall be conducted within the first 30 operating days of
operation in which the affected source operates using a CEMS.

# Test once every year. If performance testing would be required less than 15 operating days
after the Kiln has completed Startup after being down for more than 24 hours, then
performance testing may be deferred up to 15 operating days after completion of the Startup.
The Director may require testing at any time.

## Test at least once every two years. The Director may require testing at any time.

+ Initial testing is required within 180 days of startup of the reconstructed equipment

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must record the PM
CPMS output data for all periods when the process is operating, and use all the PM CPMS
data for calculations when the PM CPMS is not out-of-control. The owner/operator must
demonstrate continuous compliance by using all quality-assured hourly average data collected
by the PM CPMS for all operating hours to calculate the arithmetic average operating
parameter in units of the operating limit on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

+++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.e.1
NEW
Notification
The Director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The notification requirements for performance tests subject to 40
CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-165]

II.B.1.e.2
NEW
Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational
Safety and Health Administration (OSHA)- or Mine Safety and Health Administration
(MSHA)-approved access shall be provided to the test location. [R307-165]

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II.B.1.e.4
NEW
PM
40 CFR 60, Appendix A, Method 5 or 5I or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three (3) runs with
each run at least 120 minutes in duration and each run collecting a sample of 60 dry standard
cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.3
NEW
Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2. [R307-165]

II.B.1.e.5
NEW
Carbon Monoxide (CO)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.6
NEW
Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.7
NEW
Sulfur Dioxide (SO2)
40 CFR 60, Method 6 or 6C of Appendix A-4 or other EPA-approved method as acceptable to
the Director. [R307-165]

II.B.1.e.8
NEW
Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]

II.B.1.e.9
NEW
Total Hydrocarbons (THC)
Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL]

II.B.1.e.10
NEW
Mercury (Hg)
Continuous Emission or integrated sorbent trap monitoring (See Condition II.B.3.a). [40 CFR
63 Subpart LLL]

II.B.1.e.11
NEW
HCl
Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other
EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]

II.B.1.e.12
NEW
Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.13
NEW
Calculations
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director, to give the results in the specified units of the
emission limitation. [R307-165]

II.B.1.e.14
NEW
Existing Source Operation
For an existing source/emission point, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three years.
[R307-165]

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II.B.1.e.15
NEW
New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the maximum production rate listed in this AO. If the maximum AO
allowable production rate has not been achieved at the time of the test, the following
procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This new
allowable maximum production rate shall remain in effect until successfully tested at a higher
rate.

3) The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate (110%
of the new rate) will then be allowed if the test is successful. This process may be repeated
until the maximum AO production rate is achieved. [R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL.
[40 CFR 63 Subpart LLL]

II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times
of Dust Shuttle System operation to assist in the capture of Mercury emission. [R307-401-8]

II.B.1.h
NEW
Visible emissions from the following emission points shall not exceed the following values:

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

L. All baghouses - 10% opacity
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M. Fugitive dust - 20% opacity

N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y,
R307-401-8]

II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer
point is not required to conduct Method 22 visible emissions monitoring under this paragraph.
The enclosures for these transfer points must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

If any partially enclosed or unenclosed conveying system transfer point is located in a
building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to
40 CFR 60, according to the following:

(i) The owner/operator must conduct a monthly ten-minute visible emissions test of each
affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The
performance test must be conducted while the affected source is in operation.

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator may decrease the frequency of performance testing from monthly
to semi-annually for that affected source. If visible emissions are observed during any
semi-annual test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iii) If no visible emissions are observed during the semi-annual test for any affected source,
the owner/operator may decrease the frequency of performance testing from semi- annually to
annually for that affected source. If visible emissions are observed during any annual
performance test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iv) If visible emissions are observed during any Method 22 performance test, of Appendix
A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations,
recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60.
The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour
of any observation of visible emissions.

(v) If visible emissions from a building are monitored, the requirements of paragraphs (i)
through (iv) of this Condition apply to the monitoring of the building, and the owner/operator
must also test visible emissions from each side, roof, and vent of the building for at least ten
minutes. [R307-401]

II.B.1.j
NEW
Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed
0.005 gr/dscf:

520.BF1
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520.BF2
520.BF3
520.BF4
521.BF2
521.BF1
524.BF1
524.BF2
524.BF4
524.BF3
525.BF1
525.BF2
525.BF3
511.HP2
NRL_UPR
NRL_LWR. [R307-401-8]

II.B.1.j.1
NEW
To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration
through at least three (3) annual tests that the PM limits are not being exceeded, the
owner/operator may request approval from the Director to conduct stack testing less
frequently than annually. [R307-401-8]

II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive
dusts as dry conditions warrant or as determined necessary by the Director to maintain opacity
limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated to control fugitive dust. The application of
water or chemical treatment shall be used. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a damp/moist condition unless it is below freezing.
If chemical treatment is to be used, the plan must be approved by the Director. Records of
water and/or chemical treatment shall be kept for all periods when the plant is in operation.
The records shall include the following items: Instances of water and/or chemical application
to unpaved areas shall be recorded and maintained by the owner/operator. The ambient
temperature shall be recorded any time water should be applied but cannot due to freezing
conditions. [R307-401-8]

II.B.2.c
NEW
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

The sprays shall operate whenever dry conditions warrant meeting the required opacity
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limitations or as determined necessary by the Director. Water sprays shall not be required
during periods of freezing temperatures. [R307-401-8]

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation
of fugitive dusts as dry conditions warrant or as determined necessary by the Director.
[R307-401-8]

II.B.2.e
NEW
The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5
PM. [R307-401-8]

II.B.3 Continuous Emission Monitoring Requirements:
II.B.3.a
NEW
The owner/operator shall install, calibrate, maintain and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler.

A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the
missing data substitution procedures used by the UDAQ or the missing data substitution
procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate by the UDAQ.

B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period
including during each startup, shutdown, or malfunction.

C. The monitoring system shall comply with all applicable sections of R307-170, UAC; and
40 CFR 60, Appendix B.

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be
installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the
kiln/raw mill stack.

F. The owner/operator shall record the output of the system: including the quantity of NOx,
CO, O2 THC, Hg, HCl, and CO2 emissions at the kiln stack.

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source shall
continuously operate all required continuous monitoring devices and shall meet minimum
frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker
cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except
during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments,
the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a
PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the
results of the performance test demonstrating compliance with the filterable PM limit and
using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust
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the SSOL developed in accordance with the results of the most recent PM performance test
demonstrating compliance with the PM emission limit. The owner/operator shall use the PM
CPMS to demonstrate continuous compliance with the SSOL in accordance with the
requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

II.B.4 Fuel Limitations:
II.B.4.a
NEW
The owner/operator shall use only the following fuels in the kiln and pre-calciner:

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.

If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b
NEW
Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the
Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the
results of suitable tests giving data similar to a Proximate and Ultimate analysis of the
proposed coal additive. [R307-401-8]

II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal
additive. Approval is not required to change from one previously-approved coal additive to
another previously-approved coal additive. [R307-401-8]

II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily
heat input of the kiln and precalciner. The owner/operator may increase the average quantity
of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon
approval by the Director in accordance with the approval process described in Condition
II.B.4.b. [R307-401-8]

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II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel burning or process
installation not covered by New Source Performance Standards for sulfur emissions or
covered elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross
Btu heat input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input
for any oil except used oil. The sulfur content shall comply with all applicable sections of
UAC R307-203. [R307-203, R307-401-8]

II.B.4.c.1
NEW
Certification of fuels shall be either by the owner/operator's own testing or test reports from
the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be
available onsite. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials, UAC R307-203-1 (4)

A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be
used.

B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be
used.

C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85 are to be used. [R307-203]

II.B.4.d
NEW
The concentration/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight
3) Cadmium 2 ppm by weight
4) Chromium. 10 ppm by weight
5) Lead 100 ppm by weight
6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be
tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the burn tank and burned. [R307-401-8]

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II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned
in the rotary kiln:

A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than
five minutes in any 60-minute period

B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes
in any 60-minute period. [R307-401-8]

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the
Director. The calibration procedure and frequency shall be according to manufacturer's
specifications. Use of factory-calibrated thermocouples for temperature measurement is
approved. However, any other method of temperature measurement must be approved by the
Director prior to use. The monitoring equipment for both temperature and oxygen content
shall be located such that an inspector can at any time safely read the output. [R307-401-8]

II.B.5
NEW
Emergency Engine Requirements
II.B.5.a
NEW
The owner/operator shall only operate the emergency engines for testing and maintenance
purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency
operation. [R307-401-8]

II.B.5.b
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each emergency engine. [R307-401-8]

II.B.5.b.1
NEW
The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.5.b.2
NEW
To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN103030035-24 dated November 27, 2024
Is Derived From Source Submitted NOI dated November 30, 2022
Incorporates Additional Information Received dated April 26, 2023
Incorporates Additional Information Received dated September 26, 2023
Incorporates Additional Information Received dated July 23, 2024
Incorporates Additional Information Received dated October 25, 2024
Incorporates Additional Information Received dated November 25, 2024

REVIEWER COMMENTS

1. Comment regarding applicability of federal requirements:
New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable
by the best demonstrated technology as specified in the applicable provisions. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.

40 CFR 60, Subpart A (General Provisions)
All affected facilities subject to a source-specific NSPS are subject to the general provisions of
NSPS, Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires
initial notification, performance testing, recordkeeping, and monitoring, provides reference methods,
and mandates general control device requirements for all other subparts.

40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of
performance for affected facilities in Portland Cement Plants which have been constructed or
modified after August 17, 1971.

40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart
F: Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and
unloading systems. The Leamington coal mill is an in-line coal mill and considered an integral part
of the Leamington kiln. In-line coal mills are not subject to NSPS Subpart Y. Therefore, the coal mill
is addressed under NSPS Subpart F as part of the kiln system. The coal silos and conveying system
are subject to NSPS Subpart Y.

Ash Grove's proposed changes to the kiln system must be evaluated as to whether they trigger new
NSPS Subpart F obligations based on whether the proposed project is either a modification or a
reconstruction, as those terms are defined in NSPS Subpart A.

Ash Grove's proposed changes to the kiln system do not meet the definition of a reconstruction, nor
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 40

do they meet the definition of a modification for NOx. However, the changes meet the definition of a
modification for PM and SO2. Therefore, Ash Grove will comply with all relevant emission
standards; testing requirements; monitoring, recordkeeping, and reporting obligations that apply to
the Leamington kiln system as an existing source under NSPS Subpart F. Under NSPS Subpart A
and F, the clinker cooler is considered a reconstructed unit. Thus new limits will apply to this unit.
[Last updated January 14, 2025]

2. Comment regarding applicability of federal requirements cont.:
NSPS Subpart Y - Standards of Performance for Coal Preparation and Processing Plants
This subpart provides standards of performance for affected facilities in coal preparation and
processing plants that process more than 200 tons of coal per day.

The Leamington plant's coal silo and coal conveying system are existing affected facilities under
NSPS Subpart Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses
controlling affected facilities subject to match the limit in NSPS Subpart Y from 0.016 gr/dscf to
0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade Project. Since there are no proposed
modifications or reconstruction to the coal silo and coal conveying system, nothing about the
proposed upgrade project affects the existing applicability of NSPS Subpart Y.

NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
This subpart provides standards of performance for affected facilities located at fixed or portable
nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August
31, 1983, with additional requirements applicable to sources constructed on or after April 22, 2008.

As the crushing and screening system is controlled by baghouses and an increase in PM10 actual
emissions on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS.
Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the
Leamington Plant Upgrade Project.

Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1),
60.676(f), and 60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO
monitoring and recordkeeping requirements.

[Last updated January 14, 2025]

3. Comment regarding applicability of federal requirements cont.:
National Emission Standards for Hazardous Pollutants (NESHAPs)
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or
greater than 10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as
specified by each subpart. NESHAP apply to sources in specifically regulated industrial source
classifications (CAA Section 112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities
not regulated as a specific industrial source type. The Ash Grove Leamington Plant is a major source
of HAPs and thus is subject to certain NESHAP standards.

Subpart A - General Provisions
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All affected sources are subject to the general provisions of Subpart A unless otherwise specified by
the source-specific NESHAP. Subpart A generally requires initial notification and performance
testing, recordkeeping, monitoring, provides reference methods, and mandates general control device
requirements for all other subparts as applicable.

Subpart LLL - Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry
This subpart establishes process/source specific emission limits for PM, VOC (expressed as total
hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and
gaseous HAP compounds by limiting PM and THC emissions because portions of such emissions
are USEPA-listed HAPs. Subpart LLL requires compliance with applicable emissions limits on and
after the initial startup of cement production. To further reduce emissions, Subpart LLL also
establishes operational requirements for the use of cement kiln dust (CKD), fly ash, fuel and control
equipment. Subpart LLL also specifies process/source specific emissions testing, monitoring,
recordkeeping, reporting, and compliance demonstration requirements. The compliance requirements
for the site are detailed in Approval Order Condition II.B.1.b. Ash Grove will continue to comply
with the requirements of Subpart LLL to demonstrate compliance. This cement kiln will remain an
existing source with respect to the kiln emission standards in Subpart LLL as this project does not
trigger the definition of a new source in Subpart LLL. New source standards apply only to affected
sources that were constructed or reconstructed after May 6, 2009.
[Last updated December 20, 2024]

4. Comment regarding PSD applicability analysis:
Ash Grove is proposing to increase the throughput of limestone from the quarry to supply the New
Finish Mill to increase the amount of low-carbon cement from the Leamington Plant. Additionally,
along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
modified, and the clinker cooler will be reconstructed. These changes are anticipated to result in an
increase in clinker production. Emission calculations for this project have been completed assuming
an increase in clinker production capacity while utilizing current fuel types. This will result in an
increase in the throughput of fuel.

The Leamington Plant is considered an existing major source under PSD based on potential
emissions of PM10, PM2.5, NOx, CO, SO2, and CO2e. If a major source undergoes a physical or
operational change, the facility must determine whether the project will be considered a major
modification. Per 40 CFR 52.21(b)(2)(i), in order to be a major modification, the project must result
in a significant emissions increase, and a significant net emissions increase.

As defined at 40 CFR 52.21(b)(40): Significant emissions increase means, for a regulated NSR
pollutant, an increase in emissions that is significant for that pollutant. Significant is further defined
to mean, in reference to a net emissions increase or the potential of a source to emit any of the
following pollutants, a rate of emissions that would equal or exceed the values outlined in 40 CFR
52.21(b)(23). If the increase in emissions from the project are not significant, a major modification
has not occurred.

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 42

increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

For all pollutants, the project emissions increase was calculated as the difference between the
projected actual emissions (PAE) after the proposed project and the actual emissions prior to the
project (baseline actual emissions or BAE).

Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
". . . projected actual emissions means the maximum annual rate, in tons per year, at which an
existing emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years
(12-month period) following the date the unit resumes regular operation after the project, or in any
one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit of that regulated NSR pollutant and full utilization of the unit would
result in a significant emissions increase or a significant net emissions increase at the major
stationary source." [Last updated January 14, 2025]

5. Comment regarding PSD applicability analysis cont.:
Ash Grove estimates that the projected actual production capacity following the project will be
1,155,000 tons of clinker per year and 1,341,266 tons of limestone per year. These capacities were
used to calculate projected actual emissions from the project using representative emission factors.
Additionally, to estimate emissions from material transfer baghouses, the actual flow rates and actual
projected hours were used as a basis for projected actual emissions.

Project Emission Calculations

Project emission increases from the kiln and coal mill systems are calculated for all criteria
pollutants based on emission factors that are derived from stack testing, CEMS data, or emission
factors (i.e., VOCs and Lead), and the associated projected incremental clinker increase.

NOx emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain
hourly capacity to emit and annual potential to emit at current levels. The kiln's NOx emissions rate
will not change as a result of the physical modifications proposed by the project.

Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission
factor and multiplied by the incremental increase in clinker production. The emission factor was
selected based on the average of the 24-month consecutive month emissions for 2020 and 2021. The
CO emissions will increase.

The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing
conducted at the plant. The SO2 emissions will increase.

VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production. VOC emissions will increase.

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 43

can be found in the original NOI and subsequent addendums submitted to UDAQ.

As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from
the proposed project, each increase of emissions from both existing and new sources shall be
summed together and compared to the PSD permitting thresholds. The increase of emissions is the
"positive" difference between the projected actual emissions and baseline actual emissions (projected
minus baseline).

New Emissions Sources

The actual to projected actuals calculation is not available to new emission units. For new emission
units, the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected
emissions are based on the new sources' potentials to emit. (40 CFR § 52.21(a)(2)(iv)(f)).

The new equipment proposed includes the New Finish Mill, a new rail and truck loading/loadout,
one (1) new clinker reclaim loading hopper with a dust collector and one (1) existing clinker reclaim
hopper with a dust collector, a new Clinker Cooler to replace the existing one, and a new kiln feed
alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions:

The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;

The finish mill heater was calculated based on its maximum firing capacity and flow rates; and

The fugitive emissions were calculated based on the projected annual throughput of the New Finish
Mill, the rail loadout, and clinker production. [Last updated January 14, 2025]

6. Comment regarding PSD applicability analysis cont.:
Existing Emission Sources

For the existing sources, the projected actual emissions are the maximum annual rates in tons per
year projected to occur during the next five (5) to ten (10) years if the existing sources' design
capacities increase. Ash Grove Leamington projected the actual emissions for the next five (5) years
based on the new kiln system producing an annual average of 3,250 tons of clinker per day.

Baseline actual emissions (BAE) are defined at 40 CFR 52.21(b)(48)(ii) as:

". . . baseline actual emissions means the average rate, in tons per year, at which the emissions unit
actually emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the 10-year period immediately preceding either the date the owner or operator
begins actual construction of the project, or the date a complete permit application is received by the
Administrator."

Ash Grove has selected to use the years 2020 and 2021 for each pollutant as the representative
baseline years.

In its NOI, Ash Grove calculated the emission increase from the project as being divided into two
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 44

phases. Phased construction projects are discussed in two sections of the federal PSD regulations -
40 CFR 52.21(j)(4) and 40 CFr 52.21(r)(2). UDAQ is not processing this project as a phased
construction project, nor did Ash Grove request such a determination. Therefore, Ash Grove
provided a summary table outlining the final change in emissions from this project:

Projected Actual Increase Compared to PSD threshold (tons per year)
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2e
BAE 76.64 39.64 1,187 6.87 3,315 55.47 641,385
PAE 203.15 113.47 1,226 45.87 3,414 72.07 1,067,984

Change in Emissions 126.51 73.83 39.00 39.00 99.00 16.59 426,598

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes

If the emissions increase is greater than the PSD significance threshold for a particular pollutant, Ash
Grove has the option of conducting a PSD review or continuing through the rest of the steps to
determine if it can "net" out of a PSD review. If the project increase is less than the PSD significant
threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant.

The change in emissions from the project exceeds the significant emission threshold for three
pollutants: PM10, PM2.5 and CO2e. Ash Grove elected to attempt to net out of a PSD major
modification for the remainder of the criteria pollutants.

Netting

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant
Upgrade Project and ends on the date the upgrade begins operation. Only PM10, PM2.5, CO2e are in
excess of SERs and therefore considered in the netting analysis.

Ash Grove estimated that the commencement of construction will be in December 2024. Therefore,
the contemporaneous period for this project is December 2019 through a projected date the project
upgrade begins operation. [Last updated January 21, 2025]

7. Comment regarding PSD applicability analysis cont.:
Contemporaneous Decreases

Ash Grove replaced an existing kiln emergency drive engine with a USEPA Tier 4 diesel engine in
2022. Concurrently, Ash Grove requested an increase in the capacity of 1L Cement. Additionally,
Ash Grove submitted a minor modification NOI air permit application on June 12, 2023, which
proposes replacing the shipping generator during the contemporaneous period. The kiln emergency
drive engine and shipping generator are both higher EPA tier ratings therefore result in decreases for
PM10 and PM2.5. These changes were approved in AO DAQE-AN103030033-24 issued March 21,
2024.

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Page 45

Contemporaneous Increases

As stated above, the existing kiln emergency drive engine and shipping generator were permitted and
replaced in 2024. This resulted in an increase in emissions of CO2e.

The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout
in an effort to improve truck traffic at the loadout. The modification to add these dust collectors to
the loadout was included in DAQE-AN103030029-19. The baghouses are three (3) levels up in the
silos' enclosed space (approximately 40 feet). Both dust collectors vent directly into the interior of
the silo structure and are not vented into the atmosphere. Ash Grove requests to remove these
baghouses from its existing permitted emissions inventory. Therefore, these emissions have been
documented in the netting analysis as zero emissions.

Also included in DAQE-AN103030033-24 were two new natural gas-fired emergency generators
and increases in stockpiles, material handling and road emissions.

Could Have Been Accommodated Emissions

In calculating project emissions increase, USEPA allows the exclusion of existing
production/emissions rates that could have been accommodated during the baseline period. These
"could have been accommodated" emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as
follows:

". . . Shall exclude, in calculating any increase in emissions that results from the particular project,
that portion of the unit's emissions following the project that an existing unit could have
accommodated during the consecutive 24-month period used to establish the baseline actual
emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project,
including any increased utilization due to product demand growth;"

Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the
exclusion of existing production and emissions rates that could have been accommodated during the
baseline period, it has elected not to use this exclusion at this time. Therefore, calculation of the
"could have been" accommodated emissions have not been included in this application's
applicability analysis.

The increase from the project is added to the contemporaneous decreases and contemporaneous
increases. The resulting calculation is then compared to the PSD significance threshold to determine
if a significant net emissions increase has occurred. [Last updated January 14, 2025]

8. Comment regarding PSD applicability analysis cont.:
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2 e
Contemporaneous Inc. 1.61 0.45 0.41 0 0.27 0.07 51.74

Contemporaneous Dec. -1.54 -3.97 -0.48 -0.02 -0.27 -0.09 0

Change in Emissions 125.02 69.21 38.93 38.98 99.00 16.58 426,650

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 46

The results of the netting analysis conclude that both a significant emissions increase and a
significant net emissions increase in both particulates (PM10 and PM2.5) and CO2e will occur from
this project. Thus, the project must be reviewed as a PSD major modification. [Last updated January
14, 2025]

9. Comment regarding emission calculations:
This engineering review includes updated potential emission totals for both criteria and HAP
emissions. The potential-to-emit (PTE) values were calculated using updated values for clinker
produced and raw material inputs. BACT emission factors and limitations were used where
appropriate. Certain emission totals (NOx, SO2 and CO) were set based on avoiding a significant
increase in emissions. Specifically, the projected actual increase was set at just under the baseline
actual emissions + the significance level. As these emissions are monitored by CEM, UDAQ agrees
with this approach. Please see the netting analysis for further details on calculation of projected
actual increase. The NOx hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project.

CO2e emissions were calculated using the GHG emission factor calculated from 40 CFR Part 98
Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in Subpart A Table
A-1.

To calculate the PTE tons per year, the maximum hours (i.e., 8760) per year and the source's
emissions rates were multiplied with the throughputs. The potential throughputs have been updated
at UDAQ's request so that PAE is equal to PTE and represents the equipment's maximum design
potential.

Additional emission calculations based on source testing and monitoring, and EPA's compilation of
air emission factors AP-42. [Last updated January 14, 2025]

10. Comment regarding requirements for PSD review:
In addition to the permitting requirements of R307-401-5 through R307-401-8, there are additional
requirements under PSD that must be addressed:

1. Calculation of ambient air increments (40 CFR 52.12(c)), ambient air ceilings ((40 CFR 52.12(d)),
source impact analysis (40 CFR 52.12(k)), air quality models (40 CFR 52.12(l)) - these items are
addressed in the modeling memo DAQE-MN103030032-24.

2. Stack heights (40 CFR 52.12(h)) - Ash Grove's stack heights have been reviewed with respect to
good engineering practice and operate in a vertical unrestricted manner.

3. Control technology review (40 CFR 52.12(j)) - this is addressed in the BACT analysis section of
this review document.

4. Air quality analysis: preapplication analysis (40 CFR 52.12(m)) - this is covered in the PSD
applicability and netting analysis sections of this review document, ambient monitoring and
background data collection is also included in the modeling memo DAQE-MN103030032-24.

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 47

grain loading limit included in II.B.1.j.1 represents the required post-construction monitoring.
6. Source information (40 CFR 52.12(n)) - this is addressed under the requirements of R307-401-5
and was submitted by Ash Grove as part of the NOI package.

7. Additional impact analysis (40 CFR 52.12(o)) - these requirements cover soils, vegetation, growth
and visibility concerns. They are discussed in the modeling memo DAQE-MN103030032-24.

8. Federal land manager review (40 CFR 52.12(p)) - UDAQ provided initial notification to all
federal land managers upon receipt of the original NOI package. The draft permit and engineering
review will also be provided to the federal land managers 60-days prior to initiation of public
comment for their further review.

9. Public participation (40 CFR 52.12(q)) - this project will have a 30-day public comment period.

10. Source obligation (40 CFR 52.12(r)) - this requirement discusses source compliance with other
parts of the CAA, which is addressed within UDAQ's permitting rules in R307.
[Last updated January 14, 2025]

11. Comment regarding changes in equipment list:
The equipment list is being updated for clarity as well as adding new pieces of equipment. The
following changes are taking place:

The naming scheme is being updated to remove the numerical code from the unit designation. This
code generally referred to the associated control device and not to the emitting unit itself. This can
cause confusion especially when the same code was applied to multiple pieces of equipment.
Instead, the control devices (typically baghouse dust collectors) will be identified in the description
along with the appropriate numerical code.

Specific changes are as follows:

1. The kiln description has been updated

2. Clinker Cooler description has been updated to include a larger pulse jet baghouse.

3. The clinker storage silos, east and west clinker belts, clinker belt transfer and clinker tunnel have
been consolidated to avoid confusion

4. The north and south cement loadout exhausts now vent internally into the cement storage silos

5. The dust shuttle system has been consolidated into one line item, most identifiers removed from
subsystem descriptions as only two baghouses serve as exhaust points.

6. A new finish mill with heater has been added. Included in the description are the thirteen total
baghouses for dust control (1 main stack, 2 transfer points, 10 nuisance dust filters)

7. A new clinker reclaim hopper has been added. Both reclaim hoppers are controlled by baghouses
with updated identifiers

8. A new rail and truck loading/unloading system with two baghouses has been added.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 48

[Last updated December 20, 2024]

12. Comment regarding changes in conditions:
As a result of this project, several conditions will be added or changed. This includes one new
general condition (I.8). Changes to the equipment list (section II.A) will be addressed in a separate
reviewer comment:

I.8 - Adding this general condition to cover the requirements of R307-401-18 Eighteen Month
Review. The status of construction/installation of the new equipment shall be reviewed after
18-months.

II.B.1.a - Clinker production increases to 1,155,000 tpy
Use of limestone bypass material increases to 215,260 tpy

II.B.1.b - The NOx limit on the kiln decreases to 1,223 tpy, CO emissions from the kiln decrease to
3,395 tpy,
Adding a new CO2e limit of 0.92 tons CO2e/ton of clinker produced
PM limit on the clinker cooler decreased to 0.02 lb PM (filterable)/ton of clinker
Rule reference updated to include 40 CFR 60 Subpart F, and R307-401-8

II.B.1.e - Initial testing on the clinker cooler is now required within 180 days of startup of the unit.
Monitoring of CO2 from the kiln will be by CEM.
Formatting changes on paragraph designated ++, improve clarity, include reference to CO2
monitoring, define CPMS

II.B.1.e.4 - Update to address general PM monitoring and reference R307-401-8

II.B.1.e.14 - New condition to address new or reconstructed emission units monitoring requirements,
applicable to the clinker cooler and new finish mill.

II.B.1.h - Adding references to Subpart OOO units (limestone processing) with updated opacity
limits.
Adding 20% opacity limit on coal transfer and storage
Adding property boundary opacity limit of 20%
Updating rule reference to include Subpart OOO

II.B.1.j - New condition to address outlet grain loading limits on new baghouses, One identical limit,
15 total new baghouses.

II.B.1.j.1 - Monitoring on new baghouses as per II.B.1.e.4, added an allowance to test less frequently
than annually with three successful tests.

II.B.3.a - Updating formatting to add clarity and include reference to CO2 CEM

II.B.5 - New conditions on emergency engines, diesel fuel sulfur limits, hour of operation
restrictions, non resettable hour meter

[Last updated December 20, 2024]
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 49

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 51

TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 52

DAQE-MN103030032-24

M E M O R A N D U M

TO: John Jenks, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler
Dave Prey, Air Quality Modeler

DATE: December 12, 2024

SUBJECT: Modeling Analysis Review for the Ash Grove Cement Company – Leamington Plant,
located in Millard County, Utah
___________________________________________________________________________________
This is a Major Modification to a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Ash Grove Cement Company (Applicant) has submitted a Notice of Intent (NOI) air permit
application for a project referred to as the Leamington Upgrade Project (LUP). The proposed
upgrade project includes the construction and installation of new pollution control equipment, new
emission sources, and modifications to existing emission sources. Emission increases associated
with the LUP constitute a major modification to a Prevention of Significant Deterioration (PSD)
source subject to PSD permitting regulations. PSD regulations require the Applicant to include and
air quality impact analysis (AQIA) of the proposed projects impact on the EPA national ambient air
quality standards (NAAQS) and air quality related values (AQRV) as part of a complete NOI.

This report prepared by the New Source Review (NSR) modeling staff contains a review of the
Applicant’s Air Quality Impact Analysis (AQIA) including the methodology, data sources,
assumptions, and modeling results for comparison with State and Federal air quality standards. The
AQIA was reviewed and referenced in this report include the:
● Notice of Intent – Ash Grove Cement Leamington Plant PSD Notice of Intent Air Permit
Application, dated November 30, 2022.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

0 0
Jason Krebs

DP
DAQE-MN103030032-24
Page 2

II. APPLICABLE RULES AND ANALYSES

A Utah Air Quality Rules

The UDAQ has determined that the Applicant’s NOI is subject to the following rules for conducting an
AQIA:

R307-401 Permits: New and Modified Sources
R307-405 Permits: Major Sources Located in Attainment or Unclassified Area (PSD)
R307-406-2 Visibility – Source Review
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutant Impacts in Attainment Areas

B. Applicability

The proposed increases in emissions of PM10 and PM2.5 exceed the emission thresholds outlined in R307-
406-5 and R307-410-4. Therefore, an AQIA consistent with the requirements of R307-405-6, R307-406-
2, and R307-410-3 was submitted as part of the Applicant’s NOI. R307-410-3 establishes the U. S.
Environmental Protection Agency (US EPA) – Guideline on Air Quality Models as a formal basis for
defining the scope of the analysis, as well as the model’s construction. The results of the AQIA are
required to demonstrate the proposed project’s impact on state and federal air quality standards,
acceptable levels of impact, and action triggering thresholds referenced or listed in R307-401-6(2), R307-
401-6(3), R307-403-3(1), R307-403-5(1)(a), R307-405-4(1), R307-405-6. Annual emissions for criteria
pollutants requiring an AQIA are listed in Table 1.

Table 1: Ash Grove Leamington Proposed Net Emissions Increase

Criteria
Pollutants
Net Emission
Increase (TPY)
AQIA Trigger
Level (TPY) AQIA Required?
PM10 126.6 15 Yes
PM2.5 70.3 10 Yes

C. Required Analyses

R307-405 requires the Applicant to perform a pre-construction modeling analysis for all pollutants
emitted in a significant quantity. The purpose of the analysis is to determine if the extent of the source’s
impact is significant enough to warrant an on-site measurement of the ambient background concentration
levels. This data is included in the NAAQS analysis to represent the quality of the air prior to the
construction of the proposed project. The Applicant included a pre-construction modeling analysis for
PM10 and PM2.5 as part of the NOI. The pre-construction modeling analysis was also used to determine if
the proposed emissions would result in a significant impact to the environment, thereby triggering the
requirement for a cumulative analysis of the proposed project and other nearby existing sources.

R307-401-8 requires the Division to determine that the proposed project will comply with the NAAQS
prior to the issuance of an Approval Order (AO). R307-405(7) requires the Applicant to perform a
DAQE-MN103030032-24
Page 3
NAAQS analysis for all pollutants emitted in a significant quantity. The analysis is to include all
emissions at the proposed site under normal operating conditions using maximum anticipated short-term
release and annual release rates. Consistent with UDAQ policy, a cumulative analysis to include the
ambient background concentration and any contribution from other nearby sources is not required if the
proposed project’s impact does not exceed the PSD Class II Significant Impact Level (SIL).

R307-401-8 also requires the Division to determine that the proposed project will comply with PSD
increments prior to the issuance of an AO. Under R307-405(6), the Applicant is required to perform a
PSD Class I and II increment consumption analysis for all pollutants emitted in significant quantities.
The purpose of this analysis is to quantify any degradation in air quality since the major source baseline
date. The analysis is to include all increment consuming emissions at the proposed site under normal
operating conditions using maximum anticipated short-term and annual release rates. A cumulative
analysis to include contributions associated with growth and other increment consuming sources is not
required if the proposed project’s impact does not exceed the PSD Class I or II SIL.

R307-410-5 requires the Applicant to perform a HAPs analysis for any pollutant emitted above a
pollutant specific emission threshold value. This analysis is to include all emissions of the pollutants
resulting from the proposed modification under normal operating conditions using maximum anticipated
one-hour release rates. The Applicant did not trigger modeling for HAPs.

R307-406-2 requires the Applicant to perform a plume blight analysis. A plume blight analysis is required
to determine if plumes emanating from the proposed project would be visible inside any Class I area
within 50 kilometers of the source. The plume blight analysis is to include all emissions of NO2, SO4, and
PM10.

Under R307-405-16, an AQRV analysis is performed which evaluates regional haze and acid deposition
impacts at each of the Class I areas within 300 kilometers of the source. A regional haze analysis is
required to determine if the plumes would reduce the visual range of an observer inside the Class I area.
The regional haze analysis is to include all emissions of SO2, NOX and PM10. The deposition analysis
examines impacts from sulfur and nitrogen compounds at the Class I areas, and is based on all emissions
of SO2 and NOX. The Federal Land Managers use the Q/D approach to determine whether a PSD project
should provide detailed AQRV impact analyses, where: Q/D= [ H2SO4 + SO2 + NOx + PM10 emissions
(tpy)]/ distance (km). If Q/D is less than 10, no AQRV analysis is required.

R307-405 requires the Applicant to perform a soils and vegetation analysis. The analysis should quantify
the effects of pollutants on soils and vegetation near the highest impact location and in areas where
sensitive plant species may be impacted.

III. ON-SITE PRE-CONSTRUCTION MONITORING

A. Meteorological Data

Consistent with the US EPA - Meteorological Monitoring Guidance for Regulatory Modeling
Applications, one year of on-site data was collected using a 50-meter tower during the period October 1,
2021 through September 30, 2022. Parameters collected on-site included wind speed and direction,
temperature, delta-T, and solar radiation.

DAQE-MN103030032-24
Page 4

B. Ambient Pollutant Data

A preliminary analysis was conducted to determine the necessity for pre-construction ambient pollutant
monitoring. The results indicate that predicted concentrations of PM10 and PM2.5 exceed the monitoring
trigger level listing in the rule. A continuous PM10/PM2.5 monitor with filter based samplers was
installed near the northern edge of the Applicants property boundary, and collected particulate matter
from October 1, 2021 through September 30, 2022.

IV. MODEL SELECTION

The EPA-AERMOD dispersion modeling system is the preferred model specified in the US EPA –
Guideline on Air Quality Models to predict air pollutant concentrations in the near field (within 50
kilometers of the source). The US EPA - CALPUFF - Version 5.8 model is the preferred model to predict
concentrations in the far field (long range transport conditions beyond 50 kilometers from the source).

V. MODELING INPUTS AND ASSUMPTIONS

A. Technical Options

The regulatory default options were selected in AERMOD by the Applicant to quantify all concentrations.

B. Urban or Rural Area Designation

A review of the appropriate 7.5-minute quadrangles determined that the area should be classified as
“rural” for air modeling purposes.

C. Topography/Terrain

The Plant is at an elevation of 4,950 feet with nearby terrain features that have an effect on concentration
predictions.

a. Zone: 12
b. Location: UTM (NAD83): 397000 meters East, 4379850 meters North

D. Ambient Air

It was determined that the Plant boundary used in the AQIA meets the State’s definition of an ambient air
boundary.

E. Receptor and Terrain Elevations

The modeling domain has simple and complex terrain features in the near field. Therefore, receptor
points representing actual terrain elevations from the area were used in the analysis.

The far-field modeling domain consisted of a rectangular region covering all Class I areas within Utah,
and extending 50 kilometers beyond this area so that the model can account for re-circulation of the
plume.

DAQE-MN103030032-24
Page 5

F. Emission Rates and Release Parameters

The emission estimates and source parameters used in AERMOD for all proposed emission sources at the
site are presented in the NOI.

Speciated emission rates and source parameters used in the CALPUFF modeling are presented in Table 2.

Table 2: CALPUFF Emission Rates

Source
LCC Coordinates Modeled Emission Rates
Easting Northing SO2 SO4 NOX HNO3 NO3 SOA PMC SOIL EC
(m) (m) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr)
317.BF3 -1289410 -3738 52.81 5.03 307.58 0.00 0.00 5.03 2.60 2.90 0.11
419.BF1 -1289314 -3631 0.00 0.00 0.00 0.00 0.00 0.55 1.51 1.61 0.06
41B.BF2 -1289389 -3663 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.68 0.00
N1_FM2 -1289526 -3414 0.00 0.00 0.00 0.00 0.00 0.00 1.65 3.95 0.00
414.BF1N -1289407 -3683 0.00 0.00 0.00 0.00 0.00 0.00 0.10 0.25 0.00
2FM_HTR -1289528 -3415 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.08 0.00
514.BF1 -1289451 -3675 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.70 0.00
COMBO -1289424 -3668 0.00 0.00 0.00 0.00 0.00 0.00 1.37 5.72 0.00
FM2_CMB -1289454 -3439 0.00 0.00 0.00 0.00 0.00 0.00 0.50 1.21 0.00

Total Lb/hr 52.81 5.03 307.58 0.00 0.00 5.58 8.32 17.10 0.17
Hrs/Yr 8760 8760 8760 8760 8760 8760 8760 8760 8760
Ton/yr 231.3 22.0 1347.2 0.0 0.0 24.4 36.4 74.9 0.8

Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
317.BF3 POINT 4902.8 41.2 135.0 488 10.10 3.35
419.BF1 POINT 4891.2 18.3 60.0 388 6.36 2.90
41B.BF2 POINT 4895.2 68.6 224.9 294 17.83 0.74
N1_FM2 POINT 4832.0 49.7 163.0 363 40.08 1.40
414.BF1N POINT 4896.1 76.8 251.9 353 9.91 0.70
2FM_HTR POINT 4832.0 49.7 163.0 363 40.08 1.40
514.BF1 POINT 4889.5 39.6 130.0 294 11.86 0.91
COMBO POINT 4904.2 13.3 43.7 276 9.76 0.32
DAQE-MN103030032-24
Page 6
FM2_CMB POINT 4832.0 30.6 100.3 294 11.40 0.37

G. Building Downwash

The Applicant used the US EPA Building Profile Input Program (BPIP) to determine Good Engineering
Practice (GEP) stack heights and cross-sectional building dimensions for input into the model.

H. Ambient Background Concentrations

Millard County is in attainment for all criteria pollutants. The NAAQS analyses for PM2.5 and PM10 used
monitoring data collected on site during the pre-construction monitoring analysis. The background values
used in the NAAQS analysis are presented in Table 3.

Table 3: Background Concentrations

Pollutant Averaging
Period
Background
Concentration
(μg/m3)
PM10 24-hour 65.4
PM2.5 24-hour 10.2
Annual 4.2

I. Meteorological Data Processing

For the AERMOD model, on-site horizontal and vertical wind speed, direction, solar radiation and,
temperature data was combined with National Weather Service (NWS) upper air data collected at the Salt
Lake City International Airport (SLCIA) for the same period using the US EPA AERMET processing
system.

Meteorological data used for the CALPUFF modeling analysis consisted of 3 years (2018-2020) of data
developed by the Forest Service. The grid was 708 km (east-west) by 492 km (north-south) with a
resolution of 12 kilometers.

VI. RESULTS AND CONCLUSIONS

The Applicant performed a series of analyses to estimate the impact from the proposed project. Modeling
results and conclusions from the review of the analyses are outlined in detail below.

A. Pre-Construction Monitoring and Significant Impact Modeling

The Applicant performed a preliminary criteria pollutant analysis of the proposed modification. This
analysis indicated that increases in concentration levels of PM2.5 and PM10 were greater than the Class II
SIL, and therefore, a cumulative analysis for these pollutants was required.

DAQE-MN103030032-24
Page 7

B. NAAQS Analysis

The Applicant performed a modeling analysis to determine if the combined impact from the proposed
source, other industrial sources operating in the area, and ambient background would comply with the
NAAQS. The NAAQS analysis was reviewed by the Division and determined to be consistent with the
requirements of R307-410-3. Table 4 provides a comparison of the Applicant’s predicted air quality
concentrations and the NAAQS.

Table 4: Model Predicted NAAQS Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-hour 28.3 5 65.4 0 93.7 150 62.5%
PM2.5 24-hour 9.6 1.2 10.2 0 19.8 35 56.6%
Annual 4.4 0.3 4.2 0 8.6 9 95.6%
* Note: Only included other sources and background if source impact was above Class II SIL

C. PSD Class II Increments

The Applicant performed an analysis to determine if the impact from the proposed source would comply
with PSD Class II increments. The analysis was reviewed by the Division and determined to be
consistent with the requirements of R307-410-3. Table 5 provides a comparison of the predicted
concentrations and the PSD Class II increment.

Table 5: Model Predicted PSD Class II Increment Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Nearby
Sources*
Total Increment Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
PM10 Annual 8.1 1 0 8.1 25 32.4%
24-hour 28.3 5 0 28.3 30 94.3%
PM2.5 24-hour 6.1 1.2 0 6.1 9 67.8%
Annual 2.4 0.3 0 2.4 4 60.0%

D. Hazardous Air Pollutants

DAQE-MN103030032-24
Page 8
The Applicant performed an analysis to determine if HAP modeling is required. The analysis was
reviewed by the Division and determined to be consistent with the requirements of R307-410-3. The
analysis indicated that HAP modeling was not triggered by this modification, and therefore no HAP
modeling was performed.

E. PSD Class I Increment Consumption Analysis

The Applicant performed a CALPUFF analysis to determine if the impact from the proposed source along
with other increment consuming sources would comply with federal PSD Class I increments. The
analysis was reviewed by the Division and determined to be consistent with the requirements of R307-
410-3. The results for all Class I areas within 300 kilometers are provided in Table 6.

Table 6: Model Predicted PSD Class I Increment Concentrations

Air Period Prediction
Class I
Significant
Impact
Level
Other
Sources* Total Increment Percent
Pollutant (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
Capitol Reef
NO2 Annual 0.0018 0.1 2.5
SO2
3-Hour 0.0494 1 25
24-
Hour 0.0150 0.2 5
Annual 0.0008 0.1 2
PM2.5
24-
Hour 0.0430 0.27 2
Annual 0.0021 0.05 1
PM10
24-
Hour 0.0444 0.3 8
Annual 0.0021 0.2 4
Arches
NO2 Annual 0.0008 0.1 2.5
SO2
3-Hour 0.0408 1 25
24-
Hour 0.0102 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0522 0.27 2
Annual 0.0018 0.05 1
DAQE-MN103030032-24
Page 9
PM10
24-
Hour 0.0531 0.3 8
Annual 0.0019 0.2 4
Canyonlands
NO2 Annual 0.0010 0.1 2.5
SO2
3-Hour 0.0354 1 25
24-
Hour 0.0100 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0577 0.27 2
Annual 0.0019 0.05 1
PM10
24-
Hour 0.0591 0.3 8
Annual 0.0020 0.2 4
Bryce
NO2 Annual 0.0006 0.1 2.5
SO2
3-Hour 0.0369 1 25
24-
Hour 0.0082 0.2 5
Annual 0.0003 0.1 2
PM2.5
24-
Hour 0.0189 0.27 2
Annual 0.0010 0.05 1
PM10
24-
Hour 0.0194 0.3 8
Annual 0.0010 0.2 4
Zion
NO2 Annual 0.0011 0.1 2.5
SO2
3-Hour 0.0293 1 25
24-
Hour 0.0105 0.2 5
Annual 0.0005 0.1 2
PM2.5
24-
Hour 0.0266 0.27 2
Annual 0.0011 0.05 1
PM10 24-
Hour 0.0271 0.3 8
DAQE-MN103030032-24
Page 10
Annual 0.0012 0.2 4
* Note: Only included other increment consuming sources if source impact was above Class I SIL

Since the proposed project’s model predicted impacts at the Class I areas were less than the PSD Class I
significance levels, a cumulative analysis was not warranted.

DAQE-MN103030032-24
Page 11
F. Visibility – Plume Blight
Since the Class I areas are greater than 50 kilometers from the source, a plume blight analysis using
VISCREEN was not required.

G. Visibility – Regional Haze

The results of the Q/D analysis for the emissions increase was less than 10 but the FLMs wanted the
entire source included in the Q term. The results of including the total emissions resulted in a Q/D >10,
so an AQRV analysis was performed for visibility and acid deposition. The results shown in Table 7
indicate that the impacts are below the 0.5 Deciview (DV) threshold established by the National Park
Service, indicating that no further analysis is required.

Table 7: CALPUFF Visibility Results

Class I Area Year Maximum
Delta DV
98th
Percentile
change in
DV
#
Days
#
Days Threshold
(DV)
Below
Threshold
> 1 > 0.5
2018 0.248 0.06 0 0 0.5 Yes
Arches 2019 0.291 0.054 0 0 0.5 Yes
2020 0.216 0.106 0 0 0.5 Yes
2018 0.223 0.081 0 0 0.5 Yes
Canyonlands 2019 0.312 0.068 0 0 0.5 Yes
2020 0.186 0.085 0 0 0.5 Yes
2018 0.059 0.03 0 0 0.5 Yes
Bryce 2019 0.081 0.045 0 0 0.5 Yes
2020 0.071 0.03 0 0 0.5 Yes
2018 0.183 0.074 0 0 0.5 Yes
Capital Reef 2019 0.196 0.092 0 0 0.5 Yes
2020 0.126 0.078 0 0 0.5 Yes
2018 0.069 0.04 0 0 0.5 Yes
Zion 2019 0.123 0.039 0 0 0.5 Yes
2020 0.102 0.057 0 0 0.5 Yes

DAQE-MN103030032-24
Page 12

H. Acid Deposition

The Applicant performed a deposition analysis on impacts within the Class I areas. Results of the
analysis indicate that the impacts are below the deposition threshold (DAT) established by the National
Park Service, indicating that no further analysis is required

Table 8: CALPUFF Deposition Results for Highest Year

Class I Area
Total
Nitrate
Deposition
Total
Sulfate
Deposition
Deposition
Analysis
Threshold
(kg/ha/yr) (kg/ha/yr) (kg/ha/yr)
Canyonlands 0.0006 0.0003
0.005
Zion 0.0004 0.0002
Arches 0.0006 0.0003
Bryce 0.0006 0.0002
Capitol Reef 0.0011 0.0005

I. Soils and Vegetation Analysis

The Applicant performed an analysis to determine the extent of impacts from the proposed source on soil
and vegetation. Results of the analysis are presented in a supplemental document titled “Soil and
Vegetation Impact Analysis for the Leamington, UT Facility, June 29, 2023”. The analysis indicated that
predicted concentrations compared against the secondary NAAQS at several sensitive receptors would not
result in an adverse impact on soils and vegetation in the vicinity of the proposed project.

DP/JK:jg

DAQE-IN103030032-25

January 22, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Mr. Nelson:

Re: Intent to Approve: Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — ) A A v A ? A D @ A w D D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — ) A A v A ? A D @ A w D D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ash Grove Cement Company Ash Grove Cement Company - Leamington Cement Plant

Mailing Address Physical Address
P.O. Box 38069 Highway 132
Leamington, UT 84638 Leamington, UT 84638

Source Contact UTM Coordinates
Name: Cody Watkins 397000 m Easting
Phone: [phone] 4380100 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3241 (Cement, Hydraulic)

SOURCE INFORMATION
General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried on site),
are correctly proportioned, ground, and mixed and then fed into a rotating kiln. The kiln alters the
materials and recombines them into small stones called cement clinker. The clinker is cooled and ground
with gypsum and additional limestone into a fine powdered cement. The final product is stored on site for
later shipping. The major sources of air emissions are from the combustion of fuels for the kiln operation,
from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source of
emissions of PM2.5, PM10, NOx, CO, HAPs, and GHG. It is a minor source of SO2 emissions.
NSR Classification
Major PSD Modification

Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
DAQE-IN103030032-25
Page 4

Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

These changes result in increases in actual emissions but decreases in most potential emissions. There will
be an increase in the potential emissions of VOCs and greenhouse gases.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
DAQE-IN103030032-25
Page 5

Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
DAQE-IN103030032-25
Page 6

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
DAQE-IN103030032-25
Page 7

II.A.4 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)
II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area, and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, stacker systems. II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit-specific requirements.
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total air flow controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter
area; 9,865 acfm total air flow, controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are
controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each
is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6). II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The
following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for
NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.
II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low-pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

DAQE-IN103030032-25
Page 8

II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow through stack
E34.
II.A.18 Kiln Feed Alleviator A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the central material silo between the blending silos and the preheater. Raw feed is removed from the system near the top of the preheater tower.
II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The
coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter area;
1,700 acfm total air flow.
II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker
storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1): 1,800 acfm that discharges into the clinker tunnel.
II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
DAQE-IN103030032-25
Page 9

II.A.27 Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during loading.
II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel, all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during loading. 512.BF3 (1,000 acfm) is located on top of the silo. II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement products. Dust generated
during milling is captured by a BHA pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).

II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates from stack G55 (finish mill stack).
II.A.32 Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4).
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1 thru 3).

II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total air flow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations.
II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This
baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

DAQE-IN103030032-25
Page 10

II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.
II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023)
II.A.40 Dust Shuttle System A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides, surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the
fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

II.A.41 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons) Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
DAQE-IN103030032-25
Page 11

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)
THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)
CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)
PM: 0.02 lbs filterable PM per ton of clinker.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR 60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to approve alternative control measures, the permittee shall keep a copy of the submitted petition and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source
of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2).
[40 CFR 63 Subpart LLL]

DAQE-IN103030032-25
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II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must record the PM CPMS output data for all periods when the process is operating and use all the PM CPMS data for calculations when the PM CPMS is not out of control. The owner/operator must demonstrate continuous compliance by using all quality-assured hourly average data collected by the PM CPMS for all operating hours to calculate the arithmetic average operating parameter in units of the operating limit on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
DAQE-IN103030032-25
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II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

II.B.1.e.3 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-165]
II.B.1.e.4 PM 40 CFR 60, Appendix A, Method 5, or 5I, or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three runs, with each
run at least 120 minutes in duration and each run collecting a sample of 60 dry standard cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165]
DAQE-IN103030032-25
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II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
DAQE-IN103030032-25
Page 15

II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
DAQE-IN103030032-25
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II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer point, is not required to conduct Method 22 visible emissions monitoring under this paragraph. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator may decrease the frequency of performance testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
DAQE-IN103030032-25
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II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: Instances of water and/or chemical application to unpaved areas shall be recorded and maintained by the owner/operator. The ambient temperature shall be recorded any time water should be applied but cannot due to freezing conditions. [R307-401-8]
II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

The sprays shall operate whenever dry conditions warrant meeting the required opacity
limitations or as determined necessary by the Director. Water sprays shall not be required during
periods of freezing temperatures.

[R307-401-8]

DAQE-IN103030032-25
Page 18

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

C. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the kiln/raw mill stack

F. The owner/operator shall record the output of the system: including the quantity of NOx, CO, O2, THC, Hg, HCl, and CO2 emissions at the kiln stack

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an
affected source shall continuously operate all required continuous monitoring devices
and shall meet minimum frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.

[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]
II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments, the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the results of the performance test demonstrating compliance with the filterable PM limit and using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust the SSOL developed in accordance with the results of the most recent PM performance test demonstrating compliance with the PM emission limit. The owner/operator shall use the PM CPMS to demonstrate continuous compliance with the SSOL in accordance with the requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

DAQE-IN103030032-25
Page 19

II.B.4 Fuel Limitations: II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke F. Fuel Oil
G. Used Oil Fuel

H. Synthetic Fuel
I. Wood
J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal additive.
Approval is not required to change from one previously approved coal additive to another
previously approved coal additive. [R307-401-8]
II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily heat input of the kiln and precalciner. The owner/operator may increase the average quantity of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon approval by the Director in accordance with the approval process described in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

DAQE-IN103030032-25
Page 20

II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight
A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation
C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit-no less than 1500oF for more than five minutes in any 60-minute period B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
DAQE-IN103030032-25
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II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the Director. The calibration procedure and frequency shall be according to manufacturer's specifications. Use of factory-calibrated thermocouples for temperature measurement is approved. However, any other method of temperature measurement must be approved by the Director prior to use. The monitoring equipment for both temperature and oxygen content shall be located such that an inspector can at any time safely read the output. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall only operate the emergency engines for testing and maintenance purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency operation. [R307-401-8]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.5.b.2 To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From Source Submitted NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-IN103030032-25
Page 22

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Ash Grove Cement
(A CRH Company)
Leamington Plant
P.O Box 38069
Leamington, UT 84638
November 30, 2022
Mr. John Jenks
Utah Division of Air Quality
195 North 1950 West
Salt Lake City, Utah 84116
RE: Ash Grove Cement Leamington Plant
PSD Notice of Intent Air Permit Application
Ash Grove Cement (Ash Grove), A CRH Company, operates a Portland cement plant six (6) miles
east of Leamington, Utah located in Juab County. Currently, the plant is permitted in accordance
with Approval Order (AO) DAQE-AN103030030-22 and Title V Air Operating Permit (AOP)
#2300015004.
Ash Grove is proposing to modify the current permitted equipment and add a new finish mill and
rail/truck loading station through a project referred to as the Leamington Upgrade Project. The
accompanying Notice of Intent (NOI) air permit application has been developed to meet the Utah
Division of Air Quality’s (UDAQ’s) application requirements and the U.S. Environmental Protection
Agency’s (EPA’s) Prevention of Significant Deterioration (PSD) requirements as established in Utah
Administrative Code (UAC) R307-401 and R307-403, as well as Code of Federal Regulations (CFR)
40 CFR 52.21.
A separate netting analysis has been provided in Section 4 of the NOI air permit application to
document PSD applicability for each criteria pollutant. Ash Grove has elected to make reductions to
existing permitted equipment emission rates, which requires revisions to the baseline actual
emissions analysis. As a result, Ash Grove will be submitting revised actual emissions inventories to
update emissions previously reported for baseline years 2020 and 2021. The updated emissions
inventories for these two (2) years will be submitted in accordance with R307-150 and will use
UDAQ’s State and Local Emissions Inventory System (SLEIS) reporting software.
An air quality impact analysis and modeling protocol and report are being submitted with this NOI
air permit application under a separate submission. The modeling protocol has been prepared in
accordance with UDAQ modeling guidelines (Revised December 17, 2008) and R307-410, and EPA
air quality modeling guidelines; “Air Quality Models (Guideline)”; Final Rule, 40 CFR Part 51,
Appendix W, January 17, 2017.
Ash Grove has submitted remittance in the form of a check for the amount of $33,500 for UDAQ’s
Application Filing and Review Fees. The check has been submitted to the following address:
Mr. John Jenks
Utah Division of Air Quality
195 North 1950 West
Salt Lake City, Utah 84116

ASH GROVE LEAMINGTON PLANT UPGRADE
PSD Air Permit Application / Notice of Intent Air Permit
Application
Prepared By:
TRINITY CONSULTANTS
4525 Wasatch Boulevard
Suite 200
Salt Lake City, Utah 84124
Submitted on Behalf of:
Ash Grove Cement (A CRH Company)
Leamington Plant
P.O Box 38069
Leamington, UT 84638
Project 214502.0075

Ash Grove Leamington Plant / PSD Application | Plant Upgrade Project
Trinity Consultants
1. INTRODUCTION 1-1
1.1 Executive Summary .................................................................................................. 1-1
2. PERMIT APPLICATION GENERAL INFORMATION 2-1
2.1 Source Identification Summary ................................................................................. 2-1
2.2 Application Contents ................................................................................................. 2-1
2.3 Forms ........................................................................................................................ 2-2
2.4 Application Fees ........................................................................................................ 2-2
3. PROJECT DESCRIPTION AND EXISTING OPERATIONS 3-1
3.1 Project Description and Modification ........................................................................ 3-1
3.1.1 Kiln System (Kiln, Raw Mill, and Coal Mill).................................................................. 3-1
3.1.2 Clinker Cooler ......................................................................................................... 3-1
3.1.3 New Finish Mill ........................................................................................................ 3-2
3.1.4 New Rail and Truck Loading/Unloading ..................................................................... 3-2
3.1.5 New Kiln Feed Alleviator Baghouse ........................................................................... 3-2
3.1.6 Existing Baghouses ................................................................................................. 3-2
3.1.7 Fugitive Emissions ................................................................................................... 3-3
3.1.8 Ammonia System .................................................................................................... 3-3
3.1.9 Removal of Sources ................................................................................................. 3-4
3.1.10 Shipping Emergency Generator ................................................................................ 3-4
4. PSD APPLICABILITY ANALYSIS 4-1
4.1 Calculation Methodology ........................................................................................... 4-1
4.1.1 Projected Actual Emissions ....................................................................................... 4-1
4.1.2 Baseline Actual Emissions ........................................................................................ 4-1
4.1.3 Could Have Been Accommodated Emissions............................................................... 4-1
4.2 Project Emissions Calculations .................................................................................. 4-1
4.2.1 Kiln and Coal Mill System Modifications ..................................................................... 4-1
4.2.2 Associated Emissions Increases ................................................................................ 4-2
4.3 Netting ...................................................................................................................... 4-3
4.3.1 Contemporaneous Decreases ................................................................................... 4-3
4.3.2 Contemporaneous Increases .................................................................................... 4-4
4.4 Net Project Emissions ............................................................................................... 4-4
5. EMISSIONS RELATED INFORMATION EMISSIONS SUMMARY 5-1
5.1.1 Kiln and Coal Mill System Modifications ..................................................................... 5-1
5.1.2 Clinker Cooler ......................................................................................................... 5-2
5.1.3 New Finish Mill and Kiln Feed Alleviator Baghouses ..................................................... 5-3
5.1.4 Grinding Aid VOC Emissions from New Finish Mill ....................................................... 5-4
5.1.5 New Rail Unloading and Truck Loadout ..................................................................... 5-4
5.1.6 Fugitive Emissions ................................................................................................... 5-5
5.1.7 Material Transfer ................................................................................................... 5-11
5.1.8 Tank Calculations .................................................................................................. 5-12
5.1.9 Vertical Fixed Roof – Standing Storage Loss............................................................. 5-12
5.1.10 Tank Vapor Space Volume (VV) .............................................................................. 5-12
5.1.11 Vapor Space Expansion Factor (KE) ........................................................................ 5-13
5.1.12 Vapor Space Expansion Factor (Ks) ......................................................................... 5-15
5.1.13 Stock Vapor Density (WV) ...................................................................................... 5-16
5.1.14 Horizontal Fixed Roof – Working Loss ..................................................................... 5-16

Ash Grove Leamington Plant / PSD Application | Plant Upgrade Project
Trinity Consultants i
5.1.15 Horizontal Fixed Roof – Hazardous Air Pollutant (HAP) Speciation .............................. 5-17
6. REGULATORY REQUIRMENTS 6-19
6.1 Federal Rules – New Source Performance Standards (NSPS) .................................. 6-19
6.1.1 NSPS Subpart F – Standards of Performance for Portland Cement Plants .................... 6-19
6.1.2 Summary of Changes ............................................................................................ 6-20
6.1.3 NSPS Subpart Y – Standards of Performance for Coal Preparation and Processing Plants .. 6-
24
6.1.4 NSPS Subpart OOO – Standards of Performance for Nonmetallic Mineral Processing Plants
6-25
6.2 Federal Rules – Applicable National Emission Standards for Hazardous Pollutants. 6-26
6.2.1 Subpart A – General Provisions ............................................................................... 6-26
6.2.2 Subpart LLL – Standards for Hazardous Air Pollutants from the Portland ..................... 6-26
Cement Manufacturing Industry ........................................................................................ 6-26
6.3 State Rules – UDAQ ................................................................................................. 6-26
6.3.1 General Requirements ........................................................................................... 6-26
6.3.2 Emission Inventories ............................................................................................. 6-27
6.3.3 Emission Testing ................................................................................................... 6-28
6.3.4 Emission Standards ............................................................................................... 6-28
6.3.5 NSPS/NESHAPs ..................................................................................................... 6-29
6.3.6 Approval Order ..................................................................................................... 6-30
7. BACT 7-1
7.1 Sources Addressed in BACT ....................................................................................... 7-1
7.1.1 PM10 and PM2.5 Sources ........................................................................................... 7-1
7.2 BACT Definition ......................................................................................................... 7-2
7.3 BACT Methodology .................................................................................................... 7-3
7.3.1 Step 1 – Identify All Control Technologies .................................................................. 7-3
7.3.2 Step 2 – Eliminate Technically Infeasible Options ....................................................... 7-3
7.3.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness ...................... 7-4
7.3.4 Step 4 – Evaluate Most Effective Controls and Document Results ................................. 7-4
7.3.5 Step 5 – Select BACT ............................................................................................... 7-4
7.4 PM10 and PM2.5 Sources BACT Analysis ...................................................................... 7-4
7.4.1 PM10 and PM2.5 Modified Equipment .......................................................................... 7-4
7.4.2 PM10 and PM2.5 Fugitive Emissions .......................................................................... 7-10
7.5 NOX, SO2, CO, PM10, PM2.5, and VOCs BACT - New Finish Mill Heater ....................... 7-32
7.5.1 NOX - Finish Mill Heater Combustion BACT ............................................................... 7-32
7.5.2 CO, SO2, and VOC - Finish Mill Heater BACT ............................................................ 7-35
7.5.3 PM10 and PM2.5 New Finish Mill BACT ....................................................................... 7-36
7.6 SO2, VOC, and Lead Sources BACT Analysis ............................................................. 7-39
7.6.1 SO2 – Cement Kiln BACT ........................................................................................ 7-39
7.6.2 VOC – Cement Kiln BACT ....................................................................................... 7-42
7.6.3 VOC – Grinding Aid BACT ....................................................................................... 7-44
7.6.4 Lead Emissions ..................................................................................................... 7-45
7.7 GHG Background ..................................................................................................... 7-45
7.8 Cement Manufacturing GHG BACT .......................................................................... 7-46
7.8.1 Step 1: Identify All Control Technologies ................................................................. 7-46
7.8.2 Step 2: Eliminate Technically Infeasible Options ....................................................... 7-47
7.8.3 Step 3: Rank Remaining Control Technologies by Control Effectiveness ...................... 7-53
7.8.4 Step 4: Evaluate Most Effective Controls and Document Results ................................ 7-54

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7.8.5 Step 5: Select BACT .............................................................................................. 7-55
7.9 New Finish Mill Heater GHG BACT ........................................................................... 7-56
7.9.1 Step 1 - Identify All Control Technologies ................................................................ 7-56
7.9.2 Step 2 – Eliminate Technically Infeasible Options ..................................................... 7-56
7.9.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness .................... 7-57
7.9.4 Step 4 – Evaluate Most Effective Controls and Document Results ............................... 7-57
7.9.5 Step 5 – Select BACT ............................................................................................. 7-57
APPENDIX A. UDAQ FORMS A-1
APPENDIX B. BASELINE ACTUAL EMISSIONS AND PROJECTED ACTUAL EMISSIONS B-1
APPENDIX C. EMISSIONS CALCULATIONS C-2
APPENDIX D. MODELING SUPPORTING INFORMATION D-1

TABLE OF CONTENTS
LIST OF TABLES
Table 1-1. UDAQ Modeling Thresholds 1-3
Table 4-1 Baseline Period by Criteria Pollutant (Trinity will add with new Calculations) 4-1
Table 4-2. Projected Actual Increase Compared to PSD threshold (tons per year) 4-3
Table 4-3. Kiln Drive Engine and Limestone Bypass – Contemporaneous Decrease in PM10 and PM2.5
Emissions 4-3
Table 4-4 Kiln Drive Engine Contemporaneous Increase in GHG Emissions 4-4
Table 4-5. Third Bay Truck Loadout - Contemporaneous Increase in PM10 and PM2.5 Emissions 4-4
Table 4-6 Leamington Plant Upgrade Project Netting 4-4
Table 5-1 NOX lb/hr Baseline for NSPS Determination of Change 5-2
Table 6-1 Kiln System Modification, NSPS Subpart F Monitoring Requirements 6-22
Table 6-2 Clinker Cooler Modification, NSPS Subpart F Monitoring Requirements 6-23
Table 6-3 New Finish Mill, NSPS Subpart F Monitoring Requirements 6-24
Table 6-4 New Rail Loading and Unloading, NSPS Subpart F Monitoring Requirements 6-24
Table 7-1 PM10 Control Effectiveness for Kiln Operations 7-8
Table 7-2 Kiln PM10 and PM2.5 BACT Summary 7-8
Table 7-3. PM10 and PM2.5 Control Effectiveness for Clinker Cooler Operations 7-9

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Table 7-4. Clinker Cooler PM10 and PM2.5 BACT Summary 7-10
Table 7-5. Summary of PM10 and PM2.5 Controls for Roads 7-13
Table 7-6. Roads PM10 and PM2.5 BACT Summary 7-13
Table 7-7. PM10 and PM2.5 Control Effectiveness for Loading and Unloading Operations 7-15
Table 7-8. Quarry Loading and Unloading PM10 and PM2.5 BACT Summary 7-16
Table 7-9. Summary of PM10 and PM2.5 Control Effectiveness for Stockpiles 7-18
Table 7-10. Stockpiles PM10 and PM2.5 BACT Summary 7-19
Table 7-11. Summary of PM2.5 and PM10 for Bulldozing 7-20
Table 7-12. Bulldozing PM2.5 and PM10 BACT Summary 7-21
Table 7-13. Summary of PM10 and PM2.5 Control Methods for Disturbed Areas 7-22
Table 7-14. Disturbed Areas PM10 and PM2.5 BACT Summary 7-23
Table 7-15. Summary of PM10 and PM2.5 Control Techniques for Drilling and Blasting 7-25
Table 7-16. Drilling and Blasting PM10 and PM2.5 BACT Summary 7-26
Table 7-17. PM10 and PM2.5 Material Transfer BACT 7-26
Table 7-18. PM10 and PM2.5 Sources BACT Summary 7-27
Table 7-19. Summary of NOx Control Techniques for Finish Mill Heater Combustion 7-34
Table 7-20. Finish Mill Heater Combustion NOx BACT Summary 7-35
Table 7-21 Finish Mill Heater Combustion CO, SO2, and VOC BACT Summary 7-36
Table 7-22. New Finish Mill PM10 and PM2.5 Emission Sources 7-37
Table 7-23. Summary of PM10 Control Effectiveness for the Finish Mill 7-38
Table 7-24. Finish Mill PM10 BACT Summary 7-39
Table 7-25. SO2 Control Effectiveness for Kiln Operations 7-41
Table 7-26. Kiln SO2 BACT Summary 7-42
Table 7-27. Kiln VOC Control Effectiveness for Kiln Operations 7-43
Table 7-28. Kiln VOC BACT Summary 7-44
Table 7-29. Grinding Aid BACT Summary 7-45

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Table 7-30. Potential Control Technologies for CO2 7-47
Table 7-31. Technical Feasibility Analysis 7-47
Table 7-32. Summary of Control Technologies 7-53
Table 7-33. RBLC1 Summary of Portland Cement Kilns GHG Intensity Metric 7-55
Table 7-34. Kiln GHG BACT Summary 7-56
Table 7-35. Summary of Control Technologies 7-57
Table 7-36. New Finish Mill Heater GHG BACT Summary 7-57

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LIST OF ACRONYMS
Acronym Term or Phrase
AEI Associated Emission Increases
AP-42 EPA Compilation of Air Pollutant Emission Factors
BACT Best Available Control Technology
BAE Baseline Actual Emissions
Btu British Thermal Units
CAA Clean Air Act
CAM Compliance Assurance Monitoring
CEMS Continuous Emissions Monitoring System
CFR Code of Federal Regulations
CO Carbon Monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent
DRE Destruction & Removal Efficiency
dscf Dry Standard Cubic Foot
EIQ Emissions Inventory Questionnaire
GEP Good Engineering Practice
CSR Code of State Regulations
GHG Greenhouse Gas
HAP Hazardous Air Pollutant
HCl Hydrochloric Acid
hr Hour
ID Induced Draft
LAER Lowest Achievable Emission Rate
lb or lbs pound or pounds
MACT Maximum Achievable Control Technology
MERP Model Emission Rates for Precursors
min Minute
MACT Maximum Available Control Technology
MMBtu Million Btu
NAAQS National Ambient Air Quality Standards
NED National Elevation Dataset
NESHAP National Emission Standards for Hazardous Air Pollutants
NH3 Ammonia
NOx Oxides of Nitrogen
NSPS New Source Performance Standards
NSR New Source Review
NNSR Non-Attainment New Source Review
PAE Projected Actual Emissions
Pb Lead
PM2.5 Particulate Matter with an aerodynamic diameter less than 2.5 micrometers
PM10 Particulate Matter with an aerodynamic diameter less than 10 micrometers
PM Particulate Matter

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Acronym Term or Phrase
PSD Prevention of Significant Deterioration
PTE Potential to Emit
RACT Reasonably Available Control Technology
RBLC EPA’s RACT/BACT/LAER/Clearinghouse
RMP Risk Management Program
SER Significant Emission Rate
SIL Significant Impact Level
SIP State Implementation Plan
SO2 Sulfur Dioxide
tpy Tons per year
UDAQ Utah Division of Air Quality
USEPA United Stated Environmental Protection Agency
USGS United States Geological Survey
UTM Universal Transverse Mercator
VOC Volatile Organic Compound
yr Year

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1. INTRODUCTION
1.1 Executive Summary
Ash Grove Cement Company (Ash Grove) owns and operates a Portland Cement (PC) plant six (6) miles east
of Leamington, Utah (Leamington Plant) on Highway (Hwy) 132 in Juab County, Utah. Ash Grove is
submitting this Notice of Intent (NOI) air permit application which defines the Leamington Plant Upgrade
Project’s proposed permit modifications to the existing plant. Ash Grove is proposing to make upgrades to
its Leamington Plant to achieve the following:
► Increase grinding capacity, which will allow the production of low-clinker factor (the amount of clinker
required in the cement product) and lower carbon dioxide (CO2) cements; and
► Increase clinker production to ensure sufficient cement for the growing Salt Lake City market.
Upgrades include improved efficiency of the kiln’s precalciner and preheater, upgrades to the NOX control
system, additional equipment improvements addressed in this application, and installation of a second finish
mill and rail and truck loading and unloading. By making these improvements through the proposed upgrade
project, Ash Grove will also be able to increase clinker throughput, cement production, and shipment of
cement to serve the State of Utah’s continued economic growth and resulting Portland Cement demand.
For criteria pollutants, the gained energy efficiency and upgrade of selective non-catalytic reduction (SNCR)
controls will enable the Leamington Plant to maintain oxides of nitrogen (NOX) emissions such there is less
than a significant emissions increase and no increase in hourly capacity to emit. With additional clinker
throughput, Ash Grove projects a minor increase in sulfur dioxide (SO2), carbon monoxide (CO), volatile
organic compounds (VOCs), and lead (Pb) emissions for the project, but none of the increases equal or
exceed the applicable Significant Emission Rate. Greenhouse gas (GHG) emissions will increase with the
proposed additional clinker throughput and cement production. Also included in the project is the addition of
a second finish mill, which will result in an increase in particulate matter (PM) and a minor increase in other
criteria pollutant emissions from the addition of a gas fired heater on the new mill.
To achieve an increase in cement and clinker production, additional mined limestone and/or receipt of raw
materials will be required. To facilitate this, a rail and trucking loading/unloading system is proposed to be
installed. Although minor increases in emissions will occur with the addition of the rail and trucking
loading/unloading system and second finish mill, additional controls applied to other modified sources and
updated emission factors will result in a permitted decrease to the Leamington Plant’s site-wide potential-to-
emit (PTE) in both particulate matter with an aerodynamic diameter of 10 microns or less (PM10) and
particulate matter with an aerodynamic diameter of 2.5 microns or less (PM2.5). Although as further detailed
in the following section, Source Size And Modification Determination, the proposed changes will result in
both significant emissions increase and a significant net emissions increase of PM10, PM2.5 and GHGs from
the selected baseline.
Current Permits and Proposed Permit Modification
The Leamington Plant operates under Title V Air Operating Permit (AOP) #2300015004 and Approval Order
(AO) DAQE-AN103030030-22. The Leamington Plant is an existing major source for Prevention of Significant
Deterioration (PSD) and Title V under the Clean Air Act (CAA).

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Source-Size and Modification Determination
As addressed in Section 2.0 of this application, the Leamington Plant is an existing major PSD source
included in the list of 28 found in 40 CFR 52.21(b)(1)(iii)(a). The modifications to the PSD sources are
evaluated for the project’s net emissions increase, which exceeds significant emission rates (SERs) for PM10
and PM2.5. The remainder of the criteria pollutants result in a net emissions increase less than significant
emission rates. A separate actual to projected actuals analysis has been prepared for the project in Section
4.0. As noted above, the proposed changes will result in both a significant emissions increase and a
significant net emissions increase of PM10, PM2.5 and GHGs.
The Leamington Plant will remain a major existing source for PC Maximum Available Control Technology
(MACT) and the kiln will be subject to New Source Performance Standards (NSPS) as a modification to
existing affected facilities for PM and SO2. Maximum hourly NOX emissions will not increase thus NSPS will
not be triggered for NOX. The proposed changes to the clinker cooler will cause it to be considered
reconstructed for NSPS purposes.
Modifications to Existing Equipment
Modifications are proposed to the existing kiln precalciner, preheater, and induced draft (ID) fan. These
changes will represent less than 50% of the replacement cost of a new kiln. The changes proposed for the
clinker cooler will be in excess of 50% of the replacement cost of a new clinker cooler and will thus meet
the definition of reconstruction under NSPS. The sources anticipated to result in emission changes are
addressed in this application.
Proposed New Equipment
The proposed equipment to be added at the Leamington Plant with the plant upgrades that are addressed
in this NOI air permit application include the following:
► Second Finish Mill and Finish Mill Heater;
► Rail and Truck Loading/Unloading; and
► The Kiln Feed Alleviator will be replaced with a larger unit.
This NOI air permit application addresses the Leamington Plant upgrade’s emission sources, emission
calculations, netting analysis, Best Available Control Technology (BACT), air quality impact analysis (i.e., air
dispersion model), and regulatory applicability. A more detailed summary of the NOI air permit application is
in the following sections.
Attainment Status
The Leamington Plant is located in Juab County, which is in attainment for all criteria pollutants.
Permitting Approach
Notice of Intent Application
This NOI air permit application has been developed to meet the Utah Division of Air Quality’s (UDAQ’s) NOI
application requirements and the U.S. Environmental Protection Agency’s ( EPA’s) PSD requirements as
established in Utah Administrative Code (UAC) R307-401, R307-403, and 40 CFR 52.21.

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Emissions Calculations
PTE emissions calculations for the proposed modified and new sources have been developed based on
equipment design and throughput. A majority of the PTE emissions calculations have been developed based
on projected potential throughputs and 8,760 hours per year. A separate netting analysis has been provided
in Section 4.0 of the application to document PSD applicability for each criteria pollutant, as applicable, and
to account for emissions increases and decreases during the contemporaneous period.
BACT
BACT for PM10 and PM2.5, which are proposed to exceed significant emission rates, has been provided to
meet PSD requirements. As the GHG emissions will increase greater than 75,000 tpy the kiln has been
evaluated for BACT as an anyway source. In addition, for those pollutants for which an increase in
emissions is proposed, but not in excess of SERs, a state-level BACT analysis is provided to meet UDAQ’s
BACT requirement in UAC R307-401-5(d). Ash Grove is proposing to install state-of-the-art equipment and
associated controls with its new and modified facilities located at the Leamington Plant.
Air Dispersion Modeling
According to the Utah Division of Air Quality Emission Impact Assessment Guidelines, any site that has the
potential to emit more than the following Total Controlled Emission rates, in tons per year (tpy), for
emission increases as specified in Table 1-1, may be required to complete dispersion modeling in
accordance with UAC R307-410-41.
Table 1-1. UDAQ Modeling Thresholds
Pollutant Emission Levels Requiring
Modeling (tpy)
NO2 40
SO2 40
PM10 fugitive 5
PM10 non-fugitive 15
CO 100
Lead 0.6
Although no changes to the kiln NOX emissions are anticipated, plantwide NOx will increase slightly from the
addition of a gas-fired heater on the second finish mill but will remain less than 40 tpy. The combined
increase in SO2 emissions associated with the proposed project will not exceed 40 tpy. Additionally, the
increase in CO emissions will only result from the addition of the second finish mill’s heater and will not
exceed 100 tpy. Therefore, air dispersion modeling has not been provided for these pollutants. A cumulative
impact analysis has been completed for PM10 and PM2.5, as they are in excess of the SERs, and associated
impacts are greater than significant impact levels (SILs) for these pollutants. The project will also result in
an increase in fugitive PM10 in excess of 5 tpy. Ash Grove will submit a protocol and an air dispersion
modeling analysis for PM10 and PM2.5 to meet PSD modeling requirements under a separate cover.

1 UDAQ’s Modeling Guidelines, Revised Dec. 17, 2008

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2. PERMIT APPLICATION GENERAL INFORMATION
The following section contains the information requested under the “Source Identification Information”
section of UDAQ’s Form 1 Notice of Intent (NOI) Application Checklist.
2.1 Source Identification Summary
► Company Name: Ash Grove Cement Company
► Address: Hwy. 132 Leamington, UT 84638
► County: Juab County
► UTM Coordinates: Easting: 397,000 m, Northing: 4,379,850 m, Zone 12
► Primary SIC Code: 3241 (Cement, Hydraulic)
► Area Designation: Attainment for all Pollutants
► Source Size Determination: Major Source – AOP 2300015004 (Major for Title V,
PSD, and PC MACT)
► Current AO: DAQE-AN103030030-22
► Title V Air Operating Permit 2300015004
All correspondence regarding this submission should be addressed to:
Mr. Cody Watkins
Environmental Engineer
P.O. Box 38069
Leamington, UT 84638
Phone: [phone]
Email: [e-mail]
Jeff Briggs
Corporate Environmental Manager
Phone: [phone]
Email: [e-mail]

2.2 Application Contents
This application details the Leamington Plant operations and associated emissions methodologies utilized to
calculate emissions. Additionally, the required elements of a PSD application include the following:
► Regulatory analysis to address NSPS and NESHAPs;
► BACT review for each regulated pollutant in Section 7.0;
► Air dispersion modeling analysis completed to demonstrate compliance with the National Ambient Air
Quality Standards (NAAQS) in Appendix D;
► Air quality analysis to assess impacts on air quality;
► Class I area analysis screening; and
► Additional impacts analysis.
The UDAQ Forms for a modification to an existing source are included in Appendix A. Appendix B contains
the detailed emission calculations, Appendix C includes the facility baseline, and Appendix D includes the
modeling report and Appendix E includes the Secondary PM2.5 Qualitative Analysis.

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2.3 Forms
The following UDAQ forms have been included with the NOI application:2
► Form 1 – Notice of Intent Application Checklist;
► Form 2 – Source Identification Information;
► Form 4 – Project Information;
► Form 5 – Emissions Information Criteria/GHGs/HAPs; and
► Form 10 – Fabric Filter (Baghouse)
► Form 19 – Fuel Burning Equipment
2.4 Application Fees
Ash Grove prepaid the following UDAQ NOI fees with remittance in the form of a check associated with this
submittal:3
“Application Filing Fee” for the “Major or Minor Modification” category = $500
“Application Review Fee” for the “New Non-PSD Major source in attainment area or Modifications to Major
source in attainment area” category = $33,000
Total UDAQ fees = $33,500
Ash Grove understands that the total permit review fee is based on the total actual time spent by UDAQ
staff processing this NOI air permit application. Upon issuance of the approval order (AO), if the total review
time is more than 300 standard hours, UDAQ will invoice Ash Grove at $110 per hour for the additional time
above 300 standard hours.

2 https://deq.utah.gov/air-quality/permitting-forms-air-quality
3 https://deq.utah.gov/air-quality/fees-air-quality-permitting

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3. PROJECT DESCRIPTION AND EXISTING OPERATIONS
3.1 Project Description and Modification
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy efficiency in
its kiln system and throughout the Plant to produce more low-carbon cement. A description of the changes
to occur at the Plant are broken down into individual areas in the following sections.
3.1.1 Kiln System (Kiln, Raw Mill, and Coal Mill)
The engineering changes propose to use the existing preheater tower and change various components in
the kiln system which include:
► Mechanical upgrades to raw mill;
► Replace the pre-calciner and tertiary duct;
► Replace portions of the preheater tower;
► Replace the kiln alleviator; and
► Increase the size of the ID fan.
In addition, the Leamington Plant proposes to upgrade the SNCR system by adding injection points to
optimize both residence time and temperature profile. The upgrade will ensure that increased mixing of
ammonia is achieved to enhance the SNCR system’s ability to reduce NOX and minimize ammonia slip. This
will allow the Leamington Plant to maintain the NOX hourly capacity to emit unchanged from current levels,
after the Leamington Plant Upgrade Project.
These upgrades will result in the following emissions changes from the kiln:
► Actual kiln NOX emissions (hourly capacity to emit) will remain the same as a result of upgrades to the
SNCR System;
► CO kiln potential emissions are proposed to remain the same with the project as a result of calciner
upgrades;
► SO2, VOCs, and Lead kiln emissions will increase less than the 100-tpy SER (CO), 40-tpy SERs (SO2 and
VOCs) and 0.6-tpy SER (Lead);
► PM10 and PM2.5 emissions from the kiln will increase greater than their SERs of 15 and 10 tpy,
respectively; and
► GHG emissions resulting from the kiln will increase such that they are subject to regulation.
The Leamington kiln is an affected facility subject to NSPS, Subpart F. The proposed changes will be
considered a modification for PM and SO2 and as a result of the increase in SO2, a Continuous Emissions
Monitoring System (CEMS) will be required to monitor actual emissions of SO2.
As the Leamington kiln has a PM emissions limit of 0.7 lb of PM/ton of clinker already, it is requested to
remain the same with this modification.
3.1.2 Clinker Cooler
The clinker cooler will be reconstructed as an affected facility subject to NSPS, Subpart F. See Section 6.0 of
this application for a description of NSPS applicability. The changes proposed include:

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► New clinker cooler fans;
► Cross bar grate installation and expanded area; and
► Modifying the baghouse from plenum pulse to pulse jet.
As the clinker cooler is an affected facility subject to the reconstruction requirements of NSPS, Subpart F, a
reduction in emissions to 0.2 lb of PM per ton of clinker will be required.
3.1.3 New Finish Mill
The new finish mill will be a vertical style mill. This design offers increased energy efficiency as compared to
traditional style ball or roller mills. The finish mill will have a 10.43 MMBtu/hr heater to maintain
temperature during colder ambient temperatures. The heater will be fired with natural gas and vent out the
main baghouse on the new finish mill. The new finish mill will have five (5) additional baghouses to control
fugitive dust based on the transfer of materials. Ash Grove is proposing these baghouses to have an outlet
grain loading rate of 0.005 grains per dry standard cubic foot per minute (gr/dscfm).
Ash Grove will be adding pozzolan materials and other raw materials shipped from off site, which will be
dumped in a hopper and conveyed into silos adjacent to the new finish mill. These materials will be blended
with clinker in the new finish mill for grinding and producing low-carbon cement. The dump hoppers will be
enclosed on three (3) sides, with a roof, and will be equipped with a baghouse.
3.1.4 New Rail and Truck Loading/Unloading
The new rail and truck loading/unloading facility will be a stand-alone and east of the existing cement silos.
It will be equipped with two (2) baghouses to control fugitive emissions that vent out of the roof and that
control the transfer of cement products and/or raw materials.
3.1.5 New Kiln Feed Alleviator Baghouse
A kiln feed alleviator system and baghouse were installed at the Leamington Plant multiple years ago, yet
they never became operational. The system’s purpose was to remove conveying air used to convey kiln feed
to the top of the kiln tower. This system and baghouse will be reestablished as part of this project, which
includes the replacement of the kiln feed alleviator baghouse with another baghouse that is rated to
accommodate the system’s operations.
3.1.6 Existing Baghouses
Ash Grove is proposing to reduce their grain outlet loading from 0.016 gr/dscfm to 0.007 gr/dscfm on
existing baghouses used in the sizing and transfer of raw materials and products. The stacks on these
baghouses will be turned vertical. As demonstrated in the modeling report, some of the stacks will be
raised. The equipment with these proposed changes will not otherwise be modified, and includes:
► Stationary Crusher
► Raw Material Transfer Points
► Belt Conveyor Transfer Baghouse
► Raw Material Silos
► Fifth Component Silo
► Raw Mill Recirculation
► Raw Mill Recirculation

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► Raw Mill Recirculation
► Raw Mill Recirculation
► Raw Mill Recirculation
► Cross Belt Analyzer
► Kiln, Pre-Calciner, & Raw Mill
► Blending Silo Elevators (2)
► Kiln Feed Blending Silos (2)
► Kiln Feed Alleviator
► Clinker Belt Transfer
► East and West Clinker Storage Silos, East Clinker Belt, West Clinker Belts
► Clinker Belt Transfer 2
► Gypsum Silo
► Finish Mill
► Finish Mill Separator
► Finish Cement Storage Silos
► North Cement Loadout
► South Cement Loadout (truck load outside)
► Coal Silo
► Coal Grinding System (Coal Mill)
► Limestone Silo
► Dust Shuttle System (alkali silo)
► Shipping Generator
► Kiln Generator
► Kiln Feed Alleviator
3.1.7 Fugitive Emissions
As a result of the increase in clinker, limestone, iron, silica, and gypsum, additional mining emissions and
road emissions from transport onto the plant site will occur. The following fugitive emissions will
demonstrate an increase except where additional fugitive controls are applied. See the emissions
calculations in Appendix B for control approach and factors.
► Bulldozing and Grading
► Drilling and Blasting
► Loading and Unloading
► Roads
► Stockpiles and Disturbed Grounds
► Raw Material Handling – Prior to Kiln
► Coal Material Handling
► Plant Material Handling – Post Kiln
► Rail unloading and truck loadout
3.1.8 Ammonia System
Additional ammonia will be used in the existing SNCR system as a result of the control system upgrades.
The SNCR system has adequate capacity to accommodate the additional ammonia demand resulting from
the system upgrades. The additional ammonia ports to be added in this project will improve the SNCR
system’s effectiveness to control NOX emissions and minimize ammonia slip emissions to the atmosphere.

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Emissions from the loading and storage of ammonia have been calculated in the emissions calculations in
Appendix B.
3.1.9 Removal of Sources
3.1.9.1 Clinker Tunnel Dust Collectors
The Leamington Plant has five (5) small dust collectors that pick-up dust in the underground clinker tunnel.
The purpose of these dust collectors is to remove any dust from the tunnel at belt transfer points for safety
of the workforce. Four (4) of these dust collectors vent directly into the tunnel; their emissions do not make
it to the atmosphere. Ash Grove requests to remove these dust collectors from its existing permitted
emissions inventory. These emission units are listed in the Leamington Plant’s AO and Title V as the
following sources:
► East clinker silo discharge baghouse (511.BF1);
► West clinker silo discharge baghouse (511.BF2);
► Limestone Silo Discharge (512.BF2); and
► Gypsum silo discharge baghouse (511.BF4).
3.1.9.2 Cement Product Silo Dust Collectors
The Leamington Plant has two (2) baghouses that control the loading of cement products into trucks from
the cement silos. These baghouses are three (3) levels up into the silos’ interstitial space (approximately 40
feet). Both dust collectors vent directly into the interior of the silo structure and not vented into the
atmosphere. Ash Grove requests to remove these dust collectors from its existing permitted emissions
inventory. These emissions units are listed in the Leamington Plant’s AO and Title V as the following
sources:
► Two (2) pulse jet baghouses, 611.BF4 and 611.BF5 (Each 2,825 acfm and 682 ft2 filter area).

3.1.10 Shipping Emergency Generator
Ash Grove has added SO2 and CO emissions to the site-wide total to account for the emissions from this
generator to be comprehensive with its emissions inventory. The NOx emissions were corrected with the
most recent Approval Order.

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4. PSD APPLICABILITY ANALYSIS
As described previously, Ash Grove is proposing to increase the throughput of limestone from the quarry to
supply the second finish mill to increase the amount of low-carbon cement from the Leamington Plant.
Additionally, along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
increased and the clinker cooler will be reconstructed. These changes are anticipated to result in an increase
of clinker production. Emission calculations for this project have been completed assuming an increase in
clinker production capacity while utilizing current fuel types. This will result in a minor increase in
throughput of fuel.
The Leamington Plant is considered an existing major source under PSD based on potential emissions of
PM10, PM2.5, NOX, CO, SO2, and CO2e. If a major source will undergo a physical or operational change, the
facility must determine whether the project will be considered a major modification. Per 40 CFR
52.21(b)(2)(i), in order to be a major modification, the project must result in a significant emissions
increase, and a significant net emissions increase. Per 40 CFR 52.21(b)(3), the net emissions increase
applicability test includes evaluating the pollutant increases and decreases associated with the proposed
project, as well as any projects occurring contemporaneously. If a significant emissions increase and a
significant net emissions increase results, then PSD permitting is required, which is determined on a
pollutant-specific basis. The following approach was taken to determine the applicability of each pollutant
for a PSD major modification.
4.1 Calculation Methodology
For all pollutants, the project emissions increase was calculated as the difference between the projected
actual emissions (PAE) after the proposed project and the actual emissions prior to
the project (baseline actual emissions or BAE).
4.1.1 Projected Actual Emissions
Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
“…projected actual emissions means the maximum annual rate, in tons per year, at which an existing
emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years (12-month
period) following the date the unit resumes regular operation after the project, or in any one of the 10
years following that date, if the project involves increasing the emissions unit's design capacity or its
potential to emit that regulated NSR pollutant and full utilization of the unit would result in a significant
emissions increase or a significant net emissions increase at the major stationary source.”
Ash Grove estimates that the projected actual production capacity following the project will be 1,186,250
tons of clinker per year and 1,873,954 tons of limestone per year. These capacities were used to calculate
projected actual emissions from the project using representative emission factors. Additionally, to estimate
emissions from material transfer baghouses, the actual flow rates and actual projected hours were used as
a basis for projected actual emissions.
4.1.2 Baseline Actual Emissions
Baseline actual emissions are defined at 40 CFR 52.21(b)(48)(ii) as:

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“…baseline actual emissions means the average rate, in tons per year, at which the emissions unit actually emitted the pollutant during any
consecutive 24-month period selected by the owner or operator within the 10-year period immediately preceding either the date the owner
or operator begins actual construction of the project, or the date a complete permit application is received by the Administrator.”
Ash Grove has selected to use year 2020 and 2021 for each pollutant as the baseline years as demonstrated in Table 4-1 below.
Table 4-1 Baseline Period by Criteria Pollutant (Trinity will add with new Calculations)
Year
Emissions (tpy) Clinker
PM10 PM10
Filterable PM2.5 PM2.5
Filterable PM CON SO2 NOX VOC CO Lead CO2e Produced
(tons)
2020 120.23 108.32 68.17 56.26 11.91 1.53 1,160.38 60.02 4,006.90 0.03 638,834 803,402
2021 118.10 111.71 64.21 57.82 6.39 12.22 1,212.77 50.92 2,622.57 0.03 643,936 809,972
Baseline 119.16 110.02 66.19 57.04 9.15 6.87 1,186.58 55.47 3,314.73 .03 641,385 806,687
4.1.3 Could Have Been Accommodated Emissions
In calculating project emissions increase, USEPA allows the exclusion of existing production/emissions rates
that could have been accommodated during the baseline period. These “could have been accommodated”
emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as follows:

“…Shall exclude, in calculating any increase in emissions that results from the particular project, that portion of the unit's emissions
following the project that an existing unit could have accommodated during the consecutive 24-month period used to establish the
baseline actual emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project, including any
increased utilization due to product demand growth;”
Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the exclusion of existing production and emissions
rates that could have been accommodated during the baseline period, it has elected not to use this exclusion at this time. Therefore,
calculation of the could have accommodated emissions have not been included in this application’s applicability analysis.

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4.2 Project Emissions Calculations
4.2.1 Kiln and Coal Mill System Modifications
Project emission increases from the kiln and coal mill systems are calculated for all criteria pollutants based
on emission factors that are derived from stack testing, CEMS data, or emission factors (i.e., VOCs and
Lead), and the associated projected incremental clinker increase. Additional information for each criteria
pollutant is described below.
4.2.1.1 NOX, CO, SO2, VOC, and Lead Emission Calculations
NOX emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain hourly
capacity to emit and annual potential to emit at current levels. The kiln’s NOX emissions rate will not change
as a result of the physical modifications proposed by the project. The project’s NSPS hourly capacity
assessment is a separate analysis from the PSD Analysis and is presented in Section 5 of the application.
Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission factor and
multiplied by the incremental increase in clinker production. The emission factor was selected based on the
average of the 24-month consecutive month emissions for 2020 and 2021.
The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing conducted at the
plant.
VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production.
The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln are
presented in Appendix B.
4.2.1.2 PM10 and PM2.5 Emission Calculations
Project emissions of PM10 and PM2.5 were calculated from a site specific lb/ton emission factor and multiplied
by the incremental increase in clinker production. The emission factors are based on stack testing conducted
at the site. Condensable PM emissions were included when assessing project emissions of PM10 and PM2.5
pursuant to 40 CFR 52.21(b)(50)(i)(a). This application of condensable PM to PM10 and PM2.5 is performed
to comply with PSD requirements when evaluating project increases. This analysis does not change how
condensable PM is evaluated with respect to existing permit limits that were established at the time of
permitting. Project emissions are presented in Appendix B.
4.2.1.3 GHG Emission Calculations
GHG emissions are monitored by a CEMS and were reported in the 2020 and 2021 emission inventory (i.e.,
reported in Utah’s SLEIS). The clinker production from 2020 and 2021 was used to calculate an average
2020/2021 GHG emission factor for CO2e equivalent. The CO2e emission factor was multiplied by the
incremental increase in clinker production to calculate the project’s GHG emission increases as presented in
Appendix B.

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4.2.2 Associated Emissions Increases
As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from the
proposed project, each increase of emissions from both existing and new sources shall be summed together
and compared to the PSD permitting thresholds. The increase of emissions is the “positive” difference
between the projected actual emissions and baseline actual emissions (projected minus baseline).
4.2.2.1 New Emissions Sources
The actual to projected actuals calculation is not available to new emission units. For new emission units,
the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected emissions are
based on the new sources’ potentials to emit.
(40 CFR § 52.21(a)(2)(iv)(f)).
The new equipment proposed includes a second finish mill, a new rail and truck loading/loadout, and a new
kiln feed alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions, which are described
below.
► The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;
► The finish mill heater was calculated based on its maximum firing capacity and flow rates; and
► The fugitive emissions were calculated based on the projected annual throughput of the second finish
mill, the rail loadout, and clinker production.
4.2.2.2 Existing Sources
For the existing sources, the projected actual emissions are the maximum annual rates in tons per year
projected to occur during the next five (5) to ten (10) years if the existing sources’ design capacities
increase. Ash Grove Leamington projected the actual emissions for the next five (5) years based on the new
kiln system producing an annual average of 3,250 tons of clinker per day.
Detailed calculations for the projected actual emissions are provided in Appendix B of this application and
summarized in Table 4-2.
The project emissions increase is the difference between the projected actual emissions and the baseline
actual emissions. If the emissions increase is greater than the PSD significance threshold for a particular
pollutant, Ash Grove Leamington has the option of conducting a PSD review or continuing through the rest
of the steps to determine if it can “net” out of a PSD review. If the project increase is less than the PSD
significant threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant. Table 4-2 compares the potential increase of emissions to the significance threshold under PSD
permit program.

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Table 4-2. Projected Actual Increase Compared to PSD threshold (tons per year)

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant’s
Upgrade Project and ends on the date the upgrade begins operation. Only PM10,PM2.5, CO2e are in excess of
SERs and therefore considered in the netting analysis.
4.3 Netting
Ash Grove Leamington targets that the commencement of construction will be in March 2024. Therefore,
the contemporaneous period for this project is March 2019 through some future date the project upgrade
begins operation.
4.3.1 Contemporaneous Decreases
The Leamington Plant’s existing kiln emergency drive engine was replaced with an USEPA Tier 4 diesel
engine in 2022. Concurrently, the Leamington Plant permitted an increase in the capacity of 1L Cement. As
a baghouse was modified through this project it resulted in the following emissions decreases for PM10 and
PM2.5 as summarized in the table below.
Table 4-3. Kiln Drive Engine and Limestone Bypass – Contemporaneous Decrease in PM10 and
PM2.5 Emissions
Pollutant Contemporaneous
Decrease
PM10 -1.51
PM2.5 -3.94

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4.3.2 Contemporaneous Increases
As stated above, the Leamington Plant’s existing kiln emergency drive engine was replaced with an USEPA
Tier 4 diesel engine in 2022. This resulted in an increase of CO2e as demonstrated in the table below.
Table 4-4 Kiln Drive Engine Contemporaneous Increase in GHG Emissions
Pollutant Contemporaneous
Increase
CO2e 9.28
The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout in an
effort to improve truck traffic at the loadout. The resulting increase in PM10 and PM2.5 is summarized in the
table below.
Table 4-5. Third Bay Truck Loadout - Contemporaneous Increase in PM10 and PM2.5 Emissions
Pollutant Contemporaneous
Increase
PM10 1.06
PM2.5 1.06
4.4 Net Project Emissions
The increase from the project (Table 4-2) is added to the contemporaneous decreases and
contemporaneous increases (Table 4-3 and Table 4-4, respectively). The resulting calculation is then
compared to the PSD significance threshold to determine if a PSD review is applicable.
Table 4-6 Leamington Plant Upgrade Project Netting

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5. EMISSIONS RELATED INFORMATION EMISSIONS SUMMARY
A summary of the PTE is as follows:
Table 5-1. Potential Increase Compared to Current PTE (tons per year)

The following subsections describe the emission calculation methodologies used to calculate PTE from the
emission sources. The PTE emissions calculations in Appendix B have accounted for maximum potential
throughputs and/or 8,760 hours
5.1.1 Kiln and Coal Mill System Modifications
5.1.1.1 Criteria Pollutants
The approach to developing a PTE for the criteria pollutants are as follows:

NOX – Actual and potential kiln NOX emissions will remain unchanged following the proposed project
changes and enhancement of the SNCR system.
CO – The improved design has been engineered to reduce actual CO emissions; therefore, the PTE will
remain the same with the upgrade project.
SO2 – Calculated from a site-specific 0.35 lb/ton emission factor and multiplied by the potential increase in
clinker production.
VOCs – Calculated based on an AP-42 emissions factor and multiplied by the potential increase in clinker
production.
Lead – Calculated based on an AP-42 emissions factor and multiplied by the potential increase in clinker
production.

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PM10 – Calculated from a site-specific lb/ton emission factor and multiplied by the incremental increase in
clinker production. The emission factors are based on stack testing conducted at the site.
PM2.5 – Same as PM10.

5.1.1.2 NOX NSPS Capacity to Emit
As previously stated, the NOX hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project. Upgrades proposed to the SNCR system will cause the NOX emissions to
remain equal to or less than pre-change NOX emissions on a pound per hour (capacity to emit) basis. A pre-
change NOX hourly capacity to emit has been calculated for the kiln in accordance with the NSPS, 40 CFR
60, Appendix C - Determination Emission Rate Change. To develop a baseline, Ash Grove used the past ten
(10) years of NOX continuous emissions data (i.e., since the SNCR was installed) to establish the NOx
capacity to emit based on the maximum rolling three-hour average emission rate. This approach is
consistent with Appendix C in that it calculates a three-hour average in the same manner that stack test
results are used to calculate an average of three one-hour runs. While this methodology may underestimate
the hourly capacity to emit without upgrades, it is a good approximation of recent operational levels. The
SNCR upgrades will maintain the hourly NOx emission rate at or below this emission rate after the change,
as demonstrated in the table below.
Table 5-1 NOX lb/hr Capacity to Emit for NSPS Determination of Change
Emissions Rate lb/hr
Highest NOX 3-hour Average Prior to the Project Change 479.4
Highest NOX 3-hour Average Following the Project Change 479.4

5.1.1.3 HAP Calculations
HAP emissions reported in the 2020 and 2021 emission inventory (i.e., reported in Utah’s SLEIS) and the
clinker production from the respective years were used to create a baseline HAP emission factor for each
HAP. The HAP emission factor was multiplied by the new clinker production to calculate the project HAP
emission increases as presented in Appendix B.
5.1.2 Clinker Cooler
A change in air flow rate will occur with the reconstructed clinker cooler resulting from both the replacement
and addition of fans and modifying the baghouse from a plenum pulse to pulse jet.
As a modified source, the clinker cooler will be reconstructed. Reconstruction of the source needs to meet
0.2 lb of PM per ton of clinker to meet NSPS, Subpart F.
For PM10, and PM2.5, it is estimated that 70% of fugitive emissions have a particle diameter size of 10
micrometers or less. Additionally, it is estimated that only 15% of fugitive emissions with a diameter of 10
micrometers or less are considered PM2.5, consistent with the Bay Area Air Quality Management District

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(BAAQMD) Permit Handbook, Section 11.5 Concrete Batch Plants.4 Emission estimates are calculated as
follows:
Controlled Daily PM Emissions (lbs
day)
=
Outlet Grain Loading (gr
dscf)× Baghouse Capacity (dscfm)× 60 (min
hr )× Potential Working Hours per day (hr
day)
7,000(gr
lbs)

Controlled Annual PM Emissions (tpy)
=
Outlet Grain Loading (gr
dscf)× Baghouse Capacity (dscfm)× 60 (min
hr )× Potential Working Hours per year(hr
yr)
7,000(gr
lbs) × 2,000 (lbs
ton)

𝑂𝐿10 =𝑂𝐿× 0.7
𝑂𝐿2.5 =𝑂𝐿10 × 0.15
5.1.3 New Finish Mill and Kiln Feed Alleviator Baghouses
5.1.3.1 PM10 and PM 2.5 sources
Baghouses. The new baghouses will be guaranteed for a grain outlet loading of 0.005 gr/dscfm for PM10.
Finish mill emissions were calculated as follows:
𝐴𝑘𝑘𝑟𝑎𝑘 𝐷𝑘�ℎ𝑟𝑟�ℎ𝑘𝑘𝑟 (𝑟𝑘𝑤)
=𝑂𝑟𝑟𝑘𝑎𝑟 𝐷𝑟𝑎�ℎ𝑘 𝐿𝑘𝑎𝑎�ℎ𝑘𝑎 (𝑎𝑟
𝑎𝑟𝑎𝑎)∗𝐷𝑘𝑘𝑤𝑟𝑎𝑟𝑎 (𝑎𝑟3
𝑘�ℎ𝑘)∗60 𝑘�ℎ𝑘
�𝑟∗8,760 �𝑟
𝑤𝑟∗1 𝑘𝑎
7,000 𝑎𝑟∗1 𝑟𝑘𝑘
2,000 𝑘𝑎
5.1.3.2 Finish Mill Heater
This project includes one (1) 10.43 MMBTU/hr natural gas-fired burner. Criteria pollutants were calculated
as follows:
NOX. The manufacturer for this unit has guaranteed a NOx emission rate of 30 ppm for the natural gas fired
unit. Total annual emissions for NOx has been calculated as follows:

4 BAAQMD Permit Handbook, Section 11.5 Concrete Batch Plants, Pg. 205.

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Emission Rate (lb
hr)
=Exhaust Flowrate (acf
min)
∗
(

Pressure (1 atm)
Universal Gas Constant 0.73024 (atm ∗ft3
lbmol ∗R)∗Temperature (R)
∗(46.01 lb
mol)
)

∗60min
hr ∗Concentration (ppm)
106
CO, VOC, PM10, PM2.5, SO2 and lead emissions from the proposed burner are calculated using the emission
factors found in the Fifth Edition (2006) of AP-42 Section 1.4. Emission rates for these pollutants can be
calculated through the following equation:
Hourly Emission Rate (lb
hr)=
(Emission Factor (lb
MMscf)∗Heat Input (MMBTU
hr ))
Natural Gas Heating Value (BTU
scf )

GHG emissions from natural gas combustion are calculated using the methodology contained in the EPA
GHG Mandatory Reporting Rule (MRR) located at 40 CFR Part 98. Individual GHG emissions from natural gas
combustion are calculated using the equation listed above. The calculated emissions of individual GHGs are
then converted to CO2e by multiplying by the corresponding GWP for each GHG. The total CO2e emission
from proposed changes is calculated as follows:

()
()310GWP ON x yr
ONton Emission ON Annual
21 GWPCH x yr
CHton Emission CH Annual yr
COton Emission CO Annual yr
ton eCO Total
2
2
2
4
4
4
2
22


+


+

=



5.1.4 Grinding Aid VOC Emissions from New Finish Mill
Grinding aid emissions. Project emissions of VOC were calculated from a gallon per ton of clinker multiplied
by the incremental increase in clinker production. The emission factors are based on an average of two (2)
stack tests conducted at a similar, representative site.
5.1.5 New Rail Unloading and Truck Loadout
See new finish mill and Kiln Alleviator Baghouse PM10 and PM2.5 Section above to calculate the outlet of
baghouses using a grain outlet loading calculation. The new baghouse will be guaranteed for a grain outlet
loading of 0.005 gr/dscfm for PM10.

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5.1.6 Fugitive Emissions
5.1.6.1 Bulldozing and Grading
Bulldozing
Bulldozers will be used at the Leamington Plant during quarrying operations. After blasting, the shot rock is
loaded into haul trucks via front-end loaders. After this process is complete, bulldozers may be used to clean
up the blast area, clear space for other quarry equipment, and build pioneering roads. Depending on quarry
terrain, a bulldozer may be used to clear shot rock. Road grading occurs on an as-needed basis in the
quarry.
PM10 and PM2.5 emissions generated from bulldozing were calculated assuming one (1) bulldozer operating
8,760 hours per year. Similarly, PM10 and PM2.5 emissions generated from grading were calculated assuming
one (1) grader operating 900.5 hours per year. Bulldozer and grading emissions are multiplied by emission
factors given in AP-42, Section 11.9 (October 1998). AP-42 Table 11.9-1 provides the following equations
for calculating emission factors for total suspended solids (TSP) and PM15 from bulldozing operations:
TSP (lb
hr)=5.7(s)1.2
(M)1.4
PM15(lb
hr)=1.0(s)1.5
(M)1.4
where:
s = material silt content (%)
M = material moisture content (%)
Values for these parameters were obtained from AP-42 Table 11.9-3; the geometric mean was used: 6.9%
for the silt content and 7.9% for the moisture content.
The emission rates calculated using the above equations were multiplied by a scaling factor obtained from
AP-42 Table 11.9-1. For bulldozing, scaling factors of 0.75 and 0.105 were used for PM10 and PM2.5
emissions, respectively. For grading, 0.60 and 0.031 were used as scaling factors for PM10 and PM2.5,
respectively. Water spraying will be used as appropriate to control particulate emissions. A 70% control
efficiency is claimed, per the Western Regional Air Partnership's (WRAP's) Fugitive Dust Handbook (2006).
The average is used for conservatism. Total emissions were then calculated:
Total Hourly PM10 (lb
hr)= PM15 (lb
hr)∗PM10 Scaling Factor
Total Hourly PM2.5 (lb
hr)= PM15 (lb
hr)∗PM2.5 Scaling Factor

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Grading
Road grading operations will be performed to create and maintain roads at Leamington Plant. Grading
operations generate fugitive PM10, and PM2.5 emissions. To calculate these emissions, the following
assumptions were applied:
• Annual vehicle miles traveled (VMT) varies, and is determined by engineering design basis;
• Daily VMT is determined by dividing the annual VMT by the expected working days per year (365
days/yr);
• Road grading equipment will travel 4 mph per engineering design basis; and
• Watering provides an 70% control efficiency.5
5.1.6.2 Disturbed Areas
Disturbed area in the quarry is anticipated to increase with the increase in annual clinker throughput.
Disturbed grounds emissions represent emissions propagated from the active mining area. The disturbed
area acreage is determined per engineering design basis. For disturbed grounds, the TSP emission factor is
obtained from AP-42 Section 11.9 (Western Surface Coal Mining), table 11.9-4, July 1998. PM10 and PM2.5
emission factors are obtained using the particle size multipliers provided from AP-42 Section 13.2.5.3
(Industrial Wind Erosion), November 2006.
The PM10 emission factor for disturbed grounds is calculated as follows:
𝑂𝐿10 =𝑆𝑆𝑂× 0.5
The PM2.5 emission factor for disturbed grounds is calculated as follows:
𝑂𝐿2.5 =𝑆𝑆𝑂× 0.075
Annual disturbed area emissions are calculated as follows:
𝐴𝑘𝑘𝑟𝑎𝑘 𝐷𝑘�ℎ𝑟𝑟�ℎ𝑘𝑘𝑟 (𝑟𝑘𝑤)= 𝐷𝑘�ℎ𝑟𝑟�ℎ𝑘𝑘 𝐷𝑎𝑎𝑟𝑘𝑟 (𝑟𝑘𝑘
𝑎𝑎𝑟𝑎−𝑤𝑎𝑎𝑟)∗𝐿𝑎𝑤�ℎ𝑘𝑟𝑘 𝐷�ℎ𝑟𝑟𝑟𝑟𝑎𝑎𝑎 𝐴𝑟𝑎𝑎 (𝑎𝑎𝑟𝑎𝑟)
Daily disturbed area emissions are calculated as follows:
𝐷𝑎�ℎ𝑘𝑤 𝐷𝑘�ℎ𝑟𝑟�ℎ𝑘𝑘𝑟 (𝑘𝑎𝑟
𝑎𝑎𝑤)= 𝐴𝑘𝑘𝑟𝑎𝑘 𝐷𝑘�ℎ𝑟𝑟�ℎ𝑘𝑘𝑟 (𝑟𝑘𝑤)÷ 𝐴𝑘𝑘𝑟𝑎𝑘 𝑊𝑘𝑟𝑘�ℎ𝑘𝑎 𝐷𝑎𝑤𝑟 (𝑎𝑎𝑤
𝑤𝑎𝑎𝑟)∗2,000 (𝑘𝑎𝑟
𝑟𝑘𝑘)
5.1.6.3 Drilling and Blasting

5 An RBLC search of Process Code 99.190 identified one (1) source whose bulldozing emissions were controlled by 90%
through watering (Indiana Gasification LLC). For conservatism, a slightly lower control efficiency of 70% was used for
emission calculations.

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Drilling
Drilling operations precede blasting operations, allowing for the placement of explosives beneath the surface
of the mine’s exposed area. The increased quantity of drilling calculated represents an incremental increase
for the additional limestone to be mined.
For drilling emissions, the following assumptions are applied:
The drilling PM EF is retrieved from AP-42 Section 11.9, utilizing the conservative drilling PM EF given for
overburden material. As no EFs are provided for PM10 and PM2.5 drilling operations, EFs were calculated
using the PM10 and PM2.5 to TSP ratios for blasting overburden per AP-42 Section 11.9, where the factor for
PM10 is 0.52 and the factor for PM2.5 is 0.03, as shown below;
EFPM10 =EFPM15 × 0.52
And
EFPM2.5 =EFTSP × 0.03
For the purposes of determining the PM10 and PM2.5 EFs, the EF for PM, PM15, and TSP are considered
equivalent.
The daily emissions of PM10, and PM2.5 were calculated as follows:
Daily Emissions (lb
day)=EF (lb
hole)× Daily # of Holes (holes
day )× (1 −%control)
Where both the daily emissions and the EF are those of the pollutant in question (i.e., PM10 or PM2.5).
The annual emissions of PM10, and PM2.5 were calculated as follows:
Annual Emissions (tpy)=EF (lb
hole)× Annual Holes Drilled (holes
year )× (1 −%control)× Conversion (ton
lb )
Where both the annual emissions and the EF are those of the pollutant in question (i.e., PM10 or PM2.5).
Blasting
For the Leamington Plant to produce limestone as a raw material, drilling and blasting operations will be
conducted within the mining area to produce raw material in a manageable size, which will then be
transported via bulldozer/front-end loaders to the crushing and screening operations. The projected blasting
area is 686,857 square feet (ft2) on a rolling 12-month period and was provided per design basis. This new
square footage and increased number of blasts represents an incremental increase for the additional
limestone to be mined.
The blasting SO2 emission factor is obtained from AP-42 Section 13.3-1. The SO2 EF was developed using a
mass balance that assumes a 6% fuel oil mixture with 500 ppm sulfur content, consistent with EPA non-
road standards.

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EFSO2 (lb
ton)=Sulfur Content (ppm)× %Fuel Oil Mixture × Conversion
The NOX EF, given in pounds per ton of ANFO used, is the average of measurements from "NOX Emissions
from Blasting Operations in Open-Cut Coal Mining" by Moetaz I. Attall, Stuart J. Day, Tony Lange, William
Lilley, and Scott Morgan (2008). The CO EF, given in pounds per ton of ANFO used, is the average of
measurements in "Factors Affecting ANFO Fumes Production" by James H. Rowland III and Richard Mainiero
(2001). PM10 and PM2.5 EFs were based on the blasting PM EF given in AP-42 11.9, where a maximum
blasting depth of 70 feet is used, by the following equation:
EFPM (lb
blast)=1.4 × 10−5 × A(ft2)1.5
Where EFPM is the EF of PM in pounds per blast, and A is the average daily blast area in square feet.
Scaling factors were applied to the TSP EF to calculate PM10 and PM2.5 EFs, respectively, per AP-42 Table
11.9, as seen below. It is conservatively assumed that the PM EF is equal to the TSP EF.
EFPM10 (lb
blast)=EFPM (lb
blast)× 0.52
EFPM2.5 (lb
blast)=EFPM (lb
blast)× 0.03
Where EFPM10 is the EF of PM10 given in pounds per blast and EFPM2.5 is the EF of PM2.5 given in pounds per
blast. It is assumed that pounds per blast is equivalent to pounds per day.
Daily fugitive dust (PM10, and PM2.5) blasting emissions were calculated using blasting material quantities,
which were provided per design basis. Blasting emissions are calculated as follows:
Daily Fugitive Dust Emissions (lbs
day)=EF (lbs
blast)× (1 −%control)× (1 blast
day )
where the EF is that of PM10, or PM2.5, whichever is calculated.
Annual fugitive dust (PM10, and PM2.5) blasting emissions are given as follows:
Annual Emissions (tpy)=Daily Fugitive Dust Emissions (lbs
day)× Annual # of Blasts × Conversion (tons ⋅day
lb ⋅year )
Where the Daily Fugitive Dust Emissions are those of PM10 or PM2.5, whichever is calculated.
Daily emissions for SO2, NOX, and CO are calculated for each pollutant as follows:
Daily Emissions (lbs
day)=EF (lbs
ton)× Annual ANFO Use (tpy)× Conversion (year
days)

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5.1.6.4 Material Loading, Unloading and Transfer
Material handling operations at the Leamington Plant include loading and unloading of limestone to and
from haul trucks, material drops from conveyor belts, and material drops from haul trucks to stockpiles.
Particulate matter (PM10 and PM2.5) emissions are fugitively released from these operations and were
estimated based on material throughput, emission factors, and control efficiencies. Most of the calculations
account for additional throughput, but additional sources of material drops were also added.
Emission factors for material drops were calculated using the drop equation from AP-42 Section 13.2.4,
Aggregate Handling and Storage Piles (11/2006):
EF =k(0.0032)∗
(U
5)
1.3
(M
2)
1.4
where:
EF = emission factor (lb/ton material)
k = particle size multiplier
U = mean wind speed (miles per hour)
M = material moisture content (%)
The particle size multiplier k varies with particle diameter; 0.35 was used for PM10 and 0.05 was used for
PM2.5 emissions, per AP-42 Section 13.2.4. A mean wind speed of 10 mph was obtained from UDAQ’s
Average Annual Wind Speed map (11/2000), and a moisture content of 2% was used per UDAQ’s historical
recommendations for stone materials.
Material throughputs are estimated by multiplying existing maximum throughputs (i.e., the maximum design
throughputs prior to this project) by an increase factor. This increase factor is a conservative engineering
estimate based on the additional processing capacity expected to be obtained by this project.
Maximum daily and total annual emissions for each material handling emission source were then calculated:
Max Daily Emissions (lb
day)=EF (lb
ton)∗Throughput (ton
day)
Total Annual Emissions (ton
year)=EF(lb
ton)∗Throughput (ton
year)∗1 ton
2,000 lbs
Enclosures
A control factor was applied to drops where an enclosure exists or has been proposed with the plant
upgrade project. See Appendix B for emissions calculations.

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5.1.6.5 Stockpiles
The pile area is multiplied by a UDAQ-specified EF, along with several conversion factors, to determine the
potential emissions associated with each stockpile. EFs are chosen based on what size the particle is (PM2.5
or PM10), and whether the stockpile is controlled or uncontrolled, and active or inactive. All stockpiles will be
controlled with water application and are considered “active” during days of operation and “inactive” during
days without operation. Uncontrolled EFs were obtained from AP-42 Fourth Edition Table 8.19.1-1 and AP-
42 Appendix B.2 Table B.2-2.6,7
Annual Stockpile Emissions (tpy)=Max.Pile Area (acre)× EF (lb
day ⋅acre)× Conversion(365 day × 1 ton
1 year × 2,000 lb)
5.1.6.6 Roads
Loaders and haul trucks travel on various paved and unpaved haul and access roads throughout the
Leamington Facility, generating PM10 and PM2.5 emissions. The existing roads’ emissions have been
calculated to account for additional vehicle miles traveled for raw materials and products. Three (3) new
roads or road lengths which include: 1) Unpaved into the quarry for Limestone Bypass; 2) Paved new finish
mill raw materials; and 3) Paved rail loading.
Unpaved Roads
There are about 10 miles of roads within the facility, some of which are unpaved. Road emissions are
calculated based on Vehicle Miles Traveled (VMT), emission factors, and control efficiency. The haul and
dump truck VMT was calculated by multiplying the number of trips and round-trip distance traveled by the
truck. Uncontrolled PM10 and PM2.5 emission factors were calculated using the following equations from AP-
42, Section 13.2.2 (November 2006).
E (lb
VMT)=k(s
12)a (W
3 )
b

where:
E = size-specific emission factor (lb/VMT)
k = 1.5 (PM10 constant), 0.15 (PM2.5 constant)
a = 0.9 (PM10 and PM2.5 constant)
b = 0.45 (PM10 and PM2.5 constant)

6 AP-42 Fourth Edition, Table 8.19.1-1.
7 AP-42 Appendix B.2, Table B.2-2.

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s = surface material silt content (4.8%, per UDAQ Guidance8)
W = mean vehicle weight (tons)
The Leamington Plant will control particulate emissions from roads via chemical application, water
application, and road base. A control efficiency of 85% is claimed for these activities, per UDAQ guidance.9
Maximum daily and total annual emissions were then calculated:
Maximum Daily Emissions (lb
day)
=E (lb
VMT)∗Max Daily Vehicle Miles Traveled (VMT)∗(1 − Control Efficiency [%])
Total Annual Emissions (ton
year)
=E (lb
VMT)∗Annual Vehicle Miles Traveled (VMT)∗(1 −Control Efficiency [%])∗1 ton
2,000 lbs
Paved Roads
For paved roadways interior to the Leamington Plant, emissions were calculated using the same equation,
but a control efficiency of 95% is claimed for these activities, per UDAQ guidance. This is due to the use of
vacuum sweepers and water application.10Error! Bookmark not defined.
5.1.7 Material Transfer
Material transfer will increase with additional limestone, pozzolans, silica, iron, and shale raw materials.
From the reclaim pile forward, material is transferred by conveyor belt, screw conveyor, bucket elevator, or
pneumatic transfer. The conveyance systems are enclosed. Transfer points are controlled via a baghouse.
Therefore, baghouse emissions have been calculated. The following areas of the plant are controlled by
baghouses and considered in the calculations.
• Material Sizing and Handling, including Crushing and Screening;
• Loading and Unloading;
• Raw Material Handling;
• Plant and Existing Finish Mill Material Handling;
• Coal Material Handling; and
• Existing Truck and Rail Product Loadout.
For PM10 and PM2.5 emissions calculation from existing baghouses, see New finish mill PM10 and PM2.5
Section above to calculate the outlet of baghouses using a grain outlet loading calculation. The existing
baghouses will be changed from their current 0.016 grain outlet loading to a grain outlet loading of 0.007
gr/dscfm, unless otherwise specified.

9 UDAQ Emission Factors for Paved and Unpaved Haul Roads, January 2015
10 Ibid.

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5.1.8 Tank Calculations
This project includes additional throughput of ammonia in the existing ammonia system. Each storage tank
is assumed to be a horizontal fixed-roof (HFR) storage tank. Annual ammonia emissions from fixed-roof
storage tanks are calculated by summing the standing storage loss and working loss as shown from the
Fifth Edition (2006) of AP-42 Section 7.1 (Updated March 2020) Equation (1-1):

Where:
LT = total losses (lb
yr)
LS = standing storage losses (lb
yr)
LW = working losses (lb
yr)

The standing storage loss and working loss components of the total loss equation are discussed in the
following subsections.
5.1.9 Vertical Fixed Roof – Standing Storage Loss
Annual fixed-roof tank standing losses are estimated using Equation (1-2) from Fifth Edition of
AP-42 Section 7.1 (Updated March 2020).

Ls =365 (Vv)( Ww)(KE)(KS)
Where:
LS = Standing storage loss (lb
yr)
VV = Vapor space volume (ft3)
Wv = Stock vapor density (lb
ft3)
KE = Vapor space expansion factor (Dimensionless)
KS = Vented vapor saturation factor (Dimensionless)
365 = Constant, the number of daily events in a year (1
yr)

5.1.10 Tank Vapor Space Volume (VV)

The tank vapor space volume (VV) is calculated using Fifth Edition of AP-42 Section 7.1 (Updated March
2020) Equation (1-3):

Where:
VV = vapor space volume (ft3)
D = tank diameter, (ft)
HVO = vapor space outage (ft)

The vapor space outage, HVO, is estimated from Fifth Edition of AP-42 Section 7.1 (Updated March 2020)
Equation (1-16):
LT = LS + LW
VV =(π
4 D2)HVO

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Where:
HVO = vapor space outage (ft)
HS = tank shell height (ft)
HL = liquid height (ft)
HRO = roof outage, cone, or dome roof (ft)

5.1.11 Vapor Space Expansion Factor (KE)

The vapor space expansion factor (KE) is calculated using Fifth Edition of AP-42 Section 7.1 (Updated March
2020) Equation (1-5):

Where:
KE = vapor space expansion factor
ΔTV = daily vapor temperature range (°R)
ΔPV = daily vapor pressure range (psi)
ΔPB = breather vent pressure setting range (psi)
PA = atmospheric pressure (psia)
PVA = vapor pressure at daily average liquid surface temperature (psia)
TLA = daily average liquid surface temperature (°R)

The daily vapor temperature range is calculated using Fifth Edition of AP-42 Section 7.1 (Updated March
2020) Equation (1-7).

∆Tv =0.7∆TA +0.02αI

Where:
ΔTV = daily vapor temperature range (°R)
ΔTA = daily ambient temperature range (°R)
α = tank paint solar absorptance (dimensionless)
I = daily total solar insolation factor (BTU
ft2∗day)

The true vapor pressure of organic liquids can be estimated by using Antoine’s equation as shown in Fifth
Edition of AP-42 Section 7.1 (Updated March 2020) Equation (1-26) or Fifth Edition of AP-42 Section 7.1
(Updated March 2020) Tables 7.1-3.

log10(PVA)=A −(B
TLA +C)
Where:
TLA = daily average liquid surface temperature (°C)
PVA = vapor pressure at daily average liquid surface temperature (mm Hg)
HVO = HS −HL +HRO
KE =∆TV
TLA
+∆PV −∆PB
PA −PVA

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A = constant in vapor pressure equation (dimensionless)
B = constant in vapor pressure equation (°C)
C = constant in vapor pressure equation (°C)

The daily vapor pressure range is calculated using Fifth Edition of AP-42 Section 7.1 (Updated March 2020)
Equation (1-9).

Where:
ΔPV = daily vapor pressure range (psia)
PVX = vapor pressure at the daily maximum liquid surface
temperature
(psia)
PVN = vapor pressure at the daily minimum liquid surface
temperature
(psia)

The vapor pressures at the daily maximum and minimum liquid surface temperatures may be calculated by
substituting the daily maximum and minimum liquid surface temperatures into the vapor pressure functions
discussed above. Note that for the purposes of the emission calculations, vapor pressure at the daily
maximum liquid surface temperature, daily average surface temperature, and daily minimum liquid surface
temperature were assumed to be equivalent since a majority of the tanks are temperature controlled and/or
indoors.

The daily maximum and minimum liquid surface temperatures are calculated using Fifth Edition of AP-42
Section 7.1 (Updated March 2020) Figure 7.1-17.

Where:
TLX = daily maximum liquid surface temperature (°R)
TLA = daily average liquid surface temperature (°R)
ΔTV = daily vapor temperature range (°R)
TLN = daily minimum liquid surface temperature (°R)

The breather vent pressure setting range is calculated using Fifth Edition of AP-42 Section 7.1 (Updated
March 2020) Equation (1-10).

Where:
ΔPB = breather vent pressure setting range (psig)
PBP = breather vent pressure setting (psig)
PBV = breather vent vacuum setting (psig)

The daily ambient temperature range is calculated using Fifth Edition of AP-42 Section 7.1 (Updated March
2020) Equation (1-11).

∆PV =PVX −PVN
TLX =TLA + 0.25∆TV
TLN =TLA − 0.25∆TV
∆PB =PBP −PBV

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Where:
ΔTA = daily ambient temperature range (°R)
TAX = daily maximum ambient temperature (°R)
TAN = daily minimum ambient temperature (°R)

The daily average liquid surface temperature is calculated using Fifth Edition of AP-42 Section 7.1 (Updated
March 2020) Equation (1-28).

TLA =0.4TAA +0.6TB +0.005αI

Where:
TLA = daily average liquid surface temperature (°R)
TAA = daily average ambient temperature (°R)
TB = liquid bulk temperature (°R)
α = tank paint solar absorptance (dimensionless)
I = daily total solar insolation factor (BTU
ft2∗day)

The daily average ambient temperature is calculated using Fifth Edition of AP-42 Section 7.1 (Updated
March 2020) Equation (1-30).

Where:
TAA = daily average ambient temperature (°R)
TAX = daily maximum ambient temperature (°R)
TAN = daily minimum ambient temperature (°R)

The liquid bulk temperature is calculated using Fifth Edition of AP-42 Section 7.1 (Updated March 2020)
Equation (1-31).

TB = TAA +0.003α𝑟I

Where:
TB = liquid bulk temperature (°R)
TAA = daily average ambient temperature (°R)
αs = tank shell surface solar absorptance (dimensionless)
I = daily total solar insolation factor (BTU
ft2∗day)
5.1.12 Vapor Space Expansion Factor (Ks)

The vented vapor saturation factor, KS, is calculated using Fifth Edition of AP-42 Section 7.1 (Updated March
2020) Equation (1-21):

∆TA =TAX −TAN
TAA =TAX +TAN
2

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Where:
KS = vented vapor saturation factor (dimensionless)
PVA = vapor pressure at daily average liquid surface temperature (psia)
HVO = vapor space outage (ft)
5.1.13 Stock Vapor Density (WV)
The density of the vapor, WV, is calculated using Equation (1-22) from Fifth Edition of AP-42 Section 7.1
(Updated March 2020).
WV =MVPVA
RTV

Where:
WV = vapor density (lb
ft3)
R = the ideal gas constant (10.731 psia ft3
lbmol °R )
PVA = vapor pressure at daily average liquid surface temperature (psia)

MV = vapor molecular weight,
(Fifth Edition of AP-42 Section 7.1
(Updated March 2020) Tables 7.1-2 and
7.1-3)
(lb
lbmol)
Tv = Average vapor temperature, (Fifth Edition
of AP-42 Section 7.1 (Updated March
2020) Eqn. 1-33

(°R)
5.1.14 Horizontal Fixed Roof – Working Loss
Annual fixed roof tank working losses are estimated using Equation (1-35) from Fifth Edition of AP-42
Section 7.1 (Updated March 2020).

Lw =VQKNKPWVKB

Where:

Lw = Working Loss (lb
yr)
VQ = Net working loss throughput (ft3
yr)
VQ =5.614Q
Q = Tank throughput (bbl
yr )
WV = Vapor Density (lb
ft3)

KN = turnover factor, dimensionless
for turnovers > 36, KN =180+N
6N
KS =1
1 +0.053PVA HVO

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for turnovers ≤36 KN = 1
for hourly emission calculations KN = 1
KP = Working loss product factor, KP = 1
Kp = .75 for crude oils
N = Number of turnovers per year

KB = Vent setting correction factor, equal to 1 for settings +0.03 psig, dimensionless

Where:
VLX = tank maximum liquid volume (ft3)

Where:
D = diameter (ft)
HLX = maximum liquid height (ft)
5.1.15 Horizontal Fixed Roof – Hazardous Air Pollutant (HAP) Speciation
The individual HAP emissions from fixed roof storage tanks are estimated by multiplying the total loss by the
weight fraction in the vapor phase of the desired component as shown in Fifth Edition (2006) of AP-42
Section 7.1 Equation (4-1).

Where:
LTi = emission rate of component i, (lb
yr)
ZVi = weight fraction of component i in the vapor phase (lb
lb)
LT = total losses (lb
yr)

The component weight fractions in the vapor phase are calculated using Fifth Edition (2006) of AP-42
Equations (4-3) through (4-6):

xi =(ZLiML
Mi
)

Where:
xi = liquid mole fraction of component i, (lbmol
lbmol)
ZLi = weight fraction of component i in the liquid (lb
lb)
ML = molecular weight of liquid stock (lb
lbmol)
Mi = molecular weight of component i (lb
lbmol)

Where:
N =5.614Q
VLX

VLX =π
4 D2HLX
LTi =(ZVi)(LT)
Pi =(P)(xi)

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Pi = partial pressure of component i (psia)
xi = liquid mole fraction (lbmol
lbmol)
P = vapor pressure of pure component i at the
daily average liquid surface temperature
(psia)

Where:
yi = vapor mole fraction of component i (lbmol
lbmol)
Pi = partial pressure of component i (psia)
PVA = total vapor pressure of liquid mixture (psia)

ZVi =(yiMi
Mv
)

Where:
ZVi = vapor weight fraction of component i (lb
lb)
yi = vapor mole fraction of component i (lbmol
lbmol)
Mi = molecular weight of component i (lb
lbmol)
MV = molecular weight of vapor stock (lb
lbmol)

yi =Pi
PVA

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6. REGULATORY REQUIRMENTS
6.1 Federal Rules – New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable by the
best demonstrated technology as specified in the applicable provisions. Moreover, any source subject to an
NSPS is also subject to the general provisions of NSPS Subpart A unless specifically excluded. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.
► 40 CFR 60, Subpart A (General Provisions)
► 40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
► 40 CFR 60, Subpart Y (Standards of Performance for Coal Preparation and Processing Plants)
► 40 CFR 60, Subpart OOO (Standards of Performance for Nonmetallic Mineral Processing Plants)
► NSPS Subpart A – General Provisions
All affected facilities subject to a source-specific NSPS are subject to the general provisions of NSPS,
Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires initial notification,
performance testing, recordkeeping, and monitoring, provides reference methods, and mandates general
control device requirements for all other subparts.
6.1.1 NSPS Subpart F – Standards of Performance for Portland Cement Plants
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of performance
for affected facilities in Portland Cement Plants which have been constructed or modified after August 17,
1971.
There are two key dates to determine which emission standard an affected facility must meet: August 17,
1971 and June 16, 2008. If an affected facility is constructed, reconstructed or modified after June 16,
2008, the affected facility must potentially meet more stringent emission limits than an affected facility
constructed, reconstructed or modified after August 17, 1971, but on or before June 16, 2008.
40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart F: Kiln,
clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage, clinker storage,
finished product storage, conveyor transfer points, bagging and bulk loading and unloading systems.
NSPS Subpart F itself does not provide any definition of kiln or raw material dryer but MACT Subpart LLL
provides definition of these sources. Per MACT 40 CFR 63.1341 Definitions:
In-line coal mill means those coal mills using kiln exhaust gases in their process. Coal mills with a heat
source other than the kiln or coal mills using exhaust gases from the clinker cooler are not an in-line coal
mill.
Kiln means a device, including any associated preheater or precalciner devices, inline raw mills, inline coal
mills that produces clinker by heating limestone and other materials for subsequent production of Portland
cement. Because the inline raw mill and inline coal mill are considered an integral part of the kiln, for
purposes of determining the appropriate emissions limit, the term kiln also applies to the exhaust of the
inline raw mill and the inline coal mill.

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The Leamington coal mill is an in-line coal mill and, therefore, considered an integral part of the Leamington
kiln. In-line coal mills are not subject to NSPS Subpart Y.11 Therefore, for NSPS Subpart F regulatory
purposes, Ash Grove is considering the coal mill a part of the kiln, which is an affected facility under NSPS
Subpart F only.
6.1.2 Summary of Changes
As discussed earlier in this permit application, Ash Grove is proposing the following changes to the kiln
system, clinker cooler, and other portions of the plant:
1. Revisions to the calciner and replacement of portions of the preheater tower;
2. Increase the size of the induced draft fan on the kiln;
3. Upgrade the SNCR System;
4. Modify the clinker cooler, replace the clinker cooler fans, and enlarge the baghouse;
5. Installation of a second finish mill; and
6. Installation of a new rail loading and unloading system.
6.1.2.1 Kiln System (Kiln, Raw Mill and In-Line Coal Mill)
Ash Grove’s proposed changes to the kiln system must be evaluated as to whether they trigger new NSPS
Subpart F obligations based on whether the proposed project is either a modification or a reconstruction, as
those terms are defined in NSPS Subpart A.
Ash Grove’s proposed changes to the kiln system do not meet the definition of a reconstruction. As
described in NSPS Subpart A, a reconstruction occurs when the fixed capital cost of the new components
exceeds 50 percent of the fixed capital cost that would be required to construct a comparable entirely new
facility and it is technologically and economically feasible to meet the applicable standards. In order to
determine whether the proposed project meets the first of the two definition criteria, Ash Grove reviewed
project costs for upgrades to the kiln system (including the cost of the upgrades to the calciner and
preheater). The fixed capital cost to upgrade the Leamington kiln system is 25% of the cost to construct a
comparable new source. Therefore, the Leamington kiln system is not considered a reconstructed source
under NSPS Subpart F.
Ash Grove’s proposed changes to the kiln system do not meet the definition of a modification for NOx and
do meet the definition of a modification for PM and SO2. A modification occurs when, as the result of a
physical or operational change, there is an increase in the hourly capacity to emit of any pollutant to which
the standard applies. NSPS Subpart F regulates NOX, SO2 and PM. Therefore, emissions of each of those
three pollutants must be evaluated separately to determine whether an increase in the emission rate of any
of these three pollutants will occur as result of the modification.

11 74 Fed. Reg. 51952 (Oct. 8, 2009) (“a thermal dryer that is part of an in-line coal mill at a Portland cement manufacturing
plant where all of the thermal input is supplied by cement kiln exhaust or clinker cooler exhaust, is not subject to the
requirements in subpart Y, but,rather, must meet the applicable requirements in the appropriate Portland Cement kiln
regulations…”)

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Ash Grove has considered NSPS Subpart F applicability for each regulated pollutant and reached the
following conclusions as to NSPS Subpart F applicability:
► NOX: Through upgrading the kiln’s SNCR control it will allow the lb/hr emission rate to remain
unchanged.12
► SO2: The lb/hr SO2 emission rate is anticipated to increase.
► PM10: The lb/hr PM10 emission rate is anticipated to increase.
Ash Grove’s SNCR system will be upgraded to ensure sufficient ammonia residence time, temperature, and
application rate in the calciner and preheater to maintain the lb/hr NOX emissions rate at its pre-modification
levels. Therefore, the upgrades to the kiln are not defined as a modification for this pollutant.
For PM, a lb/hr emissions rate increase is anticipated with the installation of a larger induced draft fan
resulting in increased air flow through the kiln system. Therefore, a modification to the kiln system will
occur for PM.
For SO2, a lb/hr emissions rate increase is anticipated with the proposed increase in clinker throughput. As a
result, a modification to the kiln system will occur for SO2.
Accordingly, the project will be subject to the modification requirements for PM and SO2.
The standards for modification to the kiln are addressed in 40 CFR 60.62 as follows:
60.62(a)
On and after the date on which the performance test required to be conducted by §60.8 is completed, you
may not discharge into the atmosphere from any kiln any gases which:
60.62(a)(1)
Contain particulate matter (PM) in excess of:
60.62(a)(1)(iii)
Kilns that have undergone a modification may not discharge into the atmosphere any gases
which contain PM in excess of 0.07 pound per ton of clinker.
60.62(a)(4)
Exceed 0.4 pounds of sulfur dioxide (SO2) per ton of clinker on a 30-operating day rolling
average if construction, reconstruction, or modification commences after June 16, 2008.
UDAQ previously established short-term emission limits for the kiln system in Approval Order Condition
II.B.I.b. to ensure that PM10 and SO2 emissions meet the NSPS Subpart F standard. Even though actual
emissions will increase for PM and SO2, Ash Grove will be able to maintain existing permit limits consistent
with NSPS Subpart F. As a result of the proposed design changes, Ash Grove does not anticipate any

12 See Section 5.1.1.2 of the application where it defines the NOX capacity to emit (lb/hr) in accordance with 40 CFR 60,
Appendix C.

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revisions are required to the kiln’s emission limits for the kiln, raw mill and inline coal mill in Approval Order
condition number II.B.I.b, and the Leamington kiln will remain subject to 0.07 lb of PM/ton of clinker limit
and 0.4 lb of SO2 /ton clinker limit.
Ash Grove will comply with all relevant emission standards; testing requirements; monitoring,
recordkeeping, and reporting obligations that apply to the Leamington kiln system as an existing source
under NSPS Subpart F.
Monitoring - Kiln System
With the proposed reconstruction, Ash Grove will meet the monitoring requirements established in 40 CFR
60.63 for PM and SO2 as addressed in the table below:
Table 6-1 Kiln System Modification, NSPS Subpart F Monitoring Requirements
Affected Source by Pollutant Requirement Monitoring with Proposed Modification
Clinker throughput monitoring
requirements.
40 CFR 60.63(b)(1) Use the existing permanent weigh scale
system
PM - Modification of an existing
affected facility.
40 CFR 60.63(c)(1) Continue to use the Continuous Particulate
Monitoring System (CPMS) on the existing kiln
system. Demonstrate compliance through an
initial performance test on the CPMS following
the modification.
SO2 –Modification of an existing
affected facility.
40 CFR 60.63 (e) Installation of an SO2 Continuous Emissions
Monitoring System (CEMS) on the kiln stack.
Stack Gas Flow Rate. 40 CFR 60.63 (h) Use the existing flow rate monitor installed on
the stack. Use existing data for calculating SO2
lb/hr emissions.
With the installation of an SO2 CEMS, Ash Grove will submit a monitoring plan documenting continuous
monitoring system (CMS) requirements specified in 40 CFR 60.63(i)(1)(i-iii) and the UDAQ requirements in
R307-170.
6.1.2.2 Clinker Cooler
Ash Grove is planning to upgrade the existing clinker cooler system as previously described in item number
three of this section to meet project goals. As the proposed project is an existing cooler, Subpart F is not
triggered based on the clinker cooler being a new affected facility.
Ash Grove’s proposed changes to the clinker cooler do meet the definition of a reconstruction. As described
in NSPS Subpart A, reconstruction occurs when the fixed capital cost of the new components exceed 50
percent of the fixed capital cost that would be required to construct a comparable entirely new facility and it
is technologically and economically feasible to meet the applicable standards. Ash Grove reviewed clinker
cooler related costs and it is anticipated that the costs will be greater than 50% of the cost to construct a
comparable new source. Ash Grove believes that it is technologically and economically feasible to comply.
Therefore, the clinker cooler is being considered a reconstructed source under NSPA Subpart F.
The U.S. EPA has revised PM limits for reconstructed clinker coolers as shown below.

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60.62(b)
On and after the date on which the performance test required to be conducted by §60.8 is completed, you
may not discharge into the atmosphere from any clinker cooler any gases which:
60.62(b)(1)(i)
0.02 pound per ton of clinker if construction or reconstruction of the clinker cooler commences
after June 16, 2008.
Therefore, in order to meet requirements of NSPS Subpart F, Ash Grove will be required to meet a limit of
0.02 lb of PM/ton of clinker and requests to revise the emission limit documented in existing Approval Order
in Condition II.B.1.b.
The clinker cooler does not emit NOx or SO2 and so those limits are not relevant to the device.
Ash Grove will continue to comply with all relevant emission standards; testing requirements; monitoring,
recordkeeping, and reporting obligations that currently apply to the clinker cooler as a reconstructed source
under NSPS Subpart F.
Monitoring - Clinker Cooler
As a proposed reconstruction, Ash Grove will meet the monitoring requirements established in 40 CFR 60.63
for PM as it is subject to the emissions limit in 40 CFR 60.62(b)(1)(i):
Table 6-2 Clinker Cooler Modification, NSPS Subpart F Monitoring Requirements
Affected Source by Pollutant Requirement Monitoring with Proposed Modification
Clinker Cooler – Reconstruction
of an existing affected facility
40 CFR 60.63(c)(1) Demonstrate compliance through an initial
performance test following reconstruction.
6.1.2.3 New Finish Mill
Ash Grove is planning to install a new finish mill at the Leamington Plant. This new finish mill will be a
second mill and in addition to the existing finish mill onsite. No changes are proposed to the existing finish
mill as part of the Leamington Plant Upgrade Project. As the second finish mill will commence construction
after August 17, 1971, it is subject as a new affected facility for the requirements NSPS Subpart F. The
emission limit for a new or existing finish mill is 10% opacity.
Monitoring - New Finish Mill
The finish mill will have six (6) new baghouses. As a proposed new source, the finish mill will meet the
monitoring requirements established in 40 CFR 60.8 for PM summarized in the table below.

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Table 6-3 New Finish Mill, NSPS Subpart F Monitoring Requirements
Affected Source by Pollutant Requirement Monitoring with Proposed Modification
Finish Mill – New affected source 40 CFR 60.8 Demonstrate compliance through an initial
performance test.
Ash Grove is also proposing an exit grain loading for PM of 0.005 gr/dscfm. This is not an NSPS
requirement.
6.1.2.4 New Rail and Truck Loading/Unloading
Ash Grove is planning to install a new rail loading and unloading station at the Leamington Plant with the
upgrade project. This new rail loading and unloading system will be in addition to the existing rail loading
system onsite. As the second rail loading and unloading system will commence construction after August 17,
1971, it is subject as a new affected facility for the requirements NSPS Subpart F. The emission limit for a
bulk loading or unloading system is 10% opacity.
Monitoring - Rail Loading And Unloading System
The new rail loading and unloading system will have two (2) new baghouses. As a proposed new source,
Ash Grove will meet the monitoring requirements established in 40 CFR 60.8 for PM as summarized in the
table below.
Table 6-4 New Rail Loading and Unloading, NSPS Subpart F Monitoring Requirements
Affected Source by Pollutant Requirement Monitoring with Proposed Modification
Rail Loading And Unloading
System – New affected source
40 CFR 60.8 Demonstrate compliance through an initial
performance test.
Ash Grove is also proposing an exit grain loading for PM of 0.005 gr/dscfm. This is not an NSPS
requirement.
6.1.3 NSPS Subpart Y – Standards of Performance for Coal Preparation and
Processing Plants
NSPS Subpart Y, Standards of Performance for Coal Preparation and Processing Plants, provides standards
of performance for affected facilities in coal preparation and processing plants that process more than 200
tons of coal per day. There are three key dates to determine which emission standard an affected facility
must meet: October 27, 1974, April 28, 2008, and May 27, 2009. If an affected facility is constructed,
reconstructed or modified after October 27, 1974 and on or before April 28, 2008, the emission unit must
meet separate emission standards than an affected facility constructed, reconstructed or modified after April
28, 2008 or May 27, 2009. As previously mentioned in the application, the affected facilities in the coal mill
have been in operation since 1981 and have not been modified or reconstructed since that time. Therefore,
the affected facilities are subject to the October 27, 1974 NSPS Y standards. The following are considered
affected facilities under NSPS Subpart Y:
► Coal Silo

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Per 40 CFR 60.252(a) and 60.254(a), the Coal Silo and Coal Grinding System must meet visible emission
limits set by the standard.
The Leamington plant’s coal silo and coal grinding system are existing affected facilities under NSPS Subpart
Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS, Subpart Y from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the Leamington
Plant Upgrade Project. Since there are no proposed modifications or reconstruction to the coal silo and coal
grinding system, nothing about the proposed upgrade project affects the existing applicability of NSPS
Subpart Y.
6.1.4 NSPS Subpart OOO – Standards of Performance for Nonmetallic Mineral
Processing Plants
NSPS Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants, provides standards
of performance for affected facilities located at fixed or portable nonmetallic mineral processing plants that
are constructed, modified, or reconstructed after August 31, 1983, with additional requirements applicable
to sources constructed on or after April 22, 2008. The following are considered affected facilities under
NSPS Subpart OOO:
► Impact Crusher
► Screening Operations
► Grinding Mill
► Bucket Elevator
► Conveying Operations
► Storage Bins
► Limestone Bypass System, (LBS)
► Enclosed Truck or Railcar Loading Station
Per 40 CFR 60.672(b), NSPS Subpart OOO affected facilities must meet the emission limits and compliance
requirements in Table 3 of the standard. Truck dumping in any screening operation, feed hopper, or crusher
is exempt from the standard for particulate matter as per 40 CFR 60.672(d).
NSPS Subpart OOO is not applicable to the 211.BF1: Stationary Crusher and 211.BF2: Raw Material Transfer
for the following reason(s): it was constructed in 1981, prior to the Subpart OOO applicability date of August
31, 1983.
As the crushing and screening system is controlled by baghouses and an increase in PM10 actual emissions
on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS. Ash Grove is
proposing to reduce the existing PM emissions limit on baghouses controlling affected facilities subject to
NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade
Project.
Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1), 60.676(f), and
60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO monitoring and recordkeeping
requirements.

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6.2 Federal Rules – Applicable National Emission Standards for Hazardous
Pollutants
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or greater than
10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as specified by each
subpart. NESHAP apply to sources in specifically regulated industrial source classifications (CAA Section
112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities not regulated as a specific industrial
source type. The Ash Grove Leamington Plant is a major source of HAPs and thus is subject to certain
NESHAP standards.
6.2.1 Subpart A – General Provisions
All affected sources are subject to the general provisions of Subpart A unless otherwise specified by the
source-specific NESHAP. Subpart A generally requires initial notification and performance testing,
recordkeeping, monitoring, provides reference methods, and mandates general control device requirements
for all other subparts as applicable.
6.2.2 Subpart LLL – Standards for Hazardous Air Pollutants from the Portland
Cement Manufacturing Industry
40 CFR Part 63, Subpart LLL – National Emission Standards for Hazardous Air Pollutants from the Portland
Cement Manufacturing Industry establishes process/source specific emission limits for PM, VOC (expressed
as total hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and gaseous
HAP compounds by limiting PM and THC emissions because portions of such emissions are USEPA-listed
HAPs. Subpart LLL requires compliance with applicable emissions limits on and after the initial startup of
cement production. To further reduce emissions, Subpart LLL also establishes operational requirements for
the use of cement kiln dust (CKD), fly ash, fuel and control equipment. Subpart LLL also specifies
process/source specific emissions testing, monitoring, recordkeeping, reporting, and compliance
demonstration requirements. The compliance requirements for the site are detailed in Approval Order
Condition II.B.1.b. Ash Grove will continue to comply with the requirements of Subpart LLL to demonstrate
compliance. This cement kiln will remain an existing source with respect to the kiln emission standards in
Subpart LLL as this project does not trigger the definition of a new source in Subpart LLL. New source
standards apply only to affected sources that were constructed or reconstructed after May 6, 2009.
6.3 State Rules – UDAQ
6.3.1 General Requirements
6.3.1.1 UAC R307-101-1. General Requirements Foreword
AP-42’s Chapter 19-2 and the rules adopted by the Utah Air Quality Board AQB constitute the basis for
control of air pollution sources in the state. These rules apply and will be enforced throughout the state and
are recommended for adoption in local jurisdictions where environmental specialists are available to
cooperate in implementing rule requirements. The NAAQS, NSPS, PSD, and NESHAP standards apply
throughout the nation and are legally enforceable in Utah.
The Leamington Plant complies with the rules adopted by the Utah AQB that are applicable to the facility
and its operations which have been addressed in this application and the facility’s Title V Operating Permit.

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6.3.1.2 UAC R307-101.2 Definitions
Except where specified in individual rules, definitions in R307-101-2 are applicable to all rules adopted by
the AQB.
The Leamington Plant complies with the definitions, terms, abbreviations, and references used in the UAC
R307-101, R307-415, and 40 CFR, unless otherwise noted in the plant’s Title V.
8.2.1.3 UAC R307-102-1. Broadly Applicable Requirements. Air Pollution Prohibited, Periodic Reports
Required
The owner or operator of a source is required to furnish to the Director periodic reports required under
Section 19-2-104(1)(c) and any other information as the director may deem necessary to determine
whether the source is in compliance with Utah and Federal regulations and standards. These records are
available to the public during normal business hours.
Ash Grove furnishes to the Director the periodic reports required under Section 19-2-104(1)(c) and any
other information as the Director requests as deemed necessary.
8.2.1.4 UAC R307-107-1 and 2. General Requirements: Breakdowns - Applicability and Timing
The owner or operator of a source shall report breakdowns to the director within 24 hours of the incident
via telephone, electronic mail, fax, or other similar method. A detailed written description of the
circumstance of the incident including a corrective program directed at preventing future such incidents,
shall be submitted within 14 days of the onset of the incident.
The Leamington Plant reports breakdowns in accordance with Condition I.S.2.c of the Title V currently
issued within 24 hours via telephone, electronic mail, fax, or other similar method and provides detailed
written descriptions within 14 days of the onset of the incident to UDAQ.
8.2.1.5 UAC R307-110. General Requirements: State Implementation Plan
The Leamington Plant is located in Juab County, which is in attainment for all criteria pollutants.
6.3.2 Emission Inventories
6.3.2.1 UAC R307-150-1 through 150-7. Emission Inventories
This rule establishes the time frame, pollutants, and information that sources must include in inventory
submittals.
UAC R307-150-5 requires each large major source shall submit an emission inventory annually beginning
with calendar year 2002. The inventory shall include PM10, PM2.5, SO2, NOX, CO, VOC, and ammonia for all
emissions units including fugitive emissions. As a large major source, the Leamington Plant currently reports
its emissions inventory in accordance with Condition I.U. of its Title V and includes other chargeable
pollutants every three years in accordance with UAC R307-150-5. Emission inventories shall be submitted on
or before April 15 of each year following the calendar year for which an inventory is required.
Emissions inventories were used in developing the baseline calculations.

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6.3.3 Emission Testing
6.3.3.1 UAC R307-165-1 through 165-5. Emission Testing
Emission testing is required at least once every five years for all sources with established emission
limitations specified in approval orders issued under R307-401 or in section IX, Part H of the Utah SIP.
Notification of any performance test is given at least 30 days prior to the test. Tests are conducted while the
source is operating at the maximum production or combustion rate at which such source will be operated.
The Leamington Plant currently is in compliance with established emission limitations and additional testing
will be required as specified for NSPS, Subpart F for the modified and/or reconstructed affected facilities.
6.3.3.2 R307-170. Continuous Emission Monitoring Program
The Leamington plant has installed CEMS on its kiln; these records and reporting requirements meet the
requirements of R307-170.
As previously described in the application, Ash Grove is proposing to install an SO2 CEMS to meet NSPS,
Subpart F requirements for modification of the kiln after June 26, 2008. Ash Grove will submit a monitoring
plan documenting continuous monitoring system (CMS) requirements specified in 40 CFR 60.63(i)(1)(i-iii)
and the UDAQ requirements in R307-170.
6.3.4 Emission Standards
6.3.4.1 UAC R307-201. Emission Standards: General Emission Standards
R307-201 establishes emission standards for all areas of the state except for sources listed in Section IX,
Part H of the state implementation plan or located in a PM10 nonattainment or maintenance area.
The Leamington Plant currently is not in a PM10 Nonattainment or maintenance area; therefore, this rule is
applicable to the Leamington Plant.
6.3.4.2 UAC R307-203. Emission Standards: Sulfur Content of Fuels
Sulfur emissions shall be no more than 0.85 pounds sulfur per million gross BTU heat input for any oil. The
following specifications for each purchase of fuel oil are recorded: weight percent sulfur, gross heating value
(Btu per unit volume), and density. These parameters shall be determined in accordance with the methods
of the American Society for Testing and Materials (ASTM). Records of fuel sulfur content shall be kept for all
periods when the plant is in operation and shall be made available to the Director upon request and shall
include a period of two years ending with the date of the request.
The Leamington Plant ensures emission standards for sulfur content of fuel as described in R307-203(1)(a)
are met through guarantees provided from the vendor for weight percent sulfur and density of purchased
fuel.
6.3.4.3 UAC R307-205-4. Emission Standards: Fugitive Emissions and Fugitive Dust –
Fugitive Emissions
Fugitive emissions from sources constructed on or before April 25, 1971, shall not exceed 40% opacity.
Fugitive emissions from sources constructed or modified after April 25, 1971, shall not exceed 20% opacity.

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The Leamington Plant is compliant with the established opacity limit for fugitive emissions.
6.3.4.4 UAC R307-205-5. Emission Standards: Fugitive Emissions and Fugitive Dust –
Fugitive Dust
Owning, operating or maintaining a new or existing material storage, handling or hauling operations, as well
as any clearing or leveling on any lands greater than one-quarter acre in size, earthmoving, excavation, or
movement of trucks or construction equipment over cleared land greater than one-quarter acre in size or
access haul roads shall take measures to minimize fugitive dust from such activities. Such control may
include watering and chemical stabilization of potential fugitive dust sources or other equivalent methods or
techniques approved by the director. Operations on any land area greater than one-quarter acre in size that
has been cleared or excavated shall take the same measures described above to prevent fugitive particulate
matter from becoming airborne.
Ash Grove is currently in compliance with R307-205-5. Steps to minimize fugitive dust, such as watering and
other equivalent fugitive control methods, are conducted at the Leamington Plant. Proposed changes to the
plant will still maintain these emissions standards.
6.3.4.5 UAC R307-205-7. Emission Standards: Fugitive Emissions and Fugitive Dust –
Mining Activities
Minimizing fugitive dust shall be an integral part of site preparation, mining activities and reclamation
operations. Fugitive dust control measures include periodic watering of unpaved roads, paving of roads, and
prompt removal of coal, rock minerals, soil, and other dust-forming debris from roads. Additional controls
include frequent scraping and compaction of unpaved roads to stabilize the road surface, restricting the
speed of vehicles in and around the mining operation and restricting the travel of vehicles on other than
established roads. Enclosing, covering, watering, or otherwise treating loaded haul trucks to minimize loss of
material to wind and spillage is a viable means to control fugitive dust from haul trucks. Substitution of
conveyor systems for haul trucks and the covering of conveyor systems that are subject to wind erosion are
also suitable methods for control.
If possible, Ash Grove will minimize the area of disturbed land. Watering can be used to control disturbed
grounds. Water sprays, wet drilling, the use of shrouds, or other controls approved by the Director are used
for drilling by Ash Grove’s contracted drilling company.
Ash Grove is currently in compliance with R307-205-7. The Leamington Plant engages in various techniques
to reduce fugitive dust from its mining activities. Techniques include, but are not limited to, watering during
hauling, loading, or transferring operations, maintaining both paved and unpaved roads, restricting the
speed of vehicles in and around mining operations, and control of dust from storage piles and disturbed
grounds.
6.3.5 NSPS/NESHAPs
6.3.5.1 UAC R307-210-1. Stationary Sources
The provisions of 40 CFR Part 60, effective on June 1, 2017, except for Subparts Cb, Cc, Cd, Ce, BBBB,
DDDD, and HHHH, are incorporated by reference with the exception that references in 40 CFR to
"Administrator" shall mean "Director" unless by federal law the authority referenced is specific to the
Administrator and cannot be delegated.

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See federal requirements that address the applicability of NSPS Standards.
6.3.5.2 UAC R307-214-1. National Emission Standards for Hazardous Air Pollutants
The provisions of 40 CFR Part 61, NESHAP, effective as of July 1, 2014, are incorporated by reference. For
pollutant emission standards delegated to the State, references in 40 CFR Part 61 to "the Administrator"
shall refer to the Director.
See federal requirements that address the applicability of NESHAPs Standards.
6.3.5.3 UAC R307-214-2. National Emission Standards for Hazardous Air Pollutants.
The subparts listed in R307-214-2 from 40 CFR Part 63, NESHAP for Source Categories, effective as of July
1, 2014, are incorporated by reference. References in 40 CFR Part 63 to "the Administrator" shall refer to
the director, unless by federal law the authority is specific to the Administrator and cannot be delegated.
See federal requirements that address the applicability of NESHAP Standards.
6.3.6 Approval Order
6.3.6.1 UAC R307-401-8. Approval Order
(1) The director will issue an AO if all conditions and regulations have been met.
(a) The degree of pollution control for emissions, to include fugitive emissions and fugitive dust, is at least
best available control technology. When determining best available control technology for a new or modified
source in an ozone nonattainment or maintenance area that will emit VOC or NOX, best available control
technology shall be at least as stringent as any Control Technique Guidance document that has been
published by EPA that is applicable to the source.
(b) The proposed installation will meet the applicable requirements of:
(ii) R307-405, Permits: Major Sources in Attainment or Unclassified Areas (PSD);
(iii) R307-406, Visibility;
(iv) R307-410, Emissions Impact Analysis;
(vi) R307-210, National Standards of Performance for New Stationary Sources;
(vii) National Primary and Secondary Ambient Air Quality Standards;
(viii) R307-214, National Emission Standards for Hazardous Air Pollutants;
(ix) R307-110, Utah State Implementation Plan; and
(x) All other provisions of R307.
(2) The Title V will require that all pollution control equipment be adequately and properly maintained.

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(3) Receipt of an AO does not relieve any owner or operator of the responsibility to comply with the
provisions of R307 or the State Implementation Plan.
As required by the Ash Grove’s AO, compliance is maintained through the following:
(1) All pollution control equipment is properly maintained, and
(2) Provisions of R307 or SIP are followed.
As documented in numerous conditions in Ash Grove’s AO, BACT provisions specified in UAC R307-401 have
been applied through control equipment installed and monitoring conditions.

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7. BACT
7.1 Sources Addressed in BACT
The Leamington Plant Upgrade Project’s overall objective is to improve energy efficiency of the kiln system
and produce more low-carbon cement. The addition of a new finish mill and rail loadout will support this
objective. Additional limestone will be required to be mined and alternative materials such as pozzolans are
proposed to be brought on site to supplement a portion of the clinker to produce low-carbon cement. The
kiln system upgrades will also allow the Leamington Plant to process more clinker, thereby enabling the
plant to produce an increased volume of low-carbon cement. Emissions from the project are anticipated to
increase for PM10, PM2.5, NOX, CO, VOCs, SO2, and lead.13 The proposed modification represents an increase
greater than the PM10 and PM2.5 PSD SERs of 15 tpy and 10 tpy, respectively. The sources contributing to
the exceedance of the SER require a BACT analysis for PM10 and PM2.5 under the PSD program. In addition,
because the proposed modification is a major modification for PM10 and PM2.5, and results in a GHG
emissions increase of greater than 75,000 tons CO2e, a BACT analysis is also required under the PSD
program for GHGs. The proposed modification will also result in an annual increase in emissions of other
criteria pollutants and/or represent a modification to existing equipment; therefore, BACT analysis for each
criteria pollutant is required to satisfy UDAQ’s permitting requirements. The specific emission sources
included in the BACT analysis are presented below.
7.1.1 PM10 and PM2.5 Sources
The PM10 and PM2.5 BACT analysis for the emissions sources that demonstrate an increase in emissions
and/or are being modified have been included in the following sections.
► Modification of Existing Equipment
• Kiln calciner, preheater and ID fan.
► Reconstructed NSPS Source
• Clinker Cooler fans and baghouse.
► Fugitive Emissions
• Roads;
• Loading and Unloading;
• Stockpiles;
• Bulldozing and Grading;
• Disturbed Areas; and
• Drilling and Blasting.
► Material Transfer
• Material Sizing and Handling, including Crushing and Screening;
• Loading and Unloading;

13 NOx emissions from the kiln system will remain constant as a result of upgrades to the SNCR system, but NOx will be
emitted by the new finish mill heater.

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• Raw Material Handling;
• Plant and Finish Mill Material Handling;
• Coal Material Handling; and
• Existing Truck and Rail Product Loadout.
► Installation of New Equipment
• 2nd Finish Mill;
• Kiln Feed Alleviator Baghouse; and
• New Rail Unloading and Truck Loadout.
► New Combustion Source – Finish Mill Heater.
The proposed 2nd Finish Mill will have a direct-fired, natural gas heater, which will be a source of NOX, SO2,
CO, and VOCs. A state-level BACT has been prepared for these pollutants. The PM10 and PM2.5 emitted from
the finish mill heater will be subject to the PSD BACT analysis.
 10.4 MMBtu/hr Natural Gas-Fired Heater
► Modified SO2 and VOCs Sources
SO2 and VOCs emissions will increase less than the PSD SER at 40 tpy. As a result, a state-level BACT
analysis has been completed for the following sources.
► Kiln SO2 Emissions;
► Kiln VOCs Emissions; and
► Grinding Aid VOCs Emissions.
GHGs will increase greater than 75,000 tpy as a result of the Leamington Plant’s upgrade project. A GHG
BACT analysis has been provided for the following combustion sources.
► Kiln, Kiln calciner, preheater and inline coal mill; and
► Finish Mill Heater.
7.2 BACT Definition
Any major stationary source or major modification subject to PSD review must undergo an analysis to
ensure the use of BACT. The requirement to conduct a BACT analysis is set forth in 40 CFR 52.21. BACT is
defined in 40 CFR 52.21 as:
“…best available control technology means an emissions limitation (including a visible emission standard)
based on the maximum degree of reduction for each pollutant subject to regulation under Act which would
be emitted from any proposed major stationary source or major modification which the Administrator, on a
case‐by‐case basis, taking into account energy, environmental, and economic impacts and other costs,
determines is achievable for such source or modification through application of production processes or
available methods, systems, and techniques, including fuel cleaning or treatment or innovative fuel
combustion techniques for control of such pollutant…”

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A BACT analysis is required for each new or physically modified emission unit for each pollutant that
exceeds an applicable PSD SER. Since the PM10 and PM2.5 emissions from the proposed project exceed the
applicable PSD SER, a BACT analysis is required to assess the necessary levels of control for these
pollutants. Because GHGs are subject to regulation as a result of the proposed project resulting in an
increase of 75,000 tons or more per year CO2e, a BACT analysis is also required for that suite of pollutants.
Note that HAPs listed under CAA Section 112(b)(1) are excluded from NSR (New Source Review) or PSD
(i.e., BACT) review.
In the State of Utah, under R307-401-5(2)(d), Notice of Intent, every facility, operation, or process that
proposes any activity that would emit an air contaminant, must consider BACT for the proposed activity. The
BACT analysis below was performed pursuant to this rule. It only addresses units which will be modified,
installed, or otherwise altered according to this NOI air permit application.
7.3 BACT Methodology
In a memorandum dated December 1, 1987, the United States Environmental Protection Agency (EPA)
stated its preference for a “top-down” BACT analysis. After determining if any New Source Performance
Standard (NSPS) is applicable, the first step in this approach is to determine, for the emission unit in
question, the most stringent control available for a similar or identical source or source category. If it can be
shown that this level of control is technically, environmentally, or economically infeasible for the unit in
question, then the next most stringent level of control is determined and similarly evaluated. This process
continues until the BACT level under consideration cannot be eliminated by any substantial or unique
technical, environmental, or economic objections. Presented below are the five basic steps of a top-down
BACT review as identified by the EPA.
7.3.1 Step 1 – Identify All Control Technologies
Available control technologies are identified for each emission unit in question. The following methods are
used to identify potential technologies:
► Researching the RACT/BACT/Lowest Achievable Emission Rate (LAER) Clearinghouse (RBLC) database;
► Surveying regulatory agency emission limit requirements;
► Surveying air pollution control equipment vendor emission limit guarantees; and/or
► Surveying available literature.
7.3.2 Step 2 – Eliminate Technically Infeasible Options
The second step in the BACT analysis is to eliminate any technically infeasible control technologies. Each
control technology for each pollutant is considered, and those that are clearly technically infeasible are
eliminated. EPA states the following regarding technical feasibility:
A demonstration of technical infeasibility should be clearly documented and should show, based on physical,
chemical, and engineering principles, that technical difficulties would preclude the successful use of the
control option on the emissions unit under review.14

14 EPA's New Source Review Workshop Manual: Prevention of Significant Deterioration and Nonattainment Area Permitting,
October 1990. Page B.6

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7.3.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness
Once technically infeasible options are removed from consideration, the remaining options are ranked based
on their control effectiveness. If there is only one remaining option or if all the remaining technologies could
achieve equivalent control efficiencies, ranking based on control efficiency is not required.
7.3.4 Step 4 – Evaluate Most Effective Controls and Document Results
Beginning with the most effective control option in the ranking, detailed economic, energy, and
environmental impact evaluations are performed. If a control option is determined to be economically
feasible without adverse energy or environmental impacts, it is not necessary to evaluate the remaining
options with lower control effectiveness. The economic evaluation centers on the cost effectiveness of the
control option. Costs of installing and operating control technologies are estimated and annualized following
the methodologies outlined in the EPA’s Office of Air Quality Planning and Standards (OAQPS) Control Cost
Manual (CCM) and other industry resources. Note that the analysis is not whether controls are affordable,
but whether the monetary expenditure is effective.
7.3.5 Step 5 – Select BACT
In the final step, one pollutant-specific control option is proposed as BACT for each emission unit under
review based on evaluations from the previous step. The EPA has consistently interpreted the statutory and
regulatory BACT definitions as containing two core requirements that the Agency believes must be met by
any BACT determination, regardless of whether the "top-down" approach is used. First, the BACT analysis
must include consideration of the most stringent available control technologies, i.e., those which provide the
“maximum degree of emissions reduction.” Second, any decision to require a lesser degree of emissions
reduction must be justified by an objective analysis of “energy, environmental, and economic impacts.” The
proposed BACT must be based on the most effective engineering techniques and control equipment to
minimize emissions of air contaminants into the outside environment from its process.
7.4 PM10 and PM2.5 Sources BACT Analysis
7.4.1 PM10 and PM2.5 Modified Equipment
The existing kiln precalciner, preheater, and alleviator system are proposed to be modified, and the kiln’s ID
fan and clinker cooler fans are proposed to be replaced, which will result in increased airflow. Additionally,
the clinker cooler baghouse will be converted from a plenum pulse to a pulse jet baghouse. These
modifications are projected to result in a net increase of potential PM10 and PM2.5 emissions. The BACT
analysis for these sources is presented below.
7.4.1.1 PM10 and PM2.5 - Kiln Upgrade BACT
The rotary cement kiln is the core of the cement manufacturing process, transforming the blended raw
materials or “rawmix” into clinker through pyro processing. Emissions from the kiln occur from coal
combustion plus the physical and chemical reactions needed to transform the rawmix into clinker. This
project involves process and energy efficiency improvements and an increase in kiln production, resulting in
an increase of PM10 and PM2.5 emissions. This section specifically addresses filterable PM10 and PM2.5. The
condensable fraction is represented with the other precursors as applicable to proposed emission increases.

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The Leamington Plant’s Kiln is subject to NSPS, Subpart F for particulate. Therefore, the top-down BACT
analysis addresses applicability of the proposed changes to the kiln system to NSPS and review of the RBLC.
A summary of the resources reviewed include the following:
► NSPS Subpart F – Standards of Performance for Portland Cement Plants establishes emission standards
for cement kiln operations. Specifically, kilns modified after June 16, 2008, are limited to 0.07 lbs
PM/ton of clinker produced.15 Ash Grove will achieve or exceed this emission limitation while achieving
BACT for the kiln operations.
► EPA’s RBLC Database for Portland Cement Manufacturing (process type 90.028) and Lime/Limestone
Handling/Kiln/Storage/Manufacturing (process type 90.019).16
7.4.1.2 Step 1 – Kiln PM10 and PM2.5 BACT – Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from kiln operations are as follows:
► Baghouse/Fabric Filter;
► Cyclone;
► Electrostatic Precipitator; and
► Wet Scrubber.
Baghouse/Fabric Filter
Baghouses/fabric filtration systems remove PM2.5 and PM10 from captured air. A fabric filter unit or baghouse
consists of one or more compartments containing rows of fabric bags. Particle-laden gases pass along the
surface of the bags and then through the fabric. Particles are retained on the upstream face of the bags,
and the cleaned gas stream is vented to the atmosphere. Fabric filters collect particles with sizes ranging
from submicron to several hundred microns in diameter. Fabric filters are used for medium and low gas flow
streams with high particulate concentrations. The typical baghouse has a control efficiency between 95%
and 99.9%.17
Cyclone
A cyclone separator (cyclone) operates on the principle of centrifugal separation; the exhaust enters the
inlet and spirals around the cyclone towards the outlet. As the particles proceed through the cyclone, the
heavier material hits the outside wall and drops out, where it is collected. The cleaned gas escapes through
an inner tube. Cyclones are generally used to reduce dust loading and to collect large particles. If the
emissions are picked up and routed to a control system, either a baghouse or a cyclone is feasible. A high-
efficiency cyclone designed specifically for PM2.5 and PM10 removal is likely to achieve between 20% and
70% removal for PM2.5 and 60% to 95% removal for PM10.18
Electrostatic Precipitator
A dry electrostatic precipitator (ESP) is a particle control device that uses electrical forces to move the
particles out of a gas stream and onto collector plates. This process is accomplished by the charging of
particles in the gas stream using positively or negatively charged electrodes. The particles are then collected

15 NSPS, Subpart F, 40 CFR 60.62(a)(1)(iii)
16 Database accessed September 14, 2022.
17 Baghouse control efficiency obtained per EPA-452/F-03-026 Air Pollution Control Technology Fact Sheet
18 Cyclone control efficiency obtained per EPA-452/F-03-005, Air Pollution Control Technology Fact Sheet

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as they are attracted to oppositely opposed electrodes. Once the particles are collected onto the plates, they
are removed by knocking them loose from the plates, allowing the collected layer of particles to fall down
into a hopper. Dry ESPs are used to capture coarse particles at high concentrations with efficiencies as high
as 90% to 99.5%19. Small particles at low concentrations are not effectively collected by a ESPs.20

19 WRAP Fugitive Dust Handbook, Executive Summary, Pg. 3, September 2006
20 Waste-to-Energy, Chapter 8: Permitting Issues, Section 8.2.4.1 Electrostatic Precipitators, Rogoff, 2011

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Wet Scrubber
A wet gas scrubber is an air pollution control device that removes PM2.5 and PM10 from stationary point
source air streams. PM10 and PM2.5 are primarily removed through the impaction, diffusion, interception,
and/or absorption of the pollutant onto droplets of liquid. Depending on the application, wet scrubbers can
control 50 – 99% of PM emissions.21 This type of scrubber relies almost exclusively on inertial impaction for
PM collection. Wet scrubbers have some advantages over ESPs and baghouses in that they are particularly
useful in removing PM with the following characteristics:
► Sticky and/or hygroscopic materials;
► Combustible, corrosive, or explosive materials;
► Particles that are difficult to remove in dry form;
► PM in the presence of soluble gases; and
► PM in gas streams with high moisture content.22
7.4.1.3 Step 2 – Kiln PM10 and PM2.5 BACT – Eliminate Technically Infeasible Options
Baghouse
To implement emission control through baghouses, a capture and collection system comprised of ductwork
and hoods is required. Baghouses are a proven technology for controlling PM10 and PM2.5 at Portland cement
plants and are in use at the Leamington Plant. Therefore, baghouses are technically feasible for the kiln
operations.
Cyclone
Cyclones are a technically feasible control for kiln operations, although they are infrequently used in practice
because they are less effective at capturing smaller particles and technically feasible.
ESP
Like baghouses, ESPs require a series of ductwork and collection hoods for successful PM control. An ESP is
a technically feasible control for kiln operations.
Wet Scrubber
A wet gas scrubber is an air pollution control device that removes PM10 and PM2.5 from stationary point
source air streams like a baghouse and cyclone. A wet scrubber is technically feasible.
7.4.1.4 Step 3 – Kiln PM10 and PM2.5 BACT– Rank Remaining Control Technologies by
Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented in the table
below.

21 EPA, EPA Air Pollution Control Technology Fact Sheet, EPA-452/F-03-015, 2003
22 EPA, EPA Air Pollution Control Cost Manual, Section 6, Chapter 2: Wet Scrubbers for Particulate Matter, Pg. 2-4, EPA/452/B-
02-001, 6th Edition, January 2002

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Table 7-1 PM10 Control Effectiveness for Kiln Operations
Control Technologies Rank Percent Control Technically
Feasible?
Baghouse 1 95 – 99.9% Yes
Wet Scrubber 2 99% Yes
ESP 3 90 – 99.5% Yes
Cyclone 4 20 – 70% Yes

7.4.1.4.1 Step 4 – Kiln PM10 and PM2.5 – Evaluate Most Effective Controls and Document
Results
PM emissions are most effectively controlled using a collection system with enclosures routed to baghouses
providing up to 99.9% control efficiency. Other technologies such as wet scrubbers, cyclones and ESPs are
feasible, but provide lower control efficiencies than a baghouse. Ash Grove has selected technology with the
highest control efficiency, so there are no adverse energy, environmental or cost impacts to consider with
the use of this control technology. Thus, no further analysis is required under EPA’s top-down BACT
approach.
7.4.1.4.2 Step 5 – Kiln PM10 and PM2.5 – Select BACT
Ash Grove proposes that BACT for PM10 and PM2.5 emissions from the kiln consist of a collection system
routed to continue to be to a baghouse or fabric filter that complies with NSPS Subpart F’s the emission
standard in NSPS Subpart F of 0.02 lb PM/ton clinker for a modified source. As the proposed changes to the
kiln system currently will continue to meet the NSPS Standard for a modified source of at 0.07 lb of PM per
ton of clinker, it achieves BACT. A summary of the BACT emissions rates are in the table below.
Table 7-2 Kiln PM10 and PM2.5 BACT Summary
Source BACT Control Emission Limit
Kiln Baghouse 10% Opacity and 0.07 lb of PM/ton of Clinker
7.4.1.5 PM10 and PM2.5 – Clinker Cooler Upgrade BACT
The clinker cooler reduces the temperature of the clinker exiting the kiln. It is necessary to reduce clinker
temperature before it enters the finish mill to maintain product quality and reduce wear and tear on
equipment. The clinker cooler is equipped with a heat exchanger that captures waste heat and transfers it
to the kiln preheater for process and energy efficiency. Emissions from the clinker cooler are vented to a
baghouse.
The Leamington Plant’s clinker cooler is also subject to NSPS Subpart F for particulate. Ash Grove’s
proposed changes to the clinker cooler do meet the definition of a reconstruction under NSPS. Therefore, in

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order to meet requirements of NSPS Subpart F, Ash Grove will be required to meet a limit of 0.02 lb of
PM/ton of clinker.23
7.4.1.5.1 Step 1 – Clinker Cooler PM10 and PM2.5 BACT – Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from clinker cooler operations are as follows:
► Baghouse/Fabric Filter;
► Cyclone;
► Electrostatic Precipitator; and
► Wet Scrubber.
All these control technologies were described in the previous section, PM10 and PM2.5 – Kiln upgrade BACT.
7.4.1.5.2 Step 2 – Clinker Cooler PM10 BACT – Eliminate Technically Infeasible Options
Similar to the BACT for the PM10 and PM2.5 – Kiln upgrade, all the options identified are technically feasible.
7.4.1.5.3 Step 3 – Clinker Cooler PM10 and PM2.5 BACT – Rank Remaining Control
Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented in the table
below.
Table 7-3. PM10 and PM2.5 Control Effectiveness for Clinker Cooler Operations
Control
Technologies Rank Percent Control Technically
Feasible?
Baghouse 1 95 – 99.9% Yes
Wet Scrubber 2 99% Yes
ESP 3 90 – 99.5% Yes
Cyclone 4 20 – 70% Yes
7.4.1.5.4 Step 4 – Clinker Cooler PM10 and PM2.5 BACT – Evaluate Most Effective Controls and
Document Results
PM10 and PM2.5 emissions are most effectively controlled using a collection system with enclosures routed to
a baghouse, which can achieve up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Because the most
efficient control technology is proposed, there are no adverse energy, environmental or cost impacts to
consider with the use of this control technology. Thus, no further analysis is required under EPA’s top-down
BACT approach.

23 NSPS, Subpart F, 40 CFR 60.62(b)(1)(i)

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7.4.1.5.5 Step 5 – Clinker Cooler PM10 and PM2.5 BACT – Select BACT
Ash Grove proposes BACT for PM10 and PM2.5 emissions from the clinker cooler as consisting of a collection
system routed to a baghouse or fabric filter. As previously mentioned, Ash Grove’s proposed changes to the
clinker cooler do meet the definition of reconstruction under NSPS. Therefore, in order to meet
requirements of NSPS Subpart F, Ash Grove will be required to meet a reduced emission limit of 0.02 lb of
PM/ton of clinker. Therefore, BACT will be achieved by meeting 0.2 lb of PM per ton of clinker from the
clinker cooler baghouse.
Table 7-4. Clinker Cooler PM10 and PM2.5 BACT Summary
Source BACT Control Emission Limit
Clinker Cooler Baghouse 10% Opacity and 0.02 lb of PM/ton of
Clinker
7.4.2 PM10 and PM2.5 Fugitive Emissions
The following fugitive emissions sources will increase in PM10 and PM2.5 as a result of the Leamington Plant’s
proposed throughput increase. The sources addressed in the following BACT analyses are primarily in the
quarry, but also include emissions from roads and dumping of raw materials within the plant boundary.
The sources evaluated are listed below.
► Roads;
► Loading and Unloading;
► Stockpiles;
► Bulldozing and Grading;
► Disturbed Areas; and
► Drilling and Blasting.
7.4.2.1 PM10 and PM2.5 – Roads BACT
Fugitive PM10 and PM2.5 emissions are generated from road use when particles on the road surface are
entrained into the atmosphere by vehicular traffic. Particles are lifted and dropped from the rolling wheels,
and the road surface is exposed to air currents. PM surface loading on paved roads is the result of material
spillage and brake and tire wear, whereas PM surface loading on unpaved roads is the result of inherent
characteristics of the road surface itself. Roads at the quarry are all unpaved. Roads in the plant, leading
back to the reclaim area, and cement loadout are paved. Control technologies were identified for PM10 and
PM2.5 emissions from roads based on a review of the following relevant sources:
► WRAP Fugitive Dust Handbook;
► UDAQ’s Emission Factors for Paved and Unpaved Haul Roads;
► EPA’s AP-42 Chapter 13.2.3 Heavy Construction Operation; and
► EPA’s RBLC Database for Unpaved Roads (process type 99.150).24

24 Database accessed September 14, 2022.

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7.4.2.1.1 Step 1 - Roads PM10 and PM2.5 BACT - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from roads are as follows:
► Surface Grading;
► Chemical Treatment;
► Watering;
► Road Paving and Sweeping; and
► Reduced Speed.
7.4.2.1.2 Step 2 - Roads PM10 and PM2.5 BACT – Eliminate Technically Infeasible Options
Surface Grading
Surface grading involves creating a smooth road surface with gradual elevation changes, where uniform
height is achieved at any cross section of the road path. Surface grading also includes removing
irregularities such as corrugations and uneven material distribution. By creating a smooth road, surface
grading reduces the amount of PM that is lifted into the air from road travel. The US Army Construction
Engineering Research Laboratory stated:
“The best way to avoid dust problems is to ensure that roads are properly maintained by surface grading
and shaping for cross-sectional crowning to prevent excessive road surface wearing and consequent dust
generation.”25
Surface grading is technically feasible for unpaved roads.
Chemical Treatment
Treating unpaved roads with chemicals changes the physical characteristics of the road surface material,
inhibiting fugitive emissions by binding surface particles together. If exclusively applied, chemical treatment
has an emission control efficiency of 84%.26 In its published guidelines on emission factors for paved and
unpaved roads, the UDAQ gives an emission control efficiency of 85%.27 However, some suppressants
require that traffic be kept off the road surface for two (2) to three (3) hours after application—which is
considered a significant limitation by mine engineers.28 One study, conducted by Thompson and Visser,
found that a combination of chemical suppressants and regular watering is the only effective option for
controlling fugitive dust emissions on haul roads.29 Chemical treatment is technically feasible for unpaved
roads and not applicable to paved roads.
Watering
Watering changes the physical properties of the surface material by binding the soil particles together such
that fugitive emissions are minimized or not generated. A report from the UDAQ found that basic watering
provided a 70% control efficiency, while watering with the use of a road base provided a 75% control

25 Gebhar et al., US Army Construction Engineering Research Laboratories, Dust Control Guidance and Technology Selection
Key, May 1999
26 WRAP, WRAP Fugitive Dust Handbook, Executive Summary, Pg. 3, September 2006
27 Utah Division of Air Quality, Emission Factors for Paved and Unpaved Haul Roads, January 2015
28 US EPA, Dust Suppression on Wyoming’s Coal Mine Haul Roads, Pg. 28, November 2005
29 Ibid, Pg. 9-10.

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efficiency.30 Watering and chemical treatment are often applied in tandem to unpaved roads. When
chemical suppressant and basic watering are coupled together, UDAQ suggests that unpaved road
emissions maintain an 85% control efficiency.31 Watering is technically feasible.
Paving
Paving an unpaved road provides effective control of fugitive road emissions. Guidelines from UDAQ indicate
that paved roadways, combined with standard sweeping and watering, provide a 90% control efficiency,
while vacuum sweeping and watering provide a 95% control efficiency.32 However, WRAP suggests that
paving alone can attain a 90% control efficiency.33
Paving effectively controls PM emissions from road usage, but rapid road deterioration is a significant
concern for paving. For example, haul roads leading to and from the active quarry are susceptible to high
volume, heavy-weight equipment travel. If these haul roads were paved, frequent re-paving and road
construction would hinder haul truck travel and subsequently obstruct production. Paving heavy equipment
routes would result in the construction of vestigial roads. Furthermore, road configurations will frequently
change as mining progresses. Due to the constantly adjusted path required for quarry haul roads, and the
heavy traffic traveling thereon, paving is technically infeasible for these routes.
However, roads outside the quarry area are not anticipated to change frequently. These roads are used for
product export, raw material deliveries, and employee/visitor travel are currently paved. Paving, sweeping,
and watering of these permanent roads and supporting areas is technically feasible.
Speed Reduction
Reducing vehicle speeds inhibits the generation of fugitive dust by reducing the velocity of air streams
surrounding a travelling vehicle, thereby preventing the lift of PM10 and PM2.5. WRAP reported that emissions
of PM decrease by 44% when speeds are reduced to 25 mph on unpaved roads. In construction areas, PM
emissions are reduced by 57% when speeds are restricted to 15 mph or lower.34 Similar control efficiencies
are not reported for speed reductions on paved roads. Reducing vehicle speed is technically feasible.
7.4.2.1.3 Step 3 - Roads PM10 and PM2.5 BACT – Rank Remaining Control Technologies by
Control Effectiveness
For these technologies applied to unpaved roads, any grouping of watering, chemical treatment, and speed
reduction can be applied together, and they are not competitive. Any grouping of watering and sweeping
can be applied together for paved roads, and they are not competitive. Control methods have been ranked
in the table below:

30 Utah Division of Air Quality, Emission Factors for Paved and Unpaved Haul Roads, January 2015
31 Ibid.
32 Ibid.
33 WRAP, WRAP Fugitive Dust Handbook, Executive Summary, Pg.3, September 2006
34 Ibid.

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Table 7-5. Summary of PM10 and PM2.5 Controls for Roads
Control Technologies Rank Percent
Control
Technically
Feasible?
Paving Roads 1 90-95% Yes – for stationary
roadways
Chemical Treatment 2 84-85% Yes – for unpaved
roadways
Watering 3 70-75% Yes
Maintaining Vehicle Speeds
below 25 mph 4 44-57% Yes
Surface Grading 5 Various Yes – for unpaved
roadways

7.4.2.1.4 Step 4 - Roads PM10 and PM2.5 BACT – Evaluate Most Effective Controls and
Document Results
Maximum PM control is achieved in practice at the Leamington Plant by paving roads where practical. For
roads where paving is not feasible, providing chemical treatment in tandem with watering provides the
greatest emission control. In instances where chemical treatment is not feasible, water application combined
with speed reduction provide the greatest emission control, which is currently in practice for safety reasons
close to the active mining area. As the highest ranked technology is applied where feasible to the respective
area of the plant, there are no adverse energy, environmental or cost impacts to consider with the use of
these control technologies. Thus, no further analysis is required under EPA’s top-down BACT approach.
7.4.2.1.5 Step 5 - Roads PM10 and PM2.5 BACT – Select BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an opacity
standard and control techniques. Ash Grove proposes BACT to consist of restricting fugitive emissions to the
opacity standard defined therein, namely fugitive emissions shall not exceed 20% opacity. The table below
summarizes BACT for the Leamington Plant’s roads.
Table 7-6. Roads PM10 and PM2.5 BACT Summary
Source BACT Control Emission Limit
Unpaved Roads Vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary 20% opacity
Paved Roads Vehicle speeds ≤25 mph, watering, and
vacuum sweeping. 20% opacity
7.4.2.2 PM10 and PM2.5 Loading and Unloading BACT
Loading and unloading operations generate PM10 and PM2.5 and fugitive dust emissions at the quarry,
reclaim area, and hoppers. Loading and unloading activities at Ash Grove’s Leamington Plant include the

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loading and unloading of overburden, limestone, and reject fines material with quarry haul trucks and
loaders. Trucks delivering raw materials also unload at the Ash Grove Plant.
Loading operations within the quarry are not subject to NSPS Subpart OOO and include the following:
► In-pit loading and unloading of haul trucks;
► In-pit loading and unloading of loaders;
► Loading and unloading of topsoil and reclamation material at the reclamation area;
► Unloading of limestone, overburden, reject fines, and topsoil etc. at their respective stockpile areas; and
► Loading and unloading of shipped raw materials at the stockpile areas.
Loading and unloading also occur in the following locations:
► Shipped raw materials onto stockpiles in the reclaim area or into fixed hoppers or loading trucks in the
plant.
Ash Grove has reviewed the following sources to identify available control technologies for loading and
unloading operations:
► EPA’s RBLC Database for Other Fugitive Dust Sources (process type 99.190);35 and
► EPA’s RBLC Database for Portland Cement Manufacturing (process type 90.028).36
7.4.2.2.1 Step 1 – Loading and Unloading PM10 and PM2.5 BACT - Identify All Control
Technologies
Control technologies identified for PM10 and PM2.5 emissions from loading and unloading operations are as
follows:
► Best Management and Operational Practices;
► Enclosures; and
► Watering & Inherent Material Moisture Content.
7.4.2.2.2 Step 2 – Loading and Unloading PM10 and PM2.5 BACT – Eliminate Technically
Infeasible Options
Baghouses
Baghouses were described previously, in PM10 and PM2.5 – Kiln upgrade BACT. Its description applies here as
well. In addition, baghouses require ductwork, fans, enclosures, and/or pickup hoods to capture and route
emissions for control. This renders baghouses technically infeasible to mobile equipment or dynamic
locations, e.g., quarry operations. They are technically feasible for permanent equipment that can be
enclosed.

35 Database accessed September 15, 2022.
36 Database accessed September 15, 2022.

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Best Management Practices
Best management practices for loading and unloading activities, such as minimizing drop heights, will curtail
PM10 and PM2.5 emissions. Best management and operational practices are technically feasible. The
Leamington Plant maintains a fugitive dust control plan, which specifies best management practices to
minimize dust, and will continue to be implemented.
Watering and Inherent Material Moisture Content
In the quarry, water carryover from dozing and/or disturbed ground PM mitigation and inherent moisture
content are technically feasible.
During cement manufacturing, moisture within the rawmix must be minimized to the extent possible to
maintain product quality. All material downstream from the primary crusher must be thoroughly dried prior
to introduction into the kiln to conserve fuel and thus reduce combustion emissions. Therefore, watering
materials through the raw material handling process is not considered further.
Enclosures
Enclosures confine emissions to the enclosed area, prohibiting PM from reaching ambient air. Enclosures are
typically able to achieve a control efficiency of 50-90% of fugitive emissions.37 Although effective, industrial
enclosures are permanent structures. Loading and unloading operations will occur at various locations. Due
to the variable location of loading and unloading operations in the quarry and reclaim areas, enclosures are
technically infeasible. Enclosures have been considered at stationary hoppers if necessary to control fugitive
dust.
7.4.2.2.3 Step 3 – Loading and Unloading PM10 and PM2.5 BACT – Rank Remaining Control
Technologies by Control Effectiveness
Feasible control technologies are ranked in the table below.
Table 7-7. PM10 and PM2.5 Control Effectiveness for Loading and Unloading Operations
Control Technologies Rank Percent Control Feasible BACT
Baghouses 1 95 – 99.9% Yes – for permanently
stationary equipment
Yes – for permanently
stationary equipment
Watering, Inherent
Moisture Content, and
water carry over38
2 50 – 90% Yes – for quarry
operations
Yes – for quarry
operations
Enclosures (At stationary
hoppers or permanent
loading and unloading
points)
3 75% Yes Yes

37 Texas Commission on Environmental Quality, Material Handling: Source Types, Controls, Emission Calculations for
mechanical conveyance, p 10.
38 WRAP, WRAP Fugitive Dust Handbook, Executive Summary, Pg. 3, September 2006

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Control Technologies Rank Percent Control Feasible BACT
Best Management
Practices 4 Varies Yes Yes
7.4.2.2.4 Step 4 – Loading and Unloading PM10 and PM2.5 BACT – Evaluate Most Effective
Controls and Document Results
In the quarry area, PM10 and PM2.5 emissions are most effectively controlled through watering (including
moisture carry over), best management practices including following its fugitive dust control plan. Utilizing
these control methods are the most effective means of controlling PM10 and PM2.5 emissions. Enclosures and
baghouses on permanent hoppers will be installed where susceptible to wind, or where it is possible to
contain the fugitive emissions with an enclosure. As the highest ranked technology is applied, there are no
adverse energy, environmental or cost impacts to consider with the use of these control technologies. Thus,
no further analysis is required under EPA’s top-down BACT approach.
7.4.2.2.5 Step 5 – Loading and Unloading PM10 and PM2.5 BACT – Select BACT
The facility is subject to fugitive dust control standards in UAC R307-205 which identifies an opacity
standard and control techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the
opacity standard defined therein, namely, that fugitive emissions shall not exceed 20% opacity and
emissions are controlled with best management practices via a Fugitive Dust Control Plan. The following
table describes how BACT will be applied to loading and unloading operations.
Table 7-8. Quarry Loading and Unloading PM10 and PM2.5 BACT Summary
Source BACT Control Emission Limit
Loading and
unloading Watering and best management practices 20% opacity at the property boundary
Loading and
unloading
Enclosures and/or baghouses at
permanent stationary sources, where
practical.
20% opacity at the property boundary
7.4.2.3 PM10 and PM2.5 - Stockpiles BACT
Stockpiles principally generate fugitive particulate emissions under three (3) conditions: 1) high winds
eroding the stockpile; 2) addition of material to the stockpile; and 3) removing material from the stockpile.
Additional fugitive emissions may occur as the result of reshaping and relocating stockpiles for
maneuverability and mining purposes. Anytime a stockpile is disturbed, there is increased emission
potential. For stockpiling operations, Ash Grove has reviewed the following sources to identify available
control technologies:
► EPA’s RBLC Database for Other Fugitive Dust Sources (process type 99.190) 39
► WRAP Fugitive Dust Handbook

39 Database accessed September 15, 2022.

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7.4.2.3.1 Step 1 - Stockpiles PM10 and PM2.5 BACT - Identify All Control Technologies
Control techniques for PM emissions from stockpiles are comprised of two categories: 1) stabilization
techniques, and 2) stockpile best management practices.
Stabilization methods include:
► Watering stockpiles to form a crust;
► Applying and maintain a chemical stabilizer to all outer surfaces; and
► Applying a cover.
Best management practices include:
► Reducing stockpile height;
► Creating a wind screen;
► Removing material from the downwind side of the stockpile; and
► Reducing stockpile slope angle.
7.4.2.3.2 Step 2 - Stockpiles PM10 and PM2.5 BACT – Eliminate Technically Infeasible Options
Watering Stockpiles
Watering changes the physical properties of the surface material by binding particles together, forming a
layer of crust. This crust layer acts as a natural cover to the stockpile, preventing fugitive emissions from
high winds. By watering storage piles, a 66% and 40% control efficiency is used for PM10 and PM2.5,
respectively, per UDAQ guidance.40 This is a conservative control technology in comparison to that of 90%
given by WRAP.41 Watering is easiest where in proximity to overhead conveyors or through the water truck
periodically spraying in the quarry. As previously mentioned, moisture within the rawmix must be minimized
to the extent possible to maintain product quality. It is for this reason that watering is deemed technically
infeasible for the Leamington Plant’s stockpiles.
Applying and Maintaining Chemical or Non-Chemical Stabilizer to Outer Surfaces
Stabilizers used to control PM emissions from stockpiles include the use of chemical stabilizers such as
calcium chloride and magnesium chloride, as well as placing denser raw material on the pile surface.
Chemical stabilizers bind the compacted material and work best in environments with low humidity.42
Meanwhile, gravel application covers the pile material with a layer of dense stone, which protects fine
particles within the pile from airstreams blowing over the pile. A study by the California Air Resources Board
(CARB), as reported in WRAP, found that gravel application was just as effective as applying chemical
suppressant to material stockpiles. WRAP reports that applying chemical stabilizer or gravel to stockpiles,
results in an 84% reduction in PM10 and PM2.5.43
Active stockpiles at the Leamington Plant will be subject to frequent disturbance. To achieve the reported
control efficiencies, chemical stabilizers or gravel would need to be continuously added and removed to the
various stockpiles as material is added, removed, or reclaimed. Both chemical and non-chemical stabilizers

40 UDAQ instrction based on AP-42 Appendix B.2, Tables B.2-2 and B.2-3.
41 WRAP Fugitive Dust Handbook, Chapter 9, page 9-9, Table 9-4, September 2006
42 WRAP, WRAP Fugitive Dust Handbook, Section 3.6 Demonstrated Control Techniques: Chemical Stabilizers, September 2006
43 Ibid.

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would impact the Portland cement production process and would diminish product quality. Consequently,
the application of chemical and non-chemical stabilizers is technically infeasible.
Applying a Cover
During high wind events, airstreams have the ability to lift fine PM from stockpiles and become airborne.
Covering piles with tarps (usually made of polyethylene), prevents 90% of PM emissions.44
As mentioned above, active stockpiles are frequently disturbed. Therefore, applying a cover to active
stockpiles is technically infeasible.
Best Management Practices
Because 360-degree stockpile access is not always safe or feasible due to stockpile location, removing
material from the downwind side of the stockpile cannot be guaranteed. Therefore, removing material from
the downwind side of the stockpile is not technically feasible. The remaining best management practices of
reducing stockpile height, reducing stockpile slope angle, and screened material with reduced fines are
feasible.
7.4.2.3.3 Step 3 - Stockpiles PM10 and PM2.5 BACT – Rank Remaining Control Technologies by
Control Effectiveness
These technologies may be used together when technically practical because they are not competitive.
Table 7-9. Summary of PM10 and PM2.5 Control Effectiveness for Stockpiles
Control Technologies Rank Percent
Control Feasible?
Best Management
Practices 1 Varies Yes
7.4.2.3.4 Step 4 – Stockpiles PM10 and PM2.5 BACT – Evaluate Most Effective Controls and
Document Results
As the highest ranked technologies are applied where feasible, there are no adverse energy, environmental
or cost impacts to consider with the use of these control technologies. Thus, no further analysis is required
under EPA’s top-down BACT approach.
7.4.2.3.5 Step 5 – Stockpiles PM10 and PM2.5 BACT – Select BACT
The Leamington Plant is subject to fugitive dust control standards in UAC R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes that BACT consist of restricting fugitive
emissions to the opacity standard defined therein, namely, fugitive emissions shall not exceed 20% opacity
at the property boundary. BACT for stockpiles will be achieved through applying good management
practices through its fugitive dust plan as appropriate.

44 WRAP Fugitive Dust Handbook, Chapter 9, page 9-9, Table 9-4, September 2006

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Table 7-10. Stockpiles PM10 and PM2.5 BACT Summary
Source BACT Control Emission Limit
Stockpiles Best management practices 20% opacity

7.4.2.4 PM10 and PM2.5 – Bulldozing and Grading BACT
Bulldozers and graders at the Leamington Plant create and maintain stockpiles, facilitate overburden and
fines placement, conduct reclamation activities, and perform additional activities as quarry demands dictate.
Bulldozers and graders generate fugitive PM10 and PM2.5 emissions from movement of tracks/wheels, as well
as from the movement of material.
Fugitive emissions are commonly reduced through restricting visible emission (VE) opacity. Opacity means
the degree to which emissions reduce the transmission of light and obscure the view of an object in the
background.45 Since the 1970’s, the EPA has used opacity as a surrogate for controlling PM emissions.46
Control technologies were identified for PM10 and PM2.5 emissions from bulldozing and grading based on a
review of the following relevant sources:
► Western Regional Air Partnership (WRAP) Fugitive Dust Handbook;
► EPA’s AP42 Chapter 13.2.3 Heavy Construction Operation; and
► EPA’s RBLC Database for Other Fugitive Dust Sources (process type 99.190).47
7.4.2.4.1 Step 1 - Bulldozing and Grading PM10 and PM2.5 BACT - Identify All Control
Technologies
From reviewing the sources, the following methods were identified for controlling PM emissions from
bulldozing and grading:
► Chemical treatment; and
► Watering and enhanced soil moisture content.
7.4.2.4.2 Step 2 - Bulldozing and Grading PM10 and PM2.5 BACT – Eliminate Technically
Infeasible Options
Chemical Treatment
Treating soil areas with chemicals changes the physical characteristics of the surface material, binding
surface particles together. In turn, these bound particles inhibit fugitive emissions. Chemical treatments only
penetrate the top few inches of soil and are typically employed for roads, long term stockpiles, and
frequently traveled areas. Dozing and grading are designed to move large volumes of surface material and
continually scrape to depths greater than the chemicals can effectively penetrate. This renders the addition

45 EPA Visible Emissions Field Manual: EPA Methods 9 and 22, 1993. Pgs. 4-5.
46 US EPA, Current Knowledge of Particulate Matter (PM) Continuous Emission Monitoring, Executive Summary, September
2000
47 Database accessed September 14, 2022.

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of chemicals ineffective; therefore, chemical treatment and dozing and grading are competitive, so chemical
treatment is considered technically infeasible.
Watering
Watering changes the physical properties of the surface material by binding the soil particles together so
that fugitive emissions are minimized or not generated. When water is applied to bulldozing or grading
areas at various intervals, WRAP reports that 61% of PM emissions are controlled.48 Notably, the world’s
largest copper mine (Kennecott’s Bingham Canyon Mine) performed BACT for bulldozer operations in 2017
and reported using this control method and the 61% control efficiency, as cited by WRAP. However, an
RBLC search conducted on August 8, 2022, for Process Code 99.190 (Other Fugitive Dust Sources) revealed
that wet suppression, combined with pile compaction, provides a 90% control efficiency.49 Watering is
technically feasible.
7.4.2.4.3 Step 3 - Bulldozing and Grading PM10 and PM2.5 BACT – Rank Remaining Control
Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented in the table
below.
Table 7-11. Summary of PM2.5 and PM10 for Bulldozing
Control Technologies Rank Percent Control Technically
Feasible?
Watering 1 61-90%50 Yes
7.4.2.4.4 Step 4 – Bulldozing and Grading PM10 and PM2.5 BACT – Evaluate Most Effective
Controls and Document Results
An evaluation considering effectiveness of controls for the environment, energy, and economics is not
necessary, as the highest ranked, and only remaining, feasible control technology was chosen.
7.4.2.4.5 Step 5 – Bulldozing and Grading PM10 and PM2.5 BACT – Select BACT
The Leamington Plant is subject to fugitive dust control standards in Utah Administrative Code (UAC) R307-
205, which identifies an opacity standard and control techniques. Ash Grove proposes that BACT consist of
restricting fugitive emissions to the opacity standard defined therein, namely, fugitive emissions from
bulldozing and grading activities shall not exceed 20% opacity, and that emissions are controlled with
periodic watering of the disturbed surface. The frequency of water application will depend on ambient
weather conditions and inherent moisture content of the material being moved.

48 Ibid, Table 3-7, Control Efficiencies for Control Measures for Construction/Demolition
49 Indiana Gasification LLC, RBLC ID: IN-0166, US EPA RBLC Search:
https://cfpub.epa.gov/rblc/index.cfm?action=PermitDetail.PollutantInfo&Facility_ID=27546&Process_ID=108991&Pollutant_ID
=170&Per_Control_Equipment_Id=153919
50 Per WRAP Table 3-7 and RBLC Search Process Type 99.190, Indiana Gasification LLC

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Table 7-12. Bulldozing PM2.5 and PM10 BACT Summary
Pollutant BACT Control Emission Limit
Fugitive PM10 Watering as necessary 20% opacity
7.4.2.5 PM10 and PM2.5 - Disturbed Areas BACT
Areas are disturbed during normal quarry operations and reclamation activities. Areas will be continually
disturbed throughout the life of the quarry, and they are managed to reduce windblown dust emission
potential. Due to the nature of mining, new areas can be actively disturbed each day, while other areas will
remain undisturbed for significant periods of time. Control technologies for PM10 and PM2.5 emissions from
disturbed areas were identified from the following sources:
► EPA’s RBLC Database for Other Fugitive Dust Sources (process type 99.190); 51
► WRAP Fugitive Dust Handbook; and
► Permits available online.
7.4.2.5.1 Step 1 - Disturbed Areas PM10 and PM2.5 BACT - Identify All Control Technologies
After reviewing the sources, the following control technologies were identified:
► Chemical dust suppressants;
► Watering exposed areas;
► Scarification;
► Revegetation; and
► Best management practices.
7.4.2.5.2 Step 2 - Disturbed Areas PM10 and PM2.5 BACT – Eliminate Technically Infeasible
Options
Chemical Dust Suppressants
Chemical dust suppressants are commonly used to control PM emissions from various sources such as
roads, stockpiles, and exposed areas. When polymer emulsion dust suppressants are applied to actively
disturbed areas, emissions are reduced; however, these areas are uneven with variable sized materials and
the binding properties of dust suppressants will not be effective.52 As a result, chemical dust suppressants
are considered technically infeasible.
Watering
Watering changes the physical properties of surface material by binding the soil particles, so that the
fugitive emissions are minimized or not generated. When water is applied to an exposed area prior to a high
wind event, fugitive emissions are reduced by 90%.53 Watering is technically feasible.

51 Database accessed September 15, 2022.
52 California Air Resources Board, Evaluation of Air Quality Performance Claims for Soil-Sement, April 2002
53 Per WRAP Fugitive Dust Handbook, Executive Summary, Page 3, September 2006

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Scarification
In areas where topsoil has been removed, scarification can be an effective way to reduce fugitive emissions.
Typically, heavy-duty equipment such as ripper shanks are used to scarify material. This causes larger
material to be raised on the surface, while gravity forces smaller material that generates PM10 and PM2.5
deeper into the ground. Several mining operations, including the world’s largest coal mine, have used
scarification to create an inactive disturbed area prior to reclamation.54,55,56 It should be noted that if the
ground is already uneven from mining it can provide the same effect as scarification. Applying gravel or
course material to the surface has the same control effect. Scarification is technically feasible.
Revegetation
Revegetating disturbed areas is a means of binding soil and reducing wind erosion potential. This principal is
the same as applying a vegetative cover to a long-term stockpile. This control is technically feasible for
inactive areas.
Best Management Practices
Minimizing the quantity and frequency of disturbance are effective management practices for minimizing PM
emissions from disturbed areas. Best management practices are technically feasible.
7.4.2.5.3 Step 3 - Disturbed Areas PM10 and PM2.5 BACT – Rank Remaining Control
Technologies by Control Effectiveness
The following table lists viable control technologies according to their effectiveness.
Table 7-13. Summary of PM10 and PM2.5 Control Methods for Disturbed Areas
Control Technologies Rank Percent
Control Feasible
Water Application 1 90% Yes
Scarification 2 84% Yes
Revegetation 3 Varies Yes, for long-term
inactive areas
Best Management Practices 4 Varies Yes
7.4.2.5.4 Step 4 – Disturbed Areas PM10 and PM2.5 BACT – Evaluate Most Effective Controls
and Document Results
Watering and scarification provide the highest PM emissions control efficiencies and are proposed for use at
the Leamington Plant. Best management practices and revegetation will be used as feasible to minimize

54 Wyoming Department of Environmental Quality (WDEQ) Air Quality Division, Permit Application Analysis, A0007654,
Peabody Powder River Mining, June 2019
55 Alaska Department of Natural Resources, True North Mine Project Description, 2014
56 Michigan Department of Environmental Quality, Copperwood Resources inc, Mining Permit Application Amendment, March
2018

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disturbed areas and reclaim disturbed areas where practicable and the disturbance will be long-term. Ash
Grove proposes the highest ranked control be applied where feasible. There are no adverse energy,
environmental or cost impacts to consider with the use of these control technologies. Thus, no further
analysis is required under EPA’s top-down BACT approach.
7.4.2.5.5 Step 5 – Disturbed Areas PM10 and PM2.5 BACT – Select BACT
The Leamington Plant is subject to fugitive dust control standards in UAC R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT consist of restricting fugitive emissions
to the opacity standard defined therein, namely fugitive emissions shall not exceed 20% opacity. BACT for
disturbed areas will be achieved through best management practices, watering, scarification, and
revegetation as appropriate.
Table 7-14. Disturbed Areas PM10 and PM2.5 BACT Summary
Source BACT Control Emission Limit
Disturbed Areas Watering, scarification, revegetation,
and best management practices 20% opacity

7.4.2.6 PM10 and PM2.5 - Drilling and Blasting BACT
Drilling and blasting methods reduce overburden and limestone in the quarry to access the ore body in the
ground. Control technologies for fugitive dust generation of PM10 and PM2.5 from these activities have been
identified using the following sources:
► EPA’s RBLC Database for Other Fugitive Dust Sources (process type 99.190); 57
► UDAQ Fugitive Dust Control Plans (Revised 1/13) BMP 02;
► Dust Control Handbook for Industrial Minerals Mining and Processing, NIOSH, January, 2012; and
► WRAP Fugitive Dust Handbook.
7.4.2.6.1 Step 1 - Drilling and Blasting PM10 and PM2.5 BACT - Identify All Control Technologies
The following methods have been identified as control technologies to reduce fugitive dust emissions from
drilling and blasting:
► Apply a shroud to the drilling equipment;
► Best management and operational practices for drilling and blasting;
► Install a dust collection system on drilling equipment; and
► Install a water spray on drilling equipment.

57 Database accessed September 15, 2022.

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7.4.2.6.2 Step 2 - Drilling and Blasting PM10 and PM2.5 BACT – Eliminate Technically Infeasible
Options
Apply a Shroud to the Drilling Equipment
Installing a shroud at the drilling location is one common method for controlling fugitive dust emissions from
drilling operations. Shrouds can vary in shape (rectangular versus circular) and complexity to adapt to
mining operations. When installed and replaced correctly, shrouds can control 88% of fugitive dust
emissions.58 Using a shroud during drilling operations is technically feasible.
Best Management and Operational Practices for Drilling and Blasting
Best management practices for drilling operations consist of conducting routine inspections and
maintenance of drilling emissions control technologies. This may include repairing and/or replacing shrouds
when they become damaged. Best management and operational practices for blasting operations includes
using sufficient stem length, optimizing blasting area, and refraining from blasting operations during high
winds59. Best management and operational practices for controlling both drilling and blasting operations are
technically feasible.
Dust Collection System on Drilling Equipment
Dust control can be accomplished during drilling operations using a fan-powered, drill-mounted dust-
collection system. If properly maintained, these systems can be up to 99% efficient.60 For drilling
operations, installing a dust collection system is technically feasible but may not be available for all drill rigs.
Drilling operations at the Leamington Plant are contracted through a local drilling company. The preferred
contractor does not have drill rigs equipped with dust collection and filtration technology. Ash Grove has
little control over contractor procured equipment. Requiring drill rig dust collection would significantly limit
the contractor selection pool and could potentially cause production delays. Dust collection is technically
feasible so long as it is reasonably available.
Water Spray on Drilling Equipment
Fugitive emissions for drilling equipment can be significantly reduced through wet drilling; using a water
spray which provides continuous water flow during drilling operations. With a high volumetric flow rate, dust
control efficiencies often attain 86-97%. However, when water flow rates approach one (1) gallon per
minute (gpm) operational problems such as drill bit plugging, and drill rotation binding often occur.
Additionally, dust control efficiencies are reduced when water flow rates are reduced.61 Water sprays are
technically feasible for drilling operations.

58 Dust Control Handbook for Industrial Minerals Mining and Processing, pg. 137. NIOSH, March, 2019
59 The Office of Surface Mining, U.S. Department of Interior, Controlling the Adverse Effects of Blasting, Methods to Reduce
Airblast
60 Dust Control Handbook for Industrial Minerals Mining and Processing, pg. 124. NIOSH, March, 2019
61 Dust Control Handbook for Industrial Minerals Mining and Processing, pg. 80-82. NIOSH, January, 2012

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7.4.2.6.3 Step 3 - Drilling and Blasting PM10 and PM2.5 BACT – Rank Remaining Control
Technologies by Control Effectiveness
The feasible control technologies for fugitive dust generated from drilling operations are provided in the
table below, ranked according to effectiveness.

Table 7-15. Summary of PM10 and PM2.5 Control Techniques for Drilling and Blasting
Control Technologies Rank Percent Control Feasible
Dust Collection System 1 99% Yes
Using a Water Spray (Wet
drilling) 2 86-97% Yes
Use of a Shroud 3 63-88% Yes
Best Management and
Operational Practices 4 Varies Yes
7.4.2.6.4 Step 4 - Drilling and Blasting PM10 and PM2.5 BACT – Evaluate Most Effective
Controls and Document Results
For drilling operations, dust collection systems such as baghouses provide the highest degree of PM control
(up to 99%). Wet-drilling by using a water-spray can provide up to 97% control efficiency. Implementing a
shroud or enclosure can control 88% of PM10 emissions. Drilling operations equipped with dust collection or
watering systems provide the highest control of PM10 and PM2.5 emissions.
Ash Grove uses contractors to perform drilling operations at the Leamington Facility. Ash Grove does not
have the authority to require independent contractors to use one type of control or another. Thus, although
dust collection systems are technically feasible for drilling operations, whether they will be used or not will
be up to the drilling contractor and their availability to procure this control technique.
For blasting operations, good management practices provide the highest reduction in PM10 and PM2.5
emissions.
7.4.2.6.5 Step 5 - Drilling and Blasting PM10 and PM2.5 BACT – Select BACT
The Leamington Plant is subject to fugitive dust control standards in UAC R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes that BACT consist of restricting fugitive
emissions to the opacity standard defined therein, namely fugitive emissions shall not exceed 20% opacity.
The table below summarizes the Leamington’s approach to BACT.

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Table 7-16. Drilling and Blasting PM10 and PM2.5 BACT Summary
Pollutant BACT Control Emission Limit
Fugitive PM10 and PM2.5
Best Management Practices,
Shrouds, Watering, and dust
collection as feasible
20% opacity
7.4.2.7 NOX and SO2 – Blasting BACT
Blasting operations incorporate combustion of compounds containing ammonium nitrate to pulverize
material in the quarry area. Blasting operations will produce fugitive NOX and SO2 emissions. However, there
are no control technologies that can be used to mitigate NOX and SO2 emissions associated with blasting. As
such, no BACT analysis has been conducted for these emissions.
7.4.2.8 PM10 and PM2.5 Material Transfer, Sizing, and Storage
The Leamington Plant has sources of fugitive emissions through raw material transfer. Materials transferred
include limestone and other raw materials, coal, clinker, and cement. These materials are transferred by
conveyor belt, screw conveyor, elevator, pneumatic conveyance or chutes via gravity. At the Leamington
Plant these emissions are controlled by baghouses at their transfer points and enclosures.
The following NSPS Subparts are applicable at the Leamington Plant.
► 40 CFR 60, Subpart A (General Provisions)
► 40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
► 40 CFR 60, Subpart Y (Standards of Performance for Coal Preparation and Processing Plants)
► 40 CFR 60, Subpart OOO (Standards of Performance for Nonmetallic Mineral Processing Plants)
A summary table of the EPA’s BACT 5- Step top-down approach has been provided for these sources as
controls for these sources are similar.
Table 7-17. PM10 and PM2.5 Material Transfer BACT
Sources Pollutant Processes Addressed
Material Transfer,
crushing and sizing, and
loading
PM10/PM2.5
Limestone Crushing, Sizing, and Material Transfer;
Raw Material Transfer;
Coal Sizing and Transfer;
Existing Finish Mills;
Clinker Storage and Transfer;
Cement Storage and Truck and Rail Cement Loadout
New Rail Loading and Loadout

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Table 7-18. PM10 and PM2.5 Sources BACT Summary
Step Inertial Collection
Systems (Cyclones)3
Electrostatic
Precipitator (ESP)
1,2
Wet Scrubber4 Watering Enclosures Baghouse/Fabric Filter6
Step 1.
Identify Air
Pollution
Control
Technologies

Control
Technology
Description
Consists of one or more
conically shaped vessels
in which the exhaust gas
stream follows a circular
motion prior to the
outlet. PM enters the
cyclone suspended in the
gas stream, which is
forced into a vortex by
the shape of the cyclone.
The inertia of the PM
resists the directional
change of the gas,
resulting in an outward
movement under the
influence of centrifugal
forces until they strike
the cyclone wall. The PM
is caught in a thin
laminar layer of air next
to the cyclone wall and is
carried downward by
gravity to the collection
hopper.
An ESP uses
electrical forces to
move particles
entrained within a
exhaust stream onto
a collection surfaces
(i.e., an electrode).
A wet ESP can be
used in this
application to reduce
condensable and
filterable particulate
matter (PM)
emissions formed
due to SO2; a dry
ESP would reduce
filterable particulate
matter only.
Wet scrubbers
remove particulates
through the impact
of particles with
water droplets. Wet
scrubbers can have
high removal
efficiency for
streams with a
steady state
exhaust. The
scrubber operates
with a high pressure
drop to maintain
high removal
efficiency.
Watering changes the
physical properties of
the surface material by
binding the soil particles
so that the fugitive
emissions are minimized
or not generated.
Watering can control 50
– 90% of PM emissions
from material handling.
Materials with a high
moisture content exhibit
similar particle-binding
properties that
effectively control
emissions.
Enclosures confine the
emissions to the enclosed
area, in turn, prohibiting the
particulate emissions from
reaching ambient air. The
EPA notes that enclosures
are widely used as a method
to control PM emissions
from material processing.
Process exhaust gasses are
collected and passed through a
tightly woven or felted fabric
arranged in sheets, cartridges,
or bags that collect PM via
sieving and other mechanisms.
The dust cake that
accumulates on the filters
increases collection efficiency,
and eventually falls into a
hopper for removal. Various
cleaning techniques include
pulse-jet, reverse-air, and
shaker technologies.

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Step Inertial Collection
Systems (Cyclones)
3Electrostatic
Precipitator (ESP)
1,2
Wet Scrubber4 Watering Enclosures Baghouse/Fabric Filter6
Other
Considera
tions
In some cases, thermal
insulation is used to
reduce eat loss and cold
air from entering the
system. Cold air can
cause gas quenching and
condensation which leads
to corrosion, dust
buildup, and plugging of
the hopper or dust
removal system.
Rappers or other
mechanical
mechanisms are
used periodically to
impart a vibration or
shock to dislodge
the deposited PM on
dry ESP electrodes.
The dislodged PM is
collected in hoppers.
In wet ESP, the
collected particles
are washed off the
collection plates by a
small flow of
trickling water.

ESP systems are
typically only used
on continuous
combustion sources.
When used on an
intermittent basis,
the actual collection
efficiency decreases.
Wet scrubbing uses
a significant amount
of water and
produces a
wastewater stream
that must be
properly disposed.
This control technology
has been demonstrated
in the petroleum and
coal, chemical products,
primary metal, industrial
minerals, electronics,
electric and gas, food,
and lumber industries.
As previously
mentioned, moisture
within the rawmix must
be minimized to the
extent possible to
maintain product
quality. It is for this
reason that watering is
deemed technically
infeasible for the
Leamington Plant’s raw
materials and products.
Implementation of baghouses
will require that emissions are
picked up and routed to a
control system. This is typically
accomplished through the
installation of ductwork,
capture hoods, fans, motors,
starters, stacks, and other
equipment. For permanent
material handling equipment
such as the primary crusher
and many of the conveyors in
the plant, baghouse control
technology is technically
feasible and is in use at the
existing facility. For mobile
material handling equipment
such as the portable crusher
and its conveyors, baghouse
control technology is
technically infeasible.

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Step Inertial Collection
Systems (Cyclones)
3Electrostatic
Precipitator (ESP)
1,2
Wet Scrubber4 Watering Enclosures Baghouse/Fabric Filter6
Step 2.
Eliminate
Technically
Infeasible
Options
Feasibility
Discussion
The proposed control
train employs a baghouse
for control of PM10 and
PM2.5 emissions.
Additional particulate
removal is not practical.

That is, cyclones are
technically feasible to
control PM10 and PM2.5
emissions associated with
material handling at the
primary crusher and
within the primary
portion of the plant. For
the same reasons, they
are technically infeasible
for the mobile material
handling equipment such
as the portable crusher
and its conveyors.
The proposed
control train
employs a baghouse
for control of PM10
and PM2.5 emissions.
Additional
particulate removal
is not practical;
moreover, the ESP
would create
adverse energy and
environmental
impacts (due to the
power needed to
generate the high
voltage electrostatic
fields, and with wet
ESP, to dispose of
the wastewater
stream).

This control
technology has not
been demonstrated
in practice for
control of PM
emissions for
Fugitive emissions
sources. As a result,
an ESP is not
considered further.
For general PM, wet
scrubbers typically
attain control
efficiencies up to
99%. Scrubbers are
proven effective at
controlling
particulate matter
from emission
streams with a wide
range of
temperatures and
particulate loading.
A wet scrubber is
technically feasible
for permanent
material handling
equipment.
However, their
permanent nature
makes them
technically infeasible
for mobile
equipment such as
the portable crusher
and its conveyors.
The proposed control
train employs a
baghouse for control of
PM10 and PM2.5
emissions. During
cement manufacturing,
moisture within the
rawmix must be
minimized to the extent
possible to maintain
product quality. All
material downstream
from the primary
crusher must be
thoroughly dried prior to
introduction into the kiln
to conserve fuel and
thus reduce combustion
emissions. Therefore, it
is technically infeasible
to water material during
material handling in this
process.
Technically feasible. The
proposed control trains employ
baghouses and baghouses are
widely demonstrated in
practice.
[1] EPA, Stationary Source Control Techniques Document for Fine Particulate Matter, Section 6.1: Enclosures and Ventilation, October 1998
[2] Material Handling: Source Types, Controls, Emission Calculations, Control Methods, Pg. 10

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Step Inertial Collection
Systems (Cyclones)
3Electrostatic
Precipitator (ESP)
1,2
Wet Scrubber4 Watering Enclosures Baghouse/Fabric Filter6
Step 3. Rank
Remaining
Control
Technologies
Overall
Control
Efficiency

Base Case
Step 4.
Evaluate and
Document
Most
Effective
Controls
Cost
Effectivene
ss ($/ton)

Base Case - Highest Ranked
Source is Used. There is no
adverse energy,
environmental or cost impacts
to consider with the use of a
baghouse. Thus, no further
analysis is required under
EPA’s top-down BACT
approach.
Step 5. Select
BACT

Source PM10 and PM2.5 BACT
Limestone Crushing, Sizing,
and Material Transfer
NSPS Subpart OOO
Crusher 12% Opacity
Screens 7% Opacity
Transfers 7% Opacity
Emissions Limit - 0.007
gr/dscfm
Raw Material
Transfer
NSPS Subpart F
10% opacity
Emissions Limit - 0.007
gr/dscfm
Coal Storage and Transfer 0.031 grains per dry standard
cubic feet (gr/dscf)) (Filterable)
20% Opacity
Clinker Storage and Transfer NSPS Subpart F
10% opacity
Emissions Limit - 0.007
gr/dscfm

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Step Inertial Collection
Systems (Cyclones)
3Electrostatic
Precipitator (ESP)
1,2
Wet Scrubber4 Watering Enclosures Baghouse/Fabric Filter6

Existing Finish Mill Grinding,
Storage and Transfer
NSPS Subpart F
10% opacity
Emissions Limit - 0.007
gr/dscfm
Cement Storage and Truck
and Rail Cement Loadout
New Rail Loadout
NSPS Subpart F
10% opacity
Emissions Limit - 0.007
gr/dscfm
1 U.S. EPA, Office of Air Quality Planning and Standards, "Air Pollution Control Technology Fact Sheet (Wet Electrostatic Precipitator (ESP) - Wire Pipe Type)," EPA-452/F-03-029.
2 U.S. EPA, Office of Air Quality Planning and Standards, "Air Pollution Control Technology Fact Sheet (Wet Electrostatic Precipitator (ESP) - Wire Plate Type)," EPA-452/F-03-030. 3 U.S. EPA, Office of Air Quality Planning and Standards, "Air Pollution Control Technology Fact Sheet (Momentum Separators)," EPA-452/F-03-008.
4 U.S. EPA, Office of Air Quality Planning and Standards, "Air Pollution Control Technology Fact Sheet (Flue Gas Desulfurization (FGD) - Wet, Spray Dry, and Dry Scrubbers)," EPA-452/F-03-034.
5 U.S. EPA, Office of Air Quality Planning and Standards, "Air Pollution Control Technology Fact Sheet (Thermal Incinerator)," EPA-452/F-03-022.
6 U.S. EPA, Office of Air Quality Planning and Standards, "Air Pollution Control Technology Fact Sheet (Fabric Filter - Pulse-Jet Cleaned Type)," EPA-452/F-03-025.
7 See Table 2d. Recent Permit Limitations and Determinations of BACT for PM (Prior 10 years) for a list of non-comparable facilities from the RBLC database.

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7.5 NOX, SO2, CO, PM10, PM2.5, and VOCs BACT - New Finish Mill Heater
Material handling in the new finish mill will operate like the existing plant material handling operation. The
new finish mill is subject to NSPS Subpart F, Standards of Performance for Portland Cement Plants. In
accordance with NSPS Subpart F, emissions from locations other than the kiln and clinker cooler are
restricted to 10% opacity.
The proposed finish mill will include a process heater to maintain a minimum temperature during milling.
The proposed heater will run on natural gas and is rated at 10 MMBtu/hr. Startup and shutdown emissions
from the heater are anticipated to be no greater than normal operation as the process is simply a matter of
bringing the heater to operating temperature. Emissions evaluated in the BACT analysis for the finish mill
heater include NOX, SO2, CO, and VOCs, PM10, and PM2.5. Pollutants with identical control technologies are
grouped together in the analysis.
7.5.1 NOX - Finish Mill Heater Combustion BACT
NOX formation from combustion may occur by three (3) fundamental mechanisms. The principal mechanism
is thermal NOX formation wherein atmospheric nitrogen in the combustion air dissociates under high
temperatures and reacts with oxygen to form NOX. The second mechanism is prompt NOX, which occurs
through reactions of combustion air, nitrogen, and hydrocarbon radicals in the fuel. Prompt NOX formation is
typically negligeable when compared to thermal NOX formation. The third mechanism of NOX formation is
called fuel NOX, wherein nitrogen in the fuel reacts with oxygen in the combustion air to create NOX
compounds. Ash Grove has reviewed the following sources to identify available control technologies for
similar sized heaters:
► EPA’s RBLC Database for Misc. Boiler, Furnaces, Heaters (process type 99.600);62
7.5.1.1.1 Step 1 - finish mill Heater Combustion NOX BACT - Identify All Control Technologies
Control technologies for NOX from units of this size range are as follows:
► Ultra-Low-NOX Burners;63
► Low NOx Burners;
► Selective Catalytic Reduction;
► Selective Noncatalytic Reduction;
► Good Combustion Practices; and
► Use of Natural Gas.
7.5.1.1.2 Step 2 – finish mill Heater Combustion NOX BACT - Eliminate Technically Infeasible
Options
Ultra-Low NOX Burners
Ultra-low NOX burners can achieve NOX emission concentrations of 9 ppm or less. Ultra-Low NOX burners
use technology to reduce thermal and prompt NOX formation by lowering the flame temperature and
eliminating fuel-rich zones within the combustion flame. A lower flame temperature can be achieved by

62 Database accessed September 12, 2022.
63 Determined as BACT for process heaters of the same order of magnitude for RBLC IDs TX-0873 and WI-0311.

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introducing cool air immediately upstream of the burner by using flue gas recirculation or overfired air
injection. Fuel-rich zones are eliminated by rapidly mixing the gaseous fuel and air both prior and
immediately following the burner. As the burner is a direct fired unit and exposed to the material and
turbulent air within the finish mill, the typical technologies to achiever ultra-low NOX emissions rates are not
technically feasible.
Low-NOX Burners
LNB technology uses advanced burner design to reduce NOX formation through the restriction of oxygen,
flame temperature, and/or residence time. There are two general types of LNB: staged fuel and staged air
burners. In a stage fuel LNB, the combustion zone is separated into two regions. The first region is a lean
combustion region where a fraction of the fuel is supplied with the total quantity of combustion air.
Combustion in this zone takes place at substantially lower temperatures than a standard burner. In the
second combustion region, the remaining fuel is injected and combusted with leftover oxygen from the first
region. A staged air burner begins with full fuel but only partial combustion air, and then adds the remaining
combustion air in the second combustion region. These techniques reduce the formation of thermal NOX.
Ash Grove determined LNB’s to be a technically feasible control option for the finish mill heater.
Selective Catalytic Reduction
SCR has been applied to stationary, fossil fuel-fired, combustion units for emission control since the early
1970s. It has been applied to large (>250 MMBtu/hr) utility and industrial boilers, process heaters, and
combined-cycle gas turbines, and minimally applied to other combustion devices and processes.64 SCR can
be applied as a stand-alone NOX control or with other technologies such as combustion controls. The
reagent reacts selectively with the flue gas NOX within a specific temperature range and in the presence of
the catalyst and oxygen to reduce the NOX into molecular nitrogen (N2) and water vapor (H2O).65 The
optimum operating temperature is dependent on the type of catalyst and the flue gas composition.
Generally, the optimum temperature ranges from 480°F to 800°F.66
The effectiveness of an SCR system is dependent on a variety of factors, including the inlet NOX
concentration, the exhaust temperature, the ammonia injection rate, and the type of catalyst. SCR units
typically achieve 70 -90% NOX reduction; however, if the upstream NOX concentration is already low, it is
difficult to achieve these control efficiencies.67 Additionally, below the optimum temperature range, the
reaction rate drops sharply and effective reduction of NOX is no longer feasible.
While SCR can be installed on units of this size and configuration it is not considered a standard emission
control method and therefore SCR is generally not included in the original equipment design. 68 Additionally,
units which have varying operating load, frequent startup/shutdowns, or seasonal operations require an SCR
bypass which will complicate the design and has the potential to reduce efficiency.69 Since the need for the
heater is extremely variable this renders SCR technically infeasible.

64 EPA Air Pollution Control Cost Manual, Sixth Edition, January 2002, Chapter 2 Selective Catalytic Reduction, Section 2.1 Introduction
65 ibid.
66 EPA, Office of Air Quality Planning and Standards. OAQPS Control Cost Manual Section 4-2 Chapter 2, 6th edition. EPA 452/B-02-001. Research Triangle Park, NC. January 2002.
67 ibid.
68 EPA Air Pollution Control Cost Manual, Sixth Edition, January 2002, Chapter 2 Selective Catalytic Reduction, Section 2.2.4, Ammonia
Storage and Vaporization and Ammonia Injection
69 EPA Air Pollution Control Cost Manual, Sixth Edition, January 2002, Chapter 2 Selective Catalytic Reduction, Section 2.2.4,
Combustion Unit Design and Configuration

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Selective Noncatalytic Reduction
SNCR is a post‐combustion NOX control technology based on the reaction of urea or ammonia with NOX. In
the SNCR chemical reaction, urea [CO(NH2)2] or ammonia is injected into the combustion gas path to
reduce the NOX to nitrogen and water. Other chemicals such as hydrogen, hydrogen peroxide, and
methanol can be added to improve performance or lower the minimum threshold temperature. The overall
reaction schemes for both urea and ammonia systems can be expressed as follows:
CO(NH2)2 + 2 NO + ½ O2 → 2 N2 + CO2 + 2 H2O
4 NH2 + 6NO → 5 N2 + 6 H2O
Typical removal efficiencies for SNCR range from 30 to 65%. The reduction efficiency depends on the NOX
concentration in the flue gas. With relatively low, uncontrolled NOX emissions the reduction efficiency will be
lower than with relatively high, uncontrolled NOX emissions. Thus, SNCR used in combination with LNB may
have a lower reduction efficiency that SNCR alone. Due to the finish mill heater already utilizing LNB, using
SNCR in combination is likely to be less efficient and thus technically infeasible as a control technology.
Another important consideration for implementing SNCR is the operating temperature range. The SNCR
oxidation process requires temperatures of 1,600 to 2,100°F to achieve high conversion rates for NOX.
Operation at temperatures below this range results in ammonia slip. Operation above this range results in
oxidation of ammonia, forming additional NOX. With the exhaust gas temperature of approximately 4-500°F,
the gas in the finish mill heater would need to be preheated by at least 1,100°F in order to achieve effective
control through SNCR. Therefore, SNCR has been determined infeasible and is not considered further.
Natural Gas Combustion
Natural gas is an inherently clean burning fuel that is ubiquitous in the US and produced domestically. Using
only natural gas as fuel is technically feasible.
Good Combustion Practices
Good combustion practices include following manufacturer recommendations for operation and
maintenance. Good combustion practices are technically feasible.
7.5.1.1.3 Step 3 – Finish Mill Heater Combustion NOX BACT - Rank Remaining Control
Technologies by Control Effectiveness
All three feasible control technologies can be implemented simultaneously on the finish mill heater.
Table 7-19. Summary of NOx Control Techniques for Finish Mill Heater Combustion
Control Technologies Rank Percent Control Feasible?
Low NOX Burners 1 Up to 85%70 Yes
Use of Natural Gas 2 varies Yes

70 EPA’s AP 42, Fifth Edition, Volume 1 Chapter 1.4: Natural Gas Combustion

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Control Technologies Rank Percent Control Feasible?
Best Management
Practices 3 Varies Yes

7.5.1.1.4 Step 4 – Finish Mill Heater Combustion NOX BACT - Evaluate Most Effective Controls
and Document Results
Since the three feasible control technologies are proposed for the finish mill heater, no detailed economic,
energy, and environmental impact evaluations were conducted.
7.5.1.1.5 Step 5 – Finish Mill Heater Combustion NOX BACT - Select BACT
BACT for NOX is the use of natural gas as fuel, good combustion practices and the use of Low NOX burners.
Table 7-20. Finish Mill Heater Combustion NOx BACT Summary
Source BACT Control Emission Limit
Finish Mill Heater Use of Natural Gas fuel, Good Combustion
Practices, and Low NOX burners 30 ppmv NOX
7.5.2 CO, SO2, and VOC - Finish Mill Heater BACT
Ash Grove has reviewed the following sources to identify available control technologies for similar sized
heaters:
► EPA’s RBLC Database for Misc. Boiler, Furnaces, Heaters (process type 99.600);71
7.5.2.1.1 Step 1 - Finish Mill Heater Combustion CO, SO2, and VOC BACT - Identify All Control
Technologies
Control technologies for CO, SO2, and VOC from units of this size are as follows:
► Good Combustion Practices
► Use of Natural Gas
The finish mill heater combusts natural gas. Related natural gas combustion emissions are anticipated to be
minimal.

71 Database accessed September 12, 2022.

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7.5.2.1.2 Step 2 – Finish Mill Heater Combustion CO, SO2, and VOC BACT - Eliminate
Technically Infeasible Options
Natural Gas Combustion
Natural gas is an inherently clean burning fuel that is ubiquitous in the US and produced domestically. This
technology is technically feasible.
Good Combustion Practices
Good combustion practices include following manufacturer recommendations for operation and
maintenance. This technology is technically feasible.
7.5.2.1.3 Step 3 – Finish Mill Heater Combustion CO, , SO2, and VOC BACT - Rank Remaining
Control Technologies by Control Effectiveness
Both technologies offer intrinsic emission reductions from combustion. Since the technologies do not
compete, both technologies can and will be used simultaneously.
7.5.2.1.4 Step 4 – Finish Mill Heater Combustion CO, , SO2, and VOC BACT - Evaluate Most
Effective Controls and Document Results
Because both control technologies identified in Step 1 are proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further analysis
is required under EPA’s top-down BACT approach.
7.5.2.1.5 Step 5 – Finish Mill Heater Combustion CO, SO2, and VOC BACT - Select BACT
BACT for CO, SO2, and VOC are good combustion practices and the use of natural gas.
Table 7-21 Finish Mill Heater Combustion CO, SO2, and VOC BACT Summary
Area BACT Control Emission Limit
Finish Mill Heater Use of Natural Gas fuel and Best
Management Practices 10% Opacity
7.5.3 PM10 and PM2.5 New Finish Mill BACT
The proposed Plant upgrade include adding a second finish mill. The new finish mill will use an energy
efficient vertical roller mill assisted with a grinding aid. A total of five (5) point sources are planned for the
finish mill. In accordance with NSPS Subpart F, emissions from finish mill are restricted to 10% opacity. The
finish mill emission sources are summarized in the table below.

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Table 7-22. New Finish Mill PM10 and PM2.5 Emission Sources
Emission Unit ID Description Emission Type
211.BF2 Additive Hopper Loading Point
311.BF1 Transfer Point 1 Point
311.BF1 Transfer Point 2 Point
514.BF2 Finish Mill and Separator Point
315.BF1 Raw Material Silos Point
7.5.3.1 PM10 and PM2.5 – Finish Mill BACT
Ash Grove has reviewed the following sources to identify available control technologies.
► EPA’s RBLC Database for Portland Cement Manufacturing (process type 90.028);72 and
► Region 8 General Permit for Concrete Batch Plants.73
7.5.3.1.1 Step 1 – Finish Mill PM10 and PM2.5 BACT - Identify All Control Technologies
Control technologies identified for PM10 emissions from plant material handling operations are as follows:
► Baghouse / Fabric Filter;
► Best Management & Operational Practices;
► Cyclone;
► ESP;
► Enclosure;
► Water Application (Watering); and
► Wet Scrubber.
The same suite of PM control technologies listed for the PM10 and PM2.5 Modified Sources BACT apply here.
Refer to the PM10 and PM2.5 Modified Sources BACT for a brief description of each technology.
7.5.3.1.2 Step 2 – Finish Mill PM10 and PM2.5 BACT – Eliminate Technically Infeasible Options
Baghouse
Implementation of baghouses will require that emissions are collected and routed to a control system. This
is typically accomplished through the installation of a building, ductwork, capture hoods, fans, motors,
starters, stacks, and other equipment. Baghouse control technology is feasible for point sources.
Best Management & Operational Practices
Best management and operational practices are technically feasible.

72 Database accessed September 15, 2022.
73 EPA’s General Air Quality Permit for New or Modified Minor Source Concrete Batch Plants in Indian Country, July 2016.

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Cyclone
Like baghouses, cyclones require significant ductwork, capture hoods, fans, motors, starters, and stacks,
and are immobile by design. As such, cyclones are technically feasible under the same operating conditions
as baghouses.
ESP
ESPs are a proven technology for reducing PM emissions, especially from hot exhaust streams. Like
baghouses, ESPs require significant ductwork, capture hoods, fans, motors, starters, and stacks, and are
immobile by design. As such, ESPs are technically feasible under the same operating conditions as
baghouses.
Enclosures
Enclosures are technically feasible for controlling PM emissions from coal handling. Enclosures are needed to
capture PM emissions for routing to baghouse, cyclone, or ESP. Enclosures are technically feasible.
Watering
Clinker exiting the kiln along with additives in the finish mill must also remain dry to maintain product
quality. Therefore, it is technically infeasible to water material in the finish mill.
Wet Scrubbers
For general PM, wet scrubbers typically attain control efficiencies up to 99%. Scrubbers are proven effective
at controlling particulate matter from emission streams with a wide range of temperatures and particulate
loading. A wet scrubber is technically feasible.
7.5.3.1.3 Step 3 – Finish Mill PM10 and PM2.5 BACT – Rank Remaining Control Technologies by
Control Effectiveness
Feasible control technologies are ranked according to control effectiveness in the table below.
Table 7-23. Summary of PM10 Control Effectiveness for the Finish Mill
Control Technologies Rank Percent Control Feasible?
Baghouse 1 95 - 99.9% Yes
Wet Scrubber 2 99% Yes
ESP 3 90 – 99.5% Yes
Enclosure 4 50-90% Yes
Cyclone 5 20-70% Yes
Best Management &
Operational Practices 6 Varies Yes

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7.5.3.1.4 Step 4 – Finish Mill PM10 and PM2.5 BACT – Evaluate Most Effective Controls and
Document Results
Baghouses provide the highest emission control efficiency, controlling up to 99.9% of PM emissions from
finish mill equipment. After baghouses, using a wet scrubber or ESP provides similar PM control. Notably,
baghouses, scrubbers, and ESPs require enclosures to aid in capturing emissions and ducting to the control.
Therefore, optimal PM emission control can be achieved through implementing both baghouses and
enclosures where feasible. Plant material sizing and handling is currently done using a series of buildings
and enclosures routed to baghouse controls. Various silos storing material inputs are also equipped with
fabric filters. As the highest ranked technology is applied, there are no adverse energy, environmental or
cost impacts to consider with the use of these control technologies. Thus, no further analysis is required
under EPA’s top-down BACT approach.
7.5.3.1.5 Step 5 – Finish Mill PM10 and PM2.5 BACT – Select BACT
Ash Grove proposes BACT for finish mill PM10 emissions is compliance with NSPS Subpart F, Standards of
Performance for Portland Cement Manufacturing where applicable. Ash Grove will achieve BACT for PM10
emissions from finish mill equipment through the implementation of enclosures, baghouses, and best
management practices.
Table 7-24. Finish Mill PM10 BACT Summary
Description Emission Type BACT Control Emission Limit
Additive Hopper Loading Point
Enclosure, Baghouse,
and Best Management
Practices
10% Opacity and 0.005
grains/dsc
Transfer Point 1 Point Baghouse 10% Opacity and 0.005
grains/dscf
Transfer Point 2 Point Baghouse 10% Opacity and 0.005
grains/dscf
Finish Mill and Separator Point Baghouse 10% Opacity and 0.005
grains/dscf
Raw Material Silos Point Fabric Filters 10% Opacity and 0.005
grains/dscf

7.6 SO2, VOC, and Lead Sources BACT Analysis
The following BACT analysis is grouped by pollutant that will experience an increase in potential emissions
and the associated technically feasible control technologies. As such, the BACT analysis is separated into
SO2, VOC, and lead respectively with organic HAPs addressed with VOCs.
7.6.1 SO2 – Cement Kiln BACT
NSPS Subpart F – Standards of Performance for Portland Cement Plants, establishes emission standards for
cement kiln operations. Specifically, kilns constructed or reconstructed after June 16, 2008, are limited to
0.4 lbs SO2/ton clinker on a 30-day rolling average respectively. This limit is an existing emission limit in the
Leamington Plant’s approval order and Title V. Ash Grove will continue to achieve or exceed this emission

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limitation while achieving BACT for the kiln operations. Ash Grove has reviewed the following sources to
identify available control technologies:
► EPA’s RBLC Database for Portland Cement Manufacturing (process type 90.028); 74
► EPA’s RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019); 75
and
► NSPS Subpart F as an affected emissions facility in 40 CFR 60.62(a)(4);
► Portland Cement Association’s Formation and Techniques for Control of Sulfur Dioxide and Other Sulfur
Compounds in Portland Cement Kiln Systems.76
SO2 emissions are a result of oxidation of sulfur compounds in the rawmix and/or the coal used to fire the
kiln. However, the alkaline nature of the cement provides for direct absorption of SO2 into the product,
thereby mitigating the quantity of SO2 emissions in the exhaust stream.
7.6.1.1.1 Step 1 – Kiln SO2 BACT- Identify All Control Technologies
Control technologies identified for SO2 emissions from coal-fired kiln operations are as follows:
► Baghouse or fabric filter;
► Dry reagent injection prior to baghouse;
► Wet scrubber;
► Process optimization; and
► Good combustion practices.
Baghouse
Baghouses or fabric filters on cement kilns are reported to absorb SO2. An absorbing reagent (e.g., CaO)
must be present in the filter cake for SO2 capture to occur. The absorbing agent in this case would be
cement kiln dust collected by the baghouse. .
Dry Reagent Injection
Where sufficient SO2 absorbing materials are not present within the kiln system, lime injection may promote
SO2 capture. An example of a dry reagent injection system is the addition of calcium hydroxide (Ca(OH)2) to
the kiln feed or its injection in the riser duct between the upper cyclones of a preheater. The Ca(OH)2 reacts
with SO2 to form calcium sulfite and sulfate particles that can be removed by a traditional PM control
technology such as a baghouse. Hydrated lime and sodium bicarbonate are also effective reagents. The
removal efficiency for a dry reagent injection system is up to 70% of the SO2 in the off-gases.77
Wet Scrubber
A spray chamber/tower scrubber system, or wet scrubber, removes SO2 by injection of a wet slurry to react
with the SO2 physically and chemically. Sorbents specific to SO2 removal systems are typically lime based

74 Database accessed September 15, 2022.
75 Database accessed September 15, 2022.
76 https://www.penta.net/wp-content/uploads/2021/07/Sulfur_Control_Techniques_In_Cement_Kilns.pdf
77 Portland Cement Association’s Formation and Techniques for Control of Sulfur Dioxide and Other Sulfur Compounds in
Portland Cement Kiln Systems. 2001. Page 43.

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mixtures of alkaline materials. SO2 reacts with the slurry to form a wet mixture of calcium sulfite and
sulfate. SO2 removal efficiencies up to 99% can be achieved with a wet scrubber.78
Process Optimization
The cement kiln system itself has been determined to provide substantial SO2 control. Cement kiln systems
have highly alkaline internal environments that can absorb potential SO2 emissions when routing exhaust
gases to a preheater and the raw mill. Routing the kiln exhaust gases back through the previous process
steps acts to scrub the SO2 from the exhaust without additional equipment. Due to the interaction of raw
materials and kiln gases, rotary kiln systems have inherent SO2 removal efficiencies ranging between 40-
99% of the sulfur input to the system depending on sulfur content of the fuel and raw mix composition.79
Good Combustion Practices
The use of good combustion practices can effectively minimize SO2 gas formation. Flame impingement is a
significant cause of excess CO emissions, which in turn acts as a reducing agent to sulfates in the clinker in
latter stages of the kiln creating SO2. Avoiding flame impingement on the clinker in the burning zone can
minimize SO2 emissions. In addition to excess CO concentrations, oxygen concentrations within the burning
zone affects SO2 formation, although to a lesser extent than CO. Oxidizing conditions must exist within the
burning zone to form quality clinker by inhibiting the reduction of sulfates by CO. Oxidizing conditions have
the added benefit of minimizing SO2 formation.80
7.6.1.1.2 Step 2 – Kiln SO2 BACT- Eliminate Technically Infeasible Options
All technologies identified are technically feasible.
7.6.1.1.3 Step 3 – Kiln SO2 BACT – Rank Remaining Control Technologies by Control
Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented in the table
below.
Table 7-25. SO2 Control Effectiveness for Kiln Operations
Control Technologies Rank Percent Control Feasible?
Process Optimization 1 99% Yes
Wet Scrubber 2 99% Yes
Dry Reagent Injection 3 60% Yes
Good Combustion
Practices 4 30% Yes
Baghouse 5 Variable Yes

78 From Air Pollution Control Technology Fact Sheet for Spray-Chamber/Spray-Tower Wet Scrubber: EPA-452/F-03-016
79 Portland Cement Association, Formation and Techniques for Control of Sulfur Dioxide and Other Sulfur Compounds in
Portland Cement Kiln Systems. 2001. Pages 39-40.
80 Portland Cement Association, Formation and Techniques for Control of Sulfur Dioxide and Other Sulfur Compounds in
Portland Cement Kiln Systems. 2001. Pages 40-41.

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7.6.1.1.4 Step 4 – Kiln SO2 BACT– Evaluate Most Effective Controls and Document Results
SO2 emissions are most effectively controlled by optimizing the process and utilizing the inherent SO2
scrubbing properties of the kiln system itself. Although wet scrubbers alone can achieve equal control
efficiencies as process optimization, additional capital and operational expenses are required for water
consumption and wastewater discharge. Whereas process optimization achieves the same control
effectiveness and has the added benefit of reduced operational costs. Some capital expense may be
required as part of the process optimization exercise.
Ash Grove optimizes the kiln process by routing the exhaust from the kiln to a preheater and raw mill to
interact with the raw mix, thus creating an atmosphere similar to a dry scrubber system. Good combustion
practices also reduce SO2 formation with the added benefit of energy efficiency. A baghouse is proposed to
capture any particulates formed and exhausted through the preheater and raw mill. Because a combination
of control technologies that are the most efficient are proposed, there are no adverse energy, environmental
or cost impacts to consider with the use of this control technology. Thus, no further analysis is required
under EPA’s top-down BACT approach.
7.6.1.1.5 Step 5 – Kiln SO2 BACT – Select BACT
Ash Grove proposes BACT for control of SO2 emissions from kiln operations consist of process optimization
by routing kiln exhaust to the preheater and raw mill, good combustion practices, and use of a baghouse
prior to exhausting to the atmosphere. Additionally, the Leamington Plant’s Upgrade Project is subject to a
modification of the kiln for SO2. In 40 CFR 60.62(a)(4) it requires a kiln not to exceed 0.4 pounds of sulfur
dioxide (SO2) per ton of clinker on a 30-operating day rolling average if construction, reconstruction, or
modification commences after June 16, 2008.
The following table describes how BACT will be applied to kiln operations.
Table 7-26. Kiln SO2 BACT Summary
Source BACT Control Emission Limit
Kiln Process Optimization, Good Combustion
Practices, and a Baghouse
0.4 lb SO2/ton clinker 30-day rolling
average a
a. The project is subject to a modification under NSPS, Subpart F.
7.6.2 VOC – Cement Kiln BACT
VOCs are generated by incomplete combustion in the kiln. 40 CFR 63 Subpart LLL - NESHAP from the
Portland Cement Industry limits total hydrocarbon and total organic HAP emissions to 24 and 12 ppmv at
7% oxygen. Ash Grove will achieve or exceed these emission limitations while achieving BACT for the kiln
operations. Ash Grove has reviewed the following sources to identify available control technologies:
► EPA’s RBLC Database for Portland Cement Manufacturing (process type 90.028); 81 and
► EPA’s RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019). 82

81 Database accessed September 15, 2022.
82 Database accessed September 15, 2022.

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7.6.2.1.1 Step 1 – Kiln VOC BACT- Identify All Control Technologies
Control technologies identified for VOC emissions from coal fired kiln operations are as follows:
► Process optimization
► Good combustion practices
Process Optimization
Like the Kiln SO2 BACT analysis, optimizing the process to be as energy efficient as possible reduces fuel
throughput and thus reduces VOC emissions. Using a kiln preheater system optimizes energy efficiency of
the kiln system.
Good Combustion Practices
VOC emissions from combustion sources are generated through incomplete combustion of fuel. Good
combustion practices include optimizing the fuel to air ratio and stages of combustion to minimize products
of incomplete combustion.
7.6.2.1.2 Step 2 – Kiln VOC BACT - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.
7.6.2.1.3 Step 3 – Kiln VOC BACT – Rank Remaining Control Technologies by Control
Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented in the table
below.
Table 7-27. Kiln VOC Control Effectiveness for Kiln Operations
Control Technologies Rank Percent Control Feasible?
Process Optimization 1 Variable Yes
Good Combustion
Practices 2 Variable Yes
7.6.2.1.4 Step 4 – Kiln VOC BACT – Evaluate Most Effective Controls and Document Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove optimizes the kiln
process by capturing waste heat from the clinker cooler and routing to a kiln preheater. Good combustion
practices also reduce VOC formation with the added benefit of energy efficiency. Because a combination of
control technologies that are the most efficient are proposed, there are no adverse energy, environmental
or cost impacts to consider with the use of this control technology. Thus, no further analysis is required
under EPA’s top-down BACT approach.

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7.6.2.1.5 Step 5 – Kiln VOC BACT – Select BACT
Ash Grove proposes that BACT for control of VOC emissions from kiln operations consist of process
optimization by routing kiln heat to the preheater and good combustion practices. The following table
describes how BACT will be applied to kiln operations.
Table 7-28. Kiln VOC BACT Summary
Source BACT Control Emission Limit
Kiln Process Optimization and Good
Combustion Practices 24 ppmv @ 7% O2
7.6.3 VOC – Grinding Aid BACT
A grinding aid containing VOC is added to the new finish mill to disperse particles within the mill and expose
more surface area to grinding. An increase in grinding aid usage proportionally increases potential VOC
emissions because volatiles from the grinding aid are not combusted in the kiln. Ash Grove has reviewed the
following sources to identify available control technologies:
► EPA’s RBLC Database for Portland Cement Manufacturing (process type 90.028); 83 and
7.6.3.1.1 Step 1 –Grinding Aid VOC BACT- Identify All Control Technologies
Control technologies identified for VOC emissions from Portland Cement finish mills are as follows:
► Process optimization
Process Optimization
Limiting the use of VOC-containing grinding aid to the minimum necessary to achieve optimal grinding
conditions reduces VOCs introduced to the system.
7.6.3.1.2 Step 2 –Grinding Aid VOC BACT - Eliminate Technically Infeasible Options
The technology identified is technically feasible.
7.6.3.1.3 Step 3 –Grinding Aid VOC BACT – Rank Remaining Control Technologies by Control
Effectiveness
Only one technically feasible control technology remains in the analysis and will be carried forward to Step
4.

83 Database accessed September 15, 2022.

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7.6.3.1.4 Step 4 –Grinding Aid VOC BACT – Evaluate Most Effective Controls and Document
Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove proposes to install a
vertical finish mill with this project. Due to the new modern mill’s efficiency, it is anticipated a reduced the
amount of grinding aid required for each ton of clinker ground. Because the only feasible control technology
is proposed, there are no adverse energy, environmental or cost impacts to consider with the use of this
control technology. Thus, no further analysis is required under EPA’s top-down BACT approach.
7.6.3.1.5 Step 5 –Grinding Aid VOC BACT – Select BACT
Ash Grove proposes that BACT for control of VOC emissions from finish mill grinding operations consist of
process optimization which is installation of a more efficient grinding mill requiring less use of grinding aid.
The following table describes how BACT will be applied to the finish mill operations.
Table 7-29. Grinding Aid BACT Summary
Source BACT Control Emission Limit
Grinding Aid Good management practices 2.37 tpy.
7.6.4 Lead Emissions
The lead emissions are anticipated to demonstrate a minor increase as a result of the proposed increase in
clinker throughput with the Leamington Plant upgrade project. Lead emissions result from residual amounts
of lead in raw materials and fuel. Lead emissions will be controlled the same as PM, therefore a separate
top-down BACT analysis has not been conducted as the Leamington Plant has applied the most effective
controls.
7.7 GHG Background
On October 9, 2009 the mandatory GHG reporting regulation, referred to as 40 CFR 98, was published in
the Federal Register. Through 40 CFR 98, the U.S. EPA established the GHG Reporting Rule, which requires
the annual reporting of GHG data and other relevant information from large sources and suppliers in the
United States.84 Monitoring through the GHG Reporting Program (GHGRP) began in 2010, with first reports
due by March 31, 2011. Per 40 CFR 98.2(a)(1), any facility associated with cement production is subject to
the GHGRP and must report CO2e emissions. The CO2e is the sum of equivalent GHG emissions from CO2,
CH4, and N2O, with their respective global warming potentials (GWP) applied. Ash Grove’s facility is subject
to GHG Reporting Rule and monitors CO2 emissions from its kiln with a continuous emissions monitoring
system (CEMs).
On June 23, 2014, the U.S. Supreme Court held that required PSD permits (based on emissions of non-GHG
pollutants) may continue to require limitations on GHG emissions based on the application of BACT as an
“anyway source”.85 The Leamington Plant modification project is a major source for PSD for both PM10 and

84 Greenhouse Gas Reporting Program Requirements for Importers and Exporters, Paragraph 1, U.S. EPA, last updated August
29, 2018
85 Utility Air Regulatory Group v. EPA, 573 U.S. 302 (2014)

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PM2.5, and GHGs are estimated to be greater than 75,000 tpy and greater than zero on a mass basis;
therefore, GHGs are evaluated for BACT as an anyway source.
7.8 Cement Manufacturing GHG BACT
A BACT analysis has been conducted for CO2e emissions from the kiln system. For this GHG BACT analysis,
various control technologies or combination of technologies were identified using the RACT/BACT/LAER
Clearinghouse, available literature including guidance published by EPA and South Coast Air Quality
Management District (SCAQMD), current air regulations, other regulatory organizations, and engineering
experience. Research conducted on October 4, 2022, revealed that information on control technologies in
the RACT/BACT/LAER Clearinghouse database is limited. In March 2011, EPA published GHG permitting
guidance, as well as a white paper on available and emerging technologies for reducing GHG emissions from
the Portland cement industry in October 2010. Additionally, EPA published a series of videos on GHG permit
training in December 2010. The SCAQMD published GHG BACT guidance in 2021. Additional sources of
information where reviewed and documented based on publications from trade organizations and other
governmental committees with GHG or carbon reduction guidelines and/or recommendations.

EPA has defined in 40 CFR 86.1818-12(a) GHGs as a group of six gases: CO2, nitrous oxide (N2O), methane
(CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). GHG emissions
from the kiln result from calcination and fuel combustion. Since the primary GHG emitted by a kiln is CO2,
the BACT analysis focuses on CO2 emissions from the kiln. Emissions of CH4 and N2O are minimal from
cement kilns.

Per EPA guidance, GHG control technologies for consideration in a BACT analysis for Portland Cement
Manufacturing include:
► Source-wide energy efficiency strategies;
► Raw material substitution;
► Blended cements;
► Carbon capture utilization and storage; and
► Fuel switching.
► Other emerging technologies
7.8.1 Step 1: Identify All Control Technologies
The CO2 emissions from a cement kiln are generated by the calcination process (conversion of the calcium
carbonate in limestone to calcium oxide) and by combustion of fuel in the kiln. Potential control technologies
to reduce these CO2 emissions for a cement kiln are addressed in EPA’s white paper on Available and
Emerging Technologies for Reducing GHG Emissions from the Portland Cement Industry.86 These
technologies are listed below in Table 1-1.

86 U.S.EPA, Office of Air and Radiation, Available and Emerging Technologies for Reducing Greenhouse Gas Emissions from the
Portland Cement Industry, Oct 2010.

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Table 7-30. Potential Control Technologies for CO2
Category Potential Cement Kiln Control
Technologies
Energy Efficiency
Improvements for
the Clinker
Production Process
Pre-heater/Pre-calciner Kiln Process
Kiln Seal Management Program
Refractory Selection (Kiln Insulation)
Energy Recovery from Clinker Cooler
Use of Fluxes and Mineralizers
Heat Recovery for Power - Cogeneration
Fuel Substitution Use of Alternate Fuels (such as natural gas,
whole tires, biofuels, etc.)
CCUS Carbon Sequestration
Oxyfuel combustion
Post-combustion Capture
7.8.2 Step 2: Eliminate Technically Infeasible Options
The second step in the BACT analysis is to eliminate any technically infeasible control technologies. Each
control technology which is considered to be clearly infeasible based on physical, chemical, and engineering
principles is eliminated. The control technologies and their technical feasibilities are summarized in the Table
1-2.
Table 7-31. Technical Feasibility Analysis
Category Potential Cement Kiln Control
Technologies
Technically Feasible
(Y/N)?
Energy Efficiency
Improvements for
the Clinker
Production Process

Pre-heater/Pre-calciner Kiln Process Y
Kiln Seal Management Program Y
Refractory Selection (Kiln
Insulation)
Y
Energy Recovery from Clinker
Cooler
Y
Use of Fluxes and Mineralizers N
Heat Recovery for Power -
Cogeneration
N
Fuel Substitution Use of Alternate Fuels (such as
natural gas, whole tires, biofuels,
etc.)
Y
CCUS

Carbon Sequestration N
Oxyfuel combustion N
Post-combustion Capture N

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7.8.2.1 Energy Efficiency of the Clinker Production Process
7.8.2.1.1 Pre-heater/Pre-calciner Kiln Process
Clinker production in the kiln generally accounts for over 95% of the energy use at a Portland cement
facility with in-line raw mill.87 There are five types of cement kilns – wet process, long dry process, semidry
process, dry process with pre-heater, and dry process with pre-heater/pre-calciner. Fuel consumption
decreases and energy efficiency increases with the order of the kilns with the dry process with pre-
heater/pre-calciner being the most energy efficient process.

The energy efficiency of pre-heater/pre-calciner kilns is achieved through the use of cyclone pre-heaters and
a pre-calciner vessel. Standard pre-heater towers typically have three stages of preheat process. The kiln at
the Leamington facility will have five stages. In the pre-heater stages, the kiln feed is pre-heated with the
hot exhaust gases from the kiln. This staging occurs in cyclone structures contained in a pre-heater tower
where hot flue gases from the kiln move counter currently to the kiln feed material. Thus, with the heat
from the kiln flue gases recovered, process time is reduced due to contact between the raw feed materials
and the hot gases. The length of the rotary kiln is also reduced. Gases exiting the pre-heater tower are
further recovered and used to dry raw materials in the raw mill.

With the Leamington Plant Upgrade project, the pre-calciner will be upgraded with a new separate tertiary
air duct to supply hot air from the kiln hood or grate cooler. The pre-calciner will utilize enhanced
combustion technology and upgrade the existing selective non-catalytic reduction (SNCR) system. The pre-
calciner improves fuel efficiency of the kiln by separating the majority of the “clinkering” step from the
majority of the “calcination” step. This enables better management and efficiency of fuel combustion. The
project will also include replacement of a portion of the preheater. Pre-heater/pre-calciner kiln technology is
commercially available and has been demonstrated successfully at a number of cement plants and is
therefore considered technically feasible.
7.8.2.1.2 Kiln Seal Management Program
Kilns have seals at their inlet and outlet to reduce heat “losses” due to air infiltration. Leakage increases fuel
consumption due to the cooling effect of the air, reducing energy efficiency of the kiln, and increasing fuel
requirements. At one existing cement facility, fuel consumption was reduced by 4% by maintaining an
adequate kiln seal management program.88 The Leamington Plant repairs the kiln seal as routine
maintenance and repair. Various types of seals are commercially available (include pneumatic, lamella-type,
and spring-type seals) are considered technically feasible, but not further considered as they are a
maintenance item regularly replaced.
7.8.2.1.3 Refractory Selection (Kiln Insulation)
A cement kiln’s steel shell is lined in the combustion zone with heat resistant refractory to insulate the shell,
reducing heat losses through the shell (and thus increasing energy efficiency) and protecting the shell from
corrosive nature of the raw materials. Refractories can be made of materials such as bricks or cast
refractory concrete. Having a high temperature insulating refractory reduces kiln fuel usage.

Choice of a refractory material depends on fuels, raw materials, and operating conditions. Selection of a
refractory material needs to balance insulating abilities with durability to withstand possible localized acidic

87 http://www.energystar.gov/ia/business/industry/LBNL-54036.pdf
88 U.S.EPA, Office of Air and Radiation, Available and Emerging Technologies for Reducing Greenhouse Gas Emissions from the
Portland Cement Industry, Oct 2010.

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corrosion. Refractory selection is a technically feasible control technology to reduce CO2 emissions, but not
further considered as it is replaced regularly through routine, maintenance and repair.
7.8.2.1.4 Design of Clinker Cooler
In the cement production process, clinker produced by the cement kiln is sent to the clinker cooler for rapid
air-cooling before it is sent to the finish mill. In this process, clinker is cooled from about 2,000°F to 200°F.
This rapid cooling improves grindability of the clinker and optimizes cement reactivity. Heat is recovered
from the cooling process and returned to the process at the kiln preheater, lowering overall energy
consumption.

While older cement plants may use rotary coolers, modern cement plants use more efficient grate coolers.
Grate coolers include travelling grate, reciprocating grate, or vertical coolers. Reciprocating grate coolers are
more energy efficient than other types of clinker coolers.89 Although reciprocating grate coolers increase
electricity consumption by about 2.5 kWh/ton cement, use of a reciprocating grate cooler can reduce kiln
fuel consumption by as much as 8 percent.90 The Leamington Plant Upgrade Project will involve improving
and expanding the existing grate cooler. Grate coolers are a commercially available technology that has
been demonstrated in practice at other cement plants and is therefore considered technically feasible.
7.8.2.1.5 Use of Fluxes and Mineralizers
The use of fluxes and mineralizers has been studied extensively in the cement industry. Fluxes and
mineralizers can be added to the cement kiln raw feed to lower the peak temperature required to form
cementitious compounds in the clinker. This can correspondingly reduce fuel consumption and therefore has
the potential to reduce GHG emissions.
Generally, the most useful fluxing agent is fluoride. Other fluxes exist but have less positive impact and
more negative side effects to the cement kiln operations and product quality. Small amounts of fluoride can
reduce the peak temperature in the cement kiln required to form cement clinker by 100-200 °F. Currently,
the most common source of fluoride as a flux is spent aluminum potliner which is a hazardous waste and
can therefore only be used at cement plants permitted to burn hazardous wastes.
There are several significant potential negative side effects of using fluoride as a fluxing agent. Decreases in
product strength are a concern (which limits the uses of cement), as well as a possible negative impact on
the downstream use of fly ash and slags to create blended cements. Fluorides are also known to be
corrosive to cement kiln refractory and this can increase the frequency of kiln maintenance and decrease
the overall kiln thermal efficiency. Further, because some cement kiln raw mixes and kiln systems can be
over-sensitive to fluxing agents, there is the very real hazard that the use of fluorides in this manner could
result in a kiln “going liquid” which results in molten material pouring into the clinker cooler, destroying the
grate system in the cooler and resulting in significant damage and repairs (as well as a potential safety
hazard to plant personnel). Based on the foregoing, this technology is considered technically infeasible at
this time.
7.8.2.2 Heat Recovery for Power - Cogeneration
Since the exhaust streams from cement manufacturing processes such as the kiln, clinker cooler, and pre-
heater/pre-calciner contain significant amounts of heat energy, a portion of this heat could theoretically be

89 Ibid.
90 Ibid.

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used to generate power using steam or Rankine cycles, meeting some of the plant’s electrical needs. Given
the inherent moisture content of the limestone feed to a kiln, as present when quarried, it is more
appropriate to use the low-quality heat energy in the exhaust gases from the kiln system to dry the raw
materials than for power generation. Ash Grove has modernized the kiln to an appropriately designed five
stage pre-heater/pre-calciner kiln with in-line raw mill. Since the kiln flue gases are relied upon to preheat
the raw mix, the exhaust temperature from the kiln system that would be available for cogeneration would
be approximately 200 F. At this temperature, cogeneration is not an energy efficient option. Cogeneration
is not considered technically feasible.
7.8.2.3 Fuel Substitution
CO2 emissions from fossil fuel burning in the kiln could be potentially reduced by using relatively cleaner
burning fuels such as oil, natural gas, low carbon engineered fuels, and biomass. Although cement kilns in
the U.S. use coal and petroleum coke as primary fuels, use of alternate fuels such as natural gas is
technically feasible. The Leamington Plant currently has permitted the use of tires, cherry pits, diapers, and
other alternate fuels, which are used as available. The additional considerations on environmental and
economic impacts of using alternate fuels are discussed in further sections.
7.8.2.4 CCUS
CCUS is an approach to CO2 abatement, by which CO2 arising from large point sources like power plants and
industrial processes is captured and stored away from the atmosphere for a very long period. Utah has been
identified as a carbon and hydrogen hub by the Great Plains Institute, meaning it has the potential
resources to develop decarbonization solutions and deploy them at scale.91 Criteria for hub designation are a
high concentration of industrial emitters, high fossil fuel use, the presence of facilities qualifying for federal
carbon capture tax credits, geologic formations suitable for CO2 storage, existing commodity distribution
infrastructure, and traditional fossil fuel transportation infrastructure. It’s important to note that while
traditional infrastructure is in place for fossil fuel and other commodities, CO2 transportation infrastructure
does not yet exist in the region of the Leamington Plant.

CCUS is seen as a critical part of cutting CO2 emissions from the cement industry. Various CCUS
technologies are undergoing research and select few have been implemented at a pilot scale at cement
manufacturing plants throughout the world. In 2021, the US Department of Energy announced two initial
pilot scale CCUS project at cement plants in Colorado and Texas.92 These projects and other CCUS
technologies relevant to the cement industry are addressed in this technical feasibility analysis.

The SCAQMD BACT guidance specifically addresses CCUS technical feasibility. A potential control technique
listed in Step 1 of the BACT process is only technically feasible if it has been successfully operated on the
source type under review or is available and applicable to the source in question.93 A control technology is
only considered available if it has reached the licensing and commercial sales phase of development and is
commercially available. EPA guidance states “technologies in the pilot scale testing stages of development
would not be considered available for BACT review.” 94

CCUS technologies involves three main process steps: carbon capture, transport, and storage. First, the CO2
must be separated and/or captured from the emissions stream. Once captured, the CO2 must be

91 Great Plains Institute, An Atlas of Carbon and Hydrogen Hubs for United States Decarbonization, February 2022. Page 5.
92 Portand Cement Association, Roadmap to Carbon Nuetrality, Januaray 2022. Page 30.
93 South Coast Air Quality Managemtn District Current Bact Guidelines, Part E – Policy and Procedures for Facilities Subject to
Prevention of Significant Deterioration for Greenhouse Gases, February 5, 2021. Page 52.
94 EPA New Source Review Workshop Manual, October 1990. Page B.18.

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transported to a location for use or storage. After transport, the captured CO2 is either used or injected into
an underground reservoir for long term storage (i.e., sequestration). Some additional considerations that
have direct implications on technical feasibility at the Leamington facility include:

► Capturing CO2 is very energy intensive and has only been successfully implemented at scale on
commercial sources with high purity CO2 off gas streams such as ethanol, fertilizer, power generation
industries. Only select technologies are applicable to the cement kilns.
► Infrastructure and land use necessary for transport is not in place. Although identified as feasible in long
term, no CO2 pipeline is constructed in vicinity of the Leamington Plant.95 Adding the required
infrastructure will have statewide implications on land use.
► Infrastructure for underground CO2 injection is not in place. The Utah Geologic Survey has identified
abundant subsurface geologic reservoirs suitable for carbon sequestration.96 None of these resources
have been developed commercially and no Class VI injection wells are permitted anywhere within Utah.
In the Intergovernmental Panel on Climate Change’s (IPCC) Special report on CCUS, launched in
2005, four different types of CO2 capture technologies were distinguished: post-combustion,
pre-combustion, oxyfuel combustion, and industrial separation. This classification differentiates
industrial CO2 capture from that carried out in the power sector. However, the separation technologies
that can be used to capture CO2 in industry can have many similarities with those of the power sector,
depending on the specific process considered. In the case of the cement industry, CO2 capture can be
accomplished using post-combustion and Oxyfuel combustion technologies.97 The following potential CCUS
technologies can be considered for CO2 emission control from cement kilns: carbon sequestration, Oxyfuel
combustion, and post-combustion capture.
7.8.2.4.1 Carbon Sequestration
Carbon sequestration involves separation and capture of CO2 from the kiln exhaust gases, pressurization of
the captured CO2, transportation of the captured CO2 via pipeline, and injection and long-term geologic
storage of the captured CO2. Carbon sequestration technology is still under development and has not been
demonstrated at any cement plant in the U.S. Further, the Leamington facility is in an area with no available
CO2 pipelines that could transport emissions from the plant. Carbon sequestration is therefore considered
technically infeasible.
7.8.2.4.2 Oxyfuel Combustion
Oxyfuel combustion is a process in which fuel (coal) is burned in presence of nearly pure oxygen instead of
air. Nitrogen from the combustion air is removed using an air separation unit prior to feeding the air to the
kiln. Under these conditions, the exhaust gases are rich in CO2 (up to 80%). CO2 from the exhaust gases is
discharged to a CO2 separation, purification, and compression facility. This technology is still in research
stages and has not been demonstrated in practice at any cement plant in the U.S.98 Therefore, Oxyfuel
combustion is considered technically infeasible.

95 Great Plains Institute, An Atlas of Carbon and Hydrogen Hubs for United States Decarbonization, February 2022. Page 70. 96 Utah Geologic Survey, Survey Notes – May 2022. Eugene Ssymanski, PhD. Assessing geologic Carbon Sequestration
Opportunities in Utah. https://geology.utah.gov/map-pub/survey-notes/assessing-geologic-carbon-sequestration-
opportunities-in-utah/
97 Plaza MG, Martínez S, Rubiera F. CO2 Capture, Use, and Storage in the Cement Industry: State of the Art and Expectations.
Energies. 2020; 13(21):5692. https://doi.org/10.3390/en13215692. Page 4.
98 Ibid. Page 17.

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7.8.2.4.3 Post Combustion Capture
Post combustion capture technologies utilize kiln exhaust gasses and therefore do not directly alter kiln
firing or clinker creation. There are three different categories post-combustion technologies that can be used
to capture the CO2 from the kiln-off gas: chemical absorption, membranes, and sorption with solids. A brief
review of the state of the art of each technology is presented below.
Chemical Absorption
Chemical absorption is the most advanced post combustion capture technology. Other industries with high
purity CO2 gas streams, such as ethanol production, have demonstrated this technology is feasible at a
commercial scale using proprietary licensed technology. A brief description of the leading technologies is
presented below.
► SkyMine® Process – The kiln exhaust is first treated with a diluted sodium hydroxide (NaOH) solution to
remove SO2 and NOX. Once these pollutants are removed, the exhaust is sent to a scrubber system
where high concentration NaOH is used to react the CO2 to form sodium carbonate (Na2CO3). The
Na2CO3 solution is then sent to another scrubber where it reacts with pressurized exhaust gasses to
create sodium bicarbonate (NaHCO3) crystals. These crystals are separated in a centrifuge and the
resultant liquid is returned to the process. The NaOH solution is generated through electrolysis of NaCl
brine in a membrane cell that produces HCl as byproduct.99
► Fortera Recarb Process® - The Fortera Recarb Process involves capture of CO2 by chemically converting
CO2 to carbonates like the SkyMine® process. In this process, kiln exhaust gases are passed through a
wet scrubber with high pH water containing calcium, magnesium, sodium, and chloride as the scrubbing
liquid. CO2 in the exhaust gases is absorbed in the water and is converted to carbonic acid. High pH of
the water results in dissociation of the carbonic acid which reacts with the calcium and magnesium ions
in the water to form carbonate minerals. The carbonate minerals can be precipitated from the solution
for use in blended cement or other building materials. The scrubbing water can be treated to remove
sodium chloride and reused in the process.100
► Amine Scrubbing - This technology uses a scrubbing solvent such as monoethanolamine which
chemically binds the CO2 in the flue gas. The scrubbing solvent is then passed through a stripper where
it is heated to release the bound CO2. The stripped CO2 can be then compressed and transported to a
storage site. Such type of post-combustion control has been studied extensively for combustion sources
at gas fired power stations and has been used in the natural gas processing industry to remove
hydrogen sulfide and CO2 from natural gas. Several issues that still need to be addressed for application
of this technology at cement plants include effect of SO2 in the flue gas on formation of amine salts,
solvent degradation due to NOx in the flue gas, and high energy demands.101
Currently, these technologies have only been tested at pilot scale in the cement industry and show promise
for achieving the industry goal of being carbon neutral by 2050. Therefore, chemical absorption is currently
not technically feasible.

99 Ibid. page 5
100 Hargis, C.W.; Chen, I.A.; Devenney, M.; Fernandez, M.J.; Gilliam, R.J.; Thatcher, R.P. Calcium Carbonate Cement: A
CarbonCapture, Utilization, and Storage (CCUS) Technique. Materials 2021, 14, 2709. https://doi.org/10.3390/ma14112709
101 Plaza MG, Martínez S, Rubiera F. CO2 Capture, Use, and Storage in the Cement Industry: State of the Art and Expectations.
Energies. 2020; 13(21):5692. https://doi.org/10.3390/en13215692. Page 6.

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Membranes
Post-combustion membrane technology uses permeable or semi-permeable membranes to separate CO2
from flue gas. Gasses permeate the membrane at different speeds allowing for selective separation. The
separated CO2 can be then compressed and sent to storage site. This technology is still in the research
stages for cement plants as membranes large enough to handle the kiln exhaust are not yet available.102
Therefore, this technology is considered technically infeasible.
Sorption with Solids
Sorption works by concentrating CO2 found in the kiln exhaust onto a sorbate through physical and chemical
means. Two technologies have emerged with promise for cement manufacturing. These include physical
sorption using various solids at low temperature and chemical sorption using a variation of the calcium
looping process. The mechanisms of physical and chemical sorption as they relate to CO2 capture from
cement kilns is presented below.
► Physical Sorption – This process may use carbon materials, zeolites, alumino-phosphates, alumino-silico-
phosphates, or metal–organic frameworks. The sorbent is regenerated using pressure swing adsorption,
temperature swing adsorption, or high purity purge gas. This technology is planned for pilot scale
demonstration project at LafargeHolcim’s Portland Cement Plant in Florence, Colorado. No commercial
scale projects have been implemented to date.103
► Calcium Looping – This promising technology is based on the reversible carbonation reaction where
calcium oxide (CaO) and CO2 combine to form calcium carbonate (CaCO3). CaO is put into contact with
kiln exhaust and allowed to form CaCO3. The CO2 is then separated in a calcination reaction and can be
capture. CaO is regenerated in the calciner and reused in the process. The calciner must use Oxyfuel
combustion to generate a high purity CO2 gas stream. This technology can be implemented as a
standalone post combustion control or integrated into the existing kiln calciner to improve energy
efficiency. This technology has been studied at length with several pilot scale projects implemented
throughout the world, yet no commercial scale projects have been implemented to date.104
7.8.3 Step 3: Rank Remaining Control Technologies by Control Effectiveness
The third step in the BACT analysis is to rank remaining control technologies by control effectiveness. Table
1-3 presents a summary of the remaining control technologies and their associated control efficiencies.105

Table 7-32. Summary of Control Technologies
Cement Kiln CO2 Control Technologies Status
Fuel Substitution Possible BACT

102 Ibid. Pages 10 and 11.
103 Ibid. Pages 12 and 13.
104 Ibid. Pages 14-16.
105 While evaluating available technologies for reducing GHGs and improving energy efficiency, it should be noted that it is not
feasible to simply sum the energy efficiency savings for single measures to calculate total reduction potential since some of
the technologies have interacting impacts, one unit of energy can be reduced only once, and many thermal energy reducing
measures increase electrical energy consumption. (Reference - Cement Sustainability Initiative, World Business Council for
Sustainable Development, “Development of State of the Art-Techniques in Cement Manufacturing: Trying to Look Ahead”,
(CSI/ECRA – Technology Papers), Section 2.1, March 2017.)

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Trinity Consultants 7-54
Cement Kiln CO2 Control Technologies Status
Energy Efficiency Improvements for the
Clinker Production Process
Currently implemented BACT and
proposed with project
Energy Efficiency Improvements in Facility
Operations
Currently implemented BACT and
proposed with project
7.8.4 Step 4: Evaluate Most Effective Controls and Document Results
The fourth step in a BACT analysis is to complete the top-down analysis of the applicable control
technologies and document the results. The control technologies are evaluated on the basis of economic
and environmental considerations. Since all technically feasible energy efficiency improvements and changes
to product composition will be implemented, this section will focus on economic and environmental
considerations of fuel substitution to natural gas only. The other feasible technologies will be carried
forward to Step 5 in the BACT process.
7.8.4.1 Fuel Substitution
Ash Grove uses coal as the primary kiln fuel with diesel fuel used for start-up and is permitted to use waste
derived alternative fuels. Alternative fuels are used as availability dictates. Natural gas is currently used as a
supplemental fuel but usage is constrained by pipeline size and any significant increase in utilization would
require a new supply line and burner pipe. Firing natural gas as the primary kiln fuel can reduce CO2
emissions from fuel combustion by as much as 40%.106 However, studies have shown that use of natural
gas as primary kiln fuel can result in three times more NOx emissions than NOx emissions from coal firing.107
Creating more NOx to reduce GHG emissions is undesirable as it is a precursor to both ozone and PM2.5. Fuel
substitution essentially trades emissions of one regulated pollutant for another. Any benefit to public health
and welfare with this emissions trading scheme is debatable and Ash Grove does not believe such a tradeoff
is in the public’s interest.

Emissions trading aside, switching the kiln to natural gas as the primary fuel will require significant capital
investment and increase operating cost. The Cement Sustainability Initiative estimates capital costs to
retrofit a coal fired kiln to use natural gas as the primary fuel as an average of 10M euros in 2015.108 Using
a 2015 exchange rate of 1.1 euro/dollar and adjusting for inflation, this equals $12.95 M in September
2022.109 This estimate does not include installing additional pipeline capacity to service the kiln. The
Leamington Plant has an existing natural gas pipeline for startup and supplementing fuel, but the burner
and line would need to be completely replaced.

The nearest natural gas transmission pipeline is located approximately five (5) miles west of Nephi, UT and
conservatively estimated to be 11 miles from the Leamington Plant. The American Petroleum Institute
estimates the average U.S. gathering line pipeline cost for a 12-inch pipeline to be $83,137 per inch-mile
with a western regional cost multiplier of 0.94 creating a regional cost of $78,149 per inch-mile in 2016

106 U.S.EPA, Office of Air and Radiation, Available and Emerging Technologies for Reducing Greenhouse Gas Emissions from
the Portland Cement Industry, October 2010.
107 Neuffer, B., Laney, M., “Alternative Control Techniques Document Update – NOx Emissions from New Cement Kilns”, US
EPA # EPA-453/R-07-006, November 2007.
108 Cement Sustainability Initiative, World Business Council for Sustainable Development, “Development of State of the Art-
Techniques in Cement Manufacturing: Trying to Look Ahead”, (CSI/ECRA-Technology Papers), Section 3.13, March 2017.
109 The U.S. Bureau of Labor Statistics CPI inflation calculator used to calculate inflation to August 2022. The tool can be
accessed at: https://www.bls.gov/data/inflation_calculator.htm

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Trinity Consultants 7-55
dollars.110 Adjusted for inflation this equals $97,904.95 per inch-mile in September 2022. Using a 12-inch
pipeline and 11-mile distance, this equates to a pipeline installation cost of $12.92M to service the kiln.

Estimated capital cost to switch to natural gas fuel exceeds $25M. This large cost alone might not preclude
further analysis if the technology showed clear benefit. Implementing natural gas technology would provide
incremental public health and welfare benefit globally by reducing CO2 emissions, while increasing NOX
emissions and negatively impacting public health and welfare locally. There is no clear benefit to such a
trade-off. Methane leaks associated with natural gas infrastructure would also offset some of the CO2
reduction. Furthermore, such a large investment in fossil fuel infrastructure would provide argument to
prevent switching fuels to a reduced or zero carbon fuel in the future. Switching fuels to another fossil fuel
to reduce CO2 emissions has finite potential to mitigate CO2 emissions and is far less promising than
emerging CCUS technologies at mitigating the social impacts of CO2 emissions. Therefore, Ash Grove does
not consider fuel switching to natural gas as a feasible option.
7.8.5 Step 5: Select BACT
The fifth step in a BACT analysis is to select BACT based on the most stringent control option not eliminated
as technically, environmentally, or economically infeasible. Ash Grove proposes to continue to use an
appropriately designed in-line raw mill pre-heater/pre-calciner kiln with five (5) stage pre-heater, it is
implementing additional energy efficiency improvements described in this application with the proposed
project. Ash Grove utilizes modern grate coolers and is improving the efficiency of the clinker cooling
process with the upgrade project. The proposed pre-heater/pre-calciner kiln will provide finished product to
the local market produced in the most energy efficient and environmentally sound method of producing
Portland cement, as well as in the most economical method.

The GHG intensity metric used in the cement manufacturing industry is ton CO2e/ton clinker produced. This
provides an accurate GHG efficiency of clinker production and allows comparison across cement kilns. Ash
Grove proposes a GHG intensity metric of the lowest CO2e/ton clinker produced listed in the RBLC which is
equivalent to 0.92. The table below provides GHG BACT limits from cement kilns listed in the RBLC.
Table 7-33. RBLC1 Summary of Portland Cement Kilns GHG Intensity Metric
RBLC ID
Permit
Issuance
Year
Plant Normalized Emission Rate
(ton CO2e/ton clinker)
TX-0831 2/19/2019 GCC Permian 0.92
CO-0074 7/9/2012 GCC Rio Grande 0.95
TX-0821 8/7/2017 Alamo Cement 0.961
TX-0822 11/16/2017 Capitol Aggregates 0.97
TX-0866 10/24/2019 Texas Lehigh Cement
Company 0.97
IN-0312 7/25/2019 Lehigh Cement Company 0.97
1RBLC database accessed October 4, 2022.

110 U.S. Oil and Gas Infrastructure Investment Through 2035. American Petroleum Istitute, Exhibit 8, Page 21.

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Ash Grove is proposing a BACT limit equivalent to 0.92-ton CO2e/ton clinker. Ash Grove will use a
continuous emission monitoring system (CEMS) for CO2 to demonstrate compliance with this limit. The kiln
GHG BACT summary is provided below.
Table 7-34. Kiln GHG BACT Summary
Pollutant BACT Control Emission Limit
CO2e Energy Efficient Design
and Operation 0.92 Ton CO2e/Ton Clinker

7.9 New Finish Mill Heater GHG BACT
The proposed second finish mill will include a process heater to maintain a minimum temperature during
milling. The proposed heater will run on natural gas and is rated at 10.43 MMBtu/hr. Startup and shutdown
emissions from the heater are anticipated to be no greater than normal operation as the process is simply a
matter of bringing the heater to operating temperature. For this GHG BACT analysis, the RBLC was
consulted for similar sized external combustion sources to determine feasible control technologies111 along
with the same sources referenced in the Cement Manufacturing GHG BACT analysis. The following BACT
analysis follows the EPA five-step top-down approach.
7.9.1 Step 1 - Identify All Control Technologies
The following technology options are potentially available for the control of GHG emissions from similar
sized natural gas external combustion sources:

► Good Combustion Practices
► Fuel Selection
► Best Management and Operating Parameters
7.9.2 Step 2 – Eliminate Technically Infeasible Options
7.9.2.1 Good Combustion Practices
Good combustion practices include following manufacturer recommendations for operation and maintenance
to optimize the amount of fuel consumed through the burner. Good combustion practices are technically
feasible.
7.9.2.2 Fuel Selection
GHG emissions from fuel combustion are largely dependent on the type of fuel that is oxidized. Fuels with
lower carbon intensity, such as propane and natural gas, have lower GHG emissions than fuels with high-
carbon intensity. Biomass fuels can reduce net GHGs below fossil fuels. The proposed finish mill heater
requires rapid startup times and frequent starts and stops. Of the fuels available at the Leamington Plant,
natural gas is the lowest carbon intensity fuel available that meets the needs of the process design. The

111 RBLC querried for process code 13.310 – Natural Gas Combustion in Commercial/Institutional Size Boilers/Furnaces and
pollutant = GHGs on November 8, 2022.

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Trinity Consultants 7-57
proposed heater is natural gas fired and designed to meet the process requirements. Therefore, selecting a
different fuel than is proposed is not technically feasible.
7.9.2.3 Best Management Practices
The heater is used to maintain a minimum operating temperature in the proposed finish mill. During
summer and periods of warm weather, the process may not require supplemental heat. Reducing heater
operation to only periods when necessary for process optimization prevents excess GHG emissions. Best
management practices are technically feasible.
7.9.3 Step 3 – Rank Remaining Control Technologies by Control Effectiveness
The third step in the BACT analysis is to rank remaining control technologies by control effectiveness. The
table below presents a summary of the remaining control technologies and their associated control
efficiencies.
Table 7-35. Summary of Control Technologies
Finish Mill Heater GHG
Control Technologies
Control
Efficiency
Good Combustion Practices Varies
Best Management Practices Varies
7.9.4 Step 4 – Evaluate Most Effective Controls and Document Results
Both remaining control technologies are proposed for implementation to mitigate excess GHG emissions.
Therefore, no further consideration of economic or environmental impacts are required.
7.9.5 Step 5 – Select BACT
Ash Grove is proposing good combustion and best management practices as BACT for control of GHG
emissions from the new finish mill heater. Ash Grove will follow the manufacturers recommendations for
operation and maintenance of the heater and reduce heater operation when feasible. The finish mill heater
GHG BACT summary is provided below.
Table 7-36. New Finish Mill Heater GHG BACT Summary
Pollutant BACT Control Emission Limit
CO2e Good Combustion and Best
Management Practices 5,384 tpy

Ash Grove Leamington Plant | PSD Application | Plant Upgrade Project
Trinity Consultants A-1
APPENDIX A. UDAQ FORMS

Form 1 Date __________________
Notice of Intent (NOI) Application Checklist
Company __________________
Utah Division of Air Quality
New Source Review Section
Source Identification Information [R307-401-5]
1. Company name, mailing address, physical address and telephone number 
2. Company contact (Name, mailing address, and telephone number)
3.Name and contact of person submitting NOI application (if different than 2) 4.Source Universal Transverse Mercator (UTM) coordinates 
5. Source Standard Industrial Classification (SIC) code 
6.Area designation (attainment, maintenance, or nonattainment)
7.Federal/State requirement applicability (NAAQS, NSPS, MACT, SIP, etc.)
8.Source size determination (Major, Minor, PSD) 9. Current Approval Order(s) and/or Title V Permit numbers 
NOI Application Information: [R307-401]










N/A 
N/A 
A.Air quality analysis (air model, met data, background data, source impact analysis) N/A 
1.Detailed description of the project and source process
2.Discussion of fuels, raw materials, and products consumed/produced3.Description of equipment used in the process and operating schedule
4.Description of changes to the process, production rates, etc.
5.Site plan of source with building dimensions, stack parameters, etc.
6.Best Available Control Technology (BACT) Analysis [R307-401-8]A.BACT analysis for all new and modified equipment
7.Emissions Related Information: [R307-401-2(b)]
A.Emission calculations for each new/modified unit and site-wide
(Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs)B.References/assumptions, SDS, for each calculation and pollutant
C.All speciated HAP emissions (list in lbs/hr)
8.Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
A.Composition and physical characteristics of effluent(emission rates, temperature, volume, pollutant types and concentrations)
9.Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403]
A.NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements
B.Alternative site analysis, Major source ownership compliance certification
10.Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406]
B.Visibility impact analysis, Class I area impact
11.Signature on Application
N/A 
Note: The Division of Air Quality will not accept documents containing confidential information or data.
Documents containing confidential information will be returned to the Source submitting the application.
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Page 1 of 1
Form 4 Company____________________________
Project Information Site ______________________________
Utah Division of Air Quality
New Source Review Section
Process Data - For Modification/Amendment ONLY
1.Permit Number_______________________________
If submitting a new permit, then use Form 3
Requested Changes
2.Name of process to be modified/added:
_______________________________
End product of this process:
_______________________________
3.Permit Change Type: New Increase*
Equipment
Process
Condition Change ____________________
Other ______________________________
Other ______________________________
Other ______________________________
4.Does new emission unit affect existingpermitted process limits?
Yes No
5.Condition(s) Changing:
6.Description of Permit/Process Change**
7.New or modified materials and quantities used in process. **
Material Quantity Annually
8.New or modified process emitting units **
Emitting Unit(s) Capacity(s) Manufacture Date(s)
*If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an
emissions increase and a public comment period.
**If additional space is required, please generate a document to accommodate and attach to form.
Page 1 of 1
Company___________________________
Site _____________________________
Form 5
Emissions Information
Criteria/GHGs/ HAP’s
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr) PM10 Total
PM10 Fugitive
PM2.5
NOxSO2CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed
See Appendix B for
Emission Information
See Appendix B for
Emission Information
See Appendix B for
Emission Information
Utah Division of Air Quality
New Source Review Section
Form 10
Fabric Filters (Baghouses)
Baghouse Description
1. Briefly describe the process controlled by this baghouse:
Gas Stream Characteristics
2. Flow Rate (acfm):4. Particulate Loading (grain/scf)
Design Max Average
Expected
3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __________ Low _________
6. Gas Stream Temperature (°F):7. Fan Requirements (hp) (ft
3/min)
Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.)12. Number of Bags:13. Stack Height
___________ feet
Stack Inside Diameter
___________ inches
9. Bag Material:
□Nomex nylon
□Polyester
□Acrylics
□Fiber glass
□Cotton
□Teflon
□___________
14. Filtering
Efficiency
Rating:
_________%
15. Air to Cloth
Ratio:
______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□Reverse Air □ Shaker
□Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18.Calculated emissions for this device - See Appendix B of NOI
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
Kiln baghouse - this is an existing baghouse fitted with a new induced draft fan.
236,226 dscfm
0.007
419
295
29.6 feet zero
Compan y__ _____
Site/Source _____________________Leamington, UT Plant
Ash_______________ Grove Cement
Date Nov_______________________ember 2022
Page 2 of 2
Instructions - Form 10 Fabric Filters (Baghouses)
NOTE: 1. Submit this form in conjunction with Form 1 and Form 2.
2. Call the Division of Air Quality (DAQ) at [phone] if you have problems or questions in
filling out this form. Ask to speak with a New Source Review engineer. We will be glad to
help!
1. Describe the process equipment that the filter controls, what product is being controlled, particle size
data (if available), i.e., cement silo, grain silo, nuisance dust in work place, process control with high
dust potential, etc.
2.The maximum and design exhaust gas flow rates through the filter control device in actual cubic feet
per minute (ACFM). Check literature or call the sales agent.
3.The water/moisture content of the gas stream going through the filter.
4.The amount of particulate in the gas stream going into the filter and the amount coming out if available.
Outlet default value = 0.016 grains PM10/dscf.
5.The pressure drop range across the system. Usually given in the literature in inches of water.
6.The temperature of the gas stream entering the filter system in degrees Fahrenheit.
7.The horse power of the fan used to move the gas stream and/or the flow rate of the fan in ft3/min.
8. Name of the manufacturer of the filter equipment and the model number if available.
9.Check the type of filter bag material or fill in the blank. Check literature or call the sales agent.
10.The diameter of the bags in the system. Check literature or call the sales agent.
11. The length of the bags in the system. Check literature or call the sales agent.
12. The number of bags. Check literature or call the sales agent.
13. The height to the top of the stack from ground level and the stack inside diameter.
14. The filtering efficiency rating that the manufacturer quotes. Check literature or call the sales agent.
15. The ratio of the flow rate of air to the cloth area (A/C).
16. The number of hours that the process equipment is in operation, maximum per day and per year.
17. The way in which the filters bags are cleaned. Check the appropriate box.
18.Supply calculations for all criteria pollutants and HAPs. Use AP42 or Manufacturers data to complete
your calculations.
U:\aq\ENGINEER\GENERIC\Forms 2010\Form10 Baghouses.doc
Revised 12/20/10
Utah Division of Air Quality
New Source Review Section
Form 10
Fabric Filters (Baghouses)
Baghouse Description
1. Briefly describe the process controlled by this baghouse:
Gas Stream Characteristics
2. Flow Rate (acfm):4. Particulate Loading (grain/scf)
Design Max Average
Expected
3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __TBD____ Low __TBD____
6. Gas Stream Temperature (°F):7. Fan Requirements (hp) (ft
3/min)
Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter
(in.)
11. Bag Length (ft.)12. Number of Bags:13. Stack Height9. Bag Material:
□Nomex nylon
□Polyester
□Acrylics
□Fiber glass
□Cotton
□Teflon
□___________
14. Filtering
Efficiency
Rating:
_________%
15. Air to Cloth
Ratio:
______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□Reverse Air □ Shaker
□Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18.Calculated emissions for this device - See Appendix B of NOI
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
Clinker Cooler baghouse - this is an existing baghouse retrofitted from plenum pulse to pulse jet cleaning.
48,309 dscfm
0.005
248.1
92______ feet
Stack Inside Diameter20.9 feet zero___________ inches
Compan y__ _____
Site/Source _____________________Leamington, UT Plant
Ash_______________ Grove Cement
Date Nov_______________________ember 2022
Page 2 of 2
Instructions - Form 10 Fabric Filters (Baghouses)
NOTE: 1. Submit this form in conjunction with Form 1 and Form 2.
2.Call the Division of Air Quality (DAQ) at [phone] if you have problems or questions in
filling out this form. Ask to speak with a New Source Review engineer. We will be glad to
help!
1.Describe the process equipment that the filter controls, what product is being controlled, particle size
data (if available), i.e., cement silo, grain silo, nuisance dust in work place, process control with high
dust potential, etc.
2.The maximum and design exhaust gas flow rates through the filter control device in actual cubic feet
per minute (ACFM). Check literature or call the sales agent.
3. The water/moisture content of the gas stream going through the filter.
4.The amount of particulate in the gas stream going into the filter and the amount coming out if available.
Outlet default value = 0.016 grains PM10/dscf.
5.The pressure drop range across the system. Usually given in the literature in inches of water.
6. The temperature of the gas stream entering the filter system in degrees Fahrenheit.
7.The horse power of the fan used to move the gas stream and/or the flow rate of the fan in ft3/min.
8. Name of the manufacturer of the filter equipment and the model number if available.
9.Check the type of filter bag material or fill in the blank. Check literature or call the sales agent.
10. The diameter of the bags in the system. Check literature or call the sales agent.
11. The length of the bags in the system. Check literature or call the sales agent.
12. The number of bags. Check literature or call the sales agent.
13. The height to the top of the stack from ground level and the stack inside diameter.
14. The filtering efficiency rating that the manufacturer quotes. Check literature or call the sales agent.
15. The ratio of the flow rate of air to the cloth area (A/C).
16. The number of hours that the process equipment is in operation, maximum per day and per year.
17. The way in which the filters bags are cleaned. Check the appropriate box.
18.Supply calculations for all criteria pollutants and HAPs. Use AP42 or Manufacturers data to complete
your calculations.
U:\aq\ENGINEER\GENERIC\Forms 2010\Form10 Baghouses.doc
Revised 12/20/10
Utah Division of Air Quality
New Source Review Section
Form 10
Fabric Filters (Baghouses)
Baghouse Description
Gas Stream Characteristics - See Attached Table for Details
2. Flow Rate (acfm):4. Particulate Loading (grain/scf)
Design Max Average
Expected
3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)6. Gas Stream Temperature (°F):7. Fan Requirements (hp) (ft
3/min)
Equipment Information and Filter Characteristics - See Attached Table for Details
8. Manufacturer and Model Number:
10. Bag Diameter 11. Bag Length (ft.)12. Number of Bags:13. Stack Height9. Bag Material:
□Nomex nylon
□Polyester
□Acrylics
□Fiber glass
□Cotton
□Teflon
□___________
14. Filtering
Efficiency
Rating:
_________%
15. Air to Cloth
Ratio:
______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□Reverse Air □ Shaker
□Pulse Jet □ Other:
______________________
Emissions Calculations (PTE) - See Appendix B of NOI
18.Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
1.Briefly describe the process controlled by this baghouse:
Modified existing baghouses - 32 existing baghouses have been updated achieve 0.007 grain/dscf PM10 particulate
load rating. See attachment table for details.
Stack Inside Diameter
(in.)
0.007
Compan y__ _____
Site/Source _____________________Leamington, UT Plant
Ash_______________ Grove Cement
Date Nov_______________________ember 2022
Ash Grove Cement - Leamington Plant
Existing Modified Baghouses
Hours of
Operation Stack
Height
Stack
Diameter
Stack
Area
Stack
Diameter
Stack
Orienta
tion
(hrs/yr)(ft)(sq.ft.)(ft)
Stationary Crusher 8,760 14,762 (dscfm)17.5 32"x32"7.11 3.01 Vert.0.007 (grain/dscf)
Raw Material Transfer
Points 8,760 1,671 (dscfm)30 10"x12"0.83 1.02 Vert.0.007 (grain/dscf)
Belt Conveyor Transfer
Baghouse 8,760 1,486 (dscfm)30 11"x11"0.84 1.05 Vert.0.007 (grain/dscf)
Raw Material Silos 8,760 8,142 (dscfm)80 20"x20"2.78 1.88 Vert.0.007 (grain/dscf)
Fifth Component Silo 8,760 2,889 (dscfm)30 11"x11"0.84 1.05 Vert.0.007 (grain/dscf)
Raw Mill Recirculation 8,760 825 (dscfm)30 10"x6"0.42 0.72 Vert.0.007 (grain/dscf)
Raw Mill Recirculation 8,760 825 (dscfm)30 10"x6"0.42 0.72 Vert.0.007 (grain/dscf)
Raw Mill Recirculation 8,760 825 (dscfm)30 10"x6"0.42 0.72 Vert.0.007 (grain/dscf)
Raw Mill Recirculation 8,760 825 (dscfm)45 10"x6"0.42 0.72 Vert.0.007 (grain/dscf)
Raw Mill Recirculation 8,760 825 (dscfm)30 8"0.35 0.66 Vert.0.007 (grain/dscf)
Cross Belt Analyzer 8,760 1,156 (dscfm)30 10"x6"0.42 0.72 Vert.0.007 (grain/dscf)
Kiln, Pre-Calciner, & Raw
Mill 8,760 233,226 (dscfm)295 29.6'688.13 29.60 Vert.0.007 (grain/dscf)
Blending Silo Elevators
(2)8,760 1,203 (dscfm)30 11"x13"0.99 1.12 Vert.0.007 (grain/dscf)
Kiln Feed Blending Silos
(2)8,760 3,983 (dscfm)81 19"x19"2.51 1.77 Vert.0.007 (grain/dscf)
Clinker Belt Transfer 8,760 3,264 (dscfm)40 15"x16"1.67 1.44 Vert.0.007 (grain/dscf)
East and West Clinker
Storage Silos, East
Clinker Belt, West Clinker
Belts
8,760 5,797 (dscfm)
30 16"x40"4.44 2.39 Vert.0.007
(grain/dscf)
Clinker Tunnel 8,760 1,486 (dscfm)30 32"5.59 2.66 Vert.0.007 (grain/dscf)
East Clinker Silo
Discharge 8,760 1,486 (dscfm)30 40"x19"5.28 2.59 Vert.0.007 (grain/dscf)
West Clinker Silo
Discharge 8,760 1,486 (dscfm)30 15"x15"1.56 1.41 Vert.0.007 (grain/dscf)
Gypsum Silo Discharge 8,760 1,486 (dscfm)30 8"0.35 0.66 Vert.0.007 (grain/dscf)
Gypsum Silo 8,760 1,238 (dscfm)68.5 9"0.44 0.75 Vert.0.007 (grain/dscf)
Finish Mill 8,760 11,574 (dscfm)120 36"7.07 3.00 Vert.0.007 (grain/dscf)
Finish Mill Separator 8,760 10,346 (dscfm)120 36"7.07 3.00 Vert.0.007 (grain/dscf)
Finish Cement Storage
Silos 8,760 5,288 (dscfm)161 18"1.77 1.51 Vert.0.007 (grain/dscf)
North Cement Loadout 8,760 1,043 (dscfm)161 12"x12"1.00 1.12 Vert.0.007 (grain/dscf)
South Cement Loadout
(truck load outside)8,760 1,017 (dscfm)161 12"x12"1.00 1.12 Vert.0.007 (grain/dscf)
Coal Silo 8,760 1,403 (dscfm)81 15"x15"1.56 1.41 Vert.0.007 (grain/dscf)
Coal Grinding System
(Coal Mill)8,760 16,095 (dscfm)81 29"4.59 2.42 Vert.0.007 (grain/dscf)
Limestone Silo Discharge 8,760 1,486 (dscfm)30 10"x12"0.83 1.02 Vert.0.007 (grain/dscf)
Limestone Silo 8,760 825 (dscfm)66.25 8"0.35 0.66 Vert.0.007 (grain/dscf)
Dust Shuttle System
(alkali silo)8,760 3,714 (dscfm)65 8"x8"0.44 0.75 Vert.0.007 (grain/dscf)
Dust Shuttle System
(fringe bin)8,760 3,714 (dscfm)20 8"x8"0.44 0.75 Vert.0.007 (grain/dscf)
EF UnitUnitStack
Flow Unit PM10 EF
Utah Division of Air Quality
New Source Review Section
Form 10
Company______________________
Site/Source _____________________
Date _______________________
Fabric Filters (Baghouses)
Baghouse Description
Gas Stream Characteristics - See Attached Table for Details
2. Flow Rate (acfm):4. Particulate Loading (grain/scf)
Design Max Average
Expected
3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)6. Gas Stream Temperature (°F):7. Fan Requirements (hp) (ft
3/min)
Equipment Information and Filter Characteristics - See Attached Table for Details
8. Manufacturer and Model Number:
10. Bag Diameter 11. Bag Length (ft.)12. Number of Bags:13. Stack Height9. Bag Material:
□Nomex nylon
□Polyester
□Acrylics
□Fiber glass
□Cotton
□Teflon
□___________
14. Filtering
Efficiency
Rating:
_________%
15. Air to Cloth
Ratio:
______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□Reverse Air □ Shaker
□Pulse Jet □ Other:
______________________
Emissions Calculations (PTE) - See Appendix B of NOI
18.Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
Leamington, UT Plant Ash Grove Cement
November 2022
1.Briefly describe the process controlled by this baghouse:
New Finish Mill - six new baghouses or fabric filters. See attachment table for details.
Stack Inside Diameter
(in.)
0.005
Ash Grove Cement - Leamington Plant
New Finish Mill Baghouses
Hours of
Operation
Stack
Height
Stack
Area
Stack
Diameter
(hrs/yr)(ft)(sq.ft.)(ft)Additive Hopper Loading
Pozzolan and Gypsum
Hoppers 8,760 2,063 (dscfm)70.00 2.66 5.59 2.66 Vert.0.005 (grain/dscf)
Limestone Bypass Hopper 8,760 2,063 (dscfm)40.00 2.66 4.19 2.66 Vert.0.005 (grain/dscf)
Transfer Point 1 8,760 2,063 (dscfm)50.00 12"x12"1.00 1.15 Vert.0.005 (grain/dscf)
Transfer Point 2 8,760 2,063 (dscfm)50.00 1.25'x1.25'1.56 1.41 Vert.0.005 (grain/dscf)
Finish Mill and Separator 8,760 38,574 (dscfm)163.00 39"8.45 3.28 Vert.0.005 (grain/dscf)
Raw Material Silos 8,760 8,142 (dscfm)70.00 2.75'x2.75' 7.56 3.10 Vert.0.005 (grain/dscf)
PM10 EF EF UnitBaghouse Unit Stack Flow Unit Stack
Diameter
Stack
Orientation
Utah Division of Air Quality
New Source Review Section
Form 10
Fabric Filters (Baghouses)
Baghouse Description
Gas Stream Characteristics
2. Flow Rate (acfm):4. Particulate Loading (grain/scf)
Design Max Average
Expected
3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __TBD____ Low __TBD____
6. Gas Stream Temperature (°F):7. Fan Requirements (hp) (ft
3/min)
Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter 11. Bag Length (ft.)12. Number of Bags:13. Stack Height9. Bag Material:
□Nomex nylon
□Polyester
□Acrylics
□Fiber glass
□Cotton
□Teflon
□___________
14. Filtering
Efficiency
Rating:
_________%
15. Air to Cloth
Ratio:
______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□Reverse Air □ Shaker
□Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18.Calculated emissions for this device - See Appendix B of NOI
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
1.Briefly describe the process controlled by this baghouse:
New Rail Unloading and Truck Loadout - two new baghouses.
2,063 dscfm
0.005
ambient
40 ft
Stack Inside Diameter 2.66 ft
(in.)
Compan y__ _____
Site/Source _____________________Leamington, UT Plant
Ash_______________ Grove Cement
Date Nov_______________________ember 2022
Page 2 of 2
Instructions - Form 10 Fabric Filters (Baghouses)
NOTE: 1. Submit this form in conjunction with Form 1 and Form 2.
2. Call the Division of Air Quality (DAQ) at [phone] if you have problems or questions in
filling out this form. Ask to speak with a New Source Review engineer. We will be glad to
help!
1. Describe the process equipment that the filter controls, what product is being controlled, particle size
data (if available), i.e., cement silo, grain silo, nuisance dust in work place, process control with high
dust potential, etc.
2. The maximum and design exhaust gas flow rates through the filter control device in actual cubic feet
per minute (ACFM). Check literature or call the sales agent.
3. The water/moisture content of the gas stream going through the filter.
4. The amount of particulate in the gas stream going into the filter and the amount coming out if available.
Outlet default value = 0.016 grains PM10/dscf.
5. The pressure drop range across the system. Usually given in the literature in inches of water.
6.The temperature of the gas stream entering the filter system in degrees Fahrenheit.
7. The horse power of the fan used to move the gas stream and/or the flow rate of the fan in ft
3/min.
8. Name of the manufacturer of the filter equipment and the model number if available.
9. Check the type of filter bag material or fill in the blank. Check literature or call the sales agent.
10.The diameter of the bags in the system. Check literature or call the sales agent.
11.The length of the bags in the system. Check literature or call the sales agent.
12. The number of bags. Check literature or call the sales agent.
13. The height to the top of the stack from ground level and the stack inside diameter.
14. The filtering efficiency rating that the manufacturer quotes. Check literature or call the sales agent.
15. The ratio of the flow rate of air to the cloth area (A/C).
16. The number of hours that the process equipment is in operation, maximum per day and per year.
17. The way in which the filters bags are cleaned. Check the appropriate box.
18.Supply calculations for all criteria pollutants and HAPs. Use AP42 or Manufacturers data to complete
your calculations.
U:\aq\ENGINEER\GENERIC\Forms 2010\Form10 Baghouses.doc
Revised 12/20/10
Utah Division of Air Quality
New Source Review Section
Form 10
Fabric Filters (Baghouses)
Baghouse Description
1. Briefly describe the process controlled by this baghouse:
Gas Stream Characteristics
2. Flow Rate (acfm):4. Particulate Loading (grain/scf)
Design Max Average
Expected
3. Water Vapor Content of Effluent
Stream (lb. water/lb. dry air)
Inlet Outlet
5. Pressure Drop (inches H2O)
High __TBD____ Low __TBD____
6. Gas Stream Temperature (°F):7. Fan Requirements (hp) (ft
3/min)
Equipment Information and Filter Characteristics
8. Manufacturer and Model Number:
10. Bag Diameter 11. Bag Length (ft.)12. Number of Bags:13. Stack Height9. Bag Material:
□Nomex nylon
□Polyester
□Acrylics
□Fiber glass
□Cotton
□Teflon
□___________
14. Filtering
Efficiency
Rating:
_________%
15. Air to Cloth
Ratio:
______: 1
16. Hours of Operation:
Max Per day ________
Max Per year _______
17. Cleaning Mechanism:
□Reverse Air □ Shaker
□Pulse Jet □ Other:
______________________
Emissions Calculations (PTE)
18.Calculated emissions for this device - See Appendix B of NOI
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ____________Lbs/hr___________ Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr___________ Tons/yr VOC ___________Lbs/hr___________ Tons/yr
HAPs___________Lbs/hr (speciate)____________Tons/yr (speciate)
Submit calculations as an appendix.
Page 1 of 2
Kiln Feed Alleviator baghouse - this is a new baghouse.
9,900 dscfm
0.005
176.0
246 ft.
Stack Inside
Diameter 2.3 ft.
Compan y__ _____
Site/Source _____________________Leamington, UT Plant
Ash_______________ Grove Cement
Date Nov_______________________ember 2022
Page 2 of 2
Instructions - Form 10 Fabric Filters (Baghouses)
NOTE: 1. Submit this form in conjunction with Form 1 and Form 2.
2.Call the Division of Air Quality (DAQ) at [phone] if you have problems or questions in
filling out this form. Ask to speak with a New Source Review engineer. We will be glad to
help!
1.Describe the process equipment that the filter controls, what product is being controlled, particle size
data (if available), i.e., cement silo, grain silo, nuisance dust in work place, process control with high
dust potential, etc.
2.The maximum and design exhaust gas flow rates through the filter control device in actual cubic feet
per minute (ACFM). Check literature or call the sales agent.
3. The water/moisture content of the gas stream going through the filter.
4.The amount of particulate in the gas stream going into the filter and the amount coming out if available.
Outlet default value = 0.016 grains PM10/dscf.
5.The pressure drop range across the system. Usually given in the literature in inches of water.
6. The temperature of the gas stream entering the filter system in degrees Fahrenheit.
7.The horse power of the fan used to move the gas stream and/or the flow rate of the fan in ft3/min.
8. Name of the manufacturer of the filter equipment and the model number if available.
9.Check the type of filter bag material or fill in the blank. Check literature or call the sales agent.
10. The diameter of the bags in the system. Check literature or call the sales agent.
11. The length of the bags in the system. Check literature or call the sales agent.
12. The number of bags. Check literature or call the sales agent.
13. The height to the top of the stack from ground level and the stack inside diameter.
14. The filtering efficiency rating that the manufacturer quotes. Check literature or call the sales agent.
15. The ratio of the flow rate of air to the cloth area (A/C).
16. The number of hours that the process equipment is in operation, maximum per day and per year.
17. The way in which the filters bags are cleaned. Check the appropriate box.
18.Supply calculations for all criteria pollutants and HAPs. Use AP42 or Manufacturers data to complete
your calculations.
U:\aq\ENGINEER\GENERIC\Forms 2010\Form10 Baghouses.doc
Revised 12/20/10
Utah Division of Air Quality
New Source Review Section
Form 19
Natural Gas Boilers and Liquid Heaters
Boiler Information
1. Boiler Manufacturer: ___________________________________________________________________________
2. Model Number: ______________________________3. Serial Number: _______________________________
4. Boiler Rating: _________________(10
6 Btu per Hour)
5. Operating Schedule: __________ hours per day __________ days per week ___________ weeks per year
6. Use: □ steam: psig □hot water □other hot liquid: ________________________________
□Natural Gas □ LPG □ Butane □ Methanol
□Process Gas - H2S content in process gas __________ grain/100cu.ft.
7. Fuels:
□Fuel Oil - specify grade:□Other, specify: ______________________________________
Sulfur content % by weight Days per year during which unit is oil fired: ________________
Backup
Fuel □Diesel □ Natural Gas □ LPG □ Butane □ Methanol □ Other _________________
8. Is unit used to incinerate waste gas liquid stream? □ yes □ no
(Submit drawing of method of waste stream introduction to burners)
Gas Burner Information
9. Gas Burner Manufacturer: _____________________________________________________________________
10. No. of Burners: ______________________________11. Minimum rating per burner: _____________ cu. ft/hr
12. Average Load: _______%13. Maximum rating per burner: ____________ cu. ft/hr
14. Performance Guarantee (ppm dry corrected to 3% Oxygen):
NOx: ______________ CO: ______________ Hydrocarbons: ______________
□Manual □Automatic on-off15. Gas burner mode of control:
□Automatic hi-low □Automatic full modulation
Oil Burner Information
16. Oil burner manufacturer:
17. Model: _______________ number of burners: _________________ Size number: _______________
18. Minimum rating per burner: _____________ gal/hr 19. Maximum rating per burner: ___________ gal/hr
Page 1 of 3
TBD
X
TBD
One (1)
30 ppm
Compan y__ _____
Site/Source _____________________Leamington, UT Plant
Ash_______________ Grove Cement
Date Nov_______________________ember 2022
Page 2 of 3
Form 11 - Natural Gas Boiler and Liquid Heater
(Continued)
Modifications for Emissions Reduction
20. Type of modification: □ Low NOX Burner □ Flue Gas Recirculation (FGR)
□Oxygen Trim □Other (specify) ______________________________________
For Low-NOX Burners
21. Burner Type: □ Staged air □ Staged fuel □ Internal flue gas recirculation
□Ceramic □Other (specify): ___________________________________________________
22. Manufacturer and Model Number: _______________________________________________________________
23. Rating: ______________________ 10
6 BTU/HR 24. Combustion air blower horsepower: ____________
For Flue Gas Recirculation (FGR)
25. Type: □ Induced □ Forced Recirculation fan horsepower: ______________________________________
26. FGR capacity at full load: scfm %FGR
27. FGR gas temperature or load at which FGR commences: OF % load
28. Where is recirculation flue gas reintroduced? _______________________________________________________
For Oxygen Trim Systems
29. Manufacturer and Model Number: ________________________________________________________________
30. Recorder: □ yes □ no Describe: ____________________________________________________________
Stack or Vent Data - Same as 2nd Finish Mill Main Baghouse
31.Inside stack diameter or dimensions ____3.28 ft._
Stack height above the ground __163 ft.________
Stack height above the building ___30 ft.________
32.Gas exit temperature: ___194.5______ OF
33. Stack serves: □ this equipment only, □ other equipment (submit type and rating of all other equipment
exhausted through this stack or vent)
34.Stack flow rate: _____46,734__________ acfm Vertically restricted? □ Yes □No
Emissions Calculations (PTE) - See Appendix B of NOI
35. Calculated emissions for this device
PM10 ___________Lbs/hr___________ Tons/yr PM2.5 ___________Lbs/hr___________ Tons/yr
NOx ___________Lbs/hr ___________Tons/yr SOx ____________Lbs/hr___________ Tons/yr
CO ____________Lbs/hr ___________Tons/yr VOC ___________Lbs/hr ___________Tons/yr
CO2 ___________ Tons/yr CH4 ___________Tons/yr
N2O ___________Tons/yr
HAPs_________ Lbs/hr (speciate)__________Tons/yr (speciate)
Submit calculations as an appendix. If other pollutants are emitted, include the emissions in the appendix.
TBD

Ash Grove Leamington Plant | PSD Application | Plant Upgrade Project
Trinity Consultants B-1
APPENDIX B. BASELINE ACTUAL EMISSIONS AND PROJECTED ACTUAL
EMISSIONS
Baseline Actual Emissions
Appendix Table B-1. Operating Parameters
Description Value Unit
Daily Operating Hours 24 (hr/day)
Annual Days of Operation - PTE 365 (day/yr)
Annual Days of Operation - Baseline and PAE 330 (day/yr)
Quarry Road Loader - Average Weight 60.00 (tons)
Quarry Road Loader - Payload 24.00 (tons)
Quarry Loader - Round-Trip Distance 0.04 (miles)
Plant Loader - Average Weight 38.50 (tons)
Plant Loader - Payload 10.00 (tons)
Plant Loader - Round-Trip Distance 0.02 (miles)
Quarry Road Haul Truck - Average Weight 80.00 (tons)
Quarry Road Haul Truck - Payload 98.40 (tons)
Quarry Haul Truck - Round-Trip Distance 3.14 (miles)
Lime LBS Haul Truck - Average Weight 80.00 (tons)
Lime LBS Haul Truck - Payload 98.40 (tons)
Lime LBS Haul Truck - Round-Trip Distance (Paved)1.89 (miles)
Lime LBS Haul Truck - Round-Trip Distance (Unpaved)0.95 (miles)
CC Shale Haul Truck - Average Weight 43.25 (tons)
CC Shale Haul Truck - Payload 41.50 (tons)
CC Shale Haul Truck - Round-Trip Distance 0.49 (miles)
Gypsum Haul Truck - Average Weight 43.25 (tons)
Gypsum Haul Truck - Payload 41.50 (tons)
Gypsum Haul Truck - Round-Trip Distance 0.24 (miles)
Coal Haul Truck - Average Weight 43.25 (tons)
Coal Haul Truck - Payload 41.50 (tons)
Coal Haul Truck - Round-Trip Distance 0.15 (miles)
Geneva Slag Haul Truck - Average Weight 43.25 (tons)
Geneva Slag Haul Truck - Payload 41.50 (tons)
Geneva Slag Haul Truck - Round-Trip Distance 1.42 (miles)
Sandstone Haul Truck - Average Weight 43.25 (tons)
Sandstone Haul Truck - Payload 41.50 (tons)
Sandstone Haul Tuck - Round-Trip Distance to Raw
Material Silos 0.49 (miles)
Sandstone Haul Truck - Round-Trip Distance to
Stockpile 1.84 (miles)
Ammonia Haul Truck - Average Weight 43.25 (tons)
Ammonia Haul Truck - Payload 41.50 (tons)
Ammonia Haul Truck - Round-Trip Distance 0.89 (miles)
Product Export - Tare 22.50 (tons)
Product Export - Payload 41.50 (tons)
Product Export - Round-Trip Distance 0.43 (miles)
New Rail Line - Average Weight 43.25 (tons)
New Rail Line - Payload 41.50 (tons)
New Rail Line - Round-Trip Distance 0.51 (miles)
2FM Silo Hopper Haul Truck - Average Weight 43.25 (tons)
2FM Silo Hopper Haul Truck - Payload 41.50 (tons)
2FM Silo Hopper Haul Truck - Round-Trip Distance 0.34 (miles)
Average Exhaust Temperature 68 (F)
Standard Pressure 12.3 (psi)
Volumetric Fraction of Water Vapor (Dust Collectors) 2% (%)
Volumetric Fraction of Water Vapor (Kiln) 14% (%)
Volumetric Fraction of Water Vapor (Clinker Cooler) 0.5% (%)
Elevation Above Sea Level 1,470 (m)
Ash Grove Leamington Plant Page 1 of 10 Trinity Consultants
Baseline Actual Emissions
211.BF1 Stationary Crusher 17,885 14,762
211.BF2 Raw Material Transfer Points 2,024 1,671
311.BF1 Belt Conveyor Transfer Baghouse 1,800 1,486
315.BF1 Raw Material Silos 9,865 8,142
315.BF2 Fifth Component Silo 3,500 2,889
316.BF1 Raw Mill Recirculation 1,000 825
316.BF2 Raw Mill Recirculation 1,000 825
316.BF3 Raw Mill Recirculation 1,000 825
316.BF4 Raw Mill Recirculation 1,000 825
316.BF5 Raw Mill Recirculation 1,000 825
316.BF6 Cross Belt Analyzer 1,400 1,156
317.BF3 Kiln, Pre-Calciner, & Raw Mill 165,935 136,961
317.BF3 Projected Kiln Flow Rate 537,136 233,226
317.BF3 Potential Kiln Flow Rate 646,258 280,607
412.BF1 Blending Silo Elevators (2) 1,458 1,203
411.BF1 Kiln Feed Blending Silos (2) 4,826 3,983
419.BF1 Clinker Cooler 134,273 110,828
419.BF1 Projected Clinker Cooler Flow Rate 80,094 48,309
419.BF1 Potential Clinker Cooler Flow Rate 102,766 61,984
419.BF8 Clinker Belt Transfer 3,955 3,264
419.BF9 East and West Clinker Storage Silos, East
Clinker Belt, West Clinker Belts 7,023 5,797
511.BF Clinker Tunnel 1,800 1,486
511.BF1 East Clinker Silo Discharge 1,800 1,486
511.BF2 West Clinker Silo Discharge 1,800 1,486
511.BF4 Gypsum Silo Discharge 1,800 1,486
512.BF1 Gypsum Silo 1,500 1,238
514.BF2 Finish Mill 14,023 11,574
514.BF1 Finish Mill Separator 12,535 10,346
611.BF1 Finish Cement Storage Silos 6,407 5,288
611.BF3 North Cement Loadout 1,264 1,043
611.BF2 South Cement Loadout (truck load outside) 1,232 1,017
41B.BF1 Coal Silo 1,700 1,403
41B.BF2 Coal Grinding System (Coal Mill) 19,500 16,095
512.BF2 Limestone Silo Discharge 1,800 1,486
512.BF3 Limestone Silo 1,000 825
413.BF1 Dust Shuttle System (alkali silo) 4,500 3,714
514.BF3 Dust Shuttle System (fringe bin) 4,500 3,714
NA Kiln Feed Alleviator (New) 9,900 8,171
NA 2FM Silo Hopper (New)2,500 2,063
N1HPRFM2 2FM Limestone Hopper 2,500 2,063
N1_C1 Transfer Point 1 2,500 2,063
N1_C2 Transfer Point 2 2,500 2,063
N1_FM2 Finish Mill and Separator 46,734 38,574
N1_FMS Raw Material Silos 9,865 8,142
1. See parameters for calculation in Appendix Table B-1. Operating Parameters.
Appendix Table B-2. Flow Rate Conversions
Current ID Unit (dscfm)(acfm)
Ash Grove Leamington Plant Page 2 of 10 Trinity Consultants
Baseline Actual Emissions
Appendix Table B-3. Drilling and Blasting Inputs
Parameter 2020 2021 Baseline
Max. Daily Drilled Holes (holes/day)4.88 5.89 5.38
Max. Annual ANFO Usage (tpy)404.00 488.00 446.00
Max. Annual Blasts (blast/yr)10.00 12.00 11.00
Max. Daily Blasts (blast/day)1.00 1.00 1.00
Max. Daily Blast Area (ft2/blast)33,871.00 27,712.00 30,791.50
Appendix Table B-4. Stockpiles and Disturbed Ground
2020 2021 Baseline
Dump Slope (Dist. Ground)16.00 21.80 18.90
Quarry Slope (Dist. Ground)0.90 0.60 0.75
Quarry (Dist. Ground)14.90 19.70 17.30
Reclaim Area Total (Dist. Ground)6.40 7.80 7.10
Reclaim Area 1 1.28 1.56 1.42
Reclaim Area 2 1.28 1.56 1.42
Reclaim Area 3 1.28 1.56 1.42
Reclaim Area 4 1.28 1.56 1.42
Reclaim Area 5 1.28 1.56 1.42
Crusher Area (Dist. Ground)2.20 2.20 2.20
Storage Pile Total (Tent Area)6.00 5.00 5.50
Tent Pile 1 1.00 0.83 0.92
Tent Pile 2 1.00 0.83 0.92
Tent Pile 3 1.00 0.83 0.92
Clinker Reclaim Pile 1.00 0.83 0.92
Reclaim Pile 1 1.00 0.83 0.92
Reclaim Pile 2 1.00 0.83 0.92
Storage Pile (Crusher Pad)2.70 2.70 2.70
Appendix Table B-5. Throughputs (tpy)
Description 2020 2021 Baseline
Clinker 803,402.00 809,972.00 806,687.00
Limestone (Raw Material)1,031,743.00 1,040,518.00 1,036,130.50
Limestone (LBS)60,000.00 60,000.00 60,000.00
Gypsum 51,319.00 50,106.00 50,712.50
CC Shale 85,345.00 90,866.00 88,105.50
Sandstone 81,415.00 89,952.00 85,683.50
Coal 101,352.00 103,781.00 102,566.50
Geneva Slag 62,923.00 60,749.00 61,836.00
Ammonia 2,340.54 2,304.65 2,322.59
Clinker Reclaim 106,683.00 90,283.70 98,483.35
New Rail Line --0.00
Area
(acres)Stockpile Description
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Baseline Actual Emissions
Appendix Table B-6. Source Operating Hours
Unit 2020 2021 Baseline
Additive Hopper Loading --0.00
Transfer Point 1 --0.00
Transfer Point 2 --0.00
Finish Mill and Separator --0.00
2FM Raw Material Silos --0.00
Stationary Crusher 1,300 1,182 1,241
Raw Material Transfer Points 1,300 1,182 1,241
Belt Conveyor Transfer Baghouse 6,849 7,213 7,031
Raw Material Silos 6,849 7,213 7,031
Fifth Component Silo 6,849 7,213 7,031
Raw Mill Recirculation 6,849 7,213 7,031
Raw Mill Recirculation 6,849 7,213 7,031
Raw Mill Recirculation 6,849 7,213 7,031
Raw Mill Recirculation 6,849 7,213 7,031
Raw Mill Recirculation 6,849 7,213 7,031
Cross Belt Analyzer 6,849 7,213 7,031
Kiln, Pre-Calciner, & Raw Mill 7,931 8,213 8,072
Blending Silo Elevators (2)5,552 5,749 5,651
Kiln Feed Blending Silos (2)5,552 5,749 5,651
Clinker Cooler 7,388 7,855 7,622
Clinker Belt Transfer 7,388 7,855 7,622
East and West Clinker Storage Silos, East Clinker
Belt, West Clinker Belts 3,694 3,927 3,811
Clinker Tunnel 7,931 8,213 8,072
East Clinker Silo Discharge 3,694 3,927 3,811
West Clinker Silo Discharge 3,694 3,927 3,811
Gypsum Silo Discharge 7,856 7,285 7,570
Gypsum Silo 7,856 7,285 7,570
Finish Mill 7,856 7,285 7,570
Finish Mill Separator 7,856 7,285 7,570
Finish Cement Storage Silos 7,856 7,285 7,570
North Cement Loadout 3,966 4,106 4,036
South Cement Loadout (truck load outside)3,966 4,106 4,036
Coal Silo 7,931 8,213 8,072
Coal Grinding System (Coal Mill)7,931 8,213 8,072
Limestone Silo Discharge 8,760 8,760 8,760
Limestone Silo 8,760 8,760 8,760
Dust Shuttle System (alkali silo)8,760 8,760 8,760
Dust Shuttle System (fringe bin)8,760 8,760 8,760
Shipping Generator 112 9 61
Kiln Generator 11 26 19
Kiln Feed Alleviator (New)--0.00
2FM Silo Hopper (New)--0.00
Bulldozer 1000 1090 1045
Grader 1005 796 900.5
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Baseline Actual Emissions
Appendix Table B-7. Vehicular Miles Traveled
Description 2020 2021 Baseline
Loader in Quarry 5.22 5.26 5.24
Loader at Primary Crusher 5.22 5.26 5.24
Loader - Sandstone to Reclaim Pile 0.78 0.86 0.82
Loader - 4" to Stockpile 0.29 0.29 0.29
Loader - 4" to Stockpile (South Test Location)1.41 1.41 1.41
Loader - 4" to Portable Crusher 0.29 0.29 0.29
Loader - 1" to Haul Truck 0.29 0.29 0.29
Loader - 1" to Haul Truck (South Test Location)0.94 0.94 0.94
Loader - Clinker Reclaim 0.61 0.52 0.57
Haul Truck - Quarry - Unpaved 105.52 106.37 105.95
Haul Truck - Lime Bypass System - Paved 8.30 8.30 8.30
Haul Truck - Lime Bypass System - Unpaved --0.00
Haul Truck - Gypsum - Paved 0.89 0.87 0.88
Haul Truck - Coal - Paved 1.12 1.15 1.13
Haul Truck - CC Shale - Paved 3.07 3.27 3.17
Haul Truck - Sandstone - Stockpile - Paved 5.46 6.03 5.75
Haul Truck - Sandstone - Silo - Paved 1.46 1.62 1.54
Haul Truck - Geneva Slag - Paved 6.53 6.30 6.41
Haul Truck - Ammonia - Paved 0.15 0.15 0.15
Haul Truck - Product Export - Paved 28.46 28.63 28.55
Haul Truck - New Rail Line - Paved --0.00
Haul Truck - 2FM Silos - Paved --0.00
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Baseline Actual Emissions
Appendix Table B-8. 2020 & 2021 Actual Emissions and Resulting Baseline
Clinker
Produced
(tons)
2020 120.23 108.32 68.17 56.26 11.91 1.53 1,160.38 60.02 4,006.90 0.030 638,834.25 803,402.00
2021 118.10 111.71 64.21 57.82 6.39 12.22 1,212.77 50.92 2,622.57 0.030 643,936.12 809,972.00
Baseline 119.16 110.02 66.19 57.04 9.15 6.87 1,186.58 55.47 3,314.73 0.03 641,385.19 806,687.00
1. PM emissions from Corrected Emission Inventories.
2. Gaseous pollutant emissions from Emission Inventories.
Appendix Table B-9. Existing Sources CO2e Emissoins
Pollutant 2020 Emissions (tpy) 2021 Emissions (tpy) GWP Baseline CO2e (tpy)
CO2 636,797.30 641,889.57 1.00 639,343.44
CH4 29.95 30.00 25.00 749.44
N2O 4.32 4.35 298.00 1,292.31
641,385.19
PM10 PM10
Filterable CO2e
Emissions (tpy)1,2
SUM
Year PM CON LeadCOPM2.5 PM2.5
Filterable SO2 NOx VOC
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Baseline Actual Emissions
Hours of
Operation PM10 Emission Rate PM2.5 Emission Rate PM10 Annual
Emissions
PM2.5 Annual
Emissions
(hrs/yr)(lb/hr)(lb/hr)(tpy)(tpy)
317.BF3 Kiln, Pre-Calciner, & Raw Mill - 136,961 (dscfm)0.007 0.0049 (grain/dscf) 8,072 8.22 5.80 33.17 23.41
419.BF1 Clinker Cooler - 110,828 (dscfm)0.005 0.0035 (grain/dscf) 7,622 4.75 3.35 18.10 12.78
414.BF1N Kiln Feed Alleviator (New) - 8,171 (dscfm)0.005 0.0035 (grain/dscf) 0.00 0.35 0.25 0.00 0.00
N1HPRFM2 Additive Hopper Loading - 2,063 (dscfm)0.005 0.0035 (grain/dscf) 0.00 0.09 0.06 0.00 0.00
N1_C1 Transfer Point 1 - 2,063 (dscfm)0.005 0.0035 (grain/dscf) 0.00 0.09 0.06 0.00 0.00
N1_C2 Transfer Point 2 - 2,063 (dscfm)0.005 0.0035 (grain/dscf) 0.00 0.09 0.06 0.00 0.00
N1_FM2 Finish Mill and Separator - 38,574 (dscfm)0.005 0.0035 (grain/dscf) 0.00 1.65 1.17 0.00 0.00
N1_FMS 2FM Raw Material Silos - 8,142 (dscfm)0.005 0.0035 (grain/dscf) 0.00 0.35 0.25 0.00 0.00
2FMSXHPR 2FM Silo Hopper (New) - 2,063 (dscfm)0.005 0.0035 (grain/dscf) 0.00 0.09 0.06 0.00 0.00NRL_UPR New Rail Loadout Upper Bin - 2,063 (dscfm)0.005 0.0035 (grain/dscf) 0.00 0.09 0.06 0.00 0.00
NRL_LWR New Rail Loadout Lower Bin - 2,063 (dscfm)0.005 0.0035 (grain/dscf) 0.00 0.09 0.06 0.00 0.00
2FM_HTR 2FM Heater ---7.60 7.60 (lb/MMscf) 0.00 0.08 0.08 0.00 0.00
211.BF1 Stationary Crusher - 14,762 (dscfm)0.007 0.0049 (grain/dscf) 1,241 0.89 0.63 0.55 0.39
211.BF2 Raw Material Transfer Points - 1,671 (dscfm)0.007 0.0049 (grain/dscf) 1,241 0.10 0.07 0.06 0.04
311.BF1 Belt Conveyor Transfer Baghouse - 1,486 (dscfm)0.007 0.0049 (grain/dscf) 7,031 0.09 0.06 0.31 0.22
315.BF1 Raw Material Silos - 8,142 (dscfm)0.007 0.0049 (grain/dscf) 7,031 0.49 0.34 1.72 1.21
315.BF2 Fifth Component Silo - 2,889 (dscfm)0.007 0.0049 (grain/dscf) 7,031 0.17 0.12 0.61 0.43
316.BF1 Raw Mill Recirculation - 825 (dscfm)0.007 0.0049 (grain/dscf) 7,031 0.05 0.03 0.17 0.12
316.BF2 Raw Mill Recirculation - 825 (dscfm)0.007 0.0049 (grain/dscf) 7,031 0.05 0.03 0.17 0.12
316.BF3 Raw Mill Recirculation - 825 (dscfm)0.007 0.0049 (grain/dscf) 7,031 0.05 0.03 0.17 0.12
316.BF4 Raw Mill Recirculation - 825 (dscfm)0.007 0.0049 (grain/dscf) 7,031 0.05 0.03 0.17 0.12
316.BF5 Raw Mill Recirculation - 825 (dscfm)0.007 0.0049 (grain/dscf) 7,031 0.05 0.03 0.17 0.12
316.BF6 Cross Belt Analyzer - 1,156 (dscfm)0.007 0.0049 (grain/dscf) 7,031 0.07 0.05 0.24 0.17
412.BF1 Blending Silo Elevators (2) - 1,203 (dscfm)0.007 0.0049 (grain/dscf) 5,651 0.07 0.05 0.20 0.14
411.BF1 Kiln Feed Blending Silos (2) - 3,983 (dscfm)0.007 0.0049 (grain/dscf) 5,651 0.24 0.17 0.68 0.48419.BF8 Clinker Belt Transfer - 3,264 (dscfm)0.007 0.0049 (grain/dscf) 7,622 0.20 0.14 0.75 0.53
419.BF9 East and West Clinker Storage Silos, East Clinker Belt, West
Clinker Belts -5,797 (dscfm) 0.007 0.0049 (grain/dscf) 3,811 0.35 0.25 0.66 0.47
511.BF Clinker Tunnel - 1,486 (dscfm)0.007 0.0049 (grain/dscf) 8,072 0.09 0.06 0.36 0.25
511.BF1 East Clinker Silo Discharge - 1,486 (dscfm)0.00 0.00 (grain/dscf) 3,811 0.00 0.00 0.00 0.00
511.BF2 West Clinker Silo Discharge - 1,486 (dscfm)0.00 0.00 (grain/dscf) 3,811 0.00 0.00 0.00 0.00
511.BF4 Gypsum Silo Discharge - 1,486 (dscfm)0.00 0.00 (grain/dscf) 7,570 0.00 0.00 0.00 0.00
512.BF1 Gypsum Silo - 1,238 (dscfm)0.007 0.0049 (grain/dscf) 7,570 0.07 0.05 0.28 0.20
514.BF2 Finish Mill - 11,574 (dscfm)0.007 0.0049 (grain/dscf) 7,570 0.69 0.49 2.63 1.86
514.BF1 Finish Mill Separator - 10,346 (dscfm)0.007 0.0049 (grain/dscf) 7,570 0.62 0.44 2.35 1.66
611.BF1 Finish Cement Storage Silos - 5,288 (dscfm)0.007 0.0049 (grain/dscf) 7,570 0.32 0.22 1.20 0.85
611.BF3 North Cement Loadout - 1,043 (dscfm)0.007 0.0049 (grain/dscf) 4,036 0.06 0.04 0.13 0.09
611.BF2 South Cement Loadout (truck load outside) - 1,017 (dscfm)0.007 0.0049 (grain/dscf) 4,036 0.06 0.04 0.12 0.09
41B.BF1 Coal Silo - 1,403 (dscfm)0.007 0.0049 (grain/dscf) 8,072 0.08 0.06 0.34 0.24
41B.BF2 Coal Grinding System (Coal Mill) - 16,095 (dscfm)0.007 0.0049 (grain/dscf) 8,072 0.97 0.68 3.90 2.75
512.BF2 Limestone Silo Discharge - 1,486 (dscfm)0.00 0.00 (grain/dscf) 8,760 0.00 0.00 0.00 0.00
512.BF3 Limestone Silo - 825.3910 (dscfm)0.007 0.0049 (grain/dscf) 8,760 0.05 0.03 0.22 0.15
413.BF1 Dust Shuttle System (alkali silo) - 3,714 (dscfm)0.007 0.0049 (grain/dscf) 8,760 0.22 0.16 0.98 0.69514.BF3 Dust Shuttle System (fringe bin) - 3,714 (dscfm)0.007 0.0049 (grain/dscf) 8,760 0.22 0.16 0.98 0.69
NA Shipping Generator - 560 (hp)5.95E-04 5.95E-04 (lbs/hp-hr) 61 0.33 0.33 0.01 0.01
NA Kiln Generator - 762 (hp)3.00E-02 3.00E-02 (g/hp-hr) 19 0.05 0.05 4.66E-04 4.66E-04
Appendix Table B-10. All PM Sources
PM10 EF PM2.5 EFModel ID EF UnitUnit
Emission
Input Parameter UnitReferences
Existing Sources
New & Modified Sources
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Baseline Actual Emissions
LDR1_E +
LD1_W Quarry Loader to Haul Truck --Drop 2.76E-03 4.18E-04 (lb/ton)---1.43 0.22
HT_DUMP Quarry Haul Truck to Dump Slope - - Drop 2.76E-03 4.18E-04 (lb/ton) - - -1.43 0.22
HT1 Quarry Haul Truck to Crusher Pad - - Drop 2.76E-03 4.18E-04 (lb/ton) - - -1.43 0.22
LDR2 Quarry Loader to Crusher - - Drop 2.76E-03 4.18E-04 (lb/ton) - - -1.43 0.22
STKR1 Stacker to Reclaim Pile - - Drop 2.76E-03 4.18E-04 (lb/ton) - - -1.43 0.22
RCLMFDR Reclaim Pile to Reclaim Feeder - - Drop 2.76E-03 4.18E-04 (lb/ton) - - -1.43 0.22
LDR_SS Reclaim Loader from Sandstone Stockpile to Reclaim Pad - - Drop 2.76E-03 4.18E-04 (lb/ton) - - -0.12 0.02
HT_SS_SP Sandstone Haul Truck to Sandstone Stockpile - - Drop 2.76E-03 4.18E-04 (lb/ton) - - -0.12 0.02
LDR_3 Reclaim Loader from Reclaim Pad to 4" Stockpile - - Drop 2.76E-03 4.18E-04 (lb/ton) - - -0.08 0.01
LDR4 Reclaim Loader to Portable Crusher - - Drop 2.76E-03 4.18E-04 (lb/ton) - - -0.08 0.01
SCR Portable Crusher - - Primary Crushing 6.00E-04 2.50E-05 (lb/ton) - - -0.02 7.50E-04
SCR_DRP Drop from Portable Crusher - - Drop 2.76E-03 4.18E-04 (lb/ton) - - -0.08 0.01
LDR5 Reclaim Loader to Feeder Haul Truck - - Drop 2.76E-03 4.18E-04 (lb/ton) - - -0.08 0.01
LDR6 Haul Truck Drop - 1" to Stockpile - Drop 2.76E-03 4.18E-04 (lb/ton)0.08 0.01
HT3 Feeder Haul Truck - Limestone and Gypsum to Silo Feeder - - Drop 2.76E-03 4.18E-04 (lb/ton) - - -0.15 0.02
CLNKRDRP Reclaim Clinker Drop to Reclaim Clinker Pad - - Drop 8.27E-04 1.25E-04 (lb/ton) - - -0.04 6.17E-03
CLNKRSP Reclaim Clinker Stockpiling - - Drop 8.27E-04 1.25E-04 (lb/ton) - - -0.04 6.17E-03
SLG_DRP Geneva Slag Haul Truck Drop to Reclaim Slag Pile - - Drop 2.76E-03 4.18E-04 (lb/ton) - - -0.09 0.01
COAL_HPR Coal Hopper (Grate) - - Drop 2.76E-03 4.18E-04 (lb/ton)0.14 0.02
RAW_HPR Raw Material Hopper (Grate) - - Drop 2.76E-03 4.18E-04 (lb/ton)0.32 0.05
NRL_SPT New Rail Line Spout - - Enclosed Drop 6.89E-04 1.04E-04 (lb/ton) - - -0.00 0.00
V611.BF4 Interior Baghouse Released at Silo Door - - Volume NA NA (lb/ton) - - -0.00 0.00
V611.BF5 Interior Baghouse Released at Silo Door - - Volume NA NA (lb/ton) - - -0.00 0.00
CNVRSCR1 To Crusher - - Conveyor Transfer (Controlled)4.60E-05 1.30E-05 (lb/ton) - - -1.38E-03 3.90E-04
CNVRSCR2 From Crusher - - Conveyor Transfer (Controlled)4.60E-05 1.30E-05 (lb/ton) - - -1.38E-03 3.90E-04
DMP_SLP Dump Slope 1, 2, 3 18.90 (acres)1.04 0.16 (lb/acre/day)---3.59 0.54
QRY_SLP Quarry Slope 1, 2, 3 0.75 (acres)1.04 0.16 (lb/acre/day)---0.14 0.02
QRY Quarry 1, 2, 3 17.30 (acres)1.04 0.16 (lb/acre/day)---3.29 0.49
DG_RCLM1 Reclaim Area 1 1, 2, 3 1.42 (acres)1.04 0.16 (lb/acre/day)---0.27 0.04
DG_RCLM2 Reclaim Area 2 1, 2, 3 1.42 (acres)1.04 0.16 (lb/acre/day)---0.27 0.04
DG_RCLM3 Reclaim Area 3 1, 2, 3 1.42 (acres)1.04 0.16 (lb/acre/day)---0.27 0.04
DG_RCLM4 Reclaim Area 4 1, 2, 3 1.42 (acres)1.04 0.16 (lb/acre/day)---0.27 0.04DG_RCLM5 Reclaim Area 5 1, 2, 3 1.42 (acres)1.04 0.16 (lb/acre/day)---0.27 0.04
CRSH_AR Crusher Area 1, 2, 3 2.20 (acres)1.04 0.16 (lb/acre/day)---0.42 0.06
SP_TNT1 Storage Pile - Tent 1 1, 2, 3 0.92 (acres)6.3 1.85 (lb/acre/day)---1.05 0.31
SP_TNT2 Storage Pile - Tent 2 1, 2, 3 0.92 (acres)6.3 1.85 (lb/acre/day)---1.05 0.31
SP_TNT3 Storage Pile - Tent 3 1, 2, 3 0.92 (acres)6.3 1.85 (lb/acre/day)---1.05 0.31
SP_CR Storage Pile - Clinker Reclaim 1, 2, 3 0.92 (acres)6.3 1.85 (lb/acre/day)---1.05 0.31SP_RCLM1 Storage Pile - Reclaim 1 1, 2, 3 0.92 (acres)6.3 1.85 (lb/acre/day)---1.05 0.31
SP_RCLM2 Storage Pile - Reclaim 2 1, 2, 3 0.92 (acres)6.3 1.85 (lb/acre/day)---1.05 0.31
SP2 Storage Pile 1, 2, 3 2.70 (acres)6.3 1.85 (lb/acre/day)---3.10 0.91
BLDZR Bulldozer 4 -----1,045 0.75 0.11 0.39 0.06
GRDR Grader 4 -----901 0.60 0.03 0.27 0.01
LD_QRY Loader in Quarry 5 5.24 (VMT/day)0.38 0.04 (lb/VMT) - - - 0.33 0.03
LD_PCR Loader at Primary Crusher 5 5.24 (VMT/day)0.38 0.04 (lb/VMT) - - - 0.33 0.03
LD_SS Loader - Sandstone to Reclaim Pile 5 0.82 (VMT/day)0.13 0.01 (lb/VMT) - - - 0.02 1.71E-03
LD_4SP Loader - 4" to Stockpile 5 0.29 (VMT/day)0.13 0.01 (lb/VMT) - - - 5.99E-03 5.99E-04
LD_4SPS Loader - 4" to Stockpile (South Test Location) 5 1.41 (VMT/day)0.38 0.04 (lb/VMT) - - - 0.09 8.85E-03
LD_4PC Loader - 4" to Portable Crusher 5 0.29 (VMT/day)0.13 0.01 (lb/VMT) - - - 5.99E-03 5.99E-04
LD_1HT Loader - 1" to Haul Truck 5 0.29 (VMT/day)0.13 0.01 (lb/VMT) - - - 5.99E-03 5.99E-04
LD_1HTS Loader - 1" to Haul Truck (South Test Location) 5 0.94 (VMT/day)0.38 0.04 (lb/VMT) - - - 0.06 5.90E-03
LD_CR Loader - Clinker Reclaim 5 0.57 (VMT/day)0.10 0.01 (lb/VMT) - - - 9.67E-03 9.67E-04
HT_Q_U Haul Truck - Quarry - Unpaved 5 105.95 (VMT/day)0.43 0.04 (lb/VMT) - - - 7.56 0.76
HT_LP Haul Truck - Lime Bypass System - Paved 5 8.30 (VMT/day)0.14 0.01 (lb/VMT) - - - 0.20 0.02
HT_LU Haul Truck - Lime Bypass System - Unpaved 5 0.00 (VMT/day)0.43 0.04 (lb/VMT) - - - 0.00 0.00HT_G_P Haul Truck - Gypsum - Paved 5 0.88 (VMT/day)0.11 0.01 (lb/VMT) - - - 0.02 1.58E-03
HT_C_P Haul Truck - Coal - Paved 5 1.13 (VMT/day)0.11 0.01 (lb/VMT) - - - 0.02 2.05E-03
HT_CSP Haul Truck - CC Shale - Paved 5 3.17 (VMT/day)0.11 0.01 (lb/VMT) - - - 0.06 5.71E-03
HTSPP Haul Truck - Sandstone - Stockpile - Paved 5 5.75 (VMT/day)0.11 0.01 (lb/VMT) - - - 0.10 0.01
HTSSXP Haul Truck - Sandstone - Silo - Paved 5 1.54 (VMT/day)0.11 0.01 (lb/VMT) - - - 0.03 2.78E-03
HTGSP Haul Truck - Geneva Slag - Paved 5 6.41 (VMT/day)0.11 0.01 (lb/VMT) - - - 0.12 0.01HT_AP Haul Truck - Ammonia - Paved 5 0.15 (VMT/day)0.11 0.01 (lb/VMT) - - - 2.72E-03 2.72E-04
HT_P_P Haul Truck - Product Export - Paved 5 28.55 (VMT/day)0.11 0.01 (lb/VMT) - - - 0.51 0.05
HT_NRL Haul Truck - New Rail Line - Paved 5 0.00 (VMT/day)0.11 0.01 (lb/VMT) - - - 0.00 0.00
HT2FMS Haul Truck - 2FM Silos - Paved 5 0.00 (VMT/day)0.11 0.01 (lb/VMT) - - - 0.00 0.00
PM10 EF PM2.5 EF EF Unit
BLST Blasting - - -39.33 2.27 (lb/blast) - - - 0.22 0.01
DRL Drilling - - -0.68 0.04 (lb/hole) - - - 0.03 1.53E-03
Baseline Factors
Ash Grove Leamington Plant Page 8 of 10 Trinity Consultants
Baseline Actual Emissions
TSP Emission Factor:0.38 (ton/acre-yr)
PM10 Content: 0.5
PM2.5 Content: 0.075
4. Bulldozer and Grader calculation factors and methodology.
Bulldozing PM10 Scaling Factor:
0.75
Bulldozing PM2.5 Scaling Factor:
0.105
Grader PM10 Scaling Factor:
0.60
Grader PM2.5 Scaling Factor:
0.031
Silt Content (s):
6.90%
Moisture Content (M):
7.90%
Control Efficiency: Watering:
70%
E =
k, a, b =
k =
a =
b =
s =
WHT =
WQL =
WAV =
WPL =
WPHT =
ηW =
ηCh =
ηP =
38.50
Mean Product Haul Truck Weight (tons)
43.25
Control efficiency of water application and road base, per Per UDAQ guidance - Emission Factors for Paved and Unpaved Haul Roads, January 2015
Mean Quarry Loader Weight (tons)
60.00
Mean Access Vehicle Weight (tons)
43.25
Mean Plant Loader Weight (tons)
surface material silt content (%)
1.5 (PM10), 0.15 (PM2.5)
0.9
0.45
constants for Equation 1a
Where:
Control efficiency of chemical application, per Per UDAQ guidance - Emission Factors for Paved and Unpaved Haul Roads, January 2016
85%
Control efficiency of paving, sweeping, and watering, per Per UDAQ guidance - Emission Factors for Paved and Unpaved Haul Roads, January 2017
95%
75%
2. Per U.S. EPA AP-42, Section 11.9 (Western Surface Coal Mining), Table 11.9-4; August 1998, for Disturbed Area.
4a. AP-42 Section 11.9 (October 1998), Tables 11.9-1 and 11.9-3.
4b. The Western Regional Air Partnership's (WRAP's) Fugitive Dust Handbook, 2006, gives a control
5. AP-42, Section 13.2.2. Also, UDAQ's guidance in Emission Factors for Paved and Unpaved Haul Roads, January 2015, in conjunction with U.S. EPA AP-42 Section 13.2.2, November 2006.
E = k(s/12)a(W/3)b (Equation 1a)where:
4.80
Per UDAQ guidance - Emission Factors for Paved and Unpaved Haul Roads, January 2015
Mean Quarry Haul Truck Weight (tons)
80.00
Size-specific emission factor (lb/VMT)
3. Where no PM10 or PM2.5 emission factor was given, the following values were used to solve for the emission factor, per U.S. EPA AP-42, Section 13.2.5, page 13.2.5-3 (Industrial Wind Erosion):
1. PM10 emission factors for stockpiles taken from AP-42, Fourth Edition Table 8.19.1-1, per UDAQ guidance.
Ash Grove Leamington Plant Page 9 of 10 Trinity Consultants
Baseline Actual Emissions
Appendix Table B-11. Blasting and Drilling Area
Maximum Annual Blast
Frequency
(blasts/yr)
Maximum Annual
Area Blasted
(ft2/yr)
Maximum Daily
Blast Area
(ft2/blast)
Minimum Daily
Blast Area
(ft2/blast)
11 338,707 30,792 15,396
Appendix Table B-12. Drilling and Blasting Emission Factors
Value Units Value Units Value Units Value Units Value Units Value Units
Blasting ANFO 446 (tpy)75.64 (lb/blast) 39.33 (lb/blast) 2.27 (lb/blast) 0.0036 (lb/ton) 1.80 (lb/ton) 40.64 (lb/ton)
Drilling Annual # of Drill
Holes 1,965 (holes/yr) 1.30 (lb/hole) 0.68 (lb/hole) 3.90E-02 (lb/hole) - (lb/ton) - (lb/ton) - (lb/ton)
PM10:0.52
PM2.5:0.03
PM10 = PM15 * 0.52
PM2.5 = TSP * 0.03
Appendix Table B-13. Blasting and Drilling Emissions
Control Efficiency1
(%)PM PM10 PM2.5 SO2 NOX CO PM PM10 PM2.5 SO2 NOX CO
Blasting 0% 75.64 39.33 2.27 0.15 72.98 1,647.77 0.42 0.22 0.012 0.00 0.40 9.06
Drilling 96.0% 0.28 0.15 0.01 -- -- -- 0.05 0.03 1.53E-03 -- -- --
75.92 39.48 2.28 0.15 72.98 1,647.77 0.47 0.24 0.01 0.00 0.40 9.06
2Daily Blasting PM Emissions (lb/day) = Emission Factor (lbs/day) as only one blast is allowed per day.
3SO2, NOX, & CO Daily Blasting Emissions (lb/day) = Emission Factor (lb/ton) * Annual ANFO Throughput (tpy) / Annual Blasts (blasts/yr)
4Daily PM Drilling Emissions (lb/day) = Emission Factor (lb/hole) * Drill Holes/yr / Expected Working Days/Year
5SO2, NOX, & CO Annual Blasting Emissions (tpy) = Emission Factor (lbs/ton) * Annual ANFO Throughput (tpy) * 1 ton/2000 lbs
6Annual Blasting PM Emissions (tpy) = Emission Factor (lb/blast) * blasts/yr * 1 ton/2000 lbs
7Annual PM Drilling Emissions (tpy) = Emission Factor (lb/hole) * Drill Holes/yr * 1 ton/2000 lb
Scaling factors were applied to PM15 and TSP emission factors to calculate PM10 and PM2.5 emission factors respectively per Table 11.9-1:
As there is not data for the PM15 emission factor equation, PM15 is conservatively assumed to be equal to TSP.
Source Description Source Activity Throughput Units NOX CO
1Blasting PM emission factors retrieved from AP-42 11.9, Table 11.9-1. Using the equation below the horizontal area blasted (A) is assumed to be the average daily Blast Area.
A = horizontal area (ft2), with blasting depth ≤ 70 ft
0.000014(A)^1.5
Emission Factor1,2,3,4,5,6
PM PM10 PM2.5 SO2
2Drilling PM emission factor is retrieved from AP-42 11.9, Table 11.9-4, where the drilling PM emission factor is for overburden material for conservatism. The coal PM emission factor is lower and may be appropriate for some drilling operations.
Since no emission factors are provided for PM10 and PM2.5 drilling operations, emission factors were calculated using the PM10 and PM2.5 to TSP ratios for blasting overburden per AP-42 11.9, Table 11.9-1, where:
3 Blasting SO2 emission factorbased on a diesel sulfur content of 15 ppm, assuming complete conversion to SO2.
4 Blasting NOX emission factor is the average of measurements from "NOX Emissions from Blasting Operations in Open-Cut Coal Mining" by Moetaz I. Attall, Stuart J. Day, Tony Lange, William Lilley, and Scott Morgan (2008).
1Drilling operations will be controlled through wet-drilling. NIOSH reports 96% control efficiency for controlling fugitive emissions via wet-drilling (per NIOSH's Dust Control Handbook for Industrial Minerals Mining and
Processing, 2012). Kilgore contracts a drilling company that implements wet-drilling control technologies to reduce fugitive drilling emissions.
5 Blasting CO emission factor is the average of measurements in "Factors Affecting ANFO Fumes Production" by James H. Rowland III and Richard Mainiero (2001).
Source Description Max Daily Emissions (lbs/day)2,3,4 Annual Emissions (tpy)5,6,7
Total Annual Emissions:
6 Blasting and drilling quantities provided per design basis.
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Projected Actual Emissions
Appendix Table B-14. Facility Wide Actual Emissions to Projected Actuals Comparison
PM10 PM2.5 NOX SO2 CO VOC CO2e
Point Sources 99.16 70.00 1,186.58 7.46 3,314.73 77.00 918,323.82
Volume Sources 14.23 2.15 - - - - -
Area Sources 24.16 5.30 - - - - -
2nd Finish Mill 7.24 5.11 - - - - -
Liquid Grinding Aid (Finish Mills) - - - - - 2.37 -
Roads 14.61 1.46 - - - - -
Drilling and Blasting 0.43 0.02 0.51 0.00 11.53 - -
N.G. Heater 0.34 0.34 2.24 0.03 3.76 0.25 5,383.56
Tanks - - - - - 0.14 -
Scaled Condensables 13.10 13.10 - - - - -
BASELINE 119.17 66.19 1,186.58 6.87 3,314.73 55.47 641,385.19
Projected Actual 173.27 97.48 1,189.32 7.49 3,330.03 79.76 923,707.39
Projected Actual Increase2 54.10 31.29 2.75 0.62 15.30 24.29 282,322.20
Kiln Emer Drive Gen and
Limestone Bypass -1.51 -3.94 0.28 0.00 -0.13 -0.02 9.28
Third Bay Truck Loadout 1.06 1.06 - - - - -
53.65 28.41 3.03 0.62 15.17 24.27 282,331.48
SERs1 15 10 40 40 100 40 75,000
Threshold Exceeded?Yes Yes No No No No Yes
Unit/Process (tpy)
Proposed Site Wide Emissions (tpy)
Currently Permitted Site Wide Emissions (tpy)
1. PSD Significant Emission Rates.
2. Additional Ammonia Injection will be used in conjuction with SNCR in order to ensure no increase in NOx Emissions from the Kiln.
Contemporaneous Decreases (tpy)
Contemporaneous Increases (tpy)
Emissions Netting
Significant Emission Rates (tpy)
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Projected Actual Emissions
Description Actual
(tpy)
Clinker 1,155,000
Limestone (Raw Material) 1,341,266
Limestone (LBS) 216,260
Gypsum 63,637
CC Shale 91,932
Sandstone 116,938
Coal 120,000
Geneva Slag 78,974
Ammonia 7,971
Clinker Reclaim 101,148
New Rail Line 300,000
New Gypsum 30,000
New Pozzolan 115,000
Appendix Table B-15. Projected Actual Material Throughputs
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Projected Actual Emissions
Appendix Table B-16. Projected Actual Condensables
Baseline Clinker Throughput
Baseline Actuals
Projected Actuals Emission Factor (lb/ton)
Projected Actual Clinker Throughput
Potential Clinker Throughput
Projected Actuals
Appendix Table B-17. Existing Sources CO2e Emissoins
Pollutant 2020 Emissions (tpy) 2021 Emissions (tpy) GWP Baseline CO2e (tpy)Projected Actual
CO2 636,797.30 641,889.57 1.00 639,343.44 915,400.49
CH4 29.95 30.00 25.00 749.44 1,073.03
N2O 4.32 4.35 298.00 1,292.31 1,850.30
641,385.19 918,323.82SUM
13.10
0.02
806,687.00
PM CON
1,155,000.00
1,186,250.00
9.15
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Projected Actual Emissions
PM10 Emission
Rate
PM2.5 Emission
Rate
PM10 Annual
Emissions
PM2.5 Annual
Emissions
(lb/hr)(lb/hr)(tpy)(tpy)
317.BF3 Kiln, Pre-Calciner, & Raw Mill - 136,961 (dscfm)0.007 0.0049 (grain/dscf) - 8760 (hours) 13.99 9.88 61.29 43.26
419.BF1 Clinker Cooler - 110,828 (dscfm)0.005 0.0035 (grain/dscf) - 8760 (hours) 2.07 1.46 9.07 6.40
414.BF1N Kiln Feed Alleviator (New) - 8,171 (dscfm)0.005 0.0035 (grain/dscf) - 8760 (hours) 0.35 0.25 1.53 1.08
N1HPRFM2 Additive Hopper Loading - 2,063 (dscfm)0.005 0.0035 (grain/dscf) - 8760 (hours) 0.09 0.06 0.39 0.27
N1_C1 Transfer Point 1 - 2,063 (dscfm)0.005 0.0035 (grain/dscf) - 8760 (hours) 0.09 0.06 0.39 0.27
N1_C2 Transfer Point 2 - 2,063 (dscfm)0.005 0.0035 (grain/dscf) - 8760 (hours) 0.09 0.06 0.39 0.27
N1_FM2 Finish Mill and Separator - 38,574 (dscfm)0.005 0.0035 (grain/dscf) - 8760 (hours) 1.65 1.17 7.24 5.11
N1_FMS 2FM Raw Material Silos - 8,142 (dscfm)0.005 0.0035 (grain/dscf) - 8760 (hours) 0.35 0.25 1.53 1.08
2FMSXHPR 2FM Silo Hopper (New) - 2,063 (dscfm)0.005 0.0035 (grain/dscf) - 8760 (hours) 0.09 0.06 0.39 0.27NRL_UPR New Rail Loadout Upper Bin - 2,063 (dscfm)0.005 0.0035 (grain/dscf) - 8760 (hours) 0.09 0.06 0.39 0.27
NRL_LWR New Rail Loadout Lower Bin - 2,063 (dscfm)0.005 0.0035 (grain/dscf) - 8760 (hours) 0.09 0.06 0.39 0.27
2FM_HTR 2FM Heater ---7.60 7.60 (lb/MMscf) - 8760 (hours) 0.08 0.08 0.34 0.34
211.BF1 Stationary Crusher - 14,762 (dscfm)0.007 0.0049 (grain/dscf) Limestone (Raw Material) 1606.47 (hours) 0.89 0.63 0.71 0.50
211.BF2 Raw Material Transfer Points - 1,671 (dscfm)0.007 0.0049 (grain/dscf) Limestone (Raw Material) 1606.47 (hours) 0.10 0.07 0.08 0.06
311.BF1 Belt Conveyor Transfer Baghouse - 1,486 (dscfm)0.007 0.0049 (grain/dscf) Limestone (Raw Material) 8760.00 (hours) 0.09 0.06 0.39 0.28
315.BF1 Raw Material Silos - 8,142 (dscfm)0.007 0.0049 (grain/dscf) Limestone (Raw Material) 8760.00 (hours) 0.49 0.34 2.14 1.51
315.BF2 Fifth Component Silo - 2,889 (dscfm)0.007 0.0049 (grain/dscf) Limestone (Raw Material) 8760.00 (hours) 0.17 0.12 0.76 0.54
316.BF1 Raw Mill Recirculation - 825 (dscfm)0.007 0.0049 (grain/dscf) Limestone (Raw Material) 8760.00 (hours) 0.05 0.03 0.22 0.15
316.BF2 Raw Mill Recirculation - 825 (dscfm)0.007 0.0049 (grain/dscf) Limestone (Raw Material) 8760.00 (hours) 0.05 0.03 0.22 0.15
316.BF3 Raw Mill Recirculation - 825 (dscfm)0.007 0.0049 (grain/dscf) Limestone (Raw Material) 8760.00 (hours) 0.05 0.03 0.22 0.15
316.BF4 Raw Mill Recirculation - 825 (dscfm)0.007 0.0049 (grain/dscf) Limestone (Raw Material) 8760.00 (hours) 0.05 0.03 0.22 0.15
316.BF5 Raw Mill Recirculation - 825 (dscfm)0.007 0.0049 (grain/dscf) Limestone (Raw Material) 8760.00 (hours) 0.05 0.03 0.22 0.15
316.BF6 Cross Belt Analyzer - 1,156 (dscfm)0.007 0.0049 (grain/dscf) Limestone (Raw Material) 8760.00 (hours) 0.07 0.05 0.30 0.21
412.BF1 Blending Silo Elevators (2) - 1,203 (dscfm)0.007 0.0049 (grain/dscf) Limestone (Raw Material) 7314.54 (hours) 0.07 0.05 0.26 0.19
411.BF1 Kiln Feed Blending Silos (2) - 3,983 (dscfm)0.007 0.0049 (grain/dscf) Limestone (Raw Material) 7314.54 (hours) 0.24 0.17 0.87 0.62419.BF8 Clinker Belt Transfer - 3,264 (dscfm)0.007 0.0049 (grain/dscf) Clinker 8760.00 (hours) 0.20 0.14 0.86 0.61
419.BF9 East and West Clinker Storage Silos, East Clinker Belt, West
Clinker Belts -5,797 (dscfm) 0.007 0.0049 (grain/dscf) Clinker 5456.13 (hours) 0.35 0.25 0.95 0.67
511.BF Clinker Tunnel - 1,486 (dscfm)0.007 0.0049 (grain/dscf) Clinker 8760.00 (hours) 0.09 0.06 0.39 0.28
511.BF1 East Clinker Silo Discharge - 1,486 (dscfm)0 0 (grain/dscf) Clinker 5456.13 (hours) 0.00 0.00 0.00E+00 0.00E+00
511.BF2 West Clinker Silo Discharge - 1,486 (dscfm)0 0 (grain/dscf) Clinker 5456.13 (hours) 0.00 0.00 0.00E+00 0.00E+00
511.BF4 Gypsum Silo Discharge - 1,486 (dscfm)0 0 (grain/dscf) Gypsum 8760.00 (hours) 0.00 0.00 0.00E+00 0.00E+00
512.BF1 Gypsum Silo - 1,238 (dscfm)0.007 0.0049 (grain/dscf) Gypsum 8760.00 (hours) 0.07 0.05 0.33 0.23
514.BF2 Finish Mill - 11,574 (dscfm)0.007 0.0049 (grain/dscf) Clinker 8760.00 (hours) 0.69 0.49 3.04 2.15
514.BF1 Finish Mill Separator - 10,346 (dscfm)0.007 0.0049 (grain/dscf) Clinker 8760.00 (hours) 0.62 0.44 2.72 1.92
611.BF1 Finish Cement Storage Silos - 5,288 (dscfm)0.007 0.0049 (grain/dscf) Clinker 8760.00 (hours) 0.32 0.22 1.39 0.98
611.BF3 North Cement Loadout - 1,043 (dscfm)0.007 0.0049 (grain/dscf) Clinker 5778.88 (hours) 0.06 0.04 0.18 0.13
611.BF2 South Cement Loadout (truck load outside) - 1,017 (dscfm)0.007 0.0049 (grain/dscf) Clinker 5778.88 (hours) 0.06 0.04 0.18 0.12
41B.BF1 Coal Silo - 1,403 (dscfm)0.007 0.0049 (grain/dscf) Coal 8760.00 (hours) 0.08 0.06 0.37 0.26
41B.BF2 Coal Grinding System (Coal Mill) - 16,095 (dscfm)0.007 0.0049 (grain/dscf) Coal 8760.00 (hours) 0.97 0.68 4.23 2.99
512.BF2 Limestone Silo Discharge - 1,486 (dscfm)0 0 (grain/dscf) Limestone (Raw Material) 8760.00 (hours) 0.00 0.00 0.00E+00 0.00E+00
512.BF3 Limestone Silo - 825.3910 (dscfm)0.007 0.0049 (grain/dscf) Limestone (Raw Material) 8760.00 (hours) 0.05 0.03 0.22 0.15
413.BF1 Dust Shuttle System (alkali silo) - 3,714 (dscfm)0.007 0.0049 (grain/dscf) Limestone (Raw Material) 8760.00 (hours) 0.22 0.16 0.98 0.69514.BF3 Dust Shuttle System (fringe bin) - 3,714 (dscfm)0.007 0.0049 (grain/dscf) Clinker 8760.00 (hours) 0.22 0.16 0.98 0.69
NA Shipping Generator - 560 (hp)5.95E-04 5.95E-04 (lbs/hp-hr) - 60.50 (hours) 0.33 0.33 0.01 0.01
NA Kiln Generator - 762 (hp)3.00E-02 3.00E-02 (g/hp-hr) - 18.50 (hours) 0.05 0.05 4.66E-04 4.66E-04
Associated Throughput Projected
Variable
Projected
Variable Unit
New & Modified Sources
Existing Sources
PM10 EF PM2.5 EFModel ID EF UnitUnitEmission Input
Parameter UnitReferences
Appendix Table B-18. All PM Sources
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Projected Actual Emissions
LDR1_E +
LD1_W Quarry Loader to Haul Truck --Drop 2.76E-03 4.18E-04 (lb/ton) Limestone (Raw Material)- - - - 1.85 0.28
HT_DUMP Quarry Haul Truck to Dump Slope - - Drop 2.76E-03 4.18E-04 (lb/ton) Limestone (Raw Material) - - - - 1.85 0.28
HT1 Quarry Haul Truck to Crusher Pad - - Drop 2.76E-03 4.18E-04 (lb/ton) Limestone (Raw Material) - - - - 1.85 0.28
LDR2 Quarry Loader to Crusher - - Drop 2.76E-03 4.18E-04 (lb/ton) Limestone (Raw Material) - - - - 1.85 0.28
STKR1 Stacker to Reclaim Pile - - Drop 2.76E-03 4.18E-04 (lb/ton) Limestone (Raw Material) - - - - 1.85 0.28RCLMFDR Reclaim Pile to Reclaim Feeder - - Drop 2.76E-03 4.18E-04 (lb/ton) Limestone (Raw Material) - - - - 1.85 0.28
LDR_SS Reclaim Loader from Sandstone Stockpile to Reclaim Pad - - Drop 2.76E-03 4.18E-04 (lb/ton) Sandstone - - - - 0.16 0.02
HT_SS_SP Sandstone Haul Truck to Sandstone Stockpile - - Drop 2.76E-03 4.18E-04 (lb/ton) Sandstone - - - - 0.16 0.02
LDR_3 Reclaim Loader from Reclaim Pad to 4" Stockpile - - Drop 2.76E-03 4.18E-04 (lb/ton) Limestone (LBS) - - - - 0.30 0.05
LDR4 Reclaim Loader to Portable Crusher - - Drop 2.76E-03 4.18E-04 (lb/ton) Limestone (LBS) - - - - 0.30 0.05
SCR Portable Crusher - - Primary Crushing 6.00E-04 2.50E-05 (lb/ton) Limestone (LBS) - - - - 0.06 2.70E-03
SCR_DRP Drop from Portable Crusher - - Drop 2.76E-03 4.18E-04 (lb/ton) Limestone (LBS) - - - - 0.30 0.05
LDR5 Reclaim Loader to Feeder Haul Truck - - Drop 2.76E-03 4.18E-04 (lb/ton) Limestone (LBS) - - - - 0.30 0.05
LDR6 Haul Truck Drop - 1" to Stockpile - Drop 2.76E-03 4.18E-04 (lb/ton) Limestone (LBS) - - - - 0.30 0.05
HT3 Feeder Haul Truck - Limestone and Gypsum to Silo Feeder - - Drop 2.76E-03 4.18E-04 (lb/ton) LBS + Gypsum - - - - 0.39 0.06
CLNKRDRP Reclaim Clinker Drop to Reclaim Clinker Pad - - Drop 8.27E-04 1.25E-04 (lb/ton) Clinker Reclaim - - - - 0.04 6.34E-03
CLNKRSP Reclaim Clinker Stockpiling - - Drop 8.27E-04 1.25E-04 (lb/ton) Clinker Reclaim - - - - 0.04 6.34E-03
SLG_DRP Geneva Slag Haul Truck Drop to Reclaim Slag Pile - - Drop 2.76E-03 4.18E-04 (lb/ton) Geneva Slag - - - - 0.11 0.02
COAL_HPR Coal Hopper (Grate) - - Drop 2.76E-03 4.18E-04 (lb/ton) Coal - - - - 0.17 0.03
RAW_HPR Raw Material Hopper (Grate) - - Drop 2.76E-03 4.18E-04 (lb/ton) CC Shale + Sandstone + Geneva Slag - - - - 0.40 0.06
NRL_SPT New Rail Line Spout - - Enclosed Drop 6.89E-04 1.04E-04 (lb/ton) New Rail Line - - - - 0.10 0.02
V611.BF4 Interior Baghouse Released at Silo Door - - Volume NA NA (lb/ton) - - - - - 0.00E+00 0.00E+00
V611.BF5 Interior Baghouse Released at Silo Door - - Volume NA NA (lb/ton) - - - - - 0.00E+00 0.00E+00
CNVRSCR1 To Crusher - - Conveyor Transfer (Controlled)4.60E-05 1.30E-05 (lb/ton) Limestone (LBS) - - - - 4.97E-03 1.41E-03CNVRSCR2 From Crusher - - Conveyor Transfer (Controlled)4.60E-05 1.30E-05 (lb/ton) Limestone (LBS) - - - - 4.97E-03 1.41E-03
DMP_SLP Dump Slope 1, 2, 3 18.90 (acres)1.04 0.16 (lb/acre/day)Limestone (Raw Material)24.47 (acres)--4.65 0.70
QRY_SLP Quarry Slope 1, 2, 3 0.75 (acres)1.04 0.16 (lb/acre/day)Limestone (Raw Material)0.97 (acres)--0.18 0.03
QRY Quarry 1, 2, 3 17.30 (acres)1.04 0.16 (lb/acre/day)Limestone (Raw Material)22.39 (acres)--4.26 0.64
DG_RCLM1 Reclaim Area 1 1, 2, 3 1.42 (acres)1.04 0.16 (lb/acre/day)Limestone (Raw Material)1.84 (acres)--0.35 0.05
DG_RCLM2 Reclaim Area 2 1, 2, 3 1.42 (acres)1.04 0.16 (lb/acre/day)Limestone (Raw Material)1.84 (acres)--0.35 0.05
DG_RCLM3 Reclaim Area 3 1, 2, 3 1.42 (acres)1.04 0.16 (lb/acre/day)Limestone (Raw Material)1.84 (acres)--0.35 0.05
DG_RCLM4 Reclaim Area 4 1, 2, 3 1.42 (acres)1.04 0.16 (lb/acre/day)Limestone (Raw Material)1.84 (acres)--0.35 0.05
DG_RCLM5 Reclaim Area 5 1, 2, 3 1.42 (acres)1.04 0.16 (lb/acre/day)Limestone (Raw Material)1.84 (acres)--0.35 0.05
CRSH_AR Crusher Area 1, 2, 3 2.20 (acres)1.04 0.16 (lb/acre/day)Limestone (Raw Material)2.85 (acres)--0.54 0.08
SP_TNT1 Storage Pile - Tent 1 1, 2, 3 0.92 (acres)6.3 1.85 (lb/acre/day)Limestone (Raw Material)1.19 (acres)--1.36 0.40
SP_TNT2 Storage Pile - Tent 2 1, 2, 3 0.92 (acres)6.3 1.85 (lb/acre/day)Limestone (Raw Material)1.19 (acres)--1.36 0.40
SP_TNT3 Storage Pile - Tent 3 1, 2, 3 0.92 (acres)6.3 1.85 (lb/acre/day)Limestone (Raw Material)1.19 (acres)--1.36 0.40
SP_CR Storage Pile - Clinker Reclaim 1, 2, 3 0.92 (acres)6.3 1.85 (lb/acre/day)Clinker Reclaim 0.94 (acres)--1.08 0.32
SP_RCLM1 Storage Pile - Reclaim 1 1, 2, 3 0.92 (acres)6.3 1.85 (lb/acre/day)Limestone (Raw Material)1.19 (acres)--1.36 0.40
SP_RCLM2 Storage Pile - Reclaim 2 1, 2, 3 0.92 (acres)6.3 1.85 (lb/acre/day)Limestone (Raw Material)1.19 (acres)--1.36 0.40
SP2 Storage Pile 1, 2, 3 2.70 (acres)6.3 1.85 (lb/acre/day)Limestone (Raw Material)3.50 (acres)--4.02 1.18
BLDZR Bulldozer 4 -----Limestone (Raw Material)1352.75 (hours)0.75 0.11 0.51 0.07
GRDR Grader 4 -----Limestone (Raw Material)1165.69 (hours)0.60 0.03 0.35 0.02
LD_QRY Loader in Quarry 5 5.24 (VMT/day)0.38 0.04 (lb/VMT) Limestone + LBS 7.45 (VMT/day) - - 0.47 0.05
LD_PCR Loader at Primary Crusher 5 5.24 (VMT/day)0.38 0.04 (lb/VMT) Limestone + LBS 7.45 (VMT/day) - - 0.47 0.05
LD_SS Loader - Sandstone to Reclaim Pile 5 0.82 (VMT/day)0.13 0.01 (lb/VMT) Sandstone 1.12 (VMT/day) - - 0.02 2.34E-03
LD_4SP Loader - 4" to Stockpile 5 0.29 (VMT/day)0.13 0.01 (lb/VMT) Limestone (LBS) 1.03 (VMT/day) - - 0.02 2.16E-03
LD_4SPS Loader - 4" to Stockpile (South Test Location) 5 1.41 (VMT/day)0.38 0.04 (lb/VMT) Limestone (LBS) 5.09 (VMT/day) - - 0.32 0.03LD_4PC Loader - 4" to Portable Crusher 5 0.29 (VMT/day)0.13 0.01 (lb/VMT) Limestone (LBS) 1.03 (VMT/day) - - 0.02 2.16E-03
LD_1HT Loader - 1" to Haul Truck 5 0.29 (VMT/day)0.13 0.01 (lb/VMT) Limestone (LBS) 1.03 (VMT/day) - - 0.02 2.16E-03
LD_1HTS Loader - 1" to Haul Truck (South Test Location) 5 0.94 (VMT/day)0.38 0.04 (lb/VMT) Limestone (LBS) 3.39 (VMT/day) - - 0.21 0.02
LD_CR Loader - Clinker Reclaim 5 0.57 (VMT/day)0.10 0.01 (lb/VMT) Clinker Reclaim 0.58 (VMT/day) - - 9.93E-03 9.93E-04
HT_Q_U Haul Truck - Quarry - Unpaved 5 105.95 (VMT/day)0.43 0.04 (lb/VMT) Limestone + LBS 150.55 (VMT/day) - - 10.74 1.07
HT_LP Haul Truck - Lime Bypass System - Paved 5 8.30 (VMT/day)0.14 0.01 (lb/VMT) Limestone (LBS) 29.91 (VMT/day) - - 0.71 0.07
HT_LU Haul Truck - Lime Bypass System - Unpaved 5 0.00 (VMT/day)0.43 0.04 (lb/VMT) Limestone (LBS) 1.58 (VMT/day)- -0.11 0.01
HT_G_P Haul Truck - Gypsum - Paved 5 0.88 (VMT/day)0.11 0.01 (lb/VMT) Gypsum 1.10 (VMT/day) - - 0.02 1.98E-03
HT_C_P Haul Truck - Coal - Paved 5 1.13 (VMT/day)0.11 0.01 (lb/VMT) Coal 1.33 (VMT/day) - - 0.02 2.39E-03
HT_CSP Haul Truck - CC Shale - Paved 5 3.17 (VMT/day)0.11 0.01 (lb/VMT) CC Shale 3.31 (VMT/day) - - 0.06 5.96E-03
HTSPP Haul Truck - Sandstone - Stockpile - Paved 5 5.75 (VMT/day)0.11 0.01 (lb/VMT) Sandstone 7.84 (VMT/day) - - 0.14 0.01
HTSSXP Haul Truck - Sandstone - Silo - Paved 5 1.54 (VMT/day)0.11 0.01 (lb/VMT) Sandstone 2.10 (VMT/day) - - 0.04 3.79E-03
HTGSP Haul Truck - Geneva Slag - Paved 5 6.41 (VMT/day)0.11 0.01 (lb/VMT) Geneva Slag 8.19 (VMT/day) - - 0.15 0.01
HT_AP Haul Truck - Ammonia - Paved 5 0.15 (VMT/day)0.11 0.01 (lb/VMT) Ammonia 0.52 (VMT/day) - - 9.34E-03 9.34E-04
HT_P_P Haul Truck - Product Export - Paved 5 28.55 (VMT/day)0.11 0.01 (lb/VMT) Clinker + LBS + Gypsum 44.65 (VMT/day) - - 0.80 0.08
HT_NRL Haul Truck - New Rail Line - Paved 5 0.00 (VMT/day)0.11 0.01 (lb/VMT) - 10.13 (VMT/day) - - 0.18 0.02
HT2FMS Haul Truck - 2FM Silos - Paved 5 0.00 (VMT/day)0.11 0.01 (lb/VMT) - 3.29 (VMT/day) - - 0.06 5.92E-03
PM10 EF PM2.5 EF EF Unit PM10 EF PM2.5 EF EF Unit
BLST Blasting - - -39.33 2.27 (lb/blast) 56.48 3.26 (lb/blast) - - 0.40 0.02
DRL Drilling - - -0.68 0.04 (lb/hole) 0.68 0.04 (lb/hole) - - 0.03 1.95E-03
Projected Actual FactorsBaseline Factors
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Projected Actual Emissions
TSP Emission Factor:0.38 (ton/acre-yr)
PM10 Content:0.5
PM2.5 Content:0.075
4. Bulldozer and Grader calculation factors and methodology. Bulldozing PM10 Scaling Factor:
0.75
Bulldozing PM2.5 Scaling Factor:
0.105
Grader PM10 Scaling Factor:
0.60 Grader PM2.5 Scaling Factor:
0.031
Silt Content (s):
6.90%
Moisture Content (M):
7.90%
Control Efficiency: Watering:
70%
E =
k, a, b =
k =
a =
b =
s =
WHT =
WQL =
WAV =
WPL =
WPHT =
ηW =
ηCh =
ηP =
Where:
3. Where no PM10 or PM2.5 emission factor was given, the following values were used to solve for the emission factor, per U.S. EPA AP-42, Section 13.2.5, page 13.2.5-3 (Industrial Wind Erosion):
1. PM10 emission factors for stockpiles taken from AP-42, Fourth Edition Table 8.19.1-1, per UDAQ guidance.
2. Per U.S. EPA AP-42, Section 11.9 (Western Surface Coal Mining), Table 11.9-4; August 1998, for Disturbed Area.
4a. AP-42 Section 11.9 (October 1998), Tables 11.9-1 and 11.9-3.
4b. The Western Regional Air Partnership's (WRAP's) Fugitive Dust Handbook, 2006, gives a control
5. AP-42, Section 13.2.2. Also, UDAQ's guidance in Emission Factors for Paved and Unpaved Haul Roads, January 2015, in conjunction with U.S. EPA AP-42 Section 13.2.2, November 2006.
E = k(s/12)a(W/3)b (Equation 1a)where:
4.80
Per UDAQ guidance - Emission Factors for Paved and Unpaved Haul Roads, January 2015
Mean Quarry Haul Truck Weight (tons)
80.00
Size-specific emission factor (lb/VMT)
constants for Equation 1a
1.5 (PM10), 0.15 (PM2.5)
0.9
0.45
Control efficiency of chemical application, per Per UDAQ guidance - Emission Factors for Paved and Unpaved Haul Roads, January 2016
85%
Control efficiency of paving, sweeping, and watering, per Per UDAQ guidance - Emission Factors for Paved and Unpaved Haul Roads, January 2017
95%
38.50
Mean Product Haul Truck Weight (tons)
43.25
Control efficiency of water application and road base, per Per UDAQ guidance - Emission Factors for Paved and Unpaved Haul Roads, January 2015
75%
Mean Quarry Loader Weight (tons)
60.00
Mean Access Vehicle Weight (tons)
43.25
Mean Plant Loader Weight (tons)
surface material silt content (%)
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Projected Actual Emissions
Appendix Table B-19. Kiln and Coal Mill Gaseous Emissions
NOx SO2 CO NOx SO2 CO VOCs Lead NOx SO2 CO VOCs Lead
264.04 1.16 747.53 2.64 0.01 7.48 0.12 7.50E-05 1,695.32 7.43 4,799.69 77.00 0.05
1. Average of 2020 and 2021 lb/hr emission factors from CEMs and Stack Tests.
2. Coal mill emissions are calculated as kiln emissions/0.9*0.1. This table represents a sum of Kiln and Coal Mill emissions.
Appendix Table B-20. NOx Control
NOx1
1,186.58
1,186.00
1,695.32
509.32
0.00
Appendix Table B-21. Kiln Emergency Generator Gaseous Emissions - Contemporaneous Emissions
NOX SO2 CO VOCs NOX SO2 CO VOCs
(g/hp-hr) (g/hp-hr) (g/hp-hr) (g/hp-hr) (hrs) tpy tpy tpy tpy
Kiln Egen 4.60 1.52E-03 6.00E-01 3.00E-02 18.50 0.07 2.36E-05 9.32E-03 4.66E-04
Appendix Table B-22. Shipping Emergency Generator Gaseous Emissions
NOX SO2 CO VOCs NOX SO2 CO VOCs
(lb/hr) (lb/hr) (lb/hr) (lb/hr) (hrs) tpy tpy tpy tpy
Shipping Egen 16.79 1.10 3.62 1.33 60.50 0.51 0.03 0.11 0.04
1. None of the proposed changes and/or increases will effect the demand for the Emergency Generators. Therefore, the projected actual hours are equivalent to the baseline hours from the 2020-2021 period.
Total PTE (tpy)
Equipment
Emission Factors Projected
Operating
Time1
Projected Actual Emissions1
Actual Increase - with SNCR control
Projected Increase - without SNCR control
Kiln & Coal Mill
Baseline
1. Additional Ammonia Injection will be used in conjuction with
SNCR in order to reduce NOx emissions.
Baseline - Egens
Emission Factors (lb/ton)Emission Factors (lb/hr)1
Baseline Years
Baseline Kiln Hours
Baseline Clinker Throughput
8,072
806,687
2020-2021
Annual Emissions (tpy)
1,155,000Projected Actual Clinker Throughput
Equipment
Emission Factors Projected
Operating
Time1
Projected Actual Emissions1
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Projected Actual Emissions
Appendix Table B-23. Blasting and Drilling Area
Maximum Annual Blast
Frequency
(blasts/yr)
Maximum Annual
Area Blasted
(ft2/yr)
Maximum Daily
Blast Area
(ft2/blast)
Minimum Daily
Blast Area
(ft2/blast)
14 431,081 39,189 19,595
Appendix Table B-24. Drilling and Blasting Emission Factors
Value Units Value Units Value Units Value Units Value Units Value Units
Blasting ANFO 568 (tpy)108.61 (lb/blast) 56.48 (lb/blast) 3.26 (lb/blast) 0.0036 (lb/ton) 1.80 (lb/ton) 40.64 (lb/ton)
Drilling Annual # of Drill
Holes 2,502 (holes/yr) 1.30 (lb/hole) 0.68 (lb/hole) 3.90E-02 (lb/hole) - (lb/ton) - (lb/ton) - (lb/ton)
PM10:0.52
PM2.5:0.03
PM10 = PM15 * 0.52
PM2.5 = TSP * 0.03
Appendix Table B-25. Blasting and Drilling Emissions
Control Efficiency1
(%)PM PM10 PM2.5 SO2 NOX CO PM PM10 PM2.5 SO2 NOX CO
Blasting 0% 108.61 56.48 3.26 0.15 72.98 1,647.77 0.76 0.40 0.02 0.00 0.51 11.53
Drilling 96.0% 0.36 0.19 0.01 -- -- -- 0.07 0.03 1.95E-03 -- -- --
108.97 56.66 3.27 0.15 72.98 1,647.77 0.83 0.43 0.02 0.00 0.51 11.53
2Daily Blasting PM Emissions (lb/day) = Emission Factor (lbs/day) as only one blast is allowed per day.
3SO2, NOX, & CO Daily Blasting Emissions (lb/day) = Emission Factor (lb/ton) * Annual ANFO Throughput (tpy) / Annual Blasts (blasts/yr)
4Daily PM Drilling Emissions (lb/day) = Emission Factor (lb/hole) * Drill Holes/yr / Expected Working Days/Year
5SO2, NOX, & CO Annual Blasting Emissions (tpy) = Emission Factor (lbs/ton) * Annual ANFO Throughput (tpy) * 1 ton/2000 lbs
6Annual Blasting PM Emissions (tpy) = Emission Factor (lb/blast) * blasts/yr * 1 ton/2000 lbs
7Annual PM Drilling Emissions (tpy) = Emission Factor (lb/hole) * Drill Holes/yr * 1 ton/2000 lb
1Drilling operations will be controlled through wet-drilling. NIOSH reports 96% control efficiency for controlling fugitive emissions via wet-drilling (per NIOSH's Dust Control Handbook for Industrial Minerals Mining and
Processing, 2012). Kilgore contracts a drilling company that implements wet-drilling control technologies to reduce fugitive drilling emissions.
6 Blast and drilling quantities provided per design basis.
Source Description Max Daily Emissions (lbs/day)2,3,4 Annual Emissions (tpy)5,6,7
Total Annual Emissions:
2Drilling PM emission factor is retrieved from AP-42 11.9, Table 11.9-4, where the drilling PM emission factor is for overburden material for conservatism. The coal PM emission factor is lower and may be appropriate for some drilling operations.
Since no emission factors are provided for PM10 and PM2.5 drilling operations, emission factors were calculated using the PM10 and PM2.5 to TSP ratios for blasting overburden per AP-42 11.9, Table 11.9-1, where:
3 Blasting SO2 emission factor developed using a mass balance assuming 6% fuel oil mixture with 500 ppm sulfur content, consistent with EPA non-road standards.
4 Blasting NOX and CO emission factors retrieved from ANFO blasting agent factor from AP-42 13.3-1.
5 Blasting CO emission factor retrieved from ANFO blasting agent factor from AP-42 13.3-1.
1Blasting PM emission factors retrieved from AP-42 11.9, Table 11.9-1. Using the equation below the horizontal area blasted (A) is assumed to be the average daily Blast Area.
A = horizontal area (ft2), with blasting depth ≤ 70 ft
0.000014(A)^1.5
Scaling factors were applied to PM15 and TSP emission factors to calculate PM10 and PM2.5 emission factors respectively per Table 11.9-1:
As there is not data for the PM15 emission factor equation, PM15 is conservatively assumed to be equal to TSP.
Source Description Source Activity Throughput Units
Emission Factor1,2,3,4,5,6
PM PM10 PM2.5 SO2 NOX CO
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Projected Actual Emissions
Parameter Value Unit
Heat Input: 10.43 MMBtu/hr
Equivalent Gas Hours: 8,760 hr/yr
Natural Gas Heating Value
(HHV)1:1,020 Btu/scf
1. Natural gas HHV from AP-42 Section 1.4.1.
(lb/hr) (tpy)
NOx 50 lb/MMscf 1 0.51 2.24
CO 84 lb/MMscf 1 0.86 3.76
PM 7.60 lb/MMscf 1 0.08 0.34
PM10 7.60 lb/MMscf 1 0.08 0.34
PM2.5 7.60 lb/MMscf 1 0.08 0.34
SO2 0.60 lb/MMscf 1 0.01 0.03
VOC 5.50 lb/MMscf 1 0.06 0.25
Lead 0.0005 lb/MMscf 1 5.11E-06 2.24E-05
CO2 120,000 lb/MMscf 1 1226.59 5,372
N2O 0.64 lb/MMscf 1 0.01 2.87E-02
CH4 2.30E+00 lb/MMscf 1 0.02 0.10
CO2e 120,248.22 lb/MMscf 2 1229.12 5,384
1. Natural gas emission factors from AP-42 Section 1.4.
Appendix Table B-26. Heater Parameters
Pollutant Emission Factor Units Reference
2. Emission factor calculated from 40 CFR Part 98 Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in
Subpart A Table A-1.
Appendix Table B-27. Heater Criteria & GHG Emissions
Emissions
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Projected Actual Emissions
Appendix Table B-28. Liquid Grinding Aid Emissions
Annual Clinker 1,186,250
Lb/short-ton of clinker 1 0.004
TPY of VOCs 2.37
1. Emissions rates from client testing.
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Ash Grove Leamington Plant | PSD Application | Plant Upgrade Project
Trinity Consultants C-2
APPENDIX C. EMISSIONS CALCULATIONS

Potential To Emit
Appendix Table C-1. New Facility Wide Potential to Emit
PM10 PM2.5 NOX SO2 CO VOC CO2e
Point Sources 103.68 73.19 1,351.79 231.37 13,045.23 71.24 1,091,350
Volume Sources 17.16 2.59 - - - - -
Area Sources 34.47 7.04 - - - - -
2nd Finish Mill 7.24 5.11 - - - - -
Liquid Grinding Aid (Finish Mills) - - - - - 2.37 -
Roads 19.38 1.94 - - - - -
Drilling and Blasting 0.55 0.03 0.67 0.00 15.05 - -
N.G. Heater 0.34 0.34 2.24 0.03 3.76 0.25 5,383.56
Tanks - - - - - 0.14 -
Scaled Condensables 13.45 13.45 - - - - -
Currently Permitted1 234.79 230.35 1,351.79 192.50 13,044.87 59.38 1,053,009
New Potential to Emit 196.27 103.69 1,354.70 231.40 13,064.05 74.00 1,096,734
PTE Change2 -38.52 -126.66 2.91 38.90 19.18 14.62 43,724.56
2. Additional Ammonia Injection will be used in conjuction with SNCR in order to ensure no increase in NOx Emissions from the Kiln.
1. As permitted in DAQE-AN103030030-22.
Unit/Process (tpy)
Proposed Site Wide Emissions (tpy)
Currently Permitted Site Wide Emissions (tpy)
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Potential To Emit
Appendix Table C-2. Site Wide HAP Summary - Kiln, Coal Mill, and Heater
HAPs PTE HAP Emissions
(tpy)
Hydrochloric Acid 2.49
Dioxins 3.18E-08
Mercury 1.16E-02
Acenaphthylene 0.08
Arsenic 7.92E-03
Beryllium 4.35E-04
Cadmium 1.50E-03
Chromium & Compounds 0.09
Manganese 0.57
Lead 0.05
Selenium 0.13
Benzene6 2.04
Benzo(a)anthracene 2.83E-05
Benzo(a)pyrene 8.57E-05
Benzo(b)fluoranthene 3.69E-04
Benzo(g,h,i)perylene 5.15E-05
Benzo(k)fluoranthene 9.89E-05
Biphenyl 4.02E-03
Bis(2-ethylhexyl)phthalate 0.06
Bromomethane (methyl bromide)0.03
Carbon Disulfide 0.07
Chlorobenzene 1.05E-02
Chloromethane (Methyl chloride)0.25
Chrysene 1.06E-04
Dibenzo[a,h]anthracene 4.15E-04
Di-n-butylphthalate 0.03
Ethyl benzene 1.25E-02
Fluoranthene 5.80E-03
Fluorene 1.25E-02
Formaldehyde5 12.83
Indeno[1,2,3-C,D]pyrene 5.73E-05
Methylene Chloride 0.32
Naphthalene 1.12
Phenanthrene 0.26
Phenol 0.07
Pyrene 2.90E-03
Styrene 9.89E-04
Toluene 0.13
Dibenzofurans 3.82E-07
Xylenes (Mixture of O, M, and P Isomers)0.09
2-Methylnaphthalene 1.07E-06
3-Methylchloranthrene 8.06E-08
7,12-Dimethylbenz(a)anthracene 7.16E-07
Acenaphthene 8.06E-08
Anthracene 1.07E-07
Benz(a)anthracene 8.06E-08
Dibenzo(a,h)anthracene 5.37E-08
Dichlorobenzene 5.37E-05
Hexane 8.06E-02
Indeno(1,2,3-cd)pyrene 8.06E-08
Phenanathrene 7.61E-07
Chromium 6.27E-05
Cobalt 3.76E-06
Nickel 9.40E-05
Total 20.86
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Potential To Emit
Description Potential
(tpy)
Clinker 1,186,250
Limestone (Raw Material) 1,593,454
Limestone (LBS) 280,500
Gypsum 75,602
CC Shale 109,217
Sandstone 138,925
Coal 143,560
Geneva Slag 93,823
Ammonia 7,971
Clinker Reclaim 200,000
New Rail Line 300,000
New Gypsum 30,000
New Pozzolan 115,000
Appendix Table C-3. Potential Throughputs
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Potential To Emit
Appendix Table C-4. Potential Condensables
Baseline Clinker Throughput
Baseline Actuals
Projected Actuals Emission Factor (lb/ton)
Projected Actual Clinker Throughput
Potential Clinker Throughput
Potential
Appendix Table C-5. HAP CEMs Data.
2020 2021 Baseline Potential (PTE)
Clinker Throughput (tpy) 803,402.00 809,972.00 806,687.00 1,186,250.00
DF (mg) 17.37 17.90 17.63 25.93
Emission Rate (mg/ton) 2.16E-05 2.21E-05 2.19E-05 2.19E-05
HCl (lb) 3,171.33 2,934.46 3,052.90 4,489.35
Emission Rate (lb/ton) 3.95E-03 3.62E-03 3.78E-03 3.78E-03
Hg (lb) 11.17 17.10 14.14 20.79
Emission Rate (lb/ton) 1.39E-05 2.11E-05 1.75E-05 1.75E-05
Potential (PTE) (tpy)
0.01
2.24
2.86E-08
Dioxins and Furans (DF), Hydrochloric Acid (HCl), and Mercury (Hg) Emissions
806,687.00
13.45
PM CON
1,155,000.00
1,186,250.00
9.15
0.02
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Potential To Emit
PM10 Emission
Rate
PM2.5 Emission
Rate
PM10 Annual
Emissions
PM2.5 Annual
Emissions
(lb/hr)(lb/hr)(tpy)(tpy)
317.BF3 Kiln, Pre-Calciner, & Raw Mill - 136,961 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 16.84 11.88 61.29 43.26
419.BF1 Clinker Cooler - 110,828 (dscfm)0.005 0.0035 (grain/dscf) 8,760.00 (hours) 2.66 1.88 9.07 6.40
414.BF1N Kiln Feed Alleviator (New) - 8,171 (dscfm)0.005 0.0035 (grain/dscf) 8,760.00 (hours) 0.35 0.25 1.53 1.08
N1HPRFM2 Additive Hopper Loading - 2,063 (dscfm)0.005 0.0035 (grain/dscf) 8,760.00 (hours) 0.09 0.06 0.39 0.27
N1_C1 Transfer Point 1 - 2,063 (dscfm)0.005 0.0035 (grain/dscf) 8,760.00 (hours) 0.09 0.06 0.39 0.27
N1_C2 Transfer Point 2 - 2,063 (dscfm)0.005 0.0035 (grain/dscf) 8,760.00 (hours) 0.09 0.06 0.39 0.27
N1_FM2 Finish Mill and Separator - 38,574 (dscfm)0.005 0.0035 (grain/dscf) 8,760.00 (hours) 1.65 1.17 7.24 5.11
N1_FMS 2FM Raw Material Silos - 8,142 (dscfm)0.005 0.0035 (grain/dscf) 8,760.00 (hours) 0.35 0.25 1.53 1.08
2FMSXHPR 2FM Silo Hopper (New) - 2,063 (dscfm)0.005 0.0035 (grain/dscf) 8,760.00 (hours) 0.09 0.06 0.39 0.27NRL_UPR New Rail Loadout Upper Bin - 2,063 (dscfm)0.005 0.0035 (grain/dscf) 8,760.00 (hours) 0.09 0.06 0.39 0.27
NRL_LWR New Rail Loadout Lower Bin - 2,063 (dscfm)0.005 0.0035 (grain/dscf) 8,760.00 (hours) 0.09 0.06 0.39 0.27
2FM_HTR 2FM Heater ---7.60 7.60 (lb/MMscf) 8,760.00 (hours) 0.08 0.08 0.34 0.34
211.BF1 Stationary Crusher - 14,762 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.89 0.63 3.88 2.74
211.BF2 Raw Material Transfer Points - 1,671 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.10 0.07 0.44 0.31
311.BF1 Belt Conveyor Transfer Baghouse - 1,486 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.09 0.06 0.39 0.28
315.BF1 Raw Material Silos - 8,142 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.49 0.34 2.14 1.51
315.BF2 Fifth Component Silo - 2,889 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.17 0.12 0.76 0.54
316.BF1 Raw Mill Recirculation - 825 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.05 0.03 0.22 0.15
316.BF2 Raw Mill Recirculation - 825 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.05 0.03 0.22 0.15
316.BF3 Raw Mill Recirculation - 825 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.05 0.03 0.22 0.15
316.BF4 Raw Mill Recirculation - 825 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.05 0.03 0.22 0.15
316.BF5 Raw Mill Recirculation - 825 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.05 0.03 0.22 0.15
316.BF6 Cross Belt Analyzer - 1,156 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.07 0.05 0.30 0.21
412.BF1 Blending Silo Elevators (2) - 1,203 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.07 0.05 0.32 0.22
411.BF1 Kiln Feed Blending Silos (2) - 3,983 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.24 0.17 1.05 0.74419.BF8 Clinker Belt Transfer - 3,264 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.20 0.14 0.86 0.61
419.BF9 East and West Clinker Storage Silos, East Clinker Belt, West
Clinker Belts -5,797 (dscfm) 0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.35 0.25 1.52 1.08
511.BF Clinker Tunnel - 1,486 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.09 0.06 0.39 0.28
511.BF1 East Clinker Silo Discharge - 1,486 (dscfm)0.00 0.00 (grain/dscf) 8,760.00 (hours) 0.00 0.00 0.00 0.00
511.BF2 West Clinker Silo Discharge - 1,486 (dscfm)0.00 0.00 (grain/dscf) 8,760.00 (hours) 0.00 0.00 0.00 0.00
511.BF4 Gypsum Silo Discharge - 1,486 (dscfm)0.00 0.00 (grain/dscf) 8,760.00 (hours) 0.00 0.00 0.00 0.00
512.BF1 Gypsum Silo - 1,238 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.07 0.05 0.33 0.23
514.BF2 Finish Mill - 11,574 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.69 0.49 3.04 2.15
514.BF1 Finish Mill Separator - 10,346 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.62 0.44 2.72 1.92
611.BF1 Finish Cement Storage Silos - 5,288 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.32 0.22 1.39 0.98
611.BF3 North Cement Loadout - 1,043 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.06 0.04 0.27 0.19
611.BF2 South Cement Loadout (truck load outside) - 1,017 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.06 0.04 0.27 0.19
41B.BF1 Coal Silo - 1,403 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.08 0.06 0.37 0.26
41B.BF2 Coal Grinding System (Coal Mill) - 16,095 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.97 0.68 4.23 2.99
512.BF2 Limestone Silo Discharge - 1,486 (dscfm)0.00 0.00 (grain/dscf) 8,760.00 (hours) 0.00 0.00 0.00 0.00
512.BF3 Limestone Silo - 825.3910 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.05 0.03 0.22 0.15
413.BF1 Dust Shuttle System (alkali silo) - 3,714 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.22 0.16 0.98 0.69514.BF3 Dust Shuttle System (fringe bin) - 3,714 (dscfm)0.007 0.0049 (grain/dscf) 8,760.00 (hours) 0.22 0.16 0.98 0.69
NA Shipping Generator - 560 (hp)5.95E-04 5.95E-04 (lbs/hp-hr) 100.00 (hours) 0.33 0.33 0.02 0.02
NA Kiln Generator - 762 (hp)3.00E-02 3.00E-02 (g/hp-hr) 100.00 (hours) 0.05 0.05 2.52E-03 2.52E-03
Appendix Table C-6. All PM Sources
PM10 EF PM2.5 EFModel ID EF UnitUnitEmission Input
Parameter UnitReferences Projected
Variable
Projected
Variable Unit
Existing Sources
New & Modified Sources
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LDR1_E +
LD1_W Quarry Loader to Haul Truck --Drop 2.76E-03 4.18E-04 (lb/ton)2.20 0.33
HT_DUMP Quarry Haul Truck to Dump Slope - - Drop 2.76E-03 4.18E-04 (lb/ton) 2.20 0.33
HT1 Quarry Haul Truck to Crusher Pad - - Drop 2.76E-03 4.18E-04 (lb/ton) 2.20 0.33
LDR2 Quarry Loader to Crusher - - Drop 2.76E-03 4.18E-04 (lb/ton) 2.20 0.33
STKR1 Stacker to Reclaim Pile - - Drop 2.76E-03 4.18E-04 (lb/ton) 2.20 0.33RCLMFDR Reclaim Pile to Reclaim Feeder - - Drop 2.76E-03 4.18E-04 (lb/ton) 2.20 0.33
LDR_SS Reclaim Loader from Sandstone Stockpile to Reclaim Pad - - Drop 2.76E-03 4.18E-04 (lb/ton) 0.19 0.03
HT_SS_SP Sandstone Haul Truck to Sandstone Stockpile - - Drop 2.76E-03 4.18E-04 (lb/ton) 0.19 0.03
LDR_3 Reclaim Loader from Reclaim Pad to 4" Stockpile - - Drop 2.76E-03 4.18E-04 (lb/ton) 0.39 0.06
LDR4 Reclaim Loader to Portable Crusher - - Drop 2.76E-03 4.18E-04 (lb/ton) 0.39 0.06
SCR Portable Crusher - - Primary Crushing 6.00E-04 2.50E-05 (lb/ton) 0.08 3.51E-03
SCR_DRP Drop from Portable Crusher - - Drop 2.76E-03 4.18E-04 (lb/ton) 0.39 0.06
LDR5 Reclaim Loader to Feeder Haul Truck - - Drop 2.76E-03 4.18E-04 (lb/ton) 0.39 0.06
LDR6 Haul Truck Drop - 1" to Stockpile - Drop 2.76E-03 4.18E-04 (lb/ton) 0.39 0.06
HT3 Feeder Haul Truck - Limestone and Gypsum to Silo Feeder - - Drop 2.76E-03 4.18E-04 (lb/ton) 0.49 0.07
CLNKRDRP Reclaim Clinker Drop to Reclaim Clinker Pad - - Drop 8.27E-04 1.25E-04 (lb/ton) 0.08 0.01
CLNKRSP Reclaim Clinker Stockpiling - - Drop 8.27E-04 1.25E-04 (lb/ton) 0.08 0.01
SLG_DRP Geneva Slag Haul Truck Drop to Reclaim Slag Pile - - Drop 2.76E-03 4.18E-04 (lb/ton) 0.13 0.02
COAL_HPR Coal Hopper (Grate) - - Drop 2.76E-03 4.18E-04 (lb/ton) 0.20 0.03
RAW_HPR Raw Material Hopper (Grate) - - Drop 2.76E-03 4.18E-04 (lb/ton) 0.47 0.07
NRL_SPT New Rail Line Spout - - Enclosed Drop 6.89E-04 1.04E-04 (lb/ton) 0.10 0.02
V611.BF4 Interior Baghouse Released at Silo Door - - Volume NA NA (lb/ton) 0.00 0.00
V611.BF5 Interior Baghouse Released at Silo Door - - Volume NA NA (lb/ton) 0.00 0.00
CNVRSCR1 To Crusher - - Conveyor Transfer (Controlled)4.60E-05 1.30E-05 (lb/ton) 6.45E-03 1.82E-03CNVRSCR2 From Crusher - - Conveyor Transfer (Controlled)4.60E-05 1.30E-05 (lb/ton) 6.45E-03 1.82E-03
DMP_SLP Dump Slope 1, 2, 3 18.90 (acres)1.04 0.16 (lb/acre/day)29.07 (acres)--5.52 0.83
QRY_SLP Quarry Slope 1, 2, 3 0.75 (acres)1.04 0.16 (lb/acre/day)1.15 (acres)--0.22 0.03
QRY Quarry 1, 2, 3 17.30 (acres)1.04 0.16 (lb/acre/day)26.61 (acres)--5.06 0.76
DG_RCLM1 Reclaim Area 1 1, 2, 3 1.42 (acres)1.04 0.16 (lb/acre/day)2.18 (acres)--0.41 0.06
DG_RCLM2 Reclaim Area 2 1, 2, 3 1.42 (acres)1.04 0.16 (lb/acre/day)2.18 (acres)--0.41 0.06
DG_RCLM3 Reclaim Area 3 1, 2, 3 1.42 (acres)1.04 0.16 (lb/acre/day)2.18 (acres)--0.41 0.06
DG_RCLM4 Reclaim Area 4 1, 2, 3 1.42 (acres)1.04 0.16 (lb/acre/day)2.18 (acres)--0.41 0.06DG_RCLM5 Reclaim Area 5 1, 2, 3 1.42 (acres)1.04 0.16 (lb/acre/day)2.18 (acres)--0.41 0.06
CRSH_AR Crusher Area 1, 2, 3 2.20 (acres)1.04 0.16 (lb/acre/day)3.38 (acres)--0.64 0.10
SP_TNT1 Storage Pile - Tent 1 1, 2, 3 0.92 (acres)6.3 1.85 (lb/acre/day)1.41 (acres)--1.62 0.48
SP_TNT2 Storage Pile - Tent 2 1, 2, 3 0.92 (acres)6.3 1.85 (lb/acre/day)1.41 (acres)--1.62 0.48
SP_TNT3 Storage Pile - Tent 3 1, 2, 3 0.92 (acres)6.3 1.85 (lb/acre/day)1.41 (acres)--1.62 0.48
SP_CR Storage Pile - Clinker Reclaim 1, 2, 3 0.92 (acres)6.3 1.85 (lb/acre/day)1.86 (acres)--2.14 0.63SP_RCLM1 Storage Pile - Reclaim 1 1, 2, 3 0.92 (acres)6.3 1.85 (lb/acre/day)1.41 (acres)--1.62 0.48
SP_RCLM2 Storage Pile - Reclaim 2 1, 2, 3 0.92 (acres)6.3 1.85 (lb/acre/day)1.41 (acres)--1.62 0.48
SP2 Storage Pile 1, 2, 3 2.70 (acres)6.3 1.85 (lb/acre/day)4.15 (acres)--4.77 1.40
BLDZR Bulldozer 4 -----8,760.00 (hours)0.75 0.11 3.30 0.46
GRDR Grader 4 -----8,760.00 (hours)0.60 0.03 2.64 0.14
LD_QRY Loader in Quarry 5 5.24 (VMT/day)0.38 0.04 (lb/VMT) 8.96 (VMT/day) - - 0.62 0.06
LD_PCR Loader at Primary Crusher 5 5.24 (VMT/day)0.38 0.04 (lb/VMT) 8.96 (VMT/day) - - 0.62 0.06
LD_SS Loader - Sandstone to Reclaim Pile 5 0.82 (VMT/day)0.13 0.01 (lb/VMT) 1.33 (VMT/day) - - 0.03 3.07E-03
LD_4SP Loader - 4" to Stockpile 5 0.29 (VMT/day)0.13 0.01 (lb/VMT) 1.34 (VMT/day) - - 0.03 3.10E-03
LD_4SPS Loader - 4" to Stockpile (South Test Location) 5 1.41 (VMT/day)0.38 0.04 (lb/VMT) 6.60 (VMT/day) - - 0.46 0.05
LD_4PC Loader - 4" to Portable Crusher 5 0.29 (VMT/day)0.13 0.01 (lb/VMT) 1.34 (VMT/day) - - 0.03 3.10E-03
LD_1HT Loader - 1" to Haul Truck 5 0.29 (VMT/day)0.13 0.01 (lb/VMT) 1.34 (VMT/day) - - 0.03 3.10E-03
LD_1HTS Loader - 1" to Haul Truck (South Test Location) 5 0.94 (VMT/day)0.38 0.04 (lb/VMT) 4.40 (VMT/day) - - 0.31 0.03
LD_CR Loader - Clinker Reclaim 5 0.57 (VMT/day)0.10 0.01 (lb/VMT) 1.15 (VMT/day) - - 0.02 2.17E-03
HT_Q_U Haul Truck - Quarry - Unpaved 5 105.95 (VMT/day)0.43 0.04 (lb/VMT) 181.13 (VMT/day) - - 14.29 1.43
HT_LP Haul Truck - Lime Bypass System - Paved 5 8.30 (VMT/day)0.14 0.01 (lb/VMT) 38.79 (VMT/day) - - 1.02 0.10
HT_LU Haul Truck - Lime Bypass System - Unpaved 5 0.00 (VMT/day)0.43 0.04 (lb/VMT) 1.58 (VMT/day)- -0.12 0.01HT_G_P Haul Truck - Gypsum - Paved 5 0.88 (VMT/day)0.11 0.01 (lb/VMT) 1.31 (VMT/day) - - 0.03 2.61E-03
HT_C_P Haul Truck - Coal - Paved 5 1.13 (VMT/day)0.11 0.01 (lb/VMT) 1.59 (VMT/day) - - 0.03 3.17E-03
HT_CSP Haul Truck - CC Shale - Paved 5 3.17 (VMT/day)0.11 0.01 (lb/VMT) 3.93 (VMT/day) - - 0.08 7.83E-03
HTSPP Haul Truck - Sandstone - Stockpile - Paved 5 5.75 (VMT/day)0.11 0.01 (lb/VMT) 9.32 (VMT/day) - - 0.19 0.02
HTSSXP Haul Truck - Sandstone - Silo - Paved 5 1.54 (VMT/day)0.11 0.01 (lb/VMT) 2.50 (VMT/day) - - 0.05 4.98E-03
HTGSP Haul Truck - Geneva Slag - Paved 5 6.41 (VMT/day)0.11 0.01 (lb/VMT) 9.73 (VMT/day) - - 0.19 0.02HT_AP Haul Truck - Ammonia - Paved 5 0.15 (VMT/day)0.11 0.01 (lb/VMT) 0.52 (VMT/day) - - 0.01 1.03E-03
HT_P_P Haul Truck - Product Export - Paved 5 28.55 (VMT/day)0.11 0.01 (lb/VMT) 47.99 (VMT/day) - - 0.96 0.10
HT_NRL Haul Truck - New Rail Line - Paved 5 0.00 (VMT/day)0.11 0.01 (lb/VMT) 10.13 (VMT/day) - - 0.20 0.02
HT2FMS Haul Truck - 2FM Silos - Paved 5 0.00 (VMT/day)0.11 0.01 (lb/VMT) 3.29 (VMT/day) - - 0.07 6.55E-03
PM10 EF PM2.5 EF EF Unit
BLST Blasting - - -- -- 59.12 3.41 (lb/blast)-0.50 0.03
DRL Drilling - - -- -- 0.68 0.04 (lb/hole)-0.04 2.55E-03
Limestone (Raw Material) Potential Throughput
Limestone (LBS) Potential Throughput
Limestone (LBS) Potential Throughput
Limestone (Raw Material) Potential Throughput
Limestone (Raw Material) Potential Throughput
Limestone (Raw Material) Potential Throughput
Limestone (Raw Material) Potential Throughput
Limestone (Raw Material) Potential Throughput
LBS + Gypsum Potential Throughput
Sandstone Potential Throughput
Sandstone Potential Throughput
Limestone (LBS) Potential Throughput
Limestone (LBS) Potential Throughput
Limestone (LBS) Potential Throughput
Limestone (LBS) Potential Throughput
Limestone (LBS) Potential Throughput
Limestone (LBS) Potential Throughput
Potential Factors
Clinker Reclaim Potential Throughput
-
Coal Potential Throughput
CC Shale + Sandstone + Geneva Slag Potential Throughput
Clinker Reclaim Potential Throughput
Geneva Slag Potential Throughput
New Rail Line Potential Throughput
-
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Potential To Emit
TSP Emission Factor:0.38 (ton/acre-yr)
PM10 Content:0.5
PM2.5 Content:0.075
4. Bulldozer and Grader calculation factors and methodology. Bulldozing PM10 Scaling Factor:
0.75
Bulldozing PM2.5 Scaling Factor:
0.105
Grader PM10 Scaling Factor:
0.60 Grader PM2.5 Scaling Factor:
0.031
Silt Content (s):
6.90%
Moisture Content (M):
7.90%
Control Efficiency: Watering:
70%
E =
k, a, b =
k =
a =
b =
s =
WHT =
WQL =
WAV =
WPL =
WPHT =
ηW =
ηCh =
ηP =
constants for Equation 1a
1.5 (PM10), 0.15 (PM2.5)
0.9
0.45
4a. AP-42 Section 11.9 (October 1998), Tables 11.9-1 and 11.9-3.
4b. The Western Regional Air Partnership's (WRAP's) Fugitive Dust Handbook, 2006, gives a control
5. AP-42, Section 13.2.2. Also, UDAQ's guidance in Emission Factors for Paved and Unpaved Haul Roads, January 2015, in conjunction with U.S. EPA AP-42 Section 13.2.2, November 2006.
E = k(s/12)a(W/3)b (Equation 1a)where:
Control efficiency of chemical application, per Per UDAQ guidance - Emission Factors for Paved and Unpaved Haul Roads, January 2016
85%
Control efficiency of paving, sweeping, and watering, per Per UDAQ guidance - Emission Factors for Paved and Unpaved Haul Roads, January 2017
95%
75%
38.50
Mean Product Haul Truck Weight (tons)
43.25
Control efficiency of water application and road base, per Per UDAQ guidance - Emission Factors for Paved and Unpaved Haul Roads, January 2015
Mean Quarry Loader Weight (tons)
60.00
Mean Access Vehicle Weight (tons)
43.25
Mean Plant Loader Weight (tons)
surface material silt content (%)
4.80Per UDAQ guidance - Emission Factors for Paved and Unpaved Haul Roads, January 2015
Mean Quarry Haul Truck Weight (tons)
80.00
Size-specific emission factor (lb/VMT)
3. Where no PM10 or PM2.5 emission factor was given, the following values were used to solve for the emission factor, per U.S. EPA AP-42, Section 13.2.5, page 13.2.5-3 (Industrial Wind Erosion):
1. PM10 emission factors for stockpiles taken from AP-42, Fourth Edition Table 8.19.1-1, per UDAQ guidance.
2. Per U.S. EPA AP-42, Section 11.9 (Western Surface Coal Mining), Table 11.9-4; August 1998, for Disturbed Area.
Where:
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Potential To Emit
Appendix Table C-7. Kiln Emergency Generator Gaseous Emissions
NOX SO2 CO VOCs NOX SO2 CO VOCs
(g/hp-hr)(g/hp-hr)(g/hp-hr)(g/hp-hr)(hrs)tpy tpy tpy tpy
Kiln Egen 4.60 1.52E-03 6.00E-01 3.00E-02 100.00 0.39 1.28E-04 5.04E-02 2.52E-03
Appendix Table C-8. Shipping Emergency Generator Gaseous Emissions (Existing source included for reference)
NOX SO2 CO VOCs NOX SO2 CO VOCs
(lb/hr)(lb/hr)(lb/hr)(lb/hr)(hrs)tpy tpy tpy tpy
Shipping Egen 16.79 1.10 3.62 1.33 100.00 0.84 0.06 0.18 0.07
Appendix Table C-9. Kiln Gaseous Emissions Kiln and Coal Mill PTE
NOx SO2 CO VOCs Lead NOx SO2 CO VOCs Lead NOx SO2 CO VOCs Lead
2.80 0.39 60.08 0.12 7.50E-05 1347.17 192.45 13045 57.74 0.04 1,347.17 231.32 13,045 71.18 0.04
1. New site specific SO2 emission factor is 0.39 lb/ton.
2. Existing SO2 lb/ton factor is 0.4 lb/ton.
Appendix Table C-10. Baseline, Projected Actual, and Projected Potential GHG Emissions
Potential
Operating
Time
1,186,250
Annual Emissions (tpy)
Potential
Operating
Time
Potential to Emit
Emission Factors (lb/ton)1
Potential Clinker Throughput - Future (tpy)
Potential to Emit
Equipment
Emission Factors
Equipment
Emission Factors
Permitted Clinker Throughput (tpy)962,265
0.92
Current Potential (PTE)
Existing Annual Emissions (tpy)2
Clinker Throughput (tpy)
Baseline Kiln System CO2e (tons)
CO2e Emissions ton/ton of Clinker)
962,265
1,053,000
1.09
1,186,250
1,091,350
Future Potential (PTE)
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Appendix Table C-11. Kiln Hazardous Air Pollutants Emissions
Emission Factor PTE
(lb/ton) (tpy)
Hydrochloric Acid1 3.78E-03 2.24
Dioxins1 4.82E-11 2.86E-08
Mercury1 1.75E-05 1.04E-02
Acenaphthylene2 1.20E-04 0.07
Arsenic2 1.20E-05 7.12E-03
Beryllium2 6.60E-07 3.91E-04
Cadmium2 2.20E-06 1.30E-03
Chromium & Compounds2 1.40E-04 0.08
Manganese2 8.60E-04 0.51
Lead2 7.50E-05 0.04
Selenium2 2.00E-04 0.12
Benzene4 3.10E-03 1.84
Benzo(a)anthracene2 4.30E-08 2.55E-05
Benzo(a)pyrene2 1.30E-07 7.71E-05
Benzo(b)fluoranthene2 5.60E-07 3.32E-04
Benzo(g,h,i)perylene2 7.80E-08 4.63E-05
Benzo(k)fluoranthene2 1.50E-07 8.90E-05
Biphenyl2 6.10E-06 3.62E-03
Bis(2-ethylhexyl)phthalate2 9.50E-05 0.06
Bromomethane (methyl bromide)2 4.30E-05 0.03
Carbon Disulfide2 1.10E-04 0.07
Chlorobenzene2 1.60E-05 9.49E-03
Chloromethane (Methyl chloride)2 3.80E-04 0.23
Chrysene2 1.60E-07 9.49E-05
Dibenzo[a,h]anthracene2 6.30E-07 3.74E-04
Di-n-butylphthalate2 4.10E-05 0.02
Ethyl benzene2 1.90E-05 1.13E-02
Fluoranthene2 8.80E-06 5.22E-03
Fluorene2 1.90E-05 1.13E-02
Formaldehyde3 1.95E-02 11.54
Indeno[1,2,3-C,D]pyrene2 8.70E-08 5.16E-05
Methylene Chloride2 4.90E-04 0.29
Naphthalene2 1.70E-03 1.01
Phenanthrene2 3.90E-04 0.23
Phenol2 1.10E-04 0.07
Pyrene2 4.40E-06 2.61E-03
Styrene2 1.50E-06 8.90E-04
Toluene2 1.90E-04 0.11
Dibenzofurans2 5.80E-10 3.44E-07
Xylenes
(Mixture of O, M, and P Isomers)2 1.30E-04 0.08
18.70
1. Emissions from CEMs Data.
4. The ESP emission factor has been used as the exhuast gas exiting the baghouse is a similar
temperature to standard exhaust from an ESP and results in a similar destruction effciency.
HAP
Total HAPs
2. AP-42 11.6-9 (1/95), Fabric Filter emission factors were used if AP-42 contained both an
Electrostatic Precipitator and Fabric Filter Emission Factor.
3. TETCO Leamington Source Test December 2000
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Appendix Table C-12. Coal Mill Hazardous Air Pollutants Emissions
HAPs Emission Factor
(lbs/ton) 1
PTE HAP Emissions
(tpy)
Hydrochloric Acid 4.20E-04 2.49E-01
Dioxins 5.35E-12 3.18E-09
Mercury 1.95E-06 1.15E-03
Acenaphthylene 1.33E-05 7.91E-03
Arsenic 1.33E-06 7.91E-04
Beryllium 7.33E-08 4.35E-05
Cadmium 2.44E-07 1.45E-04
Chromium & Compounds 1.56E-05 9.23E-03
Manganese 9.56E-05 5.67E-02
Lead 8.33E-06 4.94E-03
Selenium 2.22E-05 1.32E-02
Benzene 3.44E-04 2.04E-01
Benzo(a)anthracene 4.78E-09 2.83E-06
Benzo(a)pyrene 1.44E-08 8.57E-06
Benzo(b)fluoranthene 6.22E-08 3.69E-05
Benzo(g,h,i)perylene 8.67E-09 5.14E-06
Benzo(k)fluoranthene 1.67E-08 9.89E-06
Biphenyl 6.78E-07 4.02E-04
Bis(2-ethylhexyl)phthalate 1.06E-05 6.26E-03
Bromomethane (methyl bromide)4.78E-06 2.83E-03
Carbon Disulfide 1.22E-05 7.25E-03
Chlorobenzene 1.78E-06 1.05E-03
Chloromethane (Methyl chloride)4.22E-05 2.50E-02
Chrysene 1.78E-08 1.05E-05
Dibenzo[a,h]anthracene 7.00E-08 4.15E-05
Di-n-butylphthalate 4.56E-06 2.70E-03
Ethyl benzene 2.11E-06 1.25E-03
Fluoranthene 9.78E-07 5.80E-04
Fluorene 2.11E-06 1.25E-03
Formaldehyde 2.16E-03 1.28E+00
Indeno[1,2,3-C,D]pyrene 9.67E-09 5.73E-06
Methylene Chloride 5.44E-05 3.23E-02
Naphthalene 1.89E-04 1.12E-01
Phenanthrene 4.33E-05 2.57E-02
Phenol 1.22E-05 7.25E-03
Pyrene 4.89E-07 2.90E-04
Styrene 1.67E-07 9.89E-05
Toluene 2.11E-05 1.25E-02
Dibenzofurans 6.44E-11 3.82E-08
Xylenes
(Mixture of O, M, and P Isomers)1.44E-05 8.57E-03
2.08Total
1. Emissions from these pollutants is a result of kiln exhaust gas being used to heat the coal mill. Since 10%
of the exhaust from the kiln is routed through the coal mill, coal mill emission factors are calculated as kiln
emission factors/0.9*0.1
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Appendix Table C-13. Blasting and Drilling Area
Maximum Annual
Blast Frequency
(blasts/yr)
Maximum Annual
Area Blasted
(ft2/yr)
Maximum Daily
Blast Area
(ft2/blast)
Minimum Daily
Blast Area
(ft2/blast)
17 686,857 40,403 20,202
Appendix Table C-14. Drilling and Blasting Emission Factors
Value Units Value Units Value Units Value Units Value Units Value Units
Blasting ANFO 741 (tpy)113.70 (lb/blast) 59.12 (lb/blast) 3.41 (lb/blast) 0.0036 (lb/ton) 1.80 (lb/ton) 40.64 (lb/ton)
Drilling Annual # of Drill
Holes 3,264 (holes/yr) 1.30 (lb/hole) 0.68 (lb/hole) 3.90E-02 (lb/hole) - (lb/ton) - (lb/ton) - (lb/ton)
PM10:0.52
PM2.5:0.03
PM10 = PM15 * 0.52
PM2.5 = TSP * 0.03
Appendix Table C-15. Blasting and Drilling Emissions
Control Efficiency1
(%)PM PM10 PM2.5 SO2 NOX CO PM PM10 PM2.5 SO2 NOX CO
Blasting 0% 113.70 59.12 3.41 0.16 78.45 1,771.13 0.80 0.50 0.03 0.00 0.67 15.05
Drilling 96.0% 0.47 0.24 0.01 -- -- -- 0.08 0.04 2.55E-03 -- -- --
114.16 59.37 3.42 0.16 78.45 1,771.13 0.88 0.55 0.03 0.00 0.67 15.05
2Daily Blasting PM Emissions (lb/day) = Emission Factor (lbs/day) as only one blast is allowed per day.
3SO2, NOX, & CO Daily Blasting Emissions (lb/day) = Emission Factor (lb/ton) * Annual ANFO Throughput (tpy) / Annual Blasts (blasts/yr)
4Daily PM Drilling Emissions (lb/day) = Emission Factor (lb/hole) * Drill Holes/yr / Expected Working Days/Year
5SO2, NOX, & CO Annual Blasting Emissions (tpy) = Emission Factor (lbs/ton) * Annual ANFO Throughput (tpy) * 1 ton/2000 lbs
6Annual Blasting PM Emissions (tpy) = Emission Factor (lb/blast) * blasts/yr * 1 ton/2000 lbs
7Annual PM Drilling Emissions (tpy) = Emission Factor (lb/hole) * Drill Holes/yr * 1 ton/2000 lb
Source Description Source Activity Throughput Units
Emission Factor1,2,3,4,5,6
PM PM10 PM2.5 SO2 NOX CO
1Blasting PM emission factors retrieved from AP-42 11.9, Table 11.9-1. Using the equation below the horizontal area blasted (A) is assumed to be the average daily Blast Area.
A = horizontal area (ft2), with blasting depth ≤ 70 ft
0.000014(A)^1.5
Scaling factors were applied to PM15 and TSP emission factors to calculate PM10 and PM2.5 emission factors respectively per Table 11.9-1:
As there is not data for the PM15 emission factor equation, PM15 is conservatively assumed to be equal to TSP.
2Drilling PM emission factor is retrieved from AP-42 11.9, Table 11.9-4, where the drilling PM emission factor is for overburden material for conservatism. The coal PM emission factor is lower and may be appropriate for some drilling
Since no emission factors are provided for PM10 and PM2.5 drilling operations, emission factors were calculated using the PM10 and PM2.5 to TSP ratios for blasting overburden per AP-42 11.9, Table 11.9-1, where:
3 Blasting SO2 emission factor developed using a mass balance assuming 6% fuel oil mixture with 500 ppm sulfur content, consistent with EPA non-road standards.
4 Blasting NOX emission factor is the average of measurements from "NOX Emissions from Blasting Operations in Open-Cut Coal Mining" by Moetaz I. Attall, Stuart J. Day, Tony Lange, William Lilley, and Scott Morgan (2008).
5 Blasting CO emission factor is the average of measurements in "Factors Affecting ANFO Fumes Production" by James H. Rowland III and Richard Mainiero (2001).
1Drilling operations will be controlled through wet-drilling. NIOSH reports 96% control efficiency for controlling fugitive emissions via wet-drilling (per NIOSH's Dust Control Handbook for Industrial Minerals Mining
and Processing, 2012). Kilgore contracts a drilling company that implements wet-drilling control technologies to reduce fugitive drilling emissions.
6 Blast and drilling quantities provided per design basis.
Source Description Max Daily Emissions (lbs/day)2,3,4 Annual Emissions (tpy)5,6,7
Total Annual Emissions:
Ash Grove Leamington Plant Page 11 of 15 Trinity Consultants
Potential To Emit
Parameter Value Unit
Existing Boiler Heat Input: 10.43 MMBtu/hr
Equivalent Gas Hours: 8,760 hr/yr
Natural Gas Heating Value
(HHV)1:1,020 Btu/scf
1. Natural gas HHV from AP-42 Section 1.4.1.
(lb/hr) (tpy)
NOx 50 lb/MMscf 1 0.51 2.24
CO 84 lb/MMscf 1 0.86 3.76
PM 7.60 lb/MMscf 1 0.08 0.34
PM10 7.60 lb/MMscf 1 0.08 0.34
PM2.5 7.60 lb/MMscf 1 0.08 0.34
SO2 0.60 lb/MMscf 1 0.01 0.03
VOC 5.50 lb/MMscf 1 0.06 0.25
Lead 0.0005 lb/MMscf 1 5.11E-06 2.24E-05
CO2 120,000 lb/MMscf 1 1226.59 5,372
N2O 0.64 lb/MMscf 1 0.01 2.87E-02
CH4 2.30E+00 lb/MMscf 1 0.02 0.10
CO2e 120,248.22 lb/MMscf 2 1229.12 5,384
1. Natural gas emission factors from AP-42 Section 1.4.
2. Emission factor calculated from 40 CFR Part 98 Subpart C Tables C-1 and C-2 using the Global Warming Potentials
provided in Subpart A Table A-1.
Emissions
Appendix Table C-17. Heater Criteria & GHG Emissions
Appendix Table C-16. Heater Parameters
Pollutant Emission Factor Units Reference
Ash Grove Leamington Plant Page 12 of 15 Trinity Consultants
Potential To Emit
(lb/hr) (tpy)
2-Methylnaphthalene 2.40E-05 lb/MMscf 2.45E-07 1.07E-06
3-Methylchloranthrene 1.80E-06 lb/MMscf 1.84E-08 8.06E-08
7,12-Dimethylbenz(a)anthracene 1.60E-05 lb/MMscf 1.64E-07 7.16E-07
Acenaphthene 1.80E-06 lb/MMscf 1.84E-08 8.06E-08
Acenaphthylene 1.80E-06 lb/MMscf 1.84E-08 8.06E-08
Anthracene 2.40E-06 lb/MMscf 2.45E-08 1.07E-07
Benz(a)anthracene 1.80E-06 lb/MMscf 1.84E-08 8.06E-08
Benzene 2.10E-03 lb/MMscf 2.15E-05 9.40E-05
Benzo(a)pyrene 1.20E-06 lb/MMscf 1.23E-08 5.37E-08
Benzo(b)fluoranthene 1.80E-06 lb/MMscf 1.84E-08 8.06E-08
Benzo(g,h,i)perylene 1.20E-06 lb/MMscf 1.23E-08 5.37E-08
Benzo(k)fluoranthene 1.80E-06 lb/MMscf 1.84E-08 8.06E-08
Chrysene 1.80E-06 lb/MMscf 1.84E-08 8.06E-08
Dibenzo(a,h)anthracene 1.20E-06 lb/MMscf 1.23E-08 5.37E-08
Dichlorobenzene 1.20E-03 lb/MMscf 1.23E-05 5.37E-05
Fluoranthene 3.00E-06 lb/MMscf 3.07E-08 1.34E-07
Fluorene 2.80E-06 lb/MMscf 2.86E-08 1.25E-07
Formaldehyde 7.50E-02 lb/MMscf 7.67E-04 3.36E-03
Hexane 1.80E+00 lb/MMscf 1.84E-02 8.06E-02
Indeno(1,2,3-cd)pyrene 1.80E-06 lb/MMscf 1.84E-08 8.06E-08
Naphthalene 6.10E-04 lb/MMscf 6.24E-06 2.73E-05
Phenanathrene 1.70E-05 lb/MMscf 1.74E-07 7.61E-07
Pyrene 5.00E-06 lb/MMscf 5.11E-08 2.24E-07
Toluene 3.40E-03 lb/MMscf 3.48E-05 1.52E-04
Arsenic 2.00E-04 lb/MMscf 2.04E-06 8.95E-06
Beryllium 1.20E-05 lb/MMscf 1.23E-07 5.37E-07
Cadmium 1.10E-03 lb/MMscf 1.12E-05 4.92E-05
Chromium 1.40E-03 lb/MMscf 1.43E-05 6.27E-05
Cobalt 8.40E-05 lb/MMscf 8.59E-07 3.76E-06
Lead 5.00E-04 lb/MMscf 5.11E-06 2.24E-05
Manganese 3.80E-04 lb/MMscf 3.88E-06 1.70E-05
Mercury 2.60E-04 lb/MMscf 2.66E-06 1.16E-05
Nickel 2.10E-03 lb/MMscf 2.15E-05 9.40E-05
Selenium 2.40E-05 lb/MMscf 2.45E-07 1.07E-06
Total HAPs 0.02 0.08
1. Natural gas emission factors from AP-42, Tables 1.4-3 and 1.4-4.
Pollutant Emission Factor1 Units PTE HAP Emissions
Appendix Table C-18. Heater HAPs Emissions
Ash Grove Leamington Plant Page 13 of 15 Trinity Consultants
Potential To Emit
Appendix Table C-19. Liquid Grinding Aid Emissions
Annual Clinker 1,186,250
Lb/short-ton of clinker 1 0.004
TPY of VOCs 2.37
1. Emissions rates from client testing.
Ash Grove Leamington Plant Page 14 of 15 Trinity Consultants
Potential To Emit
Appendix Table C-20. Tanks Emissions
Ammonia 0.14
Total 0.14
Type of Material Stored Ammonia Emissions
(tpy)
Ash Grove Leamington Plant Page 15 of 15 Trinity Consultants

Ash Grove Leamington Plant | PSD Application | Plant Upgrade Project
Trinity Consultants D-1
APPENDIX D. MODELING SUPPORTING INFORMATION

A modeling protocol and report and the air quality impact analysis files are submitted in separate files.

State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Lieutenant Governor

Department of Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper

RN103030032
January 21, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Josh Nelson,

Re: Engineer Review:
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

Please review and sign this letter and attached Engineer Review (ER) within 10 business days.
For this document to be considered as the application for a Title V administrative amendment, a
Title V Responsible Official must sign the next page.

Please contact John Jenks at [phone] if you have any questions or concerns about the ER.
If you accept the contents of this ER, please email this signed cover letter to John Jenks at
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 1

[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the
DAQ will consider any comments received and will issue the Approval Order.

If you do not respond to this letter within 10 business days, the project will move forward
without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue
an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 2

OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible
Official, as defined in R307-415-3, must sign the statement below. THIS IS STRICTLY
OPTIONAL.

If you do not want the Engineer Review to be considered as an application to administratively
amend your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will
require submittal of a separate Operating Permit Application to revise the Title V permit in
accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document:
Title V Operating Permit Application Due Dates clarifies the required due dates for Title V
operating permit applications and can be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality

“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate
and complete and request that this Approval Order be considered as an application
to administratively amend the Operating Permit.”

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 3

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N103030032
Owner Name Ash Grove Cement Company
Mailing Address P.O. Box 38069
Leamington, UT, 84638

Source Name Ash Grove Cement Company- Leamington Cement
Plant
Source Location Hwy 132
Leamington, UT 84638

UTM Projection 397000 m Easting, 4380100 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3241 (Cement, Hydraulic)

Source Contact Cody Watkins
Phone Number [phone]
Email [e-mail]

Billing Contact Cody Watkins
Phone Number 385.225.0615
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 30, 2022
Date of Accepted Application November 28, 2024

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 4

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 5

SOURCE DESCRIPTION

General Description
Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried
on site), are correctly proportioned, ground and mixed, and then fed into a rotating kiln. The kiln
alters the materials and recombines them into small stones called cement clinker. The clinker is
cooled and ground with gypsum and additional limestone into a fine powdered cement. The final
product is stored on site for later shipping. The major sources of air emissions are from the
combustion of fuels for the kiln operation, from the kiln, and from the clinker cooling process.
The Leamington cement plant is a major source for emissions of PM2.5, PM10, NOx, CO, HAPs
and GHG. It is a minor source of SO2 emissions.

NSR Classification:
Major PSD Modification

Source Classification
Located in Attainment Area,
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Proposal
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower, various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 6

These changes result in increases in actual emissions, but decreases in most potential emissions.
There will be an increase in the potential emissions of VOC and greenhouse gases.

EMISSION IMPACT ANALYSIS
The complete modeling review is located in DAQE-MN103030032-24. [Last updated January 14, 2025]

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 7

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
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Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 9

Review of BACT for New/Modified Emission Units

1. BACT review regarding the Leamington Plant Upgrade Project
Any major stationary source or major modification subject to PSD review must undergo an
analysis to ensure the use of BACT. The requirement to conduct a BACT analysis is set forth in 40
CFR 52.21. Similarly, Utah requires the installation of BACT for all sources of air pollution under
R307-401-5(2)(d)), BACT is defined in 40 CFR 52.21 (and R307-401-2) as:

". . . best available control technology means an emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for each pollutant subject to regulation under
Act which would be emitted from any proposed major stationary source or major modification
which the Administrator, on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such source or modification
through application of production processes or available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion techniques for control of such
pollutant . . ."

Therefore, a BACT analysis is required for each new or physically modified emission unit for each
pollutant that exceeds an applicable PSD significant emission rate (SER). Since the PM10 and PM2.5
emissions from the proposed project exceed the applicable PSD SER, a BACT analysis is required
to assess the required levels of control for these pollutants. Because the CO2e emissions are subject
to regulation as a result of the proposed project resulting in an increase of 75,000 tons or more per
year CO2e, a BACT analysis is also required for that pollutant. Note that HAPs listed under CAA
Section 112(b)(1) are excluded from NSR (New Source Review) or PSD (i.e., BACT) review.

In a memorandum dated December 1, 1987, the United States Environmental Protection Agency
(EPA) stated its preference for a "top-down" BACT analysis. After determining if any New Source
Performance Standard (NSPS) is applicable, the first step in this approach is to determine, for the
emission unit in question, the most stringent control available for a similar or identical source or
source category. If it can be shown that this level of control is technically, environmentally, or
economically infeasible for the unit in question, then the next most stringent level of control is
determined and similarly evaluated. This process continues until the BACT level under
consideration cannot be eliminated by any substantial or unique technical, environmental, or
economic objections.

Presented below are the five basic steps of a top-down BACT review as identified by the EPA.
Step 1 - Identify All Control Technologies
Step 2 - Eliminate Technically Infeasible Options
Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Step 4 - Evaluate Most Effective Controls and Document Results
Step 5 - Select BACT

Ash Grove has elected to follow this methodology and based the BACT review on each individual
pollutant. The complete BACT analysis follows. [Last updated January 14, 2025]

2. BACT review regarding PM10 and PM2.5 Sources
PM10 and PM2.5 Modified Equipment
The existing kiln precalciner, preheater, and alleviator system are proposed to be modified, and the
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 10

kiln's ID fan and clinker cooler fans are proposed to be replaced, which will result in increased
airflow. Additionally, the clinker cooler baghouse will be converted from a plenum pulse to a pulse
jet baghouse. These modifications are projected to result in a net increase of potential PM10 and
PM2.5 emissions.

Kiln Upgrade BACT
The rotary cement kiln is the core of the cement manufacturing process, transforming the blended
raw materials or "rawmix" into clinker through pyro processing. Emissions from the kiln occur
from fuel combustion plus the physical and chemical reactions needed to transform the rawmix
into clinker. This project involves process and energy efficiency improvements and an increase in
kiln production, resulting in an increase of PM10 and PM2.5 emissions. This section specifically
addresses filterable PM10 and PM2.5. The condensable fraction is represented with the other
precursors as applicable to proposed emission increases.

The Leamington Plant's Kiln is subject to NSPS, Subpart F for particulate. Therefore, a BACT
analysis addresses applicability of the proposed changes to the kiln system to NSPS and review of
the RBLC. A summary of the resources reviewed include the following:

NSPS Subpart F - Standards of Performance for Portland Cement Plants establishes emission
standards for cement kiln operations. Specifically, kilns modified after June 16, 2008, are limited to
0.07 lbs PM/ton of clinker produced.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028) and
Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from kiln operations are as follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM emissions are most effectively controlled using a collection system with enclosures routed to
baghouses providing up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Ash Grove
has selected technology with the highest control efficiency, so there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 11

Step 5 - Select BACT
Ash Grove proposes that BACT for PM10 and PM2.5 emissions from the kiln consist of a collection
system routed to a baghouse or fabric filter that complies with NSPS Subpart F's emission standard
for a modified source. BACT for the Leamington Plant's kiln are 10% opacity and 0.07 lb of
PM/ton (NSPS Subpart F emission standard) of clinker.
[Last updated January 14, 2025]

3. BACT review regarding PM10 and PM2.5 sources cont.
Clinker Cooler Upgrade BACT
The clinker cooler reduces the temperature of the clinker exiting the kiln. It is necessary to reduce
clinker temperature before it enters the finish mill to maintain product quality and reduce wear and
tear on equipment. The clinker cooler is equipped with a heat exchanger that captures waste heat
and transfers it to the kiln preheater for process and energy efficiency. Emissions from the clinker
cooler are vented to a baghouse. The Leamington Plant's clinker cooler is also subject to NSPS
Subpart F for particulate. Ash Grove's proposed changes to the clinker cooler meet the definition of
a reconstruction under NSPS. Therefore, in order to meet the requirements of NSPS Subpart F, Ash
Grove will be required to meet a limit of 0.02 lb of PM/ton of clinker.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from clinker cooler operations are as
follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM10 and PM2.5 emissions are most effectively controlled using a collection system with enclosures
routed to a baghouse, which can achieve up to 99.9% control efficiency. Other technologies such as
wet scrubbers, cyclones and ESPs are feasible, but provide lower control efficiencies than a
baghouse. Because the most efficient control technology is proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for PM10 and PM2.5 emissions from the clinker cooler is a collection system routed to a
baghouse or fabric filter. In order to meet the requirements of NSPS Subpart F, Ash Grove will
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 12

meet a reduced emission limit of 0.02 lb of PM/ton of clinker. A 10% opacity limit is also
applicable. [Last updated January 14, 2025]

4. BACT review regarding PM10 and PM2.5 sources cont.
New Finish Mill BACT
The proposed Plant upgrade include adding a second finish mill. The new finish mill will use an
energy efficient vertical roller mill assisted with a grinding aid. A total of five (5) point sources are
planned for the finish mill. In accordance with NSPS Subpart F, emissions from finish mill are
restricted to 10% opacity. Ash Grove has reviewed the following sources to identify available
control technologies.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);12 and

Region 8 General Permit for Concrete Batch Plants.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 emissions from plant material handling operations are as
follows:
Baghouse / Fabric Filter;
Best Management & Operational Practices;
Cyclone;
ESP;
Enclosure;
Water Application (Watering); and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
With the exception of water application, all options are technically feasible. Water application is
eliminated as clinker exiting the kiln along with additives in the finish mill must remain dry to
maintain product quality. Therefore, it is technically infeasible to water material in the finish mill.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Enclosure 50-90%
5. Cyclone 20-70%
6. Best Management & Operational Practices varies

Step 4 - Evaluate Most Effective Controls and Document Results
Baghouses provide the highest emission control efficiency, controlling up to 99.9% of PM
emissions from finish mill equipment. After baghouses, using a wet scrubber or ESP provides
similar PM control. Notably, baghouses, scrubbers, and ESPs require enclosures to aid in capturing
emissions and ducting to the control. Therefore, optimal PM emission control can be achieved
through implementing both baghouses and enclosures where feasible. Plant material sizing and
handling is currently done using a series of buildings and enclosures routed to baghouse controls.
Various silos storing material inputs are also equipped with fabric filters. As the highest ranked
technology is applied, there are no adverse energy, environmental or cost impacts to consider with
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the use of these control technologies. Thus, no further analysis is required under EPA's top-down
BACT approach.

Step 5 - Select BACT
BACT for finish mill PM10 emissions is compliance with NSPS Subpart F, Standards of
Performance for Portland Cement Manufacturing where applicable. Ash Grove will achieve BACT
for PM10 emissions from finish mill equipment through the implementation of enclosures,
baghouses, and best management practices. All baghouses at the finish mill will have a 10%
opacity limitation and a grain loading of 0.005 grains/dscf. [Last updated January 14, 2025]

5. BACT review regarding PM10 and PM2.5 sources cont.
Material Transfer, Sizing, and Storage BACT
The Leamington Plant has sources of fugitive emissions through raw material transfer. Materials
transferred include limestone and other raw materials, coal, clinker, and cement. These materials
are transferred by conveyor belt, screw conveyor, elevator, pneumatic conveyance or chutes via
gravity. At the Leamington Plant the fugitive emissions are enclosed at their transfer points and
routed to baghouses.

The following emission units are included in this category:
Limestone Crushing, Sizing, and Material Transfer;
Raw Material Transfer;
Coal Sizing and Transfer;
Existing Finish Mill;
Clinker Storage and Transfer;
Cement Storage and Truck and Rail Cement Loadout;
New Rail Loading and Loadout; and
New Clinker Reclaim Hopper Baghouse.

Generally, controls for these units have not changed or they are similar to current existing controls.
A full BACT analysis of each unit is included in Ash Grove's NOI and additional submitted
information. However, given that most controls remain unaltered, only the results of Step 5 -
Select BACT will be included here.

Limestone Crushing, Sizing, and Material Transfer
Subject to NSPS Subpart OOO opacity limits for existing sources.
Existing baghouses. No change from bag manufacturer's specifications.

Raw Material Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Coal Storage and Transfer
Existing Equipment. No change from bag manufacturer's specifications
20% Opacity

Clinker Storage and Transfer
Subject to NSPS Subpart F opacity limits:
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10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Existing Finish Mill Grinding, Storage and Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Cement Storage and Truck and Rail Cement Loadout, New Rail Loadout
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

New Rail Loadout, controlled by baghouse
Emissions Limit - 0.005 gr/dscfm

New Clinker Reclaim Hopper, controlled by baghouse
Subject to NSPS Subpart F opacity limits:
10% opacity
Emissions Limit - 0.005 gr/dscfm [Last updated January 14, 2025]

6. BACT review regarding PM10 and PM2.5 sources cont.
PM10 and PM2.5 Fugitive Emissions
The following fugitive emissions sources will increase emissions of PM10 and PM2.5 as a result of
the Leamington Plant's proposed throughput increase. The sources addressed in the following
BACT analyses are primarily in the quarry, but also include emissions from roads and dumping of
raw materials within the plant boundary.

The sources evaluated are listed below:
Roads;
Loading and Unloading;
Stockpiles;
Bulldozing and Grading;
Disturbed Areas; and
Drilling and Blasting.

Ash Grove currently controls emissions from these processes, and generally, controls for these
units have not changed. A full BACT analysis of each unit is included in Ash Grove's NOI and
additional submitted information. However, given that most controls remain unaltered, only the
results of Step 5 - Select BACT will be included here.

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
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Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

Stockpiles BACT
BACT shall consist of restricting fugitive emissions to the opacity standard of 20% opacity at the
property boundary. BACT for stockpiles will be achieved through applying good management
practices through its fugitive dust plan as appropriate.

Bulldozing and Grading BACT
BACT shall consist of restricting fugitive emissions from bulldozing and grading activities to no
more than 20% opacity, and that emissions are controlled with periodic watering of the disturbed
surface. The frequency of water application will depend on ambient weather conditions and
inherent moisture content of the material being moved.

Disturbed Areas BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. BACT for
disturbed areas will be achieved through best management practices, watering, scarification, and
revegetation.

Drilling and Blasting BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. This is achievable
through best management practices, shrouds, watering, and dust collection. [Last updated January
14, 2025]

7. BACT review regarding kiln system NOx emissions
Kiln System (Kiln, Raw Mill, and Coal Mill) - NOx BACT
Although there are physical changes to the kiln system, these changes are primarily related to
particulate emissions. NOx emissions are generated from the combustion of fuel - and no changes
in NOx emissions are expected from the kiln (hourly capacity to emit). The kiln NOx emissions will
remain the same as a result of upgrades to the SNCR system. The replacement of the various
components of the kiln system and portions of the preheater tower, along with new injection points,
will ensure that increased mixing of ammonia is achieved to enhance the SNCR system's ability to
reduce NOx and minimize ammonia slip. This will allow the Leamington Plant to maintain the NOx
hourly capacity to emit unchanged from current levels Leamington Plant Upgrade Project. At
present Ash Grove has no restriction on the amount of fuel combusted, only a limit on total NOx
generated, and with this project the allowed NOx PTE is decreasing from 1,352 tpy to 1,226 tpy.

Additional ammonia will be used in the existing SNCR system. While the SNCR system has
adequate capacity to accommodate the additional ammonia demand resulting from the system
upgrades, more ammonia ports are proposed to be added with the kiln system's proposed changes
of the equipment. The changes proposed to the kiln system will increase residence time and
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temperature which will improve the SNCR system's effectiveness to control NOx emissions and
minimize ammonia slip emissions to the atmosphere. No additional review of NOx BACT for the
kiln system is required under this proposal. [Last updated January 14, 2025]

8. BACT review regarding new finish mill heater emissions
Finish Mill Heater
The proposed finish mill will include a process heater to maintain a minimum temperature during
milling. The proposed heater will run on natural gas and is rated at 10 MMBtu/hr. Startup and
shutdown emissions from the heater are anticipated to be no greater than normal operation as the
process is simply a matter of bringing the heater to operating temperature. Emissions evaluated in
the BACT analysis for the finish mill heater include NOx, SO2, CO, and VOCs, PM10, and PM2.5.
Pollutants with identical control technologies are grouped together in the analysis.

NOx - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for NOx from units of this size range are as follows:
Ultra-Low-NOx Burners (ULNB);
Low NOx Burners;
Selective Catalytic Reduction (SCR);
Selective Noncatalytic Reduction (SNCR);
Good Combustion Practices; and
Use of Natural Gas.

Step 2 - Eliminate Technically Infeasible Options
Low exit temperatures render the use of SCR and SNCR ineffective. Particulate entrainment within
the finish mill could potentially foul (plug) the nozzles of ULNB. Low-NOx burners, the use of
natural gas as fuel and good combustion practices are all considered technically feasible.

Step 3 and Step 4 - Rank Remaining Control Technologies by Control Effectiveness and Evaluate
Most Effective Controls and Document Results
Since the three feasible control technologies are proposed for the finish mill heater, no detailed
economic, energy, and environmental impact evaluations were conducted. No ranking of control
effectiveness is required as all three controls are proposed.

Step 5 - Select BACT
BACT for NOx is the use of natural gas as fuel, good combustion practices and the use of Low NOx
burners.

CO, SO2, and VOC - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for CO, SO2, and VOC from units of this size are as follows:
Good Combustion Practices
Use of Natural Gas

The finish mill heater combusts natural gas. Related natural gas combustion emissions are
anticipated to be minimal.

Step 2 - Eliminate Technically Infeasible Options
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Both control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Both technologies offer intrinsic emission reductions from combustion. Since the technologies do
not compete, both technologies can and will be used simultaneously.

Step 4 - Evaluate Most Effective Controls and Document Results
Because both control technologies identified in Step 1 are proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for CO, SO2, and VOC are good combustion practices and the use of natural gas.

PM10 and PM2.5 BACT for the finish mill has been addressed in the PM10/PM2.5 sources section.
[Last updated January 14, 2025]

9. BACT review regarding SO2, VOC, and Lead Sources
The following BACT analysis is grouped by pollutants that will experience an increase in potential
emissions and the associated technically feasible control technologies. As such, the BACT analysis
is separated into SO2, VOC, and lead respectively with organic HAPs addressed with VOCs.

SO2 - Cement Kiln BACT
NSPS Subpart F - Standards of Performance for Portland Cement Plants, establishes emission
standards for cement kiln operations. Specifically, kilns constructed or reconstructed after June 16,
2008, are limited to 0.4 lbs SO2/ton clinker on a 30-day rolling average respectively. This limit is
an existing emission limit in the Leamington Plant's approval order and Title V. Ash Grove will
continue to achieve this emission limitation while achieving BACT for the kiln operations. Ash
Grove has reviewed the following sources to identify available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019); and

NSPS Subpart F as an affected emissions facility in 40 CFR 60.62(a)(4);

Portland Cement Association's Formation and Techniques for Control of Sulfur Dioxide and Other
Sulfur Compounds in Portland Cement Kiln Systems.

SO2 emissions are a result of oxidation of sulfur compounds in the rawmix and/or the coal used to
fire the kiln. However, the alkaline nature of the cement provides for direct absorption of SO2 into
the product, thereby mitigating the quantity of SO2 emissions in the exhaust stream.

Step 1 - Identify All Control Technologies
Control technologies identified for SO2 emissions from coal-fired kiln operations are as follows:
Baghouse or fabric filter;
Dry reagent injection prior to baghouse;
Wet scrubber;
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Process optimization; and
Good combustion practices.

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below:

1. Process Optimization 99%
2. Wet Scrubber 99%
3. Dry Reagent Injection 60%
4. Good Combustion Practices 30%
5. Baghouse Variable

Step 4 - Evaluate Most Effective Controls and Document Results
SO2 emissions are most effectively controlled by optimizing the process and utilizing the inherent
SO2 scrubbing properties of the kiln system itself. Although wet scrubbers alone can achieve equal
control efficiencies as process optimization, additional capital and operational expenses are
required for water consumption and wastewater discharge. Whereas process optimization achieves
the same control effectiveness and has the added benefit of reduced operational costs. Ash Grove
optimizes the kiln process by routing the exhaust from the kiln to a preheater and raw mill to
interact with the raw mix, thus creating an atmosphere similar to a dry scrubber system. Good
combustion practices also reduce SO2 formation with the added benefit of energy efficiency.

Step 5 - Select BACT
BACT for control of SO2 emissions from kiln operations shall consist of process optimization by
routing kiln exhaust to the preheater and raw mill, good combustion practices, and use of a
baghouse prior to exhausting to the atmosphere. As a modification of the kiln, 40 CFR 60.62(a)(4)
requires an emission limit of 0.4 pounds of sulfur dioxide (SO2) per ton of clinker on a
30-operating day rolling average. [Last updated January 14, 2025]

10. BACT review regarding SO2, VOC, and Lead Sources cont.
VOC - Cement Kiln BACT
VOCs are generated by incomplete combustion in the kiln. 40 CFR 63 Subpart LLL - NESHAP
from the Portland Cement Industry limits total hydrocarbon and total organic HAP emissions to 24
and 12 ppmv at 7% oxygen. Ash Grove will achieve or exceed these emission limitations while
achieving BACT for the kiln operations. Ash Grove has reviewed the following sources to identify
available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028); and

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for VOC emissions from coal fired kiln operations are as follows:
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Process optimization,
Good combustion practices

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below.

1. Process Optimization Variable
2. Good Combustion Practices Variable

Step 4 - Evaluate Most Effective Controls and Document Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove optimizes the
kiln process by capturing waste heat from the clinker cooler and routing to a kiln preheater. Good
combustion practices also reduce VOC formation with the added benefit of energy efficiency.
There are no adverse energy, environmental or cost impacts to consider with the use of this control
technology.

Step 5 - Select BACT
BACT for control of VOC emissions from kiln operations shall consist of process optimization by
routing kiln heat to the preheater and good combustion practices. An emission limit of 24 ppmv
VOC @ 7% O2 is imposed by NESHAP Subpart LLL.

VOC - Grinding Aid BACT
A grinding aid containing VOC is added to the new finish mill to disperse particles within the mill
and expose more surface area to grinding. An increase in grinding aid usage proportionally
increases potential VOC emissions because volatiles from the grinding aid are not combusted in
the kiln.

There is only one identified control option for limiting the VOC emissions from the grinding aid.
Process optimization is technically feasible. VOC emissions are most effectively controlled by
optimizing the process. Ash Grove proposes to install a vertical finish mill with this project. Due to
the new modern mill's efficiency, it is anticipated that a reduced amount of grinding aid will be
required for each ton of clinker ground. Ash Grove estimates total VOC emissions from the
grinding aid at 2.37 tpy.

Lead Emissions
The lead emissions are anticipated to increase as a result of the proposed increase in clinker
throughput with the Leamington Plant upgrade project. Lead emissions result from residual
amounts of lead in raw materials and fuel. Lead emissions will be controlled the same as PM,
therefore a separate top-down BACT analysis has not been conducted as the Leamington Plant has
applied the most effective controls. [Last updated January 14, 2025]

11. BACT review regarding Greenhouse Gases
GHG Background
On October 9, 2009, the mandatory GHG reporting regulation, referred to as 40 CFR 98, was
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published in the Federal Register. Through 40 CFR 98, the U.S. EPA established the GHG
Reporting Rule, which requires the annual reporting of GHG data and other relevant information
from large sources and suppliers in the United States. Monitoring through the GHG Reporting
Program (GHGRP) began in 2010, with the first reports due by March 31, 2011. Per 40 CFR
98.2(a)(1), any facility associated with cement production is subject to the GHGRP and must report
CO2e emissions. The CO2e is the sum of equivalent GHG emissions from CO2, CH4, and N2O,
with their respective global warming potentials (GWP) applied. Ash Grove's facility is subject to
GHG Reporting Rule and monitors CO2 emissions from its kiln with a continuous emissions
monitoring system (CEMs). On June 23, 2014, the U.S. Supreme Court held that required PSD
permits (based on emissions of non-GHG pollutants) may continue to require limitations on GHG
emissions based on the application of BACT as an "anyway source". The Leamington Plant
modification project is a major source for PSD for both PM10 and PM2.5, and GHGs are estimated
to be greater than 75,000 tpy and greater than zero on a mass basis; therefore, GHGs are evaluated
for BACT as an anyway source.

Cement Manufacturing GHG BACT
A BACT analysis has been conducted for CO2e emissions from the kiln system. For this GHG
BACT analysis, various control technologies or combinations of technologies were identified using
the RACT/BACT/LAER Clearinghouse, available literature including guidance published by EPA
and South Coast Air Quality Management District (SCAQMD), current air regulations, other
regulatory organizations, and engineering experience. In March 2011, EPA published GHG
permitting guidance, as well as a white paper on available and emerging technologies for reducing
GHG emissions from the Portland cement industry in October 2010. Additionally, EPA published a
series of videos on GHG permit training in December 2010. The SCAQMD published GHG BACT
guidance in 2021. Additional sources of information were reviewed and documented based on
publications from trade organizations and other governmental committees with GHG or carbon
reduction guidelines and/or recommendations.

EPA has defined in 40 CFR 86.1818-12(a) GHGs as a group of six gases: CO2, nitrous oxide
(N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF6). GHG emissions from the kiln result from calcination and fuel combustion.
Since the primary GHG emitted by a kiln is CO2, the BACT analysis focuses on CO2 emissions
from the kiln. Emissions of CH4 and N2O are minimal from cement kilns. Per EPA guidance, GHG
control technologies for consideration in a BACT analysis for Portland Cement Manufacturing
include:

Source-wide energy efficiency strategies;
Raw material substitution;
Blended cements;
Carbon capture utilization and storage; and
Fuel switching.
Other emerging technologies [Last updated January 14, 2025]

12. BACT review regarding Greenhouse Gases cont.
Step 1: Identify All Control Technologies
The CO2 emissions from a cement kiln are generated by the calcination process (conversion of the
calcium carbonate in limestone to calcium oxide) and by combustion of fuel in the kiln. Potential
control technologies to reduce these CO2 emissions for a cement kiln are addressed in EPA's white
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paper on Available and Emerging Technologies for Reducing GHG Emissions from the Portland
Cement Industry.

These technologies fall into three categories:
Energy Efficiency Improvements for the Clinker Production Process
Fuel Substitution
Carbon Capture and Sequestration

Step 2: Eliminate Technically Infeasible Options
Several potential energy efficiency improvements are technically feasible: Pre-heater/Pre-calciner
Kiln Process, Kiln Seal Management Program, Refractory Selection (Kiln Insulation), and Energy
Recovery from the Clinker Cooler. The use of alternative fuels such as natural gas, whole tires and
biofuel) is also technically feasible. Other control options, such as Use of Fluxes and Mineralizers,
Heat Recovery for Power - Cogeneration, Carbon Sequestration, Oxyfuel combustion, and
Post-combustion Capture have been deemed infeasible.

Step 3: Rank Remaining Control Technologies by Control Effectiveness
All four remaining control techniques are currently implemented at the Leamington Plant. This
permitting project incorporates energy efficiency improvements. Ash Grove has had a fuel
substitution program in place for several years, and this program is continually reviewed and
updated as new sources and types of fuel are identified.

Step 4: Evaluate Most Effective Controls and Document Results
Since all technically feasible energy efficiency improvements and changes to product composition
will be implemented, this section will focus on economic and environmental considerations of fuel
substitution to operate exclusively on natural gas.

Firing natural gas as the primary kiln fuel can reduce CO2 emissions from fuel combustion by as
much as 40%. However, studies have shown that use of natural gas as primary kiln fuel can result
in three times more NOx emissions than NOx emissions from coal firing. Creating more NOx to
reduce GHG emissions is undesirable as it is a precursor to both ozone and PM2.5. Fuel substitution
essentially trades emissions of one regulated pollutant for another. Estimated capital cost to switch
to natural gas fuel exceeds $25M. Implementing natural gas technology would provide incremental
public health and welfare benefit globally by reducing CO2 emissions, while increasing NOx
emissions and negatively impacting public health and welfare locally. Switching fuels to another
fossil fuel has finite potential to mitigate CO2 emissions.

Step 5: Select BACT
In addition to the proposed energy efficiency improvements addressed elsewhere in this BACT
analysis, BACT is a limit of 0.92-ton CO2e/ton clinker. Ash Grove will use a continuous emission
monitoring system (CEMS) for CO2 to demonstrate compliance with this limit. [Last updated
January 14, 2025]

13. BACT review regarding Leamington Plant Upgrade Project conclusion
The control processes and techniques covered in this BACT analysis have been reviewed by the
NSR Section of the UDAQ. Ash Groves proposed controls and associated emission limitations
represent BACT. Any emission limitations not expressed in an associated NSPS or NESHAP will
be included in the terms and conditions of this AO. A listing of all associated NSPS and NESHAP
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programs is also included in the Source Information section of this document under Applicable
Federal Programs. [Last updated December 13, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date
of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
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proper credit when notifying the Director, send the documentation to the Director, attn.: NSR
Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.

II.A.3
NEW
Stockpiles
Coal storage
Area: 1 acre
Annual throughput 20,000 tpy

AF and ARM stockpiles
Area: 0.25 acre
Annual throughput 8,000 tpy

II.A.4 Stationary Crusher
Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction
of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000
acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)

II.A.5 Raw Material Transfer
Crushed material is transported to raw material storage by belt B8. The raw material transfers
at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor
transfer point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total
filter area & water sprays. (pre-1983)

II.A.6 Material Handling
Conveyor belt systems, secondary feeders and screens, stacker system

II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit specific requirements

II.A.8 Belt Conveyor Transfer Baghouse
Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area
and 1,800 acfm total air flow, controls emissions from the conveyor belt that transfers the
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stacked material to the raw material silos.

II.A.9 Raw Material Silos
Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The
four silos are equipped with one common Fuller, plenum pulse baghouse (315.BF1) - 1,689 ft2
filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage).

II.A.10 Fifth Component Silo
Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse
(315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw
mill feed. This system includes vibrating feeders, a conveyor system, and surge bin.
Emissions are controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3,
316.BF4, 316.BF5) - each is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1
A/C ratio.

II.A.12 Cross-Belt Analyzer
Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6)

II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom
of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw
materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38).
The following equipment is installed: low-NOx burner, selective non-catalytic reduction
(SNCR) for NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued
mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric
monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct
for mercury adsorption capacity. The carbon injection system is not an emission point as it is
in an enclosed building.

II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

II.A.16 Two Kiln Feed Blending Silos
Raw material is blended in one of two blending silos prior to feeding the kiln. The blending
silos are controlled by one common Fuller, plenum pulse baghouse (411.BF1) - 1,351 ft2 filter
area; 7,160 acfm total air flow.

II.A.17 Blending Silo Elevators (2)
Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped
with a Fuller, pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow
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through stack E34.

II.A.18 Kiln Feed Alleviator
A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the
central material silo between the blending silos and the preheater. Raw feed is removed from
the system near the top of the preheater tower.

II.A.19 Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner.
The coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter
area; 1,700 acfm total air flow.

II.A.20 Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in
the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2):
19,500 acfm rated airflow with 3.75:1 A/C ratio

II.A.21 Clinker Cooler and Baghouse
Reconstructed grate type cooler used for cooling clinker from the kiln prior to transfer to
clinker storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) -
173,869 acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter
monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two
clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse
(419.BF8). The exhaust is routed to the clinker cooler stack.

II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions
generated when loading the east and west clinker silos and the out-of-spec silo are controlled
by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1):
1,800 acfm, that discharges into the clinker tunnel.

II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm, that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2)
Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers.
Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses
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(511.HP1 and new 511.HP2): 1,800 acfm each.

II.A.27 Gypsum Silo
Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2
total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust
during loading.

II.A.28 Clinker Tunnel Exitway
The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse
(511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel all discharge in the clinker tunnel.
Emissions are vented through the tunnel exitway.

II.A.29 Limestone Silo
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust
during loading. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement product. Dust
generated during milling is captured by a BHA, pulse jet baghouse (514.BF2) - 6,080 ft2 filter
area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding
stack).

II.A.31 Finish Mill (Ball Mill) Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized
cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA, pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow
controlling particulates from stack G55 (finish mill stack).

II.A.32
NEW
Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The
stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4)
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1,
525.BF1 thru 3)

II.A.33 Finish Cement Storage Silos
There are six storage and two interstice silos where the finished cement product is stored. A
single common Fuller, plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm
total air flow through stack H7 is located on top of the silos and is used to control emissions
during loading and unloading operations.

II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail
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shipping. This baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out
The cement loadout system located on the South side of the silos (truck load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF2) during unloading from the silos for truck
shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement
conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed
space inside the silos.

II.A.36
NEW
Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

II.A.37 MHO: Materials Handling Operation
Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1
& 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4;
512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.

II.A.38 LBS: Limestone Bypass System
Additional limestone is added to the clinker and gypsum by the limestone bypass system
(LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays
at the screen and material handling drop points.

II.A.39 GEN: Emergency Generators
One diesel-fired emergency generator (new)
Rating: 762 hp
(Kiln, Tier 3, permitted 2022)

Two natural gas-fired emergency generators
Rating: 304 hp
(Main office and control room, permitted in 2023)

One diesel-fired emergency generator
Rating: 560 hp
(Shipping, permitted 2023).

II.A.40 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14 inch knife gate, 8 inch knife gate, 8 inch air
slides, surge bin), and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm)
on the fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

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II.A.41
NEW
Miscellaneous Storage Tanks
One diesel storage tank (<2,000 gallons)
One gasoline storage tank (500 gallons)
Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Requirements on the Cement Plant:
II.B.1.a
NEW
The following limits shall not be exceeded:

A. Clinker production - 1,155,000 tons per rolling 12-month period

B. Used oil consumption - 85,724 gallons per rolling 12-month period

C. Limestone bypass material processed - 216,260 tons per rolling 12-month period.
[R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 25th day of each month using data from the previous 12 months.
Records shall be kept for all periods when the plant is in operation. Consumption and
production shall be calculated through use of the plant's acquisition system. [R307-401-8]

II.B.1.b
NEW
Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations:

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

SO2: 0.4 lbs per ton of clinker (3-hr average)

CO: 3,395 tons per rolling 12-month period, and 6,600 lbs/hr

NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average, and 1,233 tons per rolling
12-month period

Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is
400oF or less.

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Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)

THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)

CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)

PM: 0.02 lbs filterable PM per ton of clinker. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL,
R307-401-8]

II.B.1.c
NEW
A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR
60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust
emissions control plan shall be monitored to demonstrate that appropriate control measures are
being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of
the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall
be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in
the plan and that the source is operating in accordance with the submitted plan. For petitions
to approve alternative control measures, the permittee shall keep a copy of the submitted
petition and any approvals received. [40 CFR 60 Subpart Y]

II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area
source of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2). [40 CFR
63 Subpart LLL]

II.B.1.e
NEW
Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b
and II.B.1.d shall be performed as specified below:

A. Kiln/Raw Mill Stack
Pollutant Test Status Test Frequency
PM * #

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

B. Clinker Cooler (F31)
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Pollutant Test Status Test Frequency
PM + #

C. Testing Status (To be applied above)
* The initial testing has already been performed.

** The SO2 initial performance test was conducted on August 26, 2013.

*** The initial compliance test shall be conducted within the first 30 operating days of
operation in which the affected source operates using a CEMS.

# Test once every year. If performance testing would be required less than 15 operating days
after the Kiln has completed Startup after being down for more than 24 hours, then
performance testing may be deferred up to 15 operating days after completion of the Startup.
The Director may require testing at any time.

## Test at least once every two years. The Director may require testing at any time.

+ Initial testing is required within 180 days of startup of the reconstructed equipment

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must record the PM
CPMS output data for all periods when the process is operating, and use all the PM CPMS
data for calculations when the PM CPMS is not out-of-control. The owner/operator must
demonstrate continuous compliance by using all quality-assured hourly average data collected
by the PM CPMS for all operating hours to calculate the arithmetic average operating
parameter in units of the operating limit on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

+++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.e.1
NEW
Notification
The Director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The notification requirements for performance tests subject to 40
CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-165]

II.B.1.e.2
NEW
Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational
Safety and Health Administration (OSHA)- or Mine Safety and Health Administration
(MSHA)-approved access shall be provided to the test location. [R307-165]

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II.B.1.e.4
NEW
PM
40 CFR 60, Appendix A, Method 5 or 5I or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three (3) runs with
each run at least 120 minutes in duration and each run collecting a sample of 60 dry standard
cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.3
NEW
Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2. [R307-165]

II.B.1.e.5
NEW
Carbon Monoxide (CO)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.6
NEW
Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.7
NEW
Sulfur Dioxide (SO2)
40 CFR 60, Method 6 or 6C of Appendix A-4 or other EPA-approved method as acceptable to
the Director. [R307-165]

II.B.1.e.8
NEW
Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]

II.B.1.e.9
NEW
Total Hydrocarbons (THC)
Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL]

II.B.1.e.10
NEW
Mercury (Hg)
Continuous Emission or integrated sorbent trap monitoring (See Condition II.B.3.a). [40 CFR
63 Subpart LLL]

II.B.1.e.11
NEW
HCl
Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other
EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]

II.B.1.e.12
NEW
Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.13
NEW
Calculations
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director, to give the results in the specified units of the
emission limitation. [R307-165]

II.B.1.e.14
NEW
Existing Source Operation
For an existing source/emission point, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three years.
[R307-165]

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II.B.1.e.15
NEW
New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the maximum production rate listed in this AO. If the maximum AO
allowable production rate has not been achieved at the time of the test, the following
procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This new
allowable maximum production rate shall remain in effect until successfully tested at a higher
rate.

3) The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate (110%
of the new rate) will then be allowed if the test is successful. This process may be repeated
until the maximum AO production rate is achieved. [R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL.
[40 CFR 63 Subpart LLL]

II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times
of Dust Shuttle System operation to assist in the capture of Mercury emission. [R307-401-8]

II.B.1.h
NEW
Visible emissions from the following emission points shall not exceed the following values:

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

L. All baghouses - 10% opacity
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M. Fugitive dust - 20% opacity

N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y,
R307-401-8]

II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer
point is not required to conduct Method 22 visible emissions monitoring under this paragraph.
The enclosures for these transfer points must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

If any partially enclosed or unenclosed conveying system transfer point is located in a
building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to
40 CFR 60, according to the following:

(i) The owner/operator must conduct a monthly ten-minute visible emissions test of each
affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The
performance test must be conducted while the affected source is in operation.

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator may decrease the frequency of performance testing from monthly
to semi-annually for that affected source. If visible emissions are observed during any
semi-annual test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iii) If no visible emissions are observed during the semi-annual test for any affected source,
the owner/operator may decrease the frequency of performance testing from semi- annually to
annually for that affected source. If visible emissions are observed during any annual
performance test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iv) If visible emissions are observed during any Method 22 performance test, of Appendix
A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations,
recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60.
The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour
of any observation of visible emissions.

(v) If visible emissions from a building are monitored, the requirements of paragraphs (i)
through (iv) of this Condition apply to the monitoring of the building, and the owner/operator
must also test visible emissions from each side, roof, and vent of the building for at least ten
minutes. [R307-401]

II.B.1.j
NEW
Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed
0.005 gr/dscf:

520.BF1
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520.BF2
520.BF3
520.BF4
521.BF2
521.BF1
524.BF1
524.BF2
524.BF4
524.BF3
525.BF1
525.BF2
525.BF3
511.HP2
NRL_UPR
NRL_LWR. [R307-401-8]

II.B.1.j.1
NEW
To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration
through at least three (3) annual tests that the PM limits are not being exceeded, the
owner/operator may request approval from the Director to conduct stack testing less
frequently than annually. [R307-401-8]

II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive
dusts as dry conditions warrant or as determined necessary by the Director to maintain opacity
limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated to control fugitive dust. The application of
water or chemical treatment shall be used. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a damp/moist condition unless it is below freezing.
If chemical treatment is to be used, the plan must be approved by the Director. Records of
water and/or chemical treatment shall be kept for all periods when the plant is in operation.
The records shall include the following items: Instances of water and/or chemical application
to unpaved areas shall be recorded and maintained by the owner/operator. The ambient
temperature shall be recorded any time water should be applied but cannot due to freezing
conditions. [R307-401-8]

II.B.2.c
NEW
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

The sprays shall operate whenever dry conditions warrant meeting the required opacity
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limitations or as determined necessary by the Director. Water sprays shall not be required
during periods of freezing temperatures. [R307-401-8]

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation
of fugitive dusts as dry conditions warrant or as determined necessary by the Director.
[R307-401-8]

II.B.2.e
NEW
The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5
PM. [R307-401-8]

II.B.3 Continuous Emission Monitoring Requirements:
II.B.3.a
NEW
The owner/operator shall install, calibrate, maintain and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler.

A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the
missing data substitution procedures used by the UDAQ or the missing data substitution
procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate by the UDAQ.

B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period
including during each startup, shutdown, or malfunction.

C. The monitoring system shall comply with all applicable sections of R307-170, UAC; and
40 CFR 60, Appendix B.

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be
installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the
kiln/raw mill stack.

F. The owner/operator shall record the output of the system: including the quantity of NOx,
CO, O2 THC, Hg, HCl, and CO2 emissions at the kiln stack.

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source shall
continuously operate all required continuous monitoring devices and shall meet minimum
frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker
cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except
during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments,
the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a
PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the
results of the performance test demonstrating compliance with the filterable PM limit and
using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust
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the SSOL developed in accordance with the results of the most recent PM performance test
demonstrating compliance with the PM emission limit. The owner/operator shall use the PM
CPMS to demonstrate continuous compliance with the SSOL in accordance with the
requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

II.B.4 Fuel Limitations:
II.B.4.a
NEW
The owner/operator shall use only the following fuels in the kiln and pre-calciner:

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.

If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b
NEW
Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the
Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the
results of suitable tests giving data similar to a Proximate and Ultimate analysis of the
proposed coal additive. [R307-401-8]

II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal
additive. Approval is not required to change from one previously-approved coal additive to
another previously-approved coal additive. [R307-401-8]

II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily
heat input of the kiln and precalciner. The owner/operator may increase the average quantity
of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon
approval by the Director in accordance with the approval process described in Condition
II.B.4.b. [R307-401-8]

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II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel burning or process
installation not covered by New Source Performance Standards for sulfur emissions or
covered elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross
Btu heat input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input
for any oil except used oil. The sulfur content shall comply with all applicable sections of
UAC R307-203. [R307-203, R307-401-8]

II.B.4.c.1
NEW
Certification of fuels shall be either by the owner/operator's own testing or test reports from
the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be
available onsite. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials, UAC R307-203-1 (4)

A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be
used.

B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be
used.

C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85 are to be used. [R307-203]

II.B.4.d
NEW
The concentration/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight
3) Cadmium 2 ppm by weight
4) Chromium. 10 ppm by weight
5) Lead 100 ppm by weight
6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be
tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the burn tank and burned. [R307-401-8]

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II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned
in the rotary kiln:

A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than
five minutes in any 60-minute period

B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes
in any 60-minute period. [R307-401-8]

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the
Director. The calibration procedure and frequency shall be according to manufacturer's
specifications. Use of factory-calibrated thermocouples for temperature measurement is
approved. However, any other method of temperature measurement must be approved by the
Director prior to use. The monitoring equipment for both temperature and oxygen content
shall be located such that an inspector can at any time safely read the output. [R307-401-8]

II.B.5
NEW
Emergency Engine Requirements
II.B.5.a
NEW
The owner/operator shall only operate the emergency engines for testing and maintenance
purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency
operation. [R307-401-8]

II.B.5.b
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each emergency engine. [R307-401-8]

II.B.5.b.1
NEW
The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.5.b.2
NEW
To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN103030035-24 dated November 27, 2024
Is Derived From Source Submitted NOI dated November 30, 2022
Incorporates Additional Information Received dated April 26, 2023
Incorporates Additional Information Received dated September 26, 2023
Incorporates Additional Information Received dated July 23, 2024
Incorporates Additional Information Received dated October 25, 2024
Incorporates Additional Information Received dated November 25, 2024

REVIEWER COMMENTS

1. Comment regarding applicability of federal requirements:
New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable
by the best demonstrated technology as specified in the applicable provisions. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.

40 CFR 60, Subpart A (General Provisions)
All affected facilities subject to a source-specific NSPS are subject to the general provisions of
NSPS, Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires
initial notification, performance testing, recordkeeping, and monitoring, provides reference methods,
and mandates general control device requirements for all other subparts.

40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of
performance for affected facilities in Portland Cement Plants which have been constructed or
modified after August 17, 1971.

40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart
F: Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and
unloading systems. The Leamington coal mill is an in-line coal mill and considered an integral part
of the Leamington kiln. In-line coal mills are not subject to NSPS Subpart Y. Therefore, the coal mill
is addressed under NSPS Subpart F as part of the kiln system. The coal silos and conveying system
are subject to NSPS Subpart Y.

Ash Grove's proposed changes to the kiln system must be evaluated as to whether they trigger new
NSPS Subpart F obligations based on whether the proposed project is either a modification or a
reconstruction, as those terms are defined in NSPS Subpart A.

Ash Grove's proposed changes to the kiln system do not meet the definition of a reconstruction, nor
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Page 40

do they meet the definition of a modification for NOx. However, the changes meet the definition of a
modification for PM and SO2. Therefore, Ash Grove will comply with all relevant emission
standards; testing requirements; monitoring, recordkeeping, and reporting obligations that apply to
the Leamington kiln system as an existing source under NSPS Subpart F. Under NSPS Subpart A
and F, the clinker cooler is considered a reconstructed unit. Thus new limits will apply to this unit.
[Last updated January 14, 2025]

2. Comment regarding applicability of federal requirements cont.:
NSPS Subpart Y - Standards of Performance for Coal Preparation and Processing Plants
This subpart provides standards of performance for affected facilities in coal preparation and
processing plants that process more than 200 tons of coal per day.

The Leamington plant's coal silo and coal conveying system are existing affected facilities under
NSPS Subpart Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses
controlling affected facilities subject to match the limit in NSPS Subpart Y from 0.016 gr/dscf to
0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade Project. Since there are no proposed
modifications or reconstruction to the coal silo and coal conveying system, nothing about the
proposed upgrade project affects the existing applicability of NSPS Subpart Y.

NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
This subpart provides standards of performance for affected facilities located at fixed or portable
nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August
31, 1983, with additional requirements applicable to sources constructed on or after April 22, 2008.

As the crushing and screening system is controlled by baghouses and an increase in PM10 actual
emissions on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS.
Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the
Leamington Plant Upgrade Project.

Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1),
60.676(f), and 60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO
monitoring and recordkeeping requirements.

[Last updated January 14, 2025]

3. Comment regarding applicability of federal requirements cont.:
National Emission Standards for Hazardous Pollutants (NESHAPs)
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or
greater than 10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as
specified by each subpart. NESHAP apply to sources in specifically regulated industrial source
classifications (CAA Section 112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities
not regulated as a specific industrial source type. The Ash Grove Leamington Plant is a major source
of HAPs and thus is subject to certain NESHAP standards.

Subpart A - General Provisions
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All affected sources are subject to the general provisions of Subpart A unless otherwise specified by
the source-specific NESHAP. Subpart A generally requires initial notification and performance
testing, recordkeeping, monitoring, provides reference methods, and mandates general control device
requirements for all other subparts as applicable.

Subpart LLL - Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry
This subpart establishes process/source specific emission limits for PM, VOC (expressed as total
hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and
gaseous HAP compounds by limiting PM and THC emissions because portions of such emissions
are USEPA-listed HAPs. Subpart LLL requires compliance with applicable emissions limits on and
after the initial startup of cement production. To further reduce emissions, Subpart LLL also
establishes operational requirements for the use of cement kiln dust (CKD), fly ash, fuel and control
equipment. Subpart LLL also specifies process/source specific emissions testing, monitoring,
recordkeeping, reporting, and compliance demonstration requirements. The compliance requirements
for the site are detailed in Approval Order Condition II.B.1.b. Ash Grove will continue to comply
with the requirements of Subpart LLL to demonstrate compliance. This cement kiln will remain an
existing source with respect to the kiln emission standards in Subpart LLL as this project does not
trigger the definition of a new source in Subpart LLL. New source standards apply only to affected
sources that were constructed or reconstructed after May 6, 2009.
[Last updated December 20, 2024]

4. Comment regarding PSD applicability analysis:
Ash Grove is proposing to increase the throughput of limestone from the quarry to supply the New
Finish Mill to increase the amount of low-carbon cement from the Leamington Plant. Additionally,
along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
modified, and the clinker cooler will be reconstructed. These changes are anticipated to result in an
increase in clinker production. Emission calculations for this project have been completed assuming
an increase in clinker production capacity while utilizing current fuel types. This will result in an
increase in the throughput of fuel.

The Leamington Plant is considered an existing major source under PSD based on potential
emissions of PM10, PM2.5, NOx, CO, SO2, and CO2e. If a major source undergoes a physical or
operational change, the facility must determine whether the project will be considered a major
modification. Per 40 CFR 52.21(b)(2)(i), in order to be a major modification, the project must result
in a significant emissions increase, and a significant net emissions increase.

As defined at 40 CFR 52.21(b)(40): Significant emissions increase means, for a regulated NSR
pollutant, an increase in emissions that is significant for that pollutant. Significant is further defined
to mean, in reference to a net emissions increase or the potential of a source to emit any of the
following pollutants, a rate of emissions that would equal or exceed the values outlined in 40 CFR
52.21(b)(23). If the increase in emissions from the project are not significant, a major modification
has not occurred.

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
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increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

For all pollutants, the project emissions increase was calculated as the difference between the
projected actual emissions (PAE) after the proposed project and the actual emissions prior to the
project (baseline actual emissions or BAE).

Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
". . . projected actual emissions means the maximum annual rate, in tons per year, at which an
existing emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years
(12-month period) following the date the unit resumes regular operation after the project, or in any
one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit of that regulated NSR pollutant and full utilization of the unit would
result in a significant emissions increase or a significant net emissions increase at the major
stationary source." [Last updated January 14, 2025]

5. Comment regarding PSD applicability analysis cont.:
Ash Grove estimates that the projected actual production capacity following the project will be
1,155,000 tons of clinker per year and 1,341,266 tons of limestone per year. These capacities were
used to calculate projected actual emissions from the project using representative emission factors.
Additionally, to estimate emissions from material transfer baghouses, the actual flow rates and actual
projected hours were used as a basis for projected actual emissions.

Project Emission Calculations

Project emission increases from the kiln and coal mill systems are calculated for all criteria
pollutants based on emission factors that are derived from stack testing, CEMS data, or emission
factors (i.e., VOCs and Lead), and the associated projected incremental clinker increase.

NOx emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain
hourly capacity to emit and annual potential to emit at current levels. The kiln's NOx emissions rate
will not change as a result of the physical modifications proposed by the project.

Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission
factor and multiplied by the incremental increase in clinker production. The emission factor was
selected based on the average of the 24-month consecutive month emissions for 2020 and 2021. The
CO emissions will increase.

The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing
conducted at the plant. The SO2 emissions will increase.

VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production. VOC emissions will increase.

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 43

can be found in the original NOI and subsequent addendums submitted to UDAQ.

As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from
the proposed project, each increase of emissions from both existing and new sources shall be
summed together and compared to the PSD permitting thresholds. The increase of emissions is the
"positive" difference between the projected actual emissions and baseline actual emissions (projected
minus baseline).

New Emissions Sources

The actual to projected actuals calculation is not available to new emission units. For new emission
units, the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected
emissions are based on the new sources' potentials to emit. (40 CFR § 52.21(a)(2)(iv)(f)).

The new equipment proposed includes the New Finish Mill, a new rail and truck loading/loadout,
one (1) new clinker reclaim loading hopper with a dust collector and one (1) existing clinker reclaim
hopper with a dust collector, a new Clinker Cooler to replace the existing one, and a new kiln feed
alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions:

The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;

The finish mill heater was calculated based on its maximum firing capacity and flow rates; and

The fugitive emissions were calculated based on the projected annual throughput of the New Finish
Mill, the rail loadout, and clinker production. [Last updated January 14, 2025]

6. Comment regarding PSD applicability analysis cont.:
Existing Emission Sources

For the existing sources, the projected actual emissions are the maximum annual rates in tons per
year projected to occur during the next five (5) to ten (10) years if the existing sources' design
capacities increase. Ash Grove Leamington projected the actual emissions for the next five (5) years
based on the new kiln system producing an annual average of 3,250 tons of clinker per day.

Baseline actual emissions (BAE) are defined at 40 CFR 52.21(b)(48)(ii) as:

". . . baseline actual emissions means the average rate, in tons per year, at which the emissions unit
actually emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the 10-year period immediately preceding either the date the owner or operator
begins actual construction of the project, or the date a complete permit application is received by the
Administrator."

Ash Grove has selected to use the years 2020 and 2021 for each pollutant as the representative
baseline years.

In its NOI, Ash Grove calculated the emission increase from the project as being divided into two
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 44

phases. Phased construction projects are discussed in two sections of the federal PSD regulations -
40 CFR 52.21(j)(4) and 40 CFr 52.21(r)(2). UDAQ is not processing this project as a phased
construction project, nor did Ash Grove request such a determination. Therefore, Ash Grove
provided a summary table outlining the final change in emissions from this project:

Projected Actual Increase Compared to PSD threshold (tons per year)
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2e
BAE 76.64 39.64 1,187 6.87 3,315 55.47 641,385
PAE 203.15 113.47 1,226 45.87 3,414 72.07 1,067,984

Change in Emissions 126.51 73.83 39.00 39.00 99.00 16.59 426,598

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes

If the emissions increase is greater than the PSD significance threshold for a particular pollutant, Ash
Grove has the option of conducting a PSD review or continuing through the rest of the steps to
determine if it can "net" out of a PSD review. If the project increase is less than the PSD significant
threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant.

The change in emissions from the project exceeds the significant emission threshold for three
pollutants: PM10, PM2.5 and CO2e. Ash Grove elected to attempt to net out of a PSD major
modification for the remainder of the criteria pollutants.

Netting

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant
Upgrade Project and ends on the date the upgrade begins operation. Only PM10, PM2.5, CO2e are in
excess of SERs and therefore considered in the netting analysis.

Ash Grove estimated that the commencement of construction will be in December 2024. Therefore,
the contemporaneous period for this project is December 2019 through a projected date the project
upgrade begins operation. [Last updated January 21, 2025]

7. Comment regarding PSD applicability analysis cont.:
Contemporaneous Decreases

Ash Grove replaced an existing kiln emergency drive engine with a USEPA Tier 4 diesel engine in
2022. Concurrently, Ash Grove requested an increase in the capacity of 1L Cement. Additionally,
Ash Grove submitted a minor modification NOI air permit application on June 12, 2023, which
proposes replacing the shipping generator during the contemporaneous period. The kiln emergency
drive engine and shipping generator are both higher EPA tier ratings therefore result in decreases for
PM10 and PM2.5. These changes were approved in AO DAQE-AN103030033-24 issued March 21,
2024.

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Page 45

Contemporaneous Increases

As stated above, the existing kiln emergency drive engine and shipping generator were permitted and
replaced in 2024. This resulted in an increase in emissions of CO2e.

The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout
in an effort to improve truck traffic at the loadout. The modification to add these dust collectors to
the loadout was included in DAQE-AN103030029-19. The baghouses are three (3) levels up in the
silos' enclosed space (approximately 40 feet). Both dust collectors vent directly into the interior of
the silo structure and are not vented into the atmosphere. Ash Grove requests to remove these
baghouses from its existing permitted emissions inventory. Therefore, these emissions have been
documented in the netting analysis as zero emissions.

Also included in DAQE-AN103030033-24 were two new natural gas-fired emergency generators
and increases in stockpiles, material handling and road emissions.

Could Have Been Accommodated Emissions

In calculating project emissions increase, USEPA allows the exclusion of existing
production/emissions rates that could have been accommodated during the baseline period. These
"could have been accommodated" emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as
follows:

". . . Shall exclude, in calculating any increase in emissions that results from the particular project,
that portion of the unit's emissions following the project that an existing unit could have
accommodated during the consecutive 24-month period used to establish the baseline actual
emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project,
including any increased utilization due to product demand growth;"

Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the
exclusion of existing production and emissions rates that could have been accommodated during the
baseline period, it has elected not to use this exclusion at this time. Therefore, calculation of the
"could have been" accommodated emissions have not been included in this application's
applicability analysis.

The increase from the project is added to the contemporaneous decreases and contemporaneous
increases. The resulting calculation is then compared to the PSD significance threshold to determine
if a significant net emissions increase has occurred. [Last updated January 14, 2025]

8. Comment regarding PSD applicability analysis cont.:
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2 e
Contemporaneous Inc. 1.61 0.45 0.41 0 0.27 0.07 51.74

Contemporaneous Dec. -1.54 -3.97 -0.48 -0.02 -0.27 -0.09 0

Change in Emissions 125.02 69.21 38.93 38.98 99.00 16.58 426,650

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes
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Page 46

The results of the netting analysis conclude that both a significant emissions increase and a
significant net emissions increase in both particulates (PM10 and PM2.5) and CO2e will occur from
this project. Thus, the project must be reviewed as a PSD major modification. [Last updated January
14, 2025]

9. Comment regarding emission calculations:
This engineering review includes updated potential emission totals for both criteria and HAP
emissions. The potential-to-emit (PTE) values were calculated using updated values for clinker
produced and raw material inputs. BACT emission factors and limitations were used where
appropriate. Certain emission totals (NOx, SO2 and CO) were set based on avoiding a significant
increase in emissions. Specifically, the projected actual increase was set at just under the baseline
actual emissions + the significance level. As these emissions are monitored by CEM, UDAQ agrees
with this approach. Please see the netting analysis for further details on calculation of projected
actual increase. The NOx hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project.

CO2e emissions were calculated using the GHG emission factor calculated from 40 CFR Part 98
Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in Subpart A Table
A-1.

To calculate the PTE tons per year, the maximum hours (i.e., 8760) per year and the source's
emissions rates were multiplied with the throughputs. The potential throughputs have been updated
at UDAQ's request so that PAE is equal to PTE and represents the equipment's maximum design
potential.

Additional emission calculations based on source testing and monitoring, and EPA's compilation of
air emission factors AP-42. [Last updated January 14, 2025]

10. Comment regarding requirements for PSD review:
In addition to the permitting requirements of R307-401-5 through R307-401-8, there are additional
requirements under PSD that must be addressed:

1. Calculation of ambient air increments (40 CFR 52.12(c)), ambient air ceilings ((40 CFR 52.12(d)),
source impact analysis (40 CFR 52.12(k)), air quality models (40 CFR 52.12(l)) - these items are
addressed in the modeling memo DAQE-MN103030032-24.

2. Stack heights (40 CFR 52.12(h)) - Ash Grove's stack heights have been reviewed with respect to
good engineering practice and operate in a vertical unrestricted manner.

3. Control technology review (40 CFR 52.12(j)) - this is addressed in the BACT analysis section of
this review document.

4. Air quality analysis: preapplication analysis (40 CFR 52.12(m)) - this is covered in the PSD
applicability and netting analysis sections of this review document, ambient monitoring and
background data collection is also included in the modeling memo DAQE-MN103030032-24.

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 47

grain loading limit included in II.B.1.j.1 represents the required post-construction monitoring.
6. Source information (40 CFR 52.12(n)) - this is addressed under the requirements of R307-401-5
and was submitted by Ash Grove as part of the NOI package.

7. Additional impact analysis (40 CFR 52.12(o)) - these requirements cover soils, vegetation, growth
and visibility concerns. They are discussed in the modeling memo DAQE-MN103030032-24.

8. Federal land manager review (40 CFR 52.12(p)) - UDAQ provided initial notification to all
federal land managers upon receipt of the original NOI package. The draft permit and engineering
review will also be provided to the federal land managers 60-days prior to initiation of public
comment for their further review.

9. Public participation (40 CFR 52.12(q)) - this project will have a 30-day public comment period.

10. Source obligation (40 CFR 52.12(r)) - this requirement discusses source compliance with other
parts of the CAA, which is addressed within UDAQ's permitting rules in R307.
[Last updated January 14, 2025]

11. Comment regarding changes in equipment list:
The equipment list is being updated for clarity as well as adding new pieces of equipment. The
following changes are taking place:

The naming scheme is being updated to remove the numerical code from the unit designation. This
code generally referred to the associated control device and not to the emitting unit itself. This can
cause confusion especially when the same code was applied to multiple pieces of equipment.
Instead, the control devices (typically baghouse dust collectors) will be identified in the description
along with the appropriate numerical code.

Specific changes are as follows:

1. The kiln description has been updated

2. Clinker Cooler description has been updated to include a larger pulse jet baghouse.

3. The clinker storage silos, east and west clinker belts, clinker belt transfer and clinker tunnel have
been consolidated to avoid confusion

4. The north and south cement loadout exhausts now vent internally into the cement storage silos

5. The dust shuttle system has been consolidated into one line item, most identifiers removed from
subsystem descriptions as only two baghouses serve as exhaust points.

6. A new finish mill with heater has been added. Included in the description are the thirteen total
baghouses for dust control (1 main stack, 2 transfer points, 10 nuisance dust filters)

7. A new clinker reclaim hopper has been added. Both reclaim hoppers are controlled by baghouses
with updated identifiers

8. A new rail and truck loading/unloading system with two baghouses has been added.
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Page 48

[Last updated December 20, 2024]

12. Comment regarding changes in conditions:
As a result of this project, several conditions will be added or changed. This includes one new
general condition (I.8). Changes to the equipment list (section II.A) will be addressed in a separate
reviewer comment:

I.8 - Adding this general condition to cover the requirements of R307-401-18 Eighteen Month
Review. The status of construction/installation of the new equipment shall be reviewed after
18-months.

II.B.1.a - Clinker production increases to 1,155,000 tpy
Use of limestone bypass material increases to 215,260 tpy

II.B.1.b - The NOx limit on the kiln decreases to 1,223 tpy, CO emissions from the kiln decrease to
3,395 tpy,
Adding a new CO2e limit of 0.92 tons CO2e/ton of clinker produced
PM limit on the clinker cooler decreased to 0.02 lb PM (filterable)/ton of clinker
Rule reference updated to include 40 CFR 60 Subpart F, and R307-401-8

II.B.1.e - Initial testing on the clinker cooler is now required within 180 days of startup of the unit.
Monitoring of CO2 from the kiln will be by CEM.
Formatting changes on paragraph designated ++, improve clarity, include reference to CO2
monitoring, define CPMS

II.B.1.e.4 - Update to address general PM monitoring and reference R307-401-8

II.B.1.e.14 - New condition to address new or reconstructed emission units monitoring requirements,
applicable to the clinker cooler and new finish mill.

II.B.1.h - Adding references to Subpart OOO units (limestone processing) with updated opacity
limits.
Adding 20% opacity limit on coal transfer and storage
Adding property boundary opacity limit of 20%
Updating rule reference to include Subpart OOO

II.B.1.j - New condition to address outlet grain loading limits on new baghouses, One identical limit,
15 total new baghouses.

II.B.1.j.1 - Monitoring on new baghouses as per II.B.1.e.4, added an allowance to test less frequently
than annually with three successful tests.

II.B.3.a - Updating formatting to add clarity and include reference to CO2 CEM

II.B.5 - New conditions on emergency engines, diesel fuel sulfur limits, hour of operation
restrictions, non resettable hour meter

[Last updated December 20, 2024]
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 49

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 50

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 51

TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 52

DAQE-IN103030032-25

January 22, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Mr. Nelson:

Re: Intent to Approve: Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — ) A A v A ? A D @ A w D D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — ) A A v A ? A D @ A w D D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ash Grove Cement Company Ash Grove Cement Company - Leamington Cement Plant

Mailing Address Physical Address
P.O. Box 38069 Highway 132
Leamington, UT 84638 Leamington, UT 84638

Source Contact UTM Coordinates
Name: Cody Watkins 397000 m Easting
Phone: [phone] 4380100 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3241 (Cement, Hydraulic)

SOURCE INFORMATION
General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried on site),
are correctly proportioned, ground, and mixed and then fed into a rotating kiln. The kiln alters the
materials and recombines them into small stones called cement clinker. The clinker is cooled and ground
with gypsum and additional limestone into a fine powdered cement. The final product is stored on site for
later shipping. The major sources of air emissions are from the combustion of fuels for the kiln operation,
from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source of
emissions of PM2.5, PM10, NOx, CO, HAPs, and GHG. It is a minor source of SO2 emissions.
NSR Classification
Major PSD Modification

Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
DAQE-IN103030032-25
Page 4

Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

These changes result in increases in actual emissions but decreases in most potential emissions. There will
be an increase in the potential emissions of VOCs and greenhouse gases.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
DAQE-IN103030032-25
Page 5

Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
DAQE-IN103030032-25
Page 6

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
DAQE-IN103030032-25
Page 7

II.A.4 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)
II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area, and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, stacker systems. II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit-specific requirements.
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total air flow controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter
area; 9,865 acfm total air flow, controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are
controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each
is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6). II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The
following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for
NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.
II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low-pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

DAQE-IN103030032-25
Page 8

II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow through stack
E34.
II.A.18 Kiln Feed Alleviator A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the central material silo between the blending silos and the preheater. Raw feed is removed from the system near the top of the preheater tower.
II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The
coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter area;
1,700 acfm total air flow.
II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker
storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1): 1,800 acfm that discharges into the clinker tunnel.
II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
DAQE-IN103030032-25
Page 9

II.A.27 Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during loading.
II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel, all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during loading. 512.BF3 (1,000 acfm) is located on top of the silo. II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement products. Dust generated
during milling is captured by a BHA pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).

II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates from stack G55 (finish mill stack).
II.A.32 Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4).
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1 thru 3).

II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total air flow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations.
II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This
baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

DAQE-IN103030032-25
Page 10

II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.
II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023)
II.A.40 Dust Shuttle System A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides, surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the
fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

II.A.41 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons) Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
DAQE-IN103030032-25
Page 11

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)
THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)
CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)
PM: 0.02 lbs filterable PM per ton of clinker.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR 60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to approve alternative control measures, the permittee shall keep a copy of the submitted petition and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source
of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2).
[40 CFR 63 Subpart LLL]

DAQE-IN103030032-25
Page 12

II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must record the PM CPMS output data for all periods when the process is operating and use all the PM CPMS data for calculations when the PM CPMS is not out of control. The owner/operator must demonstrate continuous compliance by using all quality-assured hourly average data collected by the PM CPMS for all operating hours to calculate the arithmetic average operating parameter in units of the operating limit on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
DAQE-IN103030032-25
Page 13

II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

II.B.1.e.3 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-165]
II.B.1.e.4 PM 40 CFR 60, Appendix A, Method 5, or 5I, or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three runs, with each
run at least 120 minutes in duration and each run collecting a sample of 60 dry standard cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165]
DAQE-IN103030032-25
Page 14

II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
DAQE-IN103030032-25
Page 15

II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
DAQE-IN103030032-25
Page 16

II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer point, is not required to conduct Method 22 visible emissions monitoring under this paragraph. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator may decrease the frequency of performance testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
DAQE-IN103030032-25
Page 17

II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: Instances of water and/or chemical application to unpaved areas shall be recorded and maintained by the owner/operator. The ambient temperature shall be recorded any time water should be applied but cannot due to freezing conditions. [R307-401-8]
II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

The sprays shall operate whenever dry conditions warrant meeting the required opacity
limitations or as determined necessary by the Director. Water sprays shall not be required during
periods of freezing temperatures.

[R307-401-8]

DAQE-IN103030032-25
Page 18

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

C. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the kiln/raw mill stack

F. The owner/operator shall record the output of the system: including the quantity of NOx, CO, O2, THC, Hg, HCl, and CO2 emissions at the kiln stack

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an
affected source shall continuously operate all required continuous monitoring devices
and shall meet minimum frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.

[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]
II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments, the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the results of the performance test demonstrating compliance with the filterable PM limit and using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust the SSOL developed in accordance with the results of the most recent PM performance test demonstrating compliance with the PM emission limit. The owner/operator shall use the PM CPMS to demonstrate continuous compliance with the SSOL in accordance with the requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

DAQE-IN103030032-25
Page 19

II.B.4 Fuel Limitations: II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke F. Fuel Oil
G. Used Oil Fuel

H. Synthetic Fuel
I. Wood
J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal additive.
Approval is not required to change from one previously approved coal additive to another
previously approved coal additive. [R307-401-8]
II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily heat input of the kiln and precalciner. The owner/operator may increase the average quantity of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon approval by the Director in accordance with the approval process described in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

DAQE-IN103030032-25
Page 20

II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight
A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation
C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit-no less than 1500oF for more than five minutes in any 60-minute period B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
DAQE-IN103030032-25
Page 21

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the Director. The calibration procedure and frequency shall be according to manufacturer's specifications. Use of factory-calibrated thermocouples for temperature measurement is approved. However, any other method of temperature measurement must be approved by the Director prior to use. The monitoring equipment for both temperature and oxygen content shall be located such that an inspector can at any time safely read the output. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall only operate the emergency engines for testing and maintenance purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency operation. [R307-401-8]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.5.b.2 To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From Source Submitted NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-IN103030032-25
Page 22

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-GN103030032F-25

January 22, 2025

Via Certified Mail 70190700000208349796

Erik Vernon
Bureau of Land Management
440 West 200 South Suite 500
Salt Lake City, Utah 84101
[e-mail]

Dear Mr. Vernon:

RE: Notice of Publication for Ash Grove Cement Company - Leamington Cement Plant – CDS A;
MACT (Part 63), Compliance Assurance Monitoring (CAM), Title V (Part 70) Major Source,
Major Criteria Source, Major HAP Source, Attainment Area, NSPS (Part 60),
Project Number: N103030032

On January 22, 2025, the Director has completed his review of a Prevention of Significant Deterioration
project submitted by Ash Grove Cement Company. Attached to this letter are the draft Approval Order
document (Intent to Approve) and the full engineering review. Following a 60-day review by the Federal
Land Managers, this project will be submitted for a 30-day public comment period. Written comments
received by the Division at this same address during these comment periods will be considered in making
the final decision on the approval/disapproval of the proposed Approval Order. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director at the Division in writing, a hearing
will be held in accordance with R307-401-7, UAC.

If you have any questions, please contact John Jenks, who may be reached at [phone].

Sincerely,

Jon L. Black, Manager
New Source Review Division

Enclosures: Engineering Review
Modeling Memo
Intent to Approve

JLB:JJ:jg
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

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State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
RN103030032
January 21, 2025
Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]
Dear Josh Nelson,
Re: Engineer Review:
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032
Please review and sign this letter and attached Engineer Review (ER) within 10 business days.
For this document to be considered as the application for a Title V administrative amendment, a
Title V Responsible Official must sign the next page.
Please contact John Jenks at [phone] if you have any questions or concerns about the ER.
If you accept the contents of this ER, please email this signed cover letter to John Jenks at
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 1

[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the
DAQ will consider any comments received and will issue the Approval Order.

If you do not respond to this letter within 10 business days, the project will move forward
without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue
an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 2

OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible
Official, as defined in R307-415-3, must sign the statement below. THIS IS STRICTLY
OPTIONAL.

If you do not want the Engineer Review to be considered as an application to administratively
amend your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will
require submittal of a separate Operating Permit Application to revise the Title V permit in
accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document:
Title V Operating Permit Application Due Dates clarifies the required due dates for Title V
operating permit applications and can be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality

“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate
and complete and request that this Approval Order be considered as an application
to administratively amend the Operating Permit.”

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 3

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N103030032
Owner Name Ash Grove Cement Company
Mailing Address P.O. Box 38069
Leamington, UT, 84638

Source Name Ash Grove Cement Company- Leamington Cement
Plant
Source Location Hwy 132
Leamington, UT 84638

UTM Projection 397000 m Easting, 4380100 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3241 (Cement, Hydraulic)

Source Contact Cody Watkins
Phone Number [phone]
Email [e-mail]

Billing Contact Cody Watkins
Phone Number 385.225.0615
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 30, 2022
Date of Accepted Application November 28, 2024

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 4

SOURCE DESCRIPTION

General Description
Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried
on site), are correctly proportioned, ground and mixed, and then fed into a rotating kiln. The kiln
alters the materials and recombines them into small stones called cement clinker. The clinker is
cooled and ground with gypsum and additional limestone into a fine powdered cement. The final
product is stored on site for later shipping. The major sources of air emissions are from the
combustion of fuels for the kiln operation, from the kiln, and from the clinker cooling process.
The Leamington cement plant is a major source for emissions of PM2.5, PM10, NOx, CO, HAPs
and GHG. It is a minor source of SO2 emissions.

NSR Classification:
Major PSD Modification

Source Classification
Located in Attainment Area,
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Proposal
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower, various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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These changes result in increases in actual emissions, but decreases in most potential emissions.
There will be an increase in the potential emissions of VOC and greenhouse gases.

EMISSION IMPACT ANALYSIS
The complete modeling review is located in DAQE-MN103030032-24. [Last updated January 14, 2025]

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SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
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Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

Note: Change in emissions indicates the difference between previous AO and proposed modification.

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Review of BACT for New/Modified Emission Units

1. BACT review regarding the Leamington Plant Upgrade Project
Any major stationary source or major modification subject to PSD review must undergo an
analysis to ensure the use of BACT. The requirement to conduct a BACT analysis is set forth in 40
CFR 52.21. Similarly, Utah requires the installation of BACT for all sources of air pollution under
R307-401-5(2)(d)), BACT is defined in 40 CFR 52.21 (and R307-401-2) as:

". . . best available control technology means an emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for each pollutant subject to regulation under
Act which would be emitted from any proposed major stationary source or major modification
which the Administrator, on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such source or modification
through application of production processes or available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion techniques for control of such
pollutant . . ."

Therefore, a BACT analysis is required for each new or physically modified emission unit for each
pollutant that exceeds an applicable PSD significant emission rate (SER). Since the PM10 and PM2.5
emissions from the proposed project exceed the applicable PSD SER, a BACT analysis is required
to assess the required levels of control for these pollutants. Because the CO2e emissions are subject
to regulation as a result of the proposed project resulting in an increase of 75,000 tons or more per
year CO2e, a BACT analysis is also required for that pollutant. Note that HAPs listed under CAA
Section 112(b)(1) are excluded from NSR (New Source Review) or PSD (i.e., BACT) review.

In a memorandum dated December 1, 1987, the United States Environmental Protection Agency
(EPA) stated its preference for a "top-down" BACT analysis. After determining if any New Source
Performance Standard (NSPS) is applicable, the first step in this approach is to determine, for the
emission unit in question, the most stringent control available for a similar or identical source or
source category. If it can be shown that this level of control is technically, environmentally, or
economically infeasible for the unit in question, then the next most stringent level of control is
determined and similarly evaluated. This process continues until the BACT level under
consideration cannot be eliminated by any substantial or unique technical, environmental, or
economic objections.

Presented below are the five basic steps of a top-down BACT review as identified by the EPA.
Step 1 - Identify All Control Technologies
Step 2 - Eliminate Technically Infeasible Options
Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Step 4 - Evaluate Most Effective Controls and Document Results
Step 5 - Select BACT

Ash Grove has elected to follow this methodology and based the BACT review on each individual
pollutant. The complete BACT analysis follows. [Last updated January 14, 2025]

2. BACT review regarding PM10 and PM2.5 Sources
PM10 and PM2.5 Modified Equipment
The existing kiln precalciner, preheater, and alleviator system are proposed to be modified, and the
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kiln's ID fan and clinker cooler fans are proposed to be replaced, which will result in increased
airflow. Additionally, the clinker cooler baghouse will be converted from a plenum pulse to a pulse
jet baghouse. These modifications are projected to result in a net increase of potential PM10 and
PM2.5 emissions.

Kiln Upgrade BACT
The rotary cement kiln is the core of the cement manufacturing process, transforming the blended
raw materials or "rawmix" into clinker through pyro processing. Emissions from the kiln occur
from fuel combustion plus the physical and chemical reactions needed to transform the rawmix
into clinker. This project involves process and energy efficiency improvements and an increase in
kiln production, resulting in an increase of PM10 and PM2.5 emissions. This section specifically
addresses filterable PM10 and PM2.5. The condensable fraction is represented with the other
precursors as applicable to proposed emission increases.

The Leamington Plant's Kiln is subject to NSPS, Subpart F for particulate. Therefore, a BACT
analysis addresses applicability of the proposed changes to the kiln system to NSPS and review of
the RBLC. A summary of the resources reviewed include the following:

NSPS Subpart F - Standards of Performance for Portland Cement Plants establishes emission
standards for cement kiln operations. Specifically, kilns modified after June 16, 2008, are limited to
0.07 lbs PM/ton of clinker produced.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028) and
Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from kiln operations are as follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM emissions are most effectively controlled using a collection system with enclosures routed to
baghouses providing up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Ash Grove
has selected technology with the highest control efficiency, so there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.
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Step 5 - Select BACT
Ash Grove proposes that BACT for PM10 and PM2.5 emissions from the kiln consist of a collection
system routed to a baghouse or fabric filter that complies with NSPS Subpart F's emission standard
for a modified source. BACT for the Leamington Plant's kiln are 10% opacity and 0.07 lb of
PM/ton (NSPS Subpart F emission standard) of clinker.
[Last updated January 14, 2025]

3. BACT review regarding PM10 and PM2.5 sources cont.
Clinker Cooler Upgrade BACT
The clinker cooler reduces the temperature of the clinker exiting the kiln. It is necessary to reduce
clinker temperature before it enters the finish mill to maintain product quality and reduce wear and
tear on equipment. The clinker cooler is equipped with a heat exchanger that captures waste heat
and transfers it to the kiln preheater for process and energy efficiency. Emissions from the clinker
cooler are vented to a baghouse. The Leamington Plant's clinker cooler is also subject to NSPS
Subpart F for particulate. Ash Grove's proposed changes to the clinker cooler meet the definition of
a reconstruction under NSPS. Therefore, in order to meet the requirements of NSPS Subpart F, Ash
Grove will be required to meet a limit of 0.02 lb of PM/ton of clinker.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from clinker cooler operations are as
follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM10 and PM2.5 emissions are most effectively controlled using a collection system with enclosures
routed to a baghouse, which can achieve up to 99.9% control efficiency. Other technologies such as
wet scrubbers, cyclones and ESPs are feasible, but provide lower control efficiencies than a
baghouse. Because the most efficient control technology is proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for PM10 and PM2.5 emissions from the clinker cooler is a collection system routed to a
baghouse or fabric filter. In order to meet the requirements of NSPS Subpart F, Ash Grove will
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meet a reduced emission limit of 0.02 lb of PM/ton of clinker. A 10% opacity limit is also
applicable. [Last updated January 14, 2025]

4. BACT review regarding PM10 and PM2.5 sources cont.
New Finish Mill BACT
The proposed Plant upgrade include adding a second finish mill. The new finish mill will use an
energy efficient vertical roller mill assisted with a grinding aid. A total of five (5) point sources are
planned for the finish mill. In accordance with NSPS Subpart F, emissions from finish mill are
restricted to 10% opacity. Ash Grove has reviewed the following sources to identify available
control technologies.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);12 and

Region 8 General Permit for Concrete Batch Plants.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 emissions from plant material handling operations are as
follows:
Baghouse / Fabric Filter;
Best Management & Operational Practices;
Cyclone;
ESP;
Enclosure;
Water Application (Watering); and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
With the exception of water application, all options are technically feasible. Water application is
eliminated as clinker exiting the kiln along with additives in the finish mill must remain dry to
maintain product quality. Therefore, it is technically infeasible to water material in the finish mill.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Enclosure 50-90%
5. Cyclone 20-70%
6. Best Management & Operational Practices varies

Step 4 - Evaluate Most Effective Controls and Document Results
Baghouses provide the highest emission control efficiency, controlling up to 99.9% of PM
emissions from finish mill equipment. After baghouses, using a wet scrubber or ESP provides
similar PM control. Notably, baghouses, scrubbers, and ESPs require enclosures to aid in capturing
emissions and ducting to the control. Therefore, optimal PM emission control can be achieved
through implementing both baghouses and enclosures where feasible. Plant material sizing and
handling is currently done using a series of buildings and enclosures routed to baghouse controls.
Various silos storing material inputs are also equipped with fabric filters. As the highest ranked
technology is applied, there are no adverse energy, environmental or cost impacts to consider with
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the use of these control technologies. Thus, no further analysis is required under EPA's top-down
BACT approach.

Step 5 - Select BACT
BACT for finish mill PM10 emissions is compliance with NSPS Subpart F, Standards of
Performance for Portland Cement Manufacturing where applicable. Ash Grove will achieve BACT
for PM10 emissions from finish mill equipment through the implementation of enclosures,
baghouses, and best management practices. All baghouses at the finish mill will have a 10%
opacity limitation and a grain loading of 0.005 grains/dscf. [Last updated January 14, 2025]

5. BACT review regarding PM10 and PM2.5 sources cont.
Material Transfer, Sizing, and Storage BACT
The Leamington Plant has sources of fugitive emissions through raw material transfer. Materials
transferred include limestone and other raw materials, coal, clinker, and cement. These materials
are transferred by conveyor belt, screw conveyor, elevator, pneumatic conveyance or chutes via
gravity. At the Leamington Plant the fugitive emissions are enclosed at their transfer points and
routed to baghouses.

The following emission units are included in this category:
Limestone Crushing, Sizing, and Material Transfer;
Raw Material Transfer;
Coal Sizing and Transfer;
Existing Finish Mill;
Clinker Storage and Transfer;
Cement Storage and Truck and Rail Cement Loadout;
New Rail Loading and Loadout; and
New Clinker Reclaim Hopper Baghouse.

Generally, controls for these units have not changed or they are similar to current existing controls.
A full BACT analysis of each unit is included in Ash Grove's NOI and additional submitted
information. However, given that most controls remain unaltered, only the results of Step 5 -
Select BACT will be included here.

Limestone Crushing, Sizing, and Material Transfer
Subject to NSPS Subpart OOO opacity limits for existing sources.
Existing baghouses. No change from bag manufacturer's specifications.

Raw Material Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Coal Storage and Transfer
Existing Equipment. No change from bag manufacturer's specifications
20% Opacity

Clinker Storage and Transfer
Subject to NSPS Subpart F opacity limits:
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10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Existing Finish Mill Grinding, Storage and Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Cement Storage and Truck and Rail Cement Loadout, New Rail Loadout
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

New Rail Loadout, controlled by baghouse
Emissions Limit - 0.005 gr/dscfm

New Clinker Reclaim Hopper, controlled by baghouse
Subject to NSPS Subpart F opacity limits:
10% opacity
Emissions Limit - 0.005 gr/dscfm [Last updated January 14, 2025]

6. BACT review regarding PM10 and PM2.5 sources cont.
PM10 and PM2.5 Fugitive Emissions
The following fugitive emissions sources will increase emissions of PM10 and PM2.5 as a result of
the Leamington Plant's proposed throughput increase. The sources addressed in the following
BACT analyses are primarily in the quarry, but also include emissions from roads and dumping of
raw materials within the plant boundary.

The sources evaluated are listed below:
Roads;
Loading and Unloading;
Stockpiles;
Bulldozing and Grading;
Disturbed Areas; and
Drilling and Blasting.

Ash Grove currently controls emissions from these processes, and generally, controls for these
units have not changed. A full BACT analysis of each unit is included in Ash Grove's NOI and
additional submitted information. However, given that most controls remain unaltered, only the
results of Step 5 - Select BACT will be included here.

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
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Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

Stockpiles BACT
BACT shall consist of restricting fugitive emissions to the opacity standard of 20% opacity at the
property boundary. BACT for stockpiles will be achieved through applying good management
practices through its fugitive dust plan as appropriate.

Bulldozing and Grading BACT
BACT shall consist of restricting fugitive emissions from bulldozing and grading activities to no
more than 20% opacity, and that emissions are controlled with periodic watering of the disturbed
surface. The frequency of water application will depend on ambient weather conditions and
inherent moisture content of the material being moved.

Disturbed Areas BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. BACT for
disturbed areas will be achieved through best management practices, watering, scarification, and
revegetation.

Drilling and Blasting BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. This is achievable
through best management practices, shrouds, watering, and dust collection. [Last updated January
14, 2025]

7. BACT review regarding kiln system NOx emissions
Kiln System (Kiln, Raw Mill, and Coal Mill) - NOx BACT
Although there are physical changes to the kiln system, these changes are primarily related to
particulate emissions. NOx emissions are generated from the combustion of fuel - and no changes
in NOx emissions are expected from the kiln (hourly capacity to emit). The kiln NOx emissions will
remain the same as a result of upgrades to the SNCR system. The replacement of the various
components of the kiln system and portions of the preheater tower, along with new injection points,
will ensure that increased mixing of ammonia is achieved to enhance the SNCR system's ability to
reduce NOx and minimize ammonia slip. This will allow the Leamington Plant to maintain the NOx
hourly capacity to emit unchanged from current levels Leamington Plant Upgrade Project. At
present Ash Grove has no restriction on the amount of fuel combusted, only a limit on total NOx
generated, and with this project the allowed NOx PTE is decreasing from 1,352 tpy to 1,226 tpy.

Additional ammonia will be used in the existing SNCR system. While the SNCR system has
adequate capacity to accommodate the additional ammonia demand resulting from the system
upgrades, more ammonia ports are proposed to be added with the kiln system's proposed changes
of the equipment. The changes proposed to the kiln system will increase residence time and
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temperature which will improve the SNCR system's effectiveness to control NOx emissions and
minimize ammonia slip emissions to the atmosphere. No additional review of NOx BACT for the
kiln system is required under this proposal. [Last updated January 14, 2025]

8. BACT review regarding new finish mill heater emissions
Finish Mill Heater
The proposed finish mill will include a process heater to maintain a minimum temperature during
milling. The proposed heater will run on natural gas and is rated at 10 MMBtu/hr. Startup and
shutdown emissions from the heater are anticipated to be no greater than normal operation as the
process is simply a matter of bringing the heater to operating temperature. Emissions evaluated in
the BACT analysis for the finish mill heater include NOx, SO2, CO, and VOCs, PM10, and PM2.5.
Pollutants with identical control technologies are grouped together in the analysis.

NOx - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for NOx from units of this size range are as follows:
Ultra-Low-NOx Burners (ULNB);
Low NOx Burners;
Selective Catalytic Reduction (SCR);
Selective Noncatalytic Reduction (SNCR);
Good Combustion Practices; and
Use of Natural Gas.

Step 2 - Eliminate Technically Infeasible Options
Low exit temperatures render the use of SCR and SNCR ineffective. Particulate entrainment within
the finish mill could potentially foul (plug) the nozzles of ULNB. Low-NOx burners, the use of
natural gas as fuel and good combustion practices are all considered technically feasible.

Step 3 and Step 4 - Rank Remaining Control Technologies by Control Effectiveness and Evaluate
Most Effective Controls and Document Results
Since the three feasible control technologies are proposed for the finish mill heater, no detailed
economic, energy, and environmental impact evaluations were conducted. No ranking of control
effectiveness is required as all three controls are proposed.

Step 5 - Select BACT
BACT for NOx is the use of natural gas as fuel, good combustion practices and the use of Low NOx
burners.

CO, SO2, and VOC - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for CO, SO2, and VOC from units of this size are as follows:
Good Combustion Practices
Use of Natural Gas

The finish mill heater combusts natural gas. Related natural gas combustion emissions are
anticipated to be minimal.

Step 2 - Eliminate Technically Infeasible Options
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Both control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Both technologies offer intrinsic emission reductions from combustion. Since the technologies do
not compete, both technologies can and will be used simultaneously.

Step 4 - Evaluate Most Effective Controls and Document Results
Because both control technologies identified in Step 1 are proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for CO, SO2, and VOC are good combustion practices and the use of natural gas.

PM10 and PM2.5 BACT for the finish mill has been addressed in the PM10/PM2.5 sources section.
[Last updated January 14, 2025]

9. BACT review regarding SO2, VOC, and Lead Sources
The following BACT analysis is grouped by pollutants that will experience an increase in potential
emissions and the associated technically feasible control technologies. As such, the BACT analysis
is separated into SO2, VOC, and lead respectively with organic HAPs addressed with VOCs.

SO2 - Cement Kiln BACT
NSPS Subpart F - Standards of Performance for Portland Cement Plants, establishes emission
standards for cement kiln operations. Specifically, kilns constructed or reconstructed after June 16,
2008, are limited to 0.4 lbs SO2/ton clinker on a 30-day rolling average respectively. This limit is
an existing emission limit in the Leamington Plant's approval order and Title V. Ash Grove will
continue to achieve this emission limitation while achieving BACT for the kiln operations. Ash
Grove has reviewed the following sources to identify available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019); and

NSPS Subpart F as an affected emissions facility in 40 CFR 60.62(a)(4);

Portland Cement Association's Formation and Techniques for Control of Sulfur Dioxide and Other
Sulfur Compounds in Portland Cement Kiln Systems.

SO2 emissions are a result of oxidation of sulfur compounds in the rawmix and/or the coal used to
fire the kiln. However, the alkaline nature of the cement provides for direct absorption of SO2 into
the product, thereby mitigating the quantity of SO2 emissions in the exhaust stream.

Step 1 - Identify All Control Technologies
Control technologies identified for SO2 emissions from coal-fired kiln operations are as follows:
Baghouse or fabric filter;
Dry reagent injection prior to baghouse;
Wet scrubber;
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Process optimization; and
Good combustion practices.

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below:

1. Process Optimization 99%
2. Wet Scrubber 99%
3. Dry Reagent Injection 60%
4. Good Combustion Practices 30%
5. Baghouse Variable

Step 4 - Evaluate Most Effective Controls and Document Results
SO2 emissions are most effectively controlled by optimizing the process and utilizing the inherent
SO2 scrubbing properties of the kiln system itself. Although wet scrubbers alone can achieve equal
control efficiencies as process optimization, additional capital and operational expenses are
required for water consumption and wastewater discharge. Whereas process optimization achieves
the same control effectiveness and has the added benefit of reduced operational costs. Ash Grove
optimizes the kiln process by routing the exhaust from the kiln to a preheater and raw mill to
interact with the raw mix, thus creating an atmosphere similar to a dry scrubber system. Good
combustion practices also reduce SO2 formation with the added benefit of energy efficiency.

Step 5 - Select BACT
BACT for control of SO2 emissions from kiln operations shall consist of process optimization by
routing kiln exhaust to the preheater and raw mill, good combustion practices, and use of a
baghouse prior to exhausting to the atmosphere. As a modification of the kiln, 40 CFR 60.62(a)(4)
requires an emission limit of 0.4 pounds of sulfur dioxide (SO2) per ton of clinker on a
30-operating day rolling average. [Last updated January 14, 2025]

10. BACT review regarding SO2, VOC, and Lead Sources cont.
VOC - Cement Kiln BACT
VOCs are generated by incomplete combustion in the kiln. 40 CFR 63 Subpart LLL - NESHAP
from the Portland Cement Industry limits total hydrocarbon and total organic HAP emissions to 24
and 12 ppmv at 7% oxygen. Ash Grove will achieve or exceed these emission limitations while
achieving BACT for the kiln operations. Ash Grove has reviewed the following sources to identify
available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028); and

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for VOC emissions from coal fired kiln operations are as follows:
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Process optimization,
Good combustion practices

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below.

1. Process Optimization Variable
2. Good Combustion Practices Variable

Step 4 - Evaluate Most Effective Controls and Document Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove optimizes the
kiln process by capturing waste heat from the clinker cooler and routing to a kiln preheater. Good
combustion practices also reduce VOC formation with the added benefit of energy efficiency.
There are no adverse energy, environmental or cost impacts to consider with the use of this control
technology.

Step 5 - Select BACT
BACT for control of VOC emissions from kiln operations shall consist of process optimization by
routing kiln heat to the preheater and good combustion practices. An emission limit of 24 ppmv
VOC @ 7% O2 is imposed by NESHAP Subpart LLL.

VOC - Grinding Aid BACT
A grinding aid containing VOC is added to the new finish mill to disperse particles within the mill
and expose more surface area to grinding. An increase in grinding aid usage proportionally
increases potential VOC emissions because volatiles from the grinding aid are not combusted in
the kiln.

There is only one identified control option for limiting the VOC emissions from the grinding aid.
Process optimization is technically feasible. VOC emissions are most effectively controlled by
optimizing the process. Ash Grove proposes to install a vertical finish mill with this project. Due to
the new modern mill's efficiency, it is anticipated that a reduced amount of grinding aid will be
required for each ton of clinker ground. Ash Grove estimates total VOC emissions from the
grinding aid at 2.37 tpy.

Lead Emissions
The lead emissions are anticipated to increase as a result of the proposed increase in clinker
throughput with the Leamington Plant upgrade project. Lead emissions result from residual
amounts of lead in raw materials and fuel. Lead emissions will be controlled the same as PM,
therefore a separate top-down BACT analysis has not been conducted as the Leamington Plant has
applied the most effective controls. [Last updated January 14, 2025]

11. BACT review regarding Greenhouse Gases
GHG Background
On October 9, 2009, the mandatory GHG reporting regulation, referred to as 40 CFR 98, was
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published in the Federal Register. Through 40 CFR 98, the U.S. EPA established the GHG
Reporting Rule, which requires the annual reporting of GHG data and other relevant information
from large sources and suppliers in the United States. Monitoring through the GHG Reporting
Program (GHGRP) began in 2010, with the first reports due by March 31, 2011. Per 40 CFR
98.2(a)(1), any facility associated with cement production is subject to the GHGRP and must report
CO2e emissions. The CO2e is the sum of equivalent GHG emissions from CO2, CH4, and N2O,
with their respective global warming potentials (GWP) applied. Ash Grove's facility is subject to
GHG Reporting Rule and monitors CO2 emissions from its kiln with a continuous emissions
monitoring system (CEMs). On June 23, 2014, the U.S. Supreme Court held that required PSD
permits (based on emissions of non-GHG pollutants) may continue to require limitations on GHG
emissions based on the application of BACT as an "anyway source". The Leamington Plant
modification project is a major source for PSD for both PM10 and PM2.5, and GHGs are estimated
to be greater than 75,000 tpy and greater than zero on a mass basis; therefore, GHGs are evaluated
for BACT as an anyway source.

Cement Manufacturing GHG BACT
A BACT analysis has been conducted for CO2e emissions from the kiln system. For this GHG
BACT analysis, various control technologies or combinations of technologies were identified using
the RACT/BACT/LAER Clearinghouse, available literature including guidance published by EPA
and South Coast Air Quality Management District (SCAQMD), current air regulations, other
regulatory organizations, and engineering experience. In March 2011, EPA published GHG
permitting guidance, as well as a white paper on available and emerging technologies for reducing
GHG emissions from the Portland cement industry in October 2010. Additionally, EPA published a
series of videos on GHG permit training in December 2010. The SCAQMD published GHG BACT
guidance in 2021. Additional sources of information were reviewed and documented based on
publications from trade organizations and other governmental committees with GHG or carbon
reduction guidelines and/or recommendations.

EPA has defined in 40 CFR 86.1818-12(a) GHGs as a group of six gases: CO2, nitrous oxide
(N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF6). GHG emissions from the kiln result from calcination and fuel combustion.
Since the primary GHG emitted by a kiln is CO2, the BACT analysis focuses on CO2 emissions
from the kiln. Emissions of CH4 and N2O are minimal from cement kilns. Per EPA guidance, GHG
control technologies for consideration in a BACT analysis for Portland Cement Manufacturing
include:

Source-wide energy efficiency strategies;
Raw material substitution;
Blended cements;
Carbon capture utilization and storage; and
Fuel switching.
Other emerging technologies [Last updated January 14, 2025]

12. BACT review regarding Greenhouse Gases cont.
Step 1: Identify All Control Technologies
The CO2 emissions from a cement kiln are generated by the calcination process (conversion of the
calcium carbonate in limestone to calcium oxide) and by combustion of fuel in the kiln. Potential
control technologies to reduce these CO2 emissions for a cement kiln are addressed in EPA's white
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paper on Available and Emerging Technologies for Reducing GHG Emissions from the Portland
Cement Industry.

These technologies fall into three categories:
Energy Efficiency Improvements for the Clinker Production Process
Fuel Substitution
Carbon Capture and Sequestration

Step 2: Eliminate Technically Infeasible Options
Several potential energy efficiency improvements are technically feasible: Pre-heater/Pre-calciner
Kiln Process, Kiln Seal Management Program, Refractory Selection (Kiln Insulation), and Energy
Recovery from the Clinker Cooler. The use of alternative fuels such as natural gas, whole tires and
biofuel) is also technically feasible. Other control options, such as Use of Fluxes and Mineralizers,
Heat Recovery for Power - Cogeneration, Carbon Sequestration, Oxyfuel combustion, and
Post-combustion Capture have been deemed infeasible.

Step 3: Rank Remaining Control Technologies by Control Effectiveness
All four remaining control techniques are currently implemented at the Leamington Plant. This
permitting project incorporates energy efficiency improvements. Ash Grove has had a fuel
substitution program in place for several years, and this program is continually reviewed and
updated as new sources and types of fuel are identified.

Step 4: Evaluate Most Effective Controls and Document Results
Since all technically feasible energy efficiency improvements and changes to product composition
will be implemented, this section will focus on economic and environmental considerations of fuel
substitution to operate exclusively on natural gas.

Firing natural gas as the primary kiln fuel can reduce CO2 emissions from fuel combustion by as
much as 40%. However, studies have shown that use of natural gas as primary kiln fuel can result
in three times more NOx emissions than NOx emissions from coal firing. Creating more NOx to
reduce GHG emissions is undesirable as it is a precursor to both ozone and PM2.5. Fuel substitution
essentially trades emissions of one regulated pollutant for another. Estimated capital cost to switch
to natural gas fuel exceeds $25M. Implementing natural gas technology would provide incremental
public health and welfare benefit globally by reducing CO2 emissions, while increasing NOx
emissions and negatively impacting public health and welfare locally. Switching fuels to another
fossil fuel has finite potential to mitigate CO2 emissions.

Step 5: Select BACT
In addition to the proposed energy efficiency improvements addressed elsewhere in this BACT
analysis, BACT is a limit of 0.92-ton CO2e/ton clinker. Ash Grove will use a continuous emission
monitoring system (CEMS) for CO2 to demonstrate compliance with this limit. [Last updated
January 14, 2025]

13. BACT review regarding Leamington Plant Upgrade Project conclusion
The control processes and techniques covered in this BACT analysis have been reviewed by the
NSR Section of the UDAQ. Ash Groves proposed controls and associated emission limitations
represent BACT. Any emission limitations not expressed in an associated NSPS or NESHAP will
be included in the terms and conditions of this AO. A listing of all associated NSPS and NESHAP
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programs is also included in the Source Information section of this document under Applicable
Federal Programs. [Last updated December 13, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date
of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
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proper credit when notifying the Director, send the documentation to the Director, attn.: NSR
Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.

II.A.3
NEW
Stockpiles
Coal storage
Area: 1 acre
Annual throughput 20,000 tpy

AF and ARM stockpiles
Area: 0.25 acre
Annual throughput 8,000 tpy

II.A.4 Stationary Crusher
Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction
of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000
acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)

II.A.5 Raw Material Transfer
Crushed material is transported to raw material storage by belt B8. The raw material transfers
at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor
transfer point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total
filter area & water sprays. (pre-1983)

II.A.6 Material Handling
Conveyor belt systems, secondary feeders and screens, stacker system

II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit specific requirements

II.A.8 Belt Conveyor Transfer Baghouse
Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area
and 1,800 acfm total air flow, controls emissions from the conveyor belt that transfers the
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stacked material to the raw material silos.

II.A.9 Raw Material Silos
Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The
four silos are equipped with one common Fuller, plenum pulse baghouse (315.BF1) - 1,689 ft2
filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage).

II.A.10 Fifth Component Silo
Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse
(315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw
mill feed. This system includes vibrating feeders, a conveyor system, and surge bin.
Emissions are controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3,
316.BF4, 316.BF5) - each is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1
A/C ratio.

II.A.12 Cross-Belt Analyzer
Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6)

II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom
of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw
materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38).
The following equipment is installed: low-NOx burner, selective non-catalytic reduction
(SNCR) for NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued
mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric
monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct
for mercury adsorption capacity. The carbon injection system is not an emission point as it is
in an enclosed building.

II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

II.A.16 Two Kiln Feed Blending Silos
Raw material is blended in one of two blending silos prior to feeding the kiln. The blending
silos are controlled by one common Fuller, plenum pulse baghouse (411.BF1) - 1,351 ft2 filter
area; 7,160 acfm total air flow.

II.A.17 Blending Silo Elevators (2)
Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped
with a Fuller, pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow
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through stack E34.

II.A.18 Kiln Feed Alleviator
A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the
central material silo between the blending silos and the preheater. Raw feed is removed from
the system near the top of the preheater tower.

II.A.19 Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner.
The coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter
area; 1,700 acfm total air flow.

II.A.20 Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in
the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2):
19,500 acfm rated airflow with 3.75:1 A/C ratio

II.A.21 Clinker Cooler and Baghouse
Reconstructed grate type cooler used for cooling clinker from the kiln prior to transfer to
clinker storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) -
173,869 acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter
monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two
clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse
(419.BF8). The exhaust is routed to the clinker cooler stack.

II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions
generated when loading the east and west clinker silos and the out-of-spec silo are controlled
by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1):
1,800 acfm, that discharges into the clinker tunnel.

II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm, that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2)
Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers.
Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses
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(511.HP1 and new 511.HP2): 1,800 acfm each.

II.A.27 Gypsum Silo
Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2
total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust
during loading.

II.A.28 Clinker Tunnel Exitway
The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse
(511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel all discharge in the clinker tunnel.
Emissions are vented through the tunnel exitway.

II.A.29 Limestone Silo
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust
during loading. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement product. Dust
generated during milling is captured by a BHA, pulse jet baghouse (514.BF2) - 6,080 ft2 filter
area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding
stack).

II.A.31 Finish Mill (Ball Mill) Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized
cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA, pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow
controlling particulates from stack G55 (finish mill stack).

II.A.32
NEW
Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The
stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4)
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1,
525.BF1 thru 3)

II.A.33 Finish Cement Storage Silos
There are six storage and two interstice silos where the finished cement product is stored. A
single common Fuller, plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm
total air flow through stack H7 is located on top of the silos and is used to control emissions
during loading and unloading operations.

II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail
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shipping. This baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out
The cement loadout system located on the South side of the silos (truck load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF2) during unloading from the silos for truck
shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement
conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed
space inside the silos.

II.A.36
NEW
Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

II.A.37 MHO: Materials Handling Operation
Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1
& 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4;
512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.

II.A.38 LBS: Limestone Bypass System
Additional limestone is added to the clinker and gypsum by the limestone bypass system
(LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays
at the screen and material handling drop points.

II.A.39 GEN: Emergency Generators
One diesel-fired emergency generator (new)
Rating: 762 hp
(Kiln, Tier 3, permitted 2022)

Two natural gas-fired emergency generators
Rating: 304 hp
(Main office and control room, permitted in 2023)

One diesel-fired emergency generator
Rating: 560 hp
(Shipping, permitted 2023).

II.A.40 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14 inch knife gate, 8 inch knife gate, 8 inch air
slides, surge bin), and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm)
on the fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

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II.A.41
NEW
Miscellaneous Storage Tanks
One diesel storage tank (<2,000 gallons)
One gasoline storage tank (500 gallons)
Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Requirements on the Cement Plant:
II.B.1.a
NEW
The following limits shall not be exceeded:

A. Clinker production - 1,155,000 tons per rolling 12-month period

B. Used oil consumption - 85,724 gallons per rolling 12-month period

C. Limestone bypass material processed - 216,260 tons per rolling 12-month period.
[R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 25th day of each month using data from the previous 12 months.
Records shall be kept for all periods when the plant is in operation. Consumption and
production shall be calculated through use of the plant's acquisition system. [R307-401-8]

II.B.1.b
NEW
Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations:

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

SO2: 0.4 lbs per ton of clinker (3-hr average)

CO: 3,395 tons per rolling 12-month period, and 6,600 lbs/hr

NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average, and 1,233 tons per rolling
12-month period

Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is
400oF or less.

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Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)

THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)

CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)

PM: 0.02 lbs filterable PM per ton of clinker. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL,
R307-401-8]

II.B.1.c
NEW
A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR
60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust
emissions control plan shall be monitored to demonstrate that appropriate control measures are
being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of
the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall
be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in
the plan and that the source is operating in accordance with the submitted plan. For petitions
to approve alternative control measures, the permittee shall keep a copy of the submitted
petition and any approvals received. [40 CFR 60 Subpart Y]

II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area
source of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2). [40 CFR
63 Subpart LLL]

II.B.1.e
NEW
Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b
and II.B.1.d shall be performed as specified below:

A. Kiln/Raw Mill Stack
Pollutant Test Status Test Frequency
PM * #

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

B. Clinker Cooler (F31)
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Pollutant Test Status Test Frequency
PM + #

C. Testing Status (To be applied above)
* The initial testing has already been performed.

** The SO2 initial performance test was conducted on August 26, 2013.

*** The initial compliance test shall be conducted within the first 30 operating days of
operation in which the affected source operates using a CEMS.

# Test once every year. If performance testing would be required less than 15 operating days
after the Kiln has completed Startup after being down for more than 24 hours, then
performance testing may be deferred up to 15 operating days after completion of the Startup.
The Director may require testing at any time.

## Test at least once every two years. The Director may require testing at any time.

+ Initial testing is required within 180 days of startup of the reconstructed equipment

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must record the PM
CPMS output data for all periods when the process is operating, and use all the PM CPMS
data for calculations when the PM CPMS is not out-of-control. The owner/operator must
demonstrate continuous compliance by using all quality-assured hourly average data collected
by the PM CPMS for all operating hours to calculate the arithmetic average operating
parameter in units of the operating limit on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

+++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.e.1
NEW
Notification
The Director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The notification requirements for performance tests subject to 40
CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-165]

II.B.1.e.2
NEW
Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational
Safety and Health Administration (OSHA)- or Mine Safety and Health Administration
(MSHA)-approved access shall be provided to the test location. [R307-165]

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II.B.1.e.4
NEW
PM
40 CFR 60, Appendix A, Method 5 or 5I or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three (3) runs with
each run at least 120 minutes in duration and each run collecting a sample of 60 dry standard
cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.3
NEW
Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2. [R307-165]

II.B.1.e.5
NEW
Carbon Monoxide (CO)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.6
NEW
Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.7
NEW
Sulfur Dioxide (SO2)
40 CFR 60, Method 6 or 6C of Appendix A-4 or other EPA-approved method as acceptable to
the Director. [R307-165]

II.B.1.e.8
NEW
Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]

II.B.1.e.9
NEW
Total Hydrocarbons (THC)
Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL]

II.B.1.e.10
NEW
Mercury (Hg)
Continuous Emission or integrated sorbent trap monitoring (See Condition II.B.3.a). [40 CFR
63 Subpart LLL]

II.B.1.e.11
NEW
HCl
Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other
EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]

II.B.1.e.12
NEW
Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.13
NEW
Calculations
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director, to give the results in the specified units of the
emission limitation. [R307-165]

II.B.1.e.14
NEW
Existing Source Operation
For an existing source/emission point, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three years.
[R307-165]

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II.B.1.e.15
NEW
New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the maximum production rate listed in this AO. If the maximum AO
allowable production rate has not been achieved at the time of the test, the following
procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This new
allowable maximum production rate shall remain in effect until successfully tested at a higher
rate.

3) The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate (110%
of the new rate) will then be allowed if the test is successful. This process may be repeated
until the maximum AO production rate is achieved. [R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL.
[40 CFR 63 Subpart LLL]

II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times
of Dust Shuttle System operation to assist in the capture of Mercury emission. [R307-401-8]

II.B.1.h
NEW
Visible emissions from the following emission points shall not exceed the following values:

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

L. All baghouses - 10% opacity
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M. Fugitive dust - 20% opacity

N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y,
R307-401-8]

II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer
point is not required to conduct Method 22 visible emissions monitoring under this paragraph.
The enclosures for these transfer points must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

If any partially enclosed or unenclosed conveying system transfer point is located in a
building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to
40 CFR 60, according to the following:

(i) The owner/operator must conduct a monthly ten-minute visible emissions test of each
affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The
performance test must be conducted while the affected source is in operation.

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator may decrease the frequency of performance testing from monthly
to semi-annually for that affected source. If visible emissions are observed during any
semi-annual test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iii) If no visible emissions are observed during the semi-annual test for any affected source,
the owner/operator may decrease the frequency of performance testing from semi- annually to
annually for that affected source. If visible emissions are observed during any annual
performance test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iv) If visible emissions are observed during any Method 22 performance test, of Appendix
A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations,
recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60.
The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour
of any observation of visible emissions.

(v) If visible emissions from a building are monitored, the requirements of paragraphs (i)
through (iv) of this Condition apply to the monitoring of the building, and the owner/operator
must also test visible emissions from each side, roof, and vent of the building for at least ten
minutes. [R307-401]

II.B.1.j
NEW
Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed
0.005 gr/dscf:

520.BF1
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520.BF2
520.BF3
520.BF4
521.BF2
521.BF1
524.BF1
524.BF2
524.BF4
524.BF3
525.BF1
525.BF2
525.BF3
511.HP2
NRL_UPR
NRL_LWR. [R307-401-8]

II.B.1.j.1
NEW
To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration
through at least three (3) annual tests that the PM limits are not being exceeded, the
owner/operator may request approval from the Director to conduct stack testing less
frequently than annually. [R307-401-8]

II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive
dusts as dry conditions warrant or as determined necessary by the Director to maintain opacity
limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated to control fugitive dust. The application of
water or chemical treatment shall be used. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a damp/moist condition unless it is below freezing.
If chemical treatment is to be used, the plan must be approved by the Director. Records of
water and/or chemical treatment shall be kept for all periods when the plant is in operation.
The records shall include the following items: Instances of water and/or chemical application
to unpaved areas shall be recorded and maintained by the owner/operator. The ambient
temperature shall be recorded any time water should be applied but cannot due to freezing
conditions. [R307-401-8]

II.B.2.c
NEW
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

The sprays shall operate whenever dry conditions warrant meeting the required opacity
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limitations or as determined necessary by the Director. Water sprays shall not be required
during periods of freezing temperatures. [R307-401-8]

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation
of fugitive dusts as dry conditions warrant or as determined necessary by the Director.
[R307-401-8]

II.B.2.e
NEW
The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5
PM. [R307-401-8]

II.B.3 Continuous Emission Monitoring Requirements:
II.B.3.a
NEW
The owner/operator shall install, calibrate, maintain and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler.

A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the
missing data substitution procedures used by the UDAQ or the missing data substitution
procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate by the UDAQ.

B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period
including during each startup, shutdown, or malfunction.

C. The monitoring system shall comply with all applicable sections of R307-170, UAC; and
40 CFR 60, Appendix B.

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be
installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the
kiln/raw mill stack.

F. The owner/operator shall record the output of the system: including the quantity of NOx,
CO, O2 THC, Hg, HCl, and CO2 emissions at the kiln stack.

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source shall
continuously operate all required continuous monitoring devices and shall meet minimum
frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker
cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except
during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments,
the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a
PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the
results of the performance test demonstrating compliance with the filterable PM limit and
using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust
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the SSOL developed in accordance with the results of the most recent PM performance test
demonstrating compliance with the PM emission limit. The owner/operator shall use the PM
CPMS to demonstrate continuous compliance with the SSOL in accordance with the
requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

II.B.4 Fuel Limitations:
II.B.4.a
NEW
The owner/operator shall use only the following fuels in the kiln and pre-calciner:

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.

If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b
NEW
Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the
Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the
results of suitable tests giving data similar to a Proximate and Ultimate analysis of the
proposed coal additive. [R307-401-8]

II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal
additive. Approval is not required to change from one previously-approved coal additive to
another previously-approved coal additive. [R307-401-8]

II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily
heat input of the kiln and precalciner. The owner/operator may increase the average quantity
of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon
approval by the Director in accordance with the approval process described in Condition
II.B.4.b. [R307-401-8]

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II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel burning or process
installation not covered by New Source Performance Standards for sulfur emissions or
covered elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross
Btu heat input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input
for any oil except used oil. The sulfur content shall comply with all applicable sections of
UAC R307-203. [R307-203, R307-401-8]

II.B.4.c.1
NEW
Certification of fuels shall be either by the owner/operator's own testing or test reports from
the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be
available onsite. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials, UAC R307-203-1 (4)

A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be
used.

B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be
used.

C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85 are to be used. [R307-203]

II.B.4.d
NEW
The concentration/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight
3) Cadmium 2 ppm by weight
4) Chromium. 10 ppm by weight
5) Lead 100 ppm by weight
6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be
tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the burn tank and burned. [R307-401-8]

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II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned
in the rotary kiln:

A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than
five minutes in any 60-minute period

B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes
in any 60-minute period. [R307-401-8]

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the
Director. The calibration procedure and frequency shall be according to manufacturer's
specifications. Use of factory-calibrated thermocouples for temperature measurement is
approved. However, any other method of temperature measurement must be approved by the
Director prior to use. The monitoring equipment for both temperature and oxygen content
shall be located such that an inspector can at any time safely read the output. [R307-401-8]

II.B.5
NEW
Emergency Engine Requirements
II.B.5.a
NEW
The owner/operator shall only operate the emergency engines for testing and maintenance
purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency
operation. [R307-401-8]

II.B.5.b
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each emergency engine. [R307-401-8]

II.B.5.b.1
NEW
The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.5.b.2
NEW
To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN103030035-24 dated November 27, 2024
Is Derived From Source Submitted NOI dated November 30, 2022
Incorporates Additional Information Received dated April 26, 2023
Incorporates Additional Information Received dated September 26, 2023
Incorporates Additional Information Received dated July 23, 2024
Incorporates Additional Information Received dated October 25, 2024
Incorporates Additional Information Received dated November 25, 2024

REVIEWER COMMENTS

1. Comment regarding applicability of federal requirements:
New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable
by the best demonstrated technology as specified in the applicable provisions. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.

40 CFR 60, Subpart A (General Provisions)
All affected facilities subject to a source-specific NSPS are subject to the general provisions of
NSPS, Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires
initial notification, performance testing, recordkeeping, and monitoring, provides reference methods,
and mandates general control device requirements for all other subparts.

40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of
performance for affected facilities in Portland Cement Plants which have been constructed or
modified after August 17, 1971.

40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart
F: Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and
unloading systems. The Leamington coal mill is an in-line coal mill and considered an integral part
of the Leamington kiln. In-line coal mills are not subject to NSPS Subpart Y. Therefore, the coal mill
is addressed under NSPS Subpart F as part of the kiln system. The coal silos and conveying system
are subject to NSPS Subpart Y.

Ash Grove's proposed changes to the kiln system must be evaluated as to whether they trigger new
NSPS Subpart F obligations based on whether the proposed project is either a modification or a
reconstruction, as those terms are defined in NSPS Subpart A.

Ash Grove's proposed changes to the kiln system do not meet the definition of a reconstruction, nor
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Page 40

do they meet the definition of a modification for NOx. However, the changes meet the definition of a
modification for PM and SO2. Therefore, Ash Grove will comply with all relevant emission
standards; testing requirements; monitoring, recordkeeping, and reporting obligations that apply to
the Leamington kiln system as an existing source under NSPS Subpart F. Under NSPS Subpart A
and F, the clinker cooler is considered a reconstructed unit. Thus new limits will apply to this unit.
[Last updated January 14, 2025]

2. Comment regarding applicability of federal requirements cont.:
NSPS Subpart Y - Standards of Performance for Coal Preparation and Processing Plants
This subpart provides standards of performance for affected facilities in coal preparation and
processing plants that process more than 200 tons of coal per day.

The Leamington plant's coal silo and coal conveying system are existing affected facilities under
NSPS Subpart Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses
controlling affected facilities subject to match the limit in NSPS Subpart Y from 0.016 gr/dscf to
0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade Project. Since there are no proposed
modifications or reconstruction to the coal silo and coal conveying system, nothing about the
proposed upgrade project affects the existing applicability of NSPS Subpart Y.

NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
This subpart provides standards of performance for affected facilities located at fixed or portable
nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August
31, 1983, with additional requirements applicable to sources constructed on or after April 22, 2008.

As the crushing and screening system is controlled by baghouses and an increase in PM10 actual
emissions on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS.
Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the
Leamington Plant Upgrade Project.

Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1),
60.676(f), and 60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO
monitoring and recordkeeping requirements.

[Last updated January 14, 2025]

3. Comment regarding applicability of federal requirements cont.:
National Emission Standards for Hazardous Pollutants (NESHAPs)
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or
greater than 10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as
specified by each subpart. NESHAP apply to sources in specifically regulated industrial source
classifications (CAA Section 112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities
not regulated as a specific industrial source type. The Ash Grove Leamington Plant is a major source
of HAPs and thus is subject to certain NESHAP standards.

Subpart A - General Provisions
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All affected sources are subject to the general provisions of Subpart A unless otherwise specified by
the source-specific NESHAP. Subpart A generally requires initial notification and performance
testing, recordkeeping, monitoring, provides reference methods, and mandates general control device
requirements for all other subparts as applicable.

Subpart LLL - Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry
This subpart establishes process/source specific emission limits for PM, VOC (expressed as total
hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and
gaseous HAP compounds by limiting PM and THC emissions because portions of such emissions
are USEPA-listed HAPs. Subpart LLL requires compliance with applicable emissions limits on and
after the initial startup of cement production. To further reduce emissions, Subpart LLL also
establishes operational requirements for the use of cement kiln dust (CKD), fly ash, fuel and control
equipment. Subpart LLL also specifies process/source specific emissions testing, monitoring,
recordkeeping, reporting, and compliance demonstration requirements. The compliance requirements
for the site are detailed in Approval Order Condition II.B.1.b. Ash Grove will continue to comply
with the requirements of Subpart LLL to demonstrate compliance. This cement kiln will remain an
existing source with respect to the kiln emission standards in Subpart LLL as this project does not
trigger the definition of a new source in Subpart LLL. New source standards apply only to affected
sources that were constructed or reconstructed after May 6, 2009.
[Last updated December 20, 2024]

4. Comment regarding PSD applicability analysis:
Ash Grove is proposing to increase the throughput of limestone from the quarry to supply the New
Finish Mill to increase the amount of low-carbon cement from the Leamington Plant. Additionally,
along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
modified, and the clinker cooler will be reconstructed. These changes are anticipated to result in an
increase in clinker production. Emission calculations for this project have been completed assuming
an increase in clinker production capacity while utilizing current fuel types. This will result in an
increase in the throughput of fuel.

The Leamington Plant is considered an existing major source under PSD based on potential
emissions of PM10, PM2.5, NOx, CO, SO2, and CO2e. If a major source undergoes a physical or
operational change, the facility must determine whether the project will be considered a major
modification. Per 40 CFR 52.21(b)(2)(i), in order to be a major modification, the project must result
in a significant emissions increase, and a significant net emissions increase.

As defined at 40 CFR 52.21(b)(40): Significant emissions increase means, for a regulated NSR
pollutant, an increase in emissions that is significant for that pollutant. Significant is further defined
to mean, in reference to a net emissions increase or the potential of a source to emit any of the
following pollutants, a rate of emissions that would equal or exceed the values outlined in 40 CFR
52.21(b)(23). If the increase in emissions from the project are not significant, a major modification
has not occurred.

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 42

increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

For all pollutants, the project emissions increase was calculated as the difference between the
projected actual emissions (PAE) after the proposed project and the actual emissions prior to the
project (baseline actual emissions or BAE).

Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
". . . projected actual emissions means the maximum annual rate, in tons per year, at which an
existing emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years
(12-month period) following the date the unit resumes regular operation after the project, or in any
one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit of that regulated NSR pollutant and full utilization of the unit would
result in a significant emissions increase or a significant net emissions increase at the major
stationary source." [Last updated January 14, 2025]

5. Comment regarding PSD applicability analysis cont.:
Ash Grove estimates that the projected actual production capacity following the project will be
1,155,000 tons of clinker per year and 1,341,266 tons of limestone per year. These capacities were
used to calculate projected actual emissions from the project using representative emission factors.
Additionally, to estimate emissions from material transfer baghouses, the actual flow rates and actual
projected hours were used as a basis for projected actual emissions.

Project Emission Calculations

Project emission increases from the kiln and coal mill systems are calculated for all criteria
pollutants based on emission factors that are derived from stack testing, CEMS data, or emission
factors (i.e., VOCs and Lead), and the associated projected incremental clinker increase.

NOx emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain
hourly capacity to emit and annual potential to emit at current levels. The kiln's NOx emissions rate
will not change as a result of the physical modifications proposed by the project.

Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission
factor and multiplied by the incremental increase in clinker production. The emission factor was
selected based on the average of the 24-month consecutive month emissions for 2020 and 2021. The
CO emissions will increase.

The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing
conducted at the plant. The SO2 emissions will increase.

VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production. VOC emissions will increase.

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 43

can be found in the original NOI and subsequent addendums submitted to UDAQ.

As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from
the proposed project, each increase of emissions from both existing and new sources shall be
summed together and compared to the PSD permitting thresholds. The increase of emissions is the
"positive" difference between the projected actual emissions and baseline actual emissions (projected
minus baseline).

New Emissions Sources

The actual to projected actuals calculation is not available to new emission units. For new emission
units, the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected
emissions are based on the new sources' potentials to emit. (40 CFR § 52.21(a)(2)(iv)(f)).

The new equipment proposed includes the New Finish Mill, a new rail and truck loading/loadout,
one (1) new clinker reclaim loading hopper with a dust collector and one (1) existing clinker reclaim
hopper with a dust collector, a new Clinker Cooler to replace the existing one, and a new kiln feed
alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions:

The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;

The finish mill heater was calculated based on its maximum firing capacity and flow rates; and

The fugitive emissions were calculated based on the projected annual throughput of the New Finish
Mill, the rail loadout, and clinker production. [Last updated January 14, 2025]

6. Comment regarding PSD applicability analysis cont.:
Existing Emission Sources

For the existing sources, the projected actual emissions are the maximum annual rates in tons per
year projected to occur during the next five (5) to ten (10) years if the existing sources' design
capacities increase. Ash Grove Leamington projected the actual emissions for the next five (5) years
based on the new kiln system producing an annual average of 3,250 tons of clinker per day.

Baseline actual emissions (BAE) are defined at 40 CFR 52.21(b)(48)(ii) as:

". . . baseline actual emissions means the average rate, in tons per year, at which the emissions unit
actually emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the 10-year period immediately preceding either the date the owner or operator
begins actual construction of the project, or the date a complete permit application is received by the
Administrator."

Ash Grove has selected to use the years 2020 and 2021 for each pollutant as the representative
baseline years.

In its NOI, Ash Grove calculated the emission increase from the project as being divided into two
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 44

phases. Phased construction projects are discussed in two sections of the federal PSD regulations -
40 CFR 52.21(j)(4) and 40 CFr 52.21(r)(2). UDAQ is not processing this project as a phased
construction project, nor did Ash Grove request such a determination. Therefore, Ash Grove
provided a summary table outlining the final change in emissions from this project:

Projected Actual Increase Compared to PSD threshold (tons per year)
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2e
BAE 76.64 39.64 1,187 6.87 3,315 55.47 641,385
PAE 203.15 113.47 1,226 45.87 3,414 72.07 1,067,984

Change in Emissions 126.51 73.83 39.00 39.00 99.00 16.59 426,598

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes

If the emissions increase is greater than the PSD significance threshold for a particular pollutant, Ash
Grove has the option of conducting a PSD review or continuing through the rest of the steps to
determine if it can "net" out of a PSD review. If the project increase is less than the PSD significant
threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant.

The change in emissions from the project exceeds the significant emission threshold for three
pollutants: PM10, PM2.5 and CO2e. Ash Grove elected to attempt to net out of a PSD major
modification for the remainder of the criteria pollutants.

Netting

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant
Upgrade Project and ends on the date the upgrade begins operation. Only PM10, PM2.5, CO2e are in
excess of SERs and therefore considered in the netting analysis.

Ash Grove estimated that the commencement of construction will be in December 2024. Therefore,
the contemporaneous period for this project is December 2019 through a projected date the project
upgrade begins operation. [Last updated January 21, 2025]

7. Comment regarding PSD applicability analysis cont.:
Contemporaneous Decreases

Ash Grove replaced an existing kiln emergency drive engine with a USEPA Tier 4 diesel engine in
2022. Concurrently, Ash Grove requested an increase in the capacity of 1L Cement. Additionally,
Ash Grove submitted a minor modification NOI air permit application on June 12, 2023, which
proposes replacing the shipping generator during the contemporaneous period. The kiln emergency
drive engine and shipping generator are both higher EPA tier ratings therefore result in decreases for
PM10 and PM2.5. These changes were approved in AO DAQE-AN103030033-24 issued March 21,
2024.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 45

Contemporaneous Increases

As stated above, the existing kiln emergency drive engine and shipping generator were permitted and
replaced in 2024. This resulted in an increase in emissions of CO2e.

The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout
in an effort to improve truck traffic at the loadout. The modification to add these dust collectors to
the loadout was included in DAQE-AN103030029-19. The baghouses are three (3) levels up in the
silos' enclosed space (approximately 40 feet). Both dust collectors vent directly into the interior of
the silo structure and are not vented into the atmosphere. Ash Grove requests to remove these
baghouses from its existing permitted emissions inventory. Therefore, these emissions have been
documented in the netting analysis as zero emissions.

Also included in DAQE-AN103030033-24 were two new natural gas-fired emergency generators
and increases in stockpiles, material handling and road emissions.

Could Have Been Accommodated Emissions

In calculating project emissions increase, USEPA allows the exclusion of existing
production/emissions rates that could have been accommodated during the baseline period. These
"could have been accommodated" emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as
follows:

". . . Shall exclude, in calculating any increase in emissions that results from the particular project,
that portion of the unit's emissions following the project that an existing unit could have
accommodated during the consecutive 24-month period used to establish the baseline actual
emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project,
including any increased utilization due to product demand growth;"

Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the
exclusion of existing production and emissions rates that could have been accommodated during the
baseline period, it has elected not to use this exclusion at this time. Therefore, calculation of the
"could have been" accommodated emissions have not been included in this application's
applicability analysis.

The increase from the project is added to the contemporaneous decreases and contemporaneous
increases. The resulting calculation is then compared to the PSD significance threshold to determine
if a significant net emissions increase has occurred. [Last updated January 14, 2025]

8. Comment regarding PSD applicability analysis cont.:
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2 e
Contemporaneous Inc. 1.61 0.45 0.41 0 0.27 0.07 51.74

Contemporaneous Dec. -1.54 -3.97 -0.48 -0.02 -0.27 -0.09 0

Change in Emissions 125.02 69.21 38.93 38.98 99.00 16.58 426,650

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 46

The results of the netting analysis conclude that both a significant emissions increase and a
significant net emissions increase in both particulates (PM10 and PM2.5) and CO2e will occur from
this project. Thus, the project must be reviewed as a PSD major modification. [Last updated January
14, 2025]

9. Comment regarding emission calculations:
This engineering review includes updated potential emission totals for both criteria and HAP
emissions. The potential-to-emit (PTE) values were calculated using updated values for clinker
produced and raw material inputs. BACT emission factors and limitations were used where
appropriate. Certain emission totals (NOx, SO2 and CO) were set based on avoiding a significant
increase in emissions. Specifically, the projected actual increase was set at just under the baseline
actual emissions + the significance level. As these emissions are monitored by CEM, UDAQ agrees
with this approach. Please see the netting analysis for further details on calculation of projected
actual increase. The NOx hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project.

CO2e emissions were calculated using the GHG emission factor calculated from 40 CFR Part 98
Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in Subpart A Table
A-1.

To calculate the PTE tons per year, the maximum hours (i.e., 8760) per year and the source's
emissions rates were multiplied with the throughputs. The potential throughputs have been updated
at UDAQ's request so that PAE is equal to PTE and represents the equipment's maximum design
potential.

Additional emission calculations based on source testing and monitoring, and EPA's compilation of
air emission factors AP-42. [Last updated January 14, 2025]

10. Comment regarding requirements for PSD review:
In addition to the permitting requirements of R307-401-5 through R307-401-8, there are additional
requirements under PSD that must be addressed:

1. Calculation of ambient air increments (40 CFR 52.12(c)), ambient air ceilings ((40 CFR 52.12(d)),
source impact analysis (40 CFR 52.12(k)), air quality models (40 CFR 52.12(l)) - these items are
addressed in the modeling memo DAQE-MN103030032-24.

2. Stack heights (40 CFR 52.12(h)) - Ash Grove's stack heights have been reviewed with respect to
good engineering practice and operate in a vertical unrestricted manner.

3. Control technology review (40 CFR 52.12(j)) - this is addressed in the BACT analysis section of
this review document.

4. Air quality analysis: preapplication analysis (40 CFR 52.12(m)) - this is covered in the PSD
applicability and netting analysis sections of this review document, ambient monitoring and
background data collection is also included in the modeling memo DAQE-MN103030032-24.

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 47

grain loading limit included in II.B.1.j.1 represents the required post-construction monitoring.
6. Source information (40 CFR 52.12(n)) - this is addressed under the requirements of R307-401-5
and was submitted by Ash Grove as part of the NOI package.

7. Additional impact analysis (40 CFR 52.12(o)) - these requirements cover soils, vegetation, growth
and visibility concerns. They are discussed in the modeling memo DAQE-MN103030032-24.

8. Federal land manager review (40 CFR 52.12(p)) - UDAQ provided initial notification to all
federal land managers upon receipt of the original NOI package. The draft permit and engineering
review will also be provided to the federal land managers 60-days prior to initiation of public
comment for their further review.

9. Public participation (40 CFR 52.12(q)) - this project will have a 30-day public comment period.

10. Source obligation (40 CFR 52.12(r)) - this requirement discusses source compliance with other
parts of the CAA, which is addressed within UDAQ's permitting rules in R307.
[Last updated January 14, 2025]

11. Comment regarding changes in equipment list:
The equipment list is being updated for clarity as well as adding new pieces of equipment. The
following changes are taking place:

The naming scheme is being updated to remove the numerical code from the unit designation. This
code generally referred to the associated control device and not to the emitting unit itself. This can
cause confusion especially when the same code was applied to multiple pieces of equipment.
Instead, the control devices (typically baghouse dust collectors) will be identified in the description
along with the appropriate numerical code.

Specific changes are as follows:

1. The kiln description has been updated

2. Clinker Cooler description has been updated to include a larger pulse jet baghouse.

3. The clinker storage silos, east and west clinker belts, clinker belt transfer and clinker tunnel have
been consolidated to avoid confusion

4. The north and south cement loadout exhausts now vent internally into the cement storage silos

5. The dust shuttle system has been consolidated into one line item, most identifiers removed from
subsystem descriptions as only two baghouses serve as exhaust points.

6. A new finish mill with heater has been added. Included in the description are the thirteen total
baghouses for dust control (1 main stack, 2 transfer points, 10 nuisance dust filters)

7. A new clinker reclaim hopper has been added. Both reclaim hoppers are controlled by baghouses
with updated identifiers

8. A new rail and truck loading/unloading system with two baghouses has been added.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 48

[Last updated December 20, 2024]

12. Comment regarding changes in conditions:
As a result of this project, several conditions will be added or changed. This includes one new
general condition (I.8). Changes to the equipment list (section II.A) will be addressed in a separate
reviewer comment:

I.8 - Adding this general condition to cover the requirements of R307-401-18 Eighteen Month
Review. The status of construction/installation of the new equipment shall be reviewed after
18-months.

II.B.1.a - Clinker production increases to 1,155,000 tpy
Use of limestone bypass material increases to 215,260 tpy

II.B.1.b - The NOx limit on the kiln decreases to 1,223 tpy, CO emissions from the kiln decrease to
3,395 tpy,
Adding a new CO2e limit of 0.92 tons CO2e/ton of clinker produced
PM limit on the clinker cooler decreased to 0.02 lb PM (filterable)/ton of clinker
Rule reference updated to include 40 CFR 60 Subpart F, and R307-401-8

II.B.1.e - Initial testing on the clinker cooler is now required within 180 days of startup of the unit.
Monitoring of CO2 from the kiln will be by CEM.
Formatting changes on paragraph designated ++, improve clarity, include reference to CO2
monitoring, define CPMS

II.B.1.e.4 - Update to address general PM monitoring and reference R307-401-8

II.B.1.e.14 - New condition to address new or reconstructed emission units monitoring requirements,
applicable to the clinker cooler and new finish mill.

II.B.1.h - Adding references to Subpart OOO units (limestone processing) with updated opacity
limits.
Adding 20% opacity limit on coal transfer and storage
Adding property boundary opacity limit of 20%
Updating rule reference to include Subpart OOO

II.B.1.j - New condition to address outlet grain loading limits on new baghouses, One identical limit,
15 total new baghouses.

II.B.1.j.1 - Monitoring on new baghouses as per II.B.1.e.4, added an allowance to test less frequently
than annually with three successful tests.

II.B.3.a - Updating formatting to add clarity and include reference to CO2 CEM

II.B.5 - New conditions on emergency engines, diesel fuel sulfur limits, hour of operation
restrictions, non resettable hour meter

[Last updated December 20, 2024]
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 49

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 51

TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 52

DAQE-MN103030032-24

M E M O R A N D U M

TO: John Jenks, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler
Dave Prey, Air Quality Modeler

DATE: December 12, 2024

SUBJECT: Modeling Analysis Review for the Ash Grove Cement Company – Leamington Plant,
located in Millard County, Utah
___________________________________________________________________________________
This is a Major Modification to a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Ash Grove Cement Company (Applicant) has submitted a Notice of Intent (NOI) air permit
application for a project referred to as the Leamington Upgrade Project (LUP). The proposed
upgrade project includes the construction and installation of new pollution control equipment, new
emission sources, and modifications to existing emission sources. Emission increases associated
with the LUP constitute a major modification to a Prevention of Significant Deterioration (PSD)
source subject to PSD permitting regulations. PSD regulations require the Applicant to include and
air quality impact analysis (AQIA) of the proposed projects impact on the EPA national ambient air
quality standards (NAAQS) and air quality related values (AQRV) as part of a complete NOI.

This report prepared by the New Source Review (NSR) modeling staff contains a review of the
Applicant’s Air Quality Impact Analysis (AQIA) including the methodology, data sources,
assumptions, and modeling results for comparison with State and Federal air quality standards. The
AQIA was reviewed and referenced in this report include the:
● Notice of Intent – Ash Grove Cement Leamington Plant PSD Notice of Intent Air Permit
Application, dated November 30, 2022.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

0 0
Jason Krebs

DP
DAQE-MN103030032-24
Page 2

II. APPLICABLE RULES AND ANALYSES

A Utah Air Quality Rules

The UDAQ has determined that the Applicant’s NOI is subject to the following rules for conducting an
AQIA:

R307-401 Permits: New and Modified Sources
R307-405 Permits: Major Sources Located in Attainment or Unclassified Area (PSD)
R307-406-2 Visibility – Source Review
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutant Impacts in Attainment Areas

B. Applicability

The proposed increases in emissions of PM10 and PM2.5 exceed the emission thresholds outlined in R307-
406-5 and R307-410-4. Therefore, an AQIA consistent with the requirements of R307-405-6, R307-406-
2, and R307-410-3 was submitted as part of the Applicant’s NOI. R307-410-3 establishes the U. S.
Environmental Protection Agency (US EPA) – Guideline on Air Quality Models as a formal basis for
defining the scope of the analysis, as well as the model’s construction. The results of the AQIA are
required to demonstrate the proposed project’s impact on state and federal air quality standards,
acceptable levels of impact, and action triggering thresholds referenced or listed in R307-401-6(2), R307-
401-6(3), R307-403-3(1), R307-403-5(1)(a), R307-405-4(1), R307-405-6. Annual emissions for criteria
pollutants requiring an AQIA are listed in Table 1.

Table 1: Ash Grove Leamington Proposed Net Emissions Increase

Criteria
Pollutants
Net Emission
Increase (TPY)
AQIA Trigger
Level (TPY) AQIA Required?
PM10 126.6 15 Yes
PM2.5 70.3 10 Yes

C. Required Analyses

R307-405 requires the Applicant to perform a pre-construction modeling analysis for all pollutants
emitted in a significant quantity. The purpose of the analysis is to determine if the extent of the source’s
impact is significant enough to warrant an on-site measurement of the ambient background concentration
levels. This data is included in the NAAQS analysis to represent the quality of the air prior to the
construction of the proposed project. The Applicant included a pre-construction modeling analysis for
PM10 and PM2.5 as part of the NOI. The pre-construction modeling analysis was also used to determine if
the proposed emissions would result in a significant impact to the environment, thereby triggering the
requirement for a cumulative analysis of the proposed project and other nearby existing sources.

R307-401-8 requires the Division to determine that the proposed project will comply with the NAAQS
prior to the issuance of an Approval Order (AO). R307-405(7) requires the Applicant to perform a
DAQE-MN103030032-24
Page 3
NAAQS analysis for all pollutants emitted in a significant quantity. The analysis is to include all
emissions at the proposed site under normal operating conditions using maximum anticipated short-term
release and annual release rates. Consistent with UDAQ policy, a cumulative analysis to include the
ambient background concentration and any contribution from other nearby sources is not required if the
proposed project’s impact does not exceed the PSD Class II Significant Impact Level (SIL).

R307-401-8 also requires the Division to determine that the proposed project will comply with PSD
increments prior to the issuance of an AO. Under R307-405(6), the Applicant is required to perform a
PSD Class I and II increment consumption analysis for all pollutants emitted in significant quantities.
The purpose of this analysis is to quantify any degradation in air quality since the major source baseline
date. The analysis is to include all increment consuming emissions at the proposed site under normal
operating conditions using maximum anticipated short-term and annual release rates. A cumulative
analysis to include contributions associated with growth and other increment consuming sources is not
required if the proposed project’s impact does not exceed the PSD Class I or II SIL.

R307-410-5 requires the Applicant to perform a HAPs analysis for any pollutant emitted above a
pollutant specific emission threshold value. This analysis is to include all emissions of the pollutants
resulting from the proposed modification under normal operating conditions using maximum anticipated
one-hour release rates. The Applicant did not trigger modeling for HAPs.

R307-406-2 requires the Applicant to perform a plume blight analysis. A plume blight analysis is required
to determine if plumes emanating from the proposed project would be visible inside any Class I area
within 50 kilometers of the source. The plume blight analysis is to include all emissions of NO2, SO4, and
PM10.

Under R307-405-16, an AQRV analysis is performed which evaluates regional haze and acid deposition
impacts at each of the Class I areas within 300 kilometers of the source. A regional haze analysis is
required to determine if the plumes would reduce the visual range of an observer inside the Class I area.
The regional haze analysis is to include all emissions of SO2, NOX and PM10. The deposition analysis
examines impacts from sulfur and nitrogen compounds at the Class I areas, and is based on all emissions
of SO2 and NOX. The Federal Land Managers use the Q/D approach to determine whether a PSD project
should provide detailed AQRV impact analyses, where: Q/D= [ H2SO4 + SO2 + NOx + PM10 emissions
(tpy)]/ distance (km). If Q/D is less than 10, no AQRV analysis is required.

R307-405 requires the Applicant to perform a soils and vegetation analysis. The analysis should quantify
the effects of pollutants on soils and vegetation near the highest impact location and in areas where
sensitive plant species may be impacted.

III. ON-SITE PRE-CONSTRUCTION MONITORING

A. Meteorological Data

Consistent with the US EPA - Meteorological Monitoring Guidance for Regulatory Modeling
Applications, one year of on-site data was collected using a 50-meter tower during the period October 1,
2021 through September 30, 2022. Parameters collected on-site included wind speed and direction,
temperature, delta-T, and solar radiation.

DAQE-MN103030032-24
Page 4

B. Ambient Pollutant Data

A preliminary analysis was conducted to determine the necessity for pre-construction ambient pollutant
monitoring. The results indicate that predicted concentrations of PM10 and PM2.5 exceed the monitoring
trigger level listing in the rule. A continuous PM10/PM2.5 monitor with filter based samplers was
installed near the northern edge of the Applicants property boundary, and collected particulate matter
from October 1, 2021 through September 30, 2022.

IV. MODEL SELECTION

The EPA-AERMOD dispersion modeling system is the preferred model specified in the US EPA –
Guideline on Air Quality Models to predict air pollutant concentrations in the near field (within 50
kilometers of the source). The US EPA - CALPUFF - Version 5.8 model is the preferred model to predict
concentrations in the far field (long range transport conditions beyond 50 kilometers from the source).

V. MODELING INPUTS AND ASSUMPTIONS

A. Technical Options

The regulatory default options were selected in AERMOD by the Applicant to quantify all concentrations.

B. Urban or Rural Area Designation

A review of the appropriate 7.5-minute quadrangles determined that the area should be classified as
“rural” for air modeling purposes.

C. Topography/Terrain

The Plant is at an elevation of 4,950 feet with nearby terrain features that have an effect on concentration
predictions.

a. Zone: 12
b. Location: UTM (NAD83): 397000 meters East, 4379850 meters North

D. Ambient Air

It was determined that the Plant boundary used in the AQIA meets the State’s definition of an ambient air
boundary.

E. Receptor and Terrain Elevations

The modeling domain has simple and complex terrain features in the near field. Therefore, receptor
points representing actual terrain elevations from the area were used in the analysis.

The far-field modeling domain consisted of a rectangular region covering all Class I areas within Utah,
and extending 50 kilometers beyond this area so that the model can account for re-circulation of the
plume.

DAQE-MN103030032-24
Page 5

F. Emission Rates and Release Parameters

The emission estimates and source parameters used in AERMOD for all proposed emission sources at the
site are presented in the NOI.

Speciated emission rates and source parameters used in the CALPUFF modeling are presented in Table 2.

Table 2: CALPUFF Emission Rates

Source
LCC Coordinates Modeled Emission Rates
Easting Northing SO2 SO4 NOX HNO3 NO3 SOA PMC SOIL EC
(m) (m) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr)
317.BF3 -1289410 -3738 52.81 5.03 307.58 0.00 0.00 5.03 2.60 2.90 0.11
419.BF1 -1289314 -3631 0.00 0.00 0.00 0.00 0.00 0.55 1.51 1.61 0.06
41B.BF2 -1289389 -3663 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.68 0.00
N1_FM2 -1289526 -3414 0.00 0.00 0.00 0.00 0.00 0.00 1.65 3.95 0.00
414.BF1N -1289407 -3683 0.00 0.00 0.00 0.00 0.00 0.00 0.10 0.25 0.00
2FM_HTR -1289528 -3415 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.08 0.00
514.BF1 -1289451 -3675 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.70 0.00
COMBO -1289424 -3668 0.00 0.00 0.00 0.00 0.00 0.00 1.37 5.72 0.00
FM2_CMB -1289454 -3439 0.00 0.00 0.00 0.00 0.00 0.00 0.50 1.21 0.00

Total Lb/hr 52.81 5.03 307.58 0.00 0.00 5.58 8.32 17.10 0.17
Hrs/Yr 8760 8760 8760 8760 8760 8760 8760 8760 8760
Ton/yr 231.3 22.0 1347.2 0.0 0.0 24.4 36.4 74.9 0.8

Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
317.BF3 POINT 4902.8 41.2 135.0 488 10.10 3.35
419.BF1 POINT 4891.2 18.3 60.0 388 6.36 2.90
41B.BF2 POINT 4895.2 68.6 224.9 294 17.83 0.74
N1_FM2 POINT 4832.0 49.7 163.0 363 40.08 1.40
414.BF1N POINT 4896.1 76.8 251.9 353 9.91 0.70
2FM_HTR POINT 4832.0 49.7 163.0 363 40.08 1.40
514.BF1 POINT 4889.5 39.6 130.0 294 11.86 0.91
COMBO POINT 4904.2 13.3 43.7 276 9.76 0.32
DAQE-MN103030032-24
Page 6
FM2_CMB POINT 4832.0 30.6 100.3 294 11.40 0.37

G. Building Downwash

The Applicant used the US EPA Building Profile Input Program (BPIP) to determine Good Engineering
Practice (GEP) stack heights and cross-sectional building dimensions for input into the model.

H. Ambient Background Concentrations

Millard County is in attainment for all criteria pollutants. The NAAQS analyses for PM2.5 and PM10 used
monitoring data collected on site during the pre-construction monitoring analysis. The background values
used in the NAAQS analysis are presented in Table 3.

Table 3: Background Concentrations

Pollutant Averaging
Period
Background
Concentration
(μg/m3)
PM10 24-hour 65.4
PM2.5 24-hour 10.2
Annual 4.2

I. Meteorological Data Processing

For the AERMOD model, on-site horizontal and vertical wind speed, direction, solar radiation and,
temperature data was combined with National Weather Service (NWS) upper air data collected at the Salt
Lake City International Airport (SLCIA) for the same period using the US EPA AERMET processing
system.

Meteorological data used for the CALPUFF modeling analysis consisted of 3 years (2018-2020) of data
developed by the Forest Service. The grid was 708 km (east-west) by 492 km (north-south) with a
resolution of 12 kilometers.

VI. RESULTS AND CONCLUSIONS

The Applicant performed a series of analyses to estimate the impact from the proposed project. Modeling
results and conclusions from the review of the analyses are outlined in detail below.

A. Pre-Construction Monitoring and Significant Impact Modeling

The Applicant performed a preliminary criteria pollutant analysis of the proposed modification. This
analysis indicated that increases in concentration levels of PM2.5 and PM10 were greater than the Class II
SIL, and therefore, a cumulative analysis for these pollutants was required.

DAQE-MN103030032-24
Page 7

B. NAAQS Analysis

The Applicant performed a modeling analysis to determine if the combined impact from the proposed
source, other industrial sources operating in the area, and ambient background would comply with the
NAAQS. The NAAQS analysis was reviewed by the Division and determined to be consistent with the
requirements of R307-410-3. Table 4 provides a comparison of the Applicant’s predicted air quality
concentrations and the NAAQS.

Table 4: Model Predicted NAAQS Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-hour 28.3 5 65.4 0 93.7 150 62.5%
PM2.5 24-hour 9.6 1.2 10.2 0 19.8 35 56.6%
Annual 4.4 0.3 4.2 0 8.6 9 95.6%
* Note: Only included other sources and background if source impact was above Class II SIL

C. PSD Class II Increments

The Applicant performed an analysis to determine if the impact from the proposed source would comply
with PSD Class II increments. The analysis was reviewed by the Division and determined to be
consistent with the requirements of R307-410-3. Table 5 provides a comparison of the predicted
concentrations and the PSD Class II increment.

Table 5: Model Predicted PSD Class II Increment Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Nearby
Sources*
Total Increment Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
PM10 Annual 8.1 1 0 8.1 25 32.4%
24-hour 28.3 5 0 28.3 30 94.3%
PM2.5 24-hour 6.1 1.2 0 6.1 9 67.8%
Annual 2.4 0.3 0 2.4 4 60.0%

D. Hazardous Air Pollutants

DAQE-MN103030032-24
Page 8
The Applicant performed an analysis to determine if HAP modeling is required. The analysis was
reviewed by the Division and determined to be consistent with the requirements of R307-410-3. The
analysis indicated that HAP modeling was not triggered by this modification, and therefore no HAP
modeling was performed.

E. PSD Class I Increment Consumption Analysis

The Applicant performed a CALPUFF analysis to determine if the impact from the proposed source along
with other increment consuming sources would comply with federal PSD Class I increments. The
analysis was reviewed by the Division and determined to be consistent with the requirements of R307-
410-3. The results for all Class I areas within 300 kilometers are provided in Table 6.

Table 6: Model Predicted PSD Class I Increment Concentrations

Air Period Prediction
Class I
Significant
Impact
Level
Other
Sources* Total Increment Percent
Pollutant (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
Capitol Reef
NO2 Annual 0.0018 0.1 2.5
SO2
3-Hour 0.0494 1 25
24-
Hour 0.0150 0.2 5
Annual 0.0008 0.1 2
PM2.5
24-
Hour 0.0430 0.27 2
Annual 0.0021 0.05 1
PM10
24-
Hour 0.0444 0.3 8
Annual 0.0021 0.2 4
Arches
NO2 Annual 0.0008 0.1 2.5
SO2
3-Hour 0.0408 1 25
24-
Hour 0.0102 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0522 0.27 2
Annual 0.0018 0.05 1
DAQE-MN103030032-24
Page 9
PM10
24-
Hour 0.0531 0.3 8
Annual 0.0019 0.2 4
Canyonlands
NO2 Annual 0.0010 0.1 2.5
SO2
3-Hour 0.0354 1 25
24-
Hour 0.0100 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0577 0.27 2
Annual 0.0019 0.05 1
PM10
24-
Hour 0.0591 0.3 8
Annual 0.0020 0.2 4
Bryce
NO2 Annual 0.0006 0.1 2.5
SO2
3-Hour 0.0369 1 25
24-
Hour 0.0082 0.2 5
Annual 0.0003 0.1 2
PM2.5
24-
Hour 0.0189 0.27 2
Annual 0.0010 0.05 1
PM10
24-
Hour 0.0194 0.3 8
Annual 0.0010 0.2 4
Zion
NO2 Annual 0.0011 0.1 2.5
SO2
3-Hour 0.0293 1 25
24-
Hour 0.0105 0.2 5
Annual 0.0005 0.1 2
PM2.5
24-
Hour 0.0266 0.27 2
Annual 0.0011 0.05 1
PM10 24-
Hour 0.0271 0.3 8
DAQE-MN103030032-24
Page 10
Annual 0.0012 0.2 4
* Note: Only included other increment consuming sources if source impact was above Class I SIL

Since the proposed project’s model predicted impacts at the Class I areas were less than the PSD Class I
significance levels, a cumulative analysis was not warranted.

DAQE-MN103030032-24
Page 11
F. Visibility – Plume Blight
Since the Class I areas are greater than 50 kilometers from the source, a plume blight analysis using
VISCREEN was not required.

G. Visibility – Regional Haze

The results of the Q/D analysis for the emissions increase was less than 10 but the FLMs wanted the
entire source included in the Q term. The results of including the total emissions resulted in a Q/D >10,
so an AQRV analysis was performed for visibility and acid deposition. The results shown in Table 7
indicate that the impacts are below the 0.5 Deciview (DV) threshold established by the National Park
Service, indicating that no further analysis is required.

Table 7: CALPUFF Visibility Results

Class I Area Year Maximum
Delta DV
98th
Percentile
change in
DV
#
Days
#
Days Threshold
(DV)
Below
Threshold
> 1 > 0.5
2018 0.248 0.06 0 0 0.5 Yes
Arches 2019 0.291 0.054 0 0 0.5 Yes
2020 0.216 0.106 0 0 0.5 Yes
2018 0.223 0.081 0 0 0.5 Yes
Canyonlands 2019 0.312 0.068 0 0 0.5 Yes
2020 0.186 0.085 0 0 0.5 Yes
2018 0.059 0.03 0 0 0.5 Yes
Bryce 2019 0.081 0.045 0 0 0.5 Yes
2020 0.071 0.03 0 0 0.5 Yes
2018 0.183 0.074 0 0 0.5 Yes
Capital Reef 2019 0.196 0.092 0 0 0.5 Yes
2020 0.126 0.078 0 0 0.5 Yes
2018 0.069 0.04 0 0 0.5 Yes
Zion 2019 0.123 0.039 0 0 0.5 Yes
2020 0.102 0.057 0 0 0.5 Yes

DAQE-MN103030032-24
Page 12

H. Acid Deposition

The Applicant performed a deposition analysis on impacts within the Class I areas. Results of the
analysis indicate that the impacts are below the deposition threshold (DAT) established by the National
Park Service, indicating that no further analysis is required

Table 8: CALPUFF Deposition Results for Highest Year

Class I Area
Total
Nitrate
Deposition
Total
Sulfate
Deposition
Deposition
Analysis
Threshold
(kg/ha/yr) (kg/ha/yr) (kg/ha/yr)
Canyonlands 0.0006 0.0003
0.005
Zion 0.0004 0.0002
Arches 0.0006 0.0003
Bryce 0.0006 0.0002
Capitol Reef 0.0011 0.0005

I. Soils and Vegetation Analysis

The Applicant performed an analysis to determine the extent of impacts from the proposed source on soil
and vegetation. Results of the analysis are presented in a supplemental document titled “Soil and
Vegetation Impact Analysis for the Leamington, UT Facility, June 29, 2023”. The analysis indicated that
predicted concentrations compared against the secondary NAAQS at several sensitive receptors would not
result in an adverse impact on soils and vegetation in the vicinity of the proposed project.

DP/JK:jg

DAQE-IN103030032-25

January 22, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Mr. Nelson:

Re: Intent to Approve: Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — ) A A v A ? A D @ A w D D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — ) A A v A ? A D @ A w D D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ash Grove Cement Company Ash Grove Cement Company - Leamington Cement Plant

Mailing Address Physical Address
P.O. Box 38069 Highway 132
Leamington, UT 84638 Leamington, UT 84638

Source Contact UTM Coordinates
Name: Cody Watkins 397000 m Easting
Phone: [phone] 4380100 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3241 (Cement, Hydraulic)

SOURCE INFORMATION
General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried on site),
are correctly proportioned, ground, and mixed and then fed into a rotating kiln. The kiln alters the
materials and recombines them into small stones called cement clinker. The clinker is cooled and ground
with gypsum and additional limestone into a fine powdered cement. The final product is stored on site for
later shipping. The major sources of air emissions are from the combustion of fuels for the kiln operation,
from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source of
emissions of PM2.5, PM10, NOx, CO, HAPs, and GHG. It is a minor source of SO2 emissions.
NSR Classification
Major PSD Modification

Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
DAQE-IN103030032-25
Page 4

Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

These changes result in increases in actual emissions but decreases in most potential emissions. There will
be an increase in the potential emissions of VOCs and greenhouse gases.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
DAQE-IN103030032-25
Page 5

Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
DAQE-IN103030032-25
Page 6

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
DAQE-IN103030032-25
Page 7

II.A.4 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)
II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area, and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, stacker systems. II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit-specific requirements.
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total air flow controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter
area; 9,865 acfm total air flow, controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are
controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each
is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6). II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The
following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for
NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.
II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low-pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

DAQE-IN103030032-25
Page 8

II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow through stack
E34.
II.A.18 Kiln Feed Alleviator A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the central material silo between the blending silos and the preheater. Raw feed is removed from the system near the top of the preheater tower.
II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The
coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter area;
1,700 acfm total air flow.
II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker
storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1): 1,800 acfm that discharges into the clinker tunnel.
II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
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II.A.27 Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during loading.
II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel, all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during loading. 512.BF3 (1,000 acfm) is located on top of the silo. II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement products. Dust generated
during milling is captured by a BHA pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).

II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates from stack G55 (finish mill stack).
II.A.32 Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4).
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1 thru 3).

II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total air flow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations.
II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This
baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

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II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.
II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023)
II.A.40 Dust Shuttle System A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides, surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the
fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

II.A.41 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons) Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
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II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)
THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)
CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)
PM: 0.02 lbs filterable PM per ton of clinker.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR 60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to approve alternative control measures, the permittee shall keep a copy of the submitted petition and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source
of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2).
[40 CFR 63 Subpart LLL]

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II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must record the PM CPMS output data for all periods when the process is operating and use all the PM CPMS data for calculations when the PM CPMS is not out of control. The owner/operator must demonstrate continuous compliance by using all quality-assured hourly average data collected by the PM CPMS for all operating hours to calculate the arithmetic average operating parameter in units of the operating limit on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
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II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

II.B.1.e.3 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-165]
II.B.1.e.4 PM 40 CFR 60, Appendix A, Method 5, or 5I, or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three runs, with each
run at least 120 minutes in duration and each run collecting a sample of 60 dry standard cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165]
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II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
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II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
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II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer point, is not required to conduct Method 22 visible emissions monitoring under this paragraph. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator may decrease the frequency of performance testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
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II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: Instances of water and/or chemical application to unpaved areas shall be recorded and maintained by the owner/operator. The ambient temperature shall be recorded any time water should be applied but cannot due to freezing conditions. [R307-401-8]
II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

The sprays shall operate whenever dry conditions warrant meeting the required opacity
limitations or as determined necessary by the Director. Water sprays shall not be required during
periods of freezing temperatures.

[R307-401-8]

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II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

C. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the kiln/raw mill stack

F. The owner/operator shall record the output of the system: including the quantity of NOx, CO, O2, THC, Hg, HCl, and CO2 emissions at the kiln stack

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an
affected source shall continuously operate all required continuous monitoring devices
and shall meet minimum frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.

[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]
II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments, the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the results of the performance test demonstrating compliance with the filterable PM limit and using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust the SSOL developed in accordance with the results of the most recent PM performance test demonstrating compliance with the PM emission limit. The owner/operator shall use the PM CPMS to demonstrate continuous compliance with the SSOL in accordance with the requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

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II.B.4 Fuel Limitations: II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke F. Fuel Oil
G. Used Oil Fuel

H. Synthetic Fuel
I. Wood
J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal additive.
Approval is not required to change from one previously approved coal additive to another
previously approved coal additive. [R307-401-8]
II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily heat input of the kiln and precalciner. The owner/operator may increase the average quantity of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon approval by the Director in accordance with the approval process described in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

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II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight
A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation
C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit-no less than 1500oF for more than five minutes in any 60-minute period B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
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II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the Director. The calibration procedure and frequency shall be according to manufacturer's specifications. Use of factory-calibrated thermocouples for temperature measurement is approved. However, any other method of temperature measurement must be approved by the Director prior to use. The monitoring equipment for both temperature and oxygen content shall be located such that an inspector can at any time safely read the output. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall only operate the emergency engines for testing and maintenance purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency operation. [R307-401-8]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.5.b.2 To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From Source Submitted NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-IN103030032-25
Page 22

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-GN103030032G-25
January 22, 2025
Via Certified Mail 70190700000208349758
Pleasant McNeel
Regional Air Program Manager
USDA Forest Service Intermountain Region
324 25th Street
Ogden, UT 84401
[e-mail]
Dear Ms. McNeel:
RE: Notice of Publication for Ash Grove Cement Company- Leamington Cement Plant – CDS A;
MACT (Part 63), Compliance Assurance Monitoring (CAM), Title V (Part 70) Major Source,
Major Criteria Source, Major HAP Source, Attainment Area, NSPS (Part 60),
Project Number: N103030032
On January 22, 2025, the Director has completed his review of a Prevention of Significant Deterioration
project submitted by Ash Grove Cement Company. Attached to this letter are the draft Approval Order
document (Intent to Approve) and the full engineering review. Following a 60-day review by the Federal
Land Managers, this project will be submitted for a 30-day public comment period. Written comments
received by the Division at this same address during these comment periods will be considered in making
the final decision on the approval/disapproval of the proposed Approval Order. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director at the Division in writing, a hearing
will be held in accordance with R307-401-7, UAC.
If you have any questions, please contact John Jenks, who may be reached at [phone].
Sincerely,
Jon L. Black, Manager
New Source Review Division
Enclosures: Engineering Review
Modeling Memo
Intent to Approve
JLB:JJ:jg
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
Jon Black (Jan 22, 2025 15:44 MST)
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
RN103030032
January 21, 2025
Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]
Dear Josh Nelson,
Re: Engineer Review:
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032
Please review and sign this letter and attached Engineer Review (ER) within 10 business days.
For this document to be considered as the application for a Title V administrative amendment, a
Title V Responsible Official must sign the next page.
Please contact John Jenks at [phone] if you have any questions or concerns about the ER.
If you accept the contents of this ER, please email this signed cover letter to John Jenks at
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 1

[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the
DAQ will consider any comments received and will issue the Approval Order.

If you do not respond to this letter within 10 business days, the project will move forward
without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue
an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 2

OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible
Official, as defined in R307-415-3, must sign the statement below. THIS IS STRICTLY
OPTIONAL.

If you do not want the Engineer Review to be considered as an application to administratively
amend your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will
require submittal of a separate Operating Permit Application to revise the Title V permit in
accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document:
Title V Operating Permit Application Due Dates clarifies the required due dates for Title V
operating permit applications and can be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality

“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate
and complete and request that this Approval Order be considered as an application
to administratively amend the Operating Permit.”

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 3

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N103030032
Owner Name Ash Grove Cement Company
Mailing Address P.O. Box 38069
Leamington, UT, 84638

Source Name Ash Grove Cement Company- Leamington Cement
Plant
Source Location Hwy 132
Leamington, UT 84638

UTM Projection 397000 m Easting, 4380100 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3241 (Cement, Hydraulic)

Source Contact Cody Watkins
Phone Number [phone]
Email [e-mail]

Billing Contact Cody Watkins
Phone Number 385.225.0615
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 30, 2022
Date of Accepted Application November 28, 2024

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 4

SOURCE DESCRIPTION

General Description
Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried
on site), are correctly proportioned, ground and mixed, and then fed into a rotating kiln. The kiln
alters the materials and recombines them into small stones called cement clinker. The clinker is
cooled and ground with gypsum and additional limestone into a fine powdered cement. The final
product is stored on site for later shipping. The major sources of air emissions are from the
combustion of fuels for the kiln operation, from the kiln, and from the clinker cooling process.
The Leamington cement plant is a major source for emissions of PM2.5, PM10, NOx, CO, HAPs
and GHG. It is a minor source of SO2 emissions.

NSR Classification:
Major PSD Modification

Source Classification
Located in Attainment Area,
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Proposal
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower, various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 6

These changes result in increases in actual emissions, but decreases in most potential emissions.
There will be an increase in the potential emissions of VOC and greenhouse gases.

EMISSION IMPACT ANALYSIS
The complete modeling review is located in DAQE-MN103030032-24. [Last updated January 14, 2025]

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 7

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 8

Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 9

Review of BACT for New/Modified Emission Units

1. BACT review regarding the Leamington Plant Upgrade Project
Any major stationary source or major modification subject to PSD review must undergo an
analysis to ensure the use of BACT. The requirement to conduct a BACT analysis is set forth in 40
CFR 52.21. Similarly, Utah requires the installation of BACT for all sources of air pollution under
R307-401-5(2)(d)), BACT is defined in 40 CFR 52.21 (and R307-401-2) as:

". . . best available control technology means an emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for each pollutant subject to regulation under
Act which would be emitted from any proposed major stationary source or major modification
which the Administrator, on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such source or modification
through application of production processes or available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion techniques for control of such
pollutant . . ."

Therefore, a BACT analysis is required for each new or physically modified emission unit for each
pollutant that exceeds an applicable PSD significant emission rate (SER). Since the PM10 and PM2.5
emissions from the proposed project exceed the applicable PSD SER, a BACT analysis is required
to assess the required levels of control for these pollutants. Because the CO2e emissions are subject
to regulation as a result of the proposed project resulting in an increase of 75,000 tons or more per
year CO2e, a BACT analysis is also required for that pollutant. Note that HAPs listed under CAA
Section 112(b)(1) are excluded from NSR (New Source Review) or PSD (i.e., BACT) review.

In a memorandum dated December 1, 1987, the United States Environmental Protection Agency
(EPA) stated its preference for a "top-down" BACT analysis. After determining if any New Source
Performance Standard (NSPS) is applicable, the first step in this approach is to determine, for the
emission unit in question, the most stringent control available for a similar or identical source or
source category. If it can be shown that this level of control is technically, environmentally, or
economically infeasible for the unit in question, then the next most stringent level of control is
determined and similarly evaluated. This process continues until the BACT level under
consideration cannot be eliminated by any substantial or unique technical, environmental, or
economic objections.

Presented below are the five basic steps of a top-down BACT review as identified by the EPA.
Step 1 - Identify All Control Technologies
Step 2 - Eliminate Technically Infeasible Options
Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Step 4 - Evaluate Most Effective Controls and Document Results
Step 5 - Select BACT

Ash Grove has elected to follow this methodology and based the BACT review on each individual
pollutant. The complete BACT analysis follows. [Last updated January 14, 2025]

2. BACT review regarding PM10 and PM2.5 Sources
PM10 and PM2.5 Modified Equipment
The existing kiln precalciner, preheater, and alleviator system are proposed to be modified, and the
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 10

kiln's ID fan and clinker cooler fans are proposed to be replaced, which will result in increased
airflow. Additionally, the clinker cooler baghouse will be converted from a plenum pulse to a pulse
jet baghouse. These modifications are projected to result in a net increase of potential PM10 and
PM2.5 emissions.

Kiln Upgrade BACT
The rotary cement kiln is the core of the cement manufacturing process, transforming the blended
raw materials or "rawmix" into clinker through pyro processing. Emissions from the kiln occur
from fuel combustion plus the physical and chemical reactions needed to transform the rawmix
into clinker. This project involves process and energy efficiency improvements and an increase in
kiln production, resulting in an increase of PM10 and PM2.5 emissions. This section specifically
addresses filterable PM10 and PM2.5. The condensable fraction is represented with the other
precursors as applicable to proposed emission increases.

The Leamington Plant's Kiln is subject to NSPS, Subpart F for particulate. Therefore, a BACT
analysis addresses applicability of the proposed changes to the kiln system to NSPS and review of
the RBLC. A summary of the resources reviewed include the following:

NSPS Subpart F - Standards of Performance for Portland Cement Plants establishes emission
standards for cement kiln operations. Specifically, kilns modified after June 16, 2008, are limited to
0.07 lbs PM/ton of clinker produced.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028) and
Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from kiln operations are as follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM emissions are most effectively controlled using a collection system with enclosures routed to
baghouses providing up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Ash Grove
has selected technology with the highest control efficiency, so there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 11

Step 5 - Select BACT
Ash Grove proposes that BACT for PM10 and PM2.5 emissions from the kiln consist of a collection
system routed to a baghouse or fabric filter that complies with NSPS Subpart F's emission standard
for a modified source. BACT for the Leamington Plant's kiln are 10% opacity and 0.07 lb of
PM/ton (NSPS Subpart F emission standard) of clinker.
[Last updated January 14, 2025]

3. BACT review regarding PM10 and PM2.5 sources cont.
Clinker Cooler Upgrade BACT
The clinker cooler reduces the temperature of the clinker exiting the kiln. It is necessary to reduce
clinker temperature before it enters the finish mill to maintain product quality and reduce wear and
tear on equipment. The clinker cooler is equipped with a heat exchanger that captures waste heat
and transfers it to the kiln preheater for process and energy efficiency. Emissions from the clinker
cooler are vented to a baghouse. The Leamington Plant's clinker cooler is also subject to NSPS
Subpart F for particulate. Ash Grove's proposed changes to the clinker cooler meet the definition of
a reconstruction under NSPS. Therefore, in order to meet the requirements of NSPS Subpart F, Ash
Grove will be required to meet a limit of 0.02 lb of PM/ton of clinker.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from clinker cooler operations are as
follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM10 and PM2.5 emissions are most effectively controlled using a collection system with enclosures
routed to a baghouse, which can achieve up to 99.9% control efficiency. Other technologies such as
wet scrubbers, cyclones and ESPs are feasible, but provide lower control efficiencies than a
baghouse. Because the most efficient control technology is proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for PM10 and PM2.5 emissions from the clinker cooler is a collection system routed to a
baghouse or fabric filter. In order to meet the requirements of NSPS Subpart F, Ash Grove will
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 12

meet a reduced emission limit of 0.02 lb of PM/ton of clinker. A 10% opacity limit is also
applicable. [Last updated January 14, 2025]

4. BACT review regarding PM10 and PM2.5 sources cont.
New Finish Mill BACT
The proposed Plant upgrade include adding a second finish mill. The new finish mill will use an
energy efficient vertical roller mill assisted with a grinding aid. A total of five (5) point sources are
planned for the finish mill. In accordance with NSPS Subpart F, emissions from finish mill are
restricted to 10% opacity. Ash Grove has reviewed the following sources to identify available
control technologies.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);12 and

Region 8 General Permit for Concrete Batch Plants.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 emissions from plant material handling operations are as
follows:
Baghouse / Fabric Filter;
Best Management & Operational Practices;
Cyclone;
ESP;
Enclosure;
Water Application (Watering); and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
With the exception of water application, all options are technically feasible. Water application is
eliminated as clinker exiting the kiln along with additives in the finish mill must remain dry to
maintain product quality. Therefore, it is technically infeasible to water material in the finish mill.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Enclosure 50-90%
5. Cyclone 20-70%
6. Best Management & Operational Practices varies

Step 4 - Evaluate Most Effective Controls and Document Results
Baghouses provide the highest emission control efficiency, controlling up to 99.9% of PM
emissions from finish mill equipment. After baghouses, using a wet scrubber or ESP provides
similar PM control. Notably, baghouses, scrubbers, and ESPs require enclosures to aid in capturing
emissions and ducting to the control. Therefore, optimal PM emission control can be achieved
through implementing both baghouses and enclosures where feasible. Plant material sizing and
handling is currently done using a series of buildings and enclosures routed to baghouse controls.
Various silos storing material inputs are also equipped with fabric filters. As the highest ranked
technology is applied, there are no adverse energy, environmental or cost impacts to consider with
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 13

the use of these control technologies. Thus, no further analysis is required under EPA's top-down
BACT approach.

Step 5 - Select BACT
BACT for finish mill PM10 emissions is compliance with NSPS Subpart F, Standards of
Performance for Portland Cement Manufacturing where applicable. Ash Grove will achieve BACT
for PM10 emissions from finish mill equipment through the implementation of enclosures,
baghouses, and best management practices. All baghouses at the finish mill will have a 10%
opacity limitation and a grain loading of 0.005 grains/dscf. [Last updated January 14, 2025]

5. BACT review regarding PM10 and PM2.5 sources cont.
Material Transfer, Sizing, and Storage BACT
The Leamington Plant has sources of fugitive emissions through raw material transfer. Materials
transferred include limestone and other raw materials, coal, clinker, and cement. These materials
are transferred by conveyor belt, screw conveyor, elevator, pneumatic conveyance or chutes via
gravity. At the Leamington Plant the fugitive emissions are enclosed at their transfer points and
routed to baghouses.

The following emission units are included in this category:
Limestone Crushing, Sizing, and Material Transfer;
Raw Material Transfer;
Coal Sizing and Transfer;
Existing Finish Mill;
Clinker Storage and Transfer;
Cement Storage and Truck and Rail Cement Loadout;
New Rail Loading and Loadout; and
New Clinker Reclaim Hopper Baghouse.

Generally, controls for these units have not changed or they are similar to current existing controls.
A full BACT analysis of each unit is included in Ash Grove's NOI and additional submitted
information. However, given that most controls remain unaltered, only the results of Step 5 -
Select BACT will be included here.

Limestone Crushing, Sizing, and Material Transfer
Subject to NSPS Subpart OOO opacity limits for existing sources.
Existing baghouses. No change from bag manufacturer's specifications.

Raw Material Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Coal Storage and Transfer
Existing Equipment. No change from bag manufacturer's specifications
20% Opacity

Clinker Storage and Transfer
Subject to NSPS Subpart F opacity limits:
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 14

10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Existing Finish Mill Grinding, Storage and Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Cement Storage and Truck and Rail Cement Loadout, New Rail Loadout
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

New Rail Loadout, controlled by baghouse
Emissions Limit - 0.005 gr/dscfm

New Clinker Reclaim Hopper, controlled by baghouse
Subject to NSPS Subpart F opacity limits:
10% opacity
Emissions Limit - 0.005 gr/dscfm [Last updated January 14, 2025]

6. BACT review regarding PM10 and PM2.5 sources cont.
PM10 and PM2.5 Fugitive Emissions
The following fugitive emissions sources will increase emissions of PM10 and PM2.5 as a result of
the Leamington Plant's proposed throughput increase. The sources addressed in the following
BACT analyses are primarily in the quarry, but also include emissions from roads and dumping of
raw materials within the plant boundary.

The sources evaluated are listed below:
Roads;
Loading and Unloading;
Stockpiles;
Bulldozing and Grading;
Disturbed Areas; and
Drilling and Blasting.

Ash Grove currently controls emissions from these processes, and generally, controls for these
units have not changed. A full BACT analysis of each unit is included in Ash Grove's NOI and
additional submitted information. However, given that most controls remain unaltered, only the
results of Step 5 - Select BACT will be included here.

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 15

Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

Stockpiles BACT
BACT shall consist of restricting fugitive emissions to the opacity standard of 20% opacity at the
property boundary. BACT for stockpiles will be achieved through applying good management
practices through its fugitive dust plan as appropriate.

Bulldozing and Grading BACT
BACT shall consist of restricting fugitive emissions from bulldozing and grading activities to no
more than 20% opacity, and that emissions are controlled with periodic watering of the disturbed
surface. The frequency of water application will depend on ambient weather conditions and
inherent moisture content of the material being moved.

Disturbed Areas BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. BACT for
disturbed areas will be achieved through best management practices, watering, scarification, and
revegetation.

Drilling and Blasting BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. This is achievable
through best management practices, shrouds, watering, and dust collection. [Last updated January
14, 2025]

7. BACT review regarding kiln system NOx emissions
Kiln System (Kiln, Raw Mill, and Coal Mill) - NOx BACT
Although there are physical changes to the kiln system, these changes are primarily related to
particulate emissions. NOx emissions are generated from the combustion of fuel - and no changes
in NOx emissions are expected from the kiln (hourly capacity to emit). The kiln NOx emissions will
remain the same as a result of upgrades to the SNCR system. The replacement of the various
components of the kiln system and portions of the preheater tower, along with new injection points,
will ensure that increased mixing of ammonia is achieved to enhance the SNCR system's ability to
reduce NOx and minimize ammonia slip. This will allow the Leamington Plant to maintain the NOx
hourly capacity to emit unchanged from current levels Leamington Plant Upgrade Project. At
present Ash Grove has no restriction on the amount of fuel combusted, only a limit on total NOx
generated, and with this project the allowed NOx PTE is decreasing from 1,352 tpy to 1,226 tpy.

Additional ammonia will be used in the existing SNCR system. While the SNCR system has
adequate capacity to accommodate the additional ammonia demand resulting from the system
upgrades, more ammonia ports are proposed to be added with the kiln system's proposed changes
of the equipment. The changes proposed to the kiln system will increase residence time and
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temperature which will improve the SNCR system's effectiveness to control NOx emissions and
minimize ammonia slip emissions to the atmosphere. No additional review of NOx BACT for the
kiln system is required under this proposal. [Last updated January 14, 2025]

8. BACT review regarding new finish mill heater emissions
Finish Mill Heater
The proposed finish mill will include a process heater to maintain a minimum temperature during
milling. The proposed heater will run on natural gas and is rated at 10 MMBtu/hr. Startup and
shutdown emissions from the heater are anticipated to be no greater than normal operation as the
process is simply a matter of bringing the heater to operating temperature. Emissions evaluated in
the BACT analysis for the finish mill heater include NOx, SO2, CO, and VOCs, PM10, and PM2.5.
Pollutants with identical control technologies are grouped together in the analysis.

NOx - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for NOx from units of this size range are as follows:
Ultra-Low-NOx Burners (ULNB);
Low NOx Burners;
Selective Catalytic Reduction (SCR);
Selective Noncatalytic Reduction (SNCR);
Good Combustion Practices; and
Use of Natural Gas.

Step 2 - Eliminate Technically Infeasible Options
Low exit temperatures render the use of SCR and SNCR ineffective. Particulate entrainment within
the finish mill could potentially foul (plug) the nozzles of ULNB. Low-NOx burners, the use of
natural gas as fuel and good combustion practices are all considered technically feasible.

Step 3 and Step 4 - Rank Remaining Control Technologies by Control Effectiveness and Evaluate
Most Effective Controls and Document Results
Since the three feasible control technologies are proposed for the finish mill heater, no detailed
economic, energy, and environmental impact evaluations were conducted. No ranking of control
effectiveness is required as all three controls are proposed.

Step 5 - Select BACT
BACT for NOx is the use of natural gas as fuel, good combustion practices and the use of Low NOx
burners.

CO, SO2, and VOC - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for CO, SO2, and VOC from units of this size are as follows:
Good Combustion Practices
Use of Natural Gas

The finish mill heater combusts natural gas. Related natural gas combustion emissions are
anticipated to be minimal.

Step 2 - Eliminate Technically Infeasible Options
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Both control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Both technologies offer intrinsic emission reductions from combustion. Since the technologies do
not compete, both technologies can and will be used simultaneously.

Step 4 - Evaluate Most Effective Controls and Document Results
Because both control technologies identified in Step 1 are proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for CO, SO2, and VOC are good combustion practices and the use of natural gas.

PM10 and PM2.5 BACT for the finish mill has been addressed in the PM10/PM2.5 sources section.
[Last updated January 14, 2025]

9. BACT review regarding SO2, VOC, and Lead Sources
The following BACT analysis is grouped by pollutants that will experience an increase in potential
emissions and the associated technically feasible control technologies. As such, the BACT analysis
is separated into SO2, VOC, and lead respectively with organic HAPs addressed with VOCs.

SO2 - Cement Kiln BACT
NSPS Subpart F - Standards of Performance for Portland Cement Plants, establishes emission
standards for cement kiln operations. Specifically, kilns constructed or reconstructed after June 16,
2008, are limited to 0.4 lbs SO2/ton clinker on a 30-day rolling average respectively. This limit is
an existing emission limit in the Leamington Plant's approval order and Title V. Ash Grove will
continue to achieve this emission limitation while achieving BACT for the kiln operations. Ash
Grove has reviewed the following sources to identify available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019); and

NSPS Subpart F as an affected emissions facility in 40 CFR 60.62(a)(4);

Portland Cement Association's Formation and Techniques for Control of Sulfur Dioxide and Other
Sulfur Compounds in Portland Cement Kiln Systems.

SO2 emissions are a result of oxidation of sulfur compounds in the rawmix and/or the coal used to
fire the kiln. However, the alkaline nature of the cement provides for direct absorption of SO2 into
the product, thereby mitigating the quantity of SO2 emissions in the exhaust stream.

Step 1 - Identify All Control Technologies
Control technologies identified for SO2 emissions from coal-fired kiln operations are as follows:
Baghouse or fabric filter;
Dry reagent injection prior to baghouse;
Wet scrubber;
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Process optimization; and
Good combustion practices.

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below:

1. Process Optimization 99%
2. Wet Scrubber 99%
3. Dry Reagent Injection 60%
4. Good Combustion Practices 30%
5. Baghouse Variable

Step 4 - Evaluate Most Effective Controls and Document Results
SO2 emissions are most effectively controlled by optimizing the process and utilizing the inherent
SO2 scrubbing properties of the kiln system itself. Although wet scrubbers alone can achieve equal
control efficiencies as process optimization, additional capital and operational expenses are
required for water consumption and wastewater discharge. Whereas process optimization achieves
the same control effectiveness and has the added benefit of reduced operational costs. Ash Grove
optimizes the kiln process by routing the exhaust from the kiln to a preheater and raw mill to
interact with the raw mix, thus creating an atmosphere similar to a dry scrubber system. Good
combustion practices also reduce SO2 formation with the added benefit of energy efficiency.

Step 5 - Select BACT
BACT for control of SO2 emissions from kiln operations shall consist of process optimization by
routing kiln exhaust to the preheater and raw mill, good combustion practices, and use of a
baghouse prior to exhausting to the atmosphere. As a modification of the kiln, 40 CFR 60.62(a)(4)
requires an emission limit of 0.4 pounds of sulfur dioxide (SO2) per ton of clinker on a
30-operating day rolling average. [Last updated January 14, 2025]

10. BACT review regarding SO2, VOC, and Lead Sources cont.
VOC - Cement Kiln BACT
VOCs are generated by incomplete combustion in the kiln. 40 CFR 63 Subpart LLL - NESHAP
from the Portland Cement Industry limits total hydrocarbon and total organic HAP emissions to 24
and 12 ppmv at 7% oxygen. Ash Grove will achieve or exceed these emission limitations while
achieving BACT for the kiln operations. Ash Grove has reviewed the following sources to identify
available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028); and

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for VOC emissions from coal fired kiln operations are as follows:
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Process optimization,
Good combustion practices

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below.

1. Process Optimization Variable
2. Good Combustion Practices Variable

Step 4 - Evaluate Most Effective Controls and Document Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove optimizes the
kiln process by capturing waste heat from the clinker cooler and routing to a kiln preheater. Good
combustion practices also reduce VOC formation with the added benefit of energy efficiency.
There are no adverse energy, environmental or cost impacts to consider with the use of this control
technology.

Step 5 - Select BACT
BACT for control of VOC emissions from kiln operations shall consist of process optimization by
routing kiln heat to the preheater and good combustion practices. An emission limit of 24 ppmv
VOC @ 7% O2 is imposed by NESHAP Subpart LLL.

VOC - Grinding Aid BACT
A grinding aid containing VOC is added to the new finish mill to disperse particles within the mill
and expose more surface area to grinding. An increase in grinding aid usage proportionally
increases potential VOC emissions because volatiles from the grinding aid are not combusted in
the kiln.

There is only one identified control option for limiting the VOC emissions from the grinding aid.
Process optimization is technically feasible. VOC emissions are most effectively controlled by
optimizing the process. Ash Grove proposes to install a vertical finish mill with this project. Due to
the new modern mill's efficiency, it is anticipated that a reduced amount of grinding aid will be
required for each ton of clinker ground. Ash Grove estimates total VOC emissions from the
grinding aid at 2.37 tpy.

Lead Emissions
The lead emissions are anticipated to increase as a result of the proposed increase in clinker
throughput with the Leamington Plant upgrade project. Lead emissions result from residual
amounts of lead in raw materials and fuel. Lead emissions will be controlled the same as PM,
therefore a separate top-down BACT analysis has not been conducted as the Leamington Plant has
applied the most effective controls. [Last updated January 14, 2025]

11. BACT review regarding Greenhouse Gases
GHG Background
On October 9, 2009, the mandatory GHG reporting regulation, referred to as 40 CFR 98, was
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published in the Federal Register. Through 40 CFR 98, the U.S. EPA established the GHG
Reporting Rule, which requires the annual reporting of GHG data and other relevant information
from large sources and suppliers in the United States. Monitoring through the GHG Reporting
Program (GHGRP) began in 2010, with the first reports due by March 31, 2011. Per 40 CFR
98.2(a)(1), any facility associated with cement production is subject to the GHGRP and must report
CO2e emissions. The CO2e is the sum of equivalent GHG emissions from CO2, CH4, and N2O,
with their respective global warming potentials (GWP) applied. Ash Grove's facility is subject to
GHG Reporting Rule and monitors CO2 emissions from its kiln with a continuous emissions
monitoring system (CEMs). On June 23, 2014, the U.S. Supreme Court held that required PSD
permits (based on emissions of non-GHG pollutants) may continue to require limitations on GHG
emissions based on the application of BACT as an "anyway source". The Leamington Plant
modification project is a major source for PSD for both PM10 and PM2.5, and GHGs are estimated
to be greater than 75,000 tpy and greater than zero on a mass basis; therefore, GHGs are evaluated
for BACT as an anyway source.

Cement Manufacturing GHG BACT
A BACT analysis has been conducted for CO2e emissions from the kiln system. For this GHG
BACT analysis, various control technologies or combinations of technologies were identified using
the RACT/BACT/LAER Clearinghouse, available literature including guidance published by EPA
and South Coast Air Quality Management District (SCAQMD), current air regulations, other
regulatory organizations, and engineering experience. In March 2011, EPA published GHG
permitting guidance, as well as a white paper on available and emerging technologies for reducing
GHG emissions from the Portland cement industry in October 2010. Additionally, EPA published a
series of videos on GHG permit training in December 2010. The SCAQMD published GHG BACT
guidance in 2021. Additional sources of information were reviewed and documented based on
publications from trade organizations and other governmental committees with GHG or carbon
reduction guidelines and/or recommendations.

EPA has defined in 40 CFR 86.1818-12(a) GHGs as a group of six gases: CO2, nitrous oxide
(N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF6). GHG emissions from the kiln result from calcination and fuel combustion.
Since the primary GHG emitted by a kiln is CO2, the BACT analysis focuses on CO2 emissions
from the kiln. Emissions of CH4 and N2O are minimal from cement kilns. Per EPA guidance, GHG
control technologies for consideration in a BACT analysis for Portland Cement Manufacturing
include:

Source-wide energy efficiency strategies;
Raw material substitution;
Blended cements;
Carbon capture utilization and storage; and
Fuel switching.
Other emerging technologies [Last updated January 14, 2025]

12. BACT review regarding Greenhouse Gases cont.
Step 1: Identify All Control Technologies
The CO2 emissions from a cement kiln are generated by the calcination process (conversion of the
calcium carbonate in limestone to calcium oxide) and by combustion of fuel in the kiln. Potential
control technologies to reduce these CO2 emissions for a cement kiln are addressed in EPA's white
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paper on Available and Emerging Technologies for Reducing GHG Emissions from the Portland
Cement Industry.

These technologies fall into three categories:
Energy Efficiency Improvements for the Clinker Production Process
Fuel Substitution
Carbon Capture and Sequestration

Step 2: Eliminate Technically Infeasible Options
Several potential energy efficiency improvements are technically feasible: Pre-heater/Pre-calciner
Kiln Process, Kiln Seal Management Program, Refractory Selection (Kiln Insulation), and Energy
Recovery from the Clinker Cooler. The use of alternative fuels such as natural gas, whole tires and
biofuel) is also technically feasible. Other control options, such as Use of Fluxes and Mineralizers,
Heat Recovery for Power - Cogeneration, Carbon Sequestration, Oxyfuel combustion, and
Post-combustion Capture have been deemed infeasible.

Step 3: Rank Remaining Control Technologies by Control Effectiveness
All four remaining control techniques are currently implemented at the Leamington Plant. This
permitting project incorporates energy efficiency improvements. Ash Grove has had a fuel
substitution program in place for several years, and this program is continually reviewed and
updated as new sources and types of fuel are identified.

Step 4: Evaluate Most Effective Controls and Document Results
Since all technically feasible energy efficiency improvements and changes to product composition
will be implemented, this section will focus on economic and environmental considerations of fuel
substitution to operate exclusively on natural gas.

Firing natural gas as the primary kiln fuel can reduce CO2 emissions from fuel combustion by as
much as 40%. However, studies have shown that use of natural gas as primary kiln fuel can result
in three times more NOx emissions than NOx emissions from coal firing. Creating more NOx to
reduce GHG emissions is undesirable as it is a precursor to both ozone and PM2.5. Fuel substitution
essentially trades emissions of one regulated pollutant for another. Estimated capital cost to switch
to natural gas fuel exceeds $25M. Implementing natural gas technology would provide incremental
public health and welfare benefit globally by reducing CO2 emissions, while increasing NOx
emissions and negatively impacting public health and welfare locally. Switching fuels to another
fossil fuel has finite potential to mitigate CO2 emissions.

Step 5: Select BACT
In addition to the proposed energy efficiency improvements addressed elsewhere in this BACT
analysis, BACT is a limit of 0.92-ton CO2e/ton clinker. Ash Grove will use a continuous emission
monitoring system (CEMS) for CO2 to demonstrate compliance with this limit. [Last updated
January 14, 2025]

13. BACT review regarding Leamington Plant Upgrade Project conclusion
The control processes and techniques covered in this BACT analysis have been reviewed by the
NSR Section of the UDAQ. Ash Groves proposed controls and associated emission limitations
represent BACT. Any emission limitations not expressed in an associated NSPS or NESHAP will
be included in the terms and conditions of this AO. A listing of all associated NSPS and NESHAP
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programs is also included in the Source Information section of this document under Applicable
Federal Programs. [Last updated December 13, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date
of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
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proper credit when notifying the Director, send the documentation to the Director, attn.: NSR
Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.

II.A.3
NEW
Stockpiles
Coal storage
Area: 1 acre
Annual throughput 20,000 tpy

AF and ARM stockpiles
Area: 0.25 acre
Annual throughput 8,000 tpy

II.A.4 Stationary Crusher
Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction
of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000
acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)

II.A.5 Raw Material Transfer
Crushed material is transported to raw material storage by belt B8. The raw material transfers
at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor
transfer point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total
filter area & water sprays. (pre-1983)

II.A.6 Material Handling
Conveyor belt systems, secondary feeders and screens, stacker system

II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit specific requirements

II.A.8 Belt Conveyor Transfer Baghouse
Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area
and 1,800 acfm total air flow, controls emissions from the conveyor belt that transfers the
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stacked material to the raw material silos.

II.A.9 Raw Material Silos
Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The
four silos are equipped with one common Fuller, plenum pulse baghouse (315.BF1) - 1,689 ft2
filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage).

II.A.10 Fifth Component Silo
Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse
(315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw
mill feed. This system includes vibrating feeders, a conveyor system, and surge bin.
Emissions are controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3,
316.BF4, 316.BF5) - each is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1
A/C ratio.

II.A.12 Cross-Belt Analyzer
Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6)

II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom
of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw
materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38).
The following equipment is installed: low-NOx burner, selective non-catalytic reduction
(SNCR) for NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued
mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric
monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct
for mercury adsorption capacity. The carbon injection system is not an emission point as it is
in an enclosed building.

II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

II.A.16 Two Kiln Feed Blending Silos
Raw material is blended in one of two blending silos prior to feeding the kiln. The blending
silos are controlled by one common Fuller, plenum pulse baghouse (411.BF1) - 1,351 ft2 filter
area; 7,160 acfm total air flow.

II.A.17 Blending Silo Elevators (2)
Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped
with a Fuller, pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow
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through stack E34.

II.A.18 Kiln Feed Alleviator
A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the
central material silo between the blending silos and the preheater. Raw feed is removed from
the system near the top of the preheater tower.

II.A.19 Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner.
The coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter
area; 1,700 acfm total air flow.

II.A.20 Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in
the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2):
19,500 acfm rated airflow with 3.75:1 A/C ratio

II.A.21 Clinker Cooler and Baghouse
Reconstructed grate type cooler used for cooling clinker from the kiln prior to transfer to
clinker storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) -
173,869 acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter
monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two
clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse
(419.BF8). The exhaust is routed to the clinker cooler stack.

II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions
generated when loading the east and west clinker silos and the out-of-spec silo are controlled
by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1):
1,800 acfm, that discharges into the clinker tunnel.

II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm, that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2)
Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers.
Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses
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(511.HP1 and new 511.HP2): 1,800 acfm each.

II.A.27 Gypsum Silo
Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2
total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust
during loading.

II.A.28 Clinker Tunnel Exitway
The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse
(511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel all discharge in the clinker tunnel.
Emissions are vented through the tunnel exitway.

II.A.29 Limestone Silo
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust
during loading. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement product. Dust
generated during milling is captured by a BHA, pulse jet baghouse (514.BF2) - 6,080 ft2 filter
area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding
stack).

II.A.31 Finish Mill (Ball Mill) Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized
cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA, pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow
controlling particulates from stack G55 (finish mill stack).

II.A.32
NEW
Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The
stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4)
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1,
525.BF1 thru 3)

II.A.33 Finish Cement Storage Silos
There are six storage and two interstice silos where the finished cement product is stored. A
single common Fuller, plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm
total air flow through stack H7 is located on top of the silos and is used to control emissions
during loading and unloading operations.

II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail
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shipping. This baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out
The cement loadout system located on the South side of the silos (truck load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF2) during unloading from the silos for truck
shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement
conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed
space inside the silos.

II.A.36
NEW
Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

II.A.37 MHO: Materials Handling Operation
Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1
& 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4;
512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.

II.A.38 LBS: Limestone Bypass System
Additional limestone is added to the clinker and gypsum by the limestone bypass system
(LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays
at the screen and material handling drop points.

II.A.39 GEN: Emergency Generators
One diesel-fired emergency generator (new)
Rating: 762 hp
(Kiln, Tier 3, permitted 2022)

Two natural gas-fired emergency generators
Rating: 304 hp
(Main office and control room, permitted in 2023)

One diesel-fired emergency generator
Rating: 560 hp
(Shipping, permitted 2023).

II.A.40 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14 inch knife gate, 8 inch knife gate, 8 inch air
slides, surge bin), and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm)
on the fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

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II.A.41
NEW
Miscellaneous Storage Tanks
One diesel storage tank (<2,000 gallons)
One gasoline storage tank (500 gallons)
Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Requirements on the Cement Plant:
II.B.1.a
NEW
The following limits shall not be exceeded:

A. Clinker production - 1,155,000 tons per rolling 12-month period

B. Used oil consumption - 85,724 gallons per rolling 12-month period

C. Limestone bypass material processed - 216,260 tons per rolling 12-month period.
[R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 25th day of each month using data from the previous 12 months.
Records shall be kept for all periods when the plant is in operation. Consumption and
production shall be calculated through use of the plant's acquisition system. [R307-401-8]

II.B.1.b
NEW
Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations:

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

SO2: 0.4 lbs per ton of clinker (3-hr average)

CO: 3,395 tons per rolling 12-month period, and 6,600 lbs/hr

NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average, and 1,233 tons per rolling
12-month period

Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is
400oF or less.

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Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)

THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)

CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)

PM: 0.02 lbs filterable PM per ton of clinker. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL,
R307-401-8]

II.B.1.c
NEW
A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR
60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust
emissions control plan shall be monitored to demonstrate that appropriate control measures are
being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of
the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall
be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in
the plan and that the source is operating in accordance with the submitted plan. For petitions
to approve alternative control measures, the permittee shall keep a copy of the submitted
petition and any approvals received. [40 CFR 60 Subpart Y]

II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area
source of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2). [40 CFR
63 Subpart LLL]

II.B.1.e
NEW
Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b
and II.B.1.d shall be performed as specified below:

A. Kiln/Raw Mill Stack
Pollutant Test Status Test Frequency
PM * #

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

B. Clinker Cooler (F31)
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Pollutant Test Status Test Frequency
PM + #

C. Testing Status (To be applied above)
* The initial testing has already been performed.

** The SO2 initial performance test was conducted on August 26, 2013.

*** The initial compliance test shall be conducted within the first 30 operating days of
operation in which the affected source operates using a CEMS.

# Test once every year. If performance testing would be required less than 15 operating days
after the Kiln has completed Startup after being down for more than 24 hours, then
performance testing may be deferred up to 15 operating days after completion of the Startup.
The Director may require testing at any time.

## Test at least once every two years. The Director may require testing at any time.

+ Initial testing is required within 180 days of startup of the reconstructed equipment

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must record the PM
CPMS output data for all periods when the process is operating, and use all the PM CPMS
data for calculations when the PM CPMS is not out-of-control. The owner/operator must
demonstrate continuous compliance by using all quality-assured hourly average data collected
by the PM CPMS for all operating hours to calculate the arithmetic average operating
parameter in units of the operating limit on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

+++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.e.1
NEW
Notification
The Director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The notification requirements for performance tests subject to 40
CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-165]

II.B.1.e.2
NEW
Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational
Safety and Health Administration (OSHA)- or Mine Safety and Health Administration
(MSHA)-approved access shall be provided to the test location. [R307-165]

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II.B.1.e.4
NEW
PM
40 CFR 60, Appendix A, Method 5 or 5I or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three (3) runs with
each run at least 120 minutes in duration and each run collecting a sample of 60 dry standard
cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.3
NEW
Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2. [R307-165]

II.B.1.e.5
NEW
Carbon Monoxide (CO)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.6
NEW
Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.7
NEW
Sulfur Dioxide (SO2)
40 CFR 60, Method 6 or 6C of Appendix A-4 or other EPA-approved method as acceptable to
the Director. [R307-165]

II.B.1.e.8
NEW
Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]

II.B.1.e.9
NEW
Total Hydrocarbons (THC)
Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL]

II.B.1.e.10
NEW
Mercury (Hg)
Continuous Emission or integrated sorbent trap monitoring (See Condition II.B.3.a). [40 CFR
63 Subpart LLL]

II.B.1.e.11
NEW
HCl
Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other
EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]

II.B.1.e.12
NEW
Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.13
NEW
Calculations
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director, to give the results in the specified units of the
emission limitation. [R307-165]

II.B.1.e.14
NEW
Existing Source Operation
For an existing source/emission point, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three years.
[R307-165]

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II.B.1.e.15
NEW
New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the maximum production rate listed in this AO. If the maximum AO
allowable production rate has not been achieved at the time of the test, the following
procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This new
allowable maximum production rate shall remain in effect until successfully tested at a higher
rate.

3) The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate (110%
of the new rate) will then be allowed if the test is successful. This process may be repeated
until the maximum AO production rate is achieved. [R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL.
[40 CFR 63 Subpart LLL]

II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times
of Dust Shuttle System operation to assist in the capture of Mercury emission. [R307-401-8]

II.B.1.h
NEW
Visible emissions from the following emission points shall not exceed the following values:

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

L. All baghouses - 10% opacity
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M. Fugitive dust - 20% opacity

N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y,
R307-401-8]

II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer
point is not required to conduct Method 22 visible emissions monitoring under this paragraph.
The enclosures for these transfer points must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

If any partially enclosed or unenclosed conveying system transfer point is located in a
building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to
40 CFR 60, according to the following:

(i) The owner/operator must conduct a monthly ten-minute visible emissions test of each
affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The
performance test must be conducted while the affected source is in operation.

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator may decrease the frequency of performance testing from monthly
to semi-annually for that affected source. If visible emissions are observed during any
semi-annual test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iii) If no visible emissions are observed during the semi-annual test for any affected source,
the owner/operator may decrease the frequency of performance testing from semi- annually to
annually for that affected source. If visible emissions are observed during any annual
performance test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iv) If visible emissions are observed during any Method 22 performance test, of Appendix
A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations,
recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60.
The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour
of any observation of visible emissions.

(v) If visible emissions from a building are monitored, the requirements of paragraphs (i)
through (iv) of this Condition apply to the monitoring of the building, and the owner/operator
must also test visible emissions from each side, roof, and vent of the building for at least ten
minutes. [R307-401]

II.B.1.j
NEW
Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed
0.005 gr/dscf:

520.BF1
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520.BF2
520.BF3
520.BF4
521.BF2
521.BF1
524.BF1
524.BF2
524.BF4
524.BF3
525.BF1
525.BF2
525.BF3
511.HP2
NRL_UPR
NRL_LWR. [R307-401-8]

II.B.1.j.1
NEW
To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration
through at least three (3) annual tests that the PM limits are not being exceeded, the
owner/operator may request approval from the Director to conduct stack testing less
frequently than annually. [R307-401-8]

II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive
dusts as dry conditions warrant or as determined necessary by the Director to maintain opacity
limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated to control fugitive dust. The application of
water or chemical treatment shall be used. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a damp/moist condition unless it is below freezing.
If chemical treatment is to be used, the plan must be approved by the Director. Records of
water and/or chemical treatment shall be kept for all periods when the plant is in operation.
The records shall include the following items: Instances of water and/or chemical application
to unpaved areas shall be recorded and maintained by the owner/operator. The ambient
temperature shall be recorded any time water should be applied but cannot due to freezing
conditions. [R307-401-8]

II.B.2.c
NEW
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

The sprays shall operate whenever dry conditions warrant meeting the required opacity
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limitations or as determined necessary by the Director. Water sprays shall not be required
during periods of freezing temperatures. [R307-401-8]

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation
of fugitive dusts as dry conditions warrant or as determined necessary by the Director.
[R307-401-8]

II.B.2.e
NEW
The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5
PM. [R307-401-8]

II.B.3 Continuous Emission Monitoring Requirements:
II.B.3.a
NEW
The owner/operator shall install, calibrate, maintain and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler.

A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the
missing data substitution procedures used by the UDAQ or the missing data substitution
procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate by the UDAQ.

B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period
including during each startup, shutdown, or malfunction.

C. The monitoring system shall comply with all applicable sections of R307-170, UAC; and
40 CFR 60, Appendix B.

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be
installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the
kiln/raw mill stack.

F. The owner/operator shall record the output of the system: including the quantity of NOx,
CO, O2 THC, Hg, HCl, and CO2 emissions at the kiln stack.

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source shall
continuously operate all required continuous monitoring devices and shall meet minimum
frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker
cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except
during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments,
the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a
PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the
results of the performance test demonstrating compliance with the filterable PM limit and
using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust
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the SSOL developed in accordance with the results of the most recent PM performance test
demonstrating compliance with the PM emission limit. The owner/operator shall use the PM
CPMS to demonstrate continuous compliance with the SSOL in accordance with the
requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

II.B.4 Fuel Limitations:
II.B.4.a
NEW
The owner/operator shall use only the following fuels in the kiln and pre-calciner:

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.

If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b
NEW
Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the
Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the
results of suitable tests giving data similar to a Proximate and Ultimate analysis of the
proposed coal additive. [R307-401-8]

II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal
additive. Approval is not required to change from one previously-approved coal additive to
another previously-approved coal additive. [R307-401-8]

II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily
heat input of the kiln and precalciner. The owner/operator may increase the average quantity
of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon
approval by the Director in accordance with the approval process described in Condition
II.B.4.b. [R307-401-8]

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II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel burning or process
installation not covered by New Source Performance Standards for sulfur emissions or
covered elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross
Btu heat input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input
for any oil except used oil. The sulfur content shall comply with all applicable sections of
UAC R307-203. [R307-203, R307-401-8]

II.B.4.c.1
NEW
Certification of fuels shall be either by the owner/operator's own testing or test reports from
the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be
available onsite. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials, UAC R307-203-1 (4)

A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be
used.

B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be
used.

C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85 are to be used. [R307-203]

II.B.4.d
NEW
The concentration/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight
3) Cadmium 2 ppm by weight
4) Chromium. 10 ppm by weight
5) Lead 100 ppm by weight
6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be
tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the burn tank and burned. [R307-401-8]

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II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned
in the rotary kiln:

A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than
five minutes in any 60-minute period

B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes
in any 60-minute period. [R307-401-8]

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the
Director. The calibration procedure and frequency shall be according to manufacturer's
specifications. Use of factory-calibrated thermocouples for temperature measurement is
approved. However, any other method of temperature measurement must be approved by the
Director prior to use. The monitoring equipment for both temperature and oxygen content
shall be located such that an inspector can at any time safely read the output. [R307-401-8]

II.B.5
NEW
Emergency Engine Requirements
II.B.5.a
NEW
The owner/operator shall only operate the emergency engines for testing and maintenance
purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency
operation. [R307-401-8]

II.B.5.b
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each emergency engine. [R307-401-8]

II.B.5.b.1
NEW
The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.5.b.2
NEW
To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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Page 39

PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN103030035-24 dated November 27, 2024
Is Derived From Source Submitted NOI dated November 30, 2022
Incorporates Additional Information Received dated April 26, 2023
Incorporates Additional Information Received dated September 26, 2023
Incorporates Additional Information Received dated July 23, 2024
Incorporates Additional Information Received dated October 25, 2024
Incorporates Additional Information Received dated November 25, 2024

REVIEWER COMMENTS

1. Comment regarding applicability of federal requirements:
New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable
by the best demonstrated technology as specified in the applicable provisions. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.

40 CFR 60, Subpart A (General Provisions)
All affected facilities subject to a source-specific NSPS are subject to the general provisions of
NSPS, Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires
initial notification, performance testing, recordkeeping, and monitoring, provides reference methods,
and mandates general control device requirements for all other subparts.

40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of
performance for affected facilities in Portland Cement Plants which have been constructed or
modified after August 17, 1971.

40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart
F: Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and
unloading systems. The Leamington coal mill is an in-line coal mill and considered an integral part
of the Leamington kiln. In-line coal mills are not subject to NSPS Subpart Y. Therefore, the coal mill
is addressed under NSPS Subpart F as part of the kiln system. The coal silos and conveying system
are subject to NSPS Subpart Y.

Ash Grove's proposed changes to the kiln system must be evaluated as to whether they trigger new
NSPS Subpart F obligations based on whether the proposed project is either a modification or a
reconstruction, as those terms are defined in NSPS Subpart A.

Ash Grove's proposed changes to the kiln system do not meet the definition of a reconstruction, nor
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 40

do they meet the definition of a modification for NOx. However, the changes meet the definition of a
modification for PM and SO2. Therefore, Ash Grove will comply with all relevant emission
standards; testing requirements; monitoring, recordkeeping, and reporting obligations that apply to
the Leamington kiln system as an existing source under NSPS Subpart F. Under NSPS Subpart A
and F, the clinker cooler is considered a reconstructed unit. Thus new limits will apply to this unit.
[Last updated January 14, 2025]

2. Comment regarding applicability of federal requirements cont.:
NSPS Subpart Y - Standards of Performance for Coal Preparation and Processing Plants
This subpart provides standards of performance for affected facilities in coal preparation and
processing plants that process more than 200 tons of coal per day.

The Leamington plant's coal silo and coal conveying system are existing affected facilities under
NSPS Subpart Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses
controlling affected facilities subject to match the limit in NSPS Subpart Y from 0.016 gr/dscf to
0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade Project. Since there are no proposed
modifications or reconstruction to the coal silo and coal conveying system, nothing about the
proposed upgrade project affects the existing applicability of NSPS Subpart Y.

NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
This subpart provides standards of performance for affected facilities located at fixed or portable
nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August
31, 1983, with additional requirements applicable to sources constructed on or after April 22, 2008.

As the crushing and screening system is controlled by baghouses and an increase in PM10 actual
emissions on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS.
Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the
Leamington Plant Upgrade Project.

Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1),
60.676(f), and 60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO
monitoring and recordkeeping requirements.

[Last updated January 14, 2025]

3. Comment regarding applicability of federal requirements cont.:
National Emission Standards for Hazardous Pollutants (NESHAPs)
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or
greater than 10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as
specified by each subpart. NESHAP apply to sources in specifically regulated industrial source
classifications (CAA Section 112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities
not regulated as a specific industrial source type. The Ash Grove Leamington Plant is a major source
of HAPs and thus is subject to certain NESHAP standards.

Subpart A - General Provisions
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January 21, 2025
Page 41

All affected sources are subject to the general provisions of Subpart A unless otherwise specified by
the source-specific NESHAP. Subpart A generally requires initial notification and performance
testing, recordkeeping, monitoring, provides reference methods, and mandates general control device
requirements for all other subparts as applicable.

Subpart LLL - Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry
This subpart establishes process/source specific emission limits for PM, VOC (expressed as total
hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and
gaseous HAP compounds by limiting PM and THC emissions because portions of such emissions
are USEPA-listed HAPs. Subpart LLL requires compliance with applicable emissions limits on and
after the initial startup of cement production. To further reduce emissions, Subpart LLL also
establishes operational requirements for the use of cement kiln dust (CKD), fly ash, fuel and control
equipment. Subpart LLL also specifies process/source specific emissions testing, monitoring,
recordkeeping, reporting, and compliance demonstration requirements. The compliance requirements
for the site are detailed in Approval Order Condition II.B.1.b. Ash Grove will continue to comply
with the requirements of Subpart LLL to demonstrate compliance. This cement kiln will remain an
existing source with respect to the kiln emission standards in Subpart LLL as this project does not
trigger the definition of a new source in Subpart LLL. New source standards apply only to affected
sources that were constructed or reconstructed after May 6, 2009.
[Last updated December 20, 2024]

4. Comment regarding PSD applicability analysis:
Ash Grove is proposing to increase the throughput of limestone from the quarry to supply the New
Finish Mill to increase the amount of low-carbon cement from the Leamington Plant. Additionally,
along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
modified, and the clinker cooler will be reconstructed. These changes are anticipated to result in an
increase in clinker production. Emission calculations for this project have been completed assuming
an increase in clinker production capacity while utilizing current fuel types. This will result in an
increase in the throughput of fuel.

The Leamington Plant is considered an existing major source under PSD based on potential
emissions of PM10, PM2.5, NOx, CO, SO2, and CO2e. If a major source undergoes a physical or
operational change, the facility must determine whether the project will be considered a major
modification. Per 40 CFR 52.21(b)(2)(i), in order to be a major modification, the project must result
in a significant emissions increase, and a significant net emissions increase.

As defined at 40 CFR 52.21(b)(40): Significant emissions increase means, for a regulated NSR
pollutant, an increase in emissions that is significant for that pollutant. Significant is further defined
to mean, in reference to a net emissions increase or the potential of a source to emit any of the
following pollutants, a rate of emissions that would equal or exceed the values outlined in 40 CFR
52.21(b)(23). If the increase in emissions from the project are not significant, a major modification
has not occurred.

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
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January 21, 2025
Page 42

increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

For all pollutants, the project emissions increase was calculated as the difference between the
projected actual emissions (PAE) after the proposed project and the actual emissions prior to the
project (baseline actual emissions or BAE).

Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
". . . projected actual emissions means the maximum annual rate, in tons per year, at which an
existing emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years
(12-month period) following the date the unit resumes regular operation after the project, or in any
one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit of that regulated NSR pollutant and full utilization of the unit would
result in a significant emissions increase or a significant net emissions increase at the major
stationary source." [Last updated January 14, 2025]

5. Comment regarding PSD applicability analysis cont.:
Ash Grove estimates that the projected actual production capacity following the project will be
1,155,000 tons of clinker per year and 1,341,266 tons of limestone per year. These capacities were
used to calculate projected actual emissions from the project using representative emission factors.
Additionally, to estimate emissions from material transfer baghouses, the actual flow rates and actual
projected hours were used as a basis for projected actual emissions.

Project Emission Calculations

Project emission increases from the kiln and coal mill systems are calculated for all criteria
pollutants based on emission factors that are derived from stack testing, CEMS data, or emission
factors (i.e., VOCs and Lead), and the associated projected incremental clinker increase.

NOx emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain
hourly capacity to emit and annual potential to emit at current levels. The kiln's NOx emissions rate
will not change as a result of the physical modifications proposed by the project.

Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission
factor and multiplied by the incremental increase in clinker production. The emission factor was
selected based on the average of the 24-month consecutive month emissions for 2020 and 2021. The
CO emissions will increase.

The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing
conducted at the plant. The SO2 emissions will increase.

VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production. VOC emissions will increase.

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 43

can be found in the original NOI and subsequent addendums submitted to UDAQ.

As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from
the proposed project, each increase of emissions from both existing and new sources shall be
summed together and compared to the PSD permitting thresholds. The increase of emissions is the
"positive" difference between the projected actual emissions and baseline actual emissions (projected
minus baseline).

New Emissions Sources

The actual to projected actuals calculation is not available to new emission units. For new emission
units, the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected
emissions are based on the new sources' potentials to emit. (40 CFR § 52.21(a)(2)(iv)(f)).

The new equipment proposed includes the New Finish Mill, a new rail and truck loading/loadout,
one (1) new clinker reclaim loading hopper with a dust collector and one (1) existing clinker reclaim
hopper with a dust collector, a new Clinker Cooler to replace the existing one, and a new kiln feed
alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions:

The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;

The finish mill heater was calculated based on its maximum firing capacity and flow rates; and

The fugitive emissions were calculated based on the projected annual throughput of the New Finish
Mill, the rail loadout, and clinker production. [Last updated January 14, 2025]

6. Comment regarding PSD applicability analysis cont.:
Existing Emission Sources

For the existing sources, the projected actual emissions are the maximum annual rates in tons per
year projected to occur during the next five (5) to ten (10) years if the existing sources' design
capacities increase. Ash Grove Leamington projected the actual emissions for the next five (5) years
based on the new kiln system producing an annual average of 3,250 tons of clinker per day.

Baseline actual emissions (BAE) are defined at 40 CFR 52.21(b)(48)(ii) as:

". . . baseline actual emissions means the average rate, in tons per year, at which the emissions unit
actually emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the 10-year period immediately preceding either the date the owner or operator
begins actual construction of the project, or the date a complete permit application is received by the
Administrator."

Ash Grove has selected to use the years 2020 and 2021 for each pollutant as the representative
baseline years.

In its NOI, Ash Grove calculated the emission increase from the project as being divided into two
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 44

phases. Phased construction projects are discussed in two sections of the federal PSD regulations -
40 CFR 52.21(j)(4) and 40 CFr 52.21(r)(2). UDAQ is not processing this project as a phased
construction project, nor did Ash Grove request such a determination. Therefore, Ash Grove
provided a summary table outlining the final change in emissions from this project:

Projected Actual Increase Compared to PSD threshold (tons per year)
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2e
BAE 76.64 39.64 1,187 6.87 3,315 55.47 641,385
PAE 203.15 113.47 1,226 45.87 3,414 72.07 1,067,984

Change in Emissions 126.51 73.83 39.00 39.00 99.00 16.59 426,598

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes

If the emissions increase is greater than the PSD significance threshold for a particular pollutant, Ash
Grove has the option of conducting a PSD review or continuing through the rest of the steps to
determine if it can "net" out of a PSD review. If the project increase is less than the PSD significant
threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant.

The change in emissions from the project exceeds the significant emission threshold for three
pollutants: PM10, PM2.5 and CO2e. Ash Grove elected to attempt to net out of a PSD major
modification for the remainder of the criteria pollutants.

Netting

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant
Upgrade Project and ends on the date the upgrade begins operation. Only PM10, PM2.5, CO2e are in
excess of SERs and therefore considered in the netting analysis.

Ash Grove estimated that the commencement of construction will be in December 2024. Therefore,
the contemporaneous period for this project is December 2019 through a projected date the project
upgrade begins operation. [Last updated January 21, 2025]

7. Comment regarding PSD applicability analysis cont.:
Contemporaneous Decreases

Ash Grove replaced an existing kiln emergency drive engine with a USEPA Tier 4 diesel engine in
2022. Concurrently, Ash Grove requested an increase in the capacity of 1L Cement. Additionally,
Ash Grove submitted a minor modification NOI air permit application on June 12, 2023, which
proposes replacing the shipping generator during the contemporaneous period. The kiln emergency
drive engine and shipping generator are both higher EPA tier ratings therefore result in decreases for
PM10 and PM2.5. These changes were approved in AO DAQE-AN103030033-24 issued March 21,
2024.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 45

Contemporaneous Increases

As stated above, the existing kiln emergency drive engine and shipping generator were permitted and
replaced in 2024. This resulted in an increase in emissions of CO2e.

The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout
in an effort to improve truck traffic at the loadout. The modification to add these dust collectors to
the loadout was included in DAQE-AN103030029-19. The baghouses are three (3) levels up in the
silos' enclosed space (approximately 40 feet). Both dust collectors vent directly into the interior of
the silo structure and are not vented into the atmosphere. Ash Grove requests to remove these
baghouses from its existing permitted emissions inventory. Therefore, these emissions have been
documented in the netting analysis as zero emissions.

Also included in DAQE-AN103030033-24 were two new natural gas-fired emergency generators
and increases in stockpiles, material handling and road emissions.

Could Have Been Accommodated Emissions

In calculating project emissions increase, USEPA allows the exclusion of existing
production/emissions rates that could have been accommodated during the baseline period. These
"could have been accommodated" emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as
follows:

". . . Shall exclude, in calculating any increase in emissions that results from the particular project,
that portion of the unit's emissions following the project that an existing unit could have
accommodated during the consecutive 24-month period used to establish the baseline actual
emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project,
including any increased utilization due to product demand growth;"

Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the
exclusion of existing production and emissions rates that could have been accommodated during the
baseline period, it has elected not to use this exclusion at this time. Therefore, calculation of the
"could have been" accommodated emissions have not been included in this application's
applicability analysis.

The increase from the project is added to the contemporaneous decreases and contemporaneous
increases. The resulting calculation is then compared to the PSD significance threshold to determine
if a significant net emissions increase has occurred. [Last updated January 14, 2025]

8. Comment regarding PSD applicability analysis cont.:
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2 e
Contemporaneous Inc. 1.61 0.45 0.41 0 0.27 0.07 51.74

Contemporaneous Dec. -1.54 -3.97 -0.48 -0.02 -0.27 -0.09 0

Change in Emissions 125.02 69.21 38.93 38.98 99.00 16.58 426,650

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes
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Page 46

The results of the netting analysis conclude that both a significant emissions increase and a
significant net emissions increase in both particulates (PM10 and PM2.5) and CO2e will occur from
this project. Thus, the project must be reviewed as a PSD major modification. [Last updated January
14, 2025]

9. Comment regarding emission calculations:
This engineering review includes updated potential emission totals for both criteria and HAP
emissions. The potential-to-emit (PTE) values were calculated using updated values for clinker
produced and raw material inputs. BACT emission factors and limitations were used where
appropriate. Certain emission totals (NOx, SO2 and CO) were set based on avoiding a significant
increase in emissions. Specifically, the projected actual increase was set at just under the baseline
actual emissions + the significance level. As these emissions are monitored by CEM, UDAQ agrees
with this approach. Please see the netting analysis for further details on calculation of projected
actual increase. The NOx hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project.

CO2e emissions were calculated using the GHG emission factor calculated from 40 CFR Part 98
Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in Subpart A Table
A-1.

To calculate the PTE tons per year, the maximum hours (i.e., 8760) per year and the source's
emissions rates were multiplied with the throughputs. The potential throughputs have been updated
at UDAQ's request so that PAE is equal to PTE and represents the equipment's maximum design
potential.

Additional emission calculations based on source testing and monitoring, and EPA's compilation of
air emission factors AP-42. [Last updated January 14, 2025]

10. Comment regarding requirements for PSD review:
In addition to the permitting requirements of R307-401-5 through R307-401-8, there are additional
requirements under PSD that must be addressed:

1. Calculation of ambient air increments (40 CFR 52.12(c)), ambient air ceilings ((40 CFR 52.12(d)),
source impact analysis (40 CFR 52.12(k)), air quality models (40 CFR 52.12(l)) - these items are
addressed in the modeling memo DAQE-MN103030032-24.

2. Stack heights (40 CFR 52.12(h)) - Ash Grove's stack heights have been reviewed with respect to
good engineering practice and operate in a vertical unrestricted manner.

3. Control technology review (40 CFR 52.12(j)) - this is addressed in the BACT analysis section of
this review document.

4. Air quality analysis: preapplication analysis (40 CFR 52.12(m)) - this is covered in the PSD
applicability and netting analysis sections of this review document, ambient monitoring and
background data collection is also included in the modeling memo DAQE-MN103030032-24.

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 47

grain loading limit included in II.B.1.j.1 represents the required post-construction monitoring.
6. Source information (40 CFR 52.12(n)) - this is addressed under the requirements of R307-401-5
and was submitted by Ash Grove as part of the NOI package.

7. Additional impact analysis (40 CFR 52.12(o)) - these requirements cover soils, vegetation, growth
and visibility concerns. They are discussed in the modeling memo DAQE-MN103030032-24.

8. Federal land manager review (40 CFR 52.12(p)) - UDAQ provided initial notification to all
federal land managers upon receipt of the original NOI package. The draft permit and engineering
review will also be provided to the federal land managers 60-days prior to initiation of public
comment for their further review.

9. Public participation (40 CFR 52.12(q)) - this project will have a 30-day public comment period.

10. Source obligation (40 CFR 52.12(r)) - this requirement discusses source compliance with other
parts of the CAA, which is addressed within UDAQ's permitting rules in R307.
[Last updated January 14, 2025]

11. Comment regarding changes in equipment list:
The equipment list is being updated for clarity as well as adding new pieces of equipment. The
following changes are taking place:

The naming scheme is being updated to remove the numerical code from the unit designation. This
code generally referred to the associated control device and not to the emitting unit itself. This can
cause confusion especially when the same code was applied to multiple pieces of equipment.
Instead, the control devices (typically baghouse dust collectors) will be identified in the description
along with the appropriate numerical code.

Specific changes are as follows:

1. The kiln description has been updated

2. Clinker Cooler description has been updated to include a larger pulse jet baghouse.

3. The clinker storage silos, east and west clinker belts, clinker belt transfer and clinker tunnel have
been consolidated to avoid confusion

4. The north and south cement loadout exhausts now vent internally into the cement storage silos

5. The dust shuttle system has been consolidated into one line item, most identifiers removed from
subsystem descriptions as only two baghouses serve as exhaust points.

6. A new finish mill with heater has been added. Included in the description are the thirteen total
baghouses for dust control (1 main stack, 2 transfer points, 10 nuisance dust filters)

7. A new clinker reclaim hopper has been added. Both reclaim hoppers are controlled by baghouses
with updated identifiers

8. A new rail and truck loading/unloading system with two baghouses has been added.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 48

[Last updated December 20, 2024]

12. Comment regarding changes in conditions:
As a result of this project, several conditions will be added or changed. This includes one new
general condition (I.8). Changes to the equipment list (section II.A) will be addressed in a separate
reviewer comment:

I.8 - Adding this general condition to cover the requirements of R307-401-18 Eighteen Month
Review. The status of construction/installation of the new equipment shall be reviewed after
18-months.

II.B.1.a - Clinker production increases to 1,155,000 tpy
Use of limestone bypass material increases to 215,260 tpy

II.B.1.b - The NOx limit on the kiln decreases to 1,223 tpy, CO emissions from the kiln decrease to
3,395 tpy,
Adding a new CO2e limit of 0.92 tons CO2e/ton of clinker produced
PM limit on the clinker cooler decreased to 0.02 lb PM (filterable)/ton of clinker
Rule reference updated to include 40 CFR 60 Subpart F, and R307-401-8

II.B.1.e - Initial testing on the clinker cooler is now required within 180 days of startup of the unit.
Monitoring of CO2 from the kiln will be by CEM.
Formatting changes on paragraph designated ++, improve clarity, include reference to CO2
monitoring, define CPMS

II.B.1.e.4 - Update to address general PM monitoring and reference R307-401-8

II.B.1.e.14 - New condition to address new or reconstructed emission units monitoring requirements,
applicable to the clinker cooler and new finish mill.

II.B.1.h - Adding references to Subpart OOO units (limestone processing) with updated opacity
limits.
Adding 20% opacity limit on coal transfer and storage
Adding property boundary opacity limit of 20%
Updating rule reference to include Subpart OOO

II.B.1.j - New condition to address outlet grain loading limits on new baghouses, One identical limit,
15 total new baghouses.

II.B.1.j.1 - Monitoring on new baghouses as per II.B.1.e.4, added an allowance to test less frequently
than annually with three successful tests.

II.B.3.a - Updating formatting to add clarity and include reference to CO2 CEM

II.B.5 - New conditions on emergency engines, diesel fuel sulfur limits, hour of operation
restrictions, non resettable hour meter

[Last updated December 20, 2024]
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 49

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 51

TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

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DAQE-MN103030032-24

M E M O R A N D U M

TO: John Jenks, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler
Dave Prey, Air Quality Modeler

DATE: December 12, 2024

SUBJECT: Modeling Analysis Review for the Ash Grove Cement Company – Leamington Plant,
located in Millard County, Utah
___________________________________________________________________________________
This is a Major Modification to a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Ash Grove Cement Company (Applicant) has submitted a Notice of Intent (NOI) air permit
application for a project referred to as the Leamington Upgrade Project (LUP). The proposed
upgrade project includes the construction and installation of new pollution control equipment, new
emission sources, and modifications to existing emission sources. Emission increases associated
with the LUP constitute a major modification to a Prevention of Significant Deterioration (PSD)
source subject to PSD permitting regulations. PSD regulations require the Applicant to include and
air quality impact analysis (AQIA) of the proposed projects impact on the EPA national ambient air
quality standards (NAAQS) and air quality related values (AQRV) as part of a complete NOI.

This report prepared by the New Source Review (NSR) modeling staff contains a review of the
Applicant’s Air Quality Impact Analysis (AQIA) including the methodology, data sources,
assumptions, and modeling results for comparison with State and Federal air quality standards. The
AQIA was reviewed and referenced in this report include the:
● Notice of Intent – Ash Grove Cement Leamington Plant PSD Notice of Intent Air Permit
Application, dated November 30, 2022.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

0 0
Jason Krebs

DP
DAQE-MN103030032-24
Page 2

II. APPLICABLE RULES AND ANALYSES

A Utah Air Quality Rules

The UDAQ has determined that the Applicant’s NOI is subject to the following rules for conducting an
AQIA:

R307-401 Permits: New and Modified Sources
R307-405 Permits: Major Sources Located in Attainment or Unclassified Area (PSD)
R307-406-2 Visibility – Source Review
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutant Impacts in Attainment Areas

B. Applicability

The proposed increases in emissions of PM10 and PM2.5 exceed the emission thresholds outlined in R307-
406-5 and R307-410-4. Therefore, an AQIA consistent with the requirements of R307-405-6, R307-406-
2, and R307-410-3 was submitted as part of the Applicant’s NOI. R307-410-3 establishes the U. S.
Environmental Protection Agency (US EPA) – Guideline on Air Quality Models as a formal basis for
defining the scope of the analysis, as well as the model’s construction. The results of the AQIA are
required to demonstrate the proposed project’s impact on state and federal air quality standards,
acceptable levels of impact, and action triggering thresholds referenced or listed in R307-401-6(2), R307-
401-6(3), R307-403-3(1), R307-403-5(1)(a), R307-405-4(1), R307-405-6. Annual emissions for criteria
pollutants requiring an AQIA are listed in Table 1.

Table 1: Ash Grove Leamington Proposed Net Emissions Increase

Criteria
Pollutants
Net Emission
Increase (TPY)
AQIA Trigger
Level (TPY) AQIA Required?
PM10 126.6 15 Yes
PM2.5 70.3 10 Yes

C. Required Analyses

R307-405 requires the Applicant to perform a pre-construction modeling analysis for all pollutants
emitted in a significant quantity. The purpose of the analysis is to determine if the extent of the source’s
impact is significant enough to warrant an on-site measurement of the ambient background concentration
levels. This data is included in the NAAQS analysis to represent the quality of the air prior to the
construction of the proposed project. The Applicant included a pre-construction modeling analysis for
PM10 and PM2.5 as part of the NOI. The pre-construction modeling analysis was also used to determine if
the proposed emissions would result in a significant impact to the environment, thereby triggering the
requirement for a cumulative analysis of the proposed project and other nearby existing sources.

R307-401-8 requires the Division to determine that the proposed project will comply with the NAAQS
prior to the issuance of an Approval Order (AO). R307-405(7) requires the Applicant to perform a
DAQE-MN103030032-24
Page 3
NAAQS analysis for all pollutants emitted in a significant quantity. The analysis is to include all
emissions at the proposed site under normal operating conditions using maximum anticipated short-term
release and annual release rates. Consistent with UDAQ policy, a cumulative analysis to include the
ambient background concentration and any contribution from other nearby sources is not required if the
proposed project’s impact does not exceed the PSD Class II Significant Impact Level (SIL).

R307-401-8 also requires the Division to determine that the proposed project will comply with PSD
increments prior to the issuance of an AO. Under R307-405(6), the Applicant is required to perform a
PSD Class I and II increment consumption analysis for all pollutants emitted in significant quantities.
The purpose of this analysis is to quantify any degradation in air quality since the major source baseline
date. The analysis is to include all increment consuming emissions at the proposed site under normal
operating conditions using maximum anticipated short-term and annual release rates. A cumulative
analysis to include contributions associated with growth and other increment consuming sources is not
required if the proposed project’s impact does not exceed the PSD Class I or II SIL.

R307-410-5 requires the Applicant to perform a HAPs analysis for any pollutant emitted above a
pollutant specific emission threshold value. This analysis is to include all emissions of the pollutants
resulting from the proposed modification under normal operating conditions using maximum anticipated
one-hour release rates. The Applicant did not trigger modeling for HAPs.

R307-406-2 requires the Applicant to perform a plume blight analysis. A plume blight analysis is required
to determine if plumes emanating from the proposed project would be visible inside any Class I area
within 50 kilometers of the source. The plume blight analysis is to include all emissions of NO2, SO4, and
PM10.

Under R307-405-16, an AQRV analysis is performed which evaluates regional haze and acid deposition
impacts at each of the Class I areas within 300 kilometers of the source. A regional haze analysis is
required to determine if the plumes would reduce the visual range of an observer inside the Class I area.
The regional haze analysis is to include all emissions of SO2, NOX and PM10. The deposition analysis
examines impacts from sulfur and nitrogen compounds at the Class I areas, and is based on all emissions
of SO2 and NOX. The Federal Land Managers use the Q/D approach to determine whether a PSD project
should provide detailed AQRV impact analyses, where: Q/D= [ H2SO4 + SO2 + NOx + PM10 emissions
(tpy)]/ distance (km). If Q/D is less than 10, no AQRV analysis is required.

R307-405 requires the Applicant to perform a soils and vegetation analysis. The analysis should quantify
the effects of pollutants on soils and vegetation near the highest impact location and in areas where
sensitive plant species may be impacted.

III. ON-SITE PRE-CONSTRUCTION MONITORING

A. Meteorological Data

Consistent with the US EPA - Meteorological Monitoring Guidance for Regulatory Modeling
Applications, one year of on-site data was collected using a 50-meter tower during the period October 1,
2021 through September 30, 2022. Parameters collected on-site included wind speed and direction,
temperature, delta-T, and solar radiation.

DAQE-MN103030032-24
Page 4

B. Ambient Pollutant Data

A preliminary analysis was conducted to determine the necessity for pre-construction ambient pollutant
monitoring. The results indicate that predicted concentrations of PM10 and PM2.5 exceed the monitoring
trigger level listing in the rule. A continuous PM10/PM2.5 monitor with filter based samplers was
installed near the northern edge of the Applicants property boundary, and collected particulate matter
from October 1, 2021 through September 30, 2022.

IV. MODEL SELECTION

The EPA-AERMOD dispersion modeling system is the preferred model specified in the US EPA –
Guideline on Air Quality Models to predict air pollutant concentrations in the near field (within 50
kilometers of the source). The US EPA - CALPUFF - Version 5.8 model is the preferred model to predict
concentrations in the far field (long range transport conditions beyond 50 kilometers from the source).

V. MODELING INPUTS AND ASSUMPTIONS

A. Technical Options

The regulatory default options were selected in AERMOD by the Applicant to quantify all concentrations.

B. Urban or Rural Area Designation

A review of the appropriate 7.5-minute quadrangles determined that the area should be classified as
“rural” for air modeling purposes.

C. Topography/Terrain

The Plant is at an elevation of 4,950 feet with nearby terrain features that have an effect on concentration
predictions.

a. Zone: 12
b. Location: UTM (NAD83): 397000 meters East, 4379850 meters North

D. Ambient Air

It was determined that the Plant boundary used in the AQIA meets the State’s definition of an ambient air
boundary.

E. Receptor and Terrain Elevations

The modeling domain has simple and complex terrain features in the near field. Therefore, receptor
points representing actual terrain elevations from the area were used in the analysis.

The far-field modeling domain consisted of a rectangular region covering all Class I areas within Utah,
and extending 50 kilometers beyond this area so that the model can account for re-circulation of the
plume.

DAQE-MN103030032-24
Page 5

F. Emission Rates and Release Parameters

The emission estimates and source parameters used in AERMOD for all proposed emission sources at the
site are presented in the NOI.

Speciated emission rates and source parameters used in the CALPUFF modeling are presented in Table 2.

Table 2: CALPUFF Emission Rates

Source
LCC Coordinates Modeled Emission Rates
Easting Northing SO2 SO4 NOX HNO3 NO3 SOA PMC SOIL EC
(m) (m) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr)
317.BF3 -1289410 -3738 52.81 5.03 307.58 0.00 0.00 5.03 2.60 2.90 0.11
419.BF1 -1289314 -3631 0.00 0.00 0.00 0.00 0.00 0.55 1.51 1.61 0.06
41B.BF2 -1289389 -3663 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.68 0.00
N1_FM2 -1289526 -3414 0.00 0.00 0.00 0.00 0.00 0.00 1.65 3.95 0.00
414.BF1N -1289407 -3683 0.00 0.00 0.00 0.00 0.00 0.00 0.10 0.25 0.00
2FM_HTR -1289528 -3415 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.08 0.00
514.BF1 -1289451 -3675 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.70 0.00
COMBO -1289424 -3668 0.00 0.00 0.00 0.00 0.00 0.00 1.37 5.72 0.00
FM2_CMB -1289454 -3439 0.00 0.00 0.00 0.00 0.00 0.00 0.50 1.21 0.00

Total Lb/hr 52.81 5.03 307.58 0.00 0.00 5.58 8.32 17.10 0.17
Hrs/Yr 8760 8760 8760 8760 8760 8760 8760 8760 8760
Ton/yr 231.3 22.0 1347.2 0.0 0.0 24.4 36.4 74.9 0.8

Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
317.BF3 POINT 4902.8 41.2 135.0 488 10.10 3.35
419.BF1 POINT 4891.2 18.3 60.0 388 6.36 2.90
41B.BF2 POINT 4895.2 68.6 224.9 294 17.83 0.74
N1_FM2 POINT 4832.0 49.7 163.0 363 40.08 1.40
414.BF1N POINT 4896.1 76.8 251.9 353 9.91 0.70
2FM_HTR POINT 4832.0 49.7 163.0 363 40.08 1.40
514.BF1 POINT 4889.5 39.6 130.0 294 11.86 0.91
COMBO POINT 4904.2 13.3 43.7 276 9.76 0.32
DAQE-MN103030032-24
Page 6
FM2_CMB POINT 4832.0 30.6 100.3 294 11.40 0.37

G. Building Downwash

The Applicant used the US EPA Building Profile Input Program (BPIP) to determine Good Engineering
Practice (GEP) stack heights and cross-sectional building dimensions for input into the model.

H. Ambient Background Concentrations

Millard County is in attainment for all criteria pollutants. The NAAQS analyses for PM2.5 and PM10 used
monitoring data collected on site during the pre-construction monitoring analysis. The background values
used in the NAAQS analysis are presented in Table 3.

Table 3: Background Concentrations

Pollutant Averaging
Period
Background
Concentration
(μg/m3)
PM10 24-hour 65.4
PM2.5 24-hour 10.2
Annual 4.2

I. Meteorological Data Processing

For the AERMOD model, on-site horizontal and vertical wind speed, direction, solar radiation and,
temperature data was combined with National Weather Service (NWS) upper air data collected at the Salt
Lake City International Airport (SLCIA) for the same period using the US EPA AERMET processing
system.

Meteorological data used for the CALPUFF modeling analysis consisted of 3 years (2018-2020) of data
developed by the Forest Service. The grid was 708 km (east-west) by 492 km (north-south) with a
resolution of 12 kilometers.

VI. RESULTS AND CONCLUSIONS

The Applicant performed a series of analyses to estimate the impact from the proposed project. Modeling
results and conclusions from the review of the analyses are outlined in detail below.

A. Pre-Construction Monitoring and Significant Impact Modeling

The Applicant performed a preliminary criteria pollutant analysis of the proposed modification. This
analysis indicated that increases in concentration levels of PM2.5 and PM10 were greater than the Class II
SIL, and therefore, a cumulative analysis for these pollutants was required.

DAQE-MN103030032-24
Page 7

B. NAAQS Analysis

The Applicant performed a modeling analysis to determine if the combined impact from the proposed
source, other industrial sources operating in the area, and ambient background would comply with the
NAAQS. The NAAQS analysis was reviewed by the Division and determined to be consistent with the
requirements of R307-410-3. Table 4 provides a comparison of the Applicant’s predicted air quality
concentrations and the NAAQS.

Table 4: Model Predicted NAAQS Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-hour 28.3 5 65.4 0 93.7 150 62.5%
PM2.5 24-hour 9.6 1.2 10.2 0 19.8 35 56.6%
Annual 4.4 0.3 4.2 0 8.6 9 95.6%
* Note: Only included other sources and background if source impact was above Class II SIL

C. PSD Class II Increments

The Applicant performed an analysis to determine if the impact from the proposed source would comply
with PSD Class II increments. The analysis was reviewed by the Division and determined to be
consistent with the requirements of R307-410-3. Table 5 provides a comparison of the predicted
concentrations and the PSD Class II increment.

Table 5: Model Predicted PSD Class II Increment Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Nearby
Sources*
Total Increment Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
PM10 Annual 8.1 1 0 8.1 25 32.4%
24-hour 28.3 5 0 28.3 30 94.3%
PM2.5 24-hour 6.1 1.2 0 6.1 9 67.8%
Annual 2.4 0.3 0 2.4 4 60.0%

D. Hazardous Air Pollutants

DAQE-MN103030032-24
Page 8
The Applicant performed an analysis to determine if HAP modeling is required. The analysis was
reviewed by the Division and determined to be consistent with the requirements of R307-410-3. The
analysis indicated that HAP modeling was not triggered by this modification, and therefore no HAP
modeling was performed.

E. PSD Class I Increment Consumption Analysis

The Applicant performed a CALPUFF analysis to determine if the impact from the proposed source along
with other increment consuming sources would comply with federal PSD Class I increments. The
analysis was reviewed by the Division and determined to be consistent with the requirements of R307-
410-3. The results for all Class I areas within 300 kilometers are provided in Table 6.

Table 6: Model Predicted PSD Class I Increment Concentrations

Air Period Prediction
Class I
Significant
Impact
Level
Other
Sources* Total Increment Percent
Pollutant (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
Capitol Reef
NO2 Annual 0.0018 0.1 2.5
SO2
3-Hour 0.0494 1 25
24-
Hour 0.0150 0.2 5
Annual 0.0008 0.1 2
PM2.5
24-
Hour 0.0430 0.27 2
Annual 0.0021 0.05 1
PM10
24-
Hour 0.0444 0.3 8
Annual 0.0021 0.2 4
Arches
NO2 Annual 0.0008 0.1 2.5
SO2
3-Hour 0.0408 1 25
24-
Hour 0.0102 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0522 0.27 2
Annual 0.0018 0.05 1
DAQE-MN103030032-24
Page 9
PM10
24-
Hour 0.0531 0.3 8
Annual 0.0019 0.2 4
Canyonlands
NO2 Annual 0.0010 0.1 2.5
SO2
3-Hour 0.0354 1 25
24-
Hour 0.0100 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0577 0.27 2
Annual 0.0019 0.05 1
PM10
24-
Hour 0.0591 0.3 8
Annual 0.0020 0.2 4
Bryce
NO2 Annual 0.0006 0.1 2.5
SO2
3-Hour 0.0369 1 25
24-
Hour 0.0082 0.2 5
Annual 0.0003 0.1 2
PM2.5
24-
Hour 0.0189 0.27 2
Annual 0.0010 0.05 1
PM10
24-
Hour 0.0194 0.3 8
Annual 0.0010 0.2 4
Zion
NO2 Annual 0.0011 0.1 2.5
SO2
3-Hour 0.0293 1 25
24-
Hour 0.0105 0.2 5
Annual 0.0005 0.1 2
PM2.5
24-
Hour 0.0266 0.27 2
Annual 0.0011 0.05 1
PM10 24-
Hour 0.0271 0.3 8
DAQE-MN103030032-24
Page 10
Annual 0.0012 0.2 4
* Note: Only included other increment consuming sources if source impact was above Class I SIL

Since the proposed project’s model predicted impacts at the Class I areas were less than the PSD Class I
significance levels, a cumulative analysis was not warranted.

DAQE-MN103030032-24
Page 11
F. Visibility – Plume Blight
Since the Class I areas are greater than 50 kilometers from the source, a plume blight analysis using
VISCREEN was not required.

G. Visibility – Regional Haze

The results of the Q/D analysis for the emissions increase was less than 10 but the FLMs wanted the
entire source included in the Q term. The results of including the total emissions resulted in a Q/D >10,
so an AQRV analysis was performed for visibility and acid deposition. The results shown in Table 7
indicate that the impacts are below the 0.5 Deciview (DV) threshold established by the National Park
Service, indicating that no further analysis is required.

Table 7: CALPUFF Visibility Results

Class I Area Year Maximum
Delta DV
98th
Percentile
change in
DV
#
Days
#
Days Threshold
(DV)
Below
Threshold
> 1 > 0.5
2018 0.248 0.06 0 0 0.5 Yes
Arches 2019 0.291 0.054 0 0 0.5 Yes
2020 0.216 0.106 0 0 0.5 Yes
2018 0.223 0.081 0 0 0.5 Yes
Canyonlands 2019 0.312 0.068 0 0 0.5 Yes
2020 0.186 0.085 0 0 0.5 Yes
2018 0.059 0.03 0 0 0.5 Yes
Bryce 2019 0.081 0.045 0 0 0.5 Yes
2020 0.071 0.03 0 0 0.5 Yes
2018 0.183 0.074 0 0 0.5 Yes
Capital Reef 2019 0.196 0.092 0 0 0.5 Yes
2020 0.126 0.078 0 0 0.5 Yes
2018 0.069 0.04 0 0 0.5 Yes
Zion 2019 0.123 0.039 0 0 0.5 Yes
2020 0.102 0.057 0 0 0.5 Yes

DAQE-MN103030032-24
Page 12

H. Acid Deposition

The Applicant performed a deposition analysis on impacts within the Class I areas. Results of the
analysis indicate that the impacts are below the deposition threshold (DAT) established by the National
Park Service, indicating that no further analysis is required

Table 8: CALPUFF Deposition Results for Highest Year

Class I Area
Total
Nitrate
Deposition
Total
Sulfate
Deposition
Deposition
Analysis
Threshold
(kg/ha/yr) (kg/ha/yr) (kg/ha/yr)
Canyonlands 0.0006 0.0003
0.005
Zion 0.0004 0.0002
Arches 0.0006 0.0003
Bryce 0.0006 0.0002
Capitol Reef 0.0011 0.0005

I. Soils and Vegetation Analysis

The Applicant performed an analysis to determine the extent of impacts from the proposed source on soil
and vegetation. Results of the analysis are presented in a supplemental document titled “Soil and
Vegetation Impact Analysis for the Leamington, UT Facility, June 29, 2023”. The analysis indicated that
predicted concentrations compared against the secondary NAAQS at several sensitive receptors would not
result in an adverse impact on soils and vegetation in the vicinity of the proposed project.

DP/JK:jg

DAQE-IN103030032-25

January 22, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Mr. Nelson:

Re: Intent to Approve: Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — ) A A v A ? A D @ A w D D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — ) A A v A ? A D @ A w D D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ash Grove Cement Company Ash Grove Cement Company - Leamington Cement Plant

Mailing Address Physical Address
P.O. Box 38069 Highway 132
Leamington, UT 84638 Leamington, UT 84638

Source Contact UTM Coordinates
Name: Cody Watkins 397000 m Easting
Phone: [phone] 4380100 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3241 (Cement, Hydraulic)

SOURCE INFORMATION
General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried on site),
are correctly proportioned, ground, and mixed and then fed into a rotating kiln. The kiln alters the
materials and recombines them into small stones called cement clinker. The clinker is cooled and ground
with gypsum and additional limestone into a fine powdered cement. The final product is stored on site for
later shipping. The major sources of air emissions are from the combustion of fuels for the kiln operation,
from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source of
emissions of PM2.5, PM10, NOx, CO, HAPs, and GHG. It is a minor source of SO2 emissions.
NSR Classification
Major PSD Modification

Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
DAQE-IN103030032-25
Page 4

Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

These changes result in increases in actual emissions but decreases in most potential emissions. There will
be an increase in the potential emissions of VOCs and greenhouse gases.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
DAQE-IN103030032-25
Page 5

Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
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I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
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II.A.4 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)
II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area, and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, stacker systems. II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit-specific requirements.
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total air flow controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter
area; 9,865 acfm total air flow, controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are
controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each
is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6). II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The
following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for
NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.
II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low-pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

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II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow through stack
E34.
II.A.18 Kiln Feed Alleviator A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the central material silo between the blending silos and the preheater. Raw feed is removed from the system near the top of the preheater tower.
II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The
coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter area;
1,700 acfm total air flow.
II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker
storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1): 1,800 acfm that discharges into the clinker tunnel.
II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
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II.A.27 Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during loading.
II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel, all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during loading. 512.BF3 (1,000 acfm) is located on top of the silo. II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement products. Dust generated
during milling is captured by a BHA pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).

II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates from stack G55 (finish mill stack).
II.A.32 Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4).
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1 thru 3).

II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total air flow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations.
II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This
baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

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II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.
II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023)
II.A.40 Dust Shuttle System A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides, surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the
fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

II.A.41 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons) Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
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II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)
THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)
CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)
PM: 0.02 lbs filterable PM per ton of clinker.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR 60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to approve alternative control measures, the permittee shall keep a copy of the submitted petition and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source
of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2).
[40 CFR 63 Subpart LLL]

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II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must record the PM CPMS output data for all periods when the process is operating and use all the PM CPMS data for calculations when the PM CPMS is not out of control. The owner/operator must demonstrate continuous compliance by using all quality-assured hourly average data collected by the PM CPMS for all operating hours to calculate the arithmetic average operating parameter in units of the operating limit on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
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II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

II.B.1.e.3 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-165]
II.B.1.e.4 PM 40 CFR 60, Appendix A, Method 5, or 5I, or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three runs, with each
run at least 120 minutes in duration and each run collecting a sample of 60 dry standard cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165]
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II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
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II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
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II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer point, is not required to conduct Method 22 visible emissions monitoring under this paragraph. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator may decrease the frequency of performance testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
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II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: Instances of water and/or chemical application to unpaved areas shall be recorded and maintained by the owner/operator. The ambient temperature shall be recorded any time water should be applied but cannot due to freezing conditions. [R307-401-8]
II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

The sprays shall operate whenever dry conditions warrant meeting the required opacity
limitations or as determined necessary by the Director. Water sprays shall not be required during
periods of freezing temperatures.

[R307-401-8]

DAQE-IN103030032-25
Page 18

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

C. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the kiln/raw mill stack

F. The owner/operator shall record the output of the system: including the quantity of NOx, CO, O2, THC, Hg, HCl, and CO2 emissions at the kiln stack

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an
affected source shall continuously operate all required continuous monitoring devices
and shall meet minimum frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.

[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]
II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments, the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the results of the performance test demonstrating compliance with the filterable PM limit and using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust the SSOL developed in accordance with the results of the most recent PM performance test demonstrating compliance with the PM emission limit. The owner/operator shall use the PM CPMS to demonstrate continuous compliance with the SSOL in accordance with the requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

DAQE-IN103030032-25
Page 19

II.B.4 Fuel Limitations: II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke F. Fuel Oil
G. Used Oil Fuel

H. Synthetic Fuel
I. Wood
J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal additive.
Approval is not required to change from one previously approved coal additive to another
previously approved coal additive. [R307-401-8]
II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily heat input of the kiln and precalciner. The owner/operator may increase the average quantity of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon approval by the Director in accordance with the approval process described in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

DAQE-IN103030032-25
Page 20

II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight
A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation
C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit-no less than 1500oF for more than five minutes in any 60-minute period B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
DAQE-IN103030032-25
Page 21

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the Director. The calibration procedure and frequency shall be according to manufacturer's specifications. Use of factory-calibrated thermocouples for temperature measurement is approved. However, any other method of temperature measurement must be approved by the Director prior to use. The monitoring equipment for both temperature and oxygen content shall be located such that an inspector can at any time safely read the output. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall only operate the emergency engines for testing and maintenance purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency operation. [R307-401-8]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.5.b.2 To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From Source Submitted NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-IN103030032-25
Page 22

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-GN103030032H-25

January 22, 2025

Via Certified Mail 70190700000208349772

Don Shepherd
National Park Service
Air Resources Division
7333 W Jefferson Ave
Lakewood, CO 80235
[e-mail]

Dear Mr. Shepherd:

RE: Notice of Publication for Ash Grove Cement Company - Leamington Cement Plant – CDS A;
MACT (Part 63), Compliance Assurance Monitoring (CAM), Title V (Part 70) Major Source,
Major Criteria Source, Major HAP Source, Attainment Area, NSPS (Part 60),
Project Number: N103030032

On January 22, 2025, the Director has completed his review of a Prevention of Significant Deterioration
project submitted by Ash Grove Cement Company. Attached to this letter are the draft Approval Order
document (Intent to Approve) and the full engineering review. Following a 60-day review by the Federal
Land Managers, this project will be submitted for a 30-day public comment period. Written comments
received by the Division at this same address during these comment periods will be considered in making
the final decision on the approval/disapproval of the proposed Approval Order. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director at the Division in writing, a hearing
will be held in accordance with R307-401-7, UAC.

If you have any questions, please contact John Jenks, who may be reached at [phone].

Sincerely,

Jon L. Black, Manager
New Source Review Division

Enclosures: Engineering Review
Modeling Memo
Intent to Approve

JLB:JJ:jg
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

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State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
RN103030032
January 21, 2025
Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]
Dear Josh Nelson,
Re: Engineer Review:
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032
Please review and sign this letter and attached Engineer Review (ER) within 10 business days.
For this document to be considered as the application for a Title V administrative amendment, a
Title V Responsible Official must sign the next page.
Please contact John Jenks at [phone] if you have any questions or concerns about the ER.
If you accept the contents of this ER, please email this signed cover letter to John Jenks at
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 1

[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the
DAQ will consider any comments received and will issue the Approval Order.

If you do not respond to this letter within 10 business days, the project will move forward
without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue
an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 2

OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible
Official, as defined in R307-415-3, must sign the statement below. THIS IS STRICTLY
OPTIONAL.

If you do not want the Engineer Review to be considered as an application to administratively
amend your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will
require submittal of a separate Operating Permit Application to revise the Title V permit in
accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document:
Title V Operating Permit Application Due Dates clarifies the required due dates for Title V
operating permit applications and can be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality

“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate
and complete and request that this Approval Order be considered as an application
to administratively amend the Operating Permit.”

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 3

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N103030032
Owner Name Ash Grove Cement Company
Mailing Address P.O. Box 38069
Leamington, UT, 84638

Source Name Ash Grove Cement Company- Leamington Cement
Plant
Source Location Hwy 132
Leamington, UT 84638

UTM Projection 397000 m Easting, 4380100 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3241 (Cement, Hydraulic)

Source Contact Cody Watkins
Phone Number [phone]
Email [e-mail]

Billing Contact Cody Watkins
Phone Number 385.225.0615
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 30, 2022
Date of Accepted Application November 28, 2024

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 4

SOURCE DESCRIPTION

General Description
Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried
on site), are correctly proportioned, ground and mixed, and then fed into a rotating kiln. The kiln
alters the materials and recombines them into small stones called cement clinker. The clinker is
cooled and ground with gypsum and additional limestone into a fine powdered cement. The final
product is stored on site for later shipping. The major sources of air emissions are from the
combustion of fuels for the kiln operation, from the kiln, and from the clinker cooling process.
The Leamington cement plant is a major source for emissions of PM2.5, PM10, NOx, CO, HAPs
and GHG. It is a minor source of SO2 emissions.

NSR Classification:
Major PSD Modification

Source Classification
Located in Attainment Area,
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Proposal
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower, various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 6

These changes result in increases in actual emissions, but decreases in most potential emissions.
There will be an increase in the potential emissions of VOC and greenhouse gases.

EMISSION IMPACT ANALYSIS
The complete modeling review is located in DAQE-MN103030032-24. [Last updated January 14, 2025]

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 7

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 8

Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 9

Review of BACT for New/Modified Emission Units

1. BACT review regarding the Leamington Plant Upgrade Project
Any major stationary source or major modification subject to PSD review must undergo an
analysis to ensure the use of BACT. The requirement to conduct a BACT analysis is set forth in 40
CFR 52.21. Similarly, Utah requires the installation of BACT for all sources of air pollution under
R307-401-5(2)(d)), BACT is defined in 40 CFR 52.21 (and R307-401-2) as:

". . . best available control technology means an emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for each pollutant subject to regulation under
Act which would be emitted from any proposed major stationary source or major modification
which the Administrator, on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such source or modification
through application of production processes or available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion techniques for control of such
pollutant . . ."

Therefore, a BACT analysis is required for each new or physically modified emission unit for each
pollutant that exceeds an applicable PSD significant emission rate (SER). Since the PM10 and PM2.5
emissions from the proposed project exceed the applicable PSD SER, a BACT analysis is required
to assess the required levels of control for these pollutants. Because the CO2e emissions are subject
to regulation as a result of the proposed project resulting in an increase of 75,000 tons or more per
year CO2e, a BACT analysis is also required for that pollutant. Note that HAPs listed under CAA
Section 112(b)(1) are excluded from NSR (New Source Review) or PSD (i.e., BACT) review.

In a memorandum dated December 1, 1987, the United States Environmental Protection Agency
(EPA) stated its preference for a "top-down" BACT analysis. After determining if any New Source
Performance Standard (NSPS) is applicable, the first step in this approach is to determine, for the
emission unit in question, the most stringent control available for a similar or identical source or
source category. If it can be shown that this level of control is technically, environmentally, or
economically infeasible for the unit in question, then the next most stringent level of control is
determined and similarly evaluated. This process continues until the BACT level under
consideration cannot be eliminated by any substantial or unique technical, environmental, or
economic objections.

Presented below are the five basic steps of a top-down BACT review as identified by the EPA.
Step 1 - Identify All Control Technologies
Step 2 - Eliminate Technically Infeasible Options
Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Step 4 - Evaluate Most Effective Controls and Document Results
Step 5 - Select BACT

Ash Grove has elected to follow this methodology and based the BACT review on each individual
pollutant. The complete BACT analysis follows. [Last updated January 14, 2025]

2. BACT review regarding PM10 and PM2.5 Sources
PM10 and PM2.5 Modified Equipment
The existing kiln precalciner, preheater, and alleviator system are proposed to be modified, and the
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 10

kiln's ID fan and clinker cooler fans are proposed to be replaced, which will result in increased
airflow. Additionally, the clinker cooler baghouse will be converted from a plenum pulse to a pulse
jet baghouse. These modifications are projected to result in a net increase of potential PM10 and
PM2.5 emissions.

Kiln Upgrade BACT
The rotary cement kiln is the core of the cement manufacturing process, transforming the blended
raw materials or "rawmix" into clinker through pyro processing. Emissions from the kiln occur
from fuel combustion plus the physical and chemical reactions needed to transform the rawmix
into clinker. This project involves process and energy efficiency improvements and an increase in
kiln production, resulting in an increase of PM10 and PM2.5 emissions. This section specifically
addresses filterable PM10 and PM2.5. The condensable fraction is represented with the other
precursors as applicable to proposed emission increases.

The Leamington Plant's Kiln is subject to NSPS, Subpart F for particulate. Therefore, a BACT
analysis addresses applicability of the proposed changes to the kiln system to NSPS and review of
the RBLC. A summary of the resources reviewed include the following:

NSPS Subpart F - Standards of Performance for Portland Cement Plants establishes emission
standards for cement kiln operations. Specifically, kilns modified after June 16, 2008, are limited to
0.07 lbs PM/ton of clinker produced.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028) and
Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from kiln operations are as follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM emissions are most effectively controlled using a collection system with enclosures routed to
baghouses providing up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Ash Grove
has selected technology with the highest control efficiency, so there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 11

Step 5 - Select BACT
Ash Grove proposes that BACT for PM10 and PM2.5 emissions from the kiln consist of a collection
system routed to a baghouse or fabric filter that complies with NSPS Subpart F's emission standard
for a modified source. BACT for the Leamington Plant's kiln are 10% opacity and 0.07 lb of
PM/ton (NSPS Subpart F emission standard) of clinker.
[Last updated January 14, 2025]

3. BACT review regarding PM10 and PM2.5 sources cont.
Clinker Cooler Upgrade BACT
The clinker cooler reduces the temperature of the clinker exiting the kiln. It is necessary to reduce
clinker temperature before it enters the finish mill to maintain product quality and reduce wear and
tear on equipment. The clinker cooler is equipped with a heat exchanger that captures waste heat
and transfers it to the kiln preheater for process and energy efficiency. Emissions from the clinker
cooler are vented to a baghouse. The Leamington Plant's clinker cooler is also subject to NSPS
Subpart F for particulate. Ash Grove's proposed changes to the clinker cooler meet the definition of
a reconstruction under NSPS. Therefore, in order to meet the requirements of NSPS Subpart F, Ash
Grove will be required to meet a limit of 0.02 lb of PM/ton of clinker.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from clinker cooler operations are as
follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM10 and PM2.5 emissions are most effectively controlled using a collection system with enclosures
routed to a baghouse, which can achieve up to 99.9% control efficiency. Other technologies such as
wet scrubbers, cyclones and ESPs are feasible, but provide lower control efficiencies than a
baghouse. Because the most efficient control technology is proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for PM10 and PM2.5 emissions from the clinker cooler is a collection system routed to a
baghouse or fabric filter. In order to meet the requirements of NSPS Subpart F, Ash Grove will
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meet a reduced emission limit of 0.02 lb of PM/ton of clinker. A 10% opacity limit is also
applicable. [Last updated January 14, 2025]

4. BACT review regarding PM10 and PM2.5 sources cont.
New Finish Mill BACT
The proposed Plant upgrade include adding a second finish mill. The new finish mill will use an
energy efficient vertical roller mill assisted with a grinding aid. A total of five (5) point sources are
planned for the finish mill. In accordance with NSPS Subpart F, emissions from finish mill are
restricted to 10% opacity. Ash Grove has reviewed the following sources to identify available
control technologies.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);12 and

Region 8 General Permit for Concrete Batch Plants.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 emissions from plant material handling operations are as
follows:
Baghouse / Fabric Filter;
Best Management & Operational Practices;
Cyclone;
ESP;
Enclosure;
Water Application (Watering); and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
With the exception of water application, all options are technically feasible. Water application is
eliminated as clinker exiting the kiln along with additives in the finish mill must remain dry to
maintain product quality. Therefore, it is technically infeasible to water material in the finish mill.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Enclosure 50-90%
5. Cyclone 20-70%
6. Best Management & Operational Practices varies

Step 4 - Evaluate Most Effective Controls and Document Results
Baghouses provide the highest emission control efficiency, controlling up to 99.9% of PM
emissions from finish mill equipment. After baghouses, using a wet scrubber or ESP provides
similar PM control. Notably, baghouses, scrubbers, and ESPs require enclosures to aid in capturing
emissions and ducting to the control. Therefore, optimal PM emission control can be achieved
through implementing both baghouses and enclosures where feasible. Plant material sizing and
handling is currently done using a series of buildings and enclosures routed to baghouse controls.
Various silos storing material inputs are also equipped with fabric filters. As the highest ranked
technology is applied, there are no adverse energy, environmental or cost impacts to consider with
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the use of these control technologies. Thus, no further analysis is required under EPA's top-down
BACT approach.

Step 5 - Select BACT
BACT for finish mill PM10 emissions is compliance with NSPS Subpart F, Standards of
Performance for Portland Cement Manufacturing where applicable. Ash Grove will achieve BACT
for PM10 emissions from finish mill equipment through the implementation of enclosures,
baghouses, and best management practices. All baghouses at the finish mill will have a 10%
opacity limitation and a grain loading of 0.005 grains/dscf. [Last updated January 14, 2025]

5. BACT review regarding PM10 and PM2.5 sources cont.
Material Transfer, Sizing, and Storage BACT
The Leamington Plant has sources of fugitive emissions through raw material transfer. Materials
transferred include limestone and other raw materials, coal, clinker, and cement. These materials
are transferred by conveyor belt, screw conveyor, elevator, pneumatic conveyance or chutes via
gravity. At the Leamington Plant the fugitive emissions are enclosed at their transfer points and
routed to baghouses.

The following emission units are included in this category:
Limestone Crushing, Sizing, and Material Transfer;
Raw Material Transfer;
Coal Sizing and Transfer;
Existing Finish Mill;
Clinker Storage and Transfer;
Cement Storage and Truck and Rail Cement Loadout;
New Rail Loading and Loadout; and
New Clinker Reclaim Hopper Baghouse.

Generally, controls for these units have not changed or they are similar to current existing controls.
A full BACT analysis of each unit is included in Ash Grove's NOI and additional submitted
information. However, given that most controls remain unaltered, only the results of Step 5 -
Select BACT will be included here.

Limestone Crushing, Sizing, and Material Transfer
Subject to NSPS Subpart OOO opacity limits for existing sources.
Existing baghouses. No change from bag manufacturer's specifications.

Raw Material Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Coal Storage and Transfer
Existing Equipment. No change from bag manufacturer's specifications
20% Opacity

Clinker Storage and Transfer
Subject to NSPS Subpart F opacity limits:
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10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Existing Finish Mill Grinding, Storage and Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Cement Storage and Truck and Rail Cement Loadout, New Rail Loadout
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

New Rail Loadout, controlled by baghouse
Emissions Limit - 0.005 gr/dscfm

New Clinker Reclaim Hopper, controlled by baghouse
Subject to NSPS Subpart F opacity limits:
10% opacity
Emissions Limit - 0.005 gr/dscfm [Last updated January 14, 2025]

6. BACT review regarding PM10 and PM2.5 sources cont.
PM10 and PM2.5 Fugitive Emissions
The following fugitive emissions sources will increase emissions of PM10 and PM2.5 as a result of
the Leamington Plant's proposed throughput increase. The sources addressed in the following
BACT analyses are primarily in the quarry, but also include emissions from roads and dumping of
raw materials within the plant boundary.

The sources evaluated are listed below:
Roads;
Loading and Unloading;
Stockpiles;
Bulldozing and Grading;
Disturbed Areas; and
Drilling and Blasting.

Ash Grove currently controls emissions from these processes, and generally, controls for these
units have not changed. A full BACT analysis of each unit is included in Ash Grove's NOI and
additional submitted information. However, given that most controls remain unaltered, only the
results of Step 5 - Select BACT will be included here.

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
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Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

Stockpiles BACT
BACT shall consist of restricting fugitive emissions to the opacity standard of 20% opacity at the
property boundary. BACT for stockpiles will be achieved through applying good management
practices through its fugitive dust plan as appropriate.

Bulldozing and Grading BACT
BACT shall consist of restricting fugitive emissions from bulldozing and grading activities to no
more than 20% opacity, and that emissions are controlled with periodic watering of the disturbed
surface. The frequency of water application will depend on ambient weather conditions and
inherent moisture content of the material being moved.

Disturbed Areas BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. BACT for
disturbed areas will be achieved through best management practices, watering, scarification, and
revegetation.

Drilling and Blasting BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. This is achievable
through best management practices, shrouds, watering, and dust collection. [Last updated January
14, 2025]

7. BACT review regarding kiln system NOx emissions
Kiln System (Kiln, Raw Mill, and Coal Mill) - NOx BACT
Although there are physical changes to the kiln system, these changes are primarily related to
particulate emissions. NOx emissions are generated from the combustion of fuel - and no changes
in NOx emissions are expected from the kiln (hourly capacity to emit). The kiln NOx emissions will
remain the same as a result of upgrades to the SNCR system. The replacement of the various
components of the kiln system and portions of the preheater tower, along with new injection points,
will ensure that increased mixing of ammonia is achieved to enhance the SNCR system's ability to
reduce NOx and minimize ammonia slip. This will allow the Leamington Plant to maintain the NOx
hourly capacity to emit unchanged from current levels Leamington Plant Upgrade Project. At
present Ash Grove has no restriction on the amount of fuel combusted, only a limit on total NOx
generated, and with this project the allowed NOx PTE is decreasing from 1,352 tpy to 1,226 tpy.

Additional ammonia will be used in the existing SNCR system. While the SNCR system has
adequate capacity to accommodate the additional ammonia demand resulting from the system
upgrades, more ammonia ports are proposed to be added with the kiln system's proposed changes
of the equipment. The changes proposed to the kiln system will increase residence time and
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temperature which will improve the SNCR system's effectiveness to control NOx emissions and
minimize ammonia slip emissions to the atmosphere. No additional review of NOx BACT for the
kiln system is required under this proposal. [Last updated January 14, 2025]

8. BACT review regarding new finish mill heater emissions
Finish Mill Heater
The proposed finish mill will include a process heater to maintain a minimum temperature during
milling. The proposed heater will run on natural gas and is rated at 10 MMBtu/hr. Startup and
shutdown emissions from the heater are anticipated to be no greater than normal operation as the
process is simply a matter of bringing the heater to operating temperature. Emissions evaluated in
the BACT analysis for the finish mill heater include NOx, SO2, CO, and VOCs, PM10, and PM2.5.
Pollutants with identical control technologies are grouped together in the analysis.

NOx - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for NOx from units of this size range are as follows:
Ultra-Low-NOx Burners (ULNB);
Low NOx Burners;
Selective Catalytic Reduction (SCR);
Selective Noncatalytic Reduction (SNCR);
Good Combustion Practices; and
Use of Natural Gas.

Step 2 - Eliminate Technically Infeasible Options
Low exit temperatures render the use of SCR and SNCR ineffective. Particulate entrainment within
the finish mill could potentially foul (plug) the nozzles of ULNB. Low-NOx burners, the use of
natural gas as fuel and good combustion practices are all considered technically feasible.

Step 3 and Step 4 - Rank Remaining Control Technologies by Control Effectiveness and Evaluate
Most Effective Controls and Document Results
Since the three feasible control technologies are proposed for the finish mill heater, no detailed
economic, energy, and environmental impact evaluations were conducted. No ranking of control
effectiveness is required as all three controls are proposed.

Step 5 - Select BACT
BACT for NOx is the use of natural gas as fuel, good combustion practices and the use of Low NOx
burners.

CO, SO2, and VOC - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for CO, SO2, and VOC from units of this size are as follows:
Good Combustion Practices
Use of Natural Gas

The finish mill heater combusts natural gas. Related natural gas combustion emissions are
anticipated to be minimal.

Step 2 - Eliminate Technically Infeasible Options
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Both control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Both technologies offer intrinsic emission reductions from combustion. Since the technologies do
not compete, both technologies can and will be used simultaneously.

Step 4 - Evaluate Most Effective Controls and Document Results
Because both control technologies identified in Step 1 are proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for CO, SO2, and VOC are good combustion practices and the use of natural gas.

PM10 and PM2.5 BACT for the finish mill has been addressed in the PM10/PM2.5 sources section.
[Last updated January 14, 2025]

9. BACT review regarding SO2, VOC, and Lead Sources
The following BACT analysis is grouped by pollutants that will experience an increase in potential
emissions and the associated technically feasible control technologies. As such, the BACT analysis
is separated into SO2, VOC, and lead respectively with organic HAPs addressed with VOCs.

SO2 - Cement Kiln BACT
NSPS Subpart F - Standards of Performance for Portland Cement Plants, establishes emission
standards for cement kiln operations. Specifically, kilns constructed or reconstructed after June 16,
2008, are limited to 0.4 lbs SO2/ton clinker on a 30-day rolling average respectively. This limit is
an existing emission limit in the Leamington Plant's approval order and Title V. Ash Grove will
continue to achieve this emission limitation while achieving BACT for the kiln operations. Ash
Grove has reviewed the following sources to identify available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019); and

NSPS Subpart F as an affected emissions facility in 40 CFR 60.62(a)(4);

Portland Cement Association's Formation and Techniques for Control of Sulfur Dioxide and Other
Sulfur Compounds in Portland Cement Kiln Systems.

SO2 emissions are a result of oxidation of sulfur compounds in the rawmix and/or the coal used to
fire the kiln. However, the alkaline nature of the cement provides for direct absorption of SO2 into
the product, thereby mitigating the quantity of SO2 emissions in the exhaust stream.

Step 1 - Identify All Control Technologies
Control technologies identified for SO2 emissions from coal-fired kiln operations are as follows:
Baghouse or fabric filter;
Dry reagent injection prior to baghouse;
Wet scrubber;
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Process optimization; and
Good combustion practices.

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below:

1. Process Optimization 99%
2. Wet Scrubber 99%
3. Dry Reagent Injection 60%
4. Good Combustion Practices 30%
5. Baghouse Variable

Step 4 - Evaluate Most Effective Controls and Document Results
SO2 emissions are most effectively controlled by optimizing the process and utilizing the inherent
SO2 scrubbing properties of the kiln system itself. Although wet scrubbers alone can achieve equal
control efficiencies as process optimization, additional capital and operational expenses are
required for water consumption and wastewater discharge. Whereas process optimization achieves
the same control effectiveness and has the added benefit of reduced operational costs. Ash Grove
optimizes the kiln process by routing the exhaust from the kiln to a preheater and raw mill to
interact with the raw mix, thus creating an atmosphere similar to a dry scrubber system. Good
combustion practices also reduce SO2 formation with the added benefit of energy efficiency.

Step 5 - Select BACT
BACT for control of SO2 emissions from kiln operations shall consist of process optimization by
routing kiln exhaust to the preheater and raw mill, good combustion practices, and use of a
baghouse prior to exhausting to the atmosphere. As a modification of the kiln, 40 CFR 60.62(a)(4)
requires an emission limit of 0.4 pounds of sulfur dioxide (SO2) per ton of clinker on a
30-operating day rolling average. [Last updated January 14, 2025]

10. BACT review regarding SO2, VOC, and Lead Sources cont.
VOC - Cement Kiln BACT
VOCs are generated by incomplete combustion in the kiln. 40 CFR 63 Subpart LLL - NESHAP
from the Portland Cement Industry limits total hydrocarbon and total organic HAP emissions to 24
and 12 ppmv at 7% oxygen. Ash Grove will achieve or exceed these emission limitations while
achieving BACT for the kiln operations. Ash Grove has reviewed the following sources to identify
available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028); and

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for VOC emissions from coal fired kiln operations are as follows:
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Process optimization,
Good combustion practices

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below.

1. Process Optimization Variable
2. Good Combustion Practices Variable

Step 4 - Evaluate Most Effective Controls and Document Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove optimizes the
kiln process by capturing waste heat from the clinker cooler and routing to a kiln preheater. Good
combustion practices also reduce VOC formation with the added benefit of energy efficiency.
There are no adverse energy, environmental or cost impacts to consider with the use of this control
technology.

Step 5 - Select BACT
BACT for control of VOC emissions from kiln operations shall consist of process optimization by
routing kiln heat to the preheater and good combustion practices. An emission limit of 24 ppmv
VOC @ 7% O2 is imposed by NESHAP Subpart LLL.

VOC - Grinding Aid BACT
A grinding aid containing VOC is added to the new finish mill to disperse particles within the mill
and expose more surface area to grinding. An increase in grinding aid usage proportionally
increases potential VOC emissions because volatiles from the grinding aid are not combusted in
the kiln.

There is only one identified control option for limiting the VOC emissions from the grinding aid.
Process optimization is technically feasible. VOC emissions are most effectively controlled by
optimizing the process. Ash Grove proposes to install a vertical finish mill with this project. Due to
the new modern mill's efficiency, it is anticipated that a reduced amount of grinding aid will be
required for each ton of clinker ground. Ash Grove estimates total VOC emissions from the
grinding aid at 2.37 tpy.

Lead Emissions
The lead emissions are anticipated to increase as a result of the proposed increase in clinker
throughput with the Leamington Plant upgrade project. Lead emissions result from residual
amounts of lead in raw materials and fuel. Lead emissions will be controlled the same as PM,
therefore a separate top-down BACT analysis has not been conducted as the Leamington Plant has
applied the most effective controls. [Last updated January 14, 2025]

11. BACT review regarding Greenhouse Gases
GHG Background
On October 9, 2009, the mandatory GHG reporting regulation, referred to as 40 CFR 98, was
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published in the Federal Register. Through 40 CFR 98, the U.S. EPA established the GHG
Reporting Rule, which requires the annual reporting of GHG data and other relevant information
from large sources and suppliers in the United States. Monitoring through the GHG Reporting
Program (GHGRP) began in 2010, with the first reports due by March 31, 2011. Per 40 CFR
98.2(a)(1), any facility associated with cement production is subject to the GHGRP and must report
CO2e emissions. The CO2e is the sum of equivalent GHG emissions from CO2, CH4, and N2O,
with their respective global warming potentials (GWP) applied. Ash Grove's facility is subject to
GHG Reporting Rule and monitors CO2 emissions from its kiln with a continuous emissions
monitoring system (CEMs). On June 23, 2014, the U.S. Supreme Court held that required PSD
permits (based on emissions of non-GHG pollutants) may continue to require limitations on GHG
emissions based on the application of BACT as an "anyway source". The Leamington Plant
modification project is a major source for PSD for both PM10 and PM2.5, and GHGs are estimated
to be greater than 75,000 tpy and greater than zero on a mass basis; therefore, GHGs are evaluated
for BACT as an anyway source.

Cement Manufacturing GHG BACT
A BACT analysis has been conducted for CO2e emissions from the kiln system. For this GHG
BACT analysis, various control technologies or combinations of technologies were identified using
the RACT/BACT/LAER Clearinghouse, available literature including guidance published by EPA
and South Coast Air Quality Management District (SCAQMD), current air regulations, other
regulatory organizations, and engineering experience. In March 2011, EPA published GHG
permitting guidance, as well as a white paper on available and emerging technologies for reducing
GHG emissions from the Portland cement industry in October 2010. Additionally, EPA published a
series of videos on GHG permit training in December 2010. The SCAQMD published GHG BACT
guidance in 2021. Additional sources of information were reviewed and documented based on
publications from trade organizations and other governmental committees with GHG or carbon
reduction guidelines and/or recommendations.

EPA has defined in 40 CFR 86.1818-12(a) GHGs as a group of six gases: CO2, nitrous oxide
(N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF6). GHG emissions from the kiln result from calcination and fuel combustion.
Since the primary GHG emitted by a kiln is CO2, the BACT analysis focuses on CO2 emissions
from the kiln. Emissions of CH4 and N2O are minimal from cement kilns. Per EPA guidance, GHG
control technologies for consideration in a BACT analysis for Portland Cement Manufacturing
include:

Source-wide energy efficiency strategies;
Raw material substitution;
Blended cements;
Carbon capture utilization and storage; and
Fuel switching.
Other emerging technologies [Last updated January 14, 2025]

12. BACT review regarding Greenhouse Gases cont.
Step 1: Identify All Control Technologies
The CO2 emissions from a cement kiln are generated by the calcination process (conversion of the
calcium carbonate in limestone to calcium oxide) and by combustion of fuel in the kiln. Potential
control technologies to reduce these CO2 emissions for a cement kiln are addressed in EPA's white
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paper on Available and Emerging Technologies for Reducing GHG Emissions from the Portland
Cement Industry.

These technologies fall into three categories:
Energy Efficiency Improvements for the Clinker Production Process
Fuel Substitution
Carbon Capture and Sequestration

Step 2: Eliminate Technically Infeasible Options
Several potential energy efficiency improvements are technically feasible: Pre-heater/Pre-calciner
Kiln Process, Kiln Seal Management Program, Refractory Selection (Kiln Insulation), and Energy
Recovery from the Clinker Cooler. The use of alternative fuels such as natural gas, whole tires and
biofuel) is also technically feasible. Other control options, such as Use of Fluxes and Mineralizers,
Heat Recovery for Power - Cogeneration, Carbon Sequestration, Oxyfuel combustion, and
Post-combustion Capture have been deemed infeasible.

Step 3: Rank Remaining Control Technologies by Control Effectiveness
All four remaining control techniques are currently implemented at the Leamington Plant. This
permitting project incorporates energy efficiency improvements. Ash Grove has had a fuel
substitution program in place for several years, and this program is continually reviewed and
updated as new sources and types of fuel are identified.

Step 4: Evaluate Most Effective Controls and Document Results
Since all technically feasible energy efficiency improvements and changes to product composition
will be implemented, this section will focus on economic and environmental considerations of fuel
substitution to operate exclusively on natural gas.

Firing natural gas as the primary kiln fuel can reduce CO2 emissions from fuel combustion by as
much as 40%. However, studies have shown that use of natural gas as primary kiln fuel can result
in three times more NOx emissions than NOx emissions from coal firing. Creating more NOx to
reduce GHG emissions is undesirable as it is a precursor to both ozone and PM2.5. Fuel substitution
essentially trades emissions of one regulated pollutant for another. Estimated capital cost to switch
to natural gas fuel exceeds $25M. Implementing natural gas technology would provide incremental
public health and welfare benefit globally by reducing CO2 emissions, while increasing NOx
emissions and negatively impacting public health and welfare locally. Switching fuels to another
fossil fuel has finite potential to mitigate CO2 emissions.

Step 5: Select BACT
In addition to the proposed energy efficiency improvements addressed elsewhere in this BACT
analysis, BACT is a limit of 0.92-ton CO2e/ton clinker. Ash Grove will use a continuous emission
monitoring system (CEMS) for CO2 to demonstrate compliance with this limit. [Last updated
January 14, 2025]

13. BACT review regarding Leamington Plant Upgrade Project conclusion
The control processes and techniques covered in this BACT analysis have been reviewed by the
NSR Section of the UDAQ. Ash Groves proposed controls and associated emission limitations
represent BACT. Any emission limitations not expressed in an associated NSPS or NESHAP will
be included in the terms and conditions of this AO. A listing of all associated NSPS and NESHAP
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programs is also included in the Source Information section of this document under Applicable
Federal Programs. [Last updated December 13, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date
of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
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proper credit when notifying the Director, send the documentation to the Director, attn.: NSR
Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.

II.A.3
NEW
Stockpiles
Coal storage
Area: 1 acre
Annual throughput 20,000 tpy

AF and ARM stockpiles
Area: 0.25 acre
Annual throughput 8,000 tpy

II.A.4 Stationary Crusher
Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction
of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000
acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)

II.A.5 Raw Material Transfer
Crushed material is transported to raw material storage by belt B8. The raw material transfers
at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor
transfer point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total
filter area & water sprays. (pre-1983)

II.A.6 Material Handling
Conveyor belt systems, secondary feeders and screens, stacker system

II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit specific requirements

II.A.8 Belt Conveyor Transfer Baghouse
Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area
and 1,800 acfm total air flow, controls emissions from the conveyor belt that transfers the
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stacked material to the raw material silos.

II.A.9 Raw Material Silos
Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The
four silos are equipped with one common Fuller, plenum pulse baghouse (315.BF1) - 1,689 ft2
filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage).

II.A.10 Fifth Component Silo
Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse
(315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw
mill feed. This system includes vibrating feeders, a conveyor system, and surge bin.
Emissions are controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3,
316.BF4, 316.BF5) - each is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1
A/C ratio.

II.A.12 Cross-Belt Analyzer
Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6)

II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom
of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw
materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38).
The following equipment is installed: low-NOx burner, selective non-catalytic reduction
(SNCR) for NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued
mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric
monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct
for mercury adsorption capacity. The carbon injection system is not an emission point as it is
in an enclosed building.

II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

II.A.16 Two Kiln Feed Blending Silos
Raw material is blended in one of two blending silos prior to feeding the kiln. The blending
silos are controlled by one common Fuller, plenum pulse baghouse (411.BF1) - 1,351 ft2 filter
area; 7,160 acfm total air flow.

II.A.17 Blending Silo Elevators (2)
Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped
with a Fuller, pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow
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through stack E34.

II.A.18 Kiln Feed Alleviator
A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the
central material silo between the blending silos and the preheater. Raw feed is removed from
the system near the top of the preheater tower.

II.A.19 Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner.
The coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter
area; 1,700 acfm total air flow.

II.A.20 Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in
the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2):
19,500 acfm rated airflow with 3.75:1 A/C ratio

II.A.21 Clinker Cooler and Baghouse
Reconstructed grate type cooler used for cooling clinker from the kiln prior to transfer to
clinker storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) -
173,869 acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter
monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two
clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse
(419.BF8). The exhaust is routed to the clinker cooler stack.

II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions
generated when loading the east and west clinker silos and the out-of-spec silo are controlled
by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1):
1,800 acfm, that discharges into the clinker tunnel.

II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm, that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2)
Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers.
Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses
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(511.HP1 and new 511.HP2): 1,800 acfm each.

II.A.27 Gypsum Silo
Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2
total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust
during loading.

II.A.28 Clinker Tunnel Exitway
The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse
(511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel all discharge in the clinker tunnel.
Emissions are vented through the tunnel exitway.

II.A.29 Limestone Silo
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust
during loading. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement product. Dust
generated during milling is captured by a BHA, pulse jet baghouse (514.BF2) - 6,080 ft2 filter
area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding
stack).

II.A.31 Finish Mill (Ball Mill) Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized
cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA, pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow
controlling particulates from stack G55 (finish mill stack).

II.A.32
NEW
Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The
stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4)
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1,
525.BF1 thru 3)

II.A.33 Finish Cement Storage Silos
There are six storage and two interstice silos where the finished cement product is stored. A
single common Fuller, plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm
total air flow through stack H7 is located on top of the silos and is used to control emissions
during loading and unloading operations.

II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail
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shipping. This baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out
The cement loadout system located on the South side of the silos (truck load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF2) during unloading from the silos for truck
shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement
conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed
space inside the silos.

II.A.36
NEW
Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

II.A.37 MHO: Materials Handling Operation
Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1
& 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4;
512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.

II.A.38 LBS: Limestone Bypass System
Additional limestone is added to the clinker and gypsum by the limestone bypass system
(LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays
at the screen and material handling drop points.

II.A.39 GEN: Emergency Generators
One diesel-fired emergency generator (new)
Rating: 762 hp
(Kiln, Tier 3, permitted 2022)

Two natural gas-fired emergency generators
Rating: 304 hp
(Main office and control room, permitted in 2023)

One diesel-fired emergency generator
Rating: 560 hp
(Shipping, permitted 2023).

II.A.40 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14 inch knife gate, 8 inch knife gate, 8 inch air
slides, surge bin), and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm)
on the fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

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II.A.41
NEW
Miscellaneous Storage Tanks
One diesel storage tank (<2,000 gallons)
One gasoline storage tank (500 gallons)
Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Requirements on the Cement Plant:
II.B.1.a
NEW
The following limits shall not be exceeded:

A. Clinker production - 1,155,000 tons per rolling 12-month period

B. Used oil consumption - 85,724 gallons per rolling 12-month period

C. Limestone bypass material processed - 216,260 tons per rolling 12-month period.
[R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 25th day of each month using data from the previous 12 months.
Records shall be kept for all periods when the plant is in operation. Consumption and
production shall be calculated through use of the plant's acquisition system. [R307-401-8]

II.B.1.b
NEW
Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations:

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

SO2: 0.4 lbs per ton of clinker (3-hr average)

CO: 3,395 tons per rolling 12-month period, and 6,600 lbs/hr

NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average, and 1,233 tons per rolling
12-month period

Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is
400oF or less.

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Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)

THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)

CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)

PM: 0.02 lbs filterable PM per ton of clinker. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL,
R307-401-8]

II.B.1.c
NEW
A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR
60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust
emissions control plan shall be monitored to demonstrate that appropriate control measures are
being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of
the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall
be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in
the plan and that the source is operating in accordance with the submitted plan. For petitions
to approve alternative control measures, the permittee shall keep a copy of the submitted
petition and any approvals received. [40 CFR 60 Subpart Y]

II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area
source of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2). [40 CFR
63 Subpart LLL]

II.B.1.e
NEW
Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b
and II.B.1.d shall be performed as specified below:

A. Kiln/Raw Mill Stack
Pollutant Test Status Test Frequency
PM * #

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

B. Clinker Cooler (F31)
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Pollutant Test Status Test Frequency
PM + #

C. Testing Status (To be applied above)
* The initial testing has already been performed.

** The SO2 initial performance test was conducted on August 26, 2013.

*** The initial compliance test shall be conducted within the first 30 operating days of
operation in which the affected source operates using a CEMS.

# Test once every year. If performance testing would be required less than 15 operating days
after the Kiln has completed Startup after being down for more than 24 hours, then
performance testing may be deferred up to 15 operating days after completion of the Startup.
The Director may require testing at any time.

## Test at least once every two years. The Director may require testing at any time.

+ Initial testing is required within 180 days of startup of the reconstructed equipment

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must record the PM
CPMS output data for all periods when the process is operating, and use all the PM CPMS
data for calculations when the PM CPMS is not out-of-control. The owner/operator must
demonstrate continuous compliance by using all quality-assured hourly average data collected
by the PM CPMS for all operating hours to calculate the arithmetic average operating
parameter in units of the operating limit on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

+++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.e.1
NEW
Notification
The Director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The notification requirements for performance tests subject to 40
CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-165]

II.B.1.e.2
NEW
Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational
Safety and Health Administration (OSHA)- or Mine Safety and Health Administration
(MSHA)-approved access shall be provided to the test location. [R307-165]

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II.B.1.e.4
NEW
PM
40 CFR 60, Appendix A, Method 5 or 5I or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three (3) runs with
each run at least 120 minutes in duration and each run collecting a sample of 60 dry standard
cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.3
NEW
Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2. [R307-165]

II.B.1.e.5
NEW
Carbon Monoxide (CO)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.6
NEW
Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.7
NEW
Sulfur Dioxide (SO2)
40 CFR 60, Method 6 or 6C of Appendix A-4 or other EPA-approved method as acceptable to
the Director. [R307-165]

II.B.1.e.8
NEW
Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]

II.B.1.e.9
NEW
Total Hydrocarbons (THC)
Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL]

II.B.1.e.10
NEW
Mercury (Hg)
Continuous Emission or integrated sorbent trap monitoring (See Condition II.B.3.a). [40 CFR
63 Subpart LLL]

II.B.1.e.11
NEW
HCl
Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other
EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]

II.B.1.e.12
NEW
Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.13
NEW
Calculations
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director, to give the results in the specified units of the
emission limitation. [R307-165]

II.B.1.e.14
NEW
Existing Source Operation
For an existing source/emission point, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three years.
[R307-165]

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II.B.1.e.15
NEW
New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the maximum production rate listed in this AO. If the maximum AO
allowable production rate has not been achieved at the time of the test, the following
procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This new
allowable maximum production rate shall remain in effect until successfully tested at a higher
rate.

3) The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate (110%
of the new rate) will then be allowed if the test is successful. This process may be repeated
until the maximum AO production rate is achieved. [R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL.
[40 CFR 63 Subpart LLL]

II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times
of Dust Shuttle System operation to assist in the capture of Mercury emission. [R307-401-8]

II.B.1.h
NEW
Visible emissions from the following emission points shall not exceed the following values:

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

L. All baghouses - 10% opacity
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M. Fugitive dust - 20% opacity

N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y,
R307-401-8]

II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer
point is not required to conduct Method 22 visible emissions monitoring under this paragraph.
The enclosures for these transfer points must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

If any partially enclosed or unenclosed conveying system transfer point is located in a
building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to
40 CFR 60, according to the following:

(i) The owner/operator must conduct a monthly ten-minute visible emissions test of each
affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The
performance test must be conducted while the affected source is in operation.

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator may decrease the frequency of performance testing from monthly
to semi-annually for that affected source. If visible emissions are observed during any
semi-annual test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iii) If no visible emissions are observed during the semi-annual test for any affected source,
the owner/operator may decrease the frequency of performance testing from semi- annually to
annually for that affected source. If visible emissions are observed during any annual
performance test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iv) If visible emissions are observed during any Method 22 performance test, of Appendix
A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations,
recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60.
The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour
of any observation of visible emissions.

(v) If visible emissions from a building are monitored, the requirements of paragraphs (i)
through (iv) of this Condition apply to the monitoring of the building, and the owner/operator
must also test visible emissions from each side, roof, and vent of the building for at least ten
minutes. [R307-401]

II.B.1.j
NEW
Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed
0.005 gr/dscf:

520.BF1
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520.BF2
520.BF3
520.BF4
521.BF2
521.BF1
524.BF1
524.BF2
524.BF4
524.BF3
525.BF1
525.BF2
525.BF3
511.HP2
NRL_UPR
NRL_LWR. [R307-401-8]

II.B.1.j.1
NEW
To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration
through at least three (3) annual tests that the PM limits are not being exceeded, the
owner/operator may request approval from the Director to conduct stack testing less
frequently than annually. [R307-401-8]

II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive
dusts as dry conditions warrant or as determined necessary by the Director to maintain opacity
limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated to control fugitive dust. The application of
water or chemical treatment shall be used. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a damp/moist condition unless it is below freezing.
If chemical treatment is to be used, the plan must be approved by the Director. Records of
water and/or chemical treatment shall be kept for all periods when the plant is in operation.
The records shall include the following items: Instances of water and/or chemical application
to unpaved areas shall be recorded and maintained by the owner/operator. The ambient
temperature shall be recorded any time water should be applied but cannot due to freezing
conditions. [R307-401-8]

II.B.2.c
NEW
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

The sprays shall operate whenever dry conditions warrant meeting the required opacity
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limitations or as determined necessary by the Director. Water sprays shall not be required
during periods of freezing temperatures. [R307-401-8]

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation
of fugitive dusts as dry conditions warrant or as determined necessary by the Director.
[R307-401-8]

II.B.2.e
NEW
The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5
PM. [R307-401-8]

II.B.3 Continuous Emission Monitoring Requirements:
II.B.3.a
NEW
The owner/operator shall install, calibrate, maintain and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler.

A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the
missing data substitution procedures used by the UDAQ or the missing data substitution
procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate by the UDAQ.

B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period
including during each startup, shutdown, or malfunction.

C. The monitoring system shall comply with all applicable sections of R307-170, UAC; and
40 CFR 60, Appendix B.

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be
installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the
kiln/raw mill stack.

F. The owner/operator shall record the output of the system: including the quantity of NOx,
CO, O2 THC, Hg, HCl, and CO2 emissions at the kiln stack.

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source shall
continuously operate all required continuous monitoring devices and shall meet minimum
frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker
cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except
during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments,
the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a
PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the
results of the performance test demonstrating compliance with the filterable PM limit and
using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust
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the SSOL developed in accordance with the results of the most recent PM performance test
demonstrating compliance with the PM emission limit. The owner/operator shall use the PM
CPMS to demonstrate continuous compliance with the SSOL in accordance with the
requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

II.B.4 Fuel Limitations:
II.B.4.a
NEW
The owner/operator shall use only the following fuels in the kiln and pre-calciner:

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.

If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b
NEW
Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the
Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the
results of suitable tests giving data similar to a Proximate and Ultimate analysis of the
proposed coal additive. [R307-401-8]

II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal
additive. Approval is not required to change from one previously-approved coal additive to
another previously-approved coal additive. [R307-401-8]

II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily
heat input of the kiln and precalciner. The owner/operator may increase the average quantity
of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon
approval by the Director in accordance with the approval process described in Condition
II.B.4.b. [R307-401-8]

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II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel burning or process
installation not covered by New Source Performance Standards for sulfur emissions or
covered elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross
Btu heat input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input
for any oil except used oil. The sulfur content shall comply with all applicable sections of
UAC R307-203. [R307-203, R307-401-8]

II.B.4.c.1
NEW
Certification of fuels shall be either by the owner/operator's own testing or test reports from
the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be
available onsite. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials, UAC R307-203-1 (4)

A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be
used.

B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be
used.

C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85 are to be used. [R307-203]

II.B.4.d
NEW
The concentration/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight
3) Cadmium 2 ppm by weight
4) Chromium. 10 ppm by weight
5) Lead 100 ppm by weight
6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be
tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the burn tank and burned. [R307-401-8]

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II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned
in the rotary kiln:

A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than
five minutes in any 60-minute period

B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes
in any 60-minute period. [R307-401-8]

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the
Director. The calibration procedure and frequency shall be according to manufacturer's
specifications. Use of factory-calibrated thermocouples for temperature measurement is
approved. However, any other method of temperature measurement must be approved by the
Director prior to use. The monitoring equipment for both temperature and oxygen content
shall be located such that an inspector can at any time safely read the output. [R307-401-8]

II.B.5
NEW
Emergency Engine Requirements
II.B.5.a
NEW
The owner/operator shall only operate the emergency engines for testing and maintenance
purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency
operation. [R307-401-8]

II.B.5.b
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each emergency engine. [R307-401-8]

II.B.5.b.1
NEW
The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.5.b.2
NEW
To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN103030035-24 dated November 27, 2024
Is Derived From Source Submitted NOI dated November 30, 2022
Incorporates Additional Information Received dated April 26, 2023
Incorporates Additional Information Received dated September 26, 2023
Incorporates Additional Information Received dated July 23, 2024
Incorporates Additional Information Received dated October 25, 2024
Incorporates Additional Information Received dated November 25, 2024

REVIEWER COMMENTS

1. Comment regarding applicability of federal requirements:
New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable
by the best demonstrated technology as specified in the applicable provisions. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.

40 CFR 60, Subpart A (General Provisions)
All affected facilities subject to a source-specific NSPS are subject to the general provisions of
NSPS, Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires
initial notification, performance testing, recordkeeping, and monitoring, provides reference methods,
and mandates general control device requirements for all other subparts.

40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of
performance for affected facilities in Portland Cement Plants which have been constructed or
modified after August 17, 1971.

40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart
F: Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and
unloading systems. The Leamington coal mill is an in-line coal mill and considered an integral part
of the Leamington kiln. In-line coal mills are not subject to NSPS Subpart Y. Therefore, the coal mill
is addressed under NSPS Subpart F as part of the kiln system. The coal silos and conveying system
are subject to NSPS Subpart Y.

Ash Grove's proposed changes to the kiln system must be evaluated as to whether they trigger new
NSPS Subpart F obligations based on whether the proposed project is either a modification or a
reconstruction, as those terms are defined in NSPS Subpart A.

Ash Grove's proposed changes to the kiln system do not meet the definition of a reconstruction, nor
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Page 40

do they meet the definition of a modification for NOx. However, the changes meet the definition of a
modification for PM and SO2. Therefore, Ash Grove will comply with all relevant emission
standards; testing requirements; monitoring, recordkeeping, and reporting obligations that apply to
the Leamington kiln system as an existing source under NSPS Subpart F. Under NSPS Subpart A
and F, the clinker cooler is considered a reconstructed unit. Thus new limits will apply to this unit.
[Last updated January 14, 2025]

2. Comment regarding applicability of federal requirements cont.:
NSPS Subpart Y - Standards of Performance for Coal Preparation and Processing Plants
This subpart provides standards of performance for affected facilities in coal preparation and
processing plants that process more than 200 tons of coal per day.

The Leamington plant's coal silo and coal conveying system are existing affected facilities under
NSPS Subpart Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses
controlling affected facilities subject to match the limit in NSPS Subpart Y from 0.016 gr/dscf to
0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade Project. Since there are no proposed
modifications or reconstruction to the coal silo and coal conveying system, nothing about the
proposed upgrade project affects the existing applicability of NSPS Subpart Y.

NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
This subpart provides standards of performance for affected facilities located at fixed or portable
nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August
31, 1983, with additional requirements applicable to sources constructed on or after April 22, 2008.

As the crushing and screening system is controlled by baghouses and an increase in PM10 actual
emissions on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS.
Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the
Leamington Plant Upgrade Project.

Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1),
60.676(f), and 60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO
monitoring and recordkeeping requirements.

[Last updated January 14, 2025]

3. Comment regarding applicability of federal requirements cont.:
National Emission Standards for Hazardous Pollutants (NESHAPs)
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or
greater than 10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as
specified by each subpart. NESHAP apply to sources in specifically regulated industrial source
classifications (CAA Section 112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities
not regulated as a specific industrial source type. The Ash Grove Leamington Plant is a major source
of HAPs and thus is subject to certain NESHAP standards.

Subpart A - General Provisions
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All affected sources are subject to the general provisions of Subpart A unless otherwise specified by
the source-specific NESHAP. Subpart A generally requires initial notification and performance
testing, recordkeeping, monitoring, provides reference methods, and mandates general control device
requirements for all other subparts as applicable.

Subpart LLL - Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry
This subpart establishes process/source specific emission limits for PM, VOC (expressed as total
hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and
gaseous HAP compounds by limiting PM and THC emissions because portions of such emissions
are USEPA-listed HAPs. Subpart LLL requires compliance with applicable emissions limits on and
after the initial startup of cement production. To further reduce emissions, Subpart LLL also
establishes operational requirements for the use of cement kiln dust (CKD), fly ash, fuel and control
equipment. Subpart LLL also specifies process/source specific emissions testing, monitoring,
recordkeeping, reporting, and compliance demonstration requirements. The compliance requirements
for the site are detailed in Approval Order Condition II.B.1.b. Ash Grove will continue to comply
with the requirements of Subpart LLL to demonstrate compliance. This cement kiln will remain an
existing source with respect to the kiln emission standards in Subpart LLL as this project does not
trigger the definition of a new source in Subpart LLL. New source standards apply only to affected
sources that were constructed or reconstructed after May 6, 2009.
[Last updated December 20, 2024]

4. Comment regarding PSD applicability analysis:
Ash Grove is proposing to increase the throughput of limestone from the quarry to supply the New
Finish Mill to increase the amount of low-carbon cement from the Leamington Plant. Additionally,
along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
modified, and the clinker cooler will be reconstructed. These changes are anticipated to result in an
increase in clinker production. Emission calculations for this project have been completed assuming
an increase in clinker production capacity while utilizing current fuel types. This will result in an
increase in the throughput of fuel.

The Leamington Plant is considered an existing major source under PSD based on potential
emissions of PM10, PM2.5, NOx, CO, SO2, and CO2e. If a major source undergoes a physical or
operational change, the facility must determine whether the project will be considered a major
modification. Per 40 CFR 52.21(b)(2)(i), in order to be a major modification, the project must result
in a significant emissions increase, and a significant net emissions increase.

As defined at 40 CFR 52.21(b)(40): Significant emissions increase means, for a regulated NSR
pollutant, an increase in emissions that is significant for that pollutant. Significant is further defined
to mean, in reference to a net emissions increase or the potential of a source to emit any of the
following pollutants, a rate of emissions that would equal or exceed the values outlined in 40 CFR
52.21(b)(23). If the increase in emissions from the project are not significant, a major modification
has not occurred.

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
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increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

For all pollutants, the project emissions increase was calculated as the difference between the
projected actual emissions (PAE) after the proposed project and the actual emissions prior to the
project (baseline actual emissions or BAE).

Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
". . . projected actual emissions means the maximum annual rate, in tons per year, at which an
existing emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years
(12-month period) following the date the unit resumes regular operation after the project, or in any
one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit of that regulated NSR pollutant and full utilization of the unit would
result in a significant emissions increase or a significant net emissions increase at the major
stationary source." [Last updated January 14, 2025]

5. Comment regarding PSD applicability analysis cont.:
Ash Grove estimates that the projected actual production capacity following the project will be
1,155,000 tons of clinker per year and 1,341,266 tons of limestone per year. These capacities were
used to calculate projected actual emissions from the project using representative emission factors.
Additionally, to estimate emissions from material transfer baghouses, the actual flow rates and actual
projected hours were used as a basis for projected actual emissions.

Project Emission Calculations

Project emission increases from the kiln and coal mill systems are calculated for all criteria
pollutants based on emission factors that are derived from stack testing, CEMS data, or emission
factors (i.e., VOCs and Lead), and the associated projected incremental clinker increase.

NOx emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain
hourly capacity to emit and annual potential to emit at current levels. The kiln's NOx emissions rate
will not change as a result of the physical modifications proposed by the project.

Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission
factor and multiplied by the incremental increase in clinker production. The emission factor was
selected based on the average of the 24-month consecutive month emissions for 2020 and 2021. The
CO emissions will increase.

The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing
conducted at the plant. The SO2 emissions will increase.

VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production. VOC emissions will increase.

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 43

can be found in the original NOI and subsequent addendums submitted to UDAQ.

As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from
the proposed project, each increase of emissions from both existing and new sources shall be
summed together and compared to the PSD permitting thresholds. The increase of emissions is the
"positive" difference between the projected actual emissions and baseline actual emissions (projected
minus baseline).

New Emissions Sources

The actual to projected actuals calculation is not available to new emission units. For new emission
units, the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected
emissions are based on the new sources' potentials to emit. (40 CFR § 52.21(a)(2)(iv)(f)).

The new equipment proposed includes the New Finish Mill, a new rail and truck loading/loadout,
one (1) new clinker reclaim loading hopper with a dust collector and one (1) existing clinker reclaim
hopper with a dust collector, a new Clinker Cooler to replace the existing one, and a new kiln feed
alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions:

The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;

The finish mill heater was calculated based on its maximum firing capacity and flow rates; and

The fugitive emissions were calculated based on the projected annual throughput of the New Finish
Mill, the rail loadout, and clinker production. [Last updated January 14, 2025]

6. Comment regarding PSD applicability analysis cont.:
Existing Emission Sources

For the existing sources, the projected actual emissions are the maximum annual rates in tons per
year projected to occur during the next five (5) to ten (10) years if the existing sources' design
capacities increase. Ash Grove Leamington projected the actual emissions for the next five (5) years
based on the new kiln system producing an annual average of 3,250 tons of clinker per day.

Baseline actual emissions (BAE) are defined at 40 CFR 52.21(b)(48)(ii) as:

". . . baseline actual emissions means the average rate, in tons per year, at which the emissions unit
actually emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the 10-year period immediately preceding either the date the owner or operator
begins actual construction of the project, or the date a complete permit application is received by the
Administrator."

Ash Grove has selected to use the years 2020 and 2021 for each pollutant as the representative
baseline years.

In its NOI, Ash Grove calculated the emission increase from the project as being divided into two
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 44

phases. Phased construction projects are discussed in two sections of the federal PSD regulations -
40 CFR 52.21(j)(4) and 40 CFr 52.21(r)(2). UDAQ is not processing this project as a phased
construction project, nor did Ash Grove request such a determination. Therefore, Ash Grove
provided a summary table outlining the final change in emissions from this project:

Projected Actual Increase Compared to PSD threshold (tons per year)
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2e
BAE 76.64 39.64 1,187 6.87 3,315 55.47 641,385
PAE 203.15 113.47 1,226 45.87 3,414 72.07 1,067,984

Change in Emissions 126.51 73.83 39.00 39.00 99.00 16.59 426,598

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes

If the emissions increase is greater than the PSD significance threshold for a particular pollutant, Ash
Grove has the option of conducting a PSD review or continuing through the rest of the steps to
determine if it can "net" out of a PSD review. If the project increase is less than the PSD significant
threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant.

The change in emissions from the project exceeds the significant emission threshold for three
pollutants: PM10, PM2.5 and CO2e. Ash Grove elected to attempt to net out of a PSD major
modification for the remainder of the criteria pollutants.

Netting

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant
Upgrade Project and ends on the date the upgrade begins operation. Only PM10, PM2.5, CO2e are in
excess of SERs and therefore considered in the netting analysis.

Ash Grove estimated that the commencement of construction will be in December 2024. Therefore,
the contemporaneous period for this project is December 2019 through a projected date the project
upgrade begins operation. [Last updated January 21, 2025]

7. Comment regarding PSD applicability analysis cont.:
Contemporaneous Decreases

Ash Grove replaced an existing kiln emergency drive engine with a USEPA Tier 4 diesel engine in
2022. Concurrently, Ash Grove requested an increase in the capacity of 1L Cement. Additionally,
Ash Grove submitted a minor modification NOI air permit application on June 12, 2023, which
proposes replacing the shipping generator during the contemporaneous period. The kiln emergency
drive engine and shipping generator are both higher EPA tier ratings therefore result in decreases for
PM10 and PM2.5. These changes were approved in AO DAQE-AN103030033-24 issued March 21,
2024.

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Page 45

Contemporaneous Increases

As stated above, the existing kiln emergency drive engine and shipping generator were permitted and
replaced in 2024. This resulted in an increase in emissions of CO2e.

The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout
in an effort to improve truck traffic at the loadout. The modification to add these dust collectors to
the loadout was included in DAQE-AN103030029-19. The baghouses are three (3) levels up in the
silos' enclosed space (approximately 40 feet). Both dust collectors vent directly into the interior of
the silo structure and are not vented into the atmosphere. Ash Grove requests to remove these
baghouses from its existing permitted emissions inventory. Therefore, these emissions have been
documented in the netting analysis as zero emissions.

Also included in DAQE-AN103030033-24 were two new natural gas-fired emergency generators
and increases in stockpiles, material handling and road emissions.

Could Have Been Accommodated Emissions

In calculating project emissions increase, USEPA allows the exclusion of existing
production/emissions rates that could have been accommodated during the baseline period. These
"could have been accommodated" emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as
follows:

". . . Shall exclude, in calculating any increase in emissions that results from the particular project,
that portion of the unit's emissions following the project that an existing unit could have
accommodated during the consecutive 24-month period used to establish the baseline actual
emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project,
including any increased utilization due to product demand growth;"

Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the
exclusion of existing production and emissions rates that could have been accommodated during the
baseline period, it has elected not to use this exclusion at this time. Therefore, calculation of the
"could have been" accommodated emissions have not been included in this application's
applicability analysis.

The increase from the project is added to the contemporaneous decreases and contemporaneous
increases. The resulting calculation is then compared to the PSD significance threshold to determine
if a significant net emissions increase has occurred. [Last updated January 14, 2025]

8. Comment regarding PSD applicability analysis cont.:
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2 e
Contemporaneous Inc. 1.61 0.45 0.41 0 0.27 0.07 51.74

Contemporaneous Dec. -1.54 -3.97 -0.48 -0.02 -0.27 -0.09 0

Change in Emissions 125.02 69.21 38.93 38.98 99.00 16.58 426,650

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes
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Page 46

The results of the netting analysis conclude that both a significant emissions increase and a
significant net emissions increase in both particulates (PM10 and PM2.5) and CO2e will occur from
this project. Thus, the project must be reviewed as a PSD major modification. [Last updated January
14, 2025]

9. Comment regarding emission calculations:
This engineering review includes updated potential emission totals for both criteria and HAP
emissions. The potential-to-emit (PTE) values were calculated using updated values for clinker
produced and raw material inputs. BACT emission factors and limitations were used where
appropriate. Certain emission totals (NOx, SO2 and CO) were set based on avoiding a significant
increase in emissions. Specifically, the projected actual increase was set at just under the baseline
actual emissions + the significance level. As these emissions are monitored by CEM, UDAQ agrees
with this approach. Please see the netting analysis for further details on calculation of projected
actual increase. The NOx hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project.

CO2e emissions were calculated using the GHG emission factor calculated from 40 CFR Part 98
Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in Subpart A Table
A-1.

To calculate the PTE tons per year, the maximum hours (i.e., 8760) per year and the source's
emissions rates were multiplied with the throughputs. The potential throughputs have been updated
at UDAQ's request so that PAE is equal to PTE and represents the equipment's maximum design
potential.

Additional emission calculations based on source testing and monitoring, and EPA's compilation of
air emission factors AP-42. [Last updated January 14, 2025]

10. Comment regarding requirements for PSD review:
In addition to the permitting requirements of R307-401-5 through R307-401-8, there are additional
requirements under PSD that must be addressed:

1. Calculation of ambient air increments (40 CFR 52.12(c)), ambient air ceilings ((40 CFR 52.12(d)),
source impact analysis (40 CFR 52.12(k)), air quality models (40 CFR 52.12(l)) - these items are
addressed in the modeling memo DAQE-MN103030032-24.

2. Stack heights (40 CFR 52.12(h)) - Ash Grove's stack heights have been reviewed with respect to
good engineering practice and operate in a vertical unrestricted manner.

3. Control technology review (40 CFR 52.12(j)) - this is addressed in the BACT analysis section of
this review document.

4. Air quality analysis: preapplication analysis (40 CFR 52.12(m)) - this is covered in the PSD
applicability and netting analysis sections of this review document, ambient monitoring and
background data collection is also included in the modeling memo DAQE-MN103030032-24.

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 47

grain loading limit included in II.B.1.j.1 represents the required post-construction monitoring.
6. Source information (40 CFR 52.12(n)) - this is addressed under the requirements of R307-401-5
and was submitted by Ash Grove as part of the NOI package.

7. Additional impact analysis (40 CFR 52.12(o)) - these requirements cover soils, vegetation, growth
and visibility concerns. They are discussed in the modeling memo DAQE-MN103030032-24.

8. Federal land manager review (40 CFR 52.12(p)) - UDAQ provided initial notification to all
federal land managers upon receipt of the original NOI package. The draft permit and engineering
review will also be provided to the federal land managers 60-days prior to initiation of public
comment for their further review.

9. Public participation (40 CFR 52.12(q)) - this project will have a 30-day public comment period.

10. Source obligation (40 CFR 52.12(r)) - this requirement discusses source compliance with other
parts of the CAA, which is addressed within UDAQ's permitting rules in R307.
[Last updated January 14, 2025]

11. Comment regarding changes in equipment list:
The equipment list is being updated for clarity as well as adding new pieces of equipment. The
following changes are taking place:

The naming scheme is being updated to remove the numerical code from the unit designation. This
code generally referred to the associated control device and not to the emitting unit itself. This can
cause confusion especially when the same code was applied to multiple pieces of equipment.
Instead, the control devices (typically baghouse dust collectors) will be identified in the description
along with the appropriate numerical code.

Specific changes are as follows:

1. The kiln description has been updated

2. Clinker Cooler description has been updated to include a larger pulse jet baghouse.

3. The clinker storage silos, east and west clinker belts, clinker belt transfer and clinker tunnel have
been consolidated to avoid confusion

4. The north and south cement loadout exhausts now vent internally into the cement storage silos

5. The dust shuttle system has been consolidated into one line item, most identifiers removed from
subsystem descriptions as only two baghouses serve as exhaust points.

6. A new finish mill with heater has been added. Included in the description are the thirteen total
baghouses for dust control (1 main stack, 2 transfer points, 10 nuisance dust filters)

7. A new clinker reclaim hopper has been added. Both reclaim hoppers are controlled by baghouses
with updated identifiers

8. A new rail and truck loading/unloading system with two baghouses has been added.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 48

[Last updated December 20, 2024]

12. Comment regarding changes in conditions:
As a result of this project, several conditions will be added or changed. This includes one new
general condition (I.8). Changes to the equipment list (section II.A) will be addressed in a separate
reviewer comment:

I.8 - Adding this general condition to cover the requirements of R307-401-18 Eighteen Month
Review. The status of construction/installation of the new equipment shall be reviewed after
18-months.

II.B.1.a - Clinker production increases to 1,155,000 tpy
Use of limestone bypass material increases to 215,260 tpy

II.B.1.b - The NOx limit on the kiln decreases to 1,223 tpy, CO emissions from the kiln decrease to
3,395 tpy,
Adding a new CO2e limit of 0.92 tons CO2e/ton of clinker produced
PM limit on the clinker cooler decreased to 0.02 lb PM (filterable)/ton of clinker
Rule reference updated to include 40 CFR 60 Subpart F, and R307-401-8

II.B.1.e - Initial testing on the clinker cooler is now required within 180 days of startup of the unit.
Monitoring of CO2 from the kiln will be by CEM.
Formatting changes on paragraph designated ++, improve clarity, include reference to CO2
monitoring, define CPMS

II.B.1.e.4 - Update to address general PM monitoring and reference R307-401-8

II.B.1.e.14 - New condition to address new or reconstructed emission units monitoring requirements,
applicable to the clinker cooler and new finish mill.

II.B.1.h - Adding references to Subpart OOO units (limestone processing) with updated opacity
limits.
Adding 20% opacity limit on coal transfer and storage
Adding property boundary opacity limit of 20%
Updating rule reference to include Subpart OOO

II.B.1.j - New condition to address outlet grain loading limits on new baghouses, One identical limit,
15 total new baghouses.

II.B.1.j.1 - Monitoring on new baghouses as per II.B.1.e.4, added an allowance to test less frequently
than annually with three successful tests.

II.B.3.a - Updating formatting to add clarity and include reference to CO2 CEM

II.B.5 - New conditions on emergency engines, diesel fuel sulfur limits, hour of operation
restrictions, non resettable hour meter

[Last updated December 20, 2024]
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 49

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 51

TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 52

DAQE-MN103030032-24

M E M O R A N D U M

TO: John Jenks, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler
Dave Prey, Air Quality Modeler

DATE: December 12, 2024

SUBJECT: Modeling Analysis Review for the Ash Grove Cement Company – Leamington Plant,
located in Millard County, Utah
___________________________________________________________________________________
This is a Major Modification to a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Ash Grove Cement Company (Applicant) has submitted a Notice of Intent (NOI) air permit
application for a project referred to as the Leamington Upgrade Project (LUP). The proposed
upgrade project includes the construction and installation of new pollution control equipment, new
emission sources, and modifications to existing emission sources. Emission increases associated
with the LUP constitute a major modification to a Prevention of Significant Deterioration (PSD)
source subject to PSD permitting regulations. PSD regulations require the Applicant to include and
air quality impact analysis (AQIA) of the proposed projects impact on the EPA national ambient air
quality standards (NAAQS) and air quality related values (AQRV) as part of a complete NOI.

This report prepared by the New Source Review (NSR) modeling staff contains a review of the
Applicant’s Air Quality Impact Analysis (AQIA) including the methodology, data sources,
assumptions, and modeling results for comparison with State and Federal air quality standards. The
AQIA was reviewed and referenced in this report include the:
● Notice of Intent – Ash Grove Cement Leamington Plant PSD Notice of Intent Air Permit
Application, dated November 30, 2022.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

0 0
Jason Krebs

DP
DAQE-MN103030032-24
Page 2

II. APPLICABLE RULES AND ANALYSES

A Utah Air Quality Rules

The UDAQ has determined that the Applicant’s NOI is subject to the following rules for conducting an
AQIA:

R307-401 Permits: New and Modified Sources
R307-405 Permits: Major Sources Located in Attainment or Unclassified Area (PSD)
R307-406-2 Visibility – Source Review
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutant Impacts in Attainment Areas

B. Applicability

The proposed increases in emissions of PM10 and PM2.5 exceed the emission thresholds outlined in R307-
406-5 and R307-410-4. Therefore, an AQIA consistent with the requirements of R307-405-6, R307-406-
2, and R307-410-3 was submitted as part of the Applicant’s NOI. R307-410-3 establishes the U. S.
Environmental Protection Agency (US EPA) – Guideline on Air Quality Models as a formal basis for
defining the scope of the analysis, as well as the model’s construction. The results of the AQIA are
required to demonstrate the proposed project’s impact on state and federal air quality standards,
acceptable levels of impact, and action triggering thresholds referenced or listed in R307-401-6(2), R307-
401-6(3), R307-403-3(1), R307-403-5(1)(a), R307-405-4(1), R307-405-6. Annual emissions for criteria
pollutants requiring an AQIA are listed in Table 1.

Table 1: Ash Grove Leamington Proposed Net Emissions Increase

Criteria
Pollutants
Net Emission
Increase (TPY)
AQIA Trigger
Level (TPY) AQIA Required?
PM10 126.6 15 Yes
PM2.5 70.3 10 Yes

C. Required Analyses

R307-405 requires the Applicant to perform a pre-construction modeling analysis for all pollutants
emitted in a significant quantity. The purpose of the analysis is to determine if the extent of the source’s
impact is significant enough to warrant an on-site measurement of the ambient background concentration
levels. This data is included in the NAAQS analysis to represent the quality of the air prior to the
construction of the proposed project. The Applicant included a pre-construction modeling analysis for
PM10 and PM2.5 as part of the NOI. The pre-construction modeling analysis was also used to determine if
the proposed emissions would result in a significant impact to the environment, thereby triggering the
requirement for a cumulative analysis of the proposed project and other nearby existing sources.

R307-401-8 requires the Division to determine that the proposed project will comply with the NAAQS
prior to the issuance of an Approval Order (AO). R307-405(7) requires the Applicant to perform a
DAQE-MN103030032-24
Page 3
NAAQS analysis for all pollutants emitted in a significant quantity. The analysis is to include all
emissions at the proposed site under normal operating conditions using maximum anticipated short-term
release and annual release rates. Consistent with UDAQ policy, a cumulative analysis to include the
ambient background concentration and any contribution from other nearby sources is not required if the
proposed project’s impact does not exceed the PSD Class II Significant Impact Level (SIL).

R307-401-8 also requires the Division to determine that the proposed project will comply with PSD
increments prior to the issuance of an AO. Under R307-405(6), the Applicant is required to perform a
PSD Class I and II increment consumption analysis for all pollutants emitted in significant quantities.
The purpose of this analysis is to quantify any degradation in air quality since the major source baseline
date. The analysis is to include all increment consuming emissions at the proposed site under normal
operating conditions using maximum anticipated short-term and annual release rates. A cumulative
analysis to include contributions associated with growth and other increment consuming sources is not
required if the proposed project’s impact does not exceed the PSD Class I or II SIL.

R307-410-5 requires the Applicant to perform a HAPs analysis for any pollutant emitted above a
pollutant specific emission threshold value. This analysis is to include all emissions of the pollutants
resulting from the proposed modification under normal operating conditions using maximum anticipated
one-hour release rates. The Applicant did not trigger modeling for HAPs.

R307-406-2 requires the Applicant to perform a plume blight analysis. A plume blight analysis is required
to determine if plumes emanating from the proposed project would be visible inside any Class I area
within 50 kilometers of the source. The plume blight analysis is to include all emissions of NO2, SO4, and
PM10.

Under R307-405-16, an AQRV analysis is performed which evaluates regional haze and acid deposition
impacts at each of the Class I areas within 300 kilometers of the source. A regional haze analysis is
required to determine if the plumes would reduce the visual range of an observer inside the Class I area.
The regional haze analysis is to include all emissions of SO2, NOX and PM10. The deposition analysis
examines impacts from sulfur and nitrogen compounds at the Class I areas, and is based on all emissions
of SO2 and NOX. The Federal Land Managers use the Q/D approach to determine whether a PSD project
should provide detailed AQRV impact analyses, where: Q/D= [ H2SO4 + SO2 + NOx + PM10 emissions
(tpy)]/ distance (km). If Q/D is less than 10, no AQRV analysis is required.

R307-405 requires the Applicant to perform a soils and vegetation analysis. The analysis should quantify
the effects of pollutants on soils and vegetation near the highest impact location and in areas where
sensitive plant species may be impacted.

III. ON-SITE PRE-CONSTRUCTION MONITORING

A. Meteorological Data

Consistent with the US EPA - Meteorological Monitoring Guidance for Regulatory Modeling
Applications, one year of on-site data was collected using a 50-meter tower during the period October 1,
2021 through September 30, 2022. Parameters collected on-site included wind speed and direction,
temperature, delta-T, and solar radiation.

DAQE-MN103030032-24
Page 4

B. Ambient Pollutant Data

A preliminary analysis was conducted to determine the necessity for pre-construction ambient pollutant
monitoring. The results indicate that predicted concentrations of PM10 and PM2.5 exceed the monitoring
trigger level listing in the rule. A continuous PM10/PM2.5 monitor with filter based samplers was
installed near the northern edge of the Applicants property boundary, and collected particulate matter
from October 1, 2021 through September 30, 2022.

IV. MODEL SELECTION

The EPA-AERMOD dispersion modeling system is the preferred model specified in the US EPA –
Guideline on Air Quality Models to predict air pollutant concentrations in the near field (within 50
kilometers of the source). The US EPA - CALPUFF - Version 5.8 model is the preferred model to predict
concentrations in the far field (long range transport conditions beyond 50 kilometers from the source).

V. MODELING INPUTS AND ASSUMPTIONS

A. Technical Options

The regulatory default options were selected in AERMOD by the Applicant to quantify all concentrations.

B. Urban or Rural Area Designation

A review of the appropriate 7.5-minute quadrangles determined that the area should be classified as
“rural” for air modeling purposes.

C. Topography/Terrain

The Plant is at an elevation of 4,950 feet with nearby terrain features that have an effect on concentration
predictions.

a. Zone: 12
b. Location: UTM (NAD83): 397000 meters East, 4379850 meters North

D. Ambient Air

It was determined that the Plant boundary used in the AQIA meets the State’s definition of an ambient air
boundary.

E. Receptor and Terrain Elevations

The modeling domain has simple and complex terrain features in the near field. Therefore, receptor
points representing actual terrain elevations from the area were used in the analysis.

The far-field modeling domain consisted of a rectangular region covering all Class I areas within Utah,
and extending 50 kilometers beyond this area so that the model can account for re-circulation of the
plume.

DAQE-MN103030032-24
Page 5

F. Emission Rates and Release Parameters

The emission estimates and source parameters used in AERMOD for all proposed emission sources at the
site are presented in the NOI.

Speciated emission rates and source parameters used in the CALPUFF modeling are presented in Table 2.

Table 2: CALPUFF Emission Rates

Source
LCC Coordinates Modeled Emission Rates
Easting Northing SO2 SO4 NOX HNO3 NO3 SOA PMC SOIL EC
(m) (m) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr)
317.BF3 -1289410 -3738 52.81 5.03 307.58 0.00 0.00 5.03 2.60 2.90 0.11
419.BF1 -1289314 -3631 0.00 0.00 0.00 0.00 0.00 0.55 1.51 1.61 0.06
41B.BF2 -1289389 -3663 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.68 0.00
N1_FM2 -1289526 -3414 0.00 0.00 0.00 0.00 0.00 0.00 1.65 3.95 0.00
414.BF1N -1289407 -3683 0.00 0.00 0.00 0.00 0.00 0.00 0.10 0.25 0.00
2FM_HTR -1289528 -3415 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.08 0.00
514.BF1 -1289451 -3675 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.70 0.00
COMBO -1289424 -3668 0.00 0.00 0.00 0.00 0.00 0.00 1.37 5.72 0.00
FM2_CMB -1289454 -3439 0.00 0.00 0.00 0.00 0.00 0.00 0.50 1.21 0.00

Total Lb/hr 52.81 5.03 307.58 0.00 0.00 5.58 8.32 17.10 0.17
Hrs/Yr 8760 8760 8760 8760 8760 8760 8760 8760 8760
Ton/yr 231.3 22.0 1347.2 0.0 0.0 24.4 36.4 74.9 0.8

Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
317.BF3 POINT 4902.8 41.2 135.0 488 10.10 3.35
419.BF1 POINT 4891.2 18.3 60.0 388 6.36 2.90
41B.BF2 POINT 4895.2 68.6 224.9 294 17.83 0.74
N1_FM2 POINT 4832.0 49.7 163.0 363 40.08 1.40
414.BF1N POINT 4896.1 76.8 251.9 353 9.91 0.70
2FM_HTR POINT 4832.0 49.7 163.0 363 40.08 1.40
514.BF1 POINT 4889.5 39.6 130.0 294 11.86 0.91
COMBO POINT 4904.2 13.3 43.7 276 9.76 0.32
DAQE-MN103030032-24
Page 6
FM2_CMB POINT 4832.0 30.6 100.3 294 11.40 0.37

G. Building Downwash

The Applicant used the US EPA Building Profile Input Program (BPIP) to determine Good Engineering
Practice (GEP) stack heights and cross-sectional building dimensions for input into the model.

H. Ambient Background Concentrations

Millard County is in attainment for all criteria pollutants. The NAAQS analyses for PM2.5 and PM10 used
monitoring data collected on site during the pre-construction monitoring analysis. The background values
used in the NAAQS analysis are presented in Table 3.

Table 3: Background Concentrations

Pollutant Averaging
Period
Background
Concentration
(μg/m3)
PM10 24-hour 65.4
PM2.5 24-hour 10.2
Annual 4.2

I. Meteorological Data Processing

For the AERMOD model, on-site horizontal and vertical wind speed, direction, solar radiation and,
temperature data was combined with National Weather Service (NWS) upper air data collected at the Salt
Lake City International Airport (SLCIA) for the same period using the US EPA AERMET processing
system.

Meteorological data used for the CALPUFF modeling analysis consisted of 3 years (2018-2020) of data
developed by the Forest Service. The grid was 708 km (east-west) by 492 km (north-south) with a
resolution of 12 kilometers.

VI. RESULTS AND CONCLUSIONS

The Applicant performed a series of analyses to estimate the impact from the proposed project. Modeling
results and conclusions from the review of the analyses are outlined in detail below.

A. Pre-Construction Monitoring and Significant Impact Modeling

The Applicant performed a preliminary criteria pollutant analysis of the proposed modification. This
analysis indicated that increases in concentration levels of PM2.5 and PM10 were greater than the Class II
SIL, and therefore, a cumulative analysis for these pollutants was required.

DAQE-MN103030032-24
Page 7

B. NAAQS Analysis

The Applicant performed a modeling analysis to determine if the combined impact from the proposed
source, other industrial sources operating in the area, and ambient background would comply with the
NAAQS. The NAAQS analysis was reviewed by the Division and determined to be consistent with the
requirements of R307-410-3. Table 4 provides a comparison of the Applicant’s predicted air quality
concentrations and the NAAQS.

Table 4: Model Predicted NAAQS Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-hour 28.3 5 65.4 0 93.7 150 62.5%
PM2.5 24-hour 9.6 1.2 10.2 0 19.8 35 56.6%
Annual 4.4 0.3 4.2 0 8.6 9 95.6%
* Note: Only included other sources and background if source impact was above Class II SIL

C. PSD Class II Increments

The Applicant performed an analysis to determine if the impact from the proposed source would comply
with PSD Class II increments. The analysis was reviewed by the Division and determined to be
consistent with the requirements of R307-410-3. Table 5 provides a comparison of the predicted
concentrations and the PSD Class II increment.

Table 5: Model Predicted PSD Class II Increment Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Nearby
Sources*
Total Increment Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
PM10 Annual 8.1 1 0 8.1 25 32.4%
24-hour 28.3 5 0 28.3 30 94.3%
PM2.5 24-hour 6.1 1.2 0 6.1 9 67.8%
Annual 2.4 0.3 0 2.4 4 60.0%

D. Hazardous Air Pollutants

DAQE-MN103030032-24
Page 8
The Applicant performed an analysis to determine if HAP modeling is required. The analysis was
reviewed by the Division and determined to be consistent with the requirements of R307-410-3. The
analysis indicated that HAP modeling was not triggered by this modification, and therefore no HAP
modeling was performed.

E. PSD Class I Increment Consumption Analysis

The Applicant performed a CALPUFF analysis to determine if the impact from the proposed source along
with other increment consuming sources would comply with federal PSD Class I increments. The
analysis was reviewed by the Division and determined to be consistent with the requirements of R307-
410-3. The results for all Class I areas within 300 kilometers are provided in Table 6.

Table 6: Model Predicted PSD Class I Increment Concentrations

Air Period Prediction
Class I
Significant
Impact
Level
Other
Sources* Total Increment Percent
Pollutant (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
Capitol Reef
NO2 Annual 0.0018 0.1 2.5
SO2
3-Hour 0.0494 1 25
24-
Hour 0.0150 0.2 5
Annual 0.0008 0.1 2
PM2.5
24-
Hour 0.0430 0.27 2
Annual 0.0021 0.05 1
PM10
24-
Hour 0.0444 0.3 8
Annual 0.0021 0.2 4
Arches
NO2 Annual 0.0008 0.1 2.5
SO2
3-Hour 0.0408 1 25
24-
Hour 0.0102 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0522 0.27 2
Annual 0.0018 0.05 1
DAQE-MN103030032-24
Page 9
PM10
24-
Hour 0.0531 0.3 8
Annual 0.0019 0.2 4
Canyonlands
NO2 Annual 0.0010 0.1 2.5
SO2
3-Hour 0.0354 1 25
24-
Hour 0.0100 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0577 0.27 2
Annual 0.0019 0.05 1
PM10
24-
Hour 0.0591 0.3 8
Annual 0.0020 0.2 4
Bryce
NO2 Annual 0.0006 0.1 2.5
SO2
3-Hour 0.0369 1 25
24-
Hour 0.0082 0.2 5
Annual 0.0003 0.1 2
PM2.5
24-
Hour 0.0189 0.27 2
Annual 0.0010 0.05 1
PM10
24-
Hour 0.0194 0.3 8
Annual 0.0010 0.2 4
Zion
NO2 Annual 0.0011 0.1 2.5
SO2
3-Hour 0.0293 1 25
24-
Hour 0.0105 0.2 5
Annual 0.0005 0.1 2
PM2.5
24-
Hour 0.0266 0.27 2
Annual 0.0011 0.05 1
PM10 24-
Hour 0.0271 0.3 8
DAQE-MN103030032-24
Page 10
Annual 0.0012 0.2 4
* Note: Only included other increment consuming sources if source impact was above Class I SIL

Since the proposed project’s model predicted impacts at the Class I areas were less than the PSD Class I
significance levels, a cumulative analysis was not warranted.

DAQE-MN103030032-24
Page 11
F. Visibility – Plume Blight
Since the Class I areas are greater than 50 kilometers from the source, a plume blight analysis using
VISCREEN was not required.

G. Visibility – Regional Haze

The results of the Q/D analysis for the emissions increase was less than 10 but the FLMs wanted the
entire source included in the Q term. The results of including the total emissions resulted in a Q/D >10,
so an AQRV analysis was performed for visibility and acid deposition. The results shown in Table 7
indicate that the impacts are below the 0.5 Deciview (DV) threshold established by the National Park
Service, indicating that no further analysis is required.

Table 7: CALPUFF Visibility Results

Class I Area Year Maximum
Delta DV
98th
Percentile
change in
DV
#
Days
#
Days Threshold
(DV)
Below
Threshold
> 1 > 0.5
2018 0.248 0.06 0 0 0.5 Yes
Arches 2019 0.291 0.054 0 0 0.5 Yes
2020 0.216 0.106 0 0 0.5 Yes
2018 0.223 0.081 0 0 0.5 Yes
Canyonlands 2019 0.312 0.068 0 0 0.5 Yes
2020 0.186 0.085 0 0 0.5 Yes
2018 0.059 0.03 0 0 0.5 Yes
Bryce 2019 0.081 0.045 0 0 0.5 Yes
2020 0.071 0.03 0 0 0.5 Yes
2018 0.183 0.074 0 0 0.5 Yes
Capital Reef 2019 0.196 0.092 0 0 0.5 Yes
2020 0.126 0.078 0 0 0.5 Yes
2018 0.069 0.04 0 0 0.5 Yes
Zion 2019 0.123 0.039 0 0 0.5 Yes
2020 0.102 0.057 0 0 0.5 Yes

DAQE-MN103030032-24
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H. Acid Deposition

The Applicant performed a deposition analysis on impacts within the Class I areas. Results of the
analysis indicate that the impacts are below the deposition threshold (DAT) established by the National
Park Service, indicating that no further analysis is required

Table 8: CALPUFF Deposition Results for Highest Year

Class I Area
Total
Nitrate
Deposition
Total
Sulfate
Deposition
Deposition
Analysis
Threshold
(kg/ha/yr) (kg/ha/yr) (kg/ha/yr)
Canyonlands 0.0006 0.0003
0.005
Zion 0.0004 0.0002
Arches 0.0006 0.0003
Bryce 0.0006 0.0002
Capitol Reef 0.0011 0.0005

I. Soils and Vegetation Analysis

The Applicant performed an analysis to determine the extent of impacts from the proposed source on soil
and vegetation. Results of the analysis are presented in a supplemental document titled “Soil and
Vegetation Impact Analysis for the Leamington, UT Facility, June 29, 2023”. The analysis indicated that
predicted concentrations compared against the secondary NAAQS at several sensitive receptors would not
result in an adverse impact on soils and vegetation in the vicinity of the proposed project.

DP/JK:jg

DAQE-IN103030032-25

January 22, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Mr. Nelson:

Re: Intent to Approve: Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — ) A A v A ? A D @ A w D D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — ) A A v A ? A D @ A w D D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ash Grove Cement Company Ash Grove Cement Company - Leamington Cement Plant

Mailing Address Physical Address
P.O. Box 38069 Highway 132
Leamington, UT 84638 Leamington, UT 84638

Source Contact UTM Coordinates
Name: Cody Watkins 397000 m Easting
Phone: [phone] 4380100 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3241 (Cement, Hydraulic)

SOURCE INFORMATION
General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried on site),
are correctly proportioned, ground, and mixed and then fed into a rotating kiln. The kiln alters the
materials and recombines them into small stones called cement clinker. The clinker is cooled and ground
with gypsum and additional limestone into a fine powdered cement. The final product is stored on site for
later shipping. The major sources of air emissions are from the combustion of fuels for the kiln operation,
from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source of
emissions of PM2.5, PM10, NOx, CO, HAPs, and GHG. It is a minor source of SO2 emissions.
NSR Classification
Major PSD Modification

Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
DAQE-IN103030032-25
Page 4

Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

These changes result in increases in actual emissions but decreases in most potential emissions. There will
be an increase in the potential emissions of VOCs and greenhouse gases.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
DAQE-IN103030032-25
Page 5

Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
DAQE-IN103030032-25
Page 6

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
DAQE-IN103030032-25
Page 7

II.A.4 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)
II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area, and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, stacker systems. II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit-specific requirements.
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total air flow controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter
area; 9,865 acfm total air flow, controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are
controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each
is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6). II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The
following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for
NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.
II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low-pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

DAQE-IN103030032-25
Page 8

II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow through stack
E34.
II.A.18 Kiln Feed Alleviator A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the central material silo between the blending silos and the preheater. Raw feed is removed from the system near the top of the preheater tower.
II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The
coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter area;
1,700 acfm total air flow.
II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker
storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1): 1,800 acfm that discharges into the clinker tunnel.
II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
DAQE-IN103030032-25
Page 9

II.A.27 Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during loading.
II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel, all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during loading. 512.BF3 (1,000 acfm) is located on top of the silo. II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement products. Dust generated
during milling is captured by a BHA pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).

II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates from stack G55 (finish mill stack).
II.A.32 Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4).
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1 thru 3).

II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total air flow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations.
II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This
baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

DAQE-IN103030032-25
Page 10

II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.
II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023)
II.A.40 Dust Shuttle System A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides, surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the
fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

II.A.41 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons) Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
DAQE-IN103030032-25
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II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)
THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)
CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)
PM: 0.02 lbs filterable PM per ton of clinker.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR 60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to approve alternative control measures, the permittee shall keep a copy of the submitted petition and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source
of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2).
[40 CFR 63 Subpart LLL]

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II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must record the PM CPMS output data for all periods when the process is operating and use all the PM CPMS data for calculations when the PM CPMS is not out of control. The owner/operator must demonstrate continuous compliance by using all quality-assured hourly average data collected by the PM CPMS for all operating hours to calculate the arithmetic average operating parameter in units of the operating limit on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
DAQE-IN103030032-25
Page 13

II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

II.B.1.e.3 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-165]
II.B.1.e.4 PM 40 CFR 60, Appendix A, Method 5, or 5I, or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three runs, with each
run at least 120 minutes in duration and each run collecting a sample of 60 dry standard cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165]
DAQE-IN103030032-25
Page 14

II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
DAQE-IN103030032-25
Page 15

II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
DAQE-IN103030032-25
Page 16

II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer point, is not required to conduct Method 22 visible emissions monitoring under this paragraph. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator may decrease the frequency of performance testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
DAQE-IN103030032-25
Page 17

II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: Instances of water and/or chemical application to unpaved areas shall be recorded and maintained by the owner/operator. The ambient temperature shall be recorded any time water should be applied but cannot due to freezing conditions. [R307-401-8]
II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

The sprays shall operate whenever dry conditions warrant meeting the required opacity
limitations or as determined necessary by the Director. Water sprays shall not be required during
periods of freezing temperatures.

[R307-401-8]

DAQE-IN103030032-25
Page 18

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

C. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the kiln/raw mill stack

F. The owner/operator shall record the output of the system: including the quantity of NOx, CO, O2, THC, Hg, HCl, and CO2 emissions at the kiln stack

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an
affected source shall continuously operate all required continuous monitoring devices
and shall meet minimum frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.

[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]
II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments, the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the results of the performance test demonstrating compliance with the filterable PM limit and using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust the SSOL developed in accordance with the results of the most recent PM performance test demonstrating compliance with the PM emission limit. The owner/operator shall use the PM CPMS to demonstrate continuous compliance with the SSOL in accordance with the requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

DAQE-IN103030032-25
Page 19

II.B.4 Fuel Limitations: II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke F. Fuel Oil
G. Used Oil Fuel

H. Synthetic Fuel
I. Wood
J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal additive.
Approval is not required to change from one previously approved coal additive to another
previously approved coal additive. [R307-401-8]
II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily heat input of the kiln and precalciner. The owner/operator may increase the average quantity of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon approval by the Director in accordance with the approval process described in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

DAQE-IN103030032-25
Page 20

II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight
A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation
C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit-no less than 1500oF for more than five minutes in any 60-minute period B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
DAQE-IN103030032-25
Page 21

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the Director. The calibration procedure and frequency shall be according to manufacturer's specifications. Use of factory-calibrated thermocouples for temperature measurement is approved. However, any other method of temperature measurement must be approved by the Director prior to use. The monitoring equipment for both temperature and oxygen content shall be located such that an inspector can at any time safely read the output. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall only operate the emergency engines for testing and maintenance purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency operation. [R307-401-8]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.5.b.2 To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From Source Submitted NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-IN103030032-25
Page 22

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-GN103030032I-25

January 22, 2025

Via Certified Mail 70190700000208349789

Lisa Devore
National Park Service
Intermountain Region
12795 West Alameda Parkway
Lakewood, CO 80225
[e-mail]

Dear Ms. Devore:

RE: Notice of Publication for Ash Grove Cement Company- Leamington Cement Plant – CDS A;
MACT (Part 63), Compliance Assurance Monitoring (CAM), Title V (Part 70) Major Source,
Major Criteria Source, Major HAP Source, Attainment Area, NSPS (Part 60),
Project Number: N103030032

On January 22, 2025, the Director has completed his review of a Prevention of Significant Deterioration
project submitted by Ash Grove Cement Company. Attached to this letter are the draft Approval Order
document (Intent to Approve) and the full engineering review. Following a 60-day review by the Federal
Land Managers, this project will be submitted for a 30-day public comment period. Written comments
received by the Division at this same address during these comment periods will be considered in making
the final decision on the approval/disapproval of the proposed Approval Order. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director at the Division in writing, a hearing
will be held in accordance with R307-401-7, UAC.

If you have any questions, please contact John Jenks, who may be reached at [phone].

Sincerely,

Jon L. Black, Manager
New Source Review Division

Enclosures: Engineering Review
Modeling Memo
Intent to Approve

JLB:JJ:jg
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

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State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
RN103030032
January 21, 2025
Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]
Dear Josh Nelson,
Re: Engineer Review:
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032
Please review and sign this letter and attached Engineer Review (ER) within 10 business days.
For this document to be considered as the application for a Title V administrative amendment, a
Title V Responsible Official must sign the next page.
Please contact John Jenks at [phone] if you have any questions or concerns about the ER.
If you accept the contents of this ER, please email this signed cover letter to John Jenks at
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 1

[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the
DAQ will consider any comments received and will issue the Approval Order.

If you do not respond to this letter within 10 business days, the project will move forward
without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue
an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 2

OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible
Official, as defined in R307-415-3, must sign the statement below. THIS IS STRICTLY
OPTIONAL.

If you do not want the Engineer Review to be considered as an application to administratively
amend your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will
require submittal of a separate Operating Permit Application to revise the Title V permit in
accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document:
Title V Operating Permit Application Due Dates clarifies the required due dates for Title V
operating permit applications and can be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality

“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate
and complete and request that this Approval Order be considered as an application
to administratively amend the Operating Permit.”

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 3

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N103030032
Owner Name Ash Grove Cement Company
Mailing Address P.O. Box 38069
Leamington, UT, 84638

Source Name Ash Grove Cement Company- Leamington Cement
Plant
Source Location Hwy 132
Leamington, UT 84638

UTM Projection 397000 m Easting, 4380100 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3241 (Cement, Hydraulic)

Source Contact Cody Watkins
Phone Number [phone]
Email [e-mail]

Billing Contact Cody Watkins
Phone Number 385.225.0615
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 30, 2022
Date of Accepted Application November 28, 2024

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 4

SOURCE DESCRIPTION

General Description
Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried
on site), are correctly proportioned, ground and mixed, and then fed into a rotating kiln. The kiln
alters the materials and recombines them into small stones called cement clinker. The clinker is
cooled and ground with gypsum and additional limestone into a fine powdered cement. The final
product is stored on site for later shipping. The major sources of air emissions are from the
combustion of fuels for the kiln operation, from the kiln, and from the clinker cooling process.
The Leamington cement plant is a major source for emissions of PM2.5, PM10, NOx, CO, HAPs
and GHG. It is a minor source of SO2 emissions.

NSR Classification:
Major PSD Modification

Source Classification
Located in Attainment Area,
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Proposal
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower, various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 6

These changes result in increases in actual emissions, but decreases in most potential emissions.
There will be an increase in the potential emissions of VOC and greenhouse gases.

EMISSION IMPACT ANALYSIS
The complete modeling review is located in DAQE-MN103030032-24. [Last updated January 14, 2025]

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 7

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
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Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

Note: Change in emissions indicates the difference between previous AO and proposed modification.

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Review of BACT for New/Modified Emission Units

1. BACT review regarding the Leamington Plant Upgrade Project
Any major stationary source or major modification subject to PSD review must undergo an
analysis to ensure the use of BACT. The requirement to conduct a BACT analysis is set forth in 40
CFR 52.21. Similarly, Utah requires the installation of BACT for all sources of air pollution under
R307-401-5(2)(d)), BACT is defined in 40 CFR 52.21 (and R307-401-2) as:

". . . best available control technology means an emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for each pollutant subject to regulation under
Act which would be emitted from any proposed major stationary source or major modification
which the Administrator, on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such source or modification
through application of production processes or available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion techniques for control of such
pollutant . . ."

Therefore, a BACT analysis is required for each new or physically modified emission unit for each
pollutant that exceeds an applicable PSD significant emission rate (SER). Since the PM10 and PM2.5
emissions from the proposed project exceed the applicable PSD SER, a BACT analysis is required
to assess the required levels of control for these pollutants. Because the CO2e emissions are subject
to regulation as a result of the proposed project resulting in an increase of 75,000 tons or more per
year CO2e, a BACT analysis is also required for that pollutant. Note that HAPs listed under CAA
Section 112(b)(1) are excluded from NSR (New Source Review) or PSD (i.e., BACT) review.

In a memorandum dated December 1, 1987, the United States Environmental Protection Agency
(EPA) stated its preference for a "top-down" BACT analysis. After determining if any New Source
Performance Standard (NSPS) is applicable, the first step in this approach is to determine, for the
emission unit in question, the most stringent control available for a similar or identical source or
source category. If it can be shown that this level of control is technically, environmentally, or
economically infeasible for the unit in question, then the next most stringent level of control is
determined and similarly evaluated. This process continues until the BACT level under
consideration cannot be eliminated by any substantial or unique technical, environmental, or
economic objections.

Presented below are the five basic steps of a top-down BACT review as identified by the EPA.
Step 1 - Identify All Control Technologies
Step 2 - Eliminate Technically Infeasible Options
Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Step 4 - Evaluate Most Effective Controls and Document Results
Step 5 - Select BACT

Ash Grove has elected to follow this methodology and based the BACT review on each individual
pollutant. The complete BACT analysis follows. [Last updated January 14, 2025]

2. BACT review regarding PM10 and PM2.5 Sources
PM10 and PM2.5 Modified Equipment
The existing kiln precalciner, preheater, and alleviator system are proposed to be modified, and the
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kiln's ID fan and clinker cooler fans are proposed to be replaced, which will result in increased
airflow. Additionally, the clinker cooler baghouse will be converted from a plenum pulse to a pulse
jet baghouse. These modifications are projected to result in a net increase of potential PM10 and
PM2.5 emissions.

Kiln Upgrade BACT
The rotary cement kiln is the core of the cement manufacturing process, transforming the blended
raw materials or "rawmix" into clinker through pyro processing. Emissions from the kiln occur
from fuel combustion plus the physical and chemical reactions needed to transform the rawmix
into clinker. This project involves process and energy efficiency improvements and an increase in
kiln production, resulting in an increase of PM10 and PM2.5 emissions. This section specifically
addresses filterable PM10 and PM2.5. The condensable fraction is represented with the other
precursors as applicable to proposed emission increases.

The Leamington Plant's Kiln is subject to NSPS, Subpart F for particulate. Therefore, a BACT
analysis addresses applicability of the proposed changes to the kiln system to NSPS and review of
the RBLC. A summary of the resources reviewed include the following:

NSPS Subpart F - Standards of Performance for Portland Cement Plants establishes emission
standards for cement kiln operations. Specifically, kilns modified after June 16, 2008, are limited to
0.07 lbs PM/ton of clinker produced.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028) and
Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from kiln operations are as follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM emissions are most effectively controlled using a collection system with enclosures routed to
baghouses providing up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Ash Grove
has selected technology with the highest control efficiency, so there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.
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Step 5 - Select BACT
Ash Grove proposes that BACT for PM10 and PM2.5 emissions from the kiln consist of a collection
system routed to a baghouse or fabric filter that complies with NSPS Subpart F's emission standard
for a modified source. BACT for the Leamington Plant's kiln are 10% opacity and 0.07 lb of
PM/ton (NSPS Subpart F emission standard) of clinker.
[Last updated January 14, 2025]

3. BACT review regarding PM10 and PM2.5 sources cont.
Clinker Cooler Upgrade BACT
The clinker cooler reduces the temperature of the clinker exiting the kiln. It is necessary to reduce
clinker temperature before it enters the finish mill to maintain product quality and reduce wear and
tear on equipment. The clinker cooler is equipped with a heat exchanger that captures waste heat
and transfers it to the kiln preheater for process and energy efficiency. Emissions from the clinker
cooler are vented to a baghouse. The Leamington Plant's clinker cooler is also subject to NSPS
Subpart F for particulate. Ash Grove's proposed changes to the clinker cooler meet the definition of
a reconstruction under NSPS. Therefore, in order to meet the requirements of NSPS Subpart F, Ash
Grove will be required to meet a limit of 0.02 lb of PM/ton of clinker.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from clinker cooler operations are as
follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM10 and PM2.5 emissions are most effectively controlled using a collection system with enclosures
routed to a baghouse, which can achieve up to 99.9% control efficiency. Other technologies such as
wet scrubbers, cyclones and ESPs are feasible, but provide lower control efficiencies than a
baghouse. Because the most efficient control technology is proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for PM10 and PM2.5 emissions from the clinker cooler is a collection system routed to a
baghouse or fabric filter. In order to meet the requirements of NSPS Subpart F, Ash Grove will
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meet a reduced emission limit of 0.02 lb of PM/ton of clinker. A 10% opacity limit is also
applicable. [Last updated January 14, 2025]

4. BACT review regarding PM10 and PM2.5 sources cont.
New Finish Mill BACT
The proposed Plant upgrade include adding a second finish mill. The new finish mill will use an
energy efficient vertical roller mill assisted with a grinding aid. A total of five (5) point sources are
planned for the finish mill. In accordance with NSPS Subpart F, emissions from finish mill are
restricted to 10% opacity. Ash Grove has reviewed the following sources to identify available
control technologies.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);12 and

Region 8 General Permit for Concrete Batch Plants.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 emissions from plant material handling operations are as
follows:
Baghouse / Fabric Filter;
Best Management & Operational Practices;
Cyclone;
ESP;
Enclosure;
Water Application (Watering); and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
With the exception of water application, all options are technically feasible. Water application is
eliminated as clinker exiting the kiln along with additives in the finish mill must remain dry to
maintain product quality. Therefore, it is technically infeasible to water material in the finish mill.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Enclosure 50-90%
5. Cyclone 20-70%
6. Best Management & Operational Practices varies

Step 4 - Evaluate Most Effective Controls and Document Results
Baghouses provide the highest emission control efficiency, controlling up to 99.9% of PM
emissions from finish mill equipment. After baghouses, using a wet scrubber or ESP provides
similar PM control. Notably, baghouses, scrubbers, and ESPs require enclosures to aid in capturing
emissions and ducting to the control. Therefore, optimal PM emission control can be achieved
through implementing both baghouses and enclosures where feasible. Plant material sizing and
handling is currently done using a series of buildings and enclosures routed to baghouse controls.
Various silos storing material inputs are also equipped with fabric filters. As the highest ranked
technology is applied, there are no adverse energy, environmental or cost impacts to consider with
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the use of these control technologies. Thus, no further analysis is required under EPA's top-down
BACT approach.

Step 5 - Select BACT
BACT for finish mill PM10 emissions is compliance with NSPS Subpart F, Standards of
Performance for Portland Cement Manufacturing where applicable. Ash Grove will achieve BACT
for PM10 emissions from finish mill equipment through the implementation of enclosures,
baghouses, and best management practices. All baghouses at the finish mill will have a 10%
opacity limitation and a grain loading of 0.005 grains/dscf. [Last updated January 14, 2025]

5. BACT review regarding PM10 and PM2.5 sources cont.
Material Transfer, Sizing, and Storage BACT
The Leamington Plant has sources of fugitive emissions through raw material transfer. Materials
transferred include limestone and other raw materials, coal, clinker, and cement. These materials
are transferred by conveyor belt, screw conveyor, elevator, pneumatic conveyance or chutes via
gravity. At the Leamington Plant the fugitive emissions are enclosed at their transfer points and
routed to baghouses.

The following emission units are included in this category:
Limestone Crushing, Sizing, and Material Transfer;
Raw Material Transfer;
Coal Sizing and Transfer;
Existing Finish Mill;
Clinker Storage and Transfer;
Cement Storage and Truck and Rail Cement Loadout;
New Rail Loading and Loadout; and
New Clinker Reclaim Hopper Baghouse.

Generally, controls for these units have not changed or they are similar to current existing controls.
A full BACT analysis of each unit is included in Ash Grove's NOI and additional submitted
information. However, given that most controls remain unaltered, only the results of Step 5 -
Select BACT will be included here.

Limestone Crushing, Sizing, and Material Transfer
Subject to NSPS Subpart OOO opacity limits for existing sources.
Existing baghouses. No change from bag manufacturer's specifications.

Raw Material Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Coal Storage and Transfer
Existing Equipment. No change from bag manufacturer's specifications
20% Opacity

Clinker Storage and Transfer
Subject to NSPS Subpart F opacity limits:
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10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Existing Finish Mill Grinding, Storage and Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Cement Storage and Truck and Rail Cement Loadout, New Rail Loadout
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

New Rail Loadout, controlled by baghouse
Emissions Limit - 0.005 gr/dscfm

New Clinker Reclaim Hopper, controlled by baghouse
Subject to NSPS Subpart F opacity limits:
10% opacity
Emissions Limit - 0.005 gr/dscfm [Last updated January 14, 2025]

6. BACT review regarding PM10 and PM2.5 sources cont.
PM10 and PM2.5 Fugitive Emissions
The following fugitive emissions sources will increase emissions of PM10 and PM2.5 as a result of
the Leamington Plant's proposed throughput increase. The sources addressed in the following
BACT analyses are primarily in the quarry, but also include emissions from roads and dumping of
raw materials within the plant boundary.

The sources evaluated are listed below:
Roads;
Loading and Unloading;
Stockpiles;
Bulldozing and Grading;
Disturbed Areas; and
Drilling and Blasting.

Ash Grove currently controls emissions from these processes, and generally, controls for these
units have not changed. A full BACT analysis of each unit is included in Ash Grove's NOI and
additional submitted information. However, given that most controls remain unaltered, only the
results of Step 5 - Select BACT will be included here.

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
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Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

Stockpiles BACT
BACT shall consist of restricting fugitive emissions to the opacity standard of 20% opacity at the
property boundary. BACT for stockpiles will be achieved through applying good management
practices through its fugitive dust plan as appropriate.

Bulldozing and Grading BACT
BACT shall consist of restricting fugitive emissions from bulldozing and grading activities to no
more than 20% opacity, and that emissions are controlled with periodic watering of the disturbed
surface. The frequency of water application will depend on ambient weather conditions and
inherent moisture content of the material being moved.

Disturbed Areas BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. BACT for
disturbed areas will be achieved through best management practices, watering, scarification, and
revegetation.

Drilling and Blasting BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. This is achievable
through best management practices, shrouds, watering, and dust collection. [Last updated January
14, 2025]

7. BACT review regarding kiln system NOx emissions
Kiln System (Kiln, Raw Mill, and Coal Mill) - NOx BACT
Although there are physical changes to the kiln system, these changes are primarily related to
particulate emissions. NOx emissions are generated from the combustion of fuel - and no changes
in NOx emissions are expected from the kiln (hourly capacity to emit). The kiln NOx emissions will
remain the same as a result of upgrades to the SNCR system. The replacement of the various
components of the kiln system and portions of the preheater tower, along with new injection points,
will ensure that increased mixing of ammonia is achieved to enhance the SNCR system's ability to
reduce NOx and minimize ammonia slip. This will allow the Leamington Plant to maintain the NOx
hourly capacity to emit unchanged from current levels Leamington Plant Upgrade Project. At
present Ash Grove has no restriction on the amount of fuel combusted, only a limit on total NOx
generated, and with this project the allowed NOx PTE is decreasing from 1,352 tpy to 1,226 tpy.

Additional ammonia will be used in the existing SNCR system. While the SNCR system has
adequate capacity to accommodate the additional ammonia demand resulting from the system
upgrades, more ammonia ports are proposed to be added with the kiln system's proposed changes
of the equipment. The changes proposed to the kiln system will increase residence time and
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temperature which will improve the SNCR system's effectiveness to control NOx emissions and
minimize ammonia slip emissions to the atmosphere. No additional review of NOx BACT for the
kiln system is required under this proposal. [Last updated January 14, 2025]

8. BACT review regarding new finish mill heater emissions
Finish Mill Heater
The proposed finish mill will include a process heater to maintain a minimum temperature during
milling. The proposed heater will run on natural gas and is rated at 10 MMBtu/hr. Startup and
shutdown emissions from the heater are anticipated to be no greater than normal operation as the
process is simply a matter of bringing the heater to operating temperature. Emissions evaluated in
the BACT analysis for the finish mill heater include NOx, SO2, CO, and VOCs, PM10, and PM2.5.
Pollutants with identical control technologies are grouped together in the analysis.

NOx - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for NOx from units of this size range are as follows:
Ultra-Low-NOx Burners (ULNB);
Low NOx Burners;
Selective Catalytic Reduction (SCR);
Selective Noncatalytic Reduction (SNCR);
Good Combustion Practices; and
Use of Natural Gas.

Step 2 - Eliminate Technically Infeasible Options
Low exit temperatures render the use of SCR and SNCR ineffective. Particulate entrainment within
the finish mill could potentially foul (plug) the nozzles of ULNB. Low-NOx burners, the use of
natural gas as fuel and good combustion practices are all considered technically feasible.

Step 3 and Step 4 - Rank Remaining Control Technologies by Control Effectiveness and Evaluate
Most Effective Controls and Document Results
Since the three feasible control technologies are proposed for the finish mill heater, no detailed
economic, energy, and environmental impact evaluations were conducted. No ranking of control
effectiveness is required as all three controls are proposed.

Step 5 - Select BACT
BACT for NOx is the use of natural gas as fuel, good combustion practices and the use of Low NOx
burners.

CO, SO2, and VOC - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for CO, SO2, and VOC from units of this size are as follows:
Good Combustion Practices
Use of Natural Gas

The finish mill heater combusts natural gas. Related natural gas combustion emissions are
anticipated to be minimal.

Step 2 - Eliminate Technically Infeasible Options
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Both control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Both technologies offer intrinsic emission reductions from combustion. Since the technologies do
not compete, both technologies can and will be used simultaneously.

Step 4 - Evaluate Most Effective Controls and Document Results
Because both control technologies identified in Step 1 are proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for CO, SO2, and VOC are good combustion practices and the use of natural gas.

PM10 and PM2.5 BACT for the finish mill has been addressed in the PM10/PM2.5 sources section.
[Last updated January 14, 2025]

9. BACT review regarding SO2, VOC, and Lead Sources
The following BACT analysis is grouped by pollutants that will experience an increase in potential
emissions and the associated technically feasible control technologies. As such, the BACT analysis
is separated into SO2, VOC, and lead respectively with organic HAPs addressed with VOCs.

SO2 - Cement Kiln BACT
NSPS Subpart F - Standards of Performance for Portland Cement Plants, establishes emission
standards for cement kiln operations. Specifically, kilns constructed or reconstructed after June 16,
2008, are limited to 0.4 lbs SO2/ton clinker on a 30-day rolling average respectively. This limit is
an existing emission limit in the Leamington Plant's approval order and Title V. Ash Grove will
continue to achieve this emission limitation while achieving BACT for the kiln operations. Ash
Grove has reviewed the following sources to identify available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019); and

NSPS Subpart F as an affected emissions facility in 40 CFR 60.62(a)(4);

Portland Cement Association's Formation and Techniques for Control of Sulfur Dioxide and Other
Sulfur Compounds in Portland Cement Kiln Systems.

SO2 emissions are a result of oxidation of sulfur compounds in the rawmix and/or the coal used to
fire the kiln. However, the alkaline nature of the cement provides for direct absorption of SO2 into
the product, thereby mitigating the quantity of SO2 emissions in the exhaust stream.

Step 1 - Identify All Control Technologies
Control technologies identified for SO2 emissions from coal-fired kiln operations are as follows:
Baghouse or fabric filter;
Dry reagent injection prior to baghouse;
Wet scrubber;
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Process optimization; and
Good combustion practices.

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below:

1. Process Optimization 99%
2. Wet Scrubber 99%
3. Dry Reagent Injection 60%
4. Good Combustion Practices 30%
5. Baghouse Variable

Step 4 - Evaluate Most Effective Controls and Document Results
SO2 emissions are most effectively controlled by optimizing the process and utilizing the inherent
SO2 scrubbing properties of the kiln system itself. Although wet scrubbers alone can achieve equal
control efficiencies as process optimization, additional capital and operational expenses are
required for water consumption and wastewater discharge. Whereas process optimization achieves
the same control effectiveness and has the added benefit of reduced operational costs. Ash Grove
optimizes the kiln process by routing the exhaust from the kiln to a preheater and raw mill to
interact with the raw mix, thus creating an atmosphere similar to a dry scrubber system. Good
combustion practices also reduce SO2 formation with the added benefit of energy efficiency.

Step 5 - Select BACT
BACT for control of SO2 emissions from kiln operations shall consist of process optimization by
routing kiln exhaust to the preheater and raw mill, good combustion practices, and use of a
baghouse prior to exhausting to the atmosphere. As a modification of the kiln, 40 CFR 60.62(a)(4)
requires an emission limit of 0.4 pounds of sulfur dioxide (SO2) per ton of clinker on a
30-operating day rolling average. [Last updated January 14, 2025]

10. BACT review regarding SO2, VOC, and Lead Sources cont.
VOC - Cement Kiln BACT
VOCs are generated by incomplete combustion in the kiln. 40 CFR 63 Subpart LLL - NESHAP
from the Portland Cement Industry limits total hydrocarbon and total organic HAP emissions to 24
and 12 ppmv at 7% oxygen. Ash Grove will achieve or exceed these emission limitations while
achieving BACT for the kiln operations. Ash Grove has reviewed the following sources to identify
available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028); and

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for VOC emissions from coal fired kiln operations are as follows:
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Process optimization,
Good combustion practices

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below.

1. Process Optimization Variable
2. Good Combustion Practices Variable

Step 4 - Evaluate Most Effective Controls and Document Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove optimizes the
kiln process by capturing waste heat from the clinker cooler and routing to a kiln preheater. Good
combustion practices also reduce VOC formation with the added benefit of energy efficiency.
There are no adverse energy, environmental or cost impacts to consider with the use of this control
technology.

Step 5 - Select BACT
BACT for control of VOC emissions from kiln operations shall consist of process optimization by
routing kiln heat to the preheater and good combustion practices. An emission limit of 24 ppmv
VOC @ 7% O2 is imposed by NESHAP Subpart LLL.

VOC - Grinding Aid BACT
A grinding aid containing VOC is added to the new finish mill to disperse particles within the mill
and expose more surface area to grinding. An increase in grinding aid usage proportionally
increases potential VOC emissions because volatiles from the grinding aid are not combusted in
the kiln.

There is only one identified control option for limiting the VOC emissions from the grinding aid.
Process optimization is technically feasible. VOC emissions are most effectively controlled by
optimizing the process. Ash Grove proposes to install a vertical finish mill with this project. Due to
the new modern mill's efficiency, it is anticipated that a reduced amount of grinding aid will be
required for each ton of clinker ground. Ash Grove estimates total VOC emissions from the
grinding aid at 2.37 tpy.

Lead Emissions
The lead emissions are anticipated to increase as a result of the proposed increase in clinker
throughput with the Leamington Plant upgrade project. Lead emissions result from residual
amounts of lead in raw materials and fuel. Lead emissions will be controlled the same as PM,
therefore a separate top-down BACT analysis has not been conducted as the Leamington Plant has
applied the most effective controls. [Last updated January 14, 2025]

11. BACT review regarding Greenhouse Gases
GHG Background
On October 9, 2009, the mandatory GHG reporting regulation, referred to as 40 CFR 98, was
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Page 20

published in the Federal Register. Through 40 CFR 98, the U.S. EPA established the GHG
Reporting Rule, which requires the annual reporting of GHG data and other relevant information
from large sources and suppliers in the United States. Monitoring through the GHG Reporting
Program (GHGRP) began in 2010, with the first reports due by March 31, 2011. Per 40 CFR
98.2(a)(1), any facility associated with cement production is subject to the GHGRP and must report
CO2e emissions. The CO2e is the sum of equivalent GHG emissions from CO2, CH4, and N2O,
with their respective global warming potentials (GWP) applied. Ash Grove's facility is subject to
GHG Reporting Rule and monitors CO2 emissions from its kiln with a continuous emissions
monitoring system (CEMs). On June 23, 2014, the U.S. Supreme Court held that required PSD
permits (based on emissions of non-GHG pollutants) may continue to require limitations on GHG
emissions based on the application of BACT as an "anyway source". The Leamington Plant
modification project is a major source for PSD for both PM10 and PM2.5, and GHGs are estimated
to be greater than 75,000 tpy and greater than zero on a mass basis; therefore, GHGs are evaluated
for BACT as an anyway source.

Cement Manufacturing GHG BACT
A BACT analysis has been conducted for CO2e emissions from the kiln system. For this GHG
BACT analysis, various control technologies or combinations of technologies were identified using
the RACT/BACT/LAER Clearinghouse, available literature including guidance published by EPA
and South Coast Air Quality Management District (SCAQMD), current air regulations, other
regulatory organizations, and engineering experience. In March 2011, EPA published GHG
permitting guidance, as well as a white paper on available and emerging technologies for reducing
GHG emissions from the Portland cement industry in October 2010. Additionally, EPA published a
series of videos on GHG permit training in December 2010. The SCAQMD published GHG BACT
guidance in 2021. Additional sources of information were reviewed and documented based on
publications from trade organizations and other governmental committees with GHG or carbon
reduction guidelines and/or recommendations.

EPA has defined in 40 CFR 86.1818-12(a) GHGs as a group of six gases: CO2, nitrous oxide
(N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF6). GHG emissions from the kiln result from calcination and fuel combustion.
Since the primary GHG emitted by a kiln is CO2, the BACT analysis focuses on CO2 emissions
from the kiln. Emissions of CH4 and N2O are minimal from cement kilns. Per EPA guidance, GHG
control technologies for consideration in a BACT analysis for Portland Cement Manufacturing
include:

Source-wide energy efficiency strategies;
Raw material substitution;
Blended cements;
Carbon capture utilization and storage; and
Fuel switching.
Other emerging technologies [Last updated January 14, 2025]

12. BACT review regarding Greenhouse Gases cont.
Step 1: Identify All Control Technologies
The CO2 emissions from a cement kiln are generated by the calcination process (conversion of the
calcium carbonate in limestone to calcium oxide) and by combustion of fuel in the kiln. Potential
control technologies to reduce these CO2 emissions for a cement kiln are addressed in EPA's white
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paper on Available and Emerging Technologies for Reducing GHG Emissions from the Portland
Cement Industry.

These technologies fall into three categories:
Energy Efficiency Improvements for the Clinker Production Process
Fuel Substitution
Carbon Capture and Sequestration

Step 2: Eliminate Technically Infeasible Options
Several potential energy efficiency improvements are technically feasible: Pre-heater/Pre-calciner
Kiln Process, Kiln Seal Management Program, Refractory Selection (Kiln Insulation), and Energy
Recovery from the Clinker Cooler. The use of alternative fuels such as natural gas, whole tires and
biofuel) is also technically feasible. Other control options, such as Use of Fluxes and Mineralizers,
Heat Recovery for Power - Cogeneration, Carbon Sequestration, Oxyfuel combustion, and
Post-combustion Capture have been deemed infeasible.

Step 3: Rank Remaining Control Technologies by Control Effectiveness
All four remaining control techniques are currently implemented at the Leamington Plant. This
permitting project incorporates energy efficiency improvements. Ash Grove has had a fuel
substitution program in place for several years, and this program is continually reviewed and
updated as new sources and types of fuel are identified.

Step 4: Evaluate Most Effective Controls and Document Results
Since all technically feasible energy efficiency improvements and changes to product composition
will be implemented, this section will focus on economic and environmental considerations of fuel
substitution to operate exclusively on natural gas.

Firing natural gas as the primary kiln fuel can reduce CO2 emissions from fuel combustion by as
much as 40%. However, studies have shown that use of natural gas as primary kiln fuel can result
in three times more NOx emissions than NOx emissions from coal firing. Creating more NOx to
reduce GHG emissions is undesirable as it is a precursor to both ozone and PM2.5. Fuel substitution
essentially trades emissions of one regulated pollutant for another. Estimated capital cost to switch
to natural gas fuel exceeds $25M. Implementing natural gas technology would provide incremental
public health and welfare benefit globally by reducing CO2 emissions, while increasing NOx
emissions and negatively impacting public health and welfare locally. Switching fuels to another
fossil fuel has finite potential to mitigate CO2 emissions.

Step 5: Select BACT
In addition to the proposed energy efficiency improvements addressed elsewhere in this BACT
analysis, BACT is a limit of 0.92-ton CO2e/ton clinker. Ash Grove will use a continuous emission
monitoring system (CEMS) for CO2 to demonstrate compliance with this limit. [Last updated
January 14, 2025]

13. BACT review regarding Leamington Plant Upgrade Project conclusion
The control processes and techniques covered in this BACT analysis have been reviewed by the
NSR Section of the UDAQ. Ash Groves proposed controls and associated emission limitations
represent BACT. Any emission limitations not expressed in an associated NSPS or NESHAP will
be included in the terms and conditions of this AO. A listing of all associated NSPS and NESHAP
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programs is also included in the Source Information section of this document under Applicable
Federal Programs. [Last updated December 13, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date
of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
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proper credit when notifying the Director, send the documentation to the Director, attn.: NSR
Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.

II.A.3
NEW
Stockpiles
Coal storage
Area: 1 acre
Annual throughput 20,000 tpy

AF and ARM stockpiles
Area: 0.25 acre
Annual throughput 8,000 tpy

II.A.4 Stationary Crusher
Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction
of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000
acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)

II.A.5 Raw Material Transfer
Crushed material is transported to raw material storage by belt B8. The raw material transfers
at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor
transfer point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total
filter area & water sprays. (pre-1983)

II.A.6 Material Handling
Conveyor belt systems, secondary feeders and screens, stacker system

II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit specific requirements

II.A.8 Belt Conveyor Transfer Baghouse
Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area
and 1,800 acfm total air flow, controls emissions from the conveyor belt that transfers the
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stacked material to the raw material silos.

II.A.9 Raw Material Silos
Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The
four silos are equipped with one common Fuller, plenum pulse baghouse (315.BF1) - 1,689 ft2
filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage).

II.A.10 Fifth Component Silo
Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse
(315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw
mill feed. This system includes vibrating feeders, a conveyor system, and surge bin.
Emissions are controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3,
316.BF4, 316.BF5) - each is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1
A/C ratio.

II.A.12 Cross-Belt Analyzer
Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6)

II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom
of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw
materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38).
The following equipment is installed: low-NOx burner, selective non-catalytic reduction
(SNCR) for NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued
mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric
monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct
for mercury adsorption capacity. The carbon injection system is not an emission point as it is
in an enclosed building.

II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

II.A.16 Two Kiln Feed Blending Silos
Raw material is blended in one of two blending silos prior to feeding the kiln. The blending
silos are controlled by one common Fuller, plenum pulse baghouse (411.BF1) - 1,351 ft2 filter
area; 7,160 acfm total air flow.

II.A.17 Blending Silo Elevators (2)
Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped
with a Fuller, pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow
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through stack E34.

II.A.18 Kiln Feed Alleviator
A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the
central material silo between the blending silos and the preheater. Raw feed is removed from
the system near the top of the preheater tower.

II.A.19 Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner.
The coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter
area; 1,700 acfm total air flow.

II.A.20 Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in
the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2):
19,500 acfm rated airflow with 3.75:1 A/C ratio

II.A.21 Clinker Cooler and Baghouse
Reconstructed grate type cooler used for cooling clinker from the kiln prior to transfer to
clinker storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) -
173,869 acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter
monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two
clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse
(419.BF8). The exhaust is routed to the clinker cooler stack.

II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions
generated when loading the east and west clinker silos and the out-of-spec silo are controlled
by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1):
1,800 acfm, that discharges into the clinker tunnel.

II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm, that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2)
Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers.
Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses
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(511.HP1 and new 511.HP2): 1,800 acfm each.

II.A.27 Gypsum Silo
Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2
total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust
during loading.

II.A.28 Clinker Tunnel Exitway
The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse
(511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel all discharge in the clinker tunnel.
Emissions are vented through the tunnel exitway.

II.A.29 Limestone Silo
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust
during loading. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement product. Dust
generated during milling is captured by a BHA, pulse jet baghouse (514.BF2) - 6,080 ft2 filter
area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding
stack).

II.A.31 Finish Mill (Ball Mill) Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized
cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA, pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow
controlling particulates from stack G55 (finish mill stack).

II.A.32
NEW
Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The
stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4)
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1,
525.BF1 thru 3)

II.A.33 Finish Cement Storage Silos
There are six storage and two interstice silos where the finished cement product is stored. A
single common Fuller, plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm
total air flow through stack H7 is located on top of the silos and is used to control emissions
during loading and unloading operations.

II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail
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shipping. This baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out
The cement loadout system located on the South side of the silos (truck load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF2) during unloading from the silos for truck
shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement
conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed
space inside the silos.

II.A.36
NEW
Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

II.A.37 MHO: Materials Handling Operation
Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1
& 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4;
512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.

II.A.38 LBS: Limestone Bypass System
Additional limestone is added to the clinker and gypsum by the limestone bypass system
(LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays
at the screen and material handling drop points.

II.A.39 GEN: Emergency Generators
One diesel-fired emergency generator (new)
Rating: 762 hp
(Kiln, Tier 3, permitted 2022)

Two natural gas-fired emergency generators
Rating: 304 hp
(Main office and control room, permitted in 2023)

One diesel-fired emergency generator
Rating: 560 hp
(Shipping, permitted 2023).

II.A.40 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14 inch knife gate, 8 inch knife gate, 8 inch air
slides, surge bin), and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm)
on the fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

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II.A.41
NEW
Miscellaneous Storage Tanks
One diesel storage tank (<2,000 gallons)
One gasoline storage tank (500 gallons)
Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Requirements on the Cement Plant:
II.B.1.a
NEW
The following limits shall not be exceeded:

A. Clinker production - 1,155,000 tons per rolling 12-month period

B. Used oil consumption - 85,724 gallons per rolling 12-month period

C. Limestone bypass material processed - 216,260 tons per rolling 12-month period.
[R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 25th day of each month using data from the previous 12 months.
Records shall be kept for all periods when the plant is in operation. Consumption and
production shall be calculated through use of the plant's acquisition system. [R307-401-8]

II.B.1.b
NEW
Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations:

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

SO2: 0.4 lbs per ton of clinker (3-hr average)

CO: 3,395 tons per rolling 12-month period, and 6,600 lbs/hr

NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average, and 1,233 tons per rolling
12-month period

Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is
400oF or less.

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Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)

THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)

CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)

PM: 0.02 lbs filterable PM per ton of clinker. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL,
R307-401-8]

II.B.1.c
NEW
A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR
60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust
emissions control plan shall be monitored to demonstrate that appropriate control measures are
being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of
the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall
be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in
the plan and that the source is operating in accordance with the submitted plan. For petitions
to approve alternative control measures, the permittee shall keep a copy of the submitted
petition and any approvals received. [40 CFR 60 Subpart Y]

II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area
source of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2). [40 CFR
63 Subpart LLL]

II.B.1.e
NEW
Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b
and II.B.1.d shall be performed as specified below:

A. Kiln/Raw Mill Stack
Pollutant Test Status Test Frequency
PM * #

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

B. Clinker Cooler (F31)
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Pollutant Test Status Test Frequency
PM + #

C. Testing Status (To be applied above)
* The initial testing has already been performed.

** The SO2 initial performance test was conducted on August 26, 2013.

*** The initial compliance test shall be conducted within the first 30 operating days of
operation in which the affected source operates using a CEMS.

# Test once every year. If performance testing would be required less than 15 operating days
after the Kiln has completed Startup after being down for more than 24 hours, then
performance testing may be deferred up to 15 operating days after completion of the Startup.
The Director may require testing at any time.

## Test at least once every two years. The Director may require testing at any time.

+ Initial testing is required within 180 days of startup of the reconstructed equipment

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must record the PM
CPMS output data for all periods when the process is operating, and use all the PM CPMS
data for calculations when the PM CPMS is not out-of-control. The owner/operator must
demonstrate continuous compliance by using all quality-assured hourly average data collected
by the PM CPMS for all operating hours to calculate the arithmetic average operating
parameter in units of the operating limit on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

+++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.e.1
NEW
Notification
The Director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The notification requirements for performance tests subject to 40
CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-165]

II.B.1.e.2
NEW
Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational
Safety and Health Administration (OSHA)- or Mine Safety and Health Administration
(MSHA)-approved access shall be provided to the test location. [R307-165]

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II.B.1.e.4
NEW
PM
40 CFR 60, Appendix A, Method 5 or 5I or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three (3) runs with
each run at least 120 minutes in duration and each run collecting a sample of 60 dry standard
cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.3
NEW
Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2. [R307-165]

II.B.1.e.5
NEW
Carbon Monoxide (CO)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.6
NEW
Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.7
NEW
Sulfur Dioxide (SO2)
40 CFR 60, Method 6 or 6C of Appendix A-4 or other EPA-approved method as acceptable to
the Director. [R307-165]

II.B.1.e.8
NEW
Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]

II.B.1.e.9
NEW
Total Hydrocarbons (THC)
Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL]

II.B.1.e.10
NEW
Mercury (Hg)
Continuous Emission or integrated sorbent trap monitoring (See Condition II.B.3.a). [40 CFR
63 Subpart LLL]

II.B.1.e.11
NEW
HCl
Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other
EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]

II.B.1.e.12
NEW
Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.13
NEW
Calculations
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director, to give the results in the specified units of the
emission limitation. [R307-165]

II.B.1.e.14
NEW
Existing Source Operation
For an existing source/emission point, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three years.
[R307-165]

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II.B.1.e.15
NEW
New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the maximum production rate listed in this AO. If the maximum AO
allowable production rate has not been achieved at the time of the test, the following
procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This new
allowable maximum production rate shall remain in effect until successfully tested at a higher
rate.

3) The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate (110%
of the new rate) will then be allowed if the test is successful. This process may be repeated
until the maximum AO production rate is achieved. [R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL.
[40 CFR 63 Subpart LLL]

II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times
of Dust Shuttle System operation to assist in the capture of Mercury emission. [R307-401-8]

II.B.1.h
NEW
Visible emissions from the following emission points shall not exceed the following values:

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

L. All baghouses - 10% opacity
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M. Fugitive dust - 20% opacity

N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y,
R307-401-8]

II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer
point is not required to conduct Method 22 visible emissions monitoring under this paragraph.
The enclosures for these transfer points must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

If any partially enclosed or unenclosed conveying system transfer point is located in a
building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to
40 CFR 60, according to the following:

(i) The owner/operator must conduct a monthly ten-minute visible emissions test of each
affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The
performance test must be conducted while the affected source is in operation.

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator may decrease the frequency of performance testing from monthly
to semi-annually for that affected source. If visible emissions are observed during any
semi-annual test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iii) If no visible emissions are observed during the semi-annual test for any affected source,
the owner/operator may decrease the frequency of performance testing from semi- annually to
annually for that affected source. If visible emissions are observed during any annual
performance test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iv) If visible emissions are observed during any Method 22 performance test, of Appendix
A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations,
recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60.
The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour
of any observation of visible emissions.

(v) If visible emissions from a building are monitored, the requirements of paragraphs (i)
through (iv) of this Condition apply to the monitoring of the building, and the owner/operator
must also test visible emissions from each side, roof, and vent of the building for at least ten
minutes. [R307-401]

II.B.1.j
NEW
Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed
0.005 gr/dscf:

520.BF1
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520.BF2
520.BF3
520.BF4
521.BF2
521.BF1
524.BF1
524.BF2
524.BF4
524.BF3
525.BF1
525.BF2
525.BF3
511.HP2
NRL_UPR
NRL_LWR. [R307-401-8]

II.B.1.j.1
NEW
To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration
through at least three (3) annual tests that the PM limits are not being exceeded, the
owner/operator may request approval from the Director to conduct stack testing less
frequently than annually. [R307-401-8]

II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive
dusts as dry conditions warrant or as determined necessary by the Director to maintain opacity
limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated to control fugitive dust. The application of
water or chemical treatment shall be used. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a damp/moist condition unless it is below freezing.
If chemical treatment is to be used, the plan must be approved by the Director. Records of
water and/or chemical treatment shall be kept for all periods when the plant is in operation.
The records shall include the following items: Instances of water and/or chemical application
to unpaved areas shall be recorded and maintained by the owner/operator. The ambient
temperature shall be recorded any time water should be applied but cannot due to freezing
conditions. [R307-401-8]

II.B.2.c
NEW
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

The sprays shall operate whenever dry conditions warrant meeting the required opacity
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limitations or as determined necessary by the Director. Water sprays shall not be required
during periods of freezing temperatures. [R307-401-8]

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation
of fugitive dusts as dry conditions warrant or as determined necessary by the Director.
[R307-401-8]

II.B.2.e
NEW
The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5
PM. [R307-401-8]

II.B.3 Continuous Emission Monitoring Requirements:
II.B.3.a
NEW
The owner/operator shall install, calibrate, maintain and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler.

A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the
missing data substitution procedures used by the UDAQ or the missing data substitution
procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate by the UDAQ.

B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period
including during each startup, shutdown, or malfunction.

C. The monitoring system shall comply with all applicable sections of R307-170, UAC; and
40 CFR 60, Appendix B.

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be
installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the
kiln/raw mill stack.

F. The owner/operator shall record the output of the system: including the quantity of NOx,
CO, O2 THC, Hg, HCl, and CO2 emissions at the kiln stack.

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source shall
continuously operate all required continuous monitoring devices and shall meet minimum
frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker
cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except
during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments,
the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a
PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the
results of the performance test demonstrating compliance with the filterable PM limit and
using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust
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the SSOL developed in accordance with the results of the most recent PM performance test
demonstrating compliance with the PM emission limit. The owner/operator shall use the PM
CPMS to demonstrate continuous compliance with the SSOL in accordance with the
requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

II.B.4 Fuel Limitations:
II.B.4.a
NEW
The owner/operator shall use only the following fuels in the kiln and pre-calciner:

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.

If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b
NEW
Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the
Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the
results of suitable tests giving data similar to a Proximate and Ultimate analysis of the
proposed coal additive. [R307-401-8]

II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal
additive. Approval is not required to change from one previously-approved coal additive to
another previously-approved coal additive. [R307-401-8]

II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily
heat input of the kiln and precalciner. The owner/operator may increase the average quantity
of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon
approval by the Director in accordance with the approval process described in Condition
II.B.4.b. [R307-401-8]

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II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel burning or process
installation not covered by New Source Performance Standards for sulfur emissions or
covered elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross
Btu heat input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input
for any oil except used oil. The sulfur content shall comply with all applicable sections of
UAC R307-203. [R307-203, R307-401-8]

II.B.4.c.1
NEW
Certification of fuels shall be either by the owner/operator's own testing or test reports from
the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be
available onsite. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials, UAC R307-203-1 (4)

A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be
used.

B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be
used.

C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85 are to be used. [R307-203]

II.B.4.d
NEW
The concentration/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight
3) Cadmium 2 ppm by weight
4) Chromium. 10 ppm by weight
5) Lead 100 ppm by weight
6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be
tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the burn tank and burned. [R307-401-8]

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II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned
in the rotary kiln:

A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than
five minutes in any 60-minute period

B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes
in any 60-minute period. [R307-401-8]

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the
Director. The calibration procedure and frequency shall be according to manufacturer's
specifications. Use of factory-calibrated thermocouples for temperature measurement is
approved. However, any other method of temperature measurement must be approved by the
Director prior to use. The monitoring equipment for both temperature and oxygen content
shall be located such that an inspector can at any time safely read the output. [R307-401-8]

II.B.5
NEW
Emergency Engine Requirements
II.B.5.a
NEW
The owner/operator shall only operate the emergency engines for testing and maintenance
purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency
operation. [R307-401-8]

II.B.5.b
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each emergency engine. [R307-401-8]

II.B.5.b.1
NEW
The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.5.b.2
NEW
To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN103030035-24 dated November 27, 2024
Is Derived From Source Submitted NOI dated November 30, 2022
Incorporates Additional Information Received dated April 26, 2023
Incorporates Additional Information Received dated September 26, 2023
Incorporates Additional Information Received dated July 23, 2024
Incorporates Additional Information Received dated October 25, 2024
Incorporates Additional Information Received dated November 25, 2024

REVIEWER COMMENTS

1. Comment regarding applicability of federal requirements:
New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable
by the best demonstrated technology as specified in the applicable provisions. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.

40 CFR 60, Subpart A (General Provisions)
All affected facilities subject to a source-specific NSPS are subject to the general provisions of
NSPS, Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires
initial notification, performance testing, recordkeeping, and monitoring, provides reference methods,
and mandates general control device requirements for all other subparts.

40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of
performance for affected facilities in Portland Cement Plants which have been constructed or
modified after August 17, 1971.

40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart
F: Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and
unloading systems. The Leamington coal mill is an in-line coal mill and considered an integral part
of the Leamington kiln. In-line coal mills are not subject to NSPS Subpart Y. Therefore, the coal mill
is addressed under NSPS Subpart F as part of the kiln system. The coal silos and conveying system
are subject to NSPS Subpart Y.

Ash Grove's proposed changes to the kiln system must be evaluated as to whether they trigger new
NSPS Subpart F obligations based on whether the proposed project is either a modification or a
reconstruction, as those terms are defined in NSPS Subpart A.

Ash Grove's proposed changes to the kiln system do not meet the definition of a reconstruction, nor
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Page 40

do they meet the definition of a modification for NOx. However, the changes meet the definition of a
modification for PM and SO2. Therefore, Ash Grove will comply with all relevant emission
standards; testing requirements; monitoring, recordkeeping, and reporting obligations that apply to
the Leamington kiln system as an existing source under NSPS Subpart F. Under NSPS Subpart A
and F, the clinker cooler is considered a reconstructed unit. Thus new limits will apply to this unit.
[Last updated January 14, 2025]

2. Comment regarding applicability of federal requirements cont.:
NSPS Subpart Y - Standards of Performance for Coal Preparation and Processing Plants
This subpart provides standards of performance for affected facilities in coal preparation and
processing plants that process more than 200 tons of coal per day.

The Leamington plant's coal silo and coal conveying system are existing affected facilities under
NSPS Subpart Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses
controlling affected facilities subject to match the limit in NSPS Subpart Y from 0.016 gr/dscf to
0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade Project. Since there are no proposed
modifications or reconstruction to the coal silo and coal conveying system, nothing about the
proposed upgrade project affects the existing applicability of NSPS Subpart Y.

NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
This subpart provides standards of performance for affected facilities located at fixed or portable
nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August
31, 1983, with additional requirements applicable to sources constructed on or after April 22, 2008.

As the crushing and screening system is controlled by baghouses and an increase in PM10 actual
emissions on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS.
Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the
Leamington Plant Upgrade Project.

Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1),
60.676(f), and 60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO
monitoring and recordkeeping requirements.

[Last updated January 14, 2025]

3. Comment regarding applicability of federal requirements cont.:
National Emission Standards for Hazardous Pollutants (NESHAPs)
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or
greater than 10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as
specified by each subpart. NESHAP apply to sources in specifically regulated industrial source
classifications (CAA Section 112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities
not regulated as a specific industrial source type. The Ash Grove Leamington Plant is a major source
of HAPs and thus is subject to certain NESHAP standards.

Subpart A - General Provisions
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All affected sources are subject to the general provisions of Subpart A unless otherwise specified by
the source-specific NESHAP. Subpart A generally requires initial notification and performance
testing, recordkeeping, monitoring, provides reference methods, and mandates general control device
requirements for all other subparts as applicable.

Subpart LLL - Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry
This subpart establishes process/source specific emission limits for PM, VOC (expressed as total
hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and
gaseous HAP compounds by limiting PM and THC emissions because portions of such emissions
are USEPA-listed HAPs. Subpart LLL requires compliance with applicable emissions limits on and
after the initial startup of cement production. To further reduce emissions, Subpart LLL also
establishes operational requirements for the use of cement kiln dust (CKD), fly ash, fuel and control
equipment. Subpart LLL also specifies process/source specific emissions testing, monitoring,
recordkeeping, reporting, and compliance demonstration requirements. The compliance requirements
for the site are detailed in Approval Order Condition II.B.1.b. Ash Grove will continue to comply
with the requirements of Subpart LLL to demonstrate compliance. This cement kiln will remain an
existing source with respect to the kiln emission standards in Subpart LLL as this project does not
trigger the definition of a new source in Subpart LLL. New source standards apply only to affected
sources that were constructed or reconstructed after May 6, 2009.
[Last updated December 20, 2024]

4. Comment regarding PSD applicability analysis:
Ash Grove is proposing to increase the throughput of limestone from the quarry to supply the New
Finish Mill to increase the amount of low-carbon cement from the Leamington Plant. Additionally,
along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
modified, and the clinker cooler will be reconstructed. These changes are anticipated to result in an
increase in clinker production. Emission calculations for this project have been completed assuming
an increase in clinker production capacity while utilizing current fuel types. This will result in an
increase in the throughput of fuel.

The Leamington Plant is considered an existing major source under PSD based on potential
emissions of PM10, PM2.5, NOx, CO, SO2, and CO2e. If a major source undergoes a physical or
operational change, the facility must determine whether the project will be considered a major
modification. Per 40 CFR 52.21(b)(2)(i), in order to be a major modification, the project must result
in a significant emissions increase, and a significant net emissions increase.

As defined at 40 CFR 52.21(b)(40): Significant emissions increase means, for a regulated NSR
pollutant, an increase in emissions that is significant for that pollutant. Significant is further defined
to mean, in reference to a net emissions increase or the potential of a source to emit any of the
following pollutants, a rate of emissions that would equal or exceed the values outlined in 40 CFR
52.21(b)(23). If the increase in emissions from the project are not significant, a major modification
has not occurred.

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
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Page 42

increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

For all pollutants, the project emissions increase was calculated as the difference between the
projected actual emissions (PAE) after the proposed project and the actual emissions prior to the
project (baseline actual emissions or BAE).

Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
". . . projected actual emissions means the maximum annual rate, in tons per year, at which an
existing emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years
(12-month period) following the date the unit resumes regular operation after the project, or in any
one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit of that regulated NSR pollutant and full utilization of the unit would
result in a significant emissions increase or a significant net emissions increase at the major
stationary source." [Last updated January 14, 2025]

5. Comment regarding PSD applicability analysis cont.:
Ash Grove estimates that the projected actual production capacity following the project will be
1,155,000 tons of clinker per year and 1,341,266 tons of limestone per year. These capacities were
used to calculate projected actual emissions from the project using representative emission factors.
Additionally, to estimate emissions from material transfer baghouses, the actual flow rates and actual
projected hours were used as a basis for projected actual emissions.

Project Emission Calculations

Project emission increases from the kiln and coal mill systems are calculated for all criteria
pollutants based on emission factors that are derived from stack testing, CEMS data, or emission
factors (i.e., VOCs and Lead), and the associated projected incremental clinker increase.

NOx emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain
hourly capacity to emit and annual potential to emit at current levels. The kiln's NOx emissions rate
will not change as a result of the physical modifications proposed by the project.

Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission
factor and multiplied by the incremental increase in clinker production. The emission factor was
selected based on the average of the 24-month consecutive month emissions for 2020 and 2021. The
CO emissions will increase.

The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing
conducted at the plant. The SO2 emissions will increase.

VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production. VOC emissions will increase.

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 43

can be found in the original NOI and subsequent addendums submitted to UDAQ.

As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from
the proposed project, each increase of emissions from both existing and new sources shall be
summed together and compared to the PSD permitting thresholds. The increase of emissions is the
"positive" difference between the projected actual emissions and baseline actual emissions (projected
minus baseline).

New Emissions Sources

The actual to projected actuals calculation is not available to new emission units. For new emission
units, the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected
emissions are based on the new sources' potentials to emit. (40 CFR § 52.21(a)(2)(iv)(f)).

The new equipment proposed includes the New Finish Mill, a new rail and truck loading/loadout,
one (1) new clinker reclaim loading hopper with a dust collector and one (1) existing clinker reclaim
hopper with a dust collector, a new Clinker Cooler to replace the existing one, and a new kiln feed
alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions:

The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;

The finish mill heater was calculated based on its maximum firing capacity and flow rates; and

The fugitive emissions were calculated based on the projected annual throughput of the New Finish
Mill, the rail loadout, and clinker production. [Last updated January 14, 2025]

6. Comment regarding PSD applicability analysis cont.:
Existing Emission Sources

For the existing sources, the projected actual emissions are the maximum annual rates in tons per
year projected to occur during the next five (5) to ten (10) years if the existing sources' design
capacities increase. Ash Grove Leamington projected the actual emissions for the next five (5) years
based on the new kiln system producing an annual average of 3,250 tons of clinker per day.

Baseline actual emissions (BAE) are defined at 40 CFR 52.21(b)(48)(ii) as:

". . . baseline actual emissions means the average rate, in tons per year, at which the emissions unit
actually emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the 10-year period immediately preceding either the date the owner or operator
begins actual construction of the project, or the date a complete permit application is received by the
Administrator."

Ash Grove has selected to use the years 2020 and 2021 for each pollutant as the representative
baseline years.

In its NOI, Ash Grove calculated the emission increase from the project as being divided into two
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 44

phases. Phased construction projects are discussed in two sections of the federal PSD regulations -
40 CFR 52.21(j)(4) and 40 CFr 52.21(r)(2). UDAQ is not processing this project as a phased
construction project, nor did Ash Grove request such a determination. Therefore, Ash Grove
provided a summary table outlining the final change in emissions from this project:

Projected Actual Increase Compared to PSD threshold (tons per year)
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2e
BAE 76.64 39.64 1,187 6.87 3,315 55.47 641,385
PAE 203.15 113.47 1,226 45.87 3,414 72.07 1,067,984

Change in Emissions 126.51 73.83 39.00 39.00 99.00 16.59 426,598

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes

If the emissions increase is greater than the PSD significance threshold for a particular pollutant, Ash
Grove has the option of conducting a PSD review or continuing through the rest of the steps to
determine if it can "net" out of a PSD review. If the project increase is less than the PSD significant
threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant.

The change in emissions from the project exceeds the significant emission threshold for three
pollutants: PM10, PM2.5 and CO2e. Ash Grove elected to attempt to net out of a PSD major
modification for the remainder of the criteria pollutants.

Netting

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant
Upgrade Project and ends on the date the upgrade begins operation. Only PM10, PM2.5, CO2e are in
excess of SERs and therefore considered in the netting analysis.

Ash Grove estimated that the commencement of construction will be in December 2024. Therefore,
the contemporaneous period for this project is December 2019 through a projected date the project
upgrade begins operation. [Last updated January 21, 2025]

7. Comment regarding PSD applicability analysis cont.:
Contemporaneous Decreases

Ash Grove replaced an existing kiln emergency drive engine with a USEPA Tier 4 diesel engine in
2022. Concurrently, Ash Grove requested an increase in the capacity of 1L Cement. Additionally,
Ash Grove submitted a minor modification NOI air permit application on June 12, 2023, which
proposes replacing the shipping generator during the contemporaneous period. The kiln emergency
drive engine and shipping generator are both higher EPA tier ratings therefore result in decreases for
PM10 and PM2.5. These changes were approved in AO DAQE-AN103030033-24 issued March 21,
2024.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 45

Contemporaneous Increases

As stated above, the existing kiln emergency drive engine and shipping generator were permitted and
replaced in 2024. This resulted in an increase in emissions of CO2e.

The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout
in an effort to improve truck traffic at the loadout. The modification to add these dust collectors to
the loadout was included in DAQE-AN103030029-19. The baghouses are three (3) levels up in the
silos' enclosed space (approximately 40 feet). Both dust collectors vent directly into the interior of
the silo structure and are not vented into the atmosphere. Ash Grove requests to remove these
baghouses from its existing permitted emissions inventory. Therefore, these emissions have been
documented in the netting analysis as zero emissions.

Also included in DAQE-AN103030033-24 were two new natural gas-fired emergency generators
and increases in stockpiles, material handling and road emissions.

Could Have Been Accommodated Emissions

In calculating project emissions increase, USEPA allows the exclusion of existing
production/emissions rates that could have been accommodated during the baseline period. These
"could have been accommodated" emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as
follows:

". . . Shall exclude, in calculating any increase in emissions that results from the particular project,
that portion of the unit's emissions following the project that an existing unit could have
accommodated during the consecutive 24-month period used to establish the baseline actual
emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project,
including any increased utilization due to product demand growth;"

Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the
exclusion of existing production and emissions rates that could have been accommodated during the
baseline period, it has elected not to use this exclusion at this time. Therefore, calculation of the
"could have been" accommodated emissions have not been included in this application's
applicability analysis.

The increase from the project is added to the contemporaneous decreases and contemporaneous
increases. The resulting calculation is then compared to the PSD significance threshold to determine
if a significant net emissions increase has occurred. [Last updated January 14, 2025]

8. Comment regarding PSD applicability analysis cont.:
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2 e
Contemporaneous Inc. 1.61 0.45 0.41 0 0.27 0.07 51.74

Contemporaneous Dec. -1.54 -3.97 -0.48 -0.02 -0.27 -0.09 0

Change in Emissions 125.02 69.21 38.93 38.98 99.00 16.58 426,650

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 46

The results of the netting analysis conclude that both a significant emissions increase and a
significant net emissions increase in both particulates (PM10 and PM2.5) and CO2e will occur from
this project. Thus, the project must be reviewed as a PSD major modification. [Last updated January
14, 2025]

9. Comment regarding emission calculations:
This engineering review includes updated potential emission totals for both criteria and HAP
emissions. The potential-to-emit (PTE) values were calculated using updated values for clinker
produced and raw material inputs. BACT emission factors and limitations were used where
appropriate. Certain emission totals (NOx, SO2 and CO) were set based on avoiding a significant
increase in emissions. Specifically, the projected actual increase was set at just under the baseline
actual emissions + the significance level. As these emissions are monitored by CEM, UDAQ agrees
with this approach. Please see the netting analysis for further details on calculation of projected
actual increase. The NOx hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project.

CO2e emissions were calculated using the GHG emission factor calculated from 40 CFR Part 98
Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in Subpart A Table
A-1.

To calculate the PTE tons per year, the maximum hours (i.e., 8760) per year and the source's
emissions rates were multiplied with the throughputs. The potential throughputs have been updated
at UDAQ's request so that PAE is equal to PTE and represents the equipment's maximum design
potential.

Additional emission calculations based on source testing and monitoring, and EPA's compilation of
air emission factors AP-42. [Last updated January 14, 2025]

10. Comment regarding requirements for PSD review:
In addition to the permitting requirements of R307-401-5 through R307-401-8, there are additional
requirements under PSD that must be addressed:

1. Calculation of ambient air increments (40 CFR 52.12(c)), ambient air ceilings ((40 CFR 52.12(d)),
source impact analysis (40 CFR 52.12(k)), air quality models (40 CFR 52.12(l)) - these items are
addressed in the modeling memo DAQE-MN103030032-24.

2. Stack heights (40 CFR 52.12(h)) - Ash Grove's stack heights have been reviewed with respect to
good engineering practice and operate in a vertical unrestricted manner.

3. Control technology review (40 CFR 52.12(j)) - this is addressed in the BACT analysis section of
this review document.

4. Air quality analysis: preapplication analysis (40 CFR 52.12(m)) - this is covered in the PSD
applicability and netting analysis sections of this review document, ambient monitoring and
background data collection is also included in the modeling memo DAQE-MN103030032-24.

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 47

grain loading limit included in II.B.1.j.1 represents the required post-construction monitoring.
6. Source information (40 CFR 52.12(n)) - this is addressed under the requirements of R307-401-5
and was submitted by Ash Grove as part of the NOI package.

7. Additional impact analysis (40 CFR 52.12(o)) - these requirements cover soils, vegetation, growth
and visibility concerns. They are discussed in the modeling memo DAQE-MN103030032-24.

8. Federal land manager review (40 CFR 52.12(p)) - UDAQ provided initial notification to all
federal land managers upon receipt of the original NOI package. The draft permit and engineering
review will also be provided to the federal land managers 60-days prior to initiation of public
comment for their further review.

9. Public participation (40 CFR 52.12(q)) - this project will have a 30-day public comment period.

10. Source obligation (40 CFR 52.12(r)) - this requirement discusses source compliance with other
parts of the CAA, which is addressed within UDAQ's permitting rules in R307.
[Last updated January 14, 2025]

11. Comment regarding changes in equipment list:
The equipment list is being updated for clarity as well as adding new pieces of equipment. The
following changes are taking place:

The naming scheme is being updated to remove the numerical code from the unit designation. This
code generally referred to the associated control device and not to the emitting unit itself. This can
cause confusion especially when the same code was applied to multiple pieces of equipment.
Instead, the control devices (typically baghouse dust collectors) will be identified in the description
along with the appropriate numerical code.

Specific changes are as follows:

1. The kiln description has been updated

2. Clinker Cooler description has been updated to include a larger pulse jet baghouse.

3. The clinker storage silos, east and west clinker belts, clinker belt transfer and clinker tunnel have
been consolidated to avoid confusion

4. The north and south cement loadout exhausts now vent internally into the cement storage silos

5. The dust shuttle system has been consolidated into one line item, most identifiers removed from
subsystem descriptions as only two baghouses serve as exhaust points.

6. A new finish mill with heater has been added. Included in the description are the thirteen total
baghouses for dust control (1 main stack, 2 transfer points, 10 nuisance dust filters)

7. A new clinker reclaim hopper has been added. Both reclaim hoppers are controlled by baghouses
with updated identifiers

8. A new rail and truck loading/unloading system with two baghouses has been added.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 48

[Last updated December 20, 2024]

12. Comment regarding changes in conditions:
As a result of this project, several conditions will be added or changed. This includes one new
general condition (I.8). Changes to the equipment list (section II.A) will be addressed in a separate
reviewer comment:

I.8 - Adding this general condition to cover the requirements of R307-401-18 Eighteen Month
Review. The status of construction/installation of the new equipment shall be reviewed after
18-months.

II.B.1.a - Clinker production increases to 1,155,000 tpy
Use of limestone bypass material increases to 215,260 tpy

II.B.1.b - The NOx limit on the kiln decreases to 1,223 tpy, CO emissions from the kiln decrease to
3,395 tpy,
Adding a new CO2e limit of 0.92 tons CO2e/ton of clinker produced
PM limit on the clinker cooler decreased to 0.02 lb PM (filterable)/ton of clinker
Rule reference updated to include 40 CFR 60 Subpart F, and R307-401-8

II.B.1.e - Initial testing on the clinker cooler is now required within 180 days of startup of the unit.
Monitoring of CO2 from the kiln will be by CEM.
Formatting changes on paragraph designated ++, improve clarity, include reference to CO2
monitoring, define CPMS

II.B.1.e.4 - Update to address general PM monitoring and reference R307-401-8

II.B.1.e.14 - New condition to address new or reconstructed emission units monitoring requirements,
applicable to the clinker cooler and new finish mill.

II.B.1.h - Adding references to Subpart OOO units (limestone processing) with updated opacity
limits.
Adding 20% opacity limit on coal transfer and storage
Adding property boundary opacity limit of 20%
Updating rule reference to include Subpart OOO

II.B.1.j - New condition to address outlet grain loading limits on new baghouses, One identical limit,
15 total new baghouses.

II.B.1.j.1 - Monitoring on new baghouses as per II.B.1.e.4, added an allowance to test less frequently
than annually with three successful tests.

II.B.3.a - Updating formatting to add clarity and include reference to CO2 CEM

II.B.5 - New conditions on emergency engines, diesel fuel sulfur limits, hour of operation
restrictions, non resettable hour meter

[Last updated December 20, 2024]
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 49

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 51

TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 52

DAQE-MN103030032-24

M E M O R A N D U M

TO: John Jenks, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler
Dave Prey, Air Quality Modeler

DATE: December 12, 2024

SUBJECT: Modeling Analysis Review for the Ash Grove Cement Company – Leamington Plant,
located in Millard County, Utah
___________________________________________________________________________________
This is a Major Modification to a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Ash Grove Cement Company (Applicant) has submitted a Notice of Intent (NOI) air permit
application for a project referred to as the Leamington Upgrade Project (LUP). The proposed
upgrade project includes the construction and installation of new pollution control equipment, new
emission sources, and modifications to existing emission sources. Emission increases associated
with the LUP constitute a major modification to a Prevention of Significant Deterioration (PSD)
source subject to PSD permitting regulations. PSD regulations require the Applicant to include and
air quality impact analysis (AQIA) of the proposed projects impact on the EPA national ambient air
quality standards (NAAQS) and air quality related values (AQRV) as part of a complete NOI.

This report prepared by the New Source Review (NSR) modeling staff contains a review of the
Applicant’s Air Quality Impact Analysis (AQIA) including the methodology, data sources,
assumptions, and modeling results for comparison with State and Federal air quality standards. The
AQIA was reviewed and referenced in this report include the:
● Notice of Intent – Ash Grove Cement Leamington Plant PSD Notice of Intent Air Permit
Application, dated November 30, 2022.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

0 0
Jason Krebs

DP
DAQE-MN103030032-24
Page 2

II. APPLICABLE RULES AND ANALYSES

A Utah Air Quality Rules

The UDAQ has determined that the Applicant’s NOI is subject to the following rules for conducting an
AQIA:

R307-401 Permits: New and Modified Sources
R307-405 Permits: Major Sources Located in Attainment or Unclassified Area (PSD)
R307-406-2 Visibility – Source Review
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutant Impacts in Attainment Areas

B. Applicability

The proposed increases in emissions of PM10 and PM2.5 exceed the emission thresholds outlined in R307-
406-5 and R307-410-4. Therefore, an AQIA consistent with the requirements of R307-405-6, R307-406-
2, and R307-410-3 was submitted as part of the Applicant’s NOI. R307-410-3 establishes the U. S.
Environmental Protection Agency (US EPA) – Guideline on Air Quality Models as a formal basis for
defining the scope of the analysis, as well as the model’s construction. The results of the AQIA are
required to demonstrate the proposed project’s impact on state and federal air quality standards,
acceptable levels of impact, and action triggering thresholds referenced or listed in R307-401-6(2), R307-
401-6(3), R307-403-3(1), R307-403-5(1)(a), R307-405-4(1), R307-405-6. Annual emissions for criteria
pollutants requiring an AQIA are listed in Table 1.

Table 1: Ash Grove Leamington Proposed Net Emissions Increase

Criteria
Pollutants
Net Emission
Increase (TPY)
AQIA Trigger
Level (TPY) AQIA Required?
PM10 126.6 15 Yes
PM2.5 70.3 10 Yes

C. Required Analyses

R307-405 requires the Applicant to perform a pre-construction modeling analysis for all pollutants
emitted in a significant quantity. The purpose of the analysis is to determine if the extent of the source’s
impact is significant enough to warrant an on-site measurement of the ambient background concentration
levels. This data is included in the NAAQS analysis to represent the quality of the air prior to the
construction of the proposed project. The Applicant included a pre-construction modeling analysis for
PM10 and PM2.5 as part of the NOI. The pre-construction modeling analysis was also used to determine if
the proposed emissions would result in a significant impact to the environment, thereby triggering the
requirement for a cumulative analysis of the proposed project and other nearby existing sources.

R307-401-8 requires the Division to determine that the proposed project will comply with the NAAQS
prior to the issuance of an Approval Order (AO). R307-405(7) requires the Applicant to perform a
DAQE-MN103030032-24
Page 3
NAAQS analysis for all pollutants emitted in a significant quantity. The analysis is to include all
emissions at the proposed site under normal operating conditions using maximum anticipated short-term
release and annual release rates. Consistent with UDAQ policy, a cumulative analysis to include the
ambient background concentration and any contribution from other nearby sources is not required if the
proposed project’s impact does not exceed the PSD Class II Significant Impact Level (SIL).

R307-401-8 also requires the Division to determine that the proposed project will comply with PSD
increments prior to the issuance of an AO. Under R307-405(6), the Applicant is required to perform a
PSD Class I and II increment consumption analysis for all pollutants emitted in significant quantities.
The purpose of this analysis is to quantify any degradation in air quality since the major source baseline
date. The analysis is to include all increment consuming emissions at the proposed site under normal
operating conditions using maximum anticipated short-term and annual release rates. A cumulative
analysis to include contributions associated with growth and other increment consuming sources is not
required if the proposed project’s impact does not exceed the PSD Class I or II SIL.

R307-410-5 requires the Applicant to perform a HAPs analysis for any pollutant emitted above a
pollutant specific emission threshold value. This analysis is to include all emissions of the pollutants
resulting from the proposed modification under normal operating conditions using maximum anticipated
one-hour release rates. The Applicant did not trigger modeling for HAPs.

R307-406-2 requires the Applicant to perform a plume blight analysis. A plume blight analysis is required
to determine if plumes emanating from the proposed project would be visible inside any Class I area
within 50 kilometers of the source. The plume blight analysis is to include all emissions of NO2, SO4, and
PM10.

Under R307-405-16, an AQRV analysis is performed which evaluates regional haze and acid deposition
impacts at each of the Class I areas within 300 kilometers of the source. A regional haze analysis is
required to determine if the plumes would reduce the visual range of an observer inside the Class I area.
The regional haze analysis is to include all emissions of SO2, NOX and PM10. The deposition analysis
examines impacts from sulfur and nitrogen compounds at the Class I areas, and is based on all emissions
of SO2 and NOX. The Federal Land Managers use the Q/D approach to determine whether a PSD project
should provide detailed AQRV impact analyses, where: Q/D= [ H2SO4 + SO2 + NOx + PM10 emissions
(tpy)]/ distance (km). If Q/D is less than 10, no AQRV analysis is required.

R307-405 requires the Applicant to perform a soils and vegetation analysis. The analysis should quantify
the effects of pollutants on soils and vegetation near the highest impact location and in areas where
sensitive plant species may be impacted.

III. ON-SITE PRE-CONSTRUCTION MONITORING

A. Meteorological Data

Consistent with the US EPA - Meteorological Monitoring Guidance for Regulatory Modeling
Applications, one year of on-site data was collected using a 50-meter tower during the period October 1,
2021 through September 30, 2022. Parameters collected on-site included wind speed and direction,
temperature, delta-T, and solar radiation.

DAQE-MN103030032-24
Page 4

B. Ambient Pollutant Data

A preliminary analysis was conducted to determine the necessity for pre-construction ambient pollutant
monitoring. The results indicate that predicted concentrations of PM10 and PM2.5 exceed the monitoring
trigger level listing in the rule. A continuous PM10/PM2.5 monitor with filter based samplers was
installed near the northern edge of the Applicants property boundary, and collected particulate matter
from October 1, 2021 through September 30, 2022.

IV. MODEL SELECTION

The EPA-AERMOD dispersion modeling system is the preferred model specified in the US EPA –
Guideline on Air Quality Models to predict air pollutant concentrations in the near field (within 50
kilometers of the source). The US EPA - CALPUFF - Version 5.8 model is the preferred model to predict
concentrations in the far field (long range transport conditions beyond 50 kilometers from the source).

V. MODELING INPUTS AND ASSUMPTIONS

A. Technical Options

The regulatory default options were selected in AERMOD by the Applicant to quantify all concentrations.

B. Urban or Rural Area Designation

A review of the appropriate 7.5-minute quadrangles determined that the area should be classified as
“rural” for air modeling purposes.

C. Topography/Terrain

The Plant is at an elevation of 4,950 feet with nearby terrain features that have an effect on concentration
predictions.

a. Zone: 12
b. Location: UTM (NAD83): 397000 meters East, 4379850 meters North

D. Ambient Air

It was determined that the Plant boundary used in the AQIA meets the State’s definition of an ambient air
boundary.

E. Receptor and Terrain Elevations

The modeling domain has simple and complex terrain features in the near field. Therefore, receptor
points representing actual terrain elevations from the area were used in the analysis.

The far-field modeling domain consisted of a rectangular region covering all Class I areas within Utah,
and extending 50 kilometers beyond this area so that the model can account for re-circulation of the
plume.

DAQE-MN103030032-24
Page 5

F. Emission Rates and Release Parameters

The emission estimates and source parameters used in AERMOD for all proposed emission sources at the
site are presented in the NOI.

Speciated emission rates and source parameters used in the CALPUFF modeling are presented in Table 2.

Table 2: CALPUFF Emission Rates

Source
LCC Coordinates Modeled Emission Rates
Easting Northing SO2 SO4 NOX HNO3 NO3 SOA PMC SOIL EC
(m) (m) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr)
317.BF3 -1289410 -3738 52.81 5.03 307.58 0.00 0.00 5.03 2.60 2.90 0.11
419.BF1 -1289314 -3631 0.00 0.00 0.00 0.00 0.00 0.55 1.51 1.61 0.06
41B.BF2 -1289389 -3663 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.68 0.00
N1_FM2 -1289526 -3414 0.00 0.00 0.00 0.00 0.00 0.00 1.65 3.95 0.00
414.BF1N -1289407 -3683 0.00 0.00 0.00 0.00 0.00 0.00 0.10 0.25 0.00
2FM_HTR -1289528 -3415 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.08 0.00
514.BF1 -1289451 -3675 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.70 0.00
COMBO -1289424 -3668 0.00 0.00 0.00 0.00 0.00 0.00 1.37 5.72 0.00
FM2_CMB -1289454 -3439 0.00 0.00 0.00 0.00 0.00 0.00 0.50 1.21 0.00

Total Lb/hr 52.81 5.03 307.58 0.00 0.00 5.58 8.32 17.10 0.17
Hrs/Yr 8760 8760 8760 8760 8760 8760 8760 8760 8760
Ton/yr 231.3 22.0 1347.2 0.0 0.0 24.4 36.4 74.9 0.8

Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
317.BF3 POINT 4902.8 41.2 135.0 488 10.10 3.35
419.BF1 POINT 4891.2 18.3 60.0 388 6.36 2.90
41B.BF2 POINT 4895.2 68.6 224.9 294 17.83 0.74
N1_FM2 POINT 4832.0 49.7 163.0 363 40.08 1.40
414.BF1N POINT 4896.1 76.8 251.9 353 9.91 0.70
2FM_HTR POINT 4832.0 49.7 163.0 363 40.08 1.40
514.BF1 POINT 4889.5 39.6 130.0 294 11.86 0.91
COMBO POINT 4904.2 13.3 43.7 276 9.76 0.32
DAQE-MN103030032-24
Page 6
FM2_CMB POINT 4832.0 30.6 100.3 294 11.40 0.37

G. Building Downwash

The Applicant used the US EPA Building Profile Input Program (BPIP) to determine Good Engineering
Practice (GEP) stack heights and cross-sectional building dimensions for input into the model.

H. Ambient Background Concentrations

Millard County is in attainment for all criteria pollutants. The NAAQS analyses for PM2.5 and PM10 used
monitoring data collected on site during the pre-construction monitoring analysis. The background values
used in the NAAQS analysis are presented in Table 3.

Table 3: Background Concentrations

Pollutant Averaging
Period
Background
Concentration
(μg/m3)
PM10 24-hour 65.4
PM2.5 24-hour 10.2
Annual 4.2

I. Meteorological Data Processing

For the AERMOD model, on-site horizontal and vertical wind speed, direction, solar radiation and,
temperature data was combined with National Weather Service (NWS) upper air data collected at the Salt
Lake City International Airport (SLCIA) for the same period using the US EPA AERMET processing
system.

Meteorological data used for the CALPUFF modeling analysis consisted of 3 years (2018-2020) of data
developed by the Forest Service. The grid was 708 km (east-west) by 492 km (north-south) with a
resolution of 12 kilometers.

VI. RESULTS AND CONCLUSIONS

The Applicant performed a series of analyses to estimate the impact from the proposed project. Modeling
results and conclusions from the review of the analyses are outlined in detail below.

A. Pre-Construction Monitoring and Significant Impact Modeling

The Applicant performed a preliminary criteria pollutant analysis of the proposed modification. This
analysis indicated that increases in concentration levels of PM2.5 and PM10 were greater than the Class II
SIL, and therefore, a cumulative analysis for these pollutants was required.

DAQE-MN103030032-24
Page 7

B. NAAQS Analysis

The Applicant performed a modeling analysis to determine if the combined impact from the proposed
source, other industrial sources operating in the area, and ambient background would comply with the
NAAQS. The NAAQS analysis was reviewed by the Division and determined to be consistent with the
requirements of R307-410-3. Table 4 provides a comparison of the Applicant’s predicted air quality
concentrations and the NAAQS.

Table 4: Model Predicted NAAQS Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-hour 28.3 5 65.4 0 93.7 150 62.5%
PM2.5 24-hour 9.6 1.2 10.2 0 19.8 35 56.6%
Annual 4.4 0.3 4.2 0 8.6 9 95.6%
* Note: Only included other sources and background if source impact was above Class II SIL

C. PSD Class II Increments

The Applicant performed an analysis to determine if the impact from the proposed source would comply
with PSD Class II increments. The analysis was reviewed by the Division and determined to be
consistent with the requirements of R307-410-3. Table 5 provides a comparison of the predicted
concentrations and the PSD Class II increment.

Table 5: Model Predicted PSD Class II Increment Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Nearby
Sources*
Total Increment Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
PM10 Annual 8.1 1 0 8.1 25 32.4%
24-hour 28.3 5 0 28.3 30 94.3%
PM2.5 24-hour 6.1 1.2 0 6.1 9 67.8%
Annual 2.4 0.3 0 2.4 4 60.0%

D. Hazardous Air Pollutants

DAQE-MN103030032-24
Page 8
The Applicant performed an analysis to determine if HAP modeling is required. The analysis was
reviewed by the Division and determined to be consistent with the requirements of R307-410-3. The
analysis indicated that HAP modeling was not triggered by this modification, and therefore no HAP
modeling was performed.

E. PSD Class I Increment Consumption Analysis

The Applicant performed a CALPUFF analysis to determine if the impact from the proposed source along
with other increment consuming sources would comply with federal PSD Class I increments. The
analysis was reviewed by the Division and determined to be consistent with the requirements of R307-
410-3. The results for all Class I areas within 300 kilometers are provided in Table 6.

Table 6: Model Predicted PSD Class I Increment Concentrations

Air Period Prediction
Class I
Significant
Impact
Level
Other
Sources* Total Increment Percent
Pollutant (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
Capitol Reef
NO2 Annual 0.0018 0.1 2.5
SO2
3-Hour 0.0494 1 25
24-
Hour 0.0150 0.2 5
Annual 0.0008 0.1 2
PM2.5
24-
Hour 0.0430 0.27 2
Annual 0.0021 0.05 1
PM10
24-
Hour 0.0444 0.3 8
Annual 0.0021 0.2 4
Arches
NO2 Annual 0.0008 0.1 2.5
SO2
3-Hour 0.0408 1 25
24-
Hour 0.0102 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0522 0.27 2
Annual 0.0018 0.05 1
DAQE-MN103030032-24
Page 9
PM10
24-
Hour 0.0531 0.3 8
Annual 0.0019 0.2 4
Canyonlands
NO2 Annual 0.0010 0.1 2.5
SO2
3-Hour 0.0354 1 25
24-
Hour 0.0100 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0577 0.27 2
Annual 0.0019 0.05 1
PM10
24-
Hour 0.0591 0.3 8
Annual 0.0020 0.2 4
Bryce
NO2 Annual 0.0006 0.1 2.5
SO2
3-Hour 0.0369 1 25
24-
Hour 0.0082 0.2 5
Annual 0.0003 0.1 2
PM2.5
24-
Hour 0.0189 0.27 2
Annual 0.0010 0.05 1
PM10
24-
Hour 0.0194 0.3 8
Annual 0.0010 0.2 4
Zion
NO2 Annual 0.0011 0.1 2.5
SO2
3-Hour 0.0293 1 25
24-
Hour 0.0105 0.2 5
Annual 0.0005 0.1 2
PM2.5
24-
Hour 0.0266 0.27 2
Annual 0.0011 0.05 1
PM10 24-
Hour 0.0271 0.3 8
DAQE-MN103030032-24
Page 10
Annual 0.0012 0.2 4
* Note: Only included other increment consuming sources if source impact was above Class I SIL

Since the proposed project’s model predicted impacts at the Class I areas were less than the PSD Class I
significance levels, a cumulative analysis was not warranted.

DAQE-MN103030032-24
Page 11
F. Visibility – Plume Blight
Since the Class I areas are greater than 50 kilometers from the source, a plume blight analysis using
VISCREEN was not required.

G. Visibility – Regional Haze

The results of the Q/D analysis for the emissions increase was less than 10 but the FLMs wanted the
entire source included in the Q term. The results of including the total emissions resulted in a Q/D >10,
so an AQRV analysis was performed for visibility and acid deposition. The results shown in Table 7
indicate that the impacts are below the 0.5 Deciview (DV) threshold established by the National Park
Service, indicating that no further analysis is required.

Table 7: CALPUFF Visibility Results

Class I Area Year Maximum
Delta DV
98th
Percentile
change in
DV
#
Days
#
Days Threshold
(DV)
Below
Threshold
> 1 > 0.5
2018 0.248 0.06 0 0 0.5 Yes
Arches 2019 0.291 0.054 0 0 0.5 Yes
2020 0.216 0.106 0 0 0.5 Yes
2018 0.223 0.081 0 0 0.5 Yes
Canyonlands 2019 0.312 0.068 0 0 0.5 Yes
2020 0.186 0.085 0 0 0.5 Yes
2018 0.059 0.03 0 0 0.5 Yes
Bryce 2019 0.081 0.045 0 0 0.5 Yes
2020 0.071 0.03 0 0 0.5 Yes
2018 0.183 0.074 0 0 0.5 Yes
Capital Reef 2019 0.196 0.092 0 0 0.5 Yes
2020 0.126 0.078 0 0 0.5 Yes
2018 0.069 0.04 0 0 0.5 Yes
Zion 2019 0.123 0.039 0 0 0.5 Yes
2020 0.102 0.057 0 0 0.5 Yes

DAQE-MN103030032-24
Page 12

H. Acid Deposition

The Applicant performed a deposition analysis on impacts within the Class I areas. Results of the
analysis indicate that the impacts are below the deposition threshold (DAT) established by the National
Park Service, indicating that no further analysis is required

Table 8: CALPUFF Deposition Results for Highest Year

Class I Area
Total
Nitrate
Deposition
Total
Sulfate
Deposition
Deposition
Analysis
Threshold
(kg/ha/yr) (kg/ha/yr) (kg/ha/yr)
Canyonlands 0.0006 0.0003
0.005
Zion 0.0004 0.0002
Arches 0.0006 0.0003
Bryce 0.0006 0.0002
Capitol Reef 0.0011 0.0005

I. Soils and Vegetation Analysis

The Applicant performed an analysis to determine the extent of impacts from the proposed source on soil
and vegetation. Results of the analysis are presented in a supplemental document titled “Soil and
Vegetation Impact Analysis for the Leamington, UT Facility, June 29, 2023”. The analysis indicated that
predicted concentrations compared against the secondary NAAQS at several sensitive receptors would not
result in an adverse impact on soils and vegetation in the vicinity of the proposed project.

DP/JK:jg

DAQE-IN103030032-25

January 22, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Mr. Nelson:

Re: Intent to Approve: Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — ) A A v A ? A D @ A w D D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — ) A A v A ? A D @ A w D D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ash Grove Cement Company Ash Grove Cement Company - Leamington Cement Plant

Mailing Address Physical Address
P.O. Box 38069 Highway 132
Leamington, UT 84638 Leamington, UT 84638

Source Contact UTM Coordinates
Name: Cody Watkins 397000 m Easting
Phone: [phone] 4380100 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3241 (Cement, Hydraulic)

SOURCE INFORMATION
General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried on site),
are correctly proportioned, ground, and mixed and then fed into a rotating kiln. The kiln alters the
materials and recombines them into small stones called cement clinker. The clinker is cooled and ground
with gypsum and additional limestone into a fine powdered cement. The final product is stored on site for
later shipping. The major sources of air emissions are from the combustion of fuels for the kiln operation,
from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source of
emissions of PM2.5, PM10, NOx, CO, HAPs, and GHG. It is a minor source of SO2 emissions.
NSR Classification
Major PSD Modification

Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
DAQE-IN103030032-25
Page 4

Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

These changes result in increases in actual emissions but decreases in most potential emissions. There will
be an increase in the potential emissions of VOCs and greenhouse gases.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
DAQE-IN103030032-25
Page 5

Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
DAQE-IN103030032-25
Page 6

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
DAQE-IN103030032-25
Page 7

II.A.4 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)
II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area, and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, stacker systems. II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit-specific requirements.
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total air flow controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter
area; 9,865 acfm total air flow, controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are
controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each
is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6). II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The
following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for
NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.
II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low-pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

DAQE-IN103030032-25
Page 8

II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow through stack
E34.
II.A.18 Kiln Feed Alleviator A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the central material silo between the blending silos and the preheater. Raw feed is removed from the system near the top of the preheater tower.
II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The
coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter area;
1,700 acfm total air flow.
II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker
storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1): 1,800 acfm that discharges into the clinker tunnel.
II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
DAQE-IN103030032-25
Page 9

II.A.27 Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during loading.
II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel, all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during loading. 512.BF3 (1,000 acfm) is located on top of the silo. II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement products. Dust generated
during milling is captured by a BHA pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).

II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates from stack G55 (finish mill stack).
II.A.32 Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4).
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1 thru 3).

II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total air flow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations.
II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This
baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

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II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.
II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023)
II.A.40 Dust Shuttle System A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides, surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the
fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

II.A.41 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons) Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
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II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)
THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)
CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)
PM: 0.02 lbs filterable PM per ton of clinker.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR 60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to approve alternative control measures, the permittee shall keep a copy of the submitted petition and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source
of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2).
[40 CFR 63 Subpart LLL]

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II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must record the PM CPMS output data for all periods when the process is operating and use all the PM CPMS data for calculations when the PM CPMS is not out of control. The owner/operator must demonstrate continuous compliance by using all quality-assured hourly average data collected by the PM CPMS for all operating hours to calculate the arithmetic average operating parameter in units of the operating limit on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
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II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

II.B.1.e.3 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-165]
II.B.1.e.4 PM 40 CFR 60, Appendix A, Method 5, or 5I, or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three runs, with each
run at least 120 minutes in duration and each run collecting a sample of 60 dry standard cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165]
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II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
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II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
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II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer point, is not required to conduct Method 22 visible emissions monitoring under this paragraph. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator may decrease the frequency of performance testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
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II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: Instances of water and/or chemical application to unpaved areas shall be recorded and maintained by the owner/operator. The ambient temperature shall be recorded any time water should be applied but cannot due to freezing conditions. [R307-401-8]
II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

The sprays shall operate whenever dry conditions warrant meeting the required opacity
limitations or as determined necessary by the Director. Water sprays shall not be required during
periods of freezing temperatures.

[R307-401-8]

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II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

C. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the kiln/raw mill stack

F. The owner/operator shall record the output of the system: including the quantity of NOx, CO, O2, THC, Hg, HCl, and CO2 emissions at the kiln stack

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an
affected source shall continuously operate all required continuous monitoring devices
and shall meet minimum frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.

[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]
II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments, the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the results of the performance test demonstrating compliance with the filterable PM limit and using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust the SSOL developed in accordance with the results of the most recent PM performance test demonstrating compliance with the PM emission limit. The owner/operator shall use the PM CPMS to demonstrate continuous compliance with the SSOL in accordance with the requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

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II.B.4 Fuel Limitations: II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke F. Fuel Oil
G. Used Oil Fuel

H. Synthetic Fuel
I. Wood
J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal additive.
Approval is not required to change from one previously approved coal additive to another
previously approved coal additive. [R307-401-8]
II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily heat input of the kiln and precalciner. The owner/operator may increase the average quantity of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon approval by the Director in accordance with the approval process described in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

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Page 20

II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight
A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation
C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit-no less than 1500oF for more than five minutes in any 60-minute period B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
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II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the Director. The calibration procedure and frequency shall be according to manufacturer's specifications. Use of factory-calibrated thermocouples for temperature measurement is approved. However, any other method of temperature measurement must be approved by the Director prior to use. The monitoring equipment for both temperature and oxygen content shall be located such that an inspector can at any time safely read the output. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall only operate the emergency engines for testing and maintenance purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency operation. [R307-401-8]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.5.b.2 To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From Source Submitted NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-IN103030032-25
Page 22

ACRONYMS

The following lists commonly used acronyms and associated translations as they apply to this document:

40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year MACT Maximum Achievable Control Technology MMBTU Million British Thermal Units NAA Nonattainment Area NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

DAQE-GN103030032J-25
January 22, 2025
Via Certified Mail 70190700000208349765
DJ Law
EPA Region 8
1595 Wynkoop Street
Denver, Colorado 80202-1129
[e-mail]
Dear Mr. Law:
RE: Notice of Publication for Ash Grove Cement Company- Leamington Cement Plant – CDS A;
MACT (Part 63), Compliance Assurance Monitoring (CAM), Title V (Part 70) Major Source,
Major Criteria Source, Major HAP Source, Attainment Area, NSPS (Part 60),
Project Number: N103030032
On January 22, 2025, the Director has completed his review of a Prevention of Significant Deterioration
project submitted by Ash Grove Cement Company. Attached to this letter are the draft Approval Order
document (Intent to Approve) and the full engineering review. Following a 60-day review by the Federal
Land Managers, this project will be submitted for a 30-day public comment period. Written comments
received by the Division at this same address during these comment periods will be considered in making
the final decision on the approval/disapproval of the proposed Approval Order. Email comments will also
be accepted at [e-mail]. If anyone so requests to the Director at the Division in writing, a hearing
will be held in accordance with R307-401-7, UAC.
If you have any questions, please contact John Jenks, who may be reached at [phone].
Sincerely,
Jon L. Black, Manager
New Source Review Division
Enclosures: Engineering Review
Modeling Memo
Intent to Approve
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
Jon Black (Jan 22, 2025 14:59 MST)
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
RN103030032
January 21, 2025
Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]
Dear Josh Nelson,
Re: Engineer Review:
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032
Please review and sign this letter and attached Engineer Review (ER) within 10 business days.
For this document to be considered as the application for a Title V administrative amendment, a
Title V Responsible Official must sign the next page.
Please contact John Jenks at [phone] if you have any questions or concerns about the ER.
If you accept the contents of this ER, please email this signed cover letter to John Jenks at
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 1

[e-mail]. After receipt of the signed cover letter, the DAQ will prepare an Intent to
Approve (ITA) for a 30-day public comment period. When the public comment period ends, the
DAQ will consider any comments received and will issue the Approval Order.

If you do not respond to this letter within 10 business days, the project will move forward
without your approval. If you have concerns that we cannot resolve, the DAQ Director may issue
an Order prohibiting construction.

Approval Signature _____________________________________________________________
(Signature & Date)

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 2

OPTIONAL: In order for this Engineer Review and associated Approval Order conditions to be
considered as an application to administratively amend your Title V Permit, the Responsible
Official, as defined in R307-415-3, must sign the statement below. THIS IS STRICTLY
OPTIONAL.

If you do not want the Engineer Review to be considered as an application to administratively
amend your Operating Permit only the approval signature above is required.

Failure to have the Responsible Official sign below will not delay the Approval Order, but will
require submittal of a separate Operating Permit Application to revise the Title V permit in
accordance with R307-415-5a through 5e and R307-415-7a through 7i. A guidance document:
Title V Operating Permit Application Due Dates clarifies the required due dates for Title V
operating permit applications and can be viewed at:

https://deq.utah.gov/air-quality/permitting-guidance-and-guidelines-air-quality

“Based on information and belief formed after reasonable inquiry, I certify that the
statements and information provided for this Approval Order are true, accurate
and complete and request that this Approval Order be considered as an application
to administratively amend the Operating Permit.”

Responsible Official _________________________________________________
(Signature & Date)

Print Name of Responsible Official _____________________________________

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 3

UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW

SOURCE INFORMATION

Project Number N103030032
Owner Name Ash Grove Cement Company
Mailing Address P.O. Box 38069
Leamington, UT, 84638

Source Name Ash Grove Cement Company- Leamington Cement
Plant
Source Location Hwy 132
Leamington, UT 84638

UTM Projection 397000 m Easting, 4380100 m Northing
UTM Datum NAD83
UTM Zone UTM Zone 12
SIC Code 3241 (Cement, Hydraulic)

Source Contact Cody Watkins
Phone Number [phone]
Email [e-mail]

Billing Contact Cody Watkins
Phone Number 385.225.0615
Email [e-mail]

Project Engineer John Jenks, Engineer
Phone Number [phone]
Email [e-mail]

Notice of Intent (NOI) Submitted November 30, 2022
Date of Accepted Application November 28, 2024

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 4

SOURCE DESCRIPTION

General Description
Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried
on site), are correctly proportioned, ground and mixed, and then fed into a rotating kiln. The kiln
alters the materials and recombines them into small stones called cement clinker. The clinker is
cooled and ground with gypsum and additional limestone into a fine powdered cement. The final
product is stored on site for later shipping. The major sources of air emissions are from the
combustion of fuels for the kiln operation, from the kiln, and from the clinker cooling process.
The Leamington cement plant is a major source for emissions of PM2.5, PM10, NOx, CO, HAPs
and GHG. It is a minor source of SO2 emissions.

NSR Classification:
Major PSD Modification

Source Classification
Located in Attainment Area,
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Proposal
Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower, various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 6

These changes result in increases in actual emissions, but decreases in most potential emissions.
There will be an increase in the potential emissions of VOC and greenhouse gases.

EMISSION IMPACT ANALYSIS
The complete modeling review is located in DAQE-MN103030032-24. [Last updated January 14, 2025]

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 7

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 8

Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

Note: Change in emissions indicates the difference between previous AO and proposed modification.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 9

Review of BACT for New/Modified Emission Units

1. BACT review regarding the Leamington Plant Upgrade Project
Any major stationary source or major modification subject to PSD review must undergo an
analysis to ensure the use of BACT. The requirement to conduct a BACT analysis is set forth in 40
CFR 52.21. Similarly, Utah requires the installation of BACT for all sources of air pollution under
R307-401-5(2)(d)), BACT is defined in 40 CFR 52.21 (and R307-401-2) as:

". . . best available control technology means an emissions limitation (including a visible emission
standard) based on the maximum degree of reduction for each pollutant subject to regulation under
Act which would be emitted from any proposed major stationary source or major modification
which the Administrator, on a case-by-case basis, taking into account energy, environmental, and
economic impacts and other costs, determines is achievable for such source or modification
through application of production processes or available methods, systems, and techniques,
including fuel cleaning or treatment or innovative fuel combustion techniques for control of such
pollutant . . ."

Therefore, a BACT analysis is required for each new or physically modified emission unit for each
pollutant that exceeds an applicable PSD significant emission rate (SER). Since the PM10 and PM2.5
emissions from the proposed project exceed the applicable PSD SER, a BACT analysis is required
to assess the required levels of control for these pollutants. Because the CO2e emissions are subject
to regulation as a result of the proposed project resulting in an increase of 75,000 tons or more per
year CO2e, a BACT analysis is also required for that pollutant. Note that HAPs listed under CAA
Section 112(b)(1) are excluded from NSR (New Source Review) or PSD (i.e., BACT) review.

In a memorandum dated December 1, 1987, the United States Environmental Protection Agency
(EPA) stated its preference for a "top-down" BACT analysis. After determining if any New Source
Performance Standard (NSPS) is applicable, the first step in this approach is to determine, for the
emission unit in question, the most stringent control available for a similar or identical source or
source category. If it can be shown that this level of control is technically, environmentally, or
economically infeasible for the unit in question, then the next most stringent level of control is
determined and similarly evaluated. This process continues until the BACT level under
consideration cannot be eliminated by any substantial or unique technical, environmental, or
economic objections.

Presented below are the five basic steps of a top-down BACT review as identified by the EPA.
Step 1 - Identify All Control Technologies
Step 2 - Eliminate Technically Infeasible Options
Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Step 4 - Evaluate Most Effective Controls and Document Results
Step 5 - Select BACT

Ash Grove has elected to follow this methodology and based the BACT review on each individual
pollutant. The complete BACT analysis follows. [Last updated January 14, 2025]

2. BACT review regarding PM10 and PM2.5 Sources
PM10 and PM2.5 Modified Equipment
The existing kiln precalciner, preheater, and alleviator system are proposed to be modified, and the
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 10

kiln's ID fan and clinker cooler fans are proposed to be replaced, which will result in increased
airflow. Additionally, the clinker cooler baghouse will be converted from a plenum pulse to a pulse
jet baghouse. These modifications are projected to result in a net increase of potential PM10 and
PM2.5 emissions.

Kiln Upgrade BACT
The rotary cement kiln is the core of the cement manufacturing process, transforming the blended
raw materials or "rawmix" into clinker through pyro processing. Emissions from the kiln occur
from fuel combustion plus the physical and chemical reactions needed to transform the rawmix
into clinker. This project involves process and energy efficiency improvements and an increase in
kiln production, resulting in an increase of PM10 and PM2.5 emissions. This section specifically
addresses filterable PM10 and PM2.5. The condensable fraction is represented with the other
precursors as applicable to proposed emission increases.

The Leamington Plant's Kiln is subject to NSPS, Subpart F for particulate. Therefore, a BACT
analysis addresses applicability of the proposed changes to the kiln system to NSPS and review of
the RBLC. A summary of the resources reviewed include the following:

NSPS Subpart F - Standards of Performance for Portland Cement Plants establishes emission
standards for cement kiln operations. Specifically, kilns modified after June 16, 2008, are limited to
0.07 lbs PM/ton of clinker produced.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028) and
Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type 90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from kiln operations are as follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM emissions are most effectively controlled using a collection system with enclosures routed to
baghouses providing up to 99.9% control efficiency. Other technologies such as wet scrubbers,
cyclones and ESPs are feasible, but provide lower control efficiencies than a baghouse. Ash Grove
has selected technology with the highest control efficiency, so there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 11

Step 5 - Select BACT
Ash Grove proposes that BACT for PM10 and PM2.5 emissions from the kiln consist of a collection
system routed to a baghouse or fabric filter that complies with NSPS Subpart F's emission standard
for a modified source. BACT for the Leamington Plant's kiln are 10% opacity and 0.07 lb of
PM/ton (NSPS Subpart F emission standard) of clinker.
[Last updated January 14, 2025]

3. BACT review regarding PM10 and PM2.5 sources cont.
Clinker Cooler Upgrade BACT
The clinker cooler reduces the temperature of the clinker exiting the kiln. It is necessary to reduce
clinker temperature before it enters the finish mill to maintain product quality and reduce wear and
tear on equipment. The clinker cooler is equipped with a heat exchanger that captures waste heat
and transfers it to the kiln preheater for process and energy efficiency. Emissions from the clinker
cooler are vented to a baghouse. The Leamington Plant's clinker cooler is also subject to NSPS
Subpart F for particulate. Ash Grove's proposed changes to the clinker cooler meet the definition of
a reconstruction under NSPS. Therefore, in order to meet the requirements of NSPS Subpart F, Ash
Grove will be required to meet a limit of 0.02 lb of PM/ton of clinker.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 and PM2.5 emissions from clinker cooler operations are as
follows:
Baghouse/Fabric Filter;
Cyclone;
Electrostatic Precipitator; and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
All identified options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Cyclone 20 - 70%

Step 4 - Evaluate Most Effective Controls and Document Results
PM10 and PM2.5 emissions are most effectively controlled using a collection system with enclosures
routed to a baghouse, which can achieve up to 99.9% control efficiency. Other technologies such as
wet scrubbers, cyclones and ESPs are feasible, but provide lower control efficiencies than a
baghouse. Because the most efficient control technology is proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for PM10 and PM2.5 emissions from the clinker cooler is a collection system routed to a
baghouse or fabric filter. In order to meet the requirements of NSPS Subpart F, Ash Grove will
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 12

meet a reduced emission limit of 0.02 lb of PM/ton of clinker. A 10% opacity limit is also
applicable. [Last updated January 14, 2025]

4. BACT review regarding PM10 and PM2.5 sources cont.
New Finish Mill BACT
The proposed Plant upgrade include adding a second finish mill. The new finish mill will use an
energy efficient vertical roller mill assisted with a grinding aid. A total of five (5) point sources are
planned for the finish mill. In accordance with NSPS Subpart F, emissions from finish mill are
restricted to 10% opacity. Ash Grove has reviewed the following sources to identify available
control technologies.

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);12 and

Region 8 General Permit for Concrete Batch Plants.

Step 1 - Identify All Control Technologies
Control technologies identified for PM10 emissions from plant material handling operations are as
follows:
Baghouse / Fabric Filter;
Best Management & Operational Practices;
Cyclone;
ESP;
Enclosure;
Water Application (Watering); and
Wet Scrubber.

Step 2 - Eliminate Technically Infeasible Options
With the exception of water application, all options are technically feasible. Water application is
eliminated as clinker exiting the kiln along with additives in the finish mill must remain dry to
maintain product quality. Therefore, it is technically infeasible to water material in the finish mill.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
1. Baghouse 95 - 99.9%
2. Wet Scrubber 99%
3. ESP 90 - 99.5%
4. Enclosure 50-90%
5. Cyclone 20-70%
6. Best Management & Operational Practices varies

Step 4 - Evaluate Most Effective Controls and Document Results
Baghouses provide the highest emission control efficiency, controlling up to 99.9% of PM
emissions from finish mill equipment. After baghouses, using a wet scrubber or ESP provides
similar PM control. Notably, baghouses, scrubbers, and ESPs require enclosures to aid in capturing
emissions and ducting to the control. Therefore, optimal PM emission control can be achieved
through implementing both baghouses and enclosures where feasible. Plant material sizing and
handling is currently done using a series of buildings and enclosures routed to baghouse controls.
Various silos storing material inputs are also equipped with fabric filters. As the highest ranked
technology is applied, there are no adverse energy, environmental or cost impacts to consider with
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 13

the use of these control technologies. Thus, no further analysis is required under EPA's top-down
BACT approach.

Step 5 - Select BACT
BACT for finish mill PM10 emissions is compliance with NSPS Subpart F, Standards of
Performance for Portland Cement Manufacturing where applicable. Ash Grove will achieve BACT
for PM10 emissions from finish mill equipment through the implementation of enclosures,
baghouses, and best management practices. All baghouses at the finish mill will have a 10%
opacity limitation and a grain loading of 0.005 grains/dscf. [Last updated January 14, 2025]

5. BACT review regarding PM10 and PM2.5 sources cont.
Material Transfer, Sizing, and Storage BACT
The Leamington Plant has sources of fugitive emissions through raw material transfer. Materials
transferred include limestone and other raw materials, coal, clinker, and cement. These materials
are transferred by conveyor belt, screw conveyor, elevator, pneumatic conveyance or chutes via
gravity. At the Leamington Plant the fugitive emissions are enclosed at their transfer points and
routed to baghouses.

The following emission units are included in this category:
Limestone Crushing, Sizing, and Material Transfer;
Raw Material Transfer;
Coal Sizing and Transfer;
Existing Finish Mill;
Clinker Storage and Transfer;
Cement Storage and Truck and Rail Cement Loadout;
New Rail Loading and Loadout; and
New Clinker Reclaim Hopper Baghouse.

Generally, controls for these units have not changed or they are similar to current existing controls.
A full BACT analysis of each unit is included in Ash Grove's NOI and additional submitted
information. However, given that most controls remain unaltered, only the results of Step 5 -
Select BACT will be included here.

Limestone Crushing, Sizing, and Material Transfer
Subject to NSPS Subpart OOO opacity limits for existing sources.
Existing baghouses. No change from bag manufacturer's specifications.

Raw Material Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Coal Storage and Transfer
Existing Equipment. No change from bag manufacturer's specifications
20% Opacity

Clinker Storage and Transfer
Subject to NSPS Subpart F opacity limits:
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 14

10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Existing Finish Mill Grinding, Storage and Transfer
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

Cement Storage and Truck and Rail Cement Loadout, New Rail Loadout
Subject to NSPS Subpart F opacity limits:
10% opacity
Existing Equipment. No change from bag manufacturer's specifications.

New Rail Loadout, controlled by baghouse
Emissions Limit - 0.005 gr/dscfm

New Clinker Reclaim Hopper, controlled by baghouse
Subject to NSPS Subpart F opacity limits:
10% opacity
Emissions Limit - 0.005 gr/dscfm [Last updated January 14, 2025]

6. BACT review regarding PM10 and PM2.5 sources cont.
PM10 and PM2.5 Fugitive Emissions
The following fugitive emissions sources will increase emissions of PM10 and PM2.5 as a result of
the Leamington Plant's proposed throughput increase. The sources addressed in the following
BACT analyses are primarily in the quarry, but also include emissions from roads and dumping of
raw materials within the plant boundary.

The sources evaluated are listed below:
Roads;
Loading and Unloading;
Stockpiles;
Bulldozing and Grading;
Disturbed Areas; and
Drilling and Blasting.

Ash Grove currently controls emissions from these processes, and generally, controls for these
units have not changed. A full BACT analysis of each unit is included in Ash Grove's NOI and
additional submitted information. However, given that most controls remain unaltered, only the
results of Step 5 - Select BACT will be included here.

Roads PM10 and PM2.5 BACT
The Leamington Plant is subject to fugitive dust control standards in R307-205 which identifies an
opacity standard and control techniques. Ash Grove proposes BACT to consist of restricting
fugitive emissions to the opacity standard of fugitive emissions shall not exceed 20% opacity. For
unpaved roads this will be met via maintaining vehicle speeds ≤25 mph, watering, road base,
and/or chemical treatment as necessary. For paved roads maintaining vehicle speeds ≤25 mph,
watering, and vacuum sweeping will be used.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 15

Loading and Unloading BACT
Loading and unloading activities at Ash Grove's Leamington Plant include the loading and
unloading of overburden, limestone, and reject fines material with quarry haul trucks and loaders.
Trucks delivering raw materials also unload at the Ash Grove Plant. The facility is subject to
fugitive dust control standards in UAC R307-205 which identifies an opacity standard and control
techniques. Ash Grove proposes BACT consist of restricting fugitive emissions to the opacity
standard of fugitive emissions shall not exceed 20% opacity and emissions are controlled with best
management practices via a Fugitive Dust Control Plan.

Stockpiles BACT
BACT shall consist of restricting fugitive emissions to the opacity standard of 20% opacity at the
property boundary. BACT for stockpiles will be achieved through applying good management
practices through its fugitive dust plan as appropriate.

Bulldozing and Grading BACT
BACT shall consist of restricting fugitive emissions from bulldozing and grading activities to no
more than 20% opacity, and that emissions are controlled with periodic watering of the disturbed
surface. The frequency of water application will depend on ambient weather conditions and
inherent moisture content of the material being moved.

Disturbed Areas BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. BACT for
disturbed areas will be achieved through best management practices, watering, scarification, and
revegetation.

Drilling and Blasting BACT
BACT shall consist of restricting fugitive emissions to not exceed 20% opacity. This is achievable
through best management practices, shrouds, watering, and dust collection. [Last updated January
14, 2025]

7. BACT review regarding kiln system NOx emissions
Kiln System (Kiln, Raw Mill, and Coal Mill) - NOx BACT
Although there are physical changes to the kiln system, these changes are primarily related to
particulate emissions. NOx emissions are generated from the combustion of fuel - and no changes
in NOx emissions are expected from the kiln (hourly capacity to emit). The kiln NOx emissions will
remain the same as a result of upgrades to the SNCR system. The replacement of the various
components of the kiln system and portions of the preheater tower, along with new injection points,
will ensure that increased mixing of ammonia is achieved to enhance the SNCR system's ability to
reduce NOx and minimize ammonia slip. This will allow the Leamington Plant to maintain the NOx
hourly capacity to emit unchanged from current levels Leamington Plant Upgrade Project. At
present Ash Grove has no restriction on the amount of fuel combusted, only a limit on total NOx
generated, and with this project the allowed NOx PTE is decreasing from 1,352 tpy to 1,226 tpy.

Additional ammonia will be used in the existing SNCR system. While the SNCR system has
adequate capacity to accommodate the additional ammonia demand resulting from the system
upgrades, more ammonia ports are proposed to be added with the kiln system's proposed changes
of the equipment. The changes proposed to the kiln system will increase residence time and
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 16

temperature which will improve the SNCR system's effectiveness to control NOx emissions and
minimize ammonia slip emissions to the atmosphere. No additional review of NOx BACT for the
kiln system is required under this proposal. [Last updated January 14, 2025]

8. BACT review regarding new finish mill heater emissions
Finish Mill Heater
The proposed finish mill will include a process heater to maintain a minimum temperature during
milling. The proposed heater will run on natural gas and is rated at 10 MMBtu/hr. Startup and
shutdown emissions from the heater are anticipated to be no greater than normal operation as the
process is simply a matter of bringing the heater to operating temperature. Emissions evaluated in
the BACT analysis for the finish mill heater include NOx, SO2, CO, and VOCs, PM10, and PM2.5.
Pollutants with identical control technologies are grouped together in the analysis.

NOx - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for NOx from units of this size range are as follows:
Ultra-Low-NOx Burners (ULNB);
Low NOx Burners;
Selective Catalytic Reduction (SCR);
Selective Noncatalytic Reduction (SNCR);
Good Combustion Practices; and
Use of Natural Gas.

Step 2 - Eliminate Technically Infeasible Options
Low exit temperatures render the use of SCR and SNCR ineffective. Particulate entrainment within
the finish mill could potentially foul (plug) the nozzles of ULNB. Low-NOx burners, the use of
natural gas as fuel and good combustion practices are all considered technically feasible.

Step 3 and Step 4 - Rank Remaining Control Technologies by Control Effectiveness and Evaluate
Most Effective Controls and Document Results
Since the three feasible control technologies are proposed for the finish mill heater, no detailed
economic, energy, and environmental impact evaluations were conducted. No ranking of control
effectiveness is required as all three controls are proposed.

Step 5 - Select BACT
BACT for NOx is the use of natural gas as fuel, good combustion practices and the use of Low NOx
burners.

CO, SO2, and VOC - Finish Mill Heater BACT
Step 1 - Identify All Control Technologies
Control technologies for CO, SO2, and VOC from units of this size are as follows:
Good Combustion Practices
Use of Natural Gas

The finish mill heater combusts natural gas. Related natural gas combustion emissions are
anticipated to be minimal.

Step 2 - Eliminate Technically Infeasible Options
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Both control options are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Both technologies offer intrinsic emission reductions from combustion. Since the technologies do
not compete, both technologies can and will be used simultaneously.

Step 4 - Evaluate Most Effective Controls and Document Results
Because both control technologies identified in Step 1 are proposed, there are no adverse energy,
environmental or cost impacts to consider with the use of this control technology. Thus, no further
analysis is required under EPA's top-down BACT approach.

Step 5 - Select BACT
BACT for CO, SO2, and VOC are good combustion practices and the use of natural gas.

PM10 and PM2.5 BACT for the finish mill has been addressed in the PM10/PM2.5 sources section.
[Last updated January 14, 2025]

9. BACT review regarding SO2, VOC, and Lead Sources
The following BACT analysis is grouped by pollutants that will experience an increase in potential
emissions and the associated technically feasible control technologies. As such, the BACT analysis
is separated into SO2, VOC, and lead respectively with organic HAPs addressed with VOCs.

SO2 - Cement Kiln BACT
NSPS Subpart F - Standards of Performance for Portland Cement Plants, establishes emission
standards for cement kiln operations. Specifically, kilns constructed or reconstructed after June 16,
2008, are limited to 0.4 lbs SO2/ton clinker on a 30-day rolling average respectively. This limit is
an existing emission limit in the Leamington Plant's approval order and Title V. Ash Grove will
continue to achieve this emission limitation while achieving BACT for the kiln operations. Ash
Grove has reviewed the following sources to identify available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028);

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019); and

NSPS Subpart F as an affected emissions facility in 40 CFR 60.62(a)(4);

Portland Cement Association's Formation and Techniques for Control of Sulfur Dioxide and Other
Sulfur Compounds in Portland Cement Kiln Systems.

SO2 emissions are a result of oxidation of sulfur compounds in the rawmix and/or the coal used to
fire the kiln. However, the alkaline nature of the cement provides for direct absorption of SO2 into
the product, thereby mitigating the quantity of SO2 emissions in the exhaust stream.

Step 1 - Identify All Control Technologies
Control technologies identified for SO2 emissions from coal-fired kiln operations are as follows:
Baghouse or fabric filter;
Dry reagent injection prior to baghouse;
Wet scrubber;
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Process optimization; and
Good combustion practices.

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below:

1. Process Optimization 99%
2. Wet Scrubber 99%
3. Dry Reagent Injection 60%
4. Good Combustion Practices 30%
5. Baghouse Variable

Step 4 - Evaluate Most Effective Controls and Document Results
SO2 emissions are most effectively controlled by optimizing the process and utilizing the inherent
SO2 scrubbing properties of the kiln system itself. Although wet scrubbers alone can achieve equal
control efficiencies as process optimization, additional capital and operational expenses are
required for water consumption and wastewater discharge. Whereas process optimization achieves
the same control effectiveness and has the added benefit of reduced operational costs. Ash Grove
optimizes the kiln process by routing the exhaust from the kiln to a preheater and raw mill to
interact with the raw mix, thus creating an atmosphere similar to a dry scrubber system. Good
combustion practices also reduce SO2 formation with the added benefit of energy efficiency.

Step 5 - Select BACT
BACT for control of SO2 emissions from kiln operations shall consist of process optimization by
routing kiln exhaust to the preheater and raw mill, good combustion practices, and use of a
baghouse prior to exhausting to the atmosphere. As a modification of the kiln, 40 CFR 60.62(a)(4)
requires an emission limit of 0.4 pounds of sulfur dioxide (SO2) per ton of clinker on a
30-operating day rolling average. [Last updated January 14, 2025]

10. BACT review regarding SO2, VOC, and Lead Sources cont.
VOC - Cement Kiln BACT
VOCs are generated by incomplete combustion in the kiln. 40 CFR 63 Subpart LLL - NESHAP
from the Portland Cement Industry limits total hydrocarbon and total organic HAP emissions to 24
and 12 ppmv at 7% oxygen. Ash Grove will achieve or exceed these emission limitations while
achieving BACT for the kiln operations. Ash Grove has reviewed the following sources to identify
available control technologies:

EPA's RBLC Database for Portland Cement Manufacturing (process type 90.028); and

EPA's RBLC Database for Lime/Limestone Handling/Kiln/Storage/Manufacturing (process type
90.019).

Step 1 - Identify All Control Technologies
Control technologies identified for VOC emissions from coal fired kiln operations are as follows:
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Process optimization,
Good combustion practices

Step 2 - Eliminate Technically Infeasible Options
All technologies identified are technically feasible.

Step 3 - Rank Remaining Control Technologies by Control Effectiveness
Each technically feasible control technology is ranked by control effectiveness and presented
below.

1. Process Optimization Variable
2. Good Combustion Practices Variable

Step 4 - Evaluate Most Effective Controls and Document Results
VOC emissions are most effectively controlled by optimizing the process. Ash Grove optimizes the
kiln process by capturing waste heat from the clinker cooler and routing to a kiln preheater. Good
combustion practices also reduce VOC formation with the added benefit of energy efficiency.
There are no adverse energy, environmental or cost impacts to consider with the use of this control
technology.

Step 5 - Select BACT
BACT for control of VOC emissions from kiln operations shall consist of process optimization by
routing kiln heat to the preheater and good combustion practices. An emission limit of 24 ppmv
VOC @ 7% O2 is imposed by NESHAP Subpart LLL.

VOC - Grinding Aid BACT
A grinding aid containing VOC is added to the new finish mill to disperse particles within the mill
and expose more surface area to grinding. An increase in grinding aid usage proportionally
increases potential VOC emissions because volatiles from the grinding aid are not combusted in
the kiln.

There is only one identified control option for limiting the VOC emissions from the grinding aid.
Process optimization is technically feasible. VOC emissions are most effectively controlled by
optimizing the process. Ash Grove proposes to install a vertical finish mill with this project. Due to
the new modern mill's efficiency, it is anticipated that a reduced amount of grinding aid will be
required for each ton of clinker ground. Ash Grove estimates total VOC emissions from the
grinding aid at 2.37 tpy.

Lead Emissions
The lead emissions are anticipated to increase as a result of the proposed increase in clinker
throughput with the Leamington Plant upgrade project. Lead emissions result from residual
amounts of lead in raw materials and fuel. Lead emissions will be controlled the same as PM,
therefore a separate top-down BACT analysis has not been conducted as the Leamington Plant has
applied the most effective controls. [Last updated January 14, 2025]

11. BACT review regarding Greenhouse Gases
GHG Background
On October 9, 2009, the mandatory GHG reporting regulation, referred to as 40 CFR 98, was
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published in the Federal Register. Through 40 CFR 98, the U.S. EPA established the GHG
Reporting Rule, which requires the annual reporting of GHG data and other relevant information
from large sources and suppliers in the United States. Monitoring through the GHG Reporting
Program (GHGRP) began in 2010, with the first reports due by March 31, 2011. Per 40 CFR
98.2(a)(1), any facility associated with cement production is subject to the GHGRP and must report
CO2e emissions. The CO2e is the sum of equivalent GHG emissions from CO2, CH4, and N2O,
with their respective global warming potentials (GWP) applied. Ash Grove's facility is subject to
GHG Reporting Rule and monitors CO2 emissions from its kiln with a continuous emissions
monitoring system (CEMs). On June 23, 2014, the U.S. Supreme Court held that required PSD
permits (based on emissions of non-GHG pollutants) may continue to require limitations on GHG
emissions based on the application of BACT as an "anyway source". The Leamington Plant
modification project is a major source for PSD for both PM10 and PM2.5, and GHGs are estimated
to be greater than 75,000 tpy and greater than zero on a mass basis; therefore, GHGs are evaluated
for BACT as an anyway source.

Cement Manufacturing GHG BACT
A BACT analysis has been conducted for CO2e emissions from the kiln system. For this GHG
BACT analysis, various control technologies or combinations of technologies were identified using
the RACT/BACT/LAER Clearinghouse, available literature including guidance published by EPA
and South Coast Air Quality Management District (SCAQMD), current air regulations, other
regulatory organizations, and engineering experience. In March 2011, EPA published GHG
permitting guidance, as well as a white paper on available and emerging technologies for reducing
GHG emissions from the Portland cement industry in October 2010. Additionally, EPA published a
series of videos on GHG permit training in December 2010. The SCAQMD published GHG BACT
guidance in 2021. Additional sources of information were reviewed and documented based on
publications from trade organizations and other governmental committees with GHG or carbon
reduction guidelines and/or recommendations.

EPA has defined in 40 CFR 86.1818-12(a) GHGs as a group of six gases: CO2, nitrous oxide
(N2O), methane (CH4), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur
hexafluoride (SF6). GHG emissions from the kiln result from calcination and fuel combustion.
Since the primary GHG emitted by a kiln is CO2, the BACT analysis focuses on CO2 emissions
from the kiln. Emissions of CH4 and N2O are minimal from cement kilns. Per EPA guidance, GHG
control technologies for consideration in a BACT analysis for Portland Cement Manufacturing
include:

Source-wide energy efficiency strategies;
Raw material substitution;
Blended cements;
Carbon capture utilization and storage; and
Fuel switching.
Other emerging technologies [Last updated January 14, 2025]

12. BACT review regarding Greenhouse Gases cont.
Step 1: Identify All Control Technologies
The CO2 emissions from a cement kiln are generated by the calcination process (conversion of the
calcium carbonate in limestone to calcium oxide) and by combustion of fuel in the kiln. Potential
control technologies to reduce these CO2 emissions for a cement kiln are addressed in EPA's white
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paper on Available and Emerging Technologies for Reducing GHG Emissions from the Portland
Cement Industry.

These technologies fall into three categories:
Energy Efficiency Improvements for the Clinker Production Process
Fuel Substitution
Carbon Capture and Sequestration

Step 2: Eliminate Technically Infeasible Options
Several potential energy efficiency improvements are technically feasible: Pre-heater/Pre-calciner
Kiln Process, Kiln Seal Management Program, Refractory Selection (Kiln Insulation), and Energy
Recovery from the Clinker Cooler. The use of alternative fuels such as natural gas, whole tires and
biofuel) is also technically feasible. Other control options, such as Use of Fluxes and Mineralizers,
Heat Recovery for Power - Cogeneration, Carbon Sequestration, Oxyfuel combustion, and
Post-combustion Capture have been deemed infeasible.

Step 3: Rank Remaining Control Technologies by Control Effectiveness
All four remaining control techniques are currently implemented at the Leamington Plant. This
permitting project incorporates energy efficiency improvements. Ash Grove has had a fuel
substitution program in place for several years, and this program is continually reviewed and
updated as new sources and types of fuel are identified.

Step 4: Evaluate Most Effective Controls and Document Results
Since all technically feasible energy efficiency improvements and changes to product composition
will be implemented, this section will focus on economic and environmental considerations of fuel
substitution to operate exclusively on natural gas.

Firing natural gas as the primary kiln fuel can reduce CO2 emissions from fuel combustion by as
much as 40%. However, studies have shown that use of natural gas as primary kiln fuel can result
in three times more NOx emissions than NOx emissions from coal firing. Creating more NOx to
reduce GHG emissions is undesirable as it is a precursor to both ozone and PM2.5. Fuel substitution
essentially trades emissions of one regulated pollutant for another. Estimated capital cost to switch
to natural gas fuel exceeds $25M. Implementing natural gas technology would provide incremental
public health and welfare benefit globally by reducing CO2 emissions, while increasing NOx
emissions and negatively impacting public health and welfare locally. Switching fuels to another
fossil fuel has finite potential to mitigate CO2 emissions.

Step 5: Select BACT
In addition to the proposed energy efficiency improvements addressed elsewhere in this BACT
analysis, BACT is a limit of 0.92-ton CO2e/ton clinker. Ash Grove will use a continuous emission
monitoring system (CEMS) for CO2 to demonstrate compliance with this limit. [Last updated
January 14, 2025]

13. BACT review regarding Leamington Plant Upgrade Project conclusion
The control processes and techniques covered in this BACT analysis have been reviewed by the
NSR Section of the UDAQ. Ash Groves proposed controls and associated emission limitations
represent BACT. Any emission limitations not expressed in an associated NSPS or NESHAP will
be included in the terms and conditions of this AO. A listing of all associated NSPS and NESHAP
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programs is also included in the Source Information section of this document under Applicable
Federal Programs. [Last updated December 13, 2024]

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]

I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]

I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]

I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO,
including associated air pollution control equipment, in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded.
[R307-401-4]

I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]

I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date
of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
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proper credit when notifying the Director, send the documentation to the Director, attn.: NSR
Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.A THE APPROVED EQUIPMENT

II.A.1 Leamington Cement Plant

II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.

II.A.3
NEW
Stockpiles
Coal storage
Area: 1 acre
Annual throughput 20,000 tpy

AF and ARM stockpiles
Area: 0.25 acre
Annual throughput 8,000 tpy

II.A.4 Stationary Crusher
Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction
of quarried material to 3-inch minus sized material. The crusher is equipped with a 20,000
acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)

II.A.5 Raw Material Transfer
Crushed material is transported to raw material storage by belt B8. The raw material transfers
at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor
transfer point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total
filter area & water sprays. (pre-1983)

II.A.6 Material Handling
Conveyor belt systems, secondary feeders and screens, stacker system

II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit specific requirements

II.A.8 Belt Conveyor Transfer Baghouse
Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area
and 1,800 acfm total air flow, controls emissions from the conveyor belt that transfers the
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stacked material to the raw material silos.

II.A.9 Raw Material Silos
Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The
four silos are equipped with one common Fuller, plenum pulse baghouse (315.BF1) - 1,689 ft2
filter area; 9,865 acfm total air flow controlling particulates from stack C125 (raw storage).

II.A.10 Fifth Component Silo
Raw materials are stored in a silo. This silo is equipped with a BHA, pulse jet baghouse
(315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.

II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and re-introduced into the raw
mill feed. This system includes vibrating feeders, a conveyor system, and surge bin.
Emissions are controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3,
316.BF4, 316.BF5) - each is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1
A/C ratio.

II.A.12 Cross-Belt Analyzer
Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6)

II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom
of the raw mill where finely ground raw material is picked up. Combustion gases and fine raw
materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38).
The following equipment is installed: low-NOx burner, selective non-catalytic reduction
(SNCR) for NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued
mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric
monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct
for mercury adsorption capacity. The carbon injection system is not an emission point as it is
in an enclosed building.

II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

II.A.16 Two Kiln Feed Blending Silos
Raw material is blended in one of two blending silos prior to feeding the kiln. The blending
silos are controlled by one common Fuller, plenum pulse baghouse (411.BF1) - 1,351 ft2 filter
area; 7,160 acfm total air flow.

II.A.17 Blending Silo Elevators (2)
Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped
with a Fuller, pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow
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through stack E34.

II.A.18 Kiln Feed Alleviator
A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the
central material silo between the blending silos and the preheater. Raw feed is removed from
the system near the top of the preheater tower.

II.A.19 Coal Silo
Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner.
The coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter
area; 1,700 acfm total air flow.

II.A.20 Coal Grinding System
Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in
the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2):
19,500 acfm rated airflow with 3.75:1 A/C ratio

II.A.21 Clinker Cooler and Baghouse
Reconstructed grate type cooler used for cooling clinker from the kiln prior to transfer to
clinker storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) -
173,869 acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter
monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer
Clinker is removed from the clinker cooler by drag chains and dropped onto one of two
clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse
(419.BF8). The exhaust is routed to the clinker cooler stack.

II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions
generated when loading the east and west clinker silos and the out-of-spec silo are controlled
by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1):
1,800 acfm, that discharges into the clinker tunnel.

II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm, that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2)
Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers.
Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses
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(511.HP1 and new 511.HP2): 1,800 acfm each.

II.A.27 Gypsum Silo
Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2
total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust
during loading.

II.A.28 Clinker Tunnel Exitway
The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse
(511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel all discharge in the clinker tunnel.
Emissions are vented through the tunnel exitway.

II.A.29 Limestone Silo
Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor
belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust
during loading. 512.BF3 (1,000 acfm) is located on top of the silo.

II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement product. Dust
generated during milling is captured by a BHA, pulse jet baghouse (514.BF2) - 6,080 ft2 filter
area; 32,000 acfm total air flow controlling particulates from stack G105 (finish grinding
stack).

II.A.31 Finish Mill (Ball Mill) Separator
After clinker and gypsum are ground into cement product, a separator returns the oversized
cement particles to the finish mill. Dust generated by the finish mill separator is collected by a
BHA, pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow
controlling particulates from stack G55 (finish mill stack).

II.A.32
NEW
Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The
stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4)
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1,
525.BF1 thru 3)

II.A.33 Finish Cement Storage Silos
There are six storage and two interstice silos where the finished cement product is stored. A
single common Fuller, plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm
total air flow through stack H7 is located on top of the silos and is used to control emissions
during loading and unloading operations.

II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail
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shipping. This baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out
The cement loadout system located on the South side of the silos (truck load outside) is
controlled by a Fuller, pulse jet baghouse (611.BF2) during unloading from the silos for truck
shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement
conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed
space inside the silos.

II.A.36
NEW
Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

II.A.37 MHO: Materials Handling Operation
Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1
& 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4;
512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.

II.A.38 LBS: Limestone Bypass System
Additional limestone is added to the clinker and gypsum by the limestone bypass system
(LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays
at the screen and material handling drop points.

II.A.39 GEN: Emergency Generators
One diesel-fired emergency generator (new)
Rating: 762 hp
(Kiln, Tier 3, permitted 2022)

Two natural gas-fired emergency generators
Rating: 304 hp
(Main office and control room, permitted in 2023)

One diesel-fired emergency generator
Rating: 560 hp
(Shipping, permitted 2023).

II.A.40 Dust Shuttle System
A dust shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14 inch knife gate, 8 inch knife gate, 8 inch air
slides, surge bin), and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm)
on the fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

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II.A.41
NEW
Miscellaneous Storage Tanks
One diesel storage tank (<2,000 gallons)
One gasoline storage tank (500 gallons)
Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):

II.B REQUIREMENTS AND LIMITATIONS

II.B.1 Requirements on the Cement Plant:
II.B.1.a
NEW
The following limits shall not be exceeded:

A. Clinker production - 1,155,000 tons per rolling 12-month period

B. Used oil consumption - 85,724 gallons per rolling 12-month period

C. Limestone bypass material processed - 216,260 tons per rolling 12-month period.
[R307-401-8]

II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a
new 12-month total by the 25th day of each month using data from the previous 12 months.
Records shall be kept for all periods when the plant is in operation. Consumption and
production shall be calculated through use of the plant's acquisition system. [R307-401-8]

II.B.1.b
NEW
Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed
the following rates and concentrations:

Source: Kiln 1/Raw Mill Stack (D38)

PM: 0.07 lbs filterable PM per ton of clinker

SO2: 0.4 lbs per ton of clinker (3-hr average)

CO: 3,395 tons per rolling 12-month period, and 6,600 lbs/hr

NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average, and 1,233 tons per rolling
12-month period

Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is
400oF or less.

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Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)

THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)

CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)

PM: 0.02 lbs filterable PM per ton of clinker. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL,
R307-401-8]

II.B.1.c
NEW
A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR
60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust
emissions control plan shall be monitored to demonstrate that appropriate control measures are
being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of
the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall
be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in
the plan and that the source is operating in accordance with the submitted plan. For petitions
to approve alternative control measures, the permittee shall keep a copy of the submitted
petition and any approvals received. [40 CFR 60 Subpart Y]

II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area
source of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2). [40 CFR
63 Subpart LLL]

II.B.1.e
NEW
Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b
and II.B.1.d shall be performed as specified below:

A. Kiln/Raw Mill Stack
Pollutant Test Status Test Frequency
PM * #

CO * ++

SO2 ** ##

NOx * ++

Dioxin/Furan * +++

THC *** ++

Hg *** ++

HCL *** ++

CO2 * ++

B. Clinker Cooler (F31)
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Pollutant Test Status Test Frequency
PM + #

C. Testing Status (To be applied above)
* The initial testing has already been performed.

** The SO2 initial performance test was conducted on August 26, 2013.

*** The initial compliance test shall be conducted within the first 30 operating days of
operation in which the affected source operates using a CEMS.

# Test once every year. If performance testing would be required less than 15 operating days
after the Kiln has completed Startup after being down for more than 24 hours, then
performance testing may be deferred up to 15 operating days after completion of the Startup.
The Director may require testing at any time.

## Test at least once every two years. The Director may require testing at any time.

+ Initial testing is required within 180 days of startup of the reconstructed equipment

++ Compliance with the limits shall be demonstrated through use of a continuous emissions
monitoring system as outlined in Condition II.B.3.a, and as follows:
To determine continuous operating compliance, the owner/operator must record the PM
CPMS output data for all periods when the process is operating, and use all the PM CPMS
data for calculations when the PM CPMS is not out-of-control. The owner/operator must
demonstrate continuous compliance by using all quality-assured hourly average data collected
by the PM CPMS for all operating hours to calculate the arithmetic average operating
parameter in units of the operating limit on a 30 operating day rolling average basis, updated
at the end of each new kiln operating day.

+++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.e.1
NEW
Notification
The Director shall be notified at least 30 days prior to conducting any required emission
testing. A source test protocol shall be submitted to DAQ when the testing notification is
submitted to the Director. The notification requirements for performance tests subject to 40
CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
[R307-165]

II.B.1.e.2
NEW
Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other EPA-approved methods acceptable to the Director. An Occupational
Safety and Health Administration (OSHA)- or Mine Safety and Health Administration
(MSHA)-approved access shall be provided to the test location. [R307-165]

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II.B.1.e.4
NEW
PM
40 CFR 60, Appendix A, Method 5 or 5I or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three (3) runs with
each run at least 120 minutes in duration and each run collecting a sample of 60 dry standard
cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.3
NEW
Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2. [R307-165]

II.B.1.e.5
NEW
Carbon Monoxide (CO)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.6
NEW
Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.7
NEW
Sulfur Dioxide (SO2)
40 CFR 60, Method 6 or 6C of Appendix A-4 or other EPA-approved method as acceptable to
the Director. [R307-165]

II.B.1.e.8
NEW
Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]

II.B.1.e.9
NEW
Total Hydrocarbons (THC)
Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL]

II.B.1.e.10
NEW
Mercury (Hg)
Continuous Emission or integrated sorbent trap monitoring (See Condition II.B.3.a). [40 CFR
63 Subpart LLL]

II.B.1.e.11
NEW
HCl
Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other
EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]

II.B.1.e.12
NEW
Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]

II.B.1.e.13
NEW
Calculations
To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the
appropriate methods above shall be multiplied by the volumetric flow rate and any necessary
conversion factors determined by the Director, to give the results in the specified units of the
emission limitation. [R307-165]

II.B.1.e.14
NEW
Existing Source Operation
For an existing source/emission point, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous three years.
[R307-165]

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II.B.1.e.15
NEW
New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the maximum production rate listed in this AO. If the maximum AO
allowable production rate has not been achieved at the time of the test, the following
procedure shall be followed:

1) Testing shall be at no less than 90% of the production rate achieved to date.

2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This new
allowable maximum production rate shall remain in effect until successfully tested at a higher
rate.

3) The owner/operator shall request a higher production rate when necessary. Testing at no
less than 90% of the higher rate shall be conducted. A new maximum production rate (110%
of the new rate) will then be allowed if the test is successful. This process may be repeated
until the maximum AO production rate is achieved. [R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL.
[40 CFR 63 Subpart LLL]

II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times
of Dust Shuttle System operation to assist in the capture of Mercury emission. [R307-401-8]

II.B.1.h
NEW
Visible emissions from the following emission points shall not exceed the following values:

A. Limestone crushers - 15% opacity

B. Limestone screens - 10% opacity

C. Limestone conveyor transfer points - 10% opacity

D. All other crushers - 15% opacity

E. All other screens - 10% opacity

F. All other conveyor transfer points - 10% opacity

G. All stacking conveyors - 10% opacity

H. Bins and trap feeder - 10% opacity

I. All diesel engines - 20% opacity

J. All support equipment - 20% opacity

K. Coal storage and transfer - 20% opacity

L. All baghouses - 10% opacity
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M. Fugitive dust - 20% opacity

N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y,
R307-401-8]

II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer
point is not required to conduct Method 22 visible emissions monitoring under this paragraph.
The enclosures for these transfer points must be operated and maintained as total enclosures
on a continuing basis in accordance with the facility operations and maintenance plan.

If any partially enclosed or unenclosed conveying system transfer point is located in a
building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to
40 CFR 60, according to the following:

(i) The owner/operator must conduct a monthly ten-minute visible emissions test of each
affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The
performance test must be conducted while the affected source is in operation.

(ii) If no visible emissions are observed in six (6) consecutive monthly tests for any affected
source, the owner/operator may decrease the frequency of performance testing from monthly
to semi-annually for that affected source. If visible emissions are observed during any
semi-annual test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iii) If no visible emissions are observed during the semi-annual test for any affected source,
the owner/operator may decrease the frequency of performance testing from semi- annually to
annually for that affected source. If visible emissions are observed during any annual
performance test, the owner/operator must resume performance testing of that affected source
on a monthly basis and maintain that schedule until no visible emissions are observed in six
consecutive monthly tests.

(iv) If visible emissions are observed during any Method 22 performance test, of Appendix
A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations,
recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60.
The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour
of any observation of visible emissions.

(v) If visible emissions from a building are monitored, the requirements of paragraphs (i)
through (iv) of this Condition apply to the monitoring of the building, and the owner/operator
must also test visible emissions from each side, roof, and vent of the building for at least ten
minutes. [R307-401]

II.B.1.j
NEW
Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed
0.005 gr/dscf:

520.BF1
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520.BF2
520.BF3
520.BF4
521.BF2
521.BF1
524.BF1
524.BF2
524.BF4
524.BF3
525.BF1
525.BF2
525.BF3
511.HP2
NRL_UPR
NRL_LWR. [R307-401-8]

II.B.1.j.1
NEW
To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration
through at least three (3) annual tests that the PM limits are not being exceeded, the
owner/operator may request approval from the Director to conduct stack testing less
frequently than annually. [R307-401-8]

II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive
dusts as dry conditions warrant or as determined necessary by the Director to maintain opacity
limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment
shall be water sprayed and/or chemically treated to control fugitive dust. The application of
water or chemical treatment shall be used. Treatment shall be of sufficient frequency and
quantity to maintain the surface material in a damp/moist condition unless it is below freezing.
If chemical treatment is to be used, the plan must be approved by the Director. Records of
water and/or chemical treatment shall be kept for all periods when the plant is in operation.
The records shall include the following items: Instances of water and/or chemical application
to unpaved areas shall be recorded and maintained by the owner/operator. The ambient
temperature shall be recorded any time water should be applied but cannot due to freezing
conditions. [R307-401-8]

II.B.2.c
NEW
Water sprays or chemical dust suppression sprays shall be installed at the following points to
control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/ conveyor drops

The sprays shall operate whenever dry conditions warrant meeting the required opacity
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limitations or as determined necessary by the Director. Water sprays shall not be required
during periods of freezing temperatures. [R307-401-8]

II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation
of fugitive dusts as dry conditions warrant or as determined necessary by the Director.
[R307-401-8]

II.B.2.e
NEW
The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5
PM. [R307-401-8]

II.B.3 Continuous Emission Monitoring Requirements:
II.B.3.a
NEW
The owner/operator shall install, calibrate, maintain and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler.

A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the
missing data substitution procedures used by the UDAQ or the missing data substitution
procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate by the UDAQ.

B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period
including during each startup, shutdown, or malfunction.

C. The monitoring system shall comply with all applicable sections of R307-170, UAC; and
40 CFR 60, Appendix B.

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be
installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the
kiln/raw mill stack.

F. The owner/operator shall record the output of the system: including the quantity of NOx,
CO, O2 THC, Hg, HCl, and CO2 emissions at the kiln stack.

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under paragraph (d) 40 CFR 60.13, the owner/operator of an affected source shall
continuously operate all required continuous monitoring devices and shall meet minimum
frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]

II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker
cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except
during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments,
the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a
PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the
results of the performance test demonstrating compliance with the filterable PM limit and
using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust
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the SSOL developed in accordance with the results of the most recent PM performance test
demonstrating compliance with the PM emission limit. The owner/operator shall use the PM
CPMS to demonstrate continuous compliance with the SSOL in accordance with the
requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

II.B.4 Fuel Limitations:
II.B.4.a
NEW
The owner/operator shall use only the following fuels in the kiln and pre-calciner:

A. Coal

B. Diaper Derived Fuel (DDF)

C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel

H. Synthetic Fuel

I. Wood

J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.

If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b
NEW
Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the
Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the
results of suitable tests giving data similar to a Proximate and Ultimate analysis of the
proposed coal additive. [R307-401-8]

II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal
additive. Approval is not required to change from one previously-approved coal additive to
another previously-approved coal additive. [R307-401-8]

II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily
heat input of the kiln and precalciner. The owner/operator may increase the average quantity
of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon
approval by the Director in accordance with the approval process described in Condition
II.B.4.b. [R307-401-8]

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II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel burning or process
installation not covered by New Source Performance Standards for sulfur emissions or
covered elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross
Btu heat input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input
for any oil except used oil. The sulfur content shall comply with all applicable sections of
UAC R307-203. [R307-203, R307-401-8]

II.B.4.c.1
NEW
Certification of fuels shall be either by the owner/operator's own testing or test reports from
the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be
available onsite. Methods for determining sulfur content of coal and fuel oil shall be those
methods of the American Society for Testing and Materials, UAC R307-203-1 (4)

A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be
used.

B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be
used.

C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or
D3286-85 are to be used. [R307-203]

II.B.4.d
NEW
The concentration/parameters of contaminants in any used oil fuel shall not exceed the
following levels:

1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight
3) Cadmium 2 ppm by weight
4) Chromium. 10 ppm by weight
5) Lead 100 ppm by weight
6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight

A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received.
Certification shall be either by their own testing or test reports from the used oil fuel marketer.
Records of used oil fuel consumption and the test reports shall be kept for all periods when the
plant is in operation.

C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis.

D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be
tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260
before used oil fuel is transferred to the burn tank and burned. [R307-401-8]

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II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned
in the rotary kiln:

A. Combustion gas temperature at the rotary kiln exit - no less than 1500oF for more than
five minutes in any 60-minute period

B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes
in any 60-minute period. [R307-401-8]

II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the
Director. The calibration procedure and frequency shall be according to manufacturer's
specifications. Use of factory-calibrated thermocouples for temperature measurement is
approved. However, any other method of temperature measurement must be approved by the
Director prior to use. The monitoring equipment for both temperature and oxygen content
shall be located such that an inspector can at any time safely read the output. [R307-401-8]

II.B.5
NEW
Emergency Engine Requirements
II.B.5.a
NEW
The owner/operator shall only operate the emergency engines for testing and maintenance
purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency
operation. [R307-401-8]

II.B.5.b
NEW
The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in each emergency engine. [R307-401-8]

II.B.5.b.1
NEW
The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or
less. [R307-401-8]

II.B.5.b.2
NEW
To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. [R307-401-8]

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Page 39

PERMIT HISTORY

When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:

Supersedes DAQE-AN103030035-24 dated November 27, 2024
Is Derived From Source Submitted NOI dated November 30, 2022
Incorporates Additional Information Received dated April 26, 2023
Incorporates Additional Information Received dated September 26, 2023
Incorporates Additional Information Received dated July 23, 2024
Incorporates Additional Information Received dated October 25, 2024
Incorporates Additional Information Received dated November 25, 2024

REVIEWER COMMENTS

1. Comment regarding applicability of federal requirements:
New Source Performance Standards (NSPS)
NSPS requires new, modified, or reconstructed sources to control emissions to the level achievable
by the best demonstrated technology as specified in the applicable provisions. Following is a
discussion of potentially applicable subparts for the proposed changes or new emission sources at the
Leamington Plant.

40 CFR 60, Subpart A (General Provisions)
All affected facilities subject to a source-specific NSPS are subject to the general provisions of
NSPS, Subpart A unless specifically excluded by the source-specific NSPS. Subpart A requires
initial notification, performance testing, recordkeeping, and monitoring, provides reference methods,
and mandates general control device requirements for all other subparts.

40 CFR 60, Subpart F (Standards of Performance for Portland Cement Plants)
NSPS Subpart F, Standards of Performance for Portland Cement Plants, provides standards of
performance for affected facilities in Portland Cement Plants which have been constructed or
modified after August 17, 1971.

40 CFR 60.60(a) lists the following affected facilities in Portland Cement plants subject to Subpart
F: Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage,
clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and
unloading systems. The Leamington coal mill is an in-line coal mill and considered an integral part
of the Leamington kiln. In-line coal mills are not subject to NSPS Subpart Y. Therefore, the coal mill
is addressed under NSPS Subpart F as part of the kiln system. The coal silos and conveying system
are subject to NSPS Subpart Y.

Ash Grove's proposed changes to the kiln system must be evaluated as to whether they trigger new
NSPS Subpart F obligations based on whether the proposed project is either a modification or a
reconstruction, as those terms are defined in NSPS Subpart A.

Ash Grove's proposed changes to the kiln system do not meet the definition of a reconstruction, nor
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 40

do they meet the definition of a modification for NOx. However, the changes meet the definition of a
modification for PM and SO2. Therefore, Ash Grove will comply with all relevant emission
standards; testing requirements; monitoring, recordkeeping, and reporting obligations that apply to
the Leamington kiln system as an existing source under NSPS Subpart F. Under NSPS Subpart A
and F, the clinker cooler is considered a reconstructed unit. Thus new limits will apply to this unit.
[Last updated January 14, 2025]

2. Comment regarding applicability of federal requirements cont.:
NSPS Subpart Y - Standards of Performance for Coal Preparation and Processing Plants
This subpart provides standards of performance for affected facilities in coal preparation and
processing plants that process more than 200 tons of coal per day.

The Leamington plant's coal silo and coal conveying system are existing affected facilities under
NSPS Subpart Y. Ash Grove is proposing to reduce the existing PM emissions limit on baghouses
controlling affected facilities subject to match the limit in NSPS Subpart Y from 0.016 gr/dscf to
0.007 gr/dscfm for PM10 with the Leamington Plant Upgrade Project. Since there are no proposed
modifications or reconstruction to the coal silo and coal conveying system, nothing about the
proposed upgrade project affects the existing applicability of NSPS Subpart Y.

NSPS Subpart OOO - Standards of Performance for Nonmetallic Mineral Processing Plants
This subpart provides standards of performance for affected facilities located at fixed or portable
nonmetallic mineral processing plants that are constructed, modified, or reconstructed after August
31, 1983, with additional requirements applicable to sources constructed on or after April 22, 2008.

As the crushing and screening system is controlled by baghouses and an increase in PM10 actual
emissions on a lb/hr basis is not anticipated, the proposed project is not a modification under NSPS.
Ash Grove is proposing to reduce the existing PM emissions limit on baghouses controlling affected
facilities subject to NSPS Subpart OOO from 0.016 gr/dscf to 0.007 gr/dscfm for PM10 with the
Leamington Plant Upgrade Project.

Visual inspections of baghouses controlling emissions from affected sources are required per 40 CFR
60.674(c). The reporting and recordkeeping requirements outlined in 40 CFR 60.676(b)(1),
60.676(f), and 60.676(i-k) apply. Ash Grove will continue to comply the NSPS Subpart OOO
monitoring and recordkeeping requirements.

[Last updated January 14, 2025]

3. Comment regarding applicability of federal requirements cont.:
National Emission Standards for Hazardous Pollutants (NESHAPs)
NESHAPs, federal regulations found in 40 CFR 61 and 63, are emission standards for HAPs and are
applicable to major sources (i.e., sources with a source-wide PTE for HAP emissions equal to or
greater than 10 tpy of a single HAP or 25 tpy of total combined HAP) or area sources of HAPs, as
specified by each subpart. NESHAP apply to sources in specifically regulated industrial source
classifications (CAA Section 112(d)) or on a case-by-case basis (CAA Section 112(g)) for facilities
not regulated as a specific industrial source type. The Ash Grove Leamington Plant is a major source
of HAPs and thus is subject to certain NESHAP standards.

Subpart A - General Provisions
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 41

All affected sources are subject to the general provisions of Subpart A unless otherwise specified by
the source-specific NESHAP. Subpart A generally requires initial notification and performance
testing, recordkeeping, monitoring, provides reference methods, and mandates general control device
requirements for all other subparts as applicable.

Subpart LLL - Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry
This subpart establishes process/source specific emission limits for PM, VOC (expressed as total
hydrocarbon, i.e., THC), mercury (Hg), HCl, dioxins/furans (D/F), and visible emissions. In addition
to limiting HAP emissions such as Hg and D/F, Subpart LLL also limits emissions of other solid and
gaseous HAP compounds by limiting PM and THC emissions because portions of such emissions
are USEPA-listed HAPs. Subpart LLL requires compliance with applicable emissions limits on and
after the initial startup of cement production. To further reduce emissions, Subpart LLL also
establishes operational requirements for the use of cement kiln dust (CKD), fly ash, fuel and control
equipment. Subpart LLL also specifies process/source specific emissions testing, monitoring,
recordkeeping, reporting, and compliance demonstration requirements. The compliance requirements
for the site are detailed in Approval Order Condition II.B.1.b. Ash Grove will continue to comply
with the requirements of Subpart LLL to demonstrate compliance. This cement kiln will remain an
existing source with respect to the kiln emission standards in Subpart LLL as this project does not
trigger the definition of a new source in Subpart LLL. New source standards apply only to affected
sources that were constructed or reconstructed after May 6, 2009.
[Last updated December 20, 2024]

4. Comment regarding PSD applicability analysis:
Ash Grove is proposing to increase the throughput of limestone from the quarry to supply the New
Finish Mill to increase the amount of low-carbon cement from the Leamington Plant. Additionally,
along with upgrades to the calciner and preheater, the size of the current kiln ID fans will be
modified, and the clinker cooler will be reconstructed. These changes are anticipated to result in an
increase in clinker production. Emission calculations for this project have been completed assuming
an increase in clinker production capacity while utilizing current fuel types. This will result in an
increase in the throughput of fuel.

The Leamington Plant is considered an existing major source under PSD based on potential
emissions of PM10, PM2.5, NOx, CO, SO2, and CO2e. If a major source undergoes a physical or
operational change, the facility must determine whether the project will be considered a major
modification. Per 40 CFR 52.21(b)(2)(i), in order to be a major modification, the project must result
in a significant emissions increase, and a significant net emissions increase.

As defined at 40 CFR 52.21(b)(40): Significant emissions increase means, for a regulated NSR
pollutant, an increase in emissions that is significant for that pollutant. Significant is further defined
to mean, in reference to a net emissions increase or the potential of a source to emit any of the
following pollutants, a rate of emissions that would equal or exceed the values outlined in 40 CFR
52.21(b)(23). If the increase in emissions from the project are not significant, a major modification
has not occurred.

Per 40 CFR 52.21(b)(3), the net emissions increase applicability test includes evaluating the
pollutant increases and decreases associated with the proposed project, as well as any projects
occurring contemporaneously. If both a significant emissions increase and a significant net emissions
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 42

increase results, then a major modification has occurred. This evaluation is conducted on a
pollutant-by-pollutant basis.

Determination of project related emissions increases

For all pollutants, the project emissions increase was calculated as the difference between the
projected actual emissions (PAE) after the proposed project and the actual emissions prior to the
project (baseline actual emissions or BAE).

Projected actual emissions are defined in 40 CFR 52.21(b)(41)(i) as:
". . . projected actual emissions means the maximum annual rate, in tons per year, at which an
existing emissions unit is projected to emit a regulated NSR pollutant in any one of the 5 years
(12-month period) following the date the unit resumes regular operation after the project, or in any
one of the 10 years following that date, if the project involves increasing the emissions unit's design
capacity or its potential to emit of that regulated NSR pollutant and full utilization of the unit would
result in a significant emissions increase or a significant net emissions increase at the major
stationary source." [Last updated January 14, 2025]

5. Comment regarding PSD applicability analysis cont.:
Ash Grove estimates that the projected actual production capacity following the project will be
1,155,000 tons of clinker per year and 1,341,266 tons of limestone per year. These capacities were
used to calculate projected actual emissions from the project using representative emission factors.
Additionally, to estimate emissions from material transfer baghouses, the actual flow rates and actual
projected hours were used as a basis for projected actual emissions.

Project Emission Calculations

Project emission increases from the kiln and coal mill systems are calculated for all criteria
pollutants based on emission factors that are derived from stack testing, CEMS data, or emission
factors (i.e., VOCs and Lead), and the associated projected incremental clinker increase.

NOx emissions are anticipated to remain unchanged as upgrades to the SNCR system will maintain
hourly capacity to emit and annual potential to emit at current levels. The kiln's NOx emissions rate
will not change as a result of the physical modifications proposed by the project.

Project emissions of CO that are monitored by a CEMS were determined from a lb/ton emission
factor and multiplied by the incremental increase in clinker production. The emission factor was
selected based on the average of the 24-month consecutive month emissions for 2020 and 2021. The
CO emissions will increase.

The SO2 emissions were calculated from a site specific lb/ton emission factor and multiplied by the
incremental increase in clinker production. The emission factors are based on stack testing
conducted at the plant. The SO2 emissions will increase.

VOC and lead emissions were calculated based on an AP-42 emissions factor and multiplied by the
incremental increase in clinker production. VOC emissions will increase.

The emissions determined from CEMS data, stack test data and AP-42 emission factors for the kiln
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 43

can be found in the original NOI and subsequent addendums submitted to UDAQ.

As outlined in 40 CFR § 52.21(a)(2), to determine if there is a potential increase in emissions from
the proposed project, each increase of emissions from both existing and new sources shall be
summed together and compared to the PSD permitting thresholds. The increase of emissions is the
"positive" difference between the projected actual emissions and baseline actual emissions (projected
minus baseline).

New Emissions Sources

The actual to projected actuals calculation is not available to new emission units. For new emission
units, the baseline actual emissions shall equal zero (40 CFR § 52.21(b)(48)(iii)) and projected
emissions are based on the new sources' potentials to emit. (40 CFR § 52.21(a)(2)(iv)(f)).

The new equipment proposed includes the New Finish Mill, a new rail and truck loading/loadout,
one (1) new clinker reclaim loading hopper with a dust collector and one (1) existing clinker reclaim
hopper with a dust collector, a new Clinker Cooler to replace the existing one, and a new kiln feed
alleviator baghouse. Emissions calculations include baghouse PM10 and PM2.5 emissions, finish mill
heater combustion emissions, and both point and fugitive PM10 and PM2.5 emissions:

The baghouse emissions and the fugitive emissions for new sources were calculated using their
prospective potential to emit using 8,760 hours and design flow rates for the equipment;

The finish mill heater was calculated based on its maximum firing capacity and flow rates; and

The fugitive emissions were calculated based on the projected annual throughput of the New Finish
Mill, the rail loadout, and clinker production. [Last updated January 14, 2025]

6. Comment regarding PSD applicability analysis cont.:
Existing Emission Sources

For the existing sources, the projected actual emissions are the maximum annual rates in tons per
year projected to occur during the next five (5) to ten (10) years if the existing sources' design
capacities increase. Ash Grove Leamington projected the actual emissions for the next five (5) years
based on the new kiln system producing an annual average of 3,250 tons of clinker per day.

Baseline actual emissions (BAE) are defined at 40 CFR 52.21(b)(48)(ii) as:

". . . baseline actual emissions means the average rate, in tons per year, at which the emissions unit
actually emitted the pollutant during any consecutive 24-month period selected by the owner or
operator within the 10-year period immediately preceding either the date the owner or operator
begins actual construction of the project, or the date a complete permit application is received by the
Administrator."

Ash Grove has selected to use the years 2020 and 2021 for each pollutant as the representative
baseline years.

In its NOI, Ash Grove calculated the emission increase from the project as being divided into two
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 44

phases. Phased construction projects are discussed in two sections of the federal PSD regulations -
40 CFR 52.21(j)(4) and 40 CFr 52.21(r)(2). UDAQ is not processing this project as a phased
construction project, nor did Ash Grove request such a determination. Therefore, Ash Grove
provided a summary table outlining the final change in emissions from this project:

Projected Actual Increase Compared to PSD threshold (tons per year)
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2e
BAE 76.64 39.64 1,187 6.87 3,315 55.47 641,385
PAE 203.15 113.47 1,226 45.87 3,414 72.07 1,067,984

Change in Emissions 126.51 73.83 39.00 39.00 99.00 16.59 426,598

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes

If the emissions increase is greater than the PSD significance threshold for a particular pollutant, Ash
Grove has the option of conducting a PSD review or continuing through the rest of the steps to
determine if it can "net" out of a PSD review. If the project increase is less than the PSD significant
threshold for a particular pollutant, Ash Grove Leamington is not subject to a PSD review for that
pollutant.

The change in emissions from the project exceeds the significant emission threshold for three
pollutants: PM10, PM2.5 and CO2e. Ash Grove elected to attempt to net out of a PSD major
modification for the remainder of the criteria pollutants.

Netting

To determine what increases and decreases may be considered in the netting analysis, the
contemporaneous period must be defined for the project. 40 CFR § 52.21(b)(3)(ii) notes the
contemporaneous period starts on the date five (5) years before construction of the Leamington Plant
Upgrade Project and ends on the date the upgrade begins operation. Only PM10, PM2.5, CO2e are in
excess of SERs and therefore considered in the netting analysis.

Ash Grove estimated that the commencement of construction will be in December 2024. Therefore,
the contemporaneous period for this project is December 2019 through a projected date the project
upgrade begins operation. [Last updated January 21, 2025]

7. Comment regarding PSD applicability analysis cont.:
Contemporaneous Decreases

Ash Grove replaced an existing kiln emergency drive engine with a USEPA Tier 4 diesel engine in
2022. Concurrently, Ash Grove requested an increase in the capacity of 1L Cement. Additionally,
Ash Grove submitted a minor modification NOI air permit application on June 12, 2023, which
proposes replacing the shipping generator during the contemporaneous period. The kiln emergency
drive engine and shipping generator are both higher EPA tier ratings therefore result in decreases for
PM10 and PM2.5. These changes were approved in AO DAQE-AN103030033-24 issued March 21,
2024.

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 45

Contemporaneous Increases

As stated above, the existing kiln emergency drive engine and shipping generator were permitted and
replaced in 2024. This resulted in an increase in emissions of CO2e.

The Leamington Plant permitted an increase in throughput of its Third Bay Truck Product Loadout
in an effort to improve truck traffic at the loadout. The modification to add these dust collectors to
the loadout was included in DAQE-AN103030029-19. The baghouses are three (3) levels up in the
silos' enclosed space (approximately 40 feet). Both dust collectors vent directly into the interior of
the silo structure and are not vented into the atmosphere. Ash Grove requests to remove these
baghouses from its existing permitted emissions inventory. Therefore, these emissions have been
documented in the netting analysis as zero emissions.

Also included in DAQE-AN103030033-24 were two new natural gas-fired emergency generators
and increases in stockpiles, material handling and road emissions.

Could Have Been Accommodated Emissions

In calculating project emissions increase, USEPA allows the exclusion of existing
production/emissions rates that could have been accommodated during the baseline period. These
"could have been accommodated" emissions are excluded based on 40 CFR 52.21(b)(41)(ii)(c) as
follows:

". . . Shall exclude, in calculating any increase in emissions that results from the particular project,
that portion of the unit's emissions following the project that an existing unit could have
accommodated during the consecutive 24-month period used to establish the baseline actual
emissions under paragraph (b)(48) of this section and that are also unrelated to the particular project,
including any increased utilization due to product demand growth;"

Although a demand growth exclusion is available to the Ash Grove Leamington Plant for the
exclusion of existing production and emissions rates that could have been accommodated during the
baseline period, it has elected not to use this exclusion at this time. Therefore, calculation of the
"could have been" accommodated emissions have not been included in this application's
applicability analysis.

The increase from the project is added to the contemporaneous decreases and contemporaneous
increases. The resulting calculation is then compared to the PSD significance threshold to determine
if a significant net emissions increase has occurred. [Last updated January 14, 2025]

8. Comment regarding PSD applicability analysis cont.:
Emission Type PM10 PM2.5 NOx SO2 CO VOC CO2 e
Contemporaneous Inc. 1.61 0.45 0.41 0 0.27 0.07 51.74

Contemporaneous Dec. -1.54 -3.97 -0.48 -0.02 -0.27 -0.09 0

Change in Emissions 125.02 69.21 38.93 38.98 99.00 16.58 426,650

SERs 15 10 40 40 100 40 75,000
Threshold Exceeded? Yes Yes No No No No Yes
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January 21, 2025
Page 46

The results of the netting analysis conclude that both a significant emissions increase and a
significant net emissions increase in both particulates (PM10 and PM2.5) and CO2e will occur from
this project. Thus, the project must be reviewed as a PSD major modification. [Last updated January
14, 2025]

9. Comment regarding emission calculations:
This engineering review includes updated potential emission totals for both criteria and HAP
emissions. The potential-to-emit (PTE) values were calculated using updated values for clinker
produced and raw material inputs. BACT emission factors and limitations were used where
appropriate. Certain emission totals (NOx, SO2 and CO) were set based on avoiding a significant
increase in emissions. Specifically, the projected actual increase was set at just under the baseline
actual emissions + the significance level. As these emissions are monitored by CEM, UDAQ agrees
with this approach. Please see the netting analysis for further details on calculation of projected
actual increase. The NOx hourly emission rate will remain unchanged following the proposed
Leamington Plant Upgrade Project.

CO2e emissions were calculated using the GHG emission factor calculated from 40 CFR Part 98
Subpart C Tables C-1 and C-2 using the Global Warming Potentials provided in Subpart A Table
A-1.

To calculate the PTE tons per year, the maximum hours (i.e., 8760) per year and the source's
emissions rates were multiplied with the throughputs. The potential throughputs have been updated
at UDAQ's request so that PAE is equal to PTE and represents the equipment's maximum design
potential.

Additional emission calculations based on source testing and monitoring, and EPA's compilation of
air emission factors AP-42. [Last updated January 14, 2025]

10. Comment regarding requirements for PSD review:
In addition to the permitting requirements of R307-401-5 through R307-401-8, there are additional
requirements under PSD that must be addressed:

1. Calculation of ambient air increments (40 CFR 52.12(c)), ambient air ceilings ((40 CFR 52.12(d)),
source impact analysis (40 CFR 52.12(k)), air quality models (40 CFR 52.12(l)) - these items are
addressed in the modeling memo DAQE-MN103030032-24.

2. Stack heights (40 CFR 52.12(h)) - Ash Grove's stack heights have been reviewed with respect to
good engineering practice and operate in a vertical unrestricted manner.

3. Control technology review (40 CFR 52.12(j)) - this is addressed in the BACT analysis section of
this review document.

4. Air quality analysis: preapplication analysis (40 CFR 52.12(m)) - this is covered in the PSD
applicability and netting analysis sections of this review document, ambient monitoring and
background data collection is also included in the modeling memo DAQE-MN103030032-24.

5. Air quality analysis: post-construction monitoring (40 CFR 52.12(m)) - the testing of the 0.005
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 47

grain loading limit included in II.B.1.j.1 represents the required post-construction monitoring.
6. Source information (40 CFR 52.12(n)) - this is addressed under the requirements of R307-401-5
and was submitted by Ash Grove as part of the NOI package.

7. Additional impact analysis (40 CFR 52.12(o)) - these requirements cover soils, vegetation, growth
and visibility concerns. They are discussed in the modeling memo DAQE-MN103030032-24.

8. Federal land manager review (40 CFR 52.12(p)) - UDAQ provided initial notification to all
federal land managers upon receipt of the original NOI package. The draft permit and engineering
review will also be provided to the federal land managers 60-days prior to initiation of public
comment for their further review.

9. Public participation (40 CFR 52.12(q)) - this project will have a 30-day public comment period.

10. Source obligation (40 CFR 52.12(r)) - this requirement discusses source compliance with other
parts of the CAA, which is addressed within UDAQ's permitting rules in R307.
[Last updated January 14, 2025]

11. Comment regarding changes in equipment list:
The equipment list is being updated for clarity as well as adding new pieces of equipment. The
following changes are taking place:

The naming scheme is being updated to remove the numerical code from the unit designation. This
code generally referred to the associated control device and not to the emitting unit itself. This can
cause confusion especially when the same code was applied to multiple pieces of equipment.
Instead, the control devices (typically baghouse dust collectors) will be identified in the description
along with the appropriate numerical code.

Specific changes are as follows:

1. The kiln description has been updated

2. Clinker Cooler description has been updated to include a larger pulse jet baghouse.

3. The clinker storage silos, east and west clinker belts, clinker belt transfer and clinker tunnel have
been consolidated to avoid confusion

4. The north and south cement loadout exhausts now vent internally into the cement storage silos

5. The dust shuttle system has been consolidated into one line item, most identifiers removed from
subsystem descriptions as only two baghouses serve as exhaust points.

6. A new finish mill with heater has been added. Included in the description are the thirteen total
baghouses for dust control (1 main stack, 2 transfer points, 10 nuisance dust filters)

7. A new clinker reclaim hopper has been added. Both reclaim hoppers are controlled by baghouses
with updated identifiers

8. A new rail and truck loading/unloading system with two baghouses has been added.
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 48

[Last updated December 20, 2024]

12. Comment regarding changes in conditions:
As a result of this project, several conditions will be added or changed. This includes one new
general condition (I.8). Changes to the equipment list (section II.A) will be addressed in a separate
reviewer comment:

I.8 - Adding this general condition to cover the requirements of R307-401-18 Eighteen Month
Review. The status of construction/installation of the new equipment shall be reviewed after
18-months.

II.B.1.a - Clinker production increases to 1,155,000 tpy
Use of limestone bypass material increases to 215,260 tpy

II.B.1.b - The NOx limit on the kiln decreases to 1,223 tpy, CO emissions from the kiln decrease to
3,395 tpy,
Adding a new CO2e limit of 0.92 tons CO2e/ton of clinker produced
PM limit on the clinker cooler decreased to 0.02 lb PM (filterable)/ton of clinker
Rule reference updated to include 40 CFR 60 Subpart F, and R307-401-8

II.B.1.e - Initial testing on the clinker cooler is now required within 180 days of startup of the unit.
Monitoring of CO2 from the kiln will be by CEM.
Formatting changes on paragraph designated ++, improve clarity, include reference to CO2
monitoring, define CPMS

II.B.1.e.4 - Update to address general PM monitoring and reference R307-401-8

II.B.1.e.14 - New condition to address new or reconstructed emission units monitoring requirements,
applicable to the clinker cooler and new finish mill.

II.B.1.h - Adding references to Subpart OOO units (limestone processing) with updated opacity
limits.
Adding 20% opacity limit on coal transfer and storage
Adding property boundary opacity limit of 20%
Updating rule reference to include Subpart OOO

II.B.1.j - New condition to address outlet grain loading limits on new baghouses, One identical limit,
15 total new baghouses.

II.B.1.j.1 - Monitoring on new baghouses as per II.B.1.e.4, added an allowance to test less frequently
than annually with three successful tests.

II.B.3.a - Updating formatting to add clarity and include reference to CO2 CEM

II.B.5 - New conditions on emergency engines, diesel fuel sulfur limits, hour of operation
restrictions, non resettable hour meter

[Last updated December 20, 2024]
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 49

ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
January 21, 2025
Page 51

TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds

Engineer Review N103030032: Ash Grove Cement Company- Leamington Cement Plant
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Page 52

DAQE-MN103030032-24

M E M O R A N D U M

TO: John Jenks, NSR Engineer

FROM: Jason Krebs, Air Quality Modeler
Dave Prey, Air Quality Modeler

DATE: December 12, 2024

SUBJECT: Modeling Analysis Review for the Ash Grove Cement Company – Leamington Plant,
located in Millard County, Utah
___________________________________________________________________________________
This is a Major Modification to a Major Prevention of Significant Deterioration (PSD) Source.

I. OBJECTIVE
Ash Grove Cement Company (Applicant) has submitted a Notice of Intent (NOI) air permit
application for a project referred to as the Leamington Upgrade Project (LUP). The proposed
upgrade project includes the construction and installation of new pollution control equipment, new
emission sources, and modifications to existing emission sources. Emission increases associated
with the LUP constitute a major modification to a Prevention of Significant Deterioration (PSD)
source subject to PSD permitting regulations. PSD regulations require the Applicant to include and
air quality impact analysis (AQIA) of the proposed projects impact on the EPA national ambient air
quality standards (NAAQS) and air quality related values (AQRV) as part of a complete NOI.

This report prepared by the New Source Review (NSR) modeling staff contains a review of the
Applicant’s Air Quality Impact Analysis (AQIA) including the methodology, data sources,
assumptions, and modeling results for comparison with State and Federal air quality standards. The
AQIA was reviewed and referenced in this report include the:
● Notice of Intent – Ash Grove Cement Leamington Plant PSD Notice of Intent Air Permit
Application, dated November 30, 2022.

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

0 0
Jason Krebs

DP
DAQE-MN103030032-24
Page 2

II. APPLICABLE RULES AND ANALYSES

A Utah Air Quality Rules

The UDAQ has determined that the Applicant’s NOI is subject to the following rules for conducting an
AQIA:

R307-401 Permits: New and Modified Sources
R307-405 Permits: Major Sources Located in Attainment or Unclassified Area (PSD)
R307-406-2 Visibility – Source Review
R307-410-3 Use of Dispersion Models
R307-410-4 Modeling of Criteria Pollutant Impacts in Attainment Areas

B. Applicability

The proposed increases in emissions of PM10 and PM2.5 exceed the emission thresholds outlined in R307-
406-5 and R307-410-4. Therefore, an AQIA consistent with the requirements of R307-405-6, R307-406-
2, and R307-410-3 was submitted as part of the Applicant’s NOI. R307-410-3 establishes the U. S.
Environmental Protection Agency (US EPA) – Guideline on Air Quality Models as a formal basis for
defining the scope of the analysis, as well as the model’s construction. The results of the AQIA are
required to demonstrate the proposed project’s impact on state and federal air quality standards,
acceptable levels of impact, and action triggering thresholds referenced or listed in R307-401-6(2), R307-
401-6(3), R307-403-3(1), R307-403-5(1)(a), R307-405-4(1), R307-405-6. Annual emissions for criteria
pollutants requiring an AQIA are listed in Table 1.

Table 1: Ash Grove Leamington Proposed Net Emissions Increase

Criteria
Pollutants
Net Emission
Increase (TPY)
AQIA Trigger
Level (TPY) AQIA Required?
PM10 126.6 15 Yes
PM2.5 70.3 10 Yes

C. Required Analyses

R307-405 requires the Applicant to perform a pre-construction modeling analysis for all pollutants
emitted in a significant quantity. The purpose of the analysis is to determine if the extent of the source’s
impact is significant enough to warrant an on-site measurement of the ambient background concentration
levels. This data is included in the NAAQS analysis to represent the quality of the air prior to the
construction of the proposed project. The Applicant included a pre-construction modeling analysis for
PM10 and PM2.5 as part of the NOI. The pre-construction modeling analysis was also used to determine if
the proposed emissions would result in a significant impact to the environment, thereby triggering the
requirement for a cumulative analysis of the proposed project and other nearby existing sources.

R307-401-8 requires the Division to determine that the proposed project will comply with the NAAQS
prior to the issuance of an Approval Order (AO). R307-405(7) requires the Applicant to perform a
DAQE-MN103030032-24
Page 3
NAAQS analysis for all pollutants emitted in a significant quantity. The analysis is to include all
emissions at the proposed site under normal operating conditions using maximum anticipated short-term
release and annual release rates. Consistent with UDAQ policy, a cumulative analysis to include the
ambient background concentration and any contribution from other nearby sources is not required if the
proposed project’s impact does not exceed the PSD Class II Significant Impact Level (SIL).

R307-401-8 also requires the Division to determine that the proposed project will comply with PSD
increments prior to the issuance of an AO. Under R307-405(6), the Applicant is required to perform a
PSD Class I and II increment consumption analysis for all pollutants emitted in significant quantities.
The purpose of this analysis is to quantify any degradation in air quality since the major source baseline
date. The analysis is to include all increment consuming emissions at the proposed site under normal
operating conditions using maximum anticipated short-term and annual release rates. A cumulative
analysis to include contributions associated with growth and other increment consuming sources is not
required if the proposed project’s impact does not exceed the PSD Class I or II SIL.

R307-410-5 requires the Applicant to perform a HAPs analysis for any pollutant emitted above a
pollutant specific emission threshold value. This analysis is to include all emissions of the pollutants
resulting from the proposed modification under normal operating conditions using maximum anticipated
one-hour release rates. The Applicant did not trigger modeling for HAPs.

R307-406-2 requires the Applicant to perform a plume blight analysis. A plume blight analysis is required
to determine if plumes emanating from the proposed project would be visible inside any Class I area
within 50 kilometers of the source. The plume blight analysis is to include all emissions of NO2, SO4, and
PM10.

Under R307-405-16, an AQRV analysis is performed which evaluates regional haze and acid deposition
impacts at each of the Class I areas within 300 kilometers of the source. A regional haze analysis is
required to determine if the plumes would reduce the visual range of an observer inside the Class I area.
The regional haze analysis is to include all emissions of SO2, NOX and PM10. The deposition analysis
examines impacts from sulfur and nitrogen compounds at the Class I areas, and is based on all emissions
of SO2 and NOX. The Federal Land Managers use the Q/D approach to determine whether a PSD project
should provide detailed AQRV impact analyses, where: Q/D= [ H2SO4 + SO2 + NOx + PM10 emissions
(tpy)]/ distance (km). If Q/D is less than 10, no AQRV analysis is required.

R307-405 requires the Applicant to perform a soils and vegetation analysis. The analysis should quantify
the effects of pollutants on soils and vegetation near the highest impact location and in areas where
sensitive plant species may be impacted.

III. ON-SITE PRE-CONSTRUCTION MONITORING

A. Meteorological Data

Consistent with the US EPA - Meteorological Monitoring Guidance for Regulatory Modeling
Applications, one year of on-site data was collected using a 50-meter tower during the period October 1,
2021 through September 30, 2022. Parameters collected on-site included wind speed and direction,
temperature, delta-T, and solar radiation.

DAQE-MN103030032-24
Page 4

B. Ambient Pollutant Data

A preliminary analysis was conducted to determine the necessity for pre-construction ambient pollutant
monitoring. The results indicate that predicted concentrations of PM10 and PM2.5 exceed the monitoring
trigger level listing in the rule. A continuous PM10/PM2.5 monitor with filter based samplers was
installed near the northern edge of the Applicants property boundary, and collected particulate matter
from October 1, 2021 through September 30, 2022.

IV. MODEL SELECTION

The EPA-AERMOD dispersion modeling system is the preferred model specified in the US EPA –
Guideline on Air Quality Models to predict air pollutant concentrations in the near field (within 50
kilometers of the source). The US EPA - CALPUFF - Version 5.8 model is the preferred model to predict
concentrations in the far field (long range transport conditions beyond 50 kilometers from the source).

V. MODELING INPUTS AND ASSUMPTIONS

A. Technical Options

The regulatory default options were selected in AERMOD by the Applicant to quantify all concentrations.

B. Urban or Rural Area Designation

A review of the appropriate 7.5-minute quadrangles determined that the area should be classified as
“rural” for air modeling purposes.

C. Topography/Terrain

The Plant is at an elevation of 4,950 feet with nearby terrain features that have an effect on concentration
predictions.

a. Zone: 12
b. Location: UTM (NAD83): 397000 meters East, 4379850 meters North

D. Ambient Air

It was determined that the Plant boundary used in the AQIA meets the State’s definition of an ambient air
boundary.

E. Receptor and Terrain Elevations

The modeling domain has simple and complex terrain features in the near field. Therefore, receptor
points representing actual terrain elevations from the area were used in the analysis.

The far-field modeling domain consisted of a rectangular region covering all Class I areas within Utah,
and extending 50 kilometers beyond this area so that the model can account for re-circulation of the
plume.

DAQE-MN103030032-24
Page 5

F. Emission Rates and Release Parameters

The emission estimates and source parameters used in AERMOD for all proposed emission sources at the
site are presented in the NOI.

Speciated emission rates and source parameters used in the CALPUFF modeling are presented in Table 2.

Table 2: CALPUFF Emission Rates

Source
LCC Coordinates Modeled Emission Rates
Easting Northing SO2 SO4 NOX HNO3 NO3 SOA PMC SOIL EC
(m) (m) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr) (lb/hr)
317.BF3 -1289410 -3738 52.81 5.03 307.58 0.00 0.00 5.03 2.60 2.90 0.11
419.BF1 -1289314 -3631 0.00 0.00 0.00 0.00 0.00 0.55 1.51 1.61 0.06
41B.BF2 -1289389 -3663 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.68 0.00
N1_FM2 -1289526 -3414 0.00 0.00 0.00 0.00 0.00 0.00 1.65 3.95 0.00
414.BF1N -1289407 -3683 0.00 0.00 0.00 0.00 0.00 0.00 0.10 0.25 0.00
2FM_HTR -1289528 -3415 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.08 0.00
514.BF1 -1289451 -3675 0.00 0.00 0.00 0.00 0.00 0.00 0.29 0.70 0.00
COMBO -1289424 -3668 0.00 0.00 0.00 0.00 0.00 0.00 1.37 5.72 0.00
FM2_CMB -1289454 -3439 0.00 0.00 0.00 0.00 0.00 0.00 0.50 1.21 0.00

Total Lb/hr 52.81 5.03 307.58 0.00 0.00 5.58 8.32 17.10 0.17
Hrs/Yr 8760 8760 8760 8760 8760 8760 8760 8760 8760
Ton/yr 231.3 22.0 1347.2 0.0 0.0 24.4 36.4 74.9 0.8

Source Type
Source Parameters
Elev, Ht Temp Flow Dia
(ft) (m) (ft) (K) (m/s) (m)
317.BF3 POINT 4902.8 41.2 135.0 488 10.10 3.35
419.BF1 POINT 4891.2 18.3 60.0 388 6.36 2.90
41B.BF2 POINT 4895.2 68.6 224.9 294 17.83 0.74
N1_FM2 POINT 4832.0 49.7 163.0 363 40.08 1.40
414.BF1N POINT 4896.1 76.8 251.9 353 9.91 0.70
2FM_HTR POINT 4832.0 49.7 163.0 363 40.08 1.40
514.BF1 POINT 4889.5 39.6 130.0 294 11.86 0.91
COMBO POINT 4904.2 13.3 43.7 276 9.76 0.32
DAQE-MN103030032-24
Page 6
FM2_CMB POINT 4832.0 30.6 100.3 294 11.40 0.37

G. Building Downwash

The Applicant used the US EPA Building Profile Input Program (BPIP) to determine Good Engineering
Practice (GEP) stack heights and cross-sectional building dimensions for input into the model.

H. Ambient Background Concentrations

Millard County is in attainment for all criteria pollutants. The NAAQS analyses for PM2.5 and PM10 used
monitoring data collected on site during the pre-construction monitoring analysis. The background values
used in the NAAQS analysis are presented in Table 3.

Table 3: Background Concentrations

Pollutant Averaging
Period
Background
Concentration
(μg/m3)
PM10 24-hour 65.4
PM2.5 24-hour 10.2
Annual 4.2

I. Meteorological Data Processing

For the AERMOD model, on-site horizontal and vertical wind speed, direction, solar radiation and,
temperature data was combined with National Weather Service (NWS) upper air data collected at the Salt
Lake City International Airport (SLCIA) for the same period using the US EPA AERMET processing
system.

Meteorological data used for the CALPUFF modeling analysis consisted of 3 years (2018-2020) of data
developed by the Forest Service. The grid was 708 km (east-west) by 492 km (north-south) with a
resolution of 12 kilometers.

VI. RESULTS AND CONCLUSIONS

The Applicant performed a series of analyses to estimate the impact from the proposed project. Modeling
results and conclusions from the review of the analyses are outlined in detail below.

A. Pre-Construction Monitoring and Significant Impact Modeling

The Applicant performed a preliminary criteria pollutant analysis of the proposed modification. This
analysis indicated that increases in concentration levels of PM2.5 and PM10 were greater than the Class II
SIL, and therefore, a cumulative analysis for these pollutants was required.

DAQE-MN103030032-24
Page 7

B. NAAQS Analysis

The Applicant performed a modeling analysis to determine if the combined impact from the proposed
source, other industrial sources operating in the area, and ambient background would comply with the
NAAQS. The NAAQS analysis was reviewed by the Division and determined to be consistent with the
requirements of R307-410-3. Table 4 provides a comparison of the Applicant’s predicted air quality
concentrations and the NAAQS.

Table 4: Model Predicted NAAQS Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Background Nearby
Sources*
Total NAAQS Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) NAAQS
PM10 24-hour 28.3 5 65.4 0 93.7 150 62.5%
PM2.5 24-hour 9.6 1.2 10.2 0 19.8 35 56.6%
Annual 4.4 0.3 4.2 0 8.6 9 95.6%
* Note: Only included other sources and background if source impact was above Class II SIL

C. PSD Class II Increments

The Applicant performed an analysis to determine if the impact from the proposed source would comply
with PSD Class II increments. The analysis was reviewed by the Division and determined to be
consistent with the requirements of R307-410-3. Table 5 provides a comparison of the predicted
concentrations and the PSD Class II increment.

Table 5: Model Predicted PSD Class II Increment Concentrations

Air
Pollutant
Period Prediction Class II
Significant
Impact
Level
Nearby
Sources*
Total Increment Percent
(μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
PM10 Annual 8.1 1 0 8.1 25 32.4%
24-hour 28.3 5 0 28.3 30 94.3%
PM2.5 24-hour 6.1 1.2 0 6.1 9 67.8%
Annual 2.4 0.3 0 2.4 4 60.0%

D. Hazardous Air Pollutants

DAQE-MN103030032-24
Page 8
The Applicant performed an analysis to determine if HAP modeling is required. The analysis was
reviewed by the Division and determined to be consistent with the requirements of R307-410-3. The
analysis indicated that HAP modeling was not triggered by this modification, and therefore no HAP
modeling was performed.

E. PSD Class I Increment Consumption Analysis

The Applicant performed a CALPUFF analysis to determine if the impact from the proposed source along
with other increment consuming sources would comply with federal PSD Class I increments. The
analysis was reviewed by the Division and determined to be consistent with the requirements of R307-
410-3. The results for all Class I areas within 300 kilometers are provided in Table 6.

Table 6: Model Predicted PSD Class I Increment Concentrations

Air Period Prediction
Class I
Significant
Impact
Level
Other
Sources* Total Increment Percent
Pollutant (μg/m3) (μg/m3) (μg/m3) (μg/m3) (μg/m3) PSD
Capitol Reef
NO2 Annual 0.0018 0.1 2.5
SO2
3-Hour 0.0494 1 25
24-
Hour 0.0150 0.2 5
Annual 0.0008 0.1 2
PM2.5
24-
Hour 0.0430 0.27 2
Annual 0.0021 0.05 1
PM10
24-
Hour 0.0444 0.3 8
Annual 0.0021 0.2 4
Arches
NO2 Annual 0.0008 0.1 2.5
SO2
3-Hour 0.0408 1 25
24-
Hour 0.0102 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0522 0.27 2
Annual 0.0018 0.05 1
DAQE-MN103030032-24
Page 9
PM10
24-
Hour 0.0531 0.3 8
Annual 0.0019 0.2 4
Canyonlands
NO2 Annual 0.0010 0.1 2.5
SO2
3-Hour 0.0354 1 25
24-
Hour 0.0100 0.2 5
Annual 0.0006 0.1 2
PM2.5
24-
Hour 0.0577 0.27 2
Annual 0.0019 0.05 1
PM10
24-
Hour 0.0591 0.3 8
Annual 0.0020 0.2 4
Bryce
NO2 Annual 0.0006 0.1 2.5
SO2
3-Hour 0.0369 1 25
24-
Hour 0.0082 0.2 5
Annual 0.0003 0.1 2
PM2.5
24-
Hour 0.0189 0.27 2
Annual 0.0010 0.05 1
PM10
24-
Hour 0.0194 0.3 8
Annual 0.0010 0.2 4
Zion
NO2 Annual 0.0011 0.1 2.5
SO2
3-Hour 0.0293 1 25
24-
Hour 0.0105 0.2 5
Annual 0.0005 0.1 2
PM2.5
24-
Hour 0.0266 0.27 2
Annual 0.0011 0.05 1
PM10 24-
Hour 0.0271 0.3 8
DAQE-MN103030032-24
Page 10
Annual 0.0012 0.2 4
* Note: Only included other increment consuming sources if source impact was above Class I SIL

Since the proposed project’s model predicted impacts at the Class I areas were less than the PSD Class I
significance levels, a cumulative analysis was not warranted.

DAQE-MN103030032-24
Page 11
F. Visibility – Plume Blight
Since the Class I areas are greater than 50 kilometers from the source, a plume blight analysis using
VISCREEN was not required.

G. Visibility – Regional Haze

The results of the Q/D analysis for the emissions increase was less than 10 but the FLMs wanted the
entire source included in the Q term. The results of including the total emissions resulted in a Q/D >10,
so an AQRV analysis was performed for visibility and acid deposition. The results shown in Table 7
indicate that the impacts are below the 0.5 Deciview (DV) threshold established by the National Park
Service, indicating that no further analysis is required.

Table 7: CALPUFF Visibility Results

Class I Area Year Maximum
Delta DV
98th
Percentile
change in
DV
#
Days
#
Days Threshold
(DV)
Below
Threshold
> 1 > 0.5
2018 0.248 0.06 0 0 0.5 Yes
Arches 2019 0.291 0.054 0 0 0.5 Yes
2020 0.216 0.106 0 0 0.5 Yes
2018 0.223 0.081 0 0 0.5 Yes
Canyonlands 2019 0.312 0.068 0 0 0.5 Yes
2020 0.186 0.085 0 0 0.5 Yes
2018 0.059 0.03 0 0 0.5 Yes
Bryce 2019 0.081 0.045 0 0 0.5 Yes
2020 0.071 0.03 0 0 0.5 Yes
2018 0.183 0.074 0 0 0.5 Yes
Capital Reef 2019 0.196 0.092 0 0 0.5 Yes
2020 0.126 0.078 0 0 0.5 Yes
2018 0.069 0.04 0 0 0.5 Yes
Zion 2019 0.123 0.039 0 0 0.5 Yes
2020 0.102 0.057 0 0 0.5 Yes

DAQE-MN103030032-24
Page 12

H. Acid Deposition

The Applicant performed a deposition analysis on impacts within the Class I areas. Results of the
analysis indicate that the impacts are below the deposition threshold (DAT) established by the National
Park Service, indicating that no further analysis is required

Table 8: CALPUFF Deposition Results for Highest Year

Class I Area
Total
Nitrate
Deposition
Total
Sulfate
Deposition
Deposition
Analysis
Threshold
(kg/ha/yr) (kg/ha/yr) (kg/ha/yr)
Canyonlands 0.0006 0.0003
0.005
Zion 0.0004 0.0002
Arches 0.0006 0.0003
Bryce 0.0006 0.0002
Capitol Reef 0.0011 0.0005

I. Soils and Vegetation Analysis

The Applicant performed an analysis to determine the extent of impacts from the proposed source on soil
and vegetation. Results of the analysis are presented in a supplemental document titled “Soil and
Vegetation Impact Analysis for the Leamington, UT Facility, June 29, 2023”. The analysis indicated that
predicted concentrations compared against the secondary NAAQS at several sensitive receptors would not
result in an adverse impact on soils and vegetation in the vicinity of the proposed project.

DP/JK:jg

DAQE-IN103030032-25

January 22, 2025

Josh Nelson
Ash Grove Cement Company
P.O. Box 38069
Leamington, UT 84638
[e-mail]

Dear Mr. Nelson:

Re: Intent to Approve: Major Prevention of Significant Deterioration Modification of Approval Order
DAQE-AN103030035-24
Project Number: N103030032

The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.

Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or [e-mail], if you have any questions.

Sincerely,

{{$s }}

Jon L. Black, Manager
New Source Review Section

JLB:JJ:jg

cc: Central Utah Health Department
EPA Region 8

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor

Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF AIR QUALITY
Bryce C. Bird
Director

* ) ' & — ) A A v A ? A D @ A w D D ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality

INTENT TO APPROVE
DAQE-IN103030032-25
Major Prevention of Significant Deterioration Modification of
Approval Order DAQE-AN103030035-24

Prepared By
John Jenks, Engineer
[phone]
[e-mail]

Issued to
Ash Grove Cement Company - Leamington Cement Plant

Issued On
January 21, 2025

{{$s }}

New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — ) A A v A ? A D @ A w D D ˜

TABLE OF CONTENTS

TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 10
PERMIT HISTORY ................................................................................................................... 21
ACRONYMS ............................................................................................................................... 22

DAQE-IN103030032-25
Page 3

GENERAL INFORMATION

CONTACT/LOCATION INFORMATION

Owner Name Source Name
Ash Grove Cement Company Ash Grove Cement Company - Leamington Cement Plant

Mailing Address Physical Address
P.O. Box 38069 Highway 132
Leamington, UT 84638 Leamington, UT 84638

Source Contact UTM Coordinates
Name: Cody Watkins 397000 m Easting
Phone: [phone] 4380100 m Northing
Email: [e-mail] Datum NAD83
UTM Zone 12
SIC code 3241 (Cement, Hydraulic)

SOURCE INFORMATION
General Description
Ash Grove Cement Company (Ash Grove) operates the Leamington cement manufacturing plant in Juab
County, Utah. Cement is produced when inorganic raw materials, primarily limestone (quarried on site),
are correctly proportioned, ground, and mixed and then fed into a rotating kiln. The kiln alters the
materials and recombines them into small stones called cement clinker. The clinker is cooled and ground
with gypsum and additional limestone into a fine powdered cement. The final product is stored on site for
later shipping. The major sources of air emissions are from the combustion of fuels for the kiln operation,
from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source of
emissions of PM2.5, PM10, NOx, CO, HAPs, and GHG. It is a minor source of SO2 emissions.
NSR Classification
Major PSD Modification

Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A

Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
MACT (Part 63), A: General Provisions
MACT (Part 63), LLL: National Emission Standards for Hazardous Air Pollutants From the
DAQE-IN103030032-25
Page 4

Portland Cement Manufacturing Industry
Title V (Part 70) Major Source

Project Description
With the Leamington Plant Upgrade Project, Ash Grove is proposing to increase fuel and energy
efficiency in its kiln system and throughout the plant to produce more low-carbon cement.

Ash Grove has proposed multiple changes:
1. Kiln system - replace portions of the preheater tower and various mechanical upgrades;
2. Upgrading the SNCR system - adding injection ports and increasing ammonia use;
3. Modified clinker cooler;
4. New finish mill;
5. New rail and truck loading/unloading;
6. Improvements in existing baghouses; and
7. Changes in fugitive emissions.

These changes result in increases in actual emissions but decreases in most potential emissions. There will
be an increase in the potential emissions of VOCs and greenhouse gases.

SUMMARY OF EMISSIONS

The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.

Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 14,975 1,067,984
Carbon Monoxide -9631 3414.00
Lead Compounds 0.01 0.05
Nitrogen Dioxide -125.44 1226.00
Particulate Matter - PM10 -33.21 203.15
Particulate Matter - PM2.5 -117.27 113.47
Sulfur Dioxide -146.53 45.87
Volatile Organic Compounds 12.69 72.07

Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acenaphthylene(TSP) (CAS #208968) 0 160
Arsenic (TSP) (CAS #7440382) 0 16
Benzene (Including Benzene From Gasoline) (CAS #71432) 2580 4080
Benzo (B) Fluoranthene (CAS #205992) 0 1
Beryllium (TSP) (CAS #7440417) 0 1
Biphenyl (CAS #92524) 0 8
Bis(2-Ethylhexyl)Phthalate (DEHP) (CAS #117817) 0 120
Cadmium (CAS #7440439) 0 3
Carbon Disulfide (CAS #75150) 0 140
Chlorobenzene (CAS #108907) 0 20
Chromium Compounds (CAS #CMJ500) 45 180
Dibenzo(A,H)Anthracn (CAS #53703) 0 1
DAQE-IN103030032-25
Page 5

Dibutylphthalate (CAS #84742) 0 60
Ethyl Benzene (CAS #100414) 0 20
Fluoranthene (TSP) (CAS #206440) 0 12
Formaldehyde (CAS #50000) 6905 25660
Generic HAPs (CAS #GHAPS) 0 478
Hexane (CAS #110543) 0 160
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 7745 49385
Lead Compounds (CAS #LCT000) 28 100
Manganese (TSP) (CAS #7439965) 0 1140
Mercury (TSP) (CAS #7439976) 11 64
Methyl Bromide (Bromomethane) (CAS #74839) 0 60
Methylene Chloride (Dichloromethane) (CAS #75092) 0 640
Naphthalene (CAS #91203) 640 2240
Phenanthrene (CAS #85018) 0 520
Phenol (CAS #108952) 0 140
Pyrene (CAS #129000) 0 58
Selenium (TSP) (CAS #7782492) 60 260
Styrene (CAS #100425) 0 2
Toluene (CAS #108883) 0 260
Xylenes (Isomers And Mixture) (CAS #1330207) 0 180
Change (TPY) Total (TPY)
Total HAPs 11.10 43.08

PUBLIC NOTICE STATEMENT

The NOI for the above-referenced project has been evaluated and has been found to be consistent with the requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be constructed, installed, established, or modified prior to the issuance of an AO by the Director. A 30-day public comment period will be held in accordance with R307-401-7. A notification of the intent to approve will be published in the Millard County Chronicle Progress. During the public comment period the proposal and the evaluation of its impact on air quality will be available for the public to review and provide comment. If anyone so requests a public hearing within 15 days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as close as practicable to the location of the source. Any comments received during the public comment period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result of the comments received.

SECTION I: GENERAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.

I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
DAQE-IN103030032-25
Page 6

I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions covered by this AO must be reviewed and approved. [R307-401-1] I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the five-year period prior to the date of the request. Unless otherwise specified in this AO or in other applicable state and federal rules, records shall be kept for a minimum of five years. [R307-401-8]

I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall, to the extent practicable, maintain and operate any equipment approved under this AO, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Director which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. All maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107]

I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
I.8 The owner/operator shall submit documentation of the status of installation of the equipment
marked as new or reconstructed in section II.A to the Director within 18 months from the date of this AO. This AO may become invalid if construction is not commenced within 18 months
from the date of this AO or if construction is discontinued for 18 months or more. To ensure
proper credit when notifying the Director, send the documentation to the Director, attn.: NSR Section. [R307-401-18]

SECTION II: PERMITTED EQUIPMENT

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.A THE APPROVED EQUIPMENT
II.A.1 Leamington Cement Plant II.A.2 Quarry: Quarry Operations
Rock drilling operations, truck hauling, and storage piles.
II.A.3 Stockpiles Coal storage Area: 1 acre Annual throughput: 20,000 tpy AF and ARM stockpiles Area: 0.25 acre Annual throughput: 8,000 tpy
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II.A.4 Stationary Crusher Stationary crusher with an approximate production rate of 1,000 tons per hour for reduction of quarried material to 3-inch-minus-sized material. The crusher is equipped with a 20,000 acfm baghouse (211.BF1) and with water sprays on the feed hopper. (pre-1983)
II.A.5 Raw Material Transfer Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of conveyor B8 prior to loading into raw material reclaim area. The conveyor transfer
point is equipped with a baghouse (211.BF2) 1,500 acfm total airflow, 216 ft2 total filter area, and water sprays. (pre-1983)
II.A.6 Material Handling Conveyor belt systems, secondary feeders and screens, stacker systems. II.A.7 Portable Crusher
Portable unit, not a stationary source, no unit-specific requirements.
II.A.8 Belt Conveyor Transfer Baghouse Located prior to raw materials processing, this baghouse (311.BC1) with 141 ft2 filter area and 1,800 acfm total air flow controls emissions from the conveyor belt that transfers the stacked material to the raw material silos.
II.A.9 Raw Material Silos Raw materials such as limestone, silica, iron, and shale are stored in one of four silos. The four
silos are equipped with one common Fuller plenum pulse baghouse (315.BF1) - 1,689 ft2 filter
area; 9,865 acfm total air flow, controlling particulates from stack C125 (raw storage).
II.A.10 Fifth Component Silo Raw materials are stored in a silo. This silo is equipped with a BHA pulse jet baghouse (315.BF2) - 844 ft2 filter area; 3,500 acfm total air flow.
II.A.11 Raw Mill Recirculation
Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This system includes vibrating feeders, a conveyor system, and surge bin. Emissions are
controlled by five equivalent baghouses (316.BF1, 316.BF2, 316.BF3, 316.BF4, 316.BF5) - each
is a DCE Inc. Model DLM V15/15F with 1,000 acfm and 6.21:1 A/C ratio.
II.A.12 Cross-Belt Analyzer Used for quality control. Emissions are controlled by a 1,400 acfm baghouse (316.BF6). II.A.13 Kiln & Pre-Calciner and Raw Mill
Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of
the raw mill, where finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a 435,000 acfm baghouse (317.BF3) on the main stack (D38). The
following equipment is installed: low-NOx burner, selective non-catalytic reduction (SNCR) for
NOx control; NOx, CO, total hydrocarbons, CO2, and oxygen (O2) CEMS;

II.A.14 Kiln description continued mercury (Hg) CEMS or integrated sorbent trap monitoring system; PM continuous parametric monitoring system (CPMS). A carbon injection system is installed at the raw mill bypass duct for mercury adsorption capacity. The carbon injection system is not an emission point as it is in an enclosed building.
II.A.15 Solios Low Pressure Pulse Jet Baghouse
One Solios, low-pressure pulse jet baghouse - 173,712 ft2 filter area; air flow: 435,000 acfm
controlling particulates from stack D38 (raw mill/kiln stack 317.BF3)

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II.A.16 Two Kiln Feed Blending Silos Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common Fuller plenum pulse baghouse (411.BF1) - 1,351 ft2 filter area; 7,160 acfm total air flow.
II.A.17 Blending Silo Elevators (2) Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a Fuller pulse jet baghouse (412.BF1) - 676 ft2 filter area; 2,800 acfm total air flow through stack
E34.
II.A.18 Kiln Feed Alleviator A new pulse jet baghouse (414.BF1N) - 9,900 acfm total air flow controls particulate from the central material silo between the blending silos and the preheater. Raw feed is removed from the system near the top of the preheater tower.
II.A.19 Coal Silo Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The
coal storage silo is equipped with a Unifilter, shaker baghouse (41B.BF1) - 1,508 ft2 filter area;
1,700 acfm total air flow.
II.A.20 Coal Grinding System Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are controlled by a Fuller-Kovako, Model 'S' jet pulse baghouse (41B.BF2): 19,500 acfm rated airflow with 3.75:1 A/C ratio
II.A.21 Clinker Cooler and Baghouse Reconstructed grate-type cooler used for cooling clinker from the kiln prior to transfer to clinker
storage. The clinker cooler vent air is controlled by a pulse jet baghouse (419.BF1) - 173,869
acfm total air flow on the clinker cooler stack (F31). A PM continuous parameter monitoring system (CPMS) is installed.

II.A.22 Clinker Belt Transfer Clinker is removed from the clinker cooler by drag chains and dropped onto one of two clinker conveyor belts. The conveyors and transfer points are controlled by a baghouse (419.BF8). The exhaust is routed to the clinker cooler stack. II.A.23 Clinker Silos
Clinker from the clinker cooler is transferred to one of three storage silos. Emissions generated
when loading the east and west clinker silos and the out-of-spec silo are controlled by a pulse jet baghouse (419.BF9). The exhaust is routed to the clinker cooler stack.
Alternatively, clinker can be conveyed to outside storage piles.

II.A.24 East Clinker Silo Discharge Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF1): 1,800 acfm that discharges into the clinker tunnel.
II.A.25 West Clinker Silo Discharge
Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo.
Emissions during transfer of clinker to the conveyor are controlled by a baghouse (511.BF2):
1,800 acfm that discharges into the clinker tunnel.

II.A.26 Clinker Reclaim Hoppers (2) Imported clinker is fed to the clinker tunnel conveyor belt by two outside clinker hoppers. Emissions during transfer of clinker to the conveyor are controlled by two BHA baghouses (511.HP1 and new 511.HP2): 1,800 acfm each.
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II.A.27 Gypsum Silo Gypsum is stored in the gypsum storage silo. A Unifilter 1,500 acfm total airflow, 1,508 ft2 total filter area baghouse (512.BF1) is installed on the gypsum storage silo to control dust during loading.
II.A.28 Clinker Tunnel Exitway The east clinker silo discharge baghouse (511.BF1), west clinker silo discharge baghouse (511.BF2), 512.BF2 (1,800 acfm) limestone discharges in the clinker tunnel, and (511.BF4):
1,800 acfm, gypsum discharge into the clinker tunnel, all discharge in the clinker tunnel. Emissions are vented through the tunnel exitway.
II.A.29 Limestone Silo Limestone is stored in the limestone storage silo and transferred to the finish mill by conveyor belt. [BM1] One BHA baghouse is installed on the limestone storage silo to control dust during loading. 512.BF3 (1,000 acfm) is located on top of the silo. II.A.30 Finish Mill (Ball Mill)
The finish mill grinds clinker and gypsum to produce finished cement products. Dust generated
during milling is captured by a BHA pulse jet baghouse (514.BF2) - 6,080 ft2 filter area; 32,000 acfm total air flow, controlling particulates from stack G105 (finish grinding stack).

II.A.31 Finish Mill (Ball Mill) Separator After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the finish mill. Dust generated by the finish mill separator is collected by a BHA pulse jet baghouse (514.BF1) - 4,053 ft2 filter area; 20,000 acfm total air flow, controlling particulates from stack G55 (finish mill stack).
II.A.32 Finish Mill and Separator (Vertical Mill)
New finish mill, vertical style, equipped with 10.43 MMBtu/hr natural gas-fired heater. The stack is controlled by a baghouse (524.BF3): 158,376 acfm.
Two baghouses control conveyor transfer points (524.BF2 & 4).
Ten baghouses serve as nuisance dust filters (520.BF1 thru 4, 521.BF1 & 2, 524.BF1, 525.BF1 thru 3).

II.A.33 Finish Cement Storage Silos There are six storage and two interstice silos where the finished cement product is stored. A single common Fuller plenum pulse baghouse (611.BF1) - 1,351 ft2 filter area; 6,400 acfm total air flow through stack H7 is located on top of the silos and is used to control emissions during loading and unloading operations.
II.A.34 North Cement Load Out
The cement loadout system located on the North side of the silos (rail load outside) is controlled by a Fuller, pulse jet baghouse (611.BF3) during unloading from the silos for rail shipping. This
baghouse discharges into the enclosed space inside the silos.

II.A.35 South Cement Load Out The cement loadout system located on the South side of the silos (truck load outside) is controlled by a Fuller pulse jet baghouse (611.BF2) during unloading from the silos for truck shipping. Two pulse jet baghouses (611.BF4, 611.BF5) control emissions from the cement conveyor fluidslides and truck loading chutes. These baghouses discharge into the enclosed space inside the silos.
II.A.36 Rail and Truck Loading/Unloading
New rail and truck loading/unloading facility, equipped with two baghouses (NRL_UPR,
NRL_LWR) to control fugitive emissions from the roof and from transfer of cement or raw
materials - each 2,500 acfm.

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II.A.37 MHO: Materials Handling Operation Includes the following emission units: 315.BF1; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 514.BF3; 419.BF9; 419.BF10; 511.BF1 thru 4; 512.BF1; 611.BF1 thru 5; 512.BF2 & 3; 413.BF1.
II.A.38 LBS: Limestone Bypass System Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the
screen and material handling drop points.
II.A.39 GEN: Emergency Generators One diesel-fired emergency generator (new) Rating: 762 hp (Kiln, Tier 3, permitted 2022) Two natural gas-fired emergency generators Rating: 304 hp (Main office and control room, permitted in 2023) One diesel-fired emergency generator Rating: 560 hp (Shipping, permitted 2023)
II.A.40 Dust Shuttle System A dust-shuttling system is used intermittently to mitigate mercury emissions as required. The
system includes the following equipment: elevator from baghouse, pneumatic air slide, alkali
silo, pug mill, pug mill loadout, fringe bin, 14-inch knife gate, 8-inch knife gate, 8-inch air slides, surge bin, and pneumatic blower. Emissions are controlled by a baghouse (4,500 acfm) on the
fringe bin (514.BF3) and a baghouse (4,500 acfm) on the alkali silo (413.BF1).

II.A.41 Miscellaneous Storage Tanks One diesel storage tank (<2,000 gallons) One gasoline storage tank (500 gallons) Three ammonia storage tanks (8,000 gallons each)

SECTION II: SPECIAL PROVISIONS

The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO. II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Requirements on the Cement Plant: II.B.1.a The following limits shall not be exceeded: A. Clinker production - 1,155,000 tons per rolling 12-month period B. Used oil consumption - 85,724 gallons per rolling 12-month period C. Limestone bypass material processed - 216,260 tons per rolling 12-month period. [R307-401-8]
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II.B.1.a.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new 12-month total by the 25th day of each month using data from the previous 12 months. Records shall be kept for all periods when the plant is in operation. Consumption and production shall be calculated through use of the plant's acquisition system. [R307-401-8]
II.B.1.b Emissions to the atmosphere at all times from the indicated emission point(s) shall not exceed the following rates and concentrations:
Source: Kiln 1/Raw Mill Stack (D38) PM: 0.07 lbs filterable PM per ton of clinker
SO2: 0.4 lbs per ton of clinker (3-hr average)
CO: 3,395 tons per rolling 12-month period and 6,600 lbs/hr
NOx: 2.8 lbs per ton clinker based upon a 30-day rolling average and 1,233 tons per rolling 12-
month period
Dioxins and furans (D/F): 0.2 ng/dscm (TEQ) (corrected to 7% O2); or 0.4 ng/dscm (TEQ)
(corrected to 7% O2) when the average temperature at the inlet of the PM control device is 400oF or less.

Mercury (Hg): 55 lb/MM tons clinker (30-day operating day rolling average)
THC: 24 ppmvd (corrected to 7% O2) (30-day operating day rolling average)
CO2e: 0.92 ton CO2e per ton of clinker (12-month rolling average)

Source: Clinker Cooler Stack (F31)
PM: 0.02 lbs filterable PM per ton of clinker.
[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]

II.B.1.c A fugitive coal dust emissions control plan shall be submitted in accordance with 40 CFR 60.254(c) for the coal stockpile. Adherence to the most recently submitted fugitive coal dust emissions control plan shall be monitored to demonstrate that appropriate control measures are being implemented to minimize fugitive coal dust to the greatest extent practicable. A copy of the most recently submitted fugitive coal dust control plan shall be kept on site. Records shall be kept that demonstrate all components required by 40 CFR 60.254(c) have been included in the plan and that the source is operating in accordance with the submitted plan. For petitions to approve alternative control measures, the permittee shall keep a copy of the submitted petition and any approvals received. [40 CFR 60 Subpart Y]
II.B.1.d Unless the owner/operator has chosen to operate the Leamington Cement Plant as an area source
of HAPs, emissions of HCl shall not exceed 3 ppmvd (corrected to 7% O2).
[40 CFR 63 Subpart LLL]

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II.B.1.e Stack testing to show compliance with the emission limitations stated in Conditions II.B.1.b and II.B.1.d shall be performed as specified below: A. Kiln/Raw Mill Stack Pollutant Test Status Test Frequency PM * # CO * ++ SO2 ** ## NOx * ++ Dioxin/Furan * +++ THC *** ++ Hg *** ++ HCL *** ++ CO2 * ++ B. Clinker Cooler (F31) Pollutant Test Status Test Frequency PM + # C. Testing Status (To be applied above) * The initial testing has already been performed. ** The SO2 initial performance test was conducted on August 26, 2013. *** The initial compliance test shall be conducted within the first 30 operating days of operation in which the affected source operates using a CEMS. # Test once every year. If performance testing would be required less than 15 operating days after the Kiln has completed Startup after being down for more than 24 hours, then performance testing may be deferred up to 15 operating days after completion of the Startup. The Director may require testing at any time. ## Test at least once every two years. The Director may require testing at any time. + Initial testing is required within 180 days of startup of the reconstructed equipment ++ Compliance with the limits shall be demonstrated through use of a continuous emissions monitoring system as outlined in Condition II.B.3.a and as follows: To determine continuous operating compliance, the owner/operator must record the PM CPMS output data for all periods when the process is operating and use all the PM CPMS data for calculations when the PM CPMS is not out of control. The owner/operator must demonstrate continuous compliance by using all quality-assured hourly average data collected by the PM CPMS for all operating hours to calculate the arithmetic average operating parameter in units of the operating limit on a 30-operating day rolling average basis, updated at the end of each new kiln operating day. +++ Test every 30 months. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-401-8]
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II.B.1.e.1 Notification The Director shall be notified at least 30 days prior to conducting any required emission testing. A source test protocol shall be submitted to DAQ when the testing notification is submitted to the Director. The notification requirements for performance tests subject to 40 CFR 63, Subpart LLL are required within 60 days prior to conducting the performance testing. The source test protocol shall be approved by the Director prior to performing the test(s). The source test protocol shall outline the proposed test methodologies, stack to be tested, and procedures to be used. A pretest conference shall be held, if directed by the Director. [R307-165] II.B.1.e.2 Sample Location The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix A,
Method 1, or other EPA-approved methods acceptable to the Director. An Occupational Safety and Health Administration (OSHA)- or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location. [R307-165]

II.B.1.e.3 Volumetric Flow Rate 40 CFR 60, Appendix A, Method 2. [R307-165]
II.B.1.e.4 PM 40 CFR 60, Appendix A, Method 5, or 5I, or other EPA-approved method as acceptable to the
Director. The initial and subsequent PM performance tests shall consist of three runs, with each
run at least 120 minutes in duration and each run collecting a sample of 60 dry standard cubic feet. [40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-165]

II.B.1.e.5 Carbon Monoxide (CO) Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.6 Nitrogen Oxides (NOx)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.7 Sulfur Dioxide (SO2) 40 CFR 60, Method 6 or 6C of Appendix A-4, or other EPA-approved method as acceptable to the Director. [R307-165]
II.B.1.e.8 Dioxin/Furan
Continuous Monitoring System. [40 CFR 63 Subpart LLL]
II.B.1.e.9 Total Hydrocarbons (THC) Continuous Emission Monitoring (See Condition II.B.3.a). [40 CFR 63 Subpart LLL] II.B.1.e.10 Mercury (Hg)
Continuous Emission or Integrated Sorbent Trap Monitoring (See Condition II.B.3.a).
[40 CFR 63 Subpart LLL]
II.B.1.e.11 HCl Performance test methods and procedures found in 40 CFR 63.1349(b)(6) or other EPA-approved method as acceptable to the Director. [40 CFR 63 Subpart LLL]
II.B.1.e.12 Carbon Dioxide (CO2)
Continuous Emission Monitor (see Condition II.B.3.a). [R307-170]
II.B.1.e.13 Calculations To determine mass emission rates (lb/hr, etc.), the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Director, to give the results in the specified units of the emission limitation. [R307-165]
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II.B.1.e.14 Existing Source Operation For an existing source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three years. [R307-165] II.B.1.e.15 New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no less than 90% of the maximum production rate listed in this AO. If the maximum AO allowable production rate has not been achieved at the time of the test, the following procedure shall be
followed: 1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the tested achieved rate, but not more than the maximum allowable production rate. This new allowable
maximum production rate shall remain in effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at no less
than 90% of the higher rate shall be conducted. A new maximum production rate (110% of the new rate) will then be allowed if the test is successful. This process may be repeated until the
maximum AO production rate is achieved.
[R307-165]

II.B.1.f The owner/operator shall determine clinker production as outlined in 40 CFR 63 Subpart LLL. [40 CFR 63 Subpart LLL]
II.B.1.g The Dust Shuttle System Fringe Bin and Alkali Silo baghouses shall be operating at all times of
Dust Shuttle System operation to assist in the capture of mercury emission. [R307-401-8]
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II.B.1.h Visible emissions from the following emission points shall not exceed the following values: A. Limestone crushers - 15% opacity B. Limestone screens - 10% opacity C. Limestone conveyor transfer points - 10% opacity D. All other crushers - 15% opacity E. All other screens - 10% opacity F. All other conveyor transfer points - 10% opacity G. All stacking conveyors - 10% opacity H. Bins and trap feeder - 10% opacity I. All diesel engines - 20% opacity J. All support equipment - 20% opacity K. Coal storage and transfer - 20% opacity L. All baghouses - 10% opacity M. Fugitive dust - 20% opacity N. All other points - 20% opacity. [40 CFR 60 Subpart OOO, 40 CFR 60 Subpart Y, R307-401-8]
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II.B.1.i Any totally enclosed conveying system transfer point, regardless of the location of the transfer point, is not required to conduct Method 22 visible emissions monitoring under this paragraph. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner/operator must conduct a Method 22 performance test, of Appendix A-7 to 40 CFR 60, according to the following: (i) The owner/operator must conduct a monthly ten-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A-7 to 40 CFR 60. The performance test must be conducted while the affected source is in operation. (ii) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner/operator may decrease the frequency of performance testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iii) If no visible emissions are observed during the semi-annual test for any affected source, the owner/operator may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner/operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (iv) If visible emissions are observed during any Method 22 performance test of Appendix A-7 to 40 CFR 60, the owner/operator must conduct 30 minutes of opacity observations, recorded at 15-second intervals, in accordance with Method 9 of Appendix A-4 to 40 CFR 60. The Method 9 performance test, of Appendix A-4 to 40 CFR 60, must begin within one hour of any observation of visible emissions. (v) If visible emissions from a building are monitored, the requirements of paragraphs (i) through (iv) of this Condition apply to the monitoring of the building, and the owner/operator must also test visible emissions from each side, roof, and vent of the building for at least ten minutes. [R307-401]
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II.B.1.j Emissions of filterable particulate matter (PM) from the following baghouses shall not exceed 0.005 gr/dscf: 520.BF1 520.BF2 520.BF3 520.BF4 521.BF2 521.BF1 524.BF1 524.BF2 524.BF4 524.BF3 525.BF1 525.BF2 525.BF3 511.HP2 NRL_UPR NRL_LWR [R307-401-8]
II.B.1.j.1 To determine compliance with the grain loading limitation, each baghouse shall be tested as
outlined in II.B.1.e.4. Each baghouse shall be tested at least annually. Upon demonstration through at least three annual tests that the PM limits are not being exceeded, the owner/operator
may request approval from the Director to conduct stack testing less frequently than annually.
[R307-401-8]
II.B.2 Roads and Fugitive Dust Requirements:
II.B.2.a Paved roads and operational areas shall be swept and/or water sprayed to minimize fugitive dusts
as dry conditions warrant or as determined necessary by the Director to maintain opacity limits listed in this AO. [R307-401]

II.B.2.b All unpaved roads and other unpaved operational areas that are used by mobile equipment shall be water sprayed and/or chemically treated to control fugitive dust. The application of water or chemical treatment shall be used. Treatment shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist condition unless it is below freezing. If chemical treatment is to be used, the plan must be approved by the Director. Records of water and/or chemical treatment shall be kept for all periods when the plant is in operation. The records shall include the following items: Instances of water and/or chemical application to unpaved areas shall be recorded and maintained by the owner/operator. The ambient temperature shall be recorded any time water should be applied but cannot due to freezing conditions. [R307-401-8]
II.B.2.c Water sprays or chemical dust suppression sprays shall be installed at the following points to control fugitive emissions:

A. Hopper at the primary crusher

B. Material belt feeding the stacker

C. Limestone bypass screen/conveyor drops.

The sprays shall operate whenever dry conditions warrant meeting the required opacity
limitations or as determined necessary by the Director. Water sprays shall not be required during
periods of freezing temperatures.

[R307-401-8]

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II.B.2.d All disturbed surfaces not involved with operations shall be stabilized to minimize generation of fugitive dusts as dry conditions warrant or as determined necessary by the Director. [R307-401-8] II.B.2.e The owner/operator shall only conduct blasting operations between the hours of 9 AM and 5 PM.
[R307-401-8]
II.B.3 Continuous Emission Monitoring Requirements: II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system on the kiln/raw mill stack and clinker cooler. A. For the NOx mass emission limits, during any time when the CEMS are inoperable and
otherwise not measuring emissions of NOx from the kiln, the owner/operator shall apply the missing data substitution procedures used by the UDAQ or the missing data substitution procedures in 40 CFR Part 75, Subpart D, whichever is deemed appropriate
by the UDAQ
B. In calculating the 30-day rolling average emission rate, the total pounds of NOx emitted
during a specified period shall include all kiln emissions that occur during the specified period, including during each startup, shutdown, or malfunction

C. The monitoring system shall comply with all applicable sections of R307-170, UAC, and 40 CFR 60, Appendix B

D. Total Hydrocarbons (THC), HCl, Oxygen (O2) and Carbon Dioxide (CO2) CEMs shall be installed on the kiln/raw mill stack

E. A mercury (Hg) CEM or integrated sorbent trap monitoring system shall be installed on the kiln/raw mill stack

F. The owner/operator shall record the output of the system: including the quantity of NOx, CO, O2, THC, Hg, HCl, and CO2 emissions at the kiln stack

G. Except for system breakdown, repairs, calibration checks, and zero and span adjustments required under paragraph (d) 40 CFR 60.13, the owner/operator of an
affected source shall continuously operate all required continuous monitoring devices
and shall meet minimum frequency of operation requirements as outlined in 40 CFR 60.13 and Section UAC R307-170.

[40 CFR 60 Subpart F, 40 CFR 63 Subpart LLL, R307-170]
II.B.3.b The owner/operator shall install and operate a PM CPMS on the Kiln 1/Raw Mill and clinker cooler stacks in accordance with the requirements of 40 CFR 63.1350 (b) and (d). Except during periods of CPMS breakdowns, repairs, calibration checks, and zero span adjustments, the PM CPMS shall be operated at all times of kiln operation. The owner/operator shall use a PM CPMS to establish a Site-Specific Operating Limit (SSOL) for PM corresponding to the results of the performance test demonstrating compliance with the filterable PM limit and using the methodology in 40 CFR 63.1349(b). The owner/operator shall reassess and adjust the SSOL developed in accordance with the results of the most recent PM performance test demonstrating compliance with the PM emission limit. The owner/operator shall use the PM CPMS to demonstrate continuous compliance with the SSOL in accordance with the requirements of 40 CFR 63.1350(b)(1). [40 CFR 63 Subpart LLL]

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II.B.4 Fuel Limitations: II.B.4.a The owner/operator shall use only the following fuels in the kiln and pre-calciner:
A. Coal
B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)
D. Natural Gas
E. Coke F. Fuel Oil
G. Used Oil Fuel

H. Synthetic Fuel
I. Wood
J. Process Engineered Fuel (PEF)

K. Coal Additives as defined in Condition II.B.4.b.
If any other fuel is to be used, an AO shall be required in accordance with R307-401, UAC.
[R307-401]

II.B.4.b Prior to burning any proposed coal additive, the owner/operator shall obtain approval from the Director. To obtain approval, the owner/operator shall submit Safety Data Sheets (SDS) or the results of suitable tests giving data similar to a proximate and ultimate analysis of the proposed coal additive. [R307-401-8] II.B.4.b.1 Approval by the Director shall consist of a letter approving the use of the proposed coal additive.
Approval is not required to change from one previously approved coal additive to another
previously approved coal additive. [R307-401-8]
II.B.4.b.2 The average quantity of coal additives burned shall not be greater than 15% of the total daily heat input of the kiln and precalciner. The owner/operator may increase the average quantity of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon approval by the Director in accordance with the approval process described in Condition II.B.4.b. [R307-401-8]
II.B.4.c The sulfur content of any coal, oil, or mixture thereof, burned in any fuel-burning or process installation not covered by New Source Performance Standards for sulfur emissions or covered
elsewhere in this AO, shall contain no more than 1.0 pound sulfur per million gross Btu heat
input for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil
except used oil. The sulfur content shall comply with all applicable sections of UAC R307-203.
[R307-203, R307-401-8]

DAQE-IN103030032-25
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II.B.4.c.1 Certification of fuels shall be either by the owner/operator's own testing or test reports from the fuel marketer. Records of each fuel supplier's test report on sulfur content shall be available onsite. Methods for determining sulfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307-203-1 (4). A. For determining sulfur content in coal, ASTM Methods D3177-75 or D4239-85 are to be used B. For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-89 are to be used C. For determining the gross calorific (or Btu) content of coal, ASTM Methods D2015-77 or D3286-85 are to be used. [R307-203]
II.B.4.d The concentration/parameters of contaminants in any used oil fuel shall not exceed the following
levels:
1) Arsenic 5 ppm by weight
2) Barium 100 ppm by weight 3) Cadmium 2 ppm by weight
4) Chromium 10 ppm by weight
5) Lead 100 ppm by weight 6) Total halogens 1,000 ppm by weight
7) Sulfur 0.5 percent by weight
A. The flash point of all used oil to be burned shall not be less than 100oF.

B. The owner/operator shall provide test certification for each load of used oil fuel received. Certification shall be either by their own testing or test reports from the used oil fuel
marketer. Records of used oil fuel consumption and the test reports shall be kept for all
periods when the plant is in operation
C. Used oil that does not exceed any of the listed contaminants content may be burned. The
owner/operator shall record the quantities of oil burned on a daily basis
D. Any used oil fuel that contains more than 1000 ppm by weight of total halogens shall be
considered a hazardous waste and shall not be burned in the kiln/preheater. The oil shall be tested for halogen content by ASTM Method D-808-81, EPA Method 8240, or
Method 8260 before used oil fuel is transferred to the burn tank and burned.
[R307-401-8]

II.B.4.e The following operating parameters shall be met at all times when used oil or TDF is burned in the rotary kiln: A. Combustion gas temperature at the rotary kiln exit-no less than 1500oF for more than five minutes in any 60-minute period B. Oxygen content at the kiln system ID fan - no less than 2% for more than five minutes in any 60-minute period. [R307-401-8]
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II.B.4.e.1 The temperature and oxygen content shall both be monitored with equipment approved by the Director. The calibration procedure and frequency shall be according to manufacturer's specifications. Use of factory-calibrated thermocouples for temperature measurement is approved. However, any other method of temperature measurement must be approved by the Director prior to use. The monitoring equipment for both temperature and oxygen content shall be located such that an inspector can at any time safely read the output. [R307-401-8] II.B.5 Emergency Engine Requirements
II.B.5.a The owner/operator shall only operate the emergency engines for testing and maintenance purposes between the hours of 1 PM and 3 PM. There is no restriction on emergency operation. [R307-401-8]
II.B.5.b The owner/operator shall only use diesel fuel (e.g., fuel oil #1, #2, or diesel fuel oil additives) as fuel in each emergency engine. [R307-401-8]
II.B.5.b.1 The owner/operator shall only combust diesel fuel which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.5.b.2 To demonstrate compliance with the diesel fuel sulfur requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel fuel supplier. [R307-401-8]

PERMIT HISTORY

This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103030035-24 dated November 27, 2024 Is Derived From Source Submitted NOI dated November 30, 2022 Incorporates Additional Information Received dated April 26, 2023 Incorporates Additional Information Received dated September 26, 2023 Incorporates Additional Information Received dated July 23, 2024 Incorporates Additional Information Received dated October 25, 2024 Incorporates Additional Information Received dated November 25, 2024
DAQE-IN103030032-25
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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