DAQ-2025-002601

1

DAQC-487-25
Site ID 10676 (B1)

MEMORANDUM

TO: FILE – HOLCIM SWR, INC. – Utelite (Formerly Holcim Corporation)

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joe Rockwell, Environmental Scientist

DATE: May 16, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Summit County,
FRS #UT0000004904300001

INSPECTION DATE: May 15, 2025

SOURCE LOCATION: West of Rockport Reservoir
Rockport, UT 84017

Take I-80 east to exit 155 and turn right. Travel south past the Wanship Dam at
Rockport Reservoir for approximately 3 miles. Turn right (west), (Landfill
Sign) at Three Mile Canyon and travel about a half mile to the plant.

MAILING ADDRESS: P.O. Box 387
Coalville, Utah 84017

SOURCE CONTACTS: Alex Judd, Operations Manager
Cell: 435-297-4779
[e-mail]

David Vernon, Environmental Health & Safety
Cell: 435-297-4758
[e-mail]

Plant # 801-467-2800

OPERATING STATUS: Kilns #1, #3, and #4 were operating at time of the inspection.

PROCESS DESCRIPTION: Holcim produces specialty shale products that are used to strengthen concrete
products. Raw shale from the on-site quarry is transported to the mill by haul
truck. Materials are first fed into a Stamler feeder and crusher/screen by
front-end loader. After screening, the materials are transported by conveyor to a
hammer mill and screen. The product is then conveyed to feed bins. Material
from the storage bins is fed to one of three kilns (#1, #3, and #4) where the
shale is dried and baked. The materials then go through a cooling process and
are sprayed with water. Once cooled, the materials are dropped into a bucket
elevator and transported to a curing tank. In the curing tank, the lime dissipates

2

out of the baked product. Once the lime is removed, the materials are moved to
the finish stage where they are screened for sizing and then conveyed to storage
tanks by size. The finished product is shipped to manufacturers that produce
high-strength concrete, pre-cast concrete products, and concrete roofing tiles,
all over the West and Canada.

Control devices consist of water sprays at some crushers, conveyor points, and
in the yard area. The kilns and feed bins are vented through baghouses. Kiln
dust is vented through the baghouse. A dedicated water truck is also used for
the haul roads and operational areas.
APPLICABLE
REGULATIONS: Title V Operating Permit 4300001004 dated May 24, 2023, revised May 24,
2023.

Experimental Approval Order (EAO) dated December 3, 2024

40 CFR 60 Subpart A-General Provision
40 CFR 60 Subpart OOO-Standard of Performance for Nonmetallic Mineral
Processing Plants
40 CFR 60 Subpart UUU-New Source Performance Standards for Calciners
and Dryers in Mineral Industries
40 CFR 63 Subpart A-General Provisions
40 CFR 63 Subpart ZZZZ-National Emission Standards for Hazardous Air
Pollutants for Stationary Reciprocating Internal Combustion Engines

SOURCE
EVALUATION:

SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the
potential to emit, are enforceable by the EPA and citizens under the Clean Air Act of
1990 (CAA) except those terms and conditions that are specifically designated as "State
Requirements". (R307-415-6b)

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

I.B Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permittee may not operate except in
compliance with this permit. (See also Provision I.E, Application Shield)

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

3

I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit
noncompliance constitutes a violation of the Air Conservation Act and is grounds for
any of the following: enforcement action; permit termination; revocation and
reissuance; modification; or denial of a permit renewal application.
(R307-415-6a(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it
would have been necessary to halt or reduce the permitted activity in order to
maintain compliance with the conditions of this permit. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the Director, within a reasonable time, any
information that the Director may request in writing to determine whether
cause exists for modifying, revoking and reissuing, or terminating this
permit or to determine compliance with this permit. Upon request, the
permittee shall also furnish to the Director copies of records required to be
kept by this permit or, for information claimed to be confidential, the
permittee may furnish such records directly to the EPA along with a claim of
confidentiality. (R307-415-6a(6)(e))

I.C.4 This permit may be modified, revoked, reopened, and reissued, or
terminated for cause. The filing of a request by the permittee for a permit
modification, revocation and reissuance, or termination, or of a notification
of planned changes or anticipated noncompliance shall not stay any permit
condition, except as provided under R307-415- 7f(1) for minor permit
modifications. (R307-415-6a(6)(c))

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

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

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

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

4

I.D.4 Permit expiration terminates the permittee's right to operate unless a timely
and complete renewal application is submitted consistent with R307-415-7b
(see also Provision I.E, Application Shield) and R307-415-5a(1)(c) (see also
Provision I.D.2). (R307-415-7c(2))

Status: The permit expires May 24, 2028. Application for renewal is due November 24, 2027.

I.E Application Shield.

If the permittee submits a timely and complete application for renewal, the permittee's
failure to have an operating permit will not be a violation of R307-415, until the
Director takes final action on the permit renewal application. In such case, the terms
and conditions of this permit shall remain in force until permit renewal or denial. This
protection shall cease to apply if, subsequent to the completeness determination
required pursuant to R307- 415-7a(3), and as required by R307-415-5a(2), the
applicant fails to submit by the deadline specified in writing by the Director any
additional information identified as being needed to process the application.
(R307-415-7b(2))

Status: Application for renewal is due November 24, 2027.

I.F Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit
is held invalid, the remaining permit conditions remain valid and in force.
(R307-415-6a(5))

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

I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Director consistent with
R307-415-9. (R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days
after the source receives notice of the amount of the fee, whichever is later.
(R307-415-9(4)(a))

Status: In compliance – The annual emission fees invoice payment was made on
September 10, 2024, before the due date of October 3, 2024. See the SLEIS
database.

I.H No Property Rights.
This permit does not convey any property rights of any sort, or any
exclusive privilege. (R307-415-6a(6)(d))

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

5

I.I Revision Exception.

No permit revision shall be required, under any approved economic incentives,
marketable permits, emissions trading and other similar programs or processes for
changes that are provided for in this permit. (R307-415-6a(8))

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

I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required
by law, the permittee shall allow the Director or an authorized
representative to perform any of the following:

I.J.1.a Enter upon the permittee's premises where the source is located or
emissions related activity is conducted, or where records are kept under the
conditions of this permit. (R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must
be kept under the conditions of this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including
monitoring and air pollution control equipment), practice, or operation
regulated or required under this permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for
the purpose of assuring compliance with this permit or applicable
requirements. (R307-415- 6c(2)(d))

I.J.2 Any claims of confidentiality made on the information obtained during an
inspection shall be made pursuant to Utah Code Ann. Section 19-1-306.
(R307-415-6c(2)(e))

Status: In compliance – Required records were made available and no claims of
confidentially were made at time of the inspection.

I.K Certification.
Any application form, report, or compliance certification submitted pursuant to this
permit shall contain certification as to its truth, accuracy, and completeness, by a
responsible official as defined in R307-415-3. This certification shall state that, based
on information and belief formed after reasonable inquiry, the statements and
information in the document are true, accurate, and complete. (R307-415-5d)

Status: In compliance – Reports and certifications submitted by Holcim SWR, Inc. appeared to
have certification statements and were signed by the responsible officials.

6

I.L Compliance Certification.

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

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

I.L.1.b The identification of the methods or other means used by the permittee
for determining the compliance status with each term and condition
during the certification period. Such methods and other means shall
include, at a minimum, the monitoring and related recordkeeping and
reporting requirements in this permit. If necessary, the permittee also
shall identify any other material information that must be included in
the certification to comply with section 113(c)(2) of the Act, which
prohibits knowingly making a false certification or omitting material
information;

I.L.1.c The status of compliance with the terms and conditions of the permit
for the period covered by the certification, including whether
compliance during the period was continuous or intermittent. The
certification shall be based on the method or means designated in
Provision I.L.1.b. The certification shall identify each deviation and
take it into account in the compliance certification. The certification
shall also identify as possible exceptions to compliance any periods
during which compliance is required and in which an excursion or
exceedance as defined under 40 CFR Part 64 occurred; and

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

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

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

Status: In compliance – The annual compliance certification was received on April 24, 2025, for
the report period April 1, 2024 – March 31, 2025. The certification was deemed
acceptable, after it was revised. The revised certification is still considered to have been
received by the due date of April 15, 2025. See Compliance Assistance below.

7

I.M Permit Shield.

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

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

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

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

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

I.M.2.b The applicable requirements of the Acid Rain Program, consistent
with the CAA Section 408(a). (R307-415-6f(3)(c))

I.M.2.c The liability of the owner or operator of the source for any violation of
applicable requirements under Utah Code Ann. Section 19-2-
107(2)(a)(xiii) and Section 19-2- 110 prior to or at the time of issuance
of this permit. (R307-415-6f(3)(b))

I.M.2.d The ability of the Director to obtain information from the source
under Utah Code Ann. Section 19-2-120, and the ability of the EPA
to obtain information from the source under the CAA Section 114.
(R307-415-6f(3)(d))

Status: N/A – See section III of this permit.

I.N Emergency Provision.

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

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

8

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

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

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

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

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

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

Status: No emergency events were reported since the last inspection, which was
conducted on June 4, 2024.

I.O Operational Flexibility.

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

I.P Off-permit Changes.
Off-permit changes are governed by R307-415-7d(2).

I.Q Administrative Permit Amendments.

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

I.R Permit Modifications.

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

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

I.S Records and Reporting.

I.S.1 Records.

9

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

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the
source shall record the following information, where applicable:
(R307-415- 6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of
sampling or measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or
measurement.

I.S.1.c Additional record keeping requirements, if any, are described in
Section II, Special Provisions.

Status: In compliance – Required records were provided, for review, at time of the inspection.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the Director every six
months, or more frequently if specified in Section II. All instances
of deviation from permit requirements shall be clearly identified in
the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified
by a responsible official in accordance with Provision I.K of this
permit. (R307-415- 6a(3)(c)(i)

I.S.2.c All reports submitted pursuant to Provision I.S.2.a shall be certified
by a responsible official in accordance with Provision I.K of this
permit. (R307-415- 6a(3)(c)(i)

10

I.S.2.d The Director shall be notified promptly of any deviations from permit
requirements including those attributable to upset conditions as defined
in this permit, the probable cause of such deviations, and any
corrective actions or preventative measures taken. Prompt, as used in
this condition, shall be defined as written notification within the
number of days shown under "Enforceable Dates and Timelines" at
the front of this permit. Deviations from permit requirements due to
breakdowns shall be reported in accordance with the provisions of
R307-107. (R307-415-6a(3)(c)(ii))

I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this
permit to be submitted to the Director are to be sent to the
following address or to such other address as may be required by
the Director:

Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, UT
84114-4820 Phone: 801-
536-4000

I.S.3.b All reports, notifications or other submissions required by this permit to be
submitted to the EPA should be sent to one of the following addresses or to such
other address as may be required by the Director:

For annual compliance certifications:

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

For reports, notifications, or other correspondence related to permit
modifications, applications, etc.:

Environmental Protection Agency, Region VIII
Air Permitting and Monitoring Branch (mail code
8ARD-PM) 1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

Status: In compliance – Six-month monitoring report received October 15, 2024, for report period
April 1, 2024 – September 30, 2024, and monitoring report received April 11, 2025, for
report period October 1, 2024 – March 31, 2025, were deemed acceptable. There were no
devotions for the report periods.

11

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances.

I.T.1.a New applicable requirements become applicable to the permittee and there is a
remaining permit term of three or more years. No such reopening is required if
the effective date of the requirement is later than the date on which this permit
is due to expire, unless the terms and conditions of this permit have been
extended pursuant to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

I.T.1.b EPA or the Director determines that this permit must be revised or revoked to
assure compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.c Additional applicable requirements are to become effective before the renewal
date of this permit and are in conflict with existing permit conditions. (R307-
415- 7g(1)(e))

I.T.2 Additional requirements, including excess emissions requirements, become
applicable to a Title IV affected source under the Acid Rain Program. Upon
approval by EPA, excess emissions offset plans shall be deemed to be
incorporated into this permit. (R307-415- 7g(1)(b))

I.T.3 Proceedings to reopen and issue a permit shall follow the same procedures as apply to
initial permit issuance and shall affect only those parts of this permit for which cause to
reopen exists. (R307-415-7g(2))

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

I.U Inventory Requirements.
An emission inventory shall be submitted in accordance with the procedures
of R307-150, Emission Inventories. (R307-150)

Status: In compliance – The 2023 tri-annual emission inventory was received on April
15, 2024. The 2026 tri-annual emission inventory will be due April 15, 2027. See
the SLEIS database and Emission Inventory below.

I.V Title IV and Other, More Stringent Requirements

Where an applicable requirement is more stringent than an applicable
requirement of regulations promulgated under Title IV of the Act, Acid
Deposition Control, both provisions shall be incorporated into this permit.
(R307-415-6a(1)(b))

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

12

SECTION II: SPECIAL PROVISIONS
II.A Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-wide

II.A.2 Pt-38: #1 Kiln & Baghouse
Kiln rated at 14.4 tons per hour raw feed, with a baghouse, separation cyclone, and air-to-air
heat exchanger. Fired on coal, with natural-gas during startups, shutdowns, and upset conditions.

II.A.3 Pt-52: #3 Kiln & Baghouse
Kiln rated at 14.4 tons per hour raw feed, with a baghouse, separation cyclone, and air-to-air
heat exchanger. Fired on coal, with natural-gas during startups, shutdowns, and upset
conditions.

II.A.4 Pt-45: #4 Kiln & Baghouse
Kiln rated at 14.4 tons per hour raw feed, installed in 1996. 40 CFR 60 Subpart UUU applies.
Includes baghouse and air-to-air heat exchanger. Fired on coal, with natural-gas during startups,
shutdowns, and upset conditions.

II.A.5 Pt-35: #1 Cooler
Cooler for #1 Kiln. No unit-specific applicable requirements.

II.A.6 Pt-49: #3 Cooler
Cooler for #3 Kiln. No unit-specific applicable requirements.

II.A.7 Pt-42: #4 Cooler
Cooler for #4 Kiln. No unit-specific applicable requirements.

II.A.8 Pt-57: Dust Tank & Baghouse
Dust tank with a baghouse to control emissions.

II.A.9 Pt-58: Dust Tank & Baghouse
Dust tank with a baghouse to control emissions. 40 CFR 60 Subpart OOO applies.

II.A.10 Pt-59: Emergency Generator
One diesel-fired emergency generator with a maximum rating of 84 kw (113 hp). 40 CFR
63 Subpart ZZZZ applies.

II.A.11 8: Coalmill
Coal mill roll crusher. Emissions from the pulverizer cyclones #1, #3, and #4 are vented to
kiln #1, #3, or #4, or cooler #1, #3, or #4.

II.A.12 10: Crushers
Various crushers including: Stamler Feeder/breaker, roll crushers, mouse roll crusher,
hammermill. 40 CFR 60 Subpart OOO applies to roll crushers constructed after Aug. 31,
1983.

13

II.A.13 11: Screens
Various screens including high frequency screens, finish screens, raw screen, extruder
screen, scalping screen, triple deck screen, and Seco screen. 40 CFR 60 Subpart OOO
applies to the finishing end triple deck screen, the coloring bunker warehouse single deck
screen, and the finishing end high frequency screen.

II.A.14 12: Conveyor Drop Points
Various drop points from conveyor.

II.A.15 13: Conveyor Transfer Points
Various transfer points on conveyors.

II.A.16 15: Mobile Equipment Operational Areas
Haul roads and yard areas.

II.A.17 16: Storage Piles
Piles of material in various degrees of processing.

II.A.18 17: Storage Tank
One 8,300 gal tank used to store diesel fuel. No unit-specific applicable requirements.

II.A.19 18: Bagging Operation
One bagging operation where lightweight aggregate is bagged for off-site shipment. 40 CFR 60
Subpart OOO applies. Construction commenced after April 22, 2008.

II.A.20 19: Coloring Bunker Warehouse
Warehouse where dyeing of lightweight aggregate takes place. No unit-specific applicable
requirements.

Status: In compliance – No unapproved equipment was noted at time of the inspection. The Pt-57
dust tank and baghouse (item II.A.8) is no longer in service. The Pt-58 dust tank and
baghouse (item II.A.9) is the new replacement. One direct fired coal mill with a baghouse,
out of a total of four coal mills (item II.A.11) is currently not operating. The extruder
system has not been used for about 15 years. The triple deck screen (item II.A.13) was
changed out with a Replacement-In-Kind (RIK) in August 2024. There are future plans to
replace the Stamler Feeder/Breaker and hammermill (item II.A.12) with a sizer rig
crusher. There are also plans to replace the vertical 8,300-gallon diesel storage tank (item
(II.A.18) with a horizontal 8,300-gallon diesel storage tank. These changes have not
occurred to date. See Experimental AO DAQE-AN106760031-24, DAQ
Replacement-In-Kind Notice DAQE-GN106760030-24 and Compliance Assistance below.

II.B Requirements and Limitations

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

14

II.B.1 Conditions on Permitted Source

II.B.1.a Condition:

Visible emissions shall be no greater than 20 percent opacity unless otherwise specified in this
permit. [Origin: DAQE-AN106760028-22]. [R307-401-8]

II.B.1.a.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed while the
emission unit is operating, on a monthly basis by an individual trained on the
observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions other
than condensed water vapor are observed from an emission unit, an opacity
determination of that emission unit shall be performed by a certified observer within 24
hours of the initial survey. The opacity determination shall be performed in accordance
with 40 CFR 60, Appendix A, Method 9 for point sources, and in accordance with 40
CFR 51, Appendix M, Method 203C for fugitive sources.

II.B.1.a.2 Recordkeeping:

The permittee shall record the date of each visual survey. The permittee shall also
keep a log of the following information for each observed visual emission: date and
time visual emissions observed, emission point location and description, time and
date of opacity determination, and percent opacity. The records required by this
provision and all data required by 40 CFR 60, Appendix A, Method 9 or by 40 CFR
51, Appendix M, Method 203C shall be maintained in accordance with Provision
I.S.1 of this permit.

II.B.1.a.3 Reporting:

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

Status: In compliance – Daily/monthly Method 22 visual opacity observations records were
reviewed at time of the inspection. According to the records no excessive opacity was
noted since the last inspection. Therefore, no Method 9 observation were conducted.
Observation records are maintained electronically and as hard copies. In the future,
records may be electronically saved in the Parasable Database.

II.B.1.b Condition:

The total raw feed to the three kilns shall not exceed 350,000 tons per rolling 12-month
period. [Origin: DAQE-AN106760028-22]. [R307-401-8]

15

II.B.1.b.1 Monitoring:

The daily raw feed shall be recorded and the total raw feed shall be calculated for each
calendar month. To demonstrate compliance with a rolling 12-month total, a new 12
month total shall be calculated no later than the 20th of each month, using data from the
previous 12 months.

II.B.1.b.2 Recordkeeping:

Records of production shall be kept on a daily basis in accordance with Provision I.S.1
of this permit, for all periods of operation.

II.B.1.b.3 Reporting:

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

Status: In compliance – The 12-month total raw feed, for the three kilns, as of April 25, 2025, was
156,139.8 tons.

II.B.1.c Condition:

The total operating hours for the three kilns shall not exceed 24,561 hours per rolling 12-month
period. [Origin: DAQE-AN106760028-22]. [R307-401-8]

II.B.1.c.1 Monitoring:

To demonstrate compliance with a rolling 12-month total, a new 12 month total shall
be calculated no later than the 20th of each month, using data from the previous 12
months. Hours of operation for the kilns shall be determined by supervisor monitoring
and by maintaining of an operations log.

II.B.1.c.2 Recordkeeping:

A log recording all hours of operation shall be maintained in accordance with
provision I.S.1 of this permit. The log shall include the results of required
monitoring.

II.B.1.c.3 Reporting:

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

Status: In compliance – The 12-month total operating hours, for the three kilns, as of April 25,
2025, was 16,774 hours.

II.B.1.d Condition:

The total raw feed to the three kilns shall not exceed 43.2 tons per hour. [Origin: DAQE-
AN106760028- 22]. [R307-401-8]

16

II.B.1.d.1 Monitoring:

The raw feed rate shall be determined using an operations log. The raw feed shall be
monitored on an hourly basis.

II.B.1.d.2 Recordkeeping:

Records of production shall be kept on an hourly basis, and a log shall be maintained of
all operating hours, in accordance with Provision I.S.1 of this permit, for all periods of
operation.

II.B.1.d.3 Reporting:

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

Status: In compliance – The daily kiln report confirms compliance with the condition. Each unit
typically runs about 10 tph.

II.B.1.e Condition:

Sulfur content of any coal or any mixture of coals shall be no greater than 0.75 pounds sulfur
per MM gross Btu heat input. [Origin: DAQE-AN106760028-22]. [R307-401-8]

II.B.1.e.1 Monitoring:

Sulfur content of coal shall be determined by ASTM Method D-4239-18 or approved
equivalent. The sulfur content shall be tested if directed by the Director.

II.B.1.e.2 Recordkeeping:

Compliance with the above limitation shall be demonstrated by maintaining fuel receipt
records showing sulfur content of the delivered fuel, gross heating value, and density or
maintaining records of all sulfur content testing performed on the delivered fuel. The
permittee shall keep records of the conversion of the lab analysis report to the units
specified in condition II.B.1.e. Records shall be maintained in accordance with
provision I.S.1 of this permit.

II.B.1.e.3 Reporting:

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

Status: In compliance – The mine analysis reports, from Westmoreland Kemmerer, Inc. and
Skyline Mine indicate that coal purchased in the past year has a sulfur content less than
0.75 pounds sulfur per MM gross Btu heat input. Mine analysis reports show sulfur
content in percentage. The facility converts the percentage to lbs sulfur per MM gross Btu
heat input. The equation used to confirm compliance is: (1,000,000 / BTU per lb.) X %
sulfur X .01 = Lbs. sulfur per MM BTU.

17

II.B.1.f Condition:

The concentration of contaminants or parameters in any used oil fuel burned for energy
recovery in the kilns shall not exceed the following levels:

Arsenic 5 ppm by weight,
Cadmium 2 ppm by weight,
Chromium 10 ppm by weight,
Lead 100 ppm by weight,
Total Halogens 1,000 ppm by weight,
Sulfur 0.5 percent by weight, and
Flash Point not less than 100 degrees F.

Used oil exceeding any of the above contaminants shall not be burned. Any used oil fuel
that contains more than 1,000 ppm by weight of total halogens shall be considered a
hazardous waste and shall not be burned in the kiln.

The permittee utilizing used oil as a fuel shall comply with the State Division of Waste
Management and Radiation Control in accordance with UAC R315-15.

[Origin: DAQE-AN106760028-22]. [R307-401-8]

II.B.1.f.1 Monitoring:

The permittee shall maintain test certification data for each load of used oil fuel
received. Certification shall be either by permittee testing or test reports provided by
the used oil fuel marketer. The used oil fuel shall be tested for halogen content by
ASTM Method D-808-81, EPA Method 8240 or Method 8260 before used oil fuel is
burned.

II.B.1.f.2 Recordkeeping:

Daily records of the quantity of used oil fuel combusted and the test reports shall be
kept for all periods when the plant is in operation. Records shall be made available to
the Director or the Director’s representative upon request. All records shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.1.f.3 Reporting:

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

Status: N/A – Holcim SWR has never burned any used fuel oil.

18

II.B.1.g Condition:

At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to
the extent practicable, maintain and operate any permitted plant equipment, including
associated air pollution control equipment, in a manner consistent with good air pollution
control practice for minimizing emissions. Determination of whether acceptable operating
and maintenance procedures are being used will be based on information available to the
Director which may include, but is not limited to, monitoring results, opacity observations,
review of operating and maintenance procedures, and inspection of the source. [Origin:
DAQE-AN106760028-22, 40 CFR 60 (Subpart A)]. [40 CFR 60.11(d), R307-401- 4, R307-
401-8(2)]

II.B.1.g.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.g.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and
maintenance. Records shall be maintained in accordance with Provision I.S.1 of this
permit.

II.B.1.g.3 Reporting:

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

Status: In compliance – Maintenance is performed at the on-site maintenance shop. Records for
as needed and preventative maintenance (PM) are kept as hard copies. There are future
plans to incorporate the maintenance records into the Limble database.

II.B.1.h Condition:

The permittee shall comply with the applicable requirements for recycling and emission
reduction for class I and class II refrigerants pursuant to 40 CFR 82, Subpart F - Recycling and
Emissions Reduction. [Origin: 40 CFR 82 Subpart F]. [40 CFR 82.150(b)]

II.B.1.h.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I
of this permit, its compliance status with the requirements of 40 CFR 82, Subpart F.

II.B.1.h.2 Recordkeeping:

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

19

II.B.1.h.3

Reporting:

All reports required in 40 CFR 82, Subpart F shall be submitted as required. There are
no additional reporting requirements except as outlined in Section I of this permit.
Status: In compliance – The most recent annual compliance certification indicates that the
Holcim SWR plant complies with 40 CFR 82, Subpart F. Air conditioner/refrigerant
work is completed by AMF Mechanical, on an as needed basis.

II.B.1.i Condition:

The permittee shall comply with the applicable requirements for servicing of motor vehicle
air conditioners pursuant to 40 CFR 82, Subpart B - Servicing of Motor Vehicle Air
Conditioners. [Origin: 40 CFR 82 Subpart B]. [40 CFR 82.30(b)]

II.B.1.i.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of
this permit, its compliance status with the requirements of 40 CFR 82, Subpart B.

II.B.1.i.2 Recordkeeping:

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

II.B.1.i.3 Reporting:

All reports required in 40 CFR 82, Subpart B shall be submitted as required. There are
no additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance – The most recent annual compliance certification indicates that the
Holcim SWR plant complies with 40 CFR 82, Subpart B. Heavy equipment and truck air
conditioners are serviced by a third party, on an as needed basis.

II.B.1.j Condition:

The sulfur content of any fuel oil or diesel burned shall not exceed 15 ppm by weight.
[Origin: DAQE- AN106760028-22]. [R307-401-8]

II.B.1.j.1 Monitoring:

Certification of fuels shall be either by permittee’s testing or test reports from the fuel
marketer.

For determining sulfur content in oil, ATM Method D4294-89, approved
equivalent, or other method acceptable to the Director is to be used. The sulfur
content shall be tested if directed by the Director.

20

II.B.1.j.2 Recordkeeping:

Compliance shall be demonstrated by maintaining fuel receipts records showing sulfur
content of the delivered fuel, or maintain records of all sulfur content tested performed
on the delivered fuel. Records shall be maintained in accordance with Provision I.S.1
of this permit.

II.B.1.j.3 Reporting:

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

Status: In compliance – The most recent Pilot Thomas invoice dated April 24, 2025, indicates that
Ultra Low Sulfur Diesel (ULSD) has been delivered to the plant.

II.B.1.k Condition:

The permittee shall route emissions from the kilns through a baghouse prior to venting to the
atmosphere. The bag material for all bags shall be the equivalent of P84 fabric or better. The
bags shall be pulsed in staggered order. The baghouses shall be sized for approximately 45,000
acfm and an air/cloth ratio of 7:1. [Origin: DAQE-AN106760028-22]. [R307-401-8]

II.B.1.k.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.k.2 Recordkeeping:

The permittee shall keep records of all occurrences that emissions are not routed
through a baghouse prior to venting to the atmosphere.

Records of bag filter fabric and pulsing order shall be maintained in accordance with
Provision I.S.1. of this permit.

II.B.1.k.3 Reporting:

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

Status: In compliance – This condition was evaluated during the permitting process. The kilns
appeared to be venting to the baghouses at time of the inspection. Daily records show that
P84 bags are installed.

II.B.2 Conditions on Pt-38: #1 Kiln & Baghouse

II.B.2.a Condition:

Emissions of PM10 shall be no greater than 3.34 lb/hr and 0.024 grains/dscf.
[Origin: DAQE- AN106760028-22]. [R307-401-8]

21

II.B.2.a.1 Monitoring:

(A) Stack testing shall be performed as specified below:

(i) Frequency. Emissions shall be tested every five years based on the date of
the last stack test. The Director may require testing at any time in
accordance with UAC R307-165.

(ii) Notification. The Director shall be notified at least 30 days prior to
conducting any required emission testing. A source test protocol shall be
submitted the Division of Air Quality (DAQ) when the testing notification is
submitted to the Director. The source test protocol shall be approved by the
Director prior to performing the tests. 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.

(iii) Methods.

(a) Sample Location - the emission point shall conform to the requirements
of 40 CFR 60, Appendix A, Method 1, or other EPA-approved testing
method, as acceptable to the Director. An Occupational Safety and
Health Administration (OSHA) approved access shall be provided to the
test location.

(b) For stacks in which no liquid drops are present, the following methods
shall be used: 40 CFR 51, Appendix M, Methods 201 or 201a, or other
EPA-approved testing method, as acceptable to the Director. If other
approved testing methods are used which cannot measure the PM10
fraction of the filterable particulate emissions, all of the filterable
particulate emissions shall be considered PM10. The back half
condensable shall also be tested using EPA-approved testing methods,
as acceptable to the Director.

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

(d) The back half condensibles shall not be used for compliance
demonstration but shall be used for inventory purposes.

22

(iv) 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.

(v) Production Rate During Testing. The production rate during all compliance
testing shall be no less than 90% of the maximum production achieved in the
previous three (3) years.

(vi) Volumetric Flow Rate: 40 CFR 60, Appendix A, Method 2.

(B) The permittee shall use three indicators as specified below to provide
reasonable assurance of compliance with the PM10 emission limitation.
(i) Measurement Approach

(a) Indicator No. 1: Visible emissions from the baghouse exhaust shall
be monitored using EPA Reference Method 22.

(b) Indicator No. 2: Pressure drop across each baghouse shall be
measured using a differential pressure gauge.

(c) Indicator No. 3: Baghouse inlet temperature shall be measured using a
temperature sensor.

(ii) Indicator Range:

Excursions are defined for each of the three indicators as follows. Each
excursion triggers an inspection, corrective action, and a reporting
requirement.

(a) Indicator No. 1: An excursion is defined as the presence of visible
emissions.

(b) Indicator No. 2: An excursion is defined as pressure drop outside the
range of 3 to 6 inches of water column in a one-hour period.

Provision II.B.2.a.1(B)(ii)(b) of this permit does not constitute a waiver, or
a shield against enforcement, of Provision II.B.2.d of this permit.

(c) Indicator No. 3: An excursion is defined as an inlet temperature outside
the range of 250 to 550 degrees F in a one-hour period.

Once every five years, during the stack test required in (A) above, the
permittee shall acquire new test data to evaluate or update the excursion values
for the three indicators. Any resultant changes to the monitoring shall be
addressed in accordance with 40 CFR 64.7(e).

23

(iii) Performance Criteria

(a) Data Representativeness:

(1) Indicator No. 1: Visible emissions shall be monitored at the
baghouse exhaust while the baghouse is operating.

(2) Indicator No. 2: The differential pressure gauge shall measure
pressure drop with pressure taps located at the inlet and outlet of
each baghouse. The minimum accuracy of the device shall be +/- 1.0
inch of water.

(3) Indicator No. 3: The temperature sensor shall be located at the
baghouse inlet. The reading shall be accurate to within +/- 5
degrees F.

(b) QA/QC Practices and Criteria:

(1) Indicator No. 1: The visible emissions observer shall be familiar
with EPA Reference Method 22 and shall follow Method 22
procedures. The permittee shall record all maintenance and
repair activities on the baghouses and monitoring system
(including date, time, and nature of the maintenance or repair).

(2) Indicator No. 2: The pressure gauge shall be calibrated according
to manufacturer's recommendations or at least annually. Pressure
taps shall be checked for plugging according to manufacturer's
recommendations or at least weekly. Operators will record all
maintenance and repair activities on the baghouses and
monitoring system (including date, time, and nature of the
maintenance or repair).

(3) Indicator No. 3: The temperature sensor shall be calibrated
according to manufacturer's recommendations or at least annually.
Operators will record all maintenance and repair activities on the
baghouses and monitoring system (including date, time, and
nature of the maintenance or repair).

(c) Monitoring Frequency:

(1) Indicator No. 1: The visible emissions observer shall
perform a 6-minute Method 22 observation once each day.
Indicator No. 2: Pressure drop shall be measured
continuously.

(2) Indicator No. 3: Baghouse inlet temperature shall be measured
continuously.

24

(d) Data Collection Procedure:

(1) Indicator No. 1: The permittee shall keep daily records of the
results of each visible emission observation.

(2) Indicator No. 2: Pressure drop shall be collected and recorded
once each hour the kiln operates for comparison to the indicator
range.

(3) Indicator No. 3: Inlet temperature shall be collected and recorded
once each hour the kiln operates for comparison to the indicator
range.

(e) Averaging Period:

(1) Indicator No. 1: N/A

(2) Indicator No. 2: N/A

(3) Indicator No. 3: N/A

II.B.2.a.2 Recordkeeping:

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

In addition to the recordkeeping requirement described in Provision I.S.1 of this
permit, the permittee shall maintain a file of the occurrence and duration of any
excursion, corrective actions taken, and any other supporting information required to
be maintained under 40 CFR 64 (such as data used to document the adequacy of
monitoring, or records of monitoring maintenance or corrective actions). Instead of
paper records, the permittee may maintain records on alternative media, such as
microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of
such alternative media allows for expeditious inspection and review, and does not
conflict with other applicable recordkeeping requirements. (40 CFR 64.9(b)).

II.B.2.a.3 Reporting:

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

(a) Monitoring reports shall include, at a minimum, the following
information, as applicable:

(i) Summary information on the number, duration and cause
(including unknown cause, if applicable) of excursions or
exceedances, as applicable, and the corrective actions taken;
(40 CFR 64.9(a)(2)(i))

25

(ii) Summary information on the number, duration and
cause (including unknown cause, if applicable) for monitor
downtime incidents (other than downtime associated with
zero and span or other daily calibration checks, if
applicable). (40 CFR 64.9(a)(2)(ii))

(b) The permittee shall submit the results of the stack tests to the
Director within 60 days of completion of the testing. Results
shall clearly identify test results as compared to permit limits
and indicate compliance status. Reports shall include any test
data and calculations used to evaluate or revise the indicator
range and excursion level.

Status: In compliance – Kiln #1 was PM10 stack tested July 10 and 11, 2024, with results of
0.0057 gr/dscf and 0.58 lbs/hour. Results were submitted, to DAQ, on August 9, 2024. The
last CAM report was received on April 11, 2025. The next stack test, for Kiln #1, is
scheduled for July 2029.

II.B.2.b Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-
AN106760028-22]. [R307-401-8]

II.B.2.b.1 Monitoring:

A visual observation of each affected emission unit shall be performed while the
emission unit is operating, once each month that the unit operates, by an individual
trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer (VEO). If any
visible emissions are observed, an opacity determination of that emission unit shall
be performed by a certified VEO in accordance with 40 CFR 60, Appendix A,
Method 9 within 24 hours of the initial observation.

II.B.2.b.2 Recordkeeping:

Results from opacity observations and all data required by 40 CFR 60, Appendix A,
Method 9 shall be recorded and maintained in accordance with Provision I.S.1 of this
permit.

II.B.2.b.3 Reporting:

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

Status: In compliance – Review of records confirmed compliance with this condition.
Daily/monthly observations are made. Kiln baghouse stack observations are maintained
in the Parsable database. See status of condition II.B.1.a.

26

II.B.2.c Condition:

The temperature in the baghouse shall be no less than 225 degrees F.

The baghouse shall be preheated to 225 degrees F prior to bringing the kilns into production.
[Origin: DAQE-AN106760028-22]. [R307-401-8]

II.B.2.c.1 Monitoring:

The temperature shall be monitored at all times. The monitoring equipment shall be
located such that an inspector can at any time safely read the output. The reading shall
be accurate to within ± 5 degrees F. All instances when the temperature in the
baghouse drops below 225 degrees F shall be recorded.

II.B.2.c.2 Recordkeeping:

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

II.B.2.c.3 Reporting:

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

Status: In compliance – Daily Kiln Reports indicated that the baghouse temperature is
monitored hourly during kiln operation. Records show no exceedances of the
temperature since the last inspection.

II.B.2.d Condition:

Differential pressure across the fabric filter of the baghouse shall be maintained between 3
inches and 6 inches water column. [Origin: DAQE-AN106760029-22]. [R307-401-8]

II.B.2.d.1 Monitoring:

Baghouse pressure drop shall be monitored weekly with a manometer or magnahelic
pressure gauge when the baghouse is operating. If the pressure differential is outside
the range, then the cause shall be investigated and corrective measures taken within
two hours of discovering the exceedance, to restore the pressure differential to within
the range. If the pressure drop is not returned to the range within two hours a
deviation has occurred. The pressure gauge shall be located such that an inspector
/operator can safely read the indicator at any time. The reading shall be accurate to
within plus or minus 1.0 inches of water. The instrument shall be calibrated against a
primary standard annually.

II.B.2.d.2 Recordkeeping:

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

27

II.B.2.d.3 Reporting:

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

Status: In compliance – Daily Kiln Reports indicated that the differential pressure (dp) of the
baghouse is monitored hourly during kiln operation. Records show no exceedances of the
dp since the last inspection.

II.B.3 Conditions on Pt-52: #3 Kiln & Baghouse

II.B.3.a Condition:

Emissions of PM10 shall be no greater than 3.34 lb/hr and 0.024 grains/dscf.
[Origin: DAQE- AN106760028-22]. [R307-401-8]

II.B.3.a.1 Monitoring:

(A) Stack testing shall be performed as specified below:

(i) Frequency. Emissions shall be tested every five years based on the
date of the last stack test. The Director may require testing at any
time in accordance with UAC R307-165.

(ii) Notification. The Director shall be notified at least 30 days prior to
conducting any required emission testing. A source test protocol
shall be submitted the Division of Air Quality (DAQ) when the
testing notification is submitted to the Director. The source test
protocol shall be approved by the Director prior to performing the
tests. 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.

(iii) Methods.

(a) Sample Location - the emission point shall conform to
the requirements of 40 CFR 60, Appendix A, Method 1,
or other EPA-approved testing method, as acceptable to
the Director. An Occupational Safety and Health
Administration (OSHA) approved access shall be
provided to the test location.

(b) For stacks in which no liquid drops are present, the
following methods shall be used: 40 CFR 51, Appendix
M, Methods 201 or 201a, or other EPA-approved testing
method, as acceptable to the Director. If other approved
testing methods are used which cannot measure the
PM10 fraction of the filterable particulate emissions, all
of the filterable particulate emissions shall be considered

28

PM10. The back half condensable shall also be tested
using EPA-approved testing methods, as acceptable to
the Director.

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

(d) The back half condensibles shall not be used for
compliance demonstration but shall be used for inventory
purposes.

(iv) 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.

(v) Production Rate During Testing. The production rate during
all compliance testing shall be no less than 90% of the
maximum production achieved in the previous three (3)
years.

(vi) Volumetric Flow Rate: 40 CFR 60, Appendix A, Method 2.

(B) The permittee shall use three indicators as specified below to provide
reasonable assurance of compliance with the PM10 emission limitation.
(i) Measurement Approach

(a) Indicator No. 1: Visible emissions from the
baghouse exhaust shall be monitored using EPA
Reference Method 22.

(b) Indicator No. 2: Pressure drop across each
baghouse shall be measured using a differential
pressure gauge.

(c) Indicator No. 3: Baghouse inlet temperature shall be
measured using a temperature sensor.

29

(ii) Indicator Range:

Excursions are defined for each of the three indicators
as follows. Each excursion triggers an inspection,
corrective action, and a reporting requirement.

(a) Indicator No. 1: An excursion is defined as the presence
of visible emissions.

(b) Indicator No. 2: An excursion is defined as pressure
drop outside the range of 3 to 6 inches of water column
in a one-hour period.

Provision II.B.2.a.1(B)(ii)(b) of this permit does not
constitute a waiver, or a shield against enforcement, of
Provision II.B.2.d of this permit.

c) Indicator No. 3: An excursion is defined as an inlet
temperature outside the range of 250 to 550 degrees F in
a one-hour period.

Once every five years, during the stack test required in (A)
above, the permittee shall acquire new test data to evaluate
or update the excursion values for the three indicators. Any
resultant changes to the monitoring shall be addressed in
accordance with 40 CFR 64.7(e).

(iii) Performance Criteria

(a) Data Representativeness:

(1) Indicator No. 1: Visible emissions shall be
monitored at the baghouse exhaust while the
baghouse is operating.

(2) Indicator No. 2: The differential pressure gauge
shall measure pressure drop with pressure taps
located at the inlet and outlet of each baghouse.
The minimum accuracy of the device shall be +/-
1.0 inch of water.

(3) Indicator No. 3: The temperature sensor shall be
located at the baghouse inlet. The reading shall
be accurate to within +/- 5 degrees F.

(b) QA/QC Practices and Criteria:

30

(1) Indicator No. 1: The visible emissions
observer shall be familiar with EPA Reference
Method 22 and shall follow Method 22
procedures. The permittee shall record all
maintenance and repair activities on the
baghouses and monitoring system (including
date, time, and nature of the maintenance or
repair).

(2) Indicator No. 2: The pressure gauge shall be
calibrated according to manufacturer's
recommendations or at least annually. Pressure
taps shall be checked for plugging according to
manufacturer's recommendations or at least
weekly. Operators will record all maintenance
and repair activities on the baghouses and
monitoring system (including date, time, and
nature of the maintenance or repair).

(3) Indicator No. 3: The temperature sensor shall be
calibrated according to manufacturer's
recommendations or at least annually. Operators
will record all maintenance and repair activities
on the baghouses and monitoring system
(including date, time, and nature of the
maintenance or repair).

(c) Monitoring Frequency:

(1) Indicator No. 1: The visible emissions
observer shall perform a 6-minute Method
22 observation once each day.

(2) Indicator No. 2: Pressure drop shall be measured
continuously.

(3) Indicator No. 3: Baghouse inlet temperature shall be
measured continuously.

(d) Data Collection Procedure:
(1) Indicator No. 1: The permittee shall keep
daily records of the results of each visible
emission observation.

(2) Indicator No. 2: Pressure drop shall be
collected and recorded once each hour the kiln
operates for comparison to the indicator range.

31

(3) Indicator No. 3: Inlet temperature shall be
collected and recorded once each hour the kiln
operates for comparison to the indicator range.

(e) Averaging Period:

(1) Indicator No. 1: N/A

(2) Indicator No. 2: N/A

(3) Indicator No. 3: N/A

II.B.3.a.2 Recordkeeping:

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

In addition to the recordkeeping requirement described in Provision I.S.1 of this
permit, the permittee shall maintain a file of the occurrence and duration of any
excursion, corrective actions taken, and any other supporting information required to
be maintained under 40 CFR 64 (such as data used to document the adequacy of
monitoring, or records of monitoring maintenance or corrective actions). Instead of
paper records, the permittee may maintain records on alternative media, such as
microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of
such alternative media allows for expeditious inspection and review, and does not
conflict with other applicable recordkeeping requirements. (40 CFR 64.9(b)).

II.B.3.a.3 Reporting:

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

(A) Monitoring reports shall include, at a minimum, the following
information, as applicable:

(i) Summary information on the number, duration and
cause (including unknown cause, if applicable) of
excursions or exceedances, as applicable, and the
corrective actions taken; (40 CFR 64.9(a)(2)(i))

(ii) Summary information on the number, duration and
cause (including unknown cause, if applicable) for monitor
downtime incidents (other than downtime associated with
zero and span or other daily calibration checks, if
applicable). (40 CFR 64.9(a)(2)(ii))

32

(B) The permittee shall submit the results of the stack tests to
the Director within 60 days of completion of the testing. Results
shall clearly identify test results as compared to permit limits and
indicate compliance status. Reports shall include any test data and
calculations used to evaluate or revise the indicator range and
excursion level.

Status: In compliance – Kiln #3 was PM10 stack tested July 10 and 11, 2024, with results of
0.0061 gr/dscf and 0.74 lbs/hour. Results were submitted, to the DAQ, on August 9, 2024.
The last CAM report was received on April 11, 2025. The next stack test, for Kiln #3, is
scheduled for July 2029.

II.B.3.b Condition:

Visible emissions shall be no greater than 10 percent opacity.
[Origin: DAQE-AN106760028-22]. [R307-401-8]

II.B.3.b.1 Monitoring:

A visual observation of each affected emission unit shall be performed while the
emission unit is operating, once each month that the unit operates, by an individual
trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer (VEO). If any
visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9
within 24 hours of the initial observation.

II.B.3.b.2 Recordkeeping:

Results from opacity observations and all data required by 40 CFR 60, Appendix A,
Method 9 shall be recorded and maintained in accordance with Provision I.S.1 of this
permit.

II.B.3.b.3 Reporting:

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

Status: In compliance – Review of records confirmed compliance with this condition.
Daily/monthly observations are made. Kiln baghouse stack observations are maintained
in the Parsable database. See status of condition II.B.1.a.

II.B.3.c Condition:

The temperature in the baghouse shall be no less than 225 degrees F.

The baghouse shall be preheated to 225 degrees F prior to bringing the kiln into production.
[Origin: DAQE-AN106760028-22]. [R307-401-8]

33

II.B.3.c.1 Monitoring:

The temperature shall be monitored at all times. The monitoring equipment shall be located
such that an inspector can at any time safely read the output. The reading shall be accurate to
within + or - 5 degrees F. All instances when the temperature in the baghouse drops below
225 degrees F shall be recorded.

II.B.3.c.2 Recordkeeping:

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

II.B.3.c.3 Reporting:

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

Status: In compliance – Daily Kiln Reports indicated that the baghouse temperature is
monitored hourly during kiln operation. Records show no exceedances of the
temperature since the last inspection.

II.B.3.d Condition:

Differential pressure across the fabric filter of the baghouse shall be maintained between 3
inches and 6 inches water column. [Origin: DAQE-AN106760028-22]. [R307-401-8]

II.B.3.d.1 Monitoring:

Baghouse pressure drop shall be monitored weekly with a manometer or magnahelic
pressure gauge when the baghouse is operating. If the pressure differential is outside the
range, then the cause shall be investigated and corrective measures taken within two hours
of discovering the exceedance, to restore the pressure differential to within the range. If
the pressure drop is not returned to the range within two hours a deviation has occurred.
The pressure gauge shall be located such that an inspector /operator can safely read the
indicator at any time. The reading shall be accurate to within plus or minus 1.0 inches of
water. The instrument shall be calibrated against a primary standard annually.

II.B.3.d.2 Recordkeeping:

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

II.B.3.d.3 Reporting:

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

Status: In compliance – Daily Kiln Reports indicated that the differential pressure (dp) of the
baghouse is monitored hourly during kiln operation. Records show no exceedances of the
dp since the last inspection.

34

II.B.4 Conditions on Pt-45: #4 Kiln & Baghouse

II.B.4.a Condition:

Emissions of PM10 shall be no greater than 3.34 lb/hr and 0.024 grains/dscf.
[Origin: DAQE- AN106760028-22]. [40 CFR 60 Subpart UUU, R307-401-8]

II.B.4.a.1 Monitoring:

(A) Stack testing shall be performed as specified below:

(i) Frequency. Emissions shall be tested every five years
based on the date of the last stack test. The Director may
require testing at any time in accordance with UAC R307-
165.

(ii) Notification. The Director shall be notified at least 30 days
prior to conducting any required emission testing. A source
test protocol shall be submitted the Division of Air Quality
(DAQ) when the testing notification is submitted to the
Director. The source test protocol shall be approved by the
Director prior to performing the tests. 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.

(iii) Methods.

(a) Sample Location - the emission point shall conform to
the requirements of 40 CFR 60, Appendix A, Method
1, or other EPA-approved testing method, as
acceptable to the Director. An Occupational Safety
and Health Administration (OSHA) approved access
shall be provided to the test location.

(b) For stacks in which no liquid drops are present, the
following methods shall be used: 40 CFR 51, Appendix
M, Methods 201 or 201a, or other EPA-approved
testing method, as acceptable to the Director. If other
approved testing methods are used which cannot
measure the PM10 fraction of the filterable particulate
emissions, all of the filterable particulate emissions
shall be considered PM10 . The back half condensable
shall also be tested using EPA-approved testing
methods, as acceptable to the Director.

35

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

(d) The back half condensibles shall not be used for
compliance demonstration but shall be used for
inventory purposes.

(iv) 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.

(v) Production Rate During Testing. The production rate
during all compliance testing shall be no less than 90% of
the maximum production achieved in the previous three (3)
years.

(vi) Volumetric Flow Rate: 40 CFR 60, Appendix A, Method 2.

(B) The permittee shall use three indicators as specified below to
provide reasonable assurance of compliance with the PM10
emission limitation.
(i) Measurement Approach

(a) Indicator No. 1: Visible emissions from the
baghouse exhaust shall be monitored using EPA
Reference Method 22.

(b) Indicator No. 2: Pressure drop across each
baghouse shall be measured using a differential
pressure gauge.

(c) Indicator No. 3: Baghouse inlet temperature shall be
measured using a temperature sensor.

36

(ii) Indicator Range:

Excursions are defined for each of the three indicators
as follows. Each excursion triggers an inspection,
corrective action, and a reporting requirement.

(a) Indicator No. 1: An excursion is defined as the presence
of visible emissions.

(b) Indicator No. 2: An excursion is defined as pressure
drop outside the range of 3 to 6 inches of water column
in a one-hour period.

Provision II.B.2.a.1(B)(ii)(b) of this permit does not
constitute a waiver, or a shield against enforcement, of
Provision II.B.2.d of this permit.

(c) Indicator No. 3: An excursion is defined as an inlet
temperature outside the range of 250 to 550 degrees F
in a one-hour period.

Once every five years, during the stack test required in (A)
above, the permittee shall acquire new test data to evaluate
or update the excursion values for the three indicators. Any
resultant changes to the monitoring shall be addressed in
accordance with 40 CFR 64.7(e).

(iii) Performance Criteria

(1) Data Representativeness:

(1) Indicator No. 1: Visible emissions shall be
monitored at the baghouse exhaust while the
baghouse is operating.

(2) Indicator No. 2: The differential pressure gauge
shall measure pressure drop with pressure taps
located at the inlet and outlet of each baghouse.
The minimum accuracy of the device shall be +/-
1.0 inch of water.

(3) Indicator No. 3: The temperature sensor shall be
located at the baghouse inlet. The reading shall
be accurate to within +/- 5 degrees F.

37

(b) QA/QC Practices and Criteria:

(1) Indicator No. 1: The visible emissions
observer shall be familiar with EPA Reference
Method 22 and shall follow Method 22
procedures. The permittee shall record all
maintenance and repair activities on the
baghouses and monitoring system (including
date, time, and nature of the maintenance or
repair).

(2) Indicator No. 2: The pressure gauge shall be
calibrated according to manufacturer's
recommendations or at least annually. Pressure
taps shall be checked for plugging according to
manufacturer's recommendations or at least
weekly. Operators will record all maintenance
and repair activities on the baghouses and
monitoring system (including date, time, and
nature of the maintenance or repair).

(3) Indicator No. 3: The temperature sensor shall be
calibrated according to manufacturer's
recommendations or at least annually. Operators
will record all maintenance and repair activities
on the baghouses and monitoring system
(including date, time, and nature of the
maintenance or repair).

(c) Monitoring Frequency:

(1) Indicator No. 1: The visible emissions
observer shall perform a 6-minute Method
22 observation once each day.

(2) Indicator No. 2: Pressure drop shall be measured
continuously.

(3) Indicator No. 3: Baghouse inlet temperature shall be
measured continuously.

(d) Data Collection Procedure:

(1) Indicator No. 1: The permittee shall keep
daily records of the results of each visible
emission observation.

38

(2) Indicator No. 2: Pressure drop shall be
collected and recorded once each hour the kiln
operates for comparison to the indicator range.

(3) Indicator No. 3: Inlet temperature shall be
collected and recorded once each hour the kiln
operates for comparison to the indicator range.

(e) Averaging Period:

(1) Indicator No. 1: N/A

(2) Indicator No. 2: N/A

(3) Indicator No. 3: N/A

II.B.4.a.2 Recordkeeping:

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

In addition to the recordkeeping requirement described in Provision I.S.1 of this
permit, the permittee shall maintain a file of the occurrence and duration of any
excursion, corrective actions taken, and any other supporting information required to
be maintained under 40 CFR 64 (such as data used to document the adequacy of
monitoring, or records of monitoring maintenance or corrective actions). Instead of
paper records, the permittee may maintain records on alternative media, such as
microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of
such alternative media allows for expeditious inspection and review, and does not
conflict with other applicable recordkeeping requirements. (40 CFR 64.9(b)).

II.B.4.a.3 Reporting:

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

(A) Monitoring reports shall include, at a minimum, the following information, as
applicable:

(i) Summary information on the number, duration and cause (including
unknown cause, if applicable) of excursions or exceedances, as applicable,
and the corrective actions taken; (40 CFR 64.9(a)(2)(i))

(ii) Summary information on the number, duration and cause (including
unknown cause, if applicable) for monitor downtime incidents (other than
downtime associated with zero and span or other daily calibration checks, if
applicable). (40 CFR 64.9(a)(2)(ii))

39

(B) The permittee shall submit the results of the stack tests to the Director within 60
days of completion of the testing. Results shall clearly identify test results as
compared to permit limits and indicate compliance status. Reports shall include
any test data and calculations used to evaluate or revise the indicator range and
excursion level.

Status: In compliance – Kiln #4 was PM10 stack tested June 6, 2023, with results of 0.0130
gr/dscf and 1.43 lbs/hour. Results were submitted to DAQ, on August 4, 2023,
(DAQC-1578-19). The last CAM report was received on April 11, 2025. The next stack
test, for Kiln #4, is scheduled for July 2028.

II.B.4.b Condition:

Emissions of NOx shall be no greater than 20.0 lb/hr. [Origin: DAQE-AN106760028-22]
[R307-401-8]

II.B.4.b.1 Monitoring:

Stack testing shall be performed as specified below:

(A) Frequency. Emissions shall be tested every three years. The Director may
require testing at any time in accordance with UAC R307-165
(B) Notification. At least 30 days before the test, the source shall notify the
Director of the date, time, and place of testing and provide a copy of the test
protocol. The source shall attend a pretest conference if determined necessary
by the Director.
(C) Methods.
(i) Sample Location - the emission point shall conform to the requirements
of 40 CFR 60, Appendix A, Method 1, and Occupational Safety and
Health Administration (OSHA) approved access shall be provided to the
test location.
(ii) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, 7E, or other EPA
approved method as acceptable to the Director shall be used to determine
the pollutant emission rate.
(iii) 40 CFR 60, Appendix A, Method 2 shall be used to determine the volumetric
flow rate.

(D) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant
concentration as determined by the appropriate methods above shall be
multiplied by the volumetric flow rate and any necessary conversion factors
determined by the Director to give the results in the specified units of the
emission limitation.
(E) Production Rate During Testing. The production rate during all compliance
testing shall be no less than 90% of the maximum production achieved in the
previous three (3) years.

40

II.B.4.b.2 Recordkeeping:

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

II.B.4.b.3 Reporting:

In addition to the reporting requirements of Section I of this permit, the permittee
shall submit the results of the stack tests to the Director within 60 days of completion
of the testing. Results shall clearly identify test results as compared to permit limits
and indicate compliance status.

Status: In compliance – Kiln #4 was NOx stack tested on June 6, 2023, with DAQ evaluated
results of 18.5 lbs/hour. Results were submitted, to the DAQ, on August 4, 2023. The next
stack test, for Kiln #4, is scheduled for July 2026.

II.B.4.c Condition:

Visible emissions shall be no greater than 10 percent opacity. [Origin: DAQE-AN106760028-
22]. [R307-401-8]

II.B.4.c.1 Monitoring:

A visual observation of each affected emission unit shall be performed while the
emission unit is operating, once each month that the unit operates, by an individual
trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer (VEO). If any
visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9
within 24 hours of the initial observation.

II.B.4.c.2 Recordkeeping:

Results from opacity observations and all data required by 40 CFR 60, Appendix A,
Method 9 shall be recorded and maintained in accordance with Provision I.S.1 of this
permit.

II.B.4.c.3 Reporting:

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

Status: In compliance – Review of records confirmed compliance with this condition.
Daily/monthly observations are made. Kiln baghouse stack observations are maintained
in the Parsable database. See status of condition II.B.1.a.

41

II.B.4.d Condition:

The temperature in the baghouse shall be no less than 225 degrees F.

The baghouses shall be preheated to 225 degrees F prior to bringing the kilns into
production. [Origin: DAQE-AN106760028-22]. [R307-401-8]

II.B.4.d.1 Monitoring:

The temperature shall be monitored at all times. The monitoring equipment shall be
located such that an inspector can at any time safely read the output. The reading shall
be accurate to within + or - 5 degrees F. All instances when the temperature in the
baghouse drops below 225 degrees F shall be recorded.

II.B.4.d.2 Recordkeeping:

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

II.B.4.d.3 Reporting:

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

Status: In compliance – Daily Kiln Reports indicated that the baghouse temperature is
monitored hourly during kiln operation. Records show no exceedances of the
temperature since the last inspection.

II.B.4.e Condition:

Differential pressure across the fabric filter of the baghouse shall be maintained between 3
inches and 6 inches water column. [Origin: DAQE-AN106760028-22]. [R307-401-8]

II.B.4.e.1 Monitoring:

Baghouse pressure drop shall be monitored weekly with a manometer or magnahelic
pressure gauge when the baghouse is operating. If the pressure differential is outside
the range, then the cause shall be investigated and corrective measures taken within
two hours of discovering the exceedance, to restore the pressure differential to within
the range. If the pressure drop is not returned to the range within two hours a
deviation has occurred. The pressure gauge shall be located such that an inspector
/operator can safely read the indicator at any time. The reading shall be accurate to
within plus or minus 1.0 inches of water. The instrument shall be calibrated against a
primary standard annually.

II.B.4.e.2 Recordkeeping:

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

42

II.B.4.e.3 Reporting:

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

Status: In compliance – Daily Kiln Reports indicated that the differential pressure (dp) of the
baghouse is monitored hourly during kiln operation. Records show no exceedances of the
dp since the last inspection.

II.B.5 Conditions on Pt-57 and Pt-58: Dust tanks & Baghouses

II.B.5.a Condition:

Visible emissions for Pt-57 shall be no greater than 10 percent opacity. [Origin: DAQE-
AN106760028- 22]. [R307-401-8]

II.B.5.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed while the
emission unit is operating, once each month that the unit operates, by an individual
trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer (VEO). If any
visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9
within 24 hours of the initial observation.

II.B.5.a.2 Recordkeeping:

Results from opacity observations and all data required by 40 CFR 60, Appendix A,
Method 9 shall be recorded and maintained in accordance with Provision I.S.1 of this
permit.

II.B.5.a.3 Reporting:

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

Status: N/A – The Pt-57 dust tank and baghouse have not operated for years. See status of
condition II.A.

II.B.5.b Condition:

Visible emissions for Pt-58 shall be no greater than 7 percent opacity from baghouse stacks.
[Origin: 40 CFR 60, Subpart OOO]. [40 CFR Part 60.672(f), and 40 CFR Part 60 Table 2]

43

II.B.5.b.1 Monitoring:

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

II.B.5.b.2 Recordkeeping:

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

II.B.5.b.3 Reporting:

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

Status: In compliance – Review of records confirmed compliance with this condition. Daily/
monthly observations are made. See status of condition II.B.1.a.

II.B.6 Conditions on Pt-59: Emergency Generator

II.B.6.a Condition:

The permittee of affected emission units with a displacement of less than 30 liters per
cylinder that operate for the purpose specified in 40 CFR 63.6640(f)(ii) shall use diesel
fuel that meets the following per gallon standards of 40 CFR 1090.305 for nonroad diesel
fuel:

(A) Sulfur content no greater than 15 ppm (0.0015 percent) by weight and

(B) A minimum cetane index of 40 or a maximum aromatic content of 35 volume percent.

The sulfur content of any fuel oil burned shall not exceed 15 ppm by weight.

[Origin: 40 CFR 63.6604(b) and DAQE-AN106760028-22]. [40 CFR 63 Subpart ZZZZ, R307-
401-8]

II.B.6.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

44

II.B.6.a.2 Recordkeeping:

For each fuel load received, the permittee shall maintain either fuel receipt records or
other documentation showing fuel meets the specifications of ASTM D975 for the
cetane index and sulfur content for Grades No. 1-D S15 or 2-D S15 diesel. Sulfur
content shall be determined by ASTM Method D-4294-89 or approved equivalent.
The permittee shall maintain documentation demonstrating compliance with the
condition. These records shall be maintained in accordance with Provision I.S.1. of
this permit.

II.B.6.a.3 Reporting:

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

Status: In compliance – According to the recent Quarterly Fuel Analysis, published by Mohawk
Labs, cetane is > 40. The most recent Pilot Thomas invoice dated April 24, 2025, indicates
that Ultra Low Sulfur Diesel (ULSD) is used. See status of condition II.B.1.j.

II.B.6.b Condition:

The permittee shall comply with the following operating limitations at all times for each
affected emission unit: [63.6605(a)]

(A) The permittee shall operate the affected emission unit according to the requirements in
paragraphs (A)(i) through (A)(iii). Any operation other than emergency operation,
maintenance and testing, and operation in non-emergency situations for 50 hours per
year, as described in (A)(i) through (A)(iii), is prohibited. If the engine is not operated in
accordance with paragraphs (A)(i) through (A)(iii), it will not be considered an
emergency engine and shall meet all requirements for non-emergency engines.

(i) There is no time limit on the use of emergency stationary RICE in emergency
situations.
(ii) Emergency stationary RICE may be operated for any combination of the purposes
specified in (A)(ii)(1) below, for a maximum of 100 hours per calendar year. Any
operation for non- emergency situations as allowed by paragraph (A)(iii) counts
as part of the 100 hours per calendar year allowed by this condition.
(1) Emergency stationary RICE may be operated for maintenance checks and
readiness testing, provided that the tests are recommended by federal, state or
local government, the manufacturer, the vendor, the regional transmission
organization or equivalent balancing authority and transmission operator, or
the insurance company associated with the engine. The permittee may petition
the Director for approval of additional hours to be used for maintenance checks
and readiness testing, but a petition is not required if the permittee maintains
records indicating that federal, state, or local standards require maintenance
and testing of emergency RICE beyond 100 hours per calendar year.
(iii) The permittee may operate the affected emission unit up to 50 hours per year in
non-emergency situations, but those 50 hours are counted towards the 100 hours
per calendar year provided for maintenance and testing. The 50 hours per year for
non-emergency situations cannot be used for peak shaving or non-emergency

45

demand response, or to generate income for a facility to supply power to an electric
grid or otherwise supply power as part of a financial arrangement with another
entity.

(B) The permittee shall meet the following requirements at all times, except during periods of
startup:

(i) Change oil and filter every 500 hours of operation or annually, whichever comes first;
(ii) Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first,
and replace as necessary;
(iii) Inspect all hoses and belts every 500 hours of operation or annually, whichever
comes first, and replace as necessary. [40 CFR 63 Subpart ZZZZ Table 2d]

(C) During periods of startup, the permittee shall minimize the engine's time spent at idle
and minimize the engine's startup time to a period needed for appropriate and safe
loading of the engine, not to exceed 30 minutes, after which time the non-startup
emission limitations apply.
(D) The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15
as identified in Table 8 of 40 CFR 63 Subpart ZZZZ.
(E) The permittee has the option to utilize an oil analysis program as described in 40 CFR
63.6625(i) in order to extend the specified oil change requirement in paragraph (B)(i) of
this condition.

[Origin: 40 CFR 63 Subpart ZZZZ]. [40 CFR 63 Subpart ZZZZ (Table 2d(4)), 40 CFR 63
Subpart ZZZZ Table 8, 40 CFR 63.6595(a)(1), 40 CFR 63.6605(a), 40 CFR 63.6625(h),
40 CFR 63.6640(f), 40 CFR 63.6665]

II.B.6.b.1 Monitoring:

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

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

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

46

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

II.B.6.b.2 Recordkeeping:

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

The permittee shall keep records of the hours of operation of the engine that is
recorded through the non-resettable hour meter. The permittee shall document how
many hours are spent for emergency operation, including what classified the
operation as emergency and how many hours are spent for non-emergency operation.
If the engine is used for the purposes specified in 40 CFR 63.6640(f)(4)(ii), the
permittee shall keep records of the notification of the emergency situation, and the
date, start time, and end time of engine operation for these purposes. [40 CFR
63.6655(f)]

If additional hours are to be used for maintenance checks and readiness testing, the
permittee may petition the Director for approval of additional hours to be used for
maintenance checks and readiness testing, but a petition is not required if the
permittee maintains records indicating that federal, state, or local standards require
maintenance and testing of emergency RICE beyond 100 hours per calendar year. [40
CFR 63.6640(f)(2)(i)]

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

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

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

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

II.B.6.b.3 Reporting:

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

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

47

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

Status: In compliance – The emergency generator operates for emergencies and for maintenance
checks. Maintenance checks are conducted 15 minutes per week. A non-resettable hour
meter is installed on the engine. Hours of operation are as follows:

Calendar Year 2024 Hours Calendar Year 2025 Hours (To Date)
Emergency 16.6 Emergency 1.8
Maintenance 10.4 Maintenance 4.0

II.B.6.c

Condition:

The permittee shall operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety
and good air pollution control practices for minimizing emissions. The general duty to
minimize emissions does not require the permittee to make any further efforts to reduce
emissions if levels required by this standard have been achieved. Determination of whether
such operation and maintenance procedures are being used will be based on information
available to the Director which may include, but is not limited to, monitoring results,
review of operation and maintenance procedures, review of operation and maintenance
records, and inspection of the source. [Origin: 40 CFR 63 Subpart ZZZZ].
[40 CFR 63.6605(b)]

II.B.6.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.6.c.2 Recordkeeping:

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

The permittee shall document activities performed to assure proper operation and
maintenance.

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

II.B.6.c.3 Reporting:

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

Status:

In compliance – According to the maintenance records, maintenance was last performed,
in-house, on August 2024.

48

II.B.6.d Condition:

Visible emissions shall be no greater than 20 percent opacity.
[Origin: DAQE-AN106760028-22]. [R307-401-8]

II.B.6.d.1 Monitoring:

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

II.B.6.d.2 Recordkeeping:

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

II.B.6.d.3 Reporting:

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

Status: In compliance – Review of records confirmed compliance with this condition. Daily/
monthly observations are made. See status of condition II.B.1.a.

II.B.6.e Condition:

The permittee shall not consume more than 2,500 gallons of fuel oil per rolling 12-month
period for the diesel generator. [Origin: DAQE-AN106760028-22]. [R307-401-8]

II.B.6.e.1 Monitoring:

The daily use of fuel oil consumed in the generator shall be recorded and the total fuel
oil use shall be calculated for each calendar month. No later than the 20th of each
month, a new 12- month total shall be calculated using data from the previous 12
months.

49

II.B.6.e.2 Recordkeeping:

Records of fuel oil use shall be kept on a daily basis in accordance with Provision
I.S.1 of this permit, for all periods of operation. Fuel oil consumed in the generator
shall be determined by supervisor monitoring and by maintaining of an operations log.

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

II.B.6.e.3 Reporting:

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

Status: In compliance – The emergency generator fuel usage as of April 25, 2025, has not been
exceeded.

II.B.7 Conditions on 10: Crushers

II.B.7.a Condition:

Unless otherwise stated in this permit, visible emissions shall be no greater than 15
percent opacity. [Origin: DAQE-AN106760028-22]. [R307-401-8, R307-201]

II.B.7.a.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed while the
emission unit is operating, on a monthly basis by an individual trained on the
observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions
other than condensed water vapor are observed from an emission unit, an opacity
determination of that emission unit shall be performed by a certified observer within
24 hours of the initial survey. The opacity determination shall be performed in
accordance with 40 CFR 60, Appendix A, Method 9 for point sources, and in
accordance with 40 CFR 51, Appendix M, Method 203C for fugitive sources.

II.B.7.a.2 Recordkeeping:

The permittee shall record the date of each visual survey. The permittee shall also
keep a log of the following information for each observed visual emission: date and
time visual emissions observed, emission point location and description, time and
date of opacity determination, and percent opacity. The records required by this
provision and all data required by 40 CFR 60, Appendix A, Method 9 or by 40 CFR
51, Appendix M, Method 203C shall be maintained in accordance with Provision
I.S.1 of this permit.

50

II.B.7.a.3 Reporting:

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

Status: In compliance – Review of records confirmed compliance with this condition. Daily/
monthly observations are made. See status of condition II.B.1.a.

II.B.7.b Condition:

The permittee shall operate water sprays or chemical dust suppression sprays as appropriate to
control fugitive emissions. The sprays shall operate whenever dry conditions warrant or as
determined necessary by the Director. Water sprays shall not be required during periods of
freezing temperatures. [Origin: DAQE-AN106760028-22]. [R307-401-8]

II.B.7.b.1 Monitoring:

Visible inspections of the water or chemical dust suppression spray system(s) shall be
made monthly to ensure proper operating condition.

II.B.7.b.2 Recordkeeping:

Records of treatments shall be kept for all periods including the following items: date,
number of treatments made, dilution rate, and quantity, and the time of day treatments
were made. In addition, records of days of freezing temperature shall be kept. Records
of water or chemical dust suppression spray system inspection shall be kept for all
periods of operation. Records shall be maintained in accordance with provision I.S.1
of this permit.

II.B.7.b.3 Reporting:

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

Status: In compliance – Water sprays are strategically located to control fugitive emissions from
the crushers. Water spray usage records are maintained.

II.B.7.c Condition:

Visible emissions for crushers installed after April 22, 2008 shall be no greater than 12 percent
opacity. [Origin: 40 CFR 60 Subpart OOO]. [40 CFR 60.672(b), 40 CFR 60 Subpart OOO
Table 3]

II.B.7.c.1 Monitoring:

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

51

II.B.7.c.2 Recordkeeping:

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

II.B.7.c.3 Reporting:

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

Status: In compliance – Review of water spray usage records confirmed compliance with this
condition. Monthly observations are made and repairs are made to the water sprays as
needed by the operators or maintenance shop, if required.

II.B.8 Conditions on 11: Screens

II.B.8.a Condition:

The permittee shall operate water sprays or chemical dust suppression sprays as appropriate
to control fugitive emissions. The sprays shall operate whenever dry conditions warrant or as
determined necessary by the Director. Water sprays shall not be required during periods of
freezing temperatures. [Origin: DAQE-AN106760028-22]. [R307-401-8]

II.B.8.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.8.a.2 Recordkeeping:

Records of treatments shall be kept for all periods including the following items: date,
number of treatments made, dilution rate, and quantity, and the time of day treatments
were made. In addition, records of days of freezing temperature shall be kept. Records
of water or chemical dust suppression spray system inspection shall be kept for all
periods of operation. Records shall be maintained in accordance with provision I.S.1
of this permit.

II.B.8.a.3 Reporting:

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

Status: In compliance – Water sprays are strategically located to control fugitive emissions from
the screens. Water spray usage records are maintained.

52

II.B.8.b Condition:

Unless otherwise stated in this permit, visible emissions from all screens and all 40 CFR 60
Subpart OOO affected facilities that commenced construction, modification, or
reconstruction after 8/31/1983 but before 4/22/2008 shall be no greater than 10 percent
opacity. [Origin: DAQE-AN106760028-22, 40 CFR 60 Subpart OOO]. [40 CFR 60.672(b),
40 CFR 60 Subpart OOO Table 3, R307-401-8]

II.B.8.b.1 Monitoring:

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

II.B.8.b.2 Recordkeeping:

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

II.B.8.b.3 Reporting:

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

Status: In compliance – Review of water spray usage records confirmed compliance with this
condition. Monthly observations are made and repairs are made to the water sprays as
needed by the operators or maintenance shop, if required.

II.B.8.c Condition:

Visible emissions from the finishing end triple deck screen, coloring bunker warehouse
single deck screen, and the finishing end high frequency screen, and all 40 CFR 60 Subpart
OOO affected facilities that commenced construction, reconstruction, or modification on or
after 4/22/2008 shall be no greater than 7 percent opacity. [Origin: 40 CFR 60 Subpart
OOO]. [40 CFR 60.672(b)]

II.B.8.c.1 Monitoring:

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

II.B.8.c.2 Recordkeeping:

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

53

II.B.8.c.3 Reporting:

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

Status: In compliance – Review of water spray usage records confirmed compliance with this
condition. Monthly observations are made and repairs are made to the water sprays as
needed by the operators or maintenance shops, if required.

II.B.9 Conditions on 12: Conveyor Drop Points

II.B.9.a Condition:

Visible emissions shall be no greater than 20 percent opacity.
[Origin: DAQE-AN106760028-22]. [R307-401-8]

II.B.9.a.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed while the
emission unit is operating, on a monthly basis by an individual trained on the
observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions
other than condensed water vapor are observed from an emission unit, an opacity
determination of that emission unit shall be performed by a certified observer within
24 hours of the initial survey. The opacity determination shall be performed in
accordance with 40 CFR 60, Appendix A, Method 9. for point sources, and in
accordance 40 CFR 51, Appendix M Method 203C for fugitive sources.

II.B.9.a.2 Recordkeeping:

The permittee shall record the date of each visual survey. The permittee shall also
keep a log of the following information for each observed visual emission: date and
time visual emissions observed, emission point location and description, time and
date of opacity determination, and percent opacity. The records required by this
provision and all data required by 40 CFR 60, Appendix A, Method 9 or by 40 CFR
51, Appendix M Method 203C shall be maintained in accordance with Provision I.S.1
of this permit.

II.B.9.a.3 Reporting:

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

Status: In compliance – Review of records confirmed compliance with this condition. Daily/
monthly observations are made. See status of condition II.B.1.a.

54

II.B.10 Conditions on 13: Conveyor Transfer Points

II.B.10.a Condition:

Visible emissions from conveyor transfer points shall be no greater than 10 percent opacity.
[Origin: DAQE-AN106760028-22, 40 CFR 60 Subpart OOO]. [R307-401-8, 40 CFR
60.672(b), 40 CFR 60 Subpart OOO Table 3]

II.B.10.a.1 Monitoring:

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

II.B.10.a.2 Recordkeeping:

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

II.B.10.a.3 Reporting:

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

Status: In compliance – Review of water spray usage records confirmed compliance with this
condition. Monthly observations are made and repairs are made to the water sprays as
needed by the operators or maintenance shop, if required.

II.B.10.b Condition:

The permittee shall operate water sprays or chemical dust suppression sprays as appropriate
to control fugitive emissions. The sprays shall operate whenever dry conditions warrant or as
determined necessary by the Director. Water sprays shall not be required during periods of
freezing temperatures. [Origin: DAQE-AN106760028-22]. [R307-401-8]

II.B.10.b.1 Monitoring:

Visible inspections of the water or chemical dust suppression spray system(s) shall be
made monthly to ensure proper operating condition.

55

II.B.10.b.2 Recordkeeping:

Records of treatments shall be kept for all periods including the following items: date,
number of treatments made, dilution rate, and quantity, and the time of day treatments
were made. In addition, records of days of freezing temperature shall be kept. Records
of water or chemical dust suppression spray system inspection shall be kept for all
periods of operation. Records shall be maintained in accordance with provision I.S.1
of this permit.

II.B.10.b.3 Reporting:

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

Status: In compliance – Review of water spray usage records confirmed compliance with this
condition. Monthly observations are made and repairs are made to the water sprays
as needed by the operators or maintenance shop, if required.

II.B.11 Conditions on 15: Mobile Equipment Operational Areas

II.B.11.a Condition:

The permittee shall maintain visible fugitive dust emissions from haul-road traffic and
mobile equipment in operational areas at or below 20% opacity.

The permittee shall treat all unpaved roads and other unpaved operational areas that are used
by mobile equipment with water sprays and/or chemical treatments to maintain the opacity limit
of this condition.

Fugitive dust at all operational and mining operations shall be minimized as an
integral part of site preparation, mining activities, and reclamation operations in
accordance with R307-205-7. [Origin: DAQE-AN106760028-22, R307-205-7].
[R307-205-7, R307-401-8]

II.B.11.a.1 Monitoring:

In lieu of opacity monitoring, daily hours of operation of the water truck(s), and the
days when chemical dust suppressants were applied to the areas shall be monitored.
These records shall include the volume of water applied and location of applications,
or the type of chemical dust suppressant applied and location of applications. The
methods used to control disturbed or stripped areas shall be recorded as they occur,
and include dates and times, the types of control used, volume, and locations.

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

56

II.B.11.a.2 Recordkeeping:

Instances of water and/or chemical application to unpaved areas shall be recorded and
maintained by the permittee for all periods when the plant is in operation.

Records shall include the following items:

A. Date
B. Number of treatments made, dilution ratio, and quantity
C. Rainfall received, if any, and approximate amount
D. Time of day treatments were made
E. Records of temperature if the temperature is below freezing.

Records demonstrating compliance with this condition and records of all methods
used to control fugitive dust shall be maintained in accordance with Provision I.S.1 of
this permit.

II.B.11.a.3 Reporting:

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

Status: In compliance – The plant has two dedicated water trucks that are used to control
fugitive dust in the operational areas. Hard copy water records, which contain the above
information, are maintained. Minimal fugitive dust was observed. See attached VEO.

II.B.12 Conditions on 16: Storage Piles

II.B.12.a Condition:

The permittee shall operate water sprays or chemical dust suppression sprays as appropriate
to control fugitive emissions. The sprays shall operate whenever dry conditions warrant or
as determined necessary by the Director. Water sprays shall not be required during periods of
freezing temperatures. [Origin: DAQE-AN106760028-22]. [R307-401-8]

II.B.12.a.2 Recordkeeping:

Records of treatments shall be kept for all periods including the following items: date,
number of treatments made, dilution rate, and quantity, and the time of day treatments
were made. In addition, records of days of freezing temperature shall be kept. Records
of water or chemical dust suppression spray system inspection shall be kept for all
periods of operation. Records shall be maintained in accordance with provision I.S.1
of this permit

57

II.B.12.a.3 Reporting:

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

Status: In compliance – The on-site water trucks have side sprays which is used to control
fugitive dust generated from storage piles. Water records are maintained. Minimal
fugitive dust was observed. See attached VEO.

II.B.13 Conditions on 18: Bagging Operations

II.B.13.a Condition:

Visible emissions shall be no greater than 7 percent opacity from bagging operations.
[Origin: 40 CFR 60 Subpart OOO]. [40 CFR 60.672(b)]

II.B.13.a.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed while the
emission unit is operating, on a monthly basis by an individual trained on the
observation procedures of 40 CFR 60, Appendix A, Method 9. If visible emissions
other than steam are observed from an emission unit, an opacity determination of that
emission unit shall be performed by a certified observer within 24 hours of the initial
survey. The opacity determination shall be performed in accordance with 40 CFR 60,
Appendix A, Method 9, and 40 CFR 60.675.

II.B.13.a.2 Recordkeeping:

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

II.B.13.a.3 Reporting:

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

Status: In compliance – The bagging operations only operates intermittently, based on demand.
It was not operating at time of the inspection.

Experimental Approval Order (EAO) DAQE-AN106760031-24 Conditions

SECTION II: SPECIAL PROVISIONS

II.B REQUIREMENTS AND LIMITATIONS

II.B.1.a The owner/operator shall not exceed 10,000 tons of material processed through the Sizer Rig
Crusher. [R307-401

58

II.B.1.a.1 Records of the amount of material processed through the Sizer Rig Crusher shall be kept on a
daily basis. [R307-401]
Status: In compliance – Daily records were maintained of material processed. The amount of
material processed through the Sizer Rig Crusher, while on-site, was 4,231.89 tons.

II.B.1.b Weekly opacity observations shall be conducted on the Sizer Rig Crusher and associated
equipment to ensure visible emissions per R307-201, R307-205, and any applicable federal
subpart. [R307-401]

II.B.1.b.1 Records of weekly opacity observations shall be maintained. [R307-401]

Status: In compliance – Opacity Observations of the Sizer Rig Crusher were conducted on April
9, 2025, and April 22, 2025.

II.B.1.c The Sizer Rig Crusher and associated equipment shall not exceed 12 months of operation from
the date of this EAO. [R307-401]

II.B.1.c.1 Records of monthly operation shall be maintained. [R307-401]

Status: In compliance – Operation records were maintained. The Sizer Rig Crusher operated
on-site for approximately two weeks.

II.B.1.d This EAO does not give approval to violate any conditions or limitations of Holcim's AO and
Title V Operating Permits. [R307-401]

Status: In compliance – No conditions of the Title V Operating Permit have been violated.

II.B.1.e Upon completion of the Sizer Rig Crusher experiment operations, Holcim shall submit a final
report of results of the experiment. Additional operation of the equipment listed in this EAO
shall be addressed through a NOI for new equipment, submitted pursuant to UAC R307-401.
The final report shall be submitted to the Director, attention NSR Section, within 90 days of
completion of the Sizer Rig Crusher experiment operation. [R307-401]

Status: In compliance – Holcim SWR agreed to submit the final report regarding the
experimentation of the Sizer Rig Crusher. The crusher was operated on-site until the end
of April 2025, for about two weeks.

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

Not applicable to this source.

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

Not applicable to this source.

59

SECTION III: PERMIT SHIELD
The following requirements have been determined to be not applicable to this source in accordance
with Provision I.M, Permit Shield:

III.A 40 CFR 60 Subpart Y (Standards of Performance for Coal Preparation Plants)

This regulation is not applicable to the Permitted Source for the following reason(s):
40 CFR 60 Subpart Y applies to coal preparation plants that process more than 200
tons per day. By design, Holcim SWR, Inc. can only process a maximum of 72 tons
of coal a day. 40 CFR 60 Subpart Y does not apply to this source [Last updated
January 12, 2023]

SECTION IV: ACID RAIN PROVISIONS
IV.A This source is not subject to Title IV. This section is not applicable.

EMISSIONS INVENTORY:
The 2023 Tri-Annual Emissions Inventory was submitted, to the DAQ, on April 15, 2024.

60
PREVIOUS ENFORCEMENT
ACTIONS: Warning Letter – October 16, 2020

COMPLIANCE ASSISTANCE: 1) Discussed the revision of the Annual Compliance
Certification. See status of condition I.L.

2) Discussed submitting the Change of Ownership and Name
Change Form when the facility’s name is changed to Amrize.

3) Discussed submitting the final report regarding the Seizer Rig
Crusher (Experimental Approval Order (EAO)
DAQE-AN106760031-24). See Experimental Approval Order
Section.

4) Discussed submitting NOI prior to installing and operating the
Sizer Rig Crusher and diesel storage tank. See status of condition
II.A.

COMPLIANCE STATUS &
RECOMMENDATIONS: In compliance with the conditions of the Title V Operating
Permit 4300001004, dated May 24, 2023, and revised May 2023,
at time of inspection. Also, EAO DAQE-AN106760031-24,
dated December 3, 2024, at time of the inspection.

HPV STATUS: N/A

RECOMMENDATION FOR
NEXT INSPECTION: The facility will be renamed Amrize in June 2025. The facility
operates 24/7. Inspect as usual

ATTACHMENT: VEO Form

Joe Rockwell <[e-mail]>
Holcim SWR Inc.-Utelite LW Aggregate
3 messages
Aaron Lund <[e-mail]>Mon, Apr 7, 2025 at 2:37 PM
To: Joe Rockwell <[e-mail]>, Alex JUDD <[e-mail]>
Good afternoon Joe-
I'd like to confirm that Permit # 4300001004 is not required to submit an annual emission inventory into the SLEIS
webportal for reporting year 2024. Could you please confirm this for Alex and I? I attempted to fill out a report in SLEIS
and there was no link for the 2024 Reporting Year.
Thank you,
Aaron J. Lund
Manager of Land and Environment
LafargeHolcim | U.S.A.
Address: 4675 W. Teco Ave., Suite 140
Las Vegas, NV 89118
Mobile: [phone]

"Building strong, sustainable foundations today for the communities of tomorrow"

Joe Rockwell <[e-mail]>Wed, Apr 9, 2025 at 12:19 PM
To: Aaron Lund <[e-mail]>
Cc: [e-mail]
Hi Aaron -
Sorry for the delay.
According to the Emissions Inventory Section, Holcim SWR (Utelite) is not required to submit a 2024 annual emission
inventory (EI). That is why you could not fill out a report for the 2024 Reporting Year in the SLEIS database.
Currently, Holcim SWR (Utelite) is only required to submit tri-annual Emission Inventories. Since you are not considered
to be a Large Major Source and the facility is not considered to be in an O3 Non-attainment Area. That would mean that
Holcim SWR (Utelite) would be required to submit their 2026 tri-annual inventory before April 15, 2027.
Thank you for your cooperation in this matter.
Joe Rockwell | Environmental Scientist
4/9/25, 2:54 PM State of Utah Mail - Holcim SWR Inc.-Utelite LW Aggregate
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1828777619182245833&simpl=msg-f:18287776191822458…1/2
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Aaron Lund <[e-mail]>Wed, Apr 9, 2025 at 12:25 PM
To: Joe Rockwell <[e-mail]>
Cc: [e-mail]
Thank you Joe.
Aaron
[Quoted text hidden]
4/9/25, 2:54 PM State of Utah Mail - Holcim SWR Inc.-Utelite LW Aggregate
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1828777619182245833&simpl=msg-f:18287776191822458…2/2