HomeMy WebLinkAboutDAQ-2024-004690
DAQE-AN103130047-24
{{$d1 }}
Colby Roberts
Graymont Western US Incorporated
585 West Southridge Way
Sandy, UT 84070
nstettler@graymont.com
Dear Mr. Roberts:
Re: Approval Order: Enhanced Approval Order Change to DAQE-AN103130044-21 to Correct
Fugitive Dust Conditions
Project Number: N103130047
The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on June 14,
2023. Graymont Western US Incorporated must comply with the requirements of this AO, all applicable
state requirements (R307), and Federal Standards.
The project engineer for this action is John Jenks, who can be contacted at (385) 306-6510 or
jjenks@utah.gov. Future correspondence on this AO should include the engineer's name as well as the
DAQE number shown on the upper right-hand corner of this letter. No public comments were received
on this action.
Sincerely,
{{$s }}
Bryce C. Bird
Director
BCB:JJ:jg
cc: Central Utah Health Department
DJ Law, EPA Region 8
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
January 29, 2024
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality
{{#s=Sig_es_:signer1:signature}}
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APPROVAL ORDER
DAQE-AN103130047-24
Enhanced Approval Order Change to DAQE-AN103130044-21 to
Correct Fugitive Dust Conditions
Prepared By
John Jenks, Engineer
(385) 306-6510
jjenks@utah.gov
Issued to
Graymont Western US Incorporated - Cricket Mountain Plant
Issued On
{{$d2 }}
Issued By
{{$s }}
Bryce C. Bird
Director
Division of Air Quality
January 29, 2024
TABLE OF CONTENTS
TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 13
PERMIT HISTORY ................................................................................................................... 26
ACRONYMS ............................................................................................................................... 27
DAQE-AN103130047-24
Page 3
GENERAL INFORMATION
CONTACT/LOCATION INFORMATION
Owner Name Source Name
Graymont Western US Incorporated Graymont Western US Incorporated - Cricket
Mountain Plant
Mailing Address Physical Address
585 West Southridge Way
PO Box 669
Sandy, UT 84070
32 Miles Southwest of Delta, Utah; Highway 257
Delta (Millard), UT 84624
Source Contact UTM Coordinates
Name: Nate Stettler 343,100 m Easting
Phone: (801) 598-8076 4,311,010 m Northing
Email: nstettler@graymont.com Datum NAD27
UTM Zone 12
SIC code 1422 (Limestone, Crushed & Broken)
SOURCE INFORMATION
General Description
Graymont Western US Incorporated (Graymont) operates the Cricket Mountain Lime Plant in Millard
County. The Cricket Mountain Lime Plant consists of quarries and a lime processing plant, which
includes five (5) rotary lime kilns (Kilns 1 through 5). The rotary kilns are used to convert crushed
limestone ore into quicklime. The products produced for resale are lime, limestone, and kiln dust. The
kilns operate on pet coke and coal. Sources of emissions at this source include mining, limestone
processing, rotary lime kilns, post-kiln lime handling, and truck & loadout facilities.
NSR Classification
Minor Modification at Major Source
Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A
Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), HH: Standards of Performance for Lime Manufacturing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
DAQE-AN103130047-24
Page 4
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
MACT (Part 63), AAAAA: National Emission Standards for Hazardous Air Pollutants for
Lime Manufacturing Plants
Title V (Part 70) Major Source
Project Description
Graymont submitted a request for updating the chemical stabilizer dust control application. Specifically,
that the frequency of application be reduced from a schedule of three (3) times a year to two (2) times a
year. After review, UDAQ determined that the listing of dust control requirements in the AO is
redundant. The requirement to maintain a dust control plan is sufficient for the minimization of fugitive
dust. With the removal of the listed conditions in the AO, Graymont is free to modify the fugitive dust
control plan to incorporate the change in application frequency. No change in equipment, processes or
associated emissions will occur.
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 887964.00
Carbon Monoxide 0 7821.19
Nitrogen Oxides 0 3883.85
Particulate Matter - PM10 0 611.87
Particulate Matter - PM2.5 0 610.78
Sulfur Oxides 0 760.29
Volatile Organic Compounds 0 117.84
Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 0 1963
Acrolein (CAS #107028) 0 1
Arsenic (TSP) (CAS #7440382) 0 88
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 7734
Cadmium (CAS #7440439) 0 58
Chlorine (CAS #7782505) 0 1078
Chromium Compounds (CAS #CMJ500) 0 1214
Cobalt (TSP) (CAS #7440484) 0 1154
Ethyl Benzene (CAS #100414) 0 488
Formaldehyde (CAS #50000) 0 1612
Hexane (CAS #110543) 0 2566
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 0 44400
Hydrogen Fluoride (Hydrofluoric Acid) (CAS #7664393) 0 156
DAQE-AN103130047-24
Page 5
Lead (CAS #7439921) 0 1204
Manganese (TSP) (CAS #7439965) 0 546
Mercury (TSP) (CAS #7439976) 0 64
Nickel (CAS #7440020) 0 422
Selenium & Compounds (CAS #253) 0 402
Toluene (CAS #108883) 0 2678
Xylenes (Isomers And Mixture) (CAS #1330207) 0 2562
Change (TPY) Total (TPY)
Total HAPs 0 35.19
SECTION I: GENERAL PROVISIONS
I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five (5) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO
including associated air pollution control equipment in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available to
the Director which may include, but is not limited to, monitoring results, opacity observations,
review of operating and maintenance procedures, and inspection of the source. All
maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]
DAQE-AN103130047-24
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SECTION II: PERMITTED EQUIPMENT
II.A THE APPROVED EQUIPMENT
II.A.1 Lime Manufacturing Plant
[All equipment designation numbers are those used by Graymont Western U.S. Incorporated]
II.A.2 K-1 Kiln
Rotary Lime Kiln #1 rated at 600 tons of lime per 24-hour period with a preheater and baghouse
emissions control system (D-85) rated at an exhaust gas flow rate 54,000 scfm and an Air to
Cloth (A/C) ratio of 3.26:1.
NESHAP Applicability: 40 CFR 63 Subpart AAAAA
II.A.3 K-2 Kiln
Rotary Lime Kiln #2 rated at 600 tons of lime per 24-hour period with a preheater, cyclone and
baghouse emissions control system (D-275) rated at an exhaust gas flow rate of 48,000 scfm and
an A/C ratio of 2.9:1.
NESHAP Applicability: 40 CFR 63 Subpart AAAAA
II.A.4 K-3 Kiln
Rotary Lime Kiln #3 rated at 840 tons of lime per 24-hour period with a preheater, cyclone and
baghouse emissions control system (D-375) rated at an exhaust gas flow rate of 55,000 scfm and
a A/C ratio of 2.49:1.
NESHAP Applicability: 40 CFR 63 Subpart AAAAA
II.A.5 K-4 Kiln
Rotary Lime Kiln #4 rated at 1266 tons of lime per 24-hour period with a preheater, cyclone and
baghouse emissions control system (D-485) rated at an exhaust gas flow rate of 100,000 scfm
and an A/C ratio of 5:1.
NESHAP Applicability: 40 CFR 63 Subpart AAAAA
II.A.6 K-5 Kiln
Rotary Lime Kiln #5 rated at 1400 tons of lime per 24-hour period with a preheater and baghouse
emissions control system (D-585) rated at an exhaust gas flow rate of 103,000 scfm and an A/C
ratio of 3.5:1.
NESHAP Applicability: 40 CFR 63 Subpart AAAAA
II.A.7 KDE-1 Kiln Drive Engine
Rating: 52 hp
Fuel: Diesel
NSPS Applicability: 40 CFR 60 Subpart IIII
MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.8 KDE-2 Kiln Drive Engine
Rating: 45 hp
Fuel: Diesel
NSPS Applicability: 40 CFR 60 Subpart IIII
MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.9 KDE-3 Kiln Drive Engine
Rating: 55 hp
Fuel: Gasoline
MACT Applicability: 40 CFR 63 Subpart ZZZZ
DAQE-AN103130047-24
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II.A.10 KDE-4 Kiln Drive Engine
Rating: 65 hp
Fuel: Diesel
Manufacture Date: Pre 12/19/2002
MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.11 KDE-5 Kiln Drive Engine
Rating: 173.5 hp
Fuel: Diesel
NSPS Applicability: 40 CFR 60 Subpart IIII
MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.12 D-91 Coal Silo Baghouse
For Kiln #1
Exhaust gas flow rate: 1,000 scfm
II.A.13 D-94 Coal Silo Baghouse
For Kiln #2
Exhaust gas flow rate: 1,000 scfm
II.A.14 D-391 Coal Silo Baghouse
For Kiln #3
Exhaust gas flow rate: 1,000 scfm
II.A.15 D-491 Coal Silo Baghouse
For Kiln #4
Exhaust gas flow rate: 1,500 scfm
II.A.16 D-591 Coal Silo Baghouse
For Kiln #5
Exhaust gas flow rate: 1,000 acfm
II.A.17 D-331 Product Baghouse
For Kiln #1, #2 loadout area and screenhouse dust collector
Exhaust gas flow rate: 32,000 scfm
II.A.18 D-330 Product Baghouse
For Kiln #3 cooler pit dust collector
Exhaust gas flow rate: 11,000 scfm
II.A.19 D-447 Product Baghouse
For Kiln #4 cooler and screenhouse dust collector
Exhaust gas flow rate: 18,300 scfm
II.A.20 D-463 Product Baghouse
For Kiln #4 product loadout and C-463 dust collector
Exhaust gas flow rate: 8,300 scfm
II.A.21 D-341 Product Baghouse
For Silo T-341
Exhaust gas flow rate: 2,000 scfm
II.A.22 D-530 Product Baghouse
Product handling baghouse #1 for Kiln #5 screen house
Exhaust gas flow rate: 9,000 acfm
DAQE-AN103130047-24
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II.A.23 D-564 Product Baghouse
Product handling baghouse #2 for Kiln #5 screen house
Exhaust gas flow rate: 9,000 acfm
II.A.24 D-547 Product Baghouse
Product handling baghouse #3 for Kiln #5 screen house
Exhaust gas flow rate: 9,000 acfm
II.A.25 D-83 Lime Kiln Dust Silo Baghouse
For Kilns #1 and #2
Exhaust gas flow rate: 6,000 scfm
II.A.26 D-489 Lime Kiln Dust Silo Baghouse
For Kilns #4 lime kiln dust silo
Exhaust gas flow rate: 6,000 scfm
II.A.27 D-486 Lime Kiln Dust Silo Baghouse
For Kiln #4
Exhaust gas flow rate: 4,000 scfm
II.A.28 D-466 Lime Kiln Dust Silo Baghouse
For lime kiln dust silo
Exhaust gas flow rate: 4,000 scfm
II.A.29 D-586 Lime Kiln Dust Silo Baghouse
For Kiln #5 dust silo
Exhaust gas flow rate: 2,500 scfm
II.A.30 D-589 Lime Kiln Dust Silo Baghouse
For loadout of Kiln #5 dust silo
Exhaust gas flow rate: 1,500 scfm
II.A.31 T-381 Lime Kiln Dust Silo
Maximum Capacity: 300 tons
II.A.32 D-381 Lime Kiln Dust Silo Baghouse
For 300-ton lime kiln dust silo (T-381)
Exhaust gas flow rate: 3,000 scfm
II.A.33 T-381 Loadout Spout
For 300-ton lime kiln dust silo (T-381)
II.A.34 D-382 Loadout Spout (T-381) Baghouse
For Loadout Spout (T-381)
Exhaust gas flow rate: 2,000 scfm
II.A.35 D-333 Product Loadout Baghouse
For rail loadout
Exhaust gas flow rate: 10,000 scfm
II.A.36 D-10 Limestone Ore Preparation Baghouse
For stone reclaim screen for Kiln #1 & #2
Exhaust gas flow rate: 8,000 scfm
DAQE-AN103130047-24
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II.A.37 D-310 Limestone Ore Processing Baghouse
For stone dressing screen for Kiln #3
Exhaust gas flow rate: 8,000 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.38 D-414 Limestone Ore Processing Baghouse
For stone dressing screen for Kiln #4
Exhaust gas flow rate: 3,100 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.39 D-514 Limestone Ore Processing Baghouse
For stone dressing screen for Kiln #5
Exhaust gas flow rate: 4,500 acfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.40 D-1 Limestone Ore Processing Baghouse
For quarry crusher & screen
Exhaust gas flow rate: 28,000 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.41 D-503 Conveying System
For dust collection for Kiln #5 limestone conveyor transfer points
Exhaust flow rate: 2,000 acfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.42 D-403 Conveying System
For stone dump from conveyor 408 & 409 to reclaim pile
Exhaust gas flow rate: 2,200 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.43 D-415 Conveying System with Baghouse
For limestone dump to Kiln #4 preheater
Exhaust gas flow rate: 600 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.44 D-479 Dolomitic Lime Handling System Baghouse
Product transfer baghouse to S-471, T-471, T-472, T-473, and T-474. The 435-material handling
system consists of two (2) elevators, a vibratory conveyor, a number of belt conveyors, and a
mixing screw conveyor
Exhaust gas flow rate: 4,300 scfm
II.A.45 R-486 Dolomite Crusher
Rating: 40 tons/hr
II.A.46 N-470 Dolomitic Lime Handling System
Recycle Bin
II.A.47 Processed Stone Handling (PSH) Operations
Operations to transport material from storage piles (fines, small stone, medium stone, large stone
[sugar]) to kiln preheaters. Includes bins, bin transfer points, preheater transfer points, and
conveyors.
NESHAP Applicability: 40 CFR 63 Subpart AAAAA
II.A.48 Sugar Stone System
System to store, screen and load sugar stones. Includes a hopper (HP-1), screen (S-2), loadout
system (203255SSS001), conveyors (C-MISC2), and generator (GEN-1).
DAQE-AN103130047-24
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II.A.49 HP-1 Hopper Sugar Stone System
II.A.50 S-2 Screen Sugar Stone System
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.51 Loadout Sugar Stone System
Rail Loadout
II.A.52 C-MISC2 Sugars Stone System
Miscellaneous Conveyors
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.53 GEN-1 Generator Sugar Stone System
Rating: 130.1 hp
Fuel: Diesel
MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.54 Portable Crusher System (PCS)
Includes hopper, crushers (PCS-1), hopper (HP-2), generator (PCS-4), and conveyors.
II.A.55 PCS Hopper
Feed Hopper
II.A.56 PCS-1 Crusher System
ICR101: Primary Crusher
Capacity: 690 tons/hr
ICR102: Secondary Crusher
Capacity: 690 tons/hr
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.57 PCS-2 Screen/Conveyor Transfer Points
Screen and material transfer points to and from conveyor belts.
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.58 PCS-3 Conveyor Drop Points
Material drop points to the fines and product stockpiles
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.59 PCS-4 Generator Portable Crusher System
Quantity: three (3)
Rating: 740 hp combined
Fuel: Diesel
II.A.60 PCS Conveyors
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.61 D-7122 Limestone Grinding Plant Baghouse
For grinding mill, direct-fire heater, material separator
Exhaust gas flow rate: 10,000 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.62 D-7133 Limestone Grinding Plant Baghouse
For screen, three (3) bucket elevators, three (3) storage silos
Exhaust gas flow rate: 4,500 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
DAQE-AN103130047-24
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II.A.63 D-7141 Limestone Grinding Plant Baghouse
For truck load-out and rail load-out
Exhaust gas flow rate: 3,500 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.64 C-MISC1 Limestone Grinding Plant
Miscellaneous Conveyors
II.A.65 D-488 Briquetter and Crusher Baghouse
For crusher (R-486), briquetters (BRI-474 and BRI-014), and silo (T-470)
Exhaust gas flow rate: 1,700 scfm
II.A.66 BRI-474 Briquetter
II.A.67 BRI-014 Briquetter
II.A.68 C-045 Conveying System
Fines Truck Loadout Conveyor - 250 tons/hr
II.A.69 C-305 Conveying System
Medium and Small Stone Pile Conveyor - 600 tons/hr
II.A.70 S-466 Screen
Dolomitic Screen
II.A.71 C-Coal Handling
Miscellaneous Conveyors
II.A.72 Feeder-Coal Handling
Four (4) Vibratory Feeders
II.A.73 PW Portable Pressure Washer
Rating: 18 hp
Fuel: Gasoline
II.A.74 HR-1 Haul Road
Quarry to plant and plant to highway.
Length: 6 miles
II.A.75 HR-2 Haul Road
Inside quarry
II.A.76 Limestone Fines Product (LFP) Loadout System
Includes a screen hopper, screen, screen conveyors, tent storage area, product loadout hopper,
product loadout conveyor, and engines (CAT4.4 and V3600-T).
II.A.77 LFP - Engines
CAT 4.4 Generator
Rating: 130 hp
Kubota V3600-T Generator
Rating: 52 hp
Fuel: Diesel
NSPS Applicability: 40 CFR 60 Subpart IIII
MACT Applicability: 40 CFR 63 Subpart ZZZZ
DAQE-AN103130047-24
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II.A.78 LFP-1 Hopper
Capacity: 250 ton/hour
II.A.79 LFP-2 Screen
Capacity: 250 ton/hour
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.80 LFP-3 Conveyors
Capacity: 250 ton/hour
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.81 LFP-4 Storage
Tent storage area
II.A.82 LFP-5 Hopper
Product loadout hopper
Capacity: 100 ton/hour
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.83 LFP-6 Conveyor
Product Loadout Conveyor
Capacity: 100 ton/hour
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.84 Stationary Pressure Washer
Rating: 0.4 MMBtu/hr
Fuel: Propane
Listed for information purposes only
II.A.85 Fuel Storage Tanks
Four (4) 10,150-gallon diesel storage tanks
One (1) 12,000-gallon diesel storage tank
One (1) 2,000-gallon gasoline storage tank
One (1) 500-gallon gasoline storage tank
DAQE-AN103130047-24
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SECTION II: SPECIAL PROVISIONS
II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Sitewide Requirements
II.B.1.a The following limits shall not be exceeded:
A. For Kilns #1, #2, #3, #4, and #5 collectively:
1) 1,516,250 tons lime per rolling 12-month period
2) 4,706 tons lime per day
B. Sugar Stone System
1) 135,000 tons of sugar stone per rolling 12-month period
2) 750 hours of operation for the 130.1 hp generator per rolling
12-month period
C. Portable Crushing System
1) 750,000 tons of limestone per rolling 12-month period
2) 4,000 hours of operation per rolling 12-month period
D. Truck hauling of stone from the quarry to the plant
1) No more than 108 rounds trips per day (midnight to midnight)
24-hour period
E. Limestone Fines Product Loadout Process
1) 200,000 tons of limestone per rolling 12-month period
2) 6,500 hours of operation per rolling 12-month period.
[R307-401]
II.B.1.a.1 Compliance with the above 12-month production limitations shall be determined on a rolling
12-month total. Calculations for the 12-month production shall be completed within 25 calendar
days from the end of the previous month. Records of production shall be kept for all periods
when the plant is in operation. Production shall be determined by plant production records, such
as scale records or sales receipts. Hours of operation and number of truck trips shall be
determined by records of operation. The records shall be kept on a daily basis. [R307-401-8]
DAQE-AN103130047-24
Page 14
II.B.1.b Emissions to the atmosphere from the indicated emission point shall not exceed the following
rates and concentrations (standardized at 68 oF, 29.92 in Hg) (lbs/tsf = pounds per ton of stone
fed):
Emission Point: Kiln #1 Baghouse Stack
Pollutant lb/hr grain/dscf lbs/tsf
TSP 0.020 0.12
PM10 (Filterable + Condensable) 6.0 0.016
SO2 22.4
NOx 90.0
Emission Point: Kiln #2 Baghouse Stack
Pollutant lb/hr grain/dscf lbs/tsf
TSP 8.23 0.020 0.12
PM10 (Filterable + Condensable) 6.58 0.016
SO2 22.4
NOx 120.0
Emission Point: Kiln #3 Baghouse Stack
Pollutant lb/hr grain/dscf lbs/tsf
TSP 7.49 0.020 0.10
PM10 (Filterable + Condensable) 7.54 0.016
SO2 27.2
NOx 160.0
Emission Point: Kiln #4 Baghouse Stack
Pollutant lb/hr grain/dscf lbs/tsf
TSP 17.14 0.020 0.12
PM10 (Filterable + Condensable) 13.7 0.016
SO2 38.4
NOx 200.0
Emission Point: Kiln #5 Baghouse Stack
Pollutant lb/hr grain/dscf Other
TSP 0.020 0.10 lbs/tsf
PM10 (Filterable + Condensable) 11.7 0.016
SO2 59.0 1.01 lb/ton lime
NOx 210.0 3.60 lb/ton lime
CO 233.0 4.00 lb/ton lime
Emission Point: Briquetter and Crusher Baghouse (D-488) Stack
Pollutant lb/hr grain/dscf
TSP 0.29 0.020
PM10 (Filterable) 0.15 0.010
PM2.5 (Filterable) 0.15 0.010
After the installation of an SO2 CEMS, compliance with the SO2 emission limit will be based on
a 3-hour block average.
Testing for compliance with the lb/ton lime limits must comply with all stack testing
requirements.
[R307-401]
DAQE-AN103130047-24
Page 15
II.B.1.b.1 Stack testing to show compliance with the emission limitations stated in the above condition
shall be performed as specified below:
Emission Point Pollutant Status Test Frequency
Kiln #1 Baghouse Stack TSP *** +
PM10 *** +
SO2 *** +
NOx *** +
Emission Point Pollutant Status Test Frequency
Kiln #2 Baghouse Stack TSP *** +
PM10 *** +
SO2 * +
NOx * +
Emission Point Pollutant Status Test Frequency
Kiln #3 Baghouse Stack TSP *** +
PM10 *** +
SO2 * +
NOx *** +
Emission Point Pollutant Status Test Frequency
Kiln #4 Baghouse Stack TSP *** +
PM10 *** +
SO2 *** +
NOx *** +
Emission Point Pollutant Status Test Frequency
Kiln #5 Baghouse Stack TSP *** +
PM10 *** +
SO2 *** +
NOx *** +
CO *** +
Emission Point Pollutant Status Test Frequency
(D-488) Baghouse Stack TSP *** +
PM10 *** +
PM2.5 *** +
(Filterable)
* No Initial Testing was required. The source shall be tested if directed by the Director at any
time.
** Initial compliance testing is required. The initial test date shall be performed as soon as
possible and in no case later than 180 days after the startup of a new emission source, an existing
source without an AO, or the granting of an AO to an existing emission source that has not had
an initial compliance test performed. If an existing source is modified, a compliance test is
required on the modified emission point that has an emission rate limit.
*** Initial compliance testing was required and completed.
+ Test every three (3) years. The Director may require testing at any time.
[R307-401]
DAQE-AN103130047-24
Page 16
II.B.1.b.2 A. Notification
The Director shall be notified at least 60 days prior to conducting any required
emission testing for sources subject to 40 CFR 63 Subpart AAAAA. All other
sources shall notify the Director at least 30 days prior to conducting any required
emission testing. A source test protocol shall be submitted to DAQ when the
testing notification is submitted to the Director
The source test protocol shall be approved by the Director prior to performing
the test(s). The source test protocol shall outline the proposed test
methodologies, stack to be tested, and procedures to be used. A pretest
conference shall be held, if directed by the Director.
B. Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR
60, Appendix A, Method 1, or other methods as approved by the Director. An
Occupational Safety and Health Administration (OSHA) or Mine Safety and
Health Administration (MSHA) approved access shall be provided to the test
location
C. Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2 or other EPA-approved testing method
acceptable to the Director
D. Total Suspended Particulate (TSP)
40 CFR 60, Appendix A, Method 5 or other EPA-approved testing method
acceptable to the Director
E. PM10 (Filterable + Condensable)
For stacks in which no liquid drops are present, the following methods shall be
used: 40 CFR 51, Appendix M, Methods 201, 201a, or other EPA approved
method as acceptable to the Director. The back half condensables shall also be
tested using the EPA approved method acceptable by the Director. All
particulate captured shall be considered PM10
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, or other EPA approved method as acceptable to the
Director. The back half condensables shall also be tested using the EPA 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 edition
of the EPA document, AP-42, or other data acceptable to the Director.
F. PM2.5 (Filterable)
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A or
other EPA-approved testing method as acceptable to the Director. If other
approved testing methods are used which cannot measure the PM2.5 fraction of
the filterable particulate emissions, all of the filterable particulate emissions shall
be considered PM2.5. The portion of the front half of the catch considered PM2.5
shall be based on information in Appendix B of the fifth edition of the EPA
document, AP-42, or other data acceptable to the Director
G. Sulfur Dioxide (SO2)
40 CFR 60, Appendix A, Method 6, 6A, 6B, 6C, or other EPA-approved testing
method acceptable to the Director
H. Nitrogen Oxides (NOx)
40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, 7E, or other EPA approved
method as acceptable to the Director
I. Carbon Monoxide (CO)
40 CFR 60, Appendix A, Method 10, or other EPA approved method as
acceptable to the Director.
[R307-401]
DAQE-AN103130047-24
Page 17
II.B.1.b.3 J. 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
To determine emission rates in units of lbs/ton lime, the emission rate in
lbs/hour shall be divided by the tons/hour lime production rate. Lime
production rate shall either be a direct measurement or shall be calculated
using the following conversion factor: Two (2) tons of limestone feed equates
to one (1) ton of lime produced (two (2) tons limestone: one (1) ton lime).
K. New Source Operation
For a new source/emission point, the production rate during all compliance
testing shall be no less than 90% of the production rate listed in this AO. If
the maximum AO allowable production rate has not been achieved at the time
of the test, the following procedure shall be followed:
1) Testing shall be at no less than 90% of the production rate achieved to
date
2) If the test is passed, the new maximum allowable production rate shall
be 110% of the tested achieved rate, but not more than the maximum
allowable production rate. This new allowable maximum production
rate shall remain in effect until successfully tested at a higher rate
3) The owner/operator shall request a higher production rate when
necessary. Testing at no less than 90% of the higher rate shall be
conducted. A new maximum production rate (110% of the new rate)
will then be allowed if the test is successful. This process may be
repeated until the maximum AO production rate is achieved.
L. Existing Source Operation
For the existing kilns, the production rate during all compliance testing shall
be no less than 90% of the maximum production achieved in the previous
three (3) years
M. Reporting
The results of stack testing shall be submitted to the Director within 60 days of
completion of the testing. Reports shall clearly identify results as compared to
permit limits and indicate compliance status.
[R307-165, R307-401]
DAQE-AN103130047-24
Page 18
II.B.1.c Visible emissions from the following emission points shall not exceed the following opacity
values:
A. Kilns #1, #2, #3, #4, and #5 15%
B. All ancillary silo and storage bin baghouses 10%
C. Product baghouses 10 %
D. Subpart OOO baghouses 7%
E. All non-OOO crushers 15%
F. All non-OOO screens 10%
G. All non-OOO conveyor transfer points 10%
H. Subpart OOO crushers*
i. Post-April 22, 2008 12%
ii. Pre-April 22, 2008 15%
I. Subpart OOO screens*
i. Post-April 22, 2008 7%
ii. Pre-April 22, 2008 10%
J. Subpart OOO conveyor transfer points*
i. Post-April 22, 2008 7%
ii. Pre-April 22, 2008 10%
K. All diesel engines 20%
L. Conveyor drop points 20%
M. PSH operations stack emissions 7%
N. PSH operations fugitive emissions 10%
O. All other points sources 20%
*Opacity limits from 40 CFR 60 Subpart OOO shown as "Post-April 22, 2008" applies to
emission units constructed, modified, or reconstructed on or after April 22, 2008, and
"Pre-April 22, 2008" applies to emission units constructed, modified, or reconstructed on or after
August 31, 1983, but before April 22, 2008.
Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9.
For sources that are subject to NSPS, opacity shall be determined by conducting observations in
accordance with 40 CFR 60.11(b) and 40 CFR 60, Appendix A, Method 9.
Visible emissions from haul road traffic shall be minimized in accordance with the fugitive dust
control plan.
[R307-401]
DAQE-AN103130047-24
Page 19
II.B.1.c.1 The owner/operator shall make at least one (1) visual opacity survey each quarter for each kiln
drive engine. The visual opacity survey shall be performed while the unit is operating by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visual emissions observer (VEO). If visible emissions
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. The
owner/operator shall maintain a log of the visual opacity surveys, opacity determinations, and all
data required by 40 CFR 60, Appendix A, Method 9. [R307-401]
II.B.2 Fuel Requirements
II.B.2.a The owner/operator shall use coal as the primary fuel, except a combination of coal and
petroleum coke (pet coke) may be used in Kilns #1 and #5, and propane and fuel oil as a startup
fuel in all kilns. Prior to burning petroleum coke in Kilns #1 and #5 or coal with a sulfur content
in excess of 1.0 lb/MMBTU in Kilns #1, #2, #3, #4, or #5, an SO2 CEM must be installed,
calibrated, and operating on that kiln. [R307-401]
II.B.2.b The owner/operator shall use propane, diesel, and used oil in any combination in the direct fire
heating system for the limestone grinding plant. [R307-401]
II.B.2.c The sulfur content of any coal or any mixture of coals burned shall not exceed 1.0 pounds of
sulfur per MMBTU heat input. Sulfur content shall be determined by the owner/operator or the
coal supplier using ASTM Method D3174-12(2018), D3176-15, D4239-18e1, D5016-16 or an
approved equivalent ASTM Method. If the owner/operator chooses supplier certification, the
sulfur content shall be tested quarterly from a composite sample. If the owner/operator chooses
to test the sulfur content of the coal, the composite sample shall be tested quarterly from a
composite grab sample taken every 24 hours of operation. Records, or supplier furnished
certifications, of this testing shall be kept on-site for a period of five (5) years and be provided to
the Director upon request.
After a SO2 CEMS has been installed, calibrated, and is operating on a kiln, the coal that is
burned in that kiln is exempt from the 1.0 pounds of sulfur per MMBTU heat input limitation of
UAC R307-203-1(1).
[R307-203-1]
II.B.2.d Except for diesel, the sulfur content of any fuel oil burned as a startup fuel in all kilns shall not
exceed 0.85 pounds of sulfur per MMBTU heat input. Sulfur content shall be decided by ASTM
Method D-3175-75, or an approved equivalent. The sulfur content shall be tested if directed by
the Director. [R307-401]
DAQE-AN103130047-24
Page 20
II.B.2.e The air heating combustor burning used oil for energy recovery shall comply with the following:
A. The concentration/parameters of contaminants in any used oil burned as fuel
shall not exceed the following levels:
1) Arsenic 5 ppm by weight
2) Cadmium 2 ppm by weight
3) Chromium 10 ppm by weight
4) Lead 100 ppm by weight
5) Total halogens 1,000 ppm by weight
6) Sulfur 0.50 percent by weight
B. The flash point of all used oil to be burned as fuel shall not be less than 100
degrees F
C. Used oil that does not exceed any of the listed contaminants content may be
burned. The owner/operator shall record the quantities of oil burned
D. Sources utilizing used oil as a fuel shall comply with the State Division of Waste
Management and Radiation Control in accordance with R315-15, UAC.
[R307-401]
II.B.2.f The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as
fuel in the KDE-1, KDE-2, KDE-4, and KDE-5 drive engines; GEN-1 engine; portable
generators; and LFP engines. [R307-401-8]
II.B.2.g The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.2.g.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the
ULSD requirements. [R307-401-8]
II.B.3 SO2 and Opacity CEMS Requirements
II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system for the continuous measurement of opacity on kiln stacks #1, #2,
#3, #4, and #5. The owner/operator shall record the output of the system for measuring the
opacity of emissions. The monitoring system shall operate continuously in accordance with the
DAQ Policy Document for Continuous Emission Monitoring Systems. The monitoring system
shall comply with all applicable sections of R307-170, UAC and 40 CFR 60, Appendix B,
Specification 1 - Opacity. [R307-170]
II.B.3.b The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system (consisting of a SO2 pollutant concentration monitor and a flow
monitoring device) for the continuous measurement of SO2 emissions on a kiln if that kiln burns
pet coke or coal with a sulfur content in excess of 1.0 lb Sulfur/MMBtu.
The owner/operator shall record the output of the system for measuring SO2 emissions. The
monitoring system shall comply with all applicable sections of R307-170, UAC and 40 CFR 50
Appendix B, Performance Specifications 2 - SO2 and NOx Continuous Emission Monitoring
Systems.
[R307-170]
DAQE-AN103130047-24
Page 21
II.B.3.c When a SO2 CEMS has been installed calibrated, and is operating, the emission rate of SO2 in
pounds per hour measured by the SO2 CEMS for each 3-hour block averaging period will be
calculated by the following formula:
Eh = K * Chp * Qhs * [(100 - %H2O)/100]
Where: Eh = hourly SO2 mass emission rate during unit operation, lb/hr
K = 1.66 E-7 for SO2, lb/scf/ppm
Chp = hourly average SO2 concentration during unit operation, ppm (dry)
Qhs = hourly average volumetric flow rate during unit operation, scfh (wet)
%H2O = constant moisture value specific to each kiln, percent by volume.
[R307-401]
II.B.3.d All continuous opacity monitoring devices as required in federal regulations and state rules shall
be installed and operational prior to placing the affected source in operation. SO2 CEMS shall be
installed and operational on a kiln prior to that kiln burning coal with a sulfur content in excess
of 1.0 lb Sulfur/MMBtu or burning pet coke.
Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under 40 CFR 60.13(d), the owner/operator of an affected source shall continuously
operate all required continuous monitoring devices and shall meet minimum frequency of
operation requirements as outlined in 40 CFR 60.13(e) and R307-170, UAC.
[40 CFR 60, R307-170]
DAQE-AN103130047-24
Page 22
II.B.3.e The Director shall consider the continuous monitoring requirements to be met when the
following provisions are met:
A. Opacity Monitors and SO2 CEMS
1) Shall operate in accordance with 40 CFR 60.13 and R307-170 UAC
2) Prior to installation of a SO2 CEMS on a kiln, the average of three
(3) one-hour stack test results are less than the corresponding SO2
emission limit for that kiln
3) After installation of the SO2 CEMS on a kiln, the 3-hour block
average is less than the corresponding SO2 emission limit for that kiln
4) Three-hour block averages will begin on 12:01 am and end every
three (3) hours, thereafter.
B. Excess Emission Requirements
1) At no time shall the owner/operator allow excess gaseous emissions
to be emitted to the atmosphere, except as provided by the provisions of
R307-107 (Breakdowns), UAC.
C. Reporting
1) All sources required to install a continuous emission monitor shall
submit a quarterly report in an electronic format provided by the DAQ
2) All exceedances are to be reported in the quarterly report with
explanations (R307-170-8 Reason Categories, UAC) and corrective
actions.
[40 CFR 60, R307-170]
II.B.4 Haul Roads and Fugitive Dust Requirements
II.B.4.a The owner/operator shall implement a fugitive dust control plan acceptable to the Director for
control of all dust sources associated with the Cricket Mountain Plant. Adherence to the most
recently approved fugitive dust control plan shall be monitored to demonstrate that appropriate
measures are being implemented to control fugitive dust. At least once during each permit term,
the fugitive dust control plan shall be reviewed and evaluated. If the plan review indicates
changes to the dust control plan are necessary to reflect current site operations, an updated
fugitive dust control plan shall be submitted. The owner/operator shall operate in accordance
with the most current fugitive dust control plan approved by the Director. For each plan review,
a record of the date and results of the review shall be maintained. Records that demonstrate
compliance with the most recently approved fugitive dust control plan shall also be maintained.
[R307-401]
II.B.5 Other Baghouse Requirements
II.B.5.a The pressure drop on the Briquetter and Crusher (D-488) Baghouses shall not be less than 4.0
inches of water column or more than 8.0 inches of water column. [R307-401-8]
II.B.5.a.1 The pressure drop shall be monitored and recorded weekly, while the unit is operating with
equipment located such that an inspector/operator can safely read the output at any time.
[R307-401-8]
II.B.5.a.2 All instruments shall be calibrated according to the manufacturer's instructions at least once
every 12 months. [R307-401-8]
DAQE-AN103130047-24
Page 23
II.B.6 Alternate Operating Scenario for Synthetic HAPs Minor Operations
II.B.6.a This Section contains the requirements for the AOS. If the owner/operator chooses to comply
with the AOS requirements in this Section, the source will be reclassified as an area source of
HAPs as defined in 40 CFR 63.2 effective on the date that AOS operations commence. Once
reclassified, the requirements of 40 CFR 63 Subpart AAAAA will no longer apply.
Once effective, the limits of the AOS shall apply permanently and a modification to the AO will
be required should the owner/operator need to remove or modify these limits. All other
requirements in this AO will continue to apply. The AOS limits will be applied in addition to the
requirements in II.B.1 through II.B.5. [R307-401-8]
II.B.6.b The owner/operator shall notify the Director at least 30 days prior to the effective date on which
operations will commence under the AOS requirements specified in this section of the AO. The
notification shall include:
1. Test results for HCl and total organic HAPs that demonstrate the source meets the
definition of area source given in 40 CFR 63.2. Methods for measuring HCl and total
HAPs shall be those specified in 40 CFR 63.7142, or other EPA-approved methods, as
acceptable to the Director. Documentation of the testing shall be maintained
2. Date when operations will commence under the AOS and the AOS conditions
limiting HAPs emissions become effective
3. Proposed schedule for CEMS installation.
[R307-401-8]
II.B.6.c Under the AOS, the owner/operator shall limit facility-wide emissions to:
A) 9.5 tons of HCl per 12-month block period
B) 24 tons of total HAPs per 12-month block period
Total HAPs emissions must include the following compounds:
1) Organic HAPs: acetaldehyde benzene, chlorine, ethylbenzene,
formaldehyde, hexane, toluene, and xylenes
2) Metal HAPs: arsenic, cadmium, chromium compounds, cobalt, lead,
manganese, mercury, nickel, and selenium
3) HCl.
[R307-401-8]
II.B.6.c.1 To determine compliance with the 12-month block total, the owner/operator shall calculate a
monthly total by the twenty-fifth day of each month using data from the previous month. The
monthly totals shall be added to determine HCl and total HAPs emissions for the current
12-month block. The 12-month block period starts on the day that the owner/operator
commences operations under the AOS. A new 12-month block period will begin each year on
the date AOS operations commenced. [R307-401-8]
II.B.6.c.2 The owner/operator shall demonstrate compliance with the HCl emission limit using CEMS data
as outlined in Condition II.B.6.f, except as specified in II.B.6.e. The HCl CEMS shall operate
for all periods the kilns are in operation. Records, including CEMS data and calculated
emissions, shall be tabulated for each day. [R307-401-8]
DAQE-AN103130047-24
Page 24
II.B.6.c.3 The owner/operator shall demonstrate compliance with the total HAPs limit using the following
data:
A. HCl CEMS data, as per II.B.6.c.2
B. Emission rates in lbs/hr measured in the most recent stack test for organic HAPs
and metal HAPs. Stack testing requirements are specified in II.B.6.j
C. Monthly hours of operations. Hours of operation shall be determined by records
of operation and shall be kept on a daily basis.
[R307-401-8]
II.B.6.d The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system(s) for the continuous measurement of HCl emissions on Kilns
#1-#5. The CEMS(s) shall be installed and used as the primary method of compliance within
180 days from the date the owner/operator commences operation under the AOS. At a
minimum, the HCl CEMS shall consist of HCl concentration monitor(s) for each kiln, flow
monitors, and a data acquisition system capable of recording measurements from Kilns 1#-#5.
[R307-401-8]
II.B.6.e If the CEMS are not in operation when the owner/operator commences operation under the AOS,
compliance with the HCl emission limit shall be demonstrated as follows for the first 180 days of
operation under the AOS:
A. Emissions shall be estimated by multiplying the lime throughput (tons/month)
for each kiln by HCl emission factors
B. The following emission factors shall be used:
i. 1.67E-1 lbs HCl/ton of lime for the dolomitic lime line
ii. 1.26E-1 lbs HCl/ton of lime for the high calcium line.
[R307-401-8]
II.B.6.f When the HCl CEMS have been installed calibrated, and are operating, HCl emissions shall be
calculated as follows for each kiln:
A. Hourly HCl emissions (Eh) shall be calculated using CEMS data as follows:
Eh = K * C * Q
Where:
Eh = hourly HCl mass emission rate during unit operation, lb/hr
K = 9.46E-8 for HCl, lb/scf/ppm
C = HCl concentration averaged for each one-hour period, ppmvw, as measured
by the CEMS
Q = volumetric flow rate averaged for each one-hour period, scfh (wet)
B. The daily HCl emissions (Ed) in pounds shall be calculated by summing the
hourly HCl emissions (Eh) during measured during the day. For purposes of this
subsection, a "day" is defined as a period of 24-hours commencing at midnight
and ending the following midnight
C. Measured monthly HCl emissions shall be calculated by summing the daily
emissions for all operating days in each month.
[R307-401-8]
DAQE-AN103130047-24
Page 25
II.B.6.g The owner/operator shall follow the data replacement procedure below when the HCl CEMS
data are not valid or unavailable due to monitor downtime or because the monitor is out of
control, as determined by 40 CFR 60 Appendix F, Procedure 1 and/or 6:
Ema = Em * (1 +(1/DA - 1) x C
Where:
Ema = adjusted monthly HCl emissions, lbs
Em = total unadjusted HCl mass emission for the month, prior to data replacement procedure,
lb/hr
DA = data availability, fraction of operating time for which monitor data is available during the
reporting period (e.g. 95% data availability = 0.95) and,
C = Conservative Factor = 1.05 = 5% increase.
[R307-401-8]
II.B.6.h The owner/operator shall record the output of the system for measuring HCl emissions. The
monitoring system shall operate continuously in accordance with the DAQ Policy Document for
Continuous Emissions Monitoring Systems. The monitoring system shall comply with all
applicable sections of R307-170, UAC and 40 CFR 60 Subpart A and Appendix B, and either
Performance Specification PS-18 or Performance Specification PS-15 as applicable and
approved by the Director. [R307-401-8]
II.B.6.i The Director shall consider the continuous monitoring requirements to be met when the
following provisions are met:
1) Except for system breakdown, repairs, calibration checks, and zero and span
adjustments required under 40 CFR 60.13(d), the owner/operator of an affected source
shall continuously operate all required continuous monitoring devices and shall meet
minimum frequency of operation requirements as outlined in 40 CFR 60.13(e) and
R307-170, UAC. Flow measurement shall be in accordance with the requirements of 40
CFR 52; Appendix E, 40 CFR 60 Appendix B; or 40 CFR 75, Appendix A
2) Initial performance specification test shall be performed within 60 days of
installation. The performance specification test shall be conducted in accordance with
the procedures contained in 40 CFR 60, Appendix B, Performance Specifications 15 or
18. The Director shall be notified prior to conducting the performance specification test
3) At no time shall the owner/operators allow excess gaseous emissions to be emitted to
the atmosphere, except as provided by the provisions of R307-107(Breakdowns), UAC.
[R307-170]
DAQE-AN103130047-24
Page 26
II.B.6.j The owner/operator shall follow the following requirements for stack testing of organic and
metal HAPs:
A. Emission Units
Emission units subject to organic and metal HAPs testing requirements are Kiln
#1, Kiln #2, Kiln #3, Kiln #4, and Kiln #5
B. Initial Compliance Testing
Initial compliance testing shall be performed as soon as possible and not later
than 180 days after the owner/operator commences operation under the AOS
C. Frequency
Test every three (3) years
D. Test Method Organic HAPs
40 CFR 60, Appendix A, Method 320 and Method 18, or other EPA-approved
testing method acceptable to the Director
E. Test Method Chlorine
40 CFR 60, Appendix A, Method 26A, or other EPA-approved testing method
acceptable to the Director
F. Test Method Metal HAPs
40 CFR 60, Appendix A, Method 29, or other EPA-approved testing method
acceptable to the Director
G. Other
Unless otherwise specified in this Section, the stack requirements in II.B.1.b.2
and II.B.1.b.3 apply.
[R307-401-8]
II.B.6.k Quarterly reports shall be submitted as outlined in R307-170. The reports shall also include:
1) Total HCl emissions for the cumulative quarters of the current 12-month block
2) Total HAPs emissions for the cumulative quarters of the current 12-month block.
[R307-170, R307-401-8]
PERMIT HISTORY
This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103130044-21 dated May 4, 2021
Is Derived From Source Submitted NOI dated June 14, 2023
Incorporates Additional Information Received dated October 2, 2023
DAQE-AN103130047-24
Page 27
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds
DAQE-IN103130047-23
December 7, 2023
Colby Roberts
Graymont Western US Incorporated
585 West Southridge Way
Sandy, UT 84070
nstettler@graymont.com
Dear Mr. Roberts:
Re: Intent to Approve: Enhanced Approval Order Change to DAQE-AN103130044-21 to Correct
Fugitive Dust Conditions
Project Number: N103130047
The attached document is the Intent to Approve (ITA) for the above-referenced project. The ITA is
subject to public review. Any comments received shall be considered before an Approval Order (AO) is
issued. The Division of Air Quality is authorized to charge a fee for reimbursement of the actual costs
incurred in the issuance of an AO. An invoice will follow upon issuance of the final AO.
Future correspondence on this ITA should include the engineer's name, John Jenks, as well as the DAQE
number as shown on the upper right-hand corner of this letter. John Jenks, can be reached at (385) 306-
6510 or jjenks@utah.gov, if you have any questions.
Sincerely,
{{$s }}
Jon L. Black, Manager
New Source Review Section
JLB:JJ:jg
cc: Central Utah Health Department
DJ Law, EPA Region 8
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
* ) ' & — F v A ? A B @ C w B G ˜
STATE OF UTAH
Department of Environmental Quality
Division of Air Quality
INTENT TO APPROVE
DAQE-IN103130047-23
Enhanced Approval Order Change to DAQE-AN103130044-21 to
Correct Fugitive Dust Conditions
Prepared By
John Jenks, Engineer
(385) 306-6510
jjenks@utah.gov
Issued to
Graymont Western US Incorporated - Cricket Mountain Plant
Issued On
December 7, 2023
{{$s }}
New Source Review Section Manager
Jon L. Black
{{#s=Sig_es_:signer1:signature}}
* ) ' & — F v A ? A B @ C w B G ˜
TABLE OF CONTENTS
TITLE/SIGNATURE PAGE ....................................................................................................... 1
GENERAL INFORMATION ...................................................................................................... 3
CONTACT/LOCATION INFORMATION ............................................................................... 3
SOURCE INFORMATION ........................................................................................................ 3
General Description ................................................................................................................ 3
NSR Classification .................................................................................................................. 3
Source Classification .............................................................................................................. 3
Applicable Federal Standards ................................................................................................. 3
Project Description.................................................................................................................. 4
SUMMARY OF EMISSIONS .................................................................................................... 4
PUBLIC NOTICE STATEMENT............................................................................................... 5
SECTION I: GENERAL PROVISIONS .................................................................................... 5
SECTION II: PERMITTED EQUIPMENT .............................................................................. 6
SECTION II: SPECIAL PROVISIONS ................................................................................... 13
PERMIT HISTORY ................................................................................................................... 27
ACRONYMS ............................................................................................................................... 28
DAQE-IN103130047-23
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GENERAL INFORMATION
CONTACT/LOCATION INFORMATION
Owner Name Source Name
Graymont Western US Incorporated Graymont Western US Incorporated - Cricket
Mountain Plant
Mailing Address Physical Address
585 West Southridge Way
Sandy, UT, 84070
32 Miles Southwest of Delta, Utah; Highway 257
PO Box 669
Delta (Millard), UT 84624
Source Contact UTM Coordinates
Name Nate Stettler 343,100 m Easting
Phone (801) 598-8076 4,311,010 m Northing
Email nstettler@graymont.com Datum NAD27
UTM Zone 12
SIC code 1422 (Limestone, Crushed & Broken)
SOURCE INFORMATION
General Description
Graymont Western US Incorporated (Graymont) operates the Cricket Mountain Lime Plant in Millard
County. The Cricket Mountain Lime Plant consists of quarries and a lime processing plant, which
includes five rotary lime kilns (Kilns 1 through 5). The rotary kilns are used to convert crushed limestone
ore into quicklime. The products produced for resale are lime, limestone, and kiln dust. The kilns operate
on pet coke and coal. Sources of emissions at this source include mining, limestone processing, rotary
lime kilns, post-kiln lime handling, and truck & loadout facilities.
NSR Classification
Minor Modification at Major Source
Source Classification
Located in Attainment Area
Millard County
Airs Source Size: A
Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), HH: Standards of Performance for Lime Manufacturing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
DAQE-IN103130047-23
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MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
MACT (Part 63), AAAAA: National Emission Standards for Hazardous Air Pollutants for
Lime Manufacturing Plants
Title V (Part 70) Major Source
Project Description
Graymont submitted a request for updating the chemical stabilizer dust control application. Specifically,
that the frequency of application be reduced from a schedule of 3 times a year to 2 times a year. After
review, UDAQ determined that the listing of dust control requirements in the AO is redundant. The
requirement to maintain a dust control plan is sufficient for the minimization of fugitive dust. With the
removal of the listed conditions in the AO, Graymont is free to modify the fugitive dust control plan to
incorporate the change in application frequency. No change in equipment, processes or associated
emissions will occur.
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 887964.00
Carbon Monoxide 0 7821.19
Nitrogen Oxides 0 3883.85
Particulate Matter - PM10 0 611.87
Particulate Matter - PM2.5 0 610.78
Sulfur Oxides 0 760.29
Volatile Organic Compounds 0 117.84
Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 0 1963
Acrolein (CAS #107028) 0 1
Arsenic (TSP) (CAS #7440382) 0 88
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 7734
Cadmium (CAS #7440439) 0 58
Chlorine (CAS #7782505) 0 1078
Chromium Compounds (CAS #CMJ500) 0 1214
Cobalt (TSP) (CAS #7440484) 0 1154
Ethyl Benzene (CAS #100414) 0 488
Formaldehyde (CAS #50000) 0 1612
Hexane (CAS #110543) 0 2566
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 0 44400
Hydrogen Fluoride (Hydrofluoric Acid) (CAS #7664393) 0 156
Lead (CAS #7439921) 0 1204
Manganese (TSP) (CAS #7439965) 0 546
Mercury (TSP) (CAS #7439976) 0 64
Nickel (CAS #7440020) 0 422
DAQE-IN103130047-23
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Selenium & Compounds (CAS #253) 0 402
Toluene (CAS #108883) 0 2678
Xylenes (Isomers And Mixture) (CAS #1330207) 0 2562
Change (TPY) Total (TPY)
Total HAPs 0 35.19
PUBLIC NOTICE STATEMENT
The NOI for the above-referenced project has been evaluated and has been found to be consistent with the
requirements of UAC R307. Air pollution producing sources and/or their air control facilities may not be
constructed, installed, established, or modified prior to the issuance of an AO by the Director.
A 30-day public comment period will be held in accordance with UAC R307-401-7. A notification of the
intent to approve will be published in the Millard County Chronicle Progress on December 13, 2023.
During the public comment period the proposal and the evaluation of its impact on air quality will be
available for the public to review and provide comment. If anyone so requests a public hearing within 15
days of publication, it will be held in accordance with UAC R307-401-7. The hearing will be held as
close as practicable to the location of the source. Any comments received during the public comment
period and the hearing will be evaluated. The proposed conditions of the AO may be changed as a result
of the comments received.
SECTION I: GENERAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.
I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five (5) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO
including associated air pollution control equipment in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available to
the Director which may include, but is not limited to, monitoring results, opacity observations,
review of operating and maintenance procedures, and inspection of the source. All
maintenance performed on equipment authorized by this AO shall be recorded. [R307-401-4]
DAQE-IN103130047-23
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I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories.
[R307-150]
SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.
II.A THE APPROVED EQUIPMENT
II.A.1 Lime Manufacturing Plant
[All equipment designation numbers are those used by Graymont Western U.S. Incorporated]
II.A.2 K-1 Kiln
Rotary Lime Kiln #1 rated at 600 tons of lime per 24-hour period with a preheater and baghouse
emissions control system (D-85) rated at an exhaust gas flow rate 54,000 scfm and an Air to
Cloth (A/C) ratio of 3.26:1.
NESHAP Applicability: 40 CFR 63 Subpart AAAAA
II.A.3 K-2 Kiln
Rotary Lime Kiln #2 rated at 600 tons of lime per 24-hour period with a preheater, cyclone and
baghouse emissions control system (D-275) rated at an exhaust gas flow rate of 48,000 scfm and
an A/C ratio of 2.9:1.
NESHAP Applicability: 40 CFR 63 Subpart AAAAA
II.A.4 K-3 Kiln
Rotary Lime Kiln #3 rated at 840 tons of lime per 24-hour period with a preheater, cyclone and
baghouse emissions control system (D-375) rated at an exhaust gas flow rate of 55,000 scfm and
a A/C ratio of 2.49:1.
NESHAP Applicability: 40 CFR 63 Subpart AAAAA
II.A.5 K-4 Kiln
Rotary Lime Kiln #4 rated at 1266 tons of lime per 24-hour period with a preheater, cyclone and
baghouse emissions control system (D-485) rated at an exhaust gas flow rate of 100,000 scfm
and an A/C ratio of 5:1.
NESHAP Applicability: 40 CFR 63 Subpart AAAAA
II.A.6 K-5 Kiln
Rotary Lime Kiln #5 rated at 1400 tons of lime per 24-hour period with a preheater and baghouse
emissions control system (D-585) rated at an exhaust gas flow rate of 103,000 scfm and an A/C
ratio of 3.5:1.
NESHAP Applicability: 40 CFR 63 Subpart AAAAA
II.A.7 KDE-1 Kiln Drive Engine
Rating: 52 hp
Fuel: Diesel
NSPS Applicability: 40 CFR 60 Subpart IIII
MACT Applicability: 40 CFR 63 Subpart ZZZZ
DAQE-IN103130047-23
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II.A.8 KDE-2 Kiln Drive Engine
Rating: 45 hp
Fuel: Diesel
NSPS Applicability: 40 CFR 60 Subpart IIII
MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.9 KDE-3 Kiln Drive Engine
Rating: 55 hp
Fuel: Gasoline
MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.10 KDE-4 Kiln Drive Engine
Rating: 65 hp
Fuel: Diesel
Manufacture Date: Pre 12/19/2002
MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.11 KDE-5 Kiln Drive Engine
Rating: 173.5 hp
Fuel: Diesel
NSPS Applicability: 40 CFR 60 Subpart IIII
MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.12 D-91 Coal Silo Baghouse
For Kiln #1
Exhaust gas flow rate: 1,000 scfm
II.A.13 D-94 Coal Silo Baghouse
For Kiln #2
Exhaust gas flow rate: 1,000 scfm
II.A.14 D-391 Coal Silo Baghouse
For Kiln #3
Exhaust gas flow rate: 1,000 scfm
II.A.15 D-491 Coal Silo Baghouse
For Kiln #4
Exhaust gas flow rate: 1,500 scfm
II.A.16 D-591 Coal Silo Baghouse
For Kiln #5
Exhaust gas flow rate: 1,000 acfm
II.A.17 D-331 Product Baghouse
For Kiln #1, #2 loadout area and screenhouse dust collector
Exhaust gas flow rate: 32,000 scfm
II.A.18 D-330 Product Baghouse
For Kiln #3 cooler pit dust collector
Exhaust gas flow rate: 11,000 scfm
II.A.19 D-447 Product Baghouse
For Kiln #4 cooler and screenhouse dust collector
Exhaust gas flow rate: 18,300 scfm
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II.A.20 D-463 Product Baghouse
For Kiln #4 product loadout and C-463 dust collector
Exhaust gas flow rate: 8,300 scfm
II.A.21 D-341 Product Baghouse
For Silo T-341
Exhaust gas flow rate: 2,000 scfm
II.A.22 D-530 Product Baghouse
Product handling baghouse #1 for Kiln #5 screen house
Exhaust gas flow rate: 9,000 acfm
II.A.23 D-564 Product Baghouse
Product handling baghouse #2 for Kiln #5 screen house
Exhaust gas flow rate: 9,000 acfm
II.A.24 D-547 Product Baghouse
Product handling baghouse #3 for Kiln #5 screen house
Exhaust gas flow rate: 9,000 acfm
II.A.25 D-83 Lime Kiln Dust Silo Baghouse
For Kilns #1 and #2
Exhaust gas flow rate: 6,000 scfm
II.A.26 D-489 Lime Kiln Dust Silo Baghouse
For Kilns #4 lime kiln dust silo
Exhaust gas flow rate: 6,000 scfm
II.A.27 D-486 Lime Kiln Dust Silo Baghouse
For Kiln #4
Exhaust gas flow rate: 4,000 scfm
II.A.28 D-466 Lime Kiln Dust Silo Baghouse
For lime kiln dust silo
Exhaust gas flow rate: 4,000 scfm
II.A.29 D-586 Lime Kiln Dust Silo Baghouse
For Kiln #5 dust silo
Exhaust gas flow rate: 2,500 scfm
II.A.30 D-589 Lime Kiln Dust Silo Baghouse
For loadout of Kiln #5 dust silo
Exhaust gas flow rate: 1,500 scfm
II.A.31 T-381 Lime Kiln Dust Silo
Maximum Capacity: 300 tons
II.A.32 D-381 Lime Kiln Dust Silo Baghouse
For 300-ton lime kiln dust silo (T-381)
Exhaust gas flow rate: 3,000 scfm
II.A.33 T-381 Loadout Spout
For 300-ton lime kiln dust silo (T-381)
II.A.34 D-382 Loadout Spout (T-381) Baghouse
For Loadout Spout (T-381)
Exhaust gas flow rate: 2,000 scfm
DAQE-IN103130047-23
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II.A.35 D-333 Product Loadout Baghouse
For rail loadout
Exhaust gas flow rate: 10,000 scfm
II.A.36 D-10 Limestone Ore Preparation Baghouse
For stone reclaim screen for Kiln #1 & #2
Exhaust gas flow rate: 8,000 scfm
II.A.37 D-310 Limestone Ore Processing Baghouse
For stone dressing screen for Kiln #3
Exhaust gas flow rate: 8,000 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.38 D-414 Limestone Ore Processing Baghouse
For stone dressing screen for Kiln #4
Exhaust gas flow rate: 3,100 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.39 D-514 Limestone Ore Processing Baghouse
For stone dressing screen for Kiln #5
Exhaust gas flow rate: 4,500 acfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.40 D-1 Limestone Ore Processing Baghouse
For quarry crusher & screen
Exhaust gas flow rate: 28,000 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.41 D-503 Conveying System
For dust collection for Kiln #5 limestone conveyor transfer points
Exhaust flow rate: 2,000 acfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.42 D-403 Conveying System
For stone dump from conveyor 408 & 409 to reclaim pile
Exhaust gas flow rate: 2,200 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.43 D-415 Conveying System with Baghouse
For limestone dump to Kiln #4 preheater
Exhaust gas flow rate: 600 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.44 D-479 Dolomitic Lime Handling System Baghouse
Product transfer baghouse to S-471, T-471, T-472, T-473, and T-474. The 435-material
handling system consists of 2 elevators, a vibratory conveyor, a number of belt conveyors, and a
mixing screw conveyor
Exhaust gas flow rate: 4,300 scfm
II.A.45 R-486 Dolomite Crusher
Rating: 40 tons/hr
II.A.46 N-470 Dolomitic Lime Handling System
Recycle Bin
DAQE-IN103130047-23
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II.A.47 Processed Stone Handling (PSH) Operations
Operations to transport material from storage piles (fines, small stone, medium stone, large stone
[sugar]) to kiln preheaters. Includes bins, bin transfer points, preheater transfer points, and
conveyors.
NESHAP Applicability: 40 CFR 63 Subpart AAAAA
II.A.48 Sugar Stone System
System to store, screen and load sugar stones. Includes a hopper (HP-1), screen (S-2), loadout
system (203255SSS001), conveyors (C-MISC2), and generator (GEN-1).
II.A.49 HP-1 Hopper Sugar Stone System
II.A.50 S-2 Screen Sugar Stone System
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.51 Loadout Sugar Stone System
Rail Loadout
II.A.52 C-MISC2 Sugars Stone System
Miscellaneous Conveyors
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.53 GEN-1 Generator Sugar Stone System
Rating: 130.1 hp
Fuel: Diesel
MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.54 Portable Crusher System (PCS)
Includes hopper, crushers (PCS-1), hopper (HP-2), generator (PCS-4), and conveyors.
II.A.55 PCS Hopper
Feed Hopper
II.A.56 PCS-1 Crusher System
ICR101: Primary Crusher
Capacity: 690 tons/hr
ICR102: Secondary Crusher
Capacity: 690 tons/hr
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.57 PCS-2 Screen/Conveyor Transfer Points
Screen and material transfer points to and from conveyor belts.
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.58 PCS-3 Conveyor Drop Points
Material drop points to the fines and product stockpiles
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.59 PCS-4 Generator Portable Crusher System
Quantity: 3
Rating: 740 hp combined
Fuel: Diesel
II.A.60 PCS Conveyors
NSPS Applicability: 40 CFR 60 Subpart OOO
DAQE-IN103130047-23
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II.A.61 D-7122 Limestone Grinding Plant Baghouse
For grinding mill, direct-fire heater, material separator
Exhaust gas flow rate: 10,000 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.62 D-7133 Limestone Grinding Plant Baghouse
For screen, three bucket elevators, three storage silos
Exhaust gas flow rate: 4,500 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.63 D-7141 Limestone Grinding Plant Baghouse
For truck load-out and rail load-out
Exhaust gas flow rate: 3,500 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.64 C-MISC1 Limestone Grinding Plant
Miscellaneous Conveyors
II.A.65 D-488 Briquetter and Crusher Baghouse
For crusher (R-486), briquetters (BRI-474 and BRI-014), and silo (T-470)
Exhaust gas flow rate: 1,700 scfm
II.A.66 BRI-474 Briquetter
II.A.67 BRI-014 Briquetter
II.A.68 C-045 Conveying System
Fines Truck Loadout Conveyor - 250 tons/hr
II.A.69 C-305 Conveying System
Medium and Small Stone Pile Conveyor - 600 tons/hr
II.A.70 S-466 Screen
Dolomitic Screen
II.A.71 C-Coal Handling
Miscellaneous Conveyors
II.A.72 Feeder-Coal Handling
Four Vibratory Feeders
II.A.73 PW Portable Pressure Washer
Rating: 18 hp
Fuel: Gasoline
II.A.74 HR-1 Haul Road
Quarry to plant and plant to highway.
Length: 6 miles
II.A.75 HR-2 Haul Road
Inside quarry
II.A.76 Limestone Fines Product (LFP) Loadout System
Includes a screen hopper, screen, screen conveyors, tent storage area, product loadout hopper,
product loadout conveyor, and engines (CAT4.4 and V3600-T).
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II.A.77 LFP - Engines
CAT 4.4 Generator
Rating: 130 hp
Kubota V3600-T Generator
Rating: 52 hp
Fuel: Diesel
NSPS Applicability: 40 CFR 60 Subpart IIII
MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.78 LFP-1 Hopper
Capacity: 250 ton/hour
II.A.79 LFP-2 Screen
Capacity: 250 ton/hour
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.80 LFP-3 Conveyors
Capacity: 250 ton/hour
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.81 LFP-4 Storage
Tent storage area
II.A.82 LFP-5 Hopper
Product loadout hopper
Capacity: 100 ton/hour
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.83 LFP-6 Conveyor
Product Loadout Conveyor
Capacity: 100 ton/hour
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.84 Stationary Pressure Washer
Rating: 0.4 MMBtu/hr
Fuel: Propane
Listed for information purposes only
II.A.85 Fuel Storage Tanks
Four 10,150-gallon diesel storage tanks
One 12,000-gallon diesel storage tank
One 2,000-gallon gasoline storage tank
One 500-gallon gasoline storage tank
DAQE-IN103130047-23
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SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the AO.
II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Sitewide Requirements
II.B.1.a The following limits shall not be exceeded:
A. For Kilns #1, #2, #3, #4 and #5 collectively:
1) 1,516,250 tons lime per rolling 12-month period.
2) 4,706 tons lime per day.
B. Sugar Stone System
1) 135,000 tons of sugar stone per rolling 12-month period.
2) 750 hours of operation for the 130.1 hp generator per rolling 12-
month period.
C. Portable Crushing System
1) 750,000 tons of limestone per rolling 12-month period.
2) 4,000 hours of operation per rolling 12-month period.
D. Truck hauling of stone from the quarry to the plant
1) No more than 108 rounds trips per day (midnight to midnight) 24-
hour period.
E. Limestone Fines Product Loadout Process
1) 200,000 tons of limestone per rolling 12-month period.
2) 6,500 hours of operation per rolling 12-month period.
[R307-401]
II.B.1.a.1 Compliance with the above 12-month production limitations shall be determined on a rolling 12-
month total. Calculations for the 12-month production shall be completed within 25 calendar
days from the end of the previous month. Records of production shall be kept for all periods
when the plant is in operation. Production shall be determined by plant production records, such
as scale records or sales receipts. Hours of operation and number of truck trips shall be
determined by records of operation. The records shall be kept on a daily basis. [R307-401-8]
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II.B.1.b Emissions to the atmosphere from the indicated emission point shall not exceed the following
rates and concentrations (standardized at 68 oF, 29.92 in Hg) (lbs/tsf = pounds per ton of stone
fed):
Emission Point: Kiln #1 Baghouse Stack
Pollutant lb/hr grain/dscf lbs/tsf
TSP 0.020 0.12
PM10 (Filterable + Condensable) 6.0 0.016
SO2 22.4
NOx 90.0
Emission Point: Kiln #2 Baghouse Stack
Pollutant lb/hr grain/dscf lbs/tsf
TSP 8.23 0.020 0.12
PM10 (Filterable + Condensable) 6.58 0.016
SO2 22.4
NOx 120.0
Emission Point: Kiln #3 Baghouse Stack
Pollutant lb/hr grain/dscf lbs/tsf
TSP 7.49 0.020 0.10
PM10 (Filterable + Condensable) 7.54 0.016
SO2 27.2
NOx 160.0
Emission Point: Kiln #4 Baghouse Stack
Pollutant lb/hr grain/dscf lbs/tsf
TSP 17.14 0.020 0.12
PM10 (Filterable + Condensable) 13.7 0.016
SO2 38.4
NOx 200.0
Emission Point: Kiln #5 Baghouse Stack
Pollutant lb/hr grain/dscf Other
TSP 0.020 0.10 lbs/tsf
PM10 (Filterable + Condensable) 11.7 0.016
SO2 59.0 1.01 lb/ton lime
NOx 210.0 3.60 lb/ton lime
CO 233.0 4.00 lb/ton lime
Emission Point: Briquetter and Crusher Baghouse (D-488) Stack
Pollutant lb/hr grain/dscf
TSP 0.29 0.020
PM10 (Filterable) 0.15 0.010
PM2.5 (Filterable) 0.15 0.010
After the installation of an SO2 CEMS, compliance with the SO2 emission limit will be based on
a 3-hour block average.
Testing for compliance with the lb/ton lime limits must comply with all stack testing
requirements.
[R307-401]
DAQE-IN103130047-23
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II.B.1.b.1 Stack testing to show compliance with the emission limitations stated in the above condition
shall be performed as specified below:
Emission Point Pollutant Status Test Frequency
Kiln #1 Baghouse Stack TSP *** +
PM10 *** +
SO2 *** +
NOx *** +
Emission Point Pollutant Status Test Frequency
Kiln #2 Baghouse Stack TSP *** +
PM10 *** +
SO2 * +
NOx * +
Emission Point Pollutant Status Test Frequency
Kiln #3 Baghouse Stack TSP *** +
PM10 *** +
SO2 * +
NOx *** +
Emission Point Pollutant Status Test Frequency
Kiln #4 Baghouse Stack TSP *** +
PM10 *** +
SO2 *** +
NOx *** +
Emission Point Pollutant Status Test Frequency
Kiln #5 Baghouse Stack TSP *** +
PM10 *** +
SO2 *** +
NOx *** +
CO *** +
Emission Point Pollutant Status Test Frequency
(D-488) Baghouse Stack TSP *** +
PM10 *** +
PM2.5 (Filterable)*** +
* No Initial Testing was required. The source shall be tested if directed by the Director at any
time.
** Initial compliance testing is required. The initial test date shall be performed as soon as
possible and in no case later than 180 days after the startup of a new emission source, an existing
source without an AO, or the granting of an AO to an existing emission source that has not had
an initial compliance test performed. If an existing source is modified, a compliance test is
required on the modified emission point that has an emission rate limit.
*** Initial compliance testing was required and completed.
+ Test every three years. The Director may require testing at any time.
[R307-401]
DAQE-IN103130047-23
Page 16
II.B.1.b.2 A. Notification
The Director shall be notified at least 60 days prior to conducting any required emission
testing for sources subject to 40 CFR 63 Subpart AAAAA. All other sources shall notify
the Director at least 30 days prior to conducting any required emission testing. A source
test protocol shall be submitted to DAQ when the testing notification is submitted to the
Director.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
B. Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other methods as approved by the Director. An Occupational
Safety and Health Administration (OSHA) or Mine Safety and Health Administration
(MSHA) approved access shall be provided to the test location.
C. Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2 or other EPA-approved testing method acceptable to
the Director.
D. Total Suspended Particulate (TSP)
40 CFR 60, Appendix A, Method 5 or other EPA-approved testing method acceptable to
the Director.
E. PM10 (Filterable + Condensable)
For stacks in which no liquid drops are present, the following methods shall be used: 40
CFR 51, Appendix M, Methods 201, 201a, or other EPA approved method as acceptable
to the Director. The back half condensables shall also be tested using the EPA approved
method acceptable by the Director. All particulate captured shall be considered PM10.
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, or other EPA
approved method as acceptable to the Director. The back half condensables shall also be tested
using the EPA 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 edition of the EPA
document, AP-42, or other data acceptable to the Director.
F. PM2.5 (Filterable)
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A or other
EPA-approved testing method as acceptable to the Director. If other approved testing
methods are used which cannot measure the PM2.5 fraction of the filterable particulate
emissions, all of the filterable particulate emissions shall be considered PM2.5. The
portion of the front half of the catch considered PM2.5 shall be based on information in
Appendix B of the fifth edition of the EPA document, AP-42, or other data acceptable to
the Director.
G. Sulfur Dioxide (SO2)
40 CFR 60, Appendix A, Method 6, 6A, 6B, 6C, or other EPA-approved testing method
acceptable to the Director.
H. Nitrogen Oxides (NOx)
40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, 7E, or other EPA approved method
as acceptable to the Director.
I. Carbon Monoxide (CO)
40 CFR 60, Appendix A, Method 10, or other EPA approved method as acceptable to the
Director.
[R307-401]
DAQE-IN103130047-23
Page 17
II.B.1.b.3 J. 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.
To determine emission rates in units of lbs/ton lime, the emission rate in lbs/hour shall be divided
by the tons/hour lime production rate. Lime production rate shall either be a direct measurement
or shall be calculated using the following conversion factor: 2 tons of limestone feed equates to 1
ton of lime produced (2 tons limestone: 1-ton lime).
K. New Source Operation
For a new source/emission point, the production rate during all compliance testing shall
be no less than 90% of the production rate listed in this AO. If the maximum AO
allowable production rate has not been achieved at the time of the test, the following
procedure shall be followed:
1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be
110% of the tested achieved rate, but not more than the maximum allowable
production rate. This new allowable maximum production rate shall remain in
effect until successfully tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary.
Testing at no less than 90% of the higher rate shall be conducted. A new
maximum production rate (110% of the new rate) will then be allowed if the test
is successful. This process may be repeated until the maximum AO production
rate is achieved.
L. Existing Source Operation
For the existing kilns, the production rate during all compliance testing shall be no less
than 90% of the maximum production achieved in the previous three (3) years.
M. Reporting
The results of stack testing shall be submitted to the Director within 60 days of
completion of the testing. Reports shall clearly identify results as compared to permit
limits and indicate compliance status.
[R307-165, R307-401]
DAQE-IN103130047-23
Page 18
II.B.1.c Visible emissions from the following emission points shall not exceed the following opacity
values:
A. Kilns #1, #2, #3, #4, and #5 15%
B. All ancillary silo and storage bin baghouses 10%
C. Product baghouses 10 %
D. Subpart OOO baghouses 7%
E. All non-OOO crushers 15%
F. All non-OOO screens 10%
G. All non-OOO conveyor transfer points 10%
H. Subpart OOO crushers*
i. Post-April 22, 2008 12%
ii. Pre-April 22, 2008 15%
I. Subpart OOO screens*
i. Post-April 22, 2008 7%
ii. Pre-April 22, 2008 10%
J. Subpart OOO conveyor transfer points*
i. Post-April 22, 2008 7%
ii. Pre-April 22, 2008 10%
K. All diesel engines 20%
L. Conveyor drop points 20%
M. PSH operations stack emissions 7%
N. PSH operations fugitive emissions 10%
O. All other points sources 20%
*Opacity limits from 40 CFR 60 Subpart OOO shown as "Post-April 22, 2008" applies to
emission units constructed, modified, or reconstructed on or after April 22, 2008 and "Pre-April
22, 2008" applies to emission units constructed, modified, or reconstructed on or after August 31,
1983 but before April 22, 2008.
Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9.
For sources that are subject to NSPS, opacity shall be determined by conducting observations in
accordance with 40 CFR 60.11(b) and 40 CFR 60, Appendix A, Method 9.
Visible emissions from haul road traffic shall be minimized in accordance with the fugitive dust
control plan.
[R307-401]
DAQE-IN103130047-23
Page 19
II.B.1.c.1 The owner/operator shall make at least one visual opacity survey each quarter for each kiln drive
engine. The visual opacity survey shall be performed while the unit is operating by an individual
trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The individual is
not required to be a certified visual emissions observer (VEO). If visible emissions 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. The owner/operator shall
maintain a log of the visual opacity surveys, opacity determinations, and all data required by 40
CFR 60, Appendix A, Method 9. [R307-401]
II.B.2 Fuel Requirements
II.B.2.a The owner/operator shall use coal as the primary fuel, except a combination of coal and
petroleum coke (pet coke) may be used in Kilns #1 and #5, and propane and fuel oil as a startup
fuel in all kilns. Prior to burning petroleum coke in Kilns #1 and #5 or coal with a sulfur content
in excess of 1.0 lb/MMBTU in Kilns #1, #2, #3, #4, or #5, an SO2 CEM must be installed,
calibrated, and operating on that kiln. [R307-401]
II.B.2.b The owner/operator shall use propane, diesel, and used oil in any combination in the direct fire
heating system for the limestone grinding plant. [R307-401]
II.B.2.c The sulfur content of any coal or any mixture of coals burned shall not exceed 1.0 pounds of
sulfur per MMBTU heat input. Sulfur content shall be determined by the owner/operator or the
coal supplier using ASTM Method D3174-12(2018), D3176-15, D4239-18e1, D5016-16 or an
approved equivalent ASTM Method. If the owner/operator chooses supplier certification, the
sulfur content shall be tested quarterly from a composite sample. If the owner/operator chooses
to test the sulfur content of the coal, the composite sample shall be tested quarterly from a
composite grab sample taken every 24 hours of operation. Records, or supplier furnished
certifications, of this testing shall be kept on-site for a period of five (5) years and be provided to
the Director upon request.
After a SO2 CEMS has been installed, calibrated, and is operating on a kiln, the coal that is
burned in that kiln is exempt from the 1.0 pounds of sulfur per MMBTU heat input limitation of
UAC R307-203-1(1).
[R307-203-1]
II.B.2.d Except for diesel, the sulfur content of any fuel oil burned as a startup fuel in all kilns shall not
exceed 0.85 pounds of sulfur per MMBTU heat input. Sulfur content shall be decided by ASTM
Method D-3175-75, or an approved equivalent. The sulfur content shall be tested if directed by
the Director. [R307-401]
DAQE-IN103130047-23
Page 20
II.B.2.e The air heating combustor burning used oil for energy recovery shall comply with the following:
A. The concentration/parameters of contaminants in any used oil burned as fuel
shall not exceed the following levels:
1) Arsenic 5 ppm by weight
2) Cadmium 2 ppm by weight
3) Chromium 10 ppm by weight
4) Lead 100 ppm by weight
5) Total halogens 1,000 ppm by weight
6) Sulfur 0.50 percent by weight
B. The flash point of all used oil to be burned as fuel shall not be less than 100
degrees F.
C. Used oil that does not exceed any of the listed contaminants content may be
burned. The owner/operator shall record the quantities of oil burned.
D. Sources utilizing used oil as a fuel shall comply with the State Division of Waste
Management and Radiation Control in accordance with R315-15, UAC.
[R307-401]
II.B.2.f The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives) as
fuel in the KDE-1, KDE-2, KDE-4, and KDE-5 drive engines; GEN-1 engine; portable
generators; and LFP engines. [R307-401-8]
II.B.2.g The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.2.g.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall maintain
records of diesel fuel purchase invoices or obtain certification of sulfur content from the diesel
fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel meets the
ULSD requirements. [R307-401-8]
II.B.3 SO2 and Opacity CEMS Requirements
II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system for the continuous measurement of opacity on kiln stacks #1, #2,
#3, #4 and #5. The owner/operator shall record the output of the system for measuring the
opacity of emissions. The monitoring system shall operate continuously in accordance with the
DAQ Policy Document for Continuous Emission Monitoring Systems. The monitoring system
shall comply with all applicable sections of R307-170, UAC and 40 CFR 60, Appendix B,
Specification 1 - Opacity. [R307-170]
II.B.3.b The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system (consisting of a SO2 pollutant concentration monitor and a flow
monitoring device) for the continuous measurement of SO2 emissions on a kiln if that kiln burns
pet coke or coal with a sulfur content in excess of 1.0 lb Sulfur/MMBtu.
The owner/operator shall record the output of the system for measuring SO2 emissions. The
monitoring system shall comply with all applicable sections of R307-170, UAC and 40 CFR 50
Appendix B, Performance Specifications 2 - SO2 and NOx Continuous Emission Monitoring
Systems.
[R307-170]
DAQE-IN103130047-23
Page 21
II.B.3.c When a SO2 CEMS has been installed calibrated, and is operating, the emission rate of SO2 in
pounds per hour measured by the SO2 CEMS for each 3-hour block averaging period will be
calculated by the following formula:
Eh = K * Chp * Qhs * [(100 - %H2O)/100]
Where: Eh = hourly SO2 mass emission rate during unit operation, lb/hr
K = 1.66 E-7 for SO2, lb/scf/ppm
Chp = hourly average SO2 concentration during unit operation, ppm (dry)
Qhs = hourly average volumetric flow rate during unit operation, scfh (wet)
%H2O = constant moisture value specific to each kiln, percent by volume.
[R307-401]
II.B.3.d All continuous opacity monitoring devices as required in federal regulations and state rules shall
be installed and operational prior to placing the affected source in operation. SO2 CEMS shall be
installed and operational on a kiln prior to that kiln burning coal with a sulfur content in excess
of 1.0 lb Sulfur/MMBtu or burning pet coke.
Except for system breakdown, repairs, calibration checks, and zero and span adjustments
required under 40 CFR 60.13(d), the owner/operator of an affected source shall continuously
operate all required continuous monitoring devices and shall meet minimum frequency of
operation requirements as outlined in 40 CFR 60.13(e) and R307-170, UAC.
[40 CFR 60, R307-170]
DAQE-IN103130047-23
Page 22
II.B.3.e The Director shall consider the continuous monitoring requirements to be met when the
following provisions are met:
A. Opacity Monitors and SO2 CEMS
1) Shall operate in accordance with 40 CFR 60.13 and R307-170 UAC.
2) Prior to installation of a SO2 CEMS on a kiln, the average of three one-
hour stack test results are less than the corresponding SO2 emission limit for that
kiln.
3) After installation of the SO2 CEMS on a kiln, the 3-hour block average
is less than the corresponding SO2 emission limit for that kiln.
4) Three-hour block averages will begin on 12:01 am and end every 3
hours, thereafter.
B. Excess Emission Requirements
1) At no time shall the owner/operator allow excess gaseous emissions to be
emitted to the atmosphere, except as provided by the provisions of R307-107
(Breakdowns), UAC.
C. Reporting
1) All sources required to install a continuous emission monitor shall
submit a quarterly report in an electronic format provided by the DAQ.
2) All exceedances are to be reported in the quarterly report with explanations
(R307-170-8 Reason Categories, UAC) and corrective actions.
[40 CFR 60, R307-170]
II.B.4 Haul Roads and Fugitive Dust Requirements
II.B.4.a The owner/operator shall implement a fugitive dust control plan acceptable to the Director for
control of all dust sources associated with the Cricket Mountain Plant. Adherence to the most
recently approved fugitive dust control plan shall be monitored to demonstrate that appropriate
measures are being implemented to control fugitive dust. At least once during each permit term,
the fugitive dust control plan shall be reviewed and evaluated. If the plan review indicates
changes to the dust control plan are necessary to reflect current site operations, an updated
fugitive dust control plan shall be submitted. The owner/operator shall operate in accordance
with the most current fugitive dust control plan approved by the Director. For each plan review,
a record of the date and results of the review shall be maintained. Records that demonstrate
compliance with the most recently approved fugitive dust control plan shall also be maintained.
[R307-401]
II.B.5 Other Baghouse Requirements
II.B.5.a The pressure drop on the Briquetter and Crusher (D-488) Baghouses shall not be less than 4.0
inches of water column or more than 8.0 inches of water column. [R307-401-8]
II.B.5.a.1 The pressure drop shall be monitored and recorded weekly, while the unit is operating with
equipment located such that an inspector/operator can safely read the output at any time.
[R307-401-8]
II.B.5.a.2 All instruments shall be calibrated according to the manufacturer's instructions at least once
every 12 months. [R307-401-8]
DAQE-IN103130047-23
Page 23
II.B.6 Alternate Operating Scenario for Synthetic HAPs Minor Operations
II.B.6.a This Section contains the requirements for the AOS. If the owner/operator chooses to comply
with the AOS requirements in this Section, the source will be reclassified as an area source of
HAPs as defined in 40 CFR 63.2 effective on the date that AOS operations commence. Once
reclassified, the requirements of 40 CFR 63 Subpart AAAAA will no longer apply.
Once effective, the limits of the AOS shall apply permanently and a modification to the AO will
be required should the owner/operator need to remove or modify these limits. All other
requirements in this AO will continue to apply. The AOS limits will be applied in addition to the
requirements in II.B.1 through II.B.5.
[R307-401-8]
II.B.6.b The owner/operator shall notify the Director at least 30 days prior to the effective date on which
operations will commence under the AOS requirements specified in this section of the AO. The
notification shall include:
1. Test results for HCl and total organic HAPs that demonstrate the source meets the
definition of area source given in 40 CFR 63.2. Methods for measuring HCl and total
HAPs shall be those specified in 40 CFR 63.7142, or other EPA-approved methods, as
acceptable to the Director. Documentation of the testing shall be maintained.
2. Date when operations will commence under the AOS and the AOS conditions
limiting HAPs emissions become effective.
3. Proposed schedule for CEMS installation.
[R307-401-8]
II.B.6.c Under the AOS, the owner/operator shall limit facility-wide emissions to:
A) 9.5 tons of HCl per 12-month block period
B) 24 tons of total HAPs per 12-month block period
Total HAPs emissions must include the following compounds:
1) Organic HAPs: acetaldehyde benzene, chlorine, ethylbenzene, formaldehyde, hexane,
toluene, and xylenes.
2) Metal HAPs: arsenic, cadmium, chromium compounds, cobalt, lead, manganese,
mercury, nickel, and selenium.
3) HCl.
[R307-401-8]
II.B.6.c.1 To determine compliance with the 12-month block total, the owner/operator shall calculate a
monthly total by the twenty-fifth day of each month using data from the previous month. The
monthly totals shall be added to determine HCl and total HAPs emissions for the current 12-
month block. The 12-month block period starts on the day that the owner/operator commences
operations under the AOS. A new 12-month block period will begin each year on the date AOS
operations commenced. [R307-401-8]
DAQE-IN103130047-23
Page 24
II.B.6.c.2 The owner/operator shall demonstrate compliance with the HCl emission limit using CEMS data
as outlined in Condition II.B.6.f, except as specified in II.B.6.e. The HCl CEMS shall operate
for all periods the kilns are in operation. Records, including CEMS data and calculated
emissions, shall be tabulated for each day. [R307-401-8]
II.B.6.c.3 The owner/operator shall demonstrate compliance with the total HAPs limit using the following
data:
A. HCl CEMS data, as per II.B.6.c.2.
B. Emission rates in lbs/hr measured in the most recent stack test for organic HAPs
and metal HAPs. Stack testing requirements are specified in II.B.6.j.
C. Monthly hours of operations. Hours of operation shall be determined by records
of operation and shall be kept on a daily basis.
[R307-401-8]
II.B.6.d The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system(s) for the continuous measurement of HCl emissions on Kilns #1-
#5. The CEMS(s) shall be installed and used as the primary method of compliance within 180
days from the date the owner/operator commences operation under the AOS. At a minimum, the
HCl CEMS shall consist of HCl concentration monitor(s) for each kiln, flow monitors, and a data
acquisition system capable of recording measurements from Kilns 1#-#5. [R307-401-8]
II.B.6.e If the CEMS are not in operation when the owner/operator commences operation under the AOS,
compliance with the HCl emission limit shall be demonstrated as follows for the first 180 days of
operation under the AOS:
A. Emissions shall be estimated by multiplying the lime throughput (tons/month)
for each kiln by HCl emission factors.
B. The following emission factors shall be used:
i. 1.67E-1 lbs HCl/ton of lime for the dolomitic lime line.
ii. 1.26E-1 lbs HCl/ton of lime for the high calcium line.
[R307-401-8]
DAQE-IN103130047-23
Page 25
II.B.6.f When the HCl CEMS have been installed calibrated, and are operating, HCl emissions shall be
calculated as follows for each kiln:
A. Hourly HCl emissions (Eh) shall be calculated using CEMS data as follows:
Eh = K * C * Q
Where:
Eh = hourly HCl mass emission rate during unit operation, lb/hr
K = 9.46E-8 for HCl, lb/scf/ppm
C = HCl concentration averaged for each one-hour period, ppmvw, as measured by the CEMS
Q = volumetric flow rate averaged for each one-hour period, scfh (wet)
B. The daily HCl emissions (Ed) in pounds shall be calculated by summing the
hourly HCl emissions (Eh) during measured during the day. For purposes of this
subsection, a "day" is defined as a period of 24-hours commencing at midnight and
ending the following midnight.
C. Measured monthly HCl emissions shall be calculated by summing the daily
emissions for all operating days in each month.
[R307-401-8]
II.B.6.g The owner/operator shall follow the data replacement procedure below when the HCl CEMS
data are not valid or unavailable due to monitor downtime or because the monitor is out of
control, as determined by 40 CFR 60 Appendix F, Procedure 1 and/or 6:
Ema = Em * (1 +(1/DA - 1) x C
Where:
Ema = adjusted monthly HCl emissions, lbs
Em = total unadjusted HCl mass emission for the month, prior to data replacement procedure,
lb/hr
DA = data availability, fraction of operating time for which monitor data is available during the
reporting period (e.g. 95% data availability = 0.95) and,
C = Conservative Factor = 1.05 = 5% increase.
[R307-401-8]
II.B.6.h The owner/operator shall record the output of the system for measuring HCl emissions. The
monitoring system shall operate continuously in accordance with the DAQ Policy Document for
Continuous Emissions Monitoring Systems. The monitoring system shall comply with all
applicable sections of R307-170, UAC and 40 CFR 60 Subpart A and Appendix B, and either
Performance Specification PS-18 or Performance Specification PS-15 as applicable and
approved by the Director. [R307-401-8]
DAQE-IN103130047-23
Page 26
II.B.6.i The Director shall consider the continuous monitoring requirements to be met when the
following provisions are met:
1) Except for system breakdown, repairs, calibration checks, and zero and span
adjustments required under 40 CFR 60.13(d), the owner/operator of an affected source
shall continuously operate all required continuous monitoring devices and shall meet
minimum frequency of operation requirements as outlined in 40 CFR 60.13(e) and
R307-170, UAC. Flow measurement shall be in accordance with the requirements of 40
CFR 52; Appendix E, 40 CFR 60 Appendix B; or 40 CFR 75, Appendix A.
2) Initial performance specification test shall be performed within 60 days of
installation. The performance specification test shall be conducted in accordance with
the procedures contained in 40 CFR 60, Appendix B, Performance Specifications 15 or
18. The Director shall be notified prior to conducting the performance specification test.
3) At no time shall the owner/operators allow excess gaseous emissions to be emitted to
the atmosphere, except as provided by the provisions of R307-107(Breakdowns), UAC.
[R307-170]
II.B.6.j The owner/operator shall follow the following requirements for stack testing of organic and
metal HAPs:
A. Emission Units
Emission units subject to organic and metal HAPs testing requirements are Kiln #1, Kiln
#2, Kiln #3, Kiln #4, and Kiln #5.
B. Initial Compliance Testing
Initial compliance testing shall be performed as soon as possible and not later than 180
days after the owner/operator commences operation under the AOS.
C. Frequency
Test every three years.
D. Test Method Organic HAPs
40 CFR 60, Appendix A, Method 320 and Method 18, or other EPA-approved testing
method acceptable to the Director.
E. Test Method Chlorine
40 CFR 60, Appendix A, Method 26A, or other EPA-approved testing method
acceptable to the Director.
F. Test Method Metal HAPs
40 CFR 60, Appendix A, Method 29, or other EPA-approved testing method acceptable
to the Director.
G. Other
Unless otherwise specified in this Section, the stack requirements in II.B.1.b.2 and
II.B.1.b.3 apply.
[R307-401-8]
DAQE-IN103130047-23
Page 27
II.B.6.k Quarterly reports shall be submitted as outlined in R307-170. The reports shall also include:
1) Total HCl emissions for the cumulative quarters of the current 12-month block.
2) Total HAPs emissions for the cumulative quarters of the current 12-month block.
[R307-170, R307-401-8]
PERMIT HISTORY
This Approval Order shall supersede (if a modification) or will be based on the following documents:
Supersedes AO DAQE-AN103130044-21 dated May 4, 2021
Is Derived From Source Submitted NOI dated June 14, 2023
Incorporates Additional Information Received dated October 2, 2023
DAQE-IN103130047-23
Page 28
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by Environmental Protection Agency to classify
sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - Title 40 of the Code of Federal Regulations Part 98,
Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal Division of Air Quality use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - Title 40 of the Code of Federal Regulations 52.21 (b)(49)(i)
GWP Global Warming Potential - Title 40 of the Code of Federal Regulations Part 86.1818-
12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds
12/11/23, 10:38 AM State of Utah Mail - Legal Notice to be published December 13, 2023
https://mail.google.com/mail/u/0/?ik=b4fd0e1085&view=pt&search=all&permmsgid=msg-f:1785007893769648303&simpl=msg-f:1785007893769648303 1/1
Jeree Greenwood <jereeg@utah.gov>
Legal Notice to be published December 13, 2023
legals <legals@millardccp.com>Mon, Dec 11, 2023 at 10:36 AM
To: Jeree Greenwood <jereeg@utah.gov>
Received, thank you.
[Quoted text hidden]
[Quoted text hidden]
<DAQE-NN103130047-23.pdf>
DAQE-NN103130047-23
December 7, 2023
Millard County Chronicle Progress
Legal Advertising Dept
P.O. Box 249
Delta (Millard), UT 84624
RE: Legal Notice of Intent to Approve
This letter will confirm the authorization to publish the attached NOTICE in the Millard County
Chronicle Progress on December 13, 2023.
Please mail the invoice and affidavit of publication to the Utah State Department of Environmental
Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any
questions, contact Jeree Greenwood, who may be reached at (385) 306-6514.
Sincerely,
{{$s }}
Jeree Greenwood
Office Technician
Enclosure
cc: Six County Association of Governments
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820
Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF AIR QUALITY
Bryce C. Bird
Director
DAQE-NN103130047-23
Page 2
NOTICE
A Notice of Intent for the following project submitted in accordance with R307-401-1, Utah
Administrative Code (UAC), has been received for consideration by the Director:
Company Name: Graymont Western US Incorporated
Location: Graymont Western US Incorporated - Cricket Mountain Plant – 32 Miles
Southwest of Delta, Utah; Highway 257, PO Box 669, Delta (Millard), UT
Project Description: Graymont Western US Incorporated submitted a request for updating the
chemical stabilizer dust control application. Specifically, that the frequency of
application be reduced from a schedule of 3 times a year to 2 times a year. After
review, Division of Air Quality determined that the listing of dust control
requirements in the Approval Order is redundant. The requirement to maintain a
dust control plan is sufficient for the minimization of fugitive dust. With the
removal of the listed conditions in the Approval Order, Graymont is free to
modify the fugitive dust control plan to incorporate the change in application
frequency. No change in equipment, processes or associated emissions will
occur.
The completed engineering evaluation and air quality impact analysis showed the proposed project meets
the requirements of federal air quality regulations and the State air quality rules. The Director intends to
issue an Approval Order pending a 30-day public comment period. The project proposal, estimate of the
effect on local air quality and draft Approval Order are available for public inspection and comment at the
Utah Division of Air Quality, 195 North 1950 West, Salt Lake City, UT 84116. Written comments
received by the Division at this same address on or before January 12, 2024 will be considered in making
the final decision on the approval/disapproval of the proposed project. Email comments will also be
accepted at jjenks@utah.gov. If anyone so requests to the Director in writing within 15 days of
publication of this notice, a hearing will be held in accordance with R307-401-7, UAC.
Under Section 19-1-301.5, a person who wishes to challenge a Permit Order may only raise an issue or
argument during an adjudicatory proceeding that was raised during the public comment period and was
supported with sufficient information or documentation to enable the Director to fully consider the
substance and significance of the issue.
Date of Notice: December 13, 2023
{{#s=Sig_es_:signer1:signature}}
Engineer Review N103130047: Graymont Western US Incorporated- Cricket Mountain Plant
October 24, 2023
Page 2
UTAH DIVISION OF AIR QUALITY
ENGINEER REVIEW
SOURCE INFORMATION
Project Number N103130047
Owner Name Graymont Western US Incorporated
Mailing Address 585 West Southridge Way
Sandy, UT, 84070
Source Name Graymont Western US Incorporated- Cricket Mountain Plant
Source Location 32 Miles Southwest of Delta, Utah; Highway 257
PO Box 669
Delta (Millard), UT 84624
UTM Projection 343,100 m Easting, 4,311,010 m Northing
UTM Datum NAD27
UTM Zone UTM Zone 12
SIC Code 1422 (Limestone, Crushed & Broken)
Source Contact Nate Stettler
Phone Number (801) 598-8076
Email nstettler@graymont.com
Billing Contact Hal Lee
Phone Number 801-716-2652
Email hlee@graymont.com
Project Engineer John Jenks, Engineer
Phone Number (385) 306-6510
Email jjenks@utah.gov
Notice of Intent (NOI) Submitted No date entered
Date of Accepted Application No date entered
Engineer Review N103130047: Graymont Western US Incorporated- Cricket Mountain Plant
October 24, 2023
Page 3
SOURCE DESCRIPTION
General Description
Graymont Western US Inc. (Graymont) operates the Cricket Mountain Lime Plant in Millard
County. The Cricket Mountain Lime Plant consists of quarries and a lime processing plant, which
includes five rotary lime kilns (Kilns 1 through 5). The rotary kilns are used to convert crushed
limestone ore into quicklime. The products produced for resale are lime, limestone, and kiln dust.
The kilns operate on pet coke and coal. Sources of emissions at this source include mining,
limestone processing, rotary lime kilns, post-kiln lime handling, and truck & loadout facilities.
NSR Classification:
Minor Modification at Major Source
Source Classification
Located in Attainment Area,
Millard County
Airs Source Size: A
Applicable Federal Standards
NSPS (Part 60), A: General Provisions
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and Processing Plants
NSPS (Part 60), HH: Standards of Performance for Lime Manufacturing Plants
NSPS (Part 60), OOO: Standards of Performance for Nonmetallic Mineral Processing Plants
NSPS (Part 60), IIII: Standards of Performance for Stationary Compression Ignition Internal
Combustion Engines
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous Air Pollutants for
Stationary Reciprocating Internal Combustion Engines
MACT (Part 63), AAAAA: National Emission Standards for Hazardous Air Pollutants for
Lime Manufacturing Plants
Title V (Part 70) Major Source
Project Proposal
Enhanced AO Change to AO DAQE-AN103130044-21 to Correct Fugitive Dust Conditions
Project Description
Graymont submitted a request for updating the chemical stabilizer dust control application.
Specifically, that the frequency of application be reduced from a schedule of 3 times a year to 2
times a year. After review, UDAQ determined that the listing of dust control requirements in the
AO is redundant. The requirement to maintain a dust control plan is sufficient for the
minimization of fugitive dust. With the removal of the listed conditions in the AO, Graymont is
free to modify the fugitive dust control plan to incorporate the change in application frequency.
No change in equipment, processes or associated emissions will occur.
EMISSION IMPACT ANALYSIS
There is no change in emissions associated with this project. No modeling is required. [Last updated October
24, 2023]
Engineer Review N103130047: Graymont Western US Incorporated- Cricket Mountain Plant
October 24, 2023
Page 4
SUMMARY OF EMISSIONS
The emissions listed below are an estimate of the total potential emissions from the source. Some
rounding of emissions is possible.
Criteria Pollutant Change (TPY) Total (TPY)
CO2 Equivalent 0 887964.00
Carbon Monoxide 0 7821.19
Nitrogen Oxides 0 3883.85
Particulate Matter - PM10 0 611.87
Particulate Matter - PM2.5 0 610.78
Sulfur Oxides 0 760.29
Volatile Organic Compounds 0 117.84
Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr)
Acetaldehyde (CAS #75070) 0 1963
Acrolein (CAS #107028) 0 1
Arsenic (TSP) (CAS #7440382) 0 88
Benzene (Including Benzene From Gasoline) (CAS #71432) 0 7734
Cadmium (CAS #7440439) 0 58
Chlorine (CAS #7782505) 0 1078
Chromium Compounds (CAS #CMJ500) 0 1214
Cobalt (TSP) (CAS #7440484) 0 1154
Ethyl Benzene (CAS #100414) 0 488
Formaldehyde (CAS #50000) 0 1612
Hexane (CAS #110543) 0 2566
Hydrochloric Acid (Hydrogen Chloride) (CAS #7647010) 0 44400
Hydrogen Fluoride (Hydrofluoric Acid) (CAS #7664393) 0 156
Lead (CAS #7439921) 0 1204
Manganese (TSP) (CAS #7439965) 0 546
Mercury (TSP) (CAS #7439976) 0 64
Nickel (CAS #7440020) 0 422
Selenium & Compounds (CAS #253) 0 402
Toluene (CAS #108883) 0 2678
Xylenes (Isomers And Mixture) (CAS #1330207) 0 2562
Change (TPY) Total (TPY)
Total HAPs 0 35.19
Note: Change in emissions indicates the difference between previous AO and proposed modification.
Engineer Review N103130047: Graymont Western US Incorporated- Cricket Mountain Plant
October 24, 2023
Page 5
Review of BACT for New/Modified Emission Units
1. BACT review regarding No BACT review required for this project
This project represents a clean-up of fugitive dust conditions to remove redundancy. There is no
change in equipment, method of operation, or emissions associated with this project. No BACT
review is required. [Last updated October 24, 2023]
SECTION I: GENERAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):
I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in
the UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions
refer to those rules. [R307-101]
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
I.3 Modifications to the equipment or processes approved by this AO that could affect the
emissions covered by this AO must be reviewed and approved. [R307-401-1]
I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request.
Unless otherwise specified in this AO or in other applicable state and federal rules, records
shall be kept for a minimum of five (5) years. [R307-401-8]
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators
shall, to the extent practicable, maintain and operate any equipment approved under this AO
including associated air pollution control equipment in a manner consistent with good air
pollution control practice for minimizing emissions. Determination of whether acceptable
operating and maintenance procedures are being used will be based on information available
to the Director which may include, but is not limited to, monitoring results, opacity
observations, review of operating and maintenance procedures, and inspection of the source.
All maintenance performed on equipment authorized by this AO shall be recorded. [R307-
401-4]
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-
150]
Engineer Review N103130047: Graymont Western US Incorporated- Cricket Mountain Plant
October 24, 2023
Page 6
SECTION II: PERMITTED EQUIPMENT
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):
II.A THE APPROVED EQUIPMENT
II.A.1 Lime Manufacturing Plant
[All equipment designation numbers are those used by Graymont Western U.S. Inc.]
II.A.2 K-1 Kiln
Rotary Lime Kiln #1 rated at 600 tons of lime per 24-hour period with a preheater and
baghouse emissions control system (D-85) rated at an exhaust gas flow rate 54,000 scfm and
an Air to Cloth (A/C) ratio of 3.26:1.
NESHAP Applicability: 40 CFR 63 Subpart AAAAA
II.A.3 K-2 Kiln
Rotary Lime Kiln #2 rated at 600 tons of lime per 24-hour period with a preheater, cyclone
and baghouse emissions control system (D-275) rated at an exhaust gas flow rate of 48,000
scfm and an A/C ratio of 2.9:1.
NESHAP Applicability: 40 CFR 63 Subpart AAAAA
II.A.4 K-3 Kiln
Rotary Lime Kiln #3 rated at 840 tons of lime per 24-hour period with a preheater, cyclone
and baghouse emissions control system (D-375) rated at an exhaust gas flow rate of 55,000
scfm and a A/C ratio of 2.49:1.
NESHAP Applicability: 40 CFR 63 Subpart AAAAA
II.A.5 K-4 Kiln
Rotary Lime Kiln #4 rated at 1266 tons of lime per 24-hour period with a preheater, cyclone
and baghouse emissions control system (D-485) rated at an exhaust gas flow rate of 100,000
scfm and an A/C ratio of 5:1.
NESHAP Applicability: 40 CFR 63 Subpart AAAAA
II.A.6 K-5 Kiln
Rotary Lime Kiln #5 rated at 1400 tons of lime per 24-hour period with a preheater and
baghouse emissions control system (D-585) rated at an exhaust gas flow rate of 103,000 scfm
and an A/C ratio of 3.5:1.
NESHAP Applicability: 40 CFR 63 Subpart AAAAA
II.A.7 KDE-1 Kiln Drive Engine
Rating: 52 hp
Fuel: Diesel
NSPS Applicability: 40 CFR 60 Subpart IIII
MACT Applicability: 40 CFR 63 Subpart ZZZZ
Engineer Review N103130047: Graymont Western US Incorporated- Cricket Mountain Plant
October 24, 2023
Page 7
II.A.8 KDE-2 Kiln Drive Engine
Rating: 45 hp
Fuel: Diesel
NSPS Applicability: 40 CFR 60 Subpart IIII
MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.9 KDE-3 Kiln Drive Engine
Rating: 55 hp
Fuel: Gasoline
MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.10 KDE-4 Kiln Drive Engine
Rating: 65 hp
Fuel: Diesel
Manufacture Date: Pre 12/19/2002
MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.11 KDE-5 Kiln Drive Engine
Rating: 173.5 hp
Fuel: Diesel
NSPS Applicability: 40 CFR 60 Subpart IIII
MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.12 D-91 Coal Silo Baghouse
For Kiln #1
Exhaust gas flow rate: 1,000 scfm
II.A.13 D-94 Coal Silo Baghouse
For Kiln #2
Exhaust gas flow rate: 1,000 scfm
II.A.14 D-391 Coal Silo Baghouse
For Kiln #3
Exhaust gas flow rate: 1,000 scfm
II.A.15 D-491 Coal Silo Baghouse
For Kiln #4
Exhaust gas flow rate: 1,500 scfm
II.A.16 D-591 Coal Silo Baghouse
For Kiln #5
Exhaust gas flow rate: 1,000 acfm
II.A.17 D-331 Product Baghouse
For Kiln #1, #2 loadout area and screenhouse dust collector
Exhaust gas flow rate: 32,000 scfm
Engineer Review N103130047: Graymont Western US Incorporated- Cricket Mountain Plant
October 24, 2023
Page 8
II.A.18 D-330 Product Baghouse
For Kiln #3 cooler pit dust collector
Exhaust gas flow rate: 11,000 scfm
II.A.19 D-447 Product Baghouse
For Kiln #4 cooler and screenhouse dust collector
Exhaust gas flow rate: 18,300 scfm
II.A.20 D-463 Product Baghouse
For Kiln #4 product loadout and C-463 dust collector
Exhaust gas flow rate: 8,300 scfm
II.A.21 D-341 Product Baghouse
For Silo T-341
Exhaust gas flow rate: 2,000 scfm
II.A.22 D-530 Product Baghouse
Product handling baghouse #1 for Kiln #5 screen house
Exhaust gas flow rate: 9,000 acfm
II.A.23 D-564 Product Baghouse
Product handling baghouse #2 for Kiln #5 screen house
Exhaust gas flow rate: 9,000 acfm
II.A.24 D-547 Product Baghouse
Product handling baghouse #3 for Kiln #5 screen house
Exhaust gas flow rate: 9,000 acfm
II.A.25 D-83 Lime Kiln Dust Silo Baghouse
For Kilns #1 and #2
Exhaust gas flow rate: 6,000 scfm
II.A.26 D-489 Lime Kiln Dust Silo Baghouse
For Kilns #4 lime kiln dust silo
Exhaust gas flow rate: 6,000 scfm
II.A.27 D-486 Lime Kiln Dust Silo Baghouse
For Kiln #4
Exhaust gas flow rate: 4,000 scfm
II.A.28 D-466 Lime Kiln Dust Silo Baghouse
For lime kiln dust silo
Exhaust gas flow rate: 4,000 scfm
II.A.29 D-586 Lime Kiln Dust Silo Baghouse
For Kiln #5 dust silo
Exhaust gas flow rate: 2,500 scfm
Engineer Review N103130047: Graymont Western US Incorporated- Cricket Mountain Plant
October 24, 2023
Page 9
II.A.30 D-589 Lime Kiln Dust Silo Baghouse
For loadout of Kiln #5 dust silo
Exhaust gas flow rate: 1,500 scfm
II.A.31 T-381 Lime Kiln Dust Silo
Maximum Capacity: 300 tons
II.A.32 D-381 Lime Kiln Dust Silo Baghouse
For 300-ton lime kiln dust silo (T-381)
Exhaust gas flow rate: 3,000 scfm
II.A.33 T-381 Loadout Spout
For 300-ton lime kiln dust silo (T-381)
II.A.34 D-382 Loadout Spout (T-381) Baghouse
For Loadout Spout (T-381)
Exhaust gas flow rate: 2,000 scfm
II.A.35 D-333 Product Loadout Baghouse
For rail loadout
Exhaust gas flow rate: 10,000 scfm
II.A.36 D-10 Limestone Ore Preparation Baghouse
For stone reclaim screen for Kiln #1 & #2
Exhaust gas flow rate: 8,000 scfm
II.A.37 D-310 Limestone Ore Processing Baghouse
For stone dressing screen for Kiln #3
Exhaust gas flow rate: 8,000 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.38 D-414 Limestone Ore Processing Baghouse
For stone dressing screen for Kiln #4
Exhaust gas flow rate: 3,100 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.39 D-514 Limestone Ore Processing Baghouse
For stone dressing screen for Kiln #5
Exhaust gas flow rate: 4,500 acfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.40 D-1 Limestone Ore Processing Baghouse
For quarry crusher & screen
Exhaust gas flow rate: 28,000 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
Engineer Review N103130047: Graymont Western US Incorporated- Cricket Mountain Plant
October 24, 2023
Page 10
II.A.41 D-503 Conveying System
For dust collection for Kiln #5 limestone conveyor transfer points
Exhaust flow rate: 2,000 acfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.42 D-403 Conveying System
For stone dump from conveyor 408 & 409 to reclaim pile
Exhaust gas flow rate: 2,200 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.43 D-415 Conveying System with Baghouse
For limestone dump to Kiln #4 preheater
Exhaust gas flow rate: 600 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.44 D-479 Dolomitic Lime Handling System Baghouse
Product transfer baghouse to S-471, T-471, T-472, T-473, and T-474. The 435 material
handling system consists of 2 elevators, a vibratory conveyor, a number of belt conveyors, and
a mixing screw conveyor
Exhaust gas flow rate: 4,300 scfm
II.A.45 R-486 Dolomite Crusher
Rating: 40 tons/hr
II.A.46 N-470 Dolomitic Lime Handling System
Recycle Bin
II.A.47 Processed Stone Handling (PSH) Operations
Operations to transport material from storage piles (fines, small stone, medium stone, large
stone [sugar]) to kiln preheaters. Includes bins, bin transfer points, preheater transfer points,
and conveyors.
NESHAP Applicability: 40 CFR 63 Subpart AAAAA
II.A.48 Sugar Stone System
System to store, screen and load sugar stones. Includes a hopper (HP-1), screen (S-2), loadout
system (203255SSS001), conveyors (C-MISC2), and generator (GEN-1).
II.A.49 HP-1 Hopper Sugar Stone System
II.A.50 S-2 Screen Sugar Stone System
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.51 Loadout Sugar Stone System
Rail Loadout
Engineer Review N103130047: Graymont Western US Incorporated- Cricket Mountain Plant
October 24, 2023
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II.A.52 C-MISC2 Sugars Stone System
Miscellaneous Conveyors
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.53 GEN-1 Generator Sugar Stone System
Rating: 130.1 hp
Fuel: Diesel
MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.54 Portable Crusher System (PCS)
Includes hopper, crushers (PCS-1), hopper (HP-2), generator (PCS-4), and conveyors.
II.A.55 PCS Hopper
Feed Hopper
II.A.56 PCS-1 Crusher System
ICR101: Primary Crusher
Capacity: 690 tons/hr
ICR102: Secondary Crusher
Capacity: 690 tons/hr
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.57 PCS-2 Screen/Conveyor Transfer Points
Screen and material transfer points to and from conveyor belts.
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.58 PCS-3 Conveyor Drop Points
Material drop points to the fines and product stockpiles
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.59 PCS-4 Generator Portable Crusher System
Quantity: 3
Rating: 740 hp combined
Fuel: Diesel
II.A.60 PCS Conveyors
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.61 D-7122 Limestone Grinding Plant Baghouse
For grinding mill, direct-fire heater, material separator
Exhaust gas flow rate: 10,000 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
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October 24, 2023
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II.A.62 D-7133 Limestone Grinding Plant Baghouse
For screen, three bucket elevators, three storage silos
Exhaust gas flow rate: 4,500 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.63 D-7141 Limestone Grinding Plant Baghouse
For truck load-out and rail load-out
Exhaust gas flow rate: 3,500 scfm
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.64 C-MISC1 Limestone Grinding Plant
Miscellaneous Conveyors
II.A.65 D-488 Briquetter and Crusher Baghouse
For crusher (R-486), briquetters (BRI-474 and BRI-014), and silo (T-470)
Exhaust gas flow rate: 1,700 scfm
II.A.66 BRI-474 Briquetter
II.A.67 BRI-014 Briquetter
II.A.68 C-045 Conveying System
Fines Truck Loadout Conveyor - 250 tons/hr
II.A.69 C-305 Conveying System
Medium and Small Stone Pile Conveyor - 600 tons/hr
II.A.70 S-466 Screen
Dolomitic Screen
II.A.71 C-Coal Handling
Miscellaneous Conveyors
II.A.72 Feeder-Coal Handling
Four Vibratory Feeders
II.A.73 PW Portable Pressure Washer
Rating: 18 hp
Fuel: Gasoline
II.A.74 HR-1 Haul Road
Quarry to plant and plant to highway.
Length: 6 miles
II.A.75 HR-2 Haul Road
Inside quarry
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October 24, 2023
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II.A.76 Limestone Fines Product (LFP) Loadout System
Includes a screen hopper, screen, screen conveyors, tent storage area, product loadout hopper,
product loadout conveyor, and engines (CAT4.4 and V3600-T).
II.A.77 LFP - Engines
CAT 4.4 Generator
Rating: 130 hp
Kubota V3600-T Generator
Rating: 52 hp
Fuel: Diesel
NSPS Applicability: 40 CFR 60 Subpart IIII
MACT Applicability: 40 CFR 63 Subpart ZZZZ
II.A.78 LFP-1 Hopper
Capacity: 250 ton/hour
II.A.79 LFP-2 Screen
Capacity: 250 ton/hour
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.80 LFP-3 Conveyors
Capacity: 250 ton/hour
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.81 LFP-4 Storage
Tent storage area
II.A.82 LFP-5 Hopper
Product loadout hopper
Capacity: 100 ton/hour
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.83 LFP-6 Conveyor
Product Loadout Conveyor
Capacity: 100 ton/hour
NSPS Applicability: 40 CFR 60 Subpart OOO
II.A.84 Stationary Pressure Washer
Rating: 0.4 MMBtu/hr
Fuel: Propane
Listed for information purposes only
II.A.85 Fuel Storage Tanks
Four 10,150-gallon diesel storage tanks
One 12,000-gallon diesel storage tank
One 2,000-gallon gasoline storage tank
One 500-gallon gasoline storage tank
Engineer Review N103130047: Graymont Western US Incorporated- Cricket Mountain Plant
October 24, 2023
Page 14
SECTION II: SPECIAL PROVISIONS
The intent is to issue an air quality AO authorizing the project with the following recommended
conditions and that failure to comply with any of the conditions may constitute a violation of the
AO. (New or Modified conditions are indicated as “New” in the Outline Label):
II.B REQUIREMENTS AND LIMITATIONS
II.B.1 Sitewide Requirements
II.B.1.a The following limits shall not be exceeded:
A. For Kilns #1, #2, #3, #4 and #5 collectively:
1) 1,516,250 tons lime per rolling 12-month period
2) 4,706 tons lime per day
B. Sugar Stone System
1) 135,000 tons of sugar stone per rolling 12-month period
2) 750 hours of operation for the 130.1 hp generator per rolling 12-month period
C. Portable Crushing System
1) 750,000 tons of limestone per rolling 12-month period
2) 4,000 hours of operation per rolling 12-month period
D. Truck hauling of stone from the quarry to the plant
1) No more than 108 rounds trips per day (midnight to midnight) 24-hour period.
E. Limestone Fines Product Loadout Process
1) 200,000 tons of limestone per rolling 12-month period
2) 6,500 hours of operation per rolling 12-month period
[R307-401]
II.B.1.a.1 Compliance with the above 12-month production limitations shall be determined on a rolling
12-month total. Calculations for the 12-month production shall be completed within 25
calendar days from the end of the previous month. Records of production shall be kept for all
periods when the plant is in operation. Production shall be determined by plant production
records, such as scale records or sales receipts. Hours of operation and number of truck trips
shall be determined by records of operation. The records shall be kept on a daily basis. [R307-
401-8]
II.B.1.b Emissions to the atmosphere from the indicated emission point shall not exceed the following
Engineer Review N103130047: Graymont Western US Incorporated- Cricket Mountain Plant
October 24, 2023
Page 15
rates and concentrations (standardized at 68 oF, 29.92 in Hg) (lbs/tsf = pounds per ton of stone
fed):
Emission Point: Kiln #1 Baghouse Stack
Pollutant lb/hr grain/dscf lbs/tsf
TSP 0.020 0.12
PM10 (Filterable + Condensable) 6.0 0.016
SO2 22.4
NOx 90.0
Emission Point: Kiln #2 Baghouse Stack
Pollutant lb/hr grain/dscf lbs/tsf
TSP 8.23 0.020 0.12
PM10 (Filterable + Condensable) 6.58 0.016
SO2 22.4
NOx 120.0
Emission Point: Kiln #3 Baghouse Stack
Pollutant lb/hr grain/dscf lbs/tsf
TSP 7.49 0.020 0.10
PM10 (Filterable + Condensable) 7.54 0.016
SO2 27.2
NOx 160.0
Emission Point: Kiln #4 Baghouse Stack
Pollutant lb/hr grain/dscf lbs/tsf
TSP 17.14 0.020 0.12
PM10 (Filterable + Condensable) 13.7 0.016
SO2 38.4
NOx 200.0
Emission Point: Kiln #5 Baghouse Stack
Pollutant lb/hr grain/dscf Other
TSP 0.020 0.10 lbs/tsf
PM10 (Filterable + Condensable) 11.7 0.016
SO2 59.0 1.01 lb/ton lime
NOx 210.0 3.60 lb/ton lime
CO 233.0 4.00 lb/ton lime
Emission Point: Briquetter and Crusher Baghouse (D-488) Stack
Pollutant lb/hr grain/dscf
Engineer Review N103130047: Graymont Western US Incorporated- Cricket Mountain Plant
October 24, 2023
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TSP 0.29 0.020
PM10 (Filterable) 0.15 0.010
PM2.5 (Filterable) 0.15 0.010
After the installation of an SO2 CEMS, compliance with the SO2 emission limit will be based
on a 3-hour block average.
Testing for compliance with the lb/ton lime limits must comply with all stack testing
requirements.
[R307-401]
II.B.1.b.1 Stack testing to show compliance with the emission limitations stated in the above condition
shall be performed as specified below:
Emission Point Pollutant Status Test Frequency
Kiln #1 Baghouse Stack TSP *** +
PM10 *** +
SO2 *** +
NOx *** +
Emission Point Pollutant Status Test Frequency
Kiln #2 Baghouse Stack TSP *** +
PM10 *** +
SO2 * +
NOx * +
Emission Point Pollutant Status Test Frequency
Kiln #3 Baghouse Stack TSP *** +
PM10 *** +
SO2 * +
NOx *** +
Emission Point Pollutant Status Test Frequency
Kiln #4 Baghouse Stack TSP *** +
PM10 *** +
SO2 *** +
NOx *** +
Emission Point Pollutant Status Test Frequency
Kiln #5 Baghouse Stack TSP *** +
PM10 *** +
SO2 *** +
NOx *** +
CO *** +
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Emission Point Pollutant Status Test Frequency
(D-488) Baghouse Stack TSP *** +
PM10 *** +
PM2.5 (Filterable)*** +
* No Initial Testing was required. The source shall be tested if directed by the Director at any
time.
** Initial compliance testing is required. The initial test date shall be performed as soon as
possible and in no case later than 180 days after the startup of a new emission source, an
existing source without an AO, or the granting of an AO to an existing emission source that
has not had an initial compliance test performed. If an existing source is modified, a
compliance test is required on the modified emission point that has an emission rate limit.
*** Initial compliance testing was required and completed.
+ Test every three years. The Director may require testing at any time.
[R307-401]
II.B.1.b.2 A. Notification
The Director shall be notified at least 60 days prior to conducting any required emission
testing for sources subject to 40 CFR 63 Subpart AAAAA. All other sources shall notify the
Director at least 30 days prior to conducting any required emission testing. A source test
protocol shall be submitted to DAQ when the testing notification is submitted to the Director.
The source test protocol shall be approved by the Director prior to performing the test(s). The
source test protocol shall outline the proposed test methodologies, stack to be tested, and
procedures to be used. A pretest conference shall be held, if directed by the Director.
B. Sample Location
The emission point shall be designed to conform to the requirements of 40 CFR 60, Appendix
A, Method 1, or other methods as approved by the Director. An Occupational Safety and
Health Administration (OSHA) or Mine Safety and Health Administration (MSHA) approved
access shall be provided to the test location.
C. Volumetric Flow Rate
40 CFR 60, Appendix A, Method 2 or other EPA-approved testing method acceptable to the
Director.
D. Total Suspended Particulate (TSP)
40 CFR 60, Appendix A, Method 5 or other EPA-approved testing method acceptable to the
Director.
E. PM10 (Filterable + Condensable)
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For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR
51, Appendix M, Methods 201, 201a, or other EPA approved method as acceptable to the
Director. The back half condensables shall also be tested using the EPA approved method
acceptable by the Director. All particulate captured shall be considered PM10.
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, or other EPA
approved method as acceptable to the Director. The back half condensables shall also be
tested using the EPA 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 edition of the
EPA document, AP-42, or other data acceptable to the Director.
F. PM2.5 (Filterable)
40 CFR 60, Appendix A, Method 5; 40 CFR 51, Appendix M, Method 201A or other EPA-
approved testing method as acceptable to the Director. If other approved testing methods are
used which cannot measure the PM2.5 fraction of the filterable particulate emissions, all of the
filterable particulate emissions shall be considered PM2.5. The portion of the front half of the
catch considered PM2.5 shall be based on information in Appendix B of the fifth edition of the
EPA document, AP-42, or other data acceptable to the Director.
G. Sulfur Dioxide (SO2)
40 CFR 60, Appendix A, Method 6, 6A, 6B, 6C, or other EPA-approved testing method
acceptable to the Director.
H. Nitrogen Oxides (NOx)
40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, 7E, or other EPA approved method as
acceptable to the Director.
I. Carbon Monoxide (CO)
40 CFR 60, Appendix A, Method 10, or other EPA approved method as acceptable to the
Director.
[R307-401]
II.B.1.b.3 J. 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.
To determine emission rates in units of lbs/ton lime, the emission rate in lbs/hour shall be
divided by the tons/hour lime production rate. Lime production rate shall either be a direct
measurement or shall be calculated using the following conversion factor: 2 tons of limestone
feed equates to 1 ton of lime produced (2 tons limestone: 1 ton lime).
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K. New Source Operation
For a new source/emission point, the production rate during all compliance testing shall be no
less than 90% of the production rate listed in this AO. If the maximum AO allowable
production rate has not been achieved at the time of the test, the following procedure shall be
followed:
1) Testing shall be at no less than 90% of the production rate achieved to date.
2) If the test is passed, the new maximum allowable production rate shall be 110% of the
tested achieved rate, but not more than the maximum allowable production rate. This
new allowable maximum production rate shall remain in effect until successfully
tested at a higher rate.
3) The owner/operator shall request a higher production rate when necessary. Testing at
no less than 90% of the higher rate shall be conducted. A new maximum production rate
(110% of the new rate) will then be allowed if the test is successful. This process may
be repeated until the maximum AO production rate is achieved.
L. Existing Source Operation
For the existing kilns, the production rate during all compliance testing shall be no less than
90% of the maximum production achieved in the previous three (3) years.
M. Reporting
The results of stack testing shall be submitted to the Director within 60 days of completion of
the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. [R307-165, R307-401]
II.B.1.c Visible emissions from the following emission points shall not exceed the following opacity
values:
A. Kilns #1, #2, #3, #4, and #5 15%
B. All ancillary silo and storage bin baghouses 10%
C. Product baghouses 10 %
D. Subpart OOO baghouses 7%
E. All non-OOO crushers 15%
F. All non-OOO screens 10%
G. All non-OOO conveyor transfer points 10%
H. Subpart OOO crushers*
i. Post-April 22, 2008 12%
ii. Pre-April 22, 2008 15%
I. Subpart OOO screens*
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i. Post-April 22, 2008 7%
ii. Pre-April 22, 2008 10%
J. Subpart OOO conveyor transfer points*
i. Post-April 22, 2008 7%
ii. Pre-April 22, 2008 10%
K. All diesel engines 20%
L. Conveyor drop points 20%
M. PSH operations stack emissions 7%
N. PSH operations fugitive emissions 10%
O. All other points sources 20%
*Opacity limits from 40 CFR 60 Subpart OOO shown as "Post-April 22, 2008" applies to
emission units constructed, modified, or reconstructed on or after April 22, 2008 and "Pre-
April 22, 2008" applies to emission units constructed, modified, or reconstructed on or after
August 31, 1983 but before April 22, 2008.
Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9.
For sources that are subject to NSPS, opacity shall be determined by conducting observations
in accordance with 40 CFR 60.11(b) and 40 CFR 60, Appendix A, Method 9.
Visible emissions from haul road traffic shall be minimized in accordance with the fugitive
dust control plan.
[R307-401]
II.B.1.c.1 The owner/operator shall make at least one visual opacity survey each quarter for each kiln
drive engine. The visual opacity survey shall be performed while the unit is operating by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visual emissions observer (VEO). If visible
emissions 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. The
owner/operator shall maintain a log of the visual opacity surveys, opacity determinations, and
all data required by 40 CFR 60, Appendix A, Method 9. [R307-401]
II.B.2 Fuel Requirements
II.B.2.a The owner/operator shall use coal as the primary fuel, except a combination of coal and
petroleum coke (pet coke) may be used in Kilns #1 and #5, and propane and fuel oil as a
startup fuel in all kilns. Prior to burning petroleum coke in Kilns #1 and #5 or coal with a
sulfur content in excess of 1.0 lb/MMBTU in Kilns #1, #2, #3, #4, or #5, an SO2 CEM must
be installed, calibrated, and operating on that kiln. [R307-401]
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II.B.2.b The owner/operator shall use propane, diesel, and used oil in any combination in the direct fire
heating system for the limestone grinding plant. [R307-401]
II.B.2.c The sulfur content of any coal or any mixture of coals burned shall not exceed 1.0 pounds of
sulfur per MMBTU heat input. Sulfur content shall be determined by the owner/operator or
the coal supplier using ASTM Method D3174-12(2018), D3176-15, D4239-18e1, D5016-16
or an approved equivalent ASTM Method. If the owner/operator chooses supplier
certification, the sulfur content shall be tested quarterly from a composite sample. If the
owner/operator chooses to test the sulfur content of the coal, the composite sample shall be
tested quarterly from a composite grab sample taken every 24 hours of operation. Records, or
supplier furnished certifications, of this testing shall be kept on-site for a period of five (5)
years and be provided to the Director upon request.
After a SO2 CEMS has been installed, calibrated, and is operating on a kiln, the coal that is
burned in that kiln is exempt from the 1.0 pounds of sulfur per MMBTU heat input limitation
of UAC R307-203-1(1).
[R307-203-1]
II.B.2.d Except for diesel, the sulfur content of any fuel oil burned as a startup fuel in all kilns shall not
exceed 0.85 pounds of sulfur per MMBTU heat input. Sulfur content shall be decided by
ASTM Method D-3175-75, or an approved equivalent. The sulfur content shall be tested if
directed by the Director. [R307-401]
II.B.2.e The air heating combustor burning used oil for energy recovery shall comply with the
following:
A. The concentration/parameters of contaminants in any used oil burned as fuel shall
not exceed the following levels:
1) Arsenic 5 ppm by weight
2) Cadmium 2 ppm by weight
3) Chromium 10 ppm by weight
4) Lead 100 ppm by weight
5) Total halogens 1,000 ppm by weight
6) Sulfur 0.50 percent by weight
B. The flash point of all used oil to be burned as fuel shall not be less than 100 degrees F
C. Used oil that does not exceed any of the listed contaminants content may be burned.
The owner/operator shall record the quantities of oil burned.
D. Sources utilizing used oil as a fuel shall comply with the State Division of Waste
Management and Radiation Control in accordance with R315-15, UAC.
[R307-401]
II.B.2.f The owner/operator shall only use diesel fuel (e.g. fuel oil #1, #2, or diesel fuel oil additives)
as fuel in the KDE-1, KDE-2, KDE-4, and KDE-5 drive engines; GEN-1 engine; portable
generators; and LFP engines. [R307-401-8]
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II.B.2.g The owner/operator shall only combust diesel fuel that meets the definition of ultra-low sulfur
diesel (ULSD), which has a sulfur content of 15 ppm or less. [R307-401-8]
II.B.2.g.1 To demonstrate compliance with the ULSD fuel requirement, the owner/operator shall
maintain records of diesel fuel purchase invoices or obtain certification of sulfur content from
the diesel fuel supplier. The diesel fuel purchase invoices shall indicate that the diesel fuel
meets the ULSD requirements. [R307-401-8]
II.B.3 SO2 and Opacity CEMS Requirements
II.B.3.a The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system for the continuous measurement of opacity on kiln stacks #1, #2,
#3, #4 and #5. The owner/operator shall record the output of the system for measuring the
opacity of emissions. The monitoring system shall operate continuously in accordance with
the DAQ Policy Document for Continuous Emission Monitoring Systems. The monitoring
system shall comply with all applicable sections of R307-170, UAC and 40 CFR 60,
Appendix B, Specification 1 - Opacity.
[R307-170]
II.B.3.b
NEW
The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system (consisting of a SO2 pollutant concentration monitor and a flow
monitoring device) for the continuous measurement of SO2 emissions on a kiln if that kiln
burns pet coke or coal with a sulfur content in excess of 1.0 lb Sulfur/MMBtu.
The owner/operator shall record the output of the system for measuring SO2 emissions. The
monitoring system shall comply with all applicable sections of R307-170, UAC and 40 CFR
50 Appendix B, Performance Specifications 2 - SO2 and NOx Continuous Emission
Monitoring Systems
[R307-170]
II.B.3.c When a SO2 CEMS has been installed calibrated, and is operating, the emission rate of SO2 in
pounds per hour measured by the SO2 CEMS for each 3-hour block averaging period will be
calculated by the following formula:
Eh = K * Chp * Qhs * [(100 - %H2O)/100]
Where: Eh = hourly SO2 mass emission rate during unit operation, lb/hr
K = 1.66 E-7 for SO2, lb/scf/ppm
Chp = hourly average SO2 concentration during unit operation, ppm (dry)
Qhs = hourly average volumetric flow rate during unit operation, scfh (wet)
%H2O = constant moisture value specific to each kiln, percent by volume.
[R307-401]
II.B.3.d All continuous opacity monitoring devices as required in federal regulations and state rules
shall be installed and operational prior to placing the affected source in operation. SO2 CEMS
shall be installed and operational on a kiln prior to that kiln burning coal with a sulfur content
in excess of 1.0 lb Sulfur/MMBtu or burning pet coke.
Except for system breakdown, repairs, calibration checks, and zero and span adjustments
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required under 40 CFR 60.13(d), the owner/operator of an affected source shall continuously
operate all required continuous monitoring devices and shall meet minimum frequency of
operation requirements as outlined in 40 CFR 60.13(e) and R307-170, UAC.
[40 CFR 60, R307-170]
II.B.3.e The Director shall consider the continuous monitoring requirements to be met when the
following provisions are met:
A. Opacity Monitors and SO2 CEMS
1) Shall operate in accordance with 40 CFR 60.13 and R307-170 UAC.
2) Prior to installation of a SO2 CEMS on a kiln, the average of three one-hour
stack test results are less than the corresponding SO2 emission limit for that kiln.
3) After installation of the SO2 CEMS on a kiln, the 3-hour block average is less
than the corresponding SO2 emission limit for that kiln.
4) Three-hour block averages will begin on 12:01 am and end every 3 hours,
thereafter.
B. Excess Emission Requirements
1) At no time shall the owner/operator allow excess gaseous emissions to be
emitted to the atmosphere, except as provided by the provisions of R307-107 (Breakdowns),
UAC.
C. Reporting
1) All sources required to install a continuous emission monitor shall submit a
quarterly report in an electronic format provided by the DAQ.
2) All exceedances are to be reported in the quarterly report with explanations
R307-170-8 Reason Categories, UAC) and corrective actions.
[40 CFR 60, R307-170]
II.B.4 Haul Roads and Fugitive Dust Requirements
II.B.4.a
NEW
The owner/operator shall implement a fugitive dust control plan acceptable to the Director for
control of all dust sources associated with the Cricket Mountain Plant. Adherence to the most
recently approved fugitive dust control plan shall be monitored to demonstrate that appropriate
measures are being implemented to control fugitive dust. At least once during each permit
term, the fugitive dust control plan shall be reviewed and evaluated. If the plan review
indicates changes to the dust control plan are necessary to reflect current site operations, an
updated fugitive dust control plan shall be submitted. The owner/operator shall operate in
accordance with the most current fugitive dust control plan approved by the Director. For each
plan review, a record of the date and results of the review shall be maintained. Records that
demonstrate compliance with the most recently approved fugitive dust control plan shall also
be maintained. [R307-401]
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II.B.5 Other Baghouse Requirements
II.B.5.a The pressure drop on the Briquetter and Crusher (D-488) Baghouses shall not be less than 4.0
inches of water column or more than 8.0 inches of water column. [R307-401-8]
II.B.5.a.1 The pressure drop shall be monitored and recorded weekly, while the unit is operating with
equipment located such that an inspector/operator can safely read the output at any time.
[R307-401-8]
II.B.5.a.2 All instruments shall be calibrated according to the manufacturer's instructions at least once
every 12 months. [R307-401-8]
II.B.6 Alternate Operating Scenario for Synthetic HAPs Minor Operations
II.B.6.a This Section contains the requirements for the AOS. If the owner/operator chooses to comply
with the AOS requirements in this Section, the source will be reclassified as an area source of
HAPs as defined in 40 CFR 63.2 effective on the date that AOS operations commence. Once
reclassified, the requirements of 40 CFR 63 Subpart AAAAA will no longer apply.
Once effective, the limits of the AOS shall apply permanently and a modification to the AO
will be required should the owner/operator need to remove or modify these limits. All other
requirements in this AO will continue to apply. The AOS limits will be applied in addition to
the requirements in II.B.1 through II.B.5. [R307-401-8]
II.B.6.b The owner/operator shall notify the Director at least 30 days prior to the effective date on
which operations will commence under the AOS requirements specified in this section of the
AO. The notification shall include:
1. Test results for HCl and total organic HAPs that demonstrate the source meets the
definition of area source given in 40 CFR 63.2. Methods for measuring HCl and total HAPs
shall be those specified in 40 CFR 63.7142, or other EPA-approved methods, as acceptable to
the Director. Documentation of the testing shall be maintained.
2. Date when operations will commence under the AOS and the AOS conditions limiting
HAPs emissions become effective.
3. Proposed schedule for CEMS installation. [R307-401-8]
II.B.6.c Under the AOS, the owner/operator shall limit facility-wide emissions to:
A) 9.5 tons of HCl per 12-month block period
B) 24 tons of total HAPs per 12-month block period
Total HAPs emissions must include the following compounds:
1) Organic HAPs: acetaldehyde benzene, chlorine, ethylbenzene, formaldehyde, hexane,
toluene, and xylenes.
2) Metal HAPs: arsenic, cadmium, chromium compounds, cobalt, lead, manganese,
mercury, nickel, and selenium.
3) HCl. [R307-401-8]
II.B.6.c.1 To determine compliance with the 12-month block total, the owner/operator shall calculate a
monthly total by the twenty-fifth day of each month using data from the previous month. The
monthly totals shall be added to determine HCl and total HAPs emissions for the current 12-
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Page 25
month block. The 12-month block period starts on the day that the owner/operator commences
operations under the AOS. A new 12-month block period will begin each year on the date
AOS operations commenced. [R307-401-8]
II.B.6.c.2 The owner/operator shall demonstrate compliance with the HCl emission limit using CEMS
data as outlined in Condition II.B.6.f, except as specified in II.B.6.e. The HCl CEMS shall
operate for all periods the kilns are in operation. Records, including CEMS data and
calculated emissions, shall be tabulated for each day. [R307-401-8]
II.B.6.c.3 The owner/operator shall demonstrate compliance with the total HAPs limit using the
following data:
A. HCl CEMS data, as per II.B.6.c.2
B. Emission rates in lbs/hr measured in the most recent stack test for organic HAPs and
metal HAPs. Stack testing requirements are specified in II.B.6.j.
C. Monthly hours of operations. Hours of operation shall be determined by records of
operation and shall be kept on a daily basis. [R307-401-8]
II.B.6.d The owner/operator shall install, calibrate, maintain, and continuously operate a continuous
emissions monitoring system(s) for the continuous measurement of HCl emissions on Kilns
#1-#5. The CEMS(s) shall be installed and used as the primary method of compliance within
180 days from the date the owner/operator commences operation under the AOS. At a
minimum, the HCl CEMS shall consist of HCl concentration monitor(s) for each kiln, flow
monitors, and a data acquisition system capable of recording measurements from Kilns 1#-#5.
[R307-401-8]
II.B.6.e If the CEMS are not in operation when the owner/operator commences operation under the
AOS, compliance with the HCl emission limit shall be demonstrated as follows for the first
180 days of operation under the AOS:
A. Emissions shall be estimated by multiplying the lime throughput (tons/month) for
each kiln by HCl emission factors.
B. The following emission factors shall be used:
i. 1.67E-1 lbs HCl/ton of lime for the dolomitic lime line
ii. 1.26E-1 lbs HCl/ton of lime for the high calcium line. [R307-401-8]
II.B.6.f When the HCl CEMS have been installed calibrated, and are operating, HCl emissions shall
be calculated as follows for each kiln:
A. Hourly HCl emissions (Eh) shall be calculated using CEMS data as follows:
Eh = K * C * Q
Where:
Eh = hourly HCl mass emission rate during unit operation, lb/hr
K = 9.46E-8 for HCl, lb/scf/ppm
C = HCl concentration averaged for each one-hour period, ppmvw, as measured by the CEMS
Q = volumetric flow rate averaged for each one-hour period, scfh (wet)
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B. The daily HCl emissions (Ed) in pounds shall be calculated by summing the hourly
HCl emissions (Eh) during measured during the day. For purposes of this subsection, a "day"
is defined as a period of 24-hours commencing at midnight and ending the following
midnight.
C. Measured monthly HCl emissions shall be calculated by summing the daily emissions for
all operating days in each month. [R307-401-8]
II.B.6.g The owner/operator shall follow the data replacement procedure below when the HCl CEMS
data are not valid or unavailable due to monitor downtime or because the monitor is out of
control, as determined by 40 CFR 60 Appendix F, Procedure 1 and/or 6:
Ema = Em * (1 +(1/DA - 1) x C
Where:
Ema = adjusted monthly HCl emissions, lbs
Em = total unadjusted HCl mass emission for the month, prior to data replacement procedure,
lb/hr
DA = data availability, fraction of operating time for which monitor data is available during
the reporting period (e.g. 95% data availability = 0.95) and,
C = Conservative Factor = 1.05 = 5% increase. [R307-401-8]
II.B.6.h The owner/operator shall record the output of the system for measuring HCl emissions. The
monitoring system shall operate continuously in accordance with the DAQ Policy Document
for Continuous Emissions Monitoring Systems. The monitoring system shall comply with all
applicable sections of R307-170, UAC and 40 CFR 60 Subpart A and Appendix B, and either
Performance Specification PS-18 or Performance Specification PS-15 as applicable and
approved by the Director. [R307-401-8]
II.B.6.i The Director shall consider the continuous monitoring requirements to be met when the
following provisions are met:
1) Except for system breakdown, repairs, calibration checks, and zero and span
adjustments required under 40 CFR 60.13(d), the owner/operator of an affected source shall
continuously operate all required continuous monitoring devices and shall meet minimum
frequency of operation requirements as outlined in 40 CFR 60.13(e) and R307-170, UAC.
Flow measurement shall be in accordance with the requirements of 40 CFR 52; Appendix E,
40 CFR 60 Appendix B; or 40 CFR 75, Appendix A.
2) Initial performance specification test shall be performed within 60 days of installation.
The performance specification test shall be conducted in accordance with the procedures
contained in 40 CFR 60, Appendix B, Performance Specifications 15 or 18. The Director shall
be notified prior to conducting the performance specification test.
3) At no time shall the owner/operators allow excess gaseous emissions to be emitted to
the atmosphere, except as provided by the provisions of R307-107(Breakdowns), UAC.
[R307-170]
II.B.6.j The owner/operator shall follow the following requirements for stack testing of organic and
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Page 27
metal HAPs:
A. Emission Units
Emission units subject to organic and metal HAPs testing requirements are Kiln #1, Kiln #2,
Kiln #3, Kiln #4, and Kiln #5.
B. Initial Compliance Testing
Initial compliance testing shall be performed as soon as possible and not later than 180 days
after the owner/operator commences operation under the AOS.
C. Frequency
Test every three years
D. Test Method Organic HAPs
40 CFR 60, Appendix A, Method 320 and Method 18, or other EPA-approved testing method
acceptable to the Director.
E. Test Method Chlorine
40 CFR 60, Appendix A, Method 26A, or other EPA-approved testing method acceptable to
the Director.
F. Test Method Metal HAPs
40 CFR 60, Appendix A, Method 29, or other EPA-approved testing method acceptable to the
Director.
G. Other
Unless otherwise specified in this Section, the stack requirements in II.B.1.b.2 and II.B.1.b.3
apply. [R307-401-8]
II.B.6.k Quarterly reports shall be submitted as outlined in R307-170. The reports shall also include:
1) Total HCl emissions for the cumulative quarters of the current 12-month block.
2) Total HAPs emissions for the cumulative quarters of the current 12-month block.
[R307-170, R307-401-8]
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PERMIT HISTORY
When issued, the approval order shall supersede (if a modification) or will be based on the
following documents:
Is Derived From Source Submitted NOI dated December 14, 2021
Incorporates Additional Information Received dated October 2, 2023
Supersedes DAQE-AN103130044-21 dated May 4, 2021
REVIEWER COMMENTS
1. Comment regarding Changes in fugitive dust requirements.:
The conditions being removed or changed by this project are redundant with existing condition
II.B.4.h (since renumbered to II.B.4.b) - the requirement to abide by a fugitive dust control plan. As
these conditions are redundant, there is no relaxation in permit requirements through their removal.
Condition II.B.4.b has been updated as follows:
"The owner/operator shall implement a fugitive dust control plan acceptable to the Director for
control of all dust sources associated with the Cricket Mountain Plant. Adherence to the most
recently approved fugitive dust control plan shall be monitored to demonstrate that appropriate
measures are being implemented to control fugitive dust. At least once during each permit term, the
fugitive dust control plan shall be reviewed and evaluated. If the plan review indicates changes to the
dust control plan are necessary to reflect current site operations, an updated fugitive dust control plan
shall be submitted. The owner/operator shall operate in accordance with the most current fugitive
dust control plan approved by the Director. For each plan review, a record of the date and results of
the review shall be maintained. Records that demonstrate compliance with the most recently
approved fugitive dust control plan shall also be maintained." This addresses the requirements of
Title V and the Regional Haze SIP. [Last updated October 24, 2023]
2. Comment regarding Changes in conditions:
The following changes are made by this project:
1. Condition II.B.1.c removed subcondition P. This is an internal reference to Section II.B.4 which
covers the requirements for fugitive dust and haul roads. It has no specific compliance requirement
by itself.
2. Condition II.B.3.b removed the sentence "The monitoring system shall operate continuously in
accordance with the DAQ Policy Document for Continuous Emissions Monitoring Systems." This
document is no longer applicable as 40 CFR 60 subpart A and Appendix B cover the necessary
requirements.
3. Conditions II.B.4.a through II.B.4.f have been removed and Conditions II.B.4.g and II.B.4.h have
been appropriately renumbered. These existing conditions are redundant with the requirement of
existing condition II.B.4.h (now renumbered as II.B.4.b) which outlines the need for a fugitive dust
control plan. The fugitive dust control plan maintains the same set of requirements as Conditions
II.B.4.a through II.B.4.f - with the added benefit of periodic review and updating.
4. Condition II.A.85 will be updated to include 6 storage tanks previously left off the AO. These are
not new tanks, they are existing tanks mistakenly left off the equipment list.
5. Condition I.8 is no longer necessary as Graymont has completed installation of the listed
equipment.
6. Condition II.B.6.c.1 has been changed to require record submission by the 25th day of the month.
This aligns it with the submission requirements of condition II.B.1.a.1
Engineer Review N103130047: Graymont Western US Incorporated- Cricket Mountain Plant
October 24, 2023
Page 29
7. Condition II.B.6.k has been changed to clarify that the required records are for the cumulative
quarters of the current 12-month block.
[Last updated November 20, 2023]
Engineer Review N103130047: Graymont Western US Incorporated- Cricket Mountain Plant
October 24, 2023
Page 30
ACRONYMS
The following lists commonly used acronyms and associated translations as they apply to this
document:
40 CFR Title 40 of the Code of Federal Regulations
AO Approval Order
BACT Best Available Control Technology
CAA Clean Air Act
CAAA Clean Air Act Amendments
CDS Classification Data System (used by EPA to classify sources by size/type)
CEM Continuous emissions monitor
CEMS Continuous emissions monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon monoxide
CO2 Carbon Dioxide
CO2e Carbon Dioxide Equivalent - 40 CFR Part 98, Subpart A, Table A-1
COM Continuous opacity monitor
DAQ/UDAQ Division of Air Quality
DAQE This is a document tracking code for internal UDAQ use
EPA Environmental Protection Agency
FDCP Fugitive dust control plan
GHG Greenhouse Gas(es) - 40 CFR 52.21 (b)(49)(i)
GWP Global Warming Potential - 40 CFR Part 86.1818-12(a)
HAP or HAPs Hazardous air pollutant(s)
ITA Intent to Approve
LB/HR Pounds per hour
LB/YR Pounds per year
MACT Maximum Achievable Control Technology
MMBTU Million British Thermal Units
NAA Nonattainment Area
NAAQS National Ambient Air Quality Standards
NESHAP National Emission Standards for Hazardous Air Pollutants
NOI Notice of Intent
NOx Oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
PM10 Particulate matter less than 10 microns in size
PM2.5 Particulate matter less than 2.5 microns in size
PSD Prevention of Significant Deterioration
PTE Potential to Emit
R307 Rules Series 307
R307-401 Rules Series 307 - Section 401
SO2 Sulfur dioxide
Title IV Title IV of the Clean Air Act
Title V Title V of the Clean Air Act
TPY Tons per year
UAC Utah Administrative Code
VOC Volatile organic compounds
December 14, 2021
Mr. Jon Black
Attn: Permitting
Utah Division of Air Quality
195 North 1950 West
Salt Lake City, UT 84116
RE: Notification of Intent: Graymont Western US Incorporated – Cricket
Mountain Plant
Dear Mr. Black:
Graymont Western US Incorporated (Graymont) is submitting a Notice of Intent (NOI)
for the Cricket Mountain Lime Plant (Cricket Mountain) located on Highway 257, 32
miles southwest of Delta, Utah 84624. This NOI is being submitted to request a change
to the existing Fugitive Dust Control Plan, specifically to the application frequency of
the chemical treatment (i.e., Magnesium Chloride (MgCl2) dust suppression control).
This NOI package is to update the AO under Cricket Mountain Title V Operating
Permit (Number 2700005004) and includes the following electronic forms:
• Form 1: Notice of Intent Application
• Form 2: Company Information
• Form 4: Project Information
• Form 5: Emissions Information
Unpaved gravel roads are treated with MgCl2 at Cricket Mountain to provide control of
fugitive dust (airborne dust) resulting from plant operations traffic, in accordance with
the National Ambient Air Quality Standards (NAAQS), Utah Department of
Environmental Quality (UDEQ) Division of Air Quality’s (UDAQ’s) Fugitive Dust Rule
(R307-309) and the requirements of the Cricket Mountain Fugitive Dust Control Plan.
As included in Cricket Mountain’s Fugitive Dust Control Plan, the current frequency of
MgCl2 application to the unpaved haul roads is three times a year. Upon further review,
Cricket Mountain
Lime Plant
NOI Application
Package
PREPARED FOR:
GRAYMONT WESTERN
US INC.
PROJECT NO. 318-4-10
DECEMBER 14, 2021
ii
TABLE OF CONTENTS
1.0 Introduction and Checklist ................................................................................................................. 1
Form 1 Notice of Intent (NOI) Application Checklist ....................................................................... 2
2.0 Source Identification Information [R307-401-5] ............................................................................... 3
2.1 Area Designation (Attainment, Maintenance, or Nonattainment) ............................................ 3
2.2 Federal/State Requirement Applicability (NAAQS, NSPS, MACT, SIP, etc.) ........................ 3
2.2.1 National Ambient Air Quality Standards (NAAQS) ............................................................ 3
2.2.2 New Source Performance Standards (NSPS) ......................................................................... 3
2.2.3 Major Source Maximum Achievable Control Technology (MACT) ................................... 3
2.2.4 National Emission Standards for Hazardous Air Pollutants (NESHAP) .......................... 3
2.3 Source Size Determination (Major, Minor, PSD) ......................................................................... 3
3.0 NOI Application Information [R307-401] ......................................................................................... 4
3.1 Detailed Description of the Project and Source Process ............................................................. 4
3.2 Discussion of Fuels, Raw Materials, and Products Consumed/Produced .............................. 4
3.3 Description of Equipment Used in the Process and Operating Schedule ................................ 4
3.4 Description of Changes to the Process, Production Rates, etc. .................................................. 4
3.5 Site Plan of Source with Building Dimensions, Stack Parameters, etc. .................................... 4
3.6 Best Available Control Technology (BACT) Analysis [R307-401-8] .......................................... 5
3.7 Emissions Related Information: [R307-401-2(b)] .......................................................................... 5
3.8 Emissions Impact Analysis – Approved Modeling Protocol [R307-410] .................................. 5
3.9 Nonattainment/Maintenance Areas – Major NSR/Minor (Offsetting Only) [R307-403] ...... 5
3.10 Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406] ................. 6
3.11 Signature on Application .............................................................................................................. 6
4.0 References ............................................................................................................................................. 7
Figures
Figure 1. Cricket Mountain Roads Plan .................................................................................................. 5
Appendices
Appendix A – Applicable UDAQ NOI Forms
1
1.0 INTRODUCTION AND CHECKLIST
Graymont Western US Inc. (Graymont) is submitting this Notice of Intent (NOI) application
package for the following modification to the Cricket Mountain Lime Plant (Cricket Mountain):
1. Update the frequency of chemical surfactant application on the main haul road and the
sales road to twice per year.
This NOI application document is organized in a manner that follows the outline provided in
the UDAQ Form 1 – NOI Application Checklist, provided on the next page. The checklist items
that are not specifically listed on the applicable official application forms or require further
details are addressed in this application document. This NOI application package includes the
following appendix:
Appendix A – Applicable UDAQ NOI Forms
2
Form 1 Notice of Intent (NOI) Application Checklist
3
2.0 SOURCE IDENTIFICATION INFORMATION
[R307-401-5]
NOI application checklist source identification items 1 through 5 and 9 are provided on Form 2
in Appendix A. The remaining items from the NOI application checklist – Source Identification
Information are provided in this section.
2.1 Area Designation (Attainment, Maintenance, or Nonattainment)
The Cricket Mountain is in Millard County, which is in compliance with National Ambient Air
Quality Standards (NAAQS) for all applicable pollutants (EPA 2021).
2.2 Federal/State Requirement Applicability (NAAQS, NSPS, MACT,
SIP, etc.)
Federal and state requirements are addressed in this section.
2.2.1 National Ambient Air Quality Standards (NAAQS)
There are no proposed changes to emissions from the main haul road and sales road as a result
of this modification.
2.2.2 New Source Performance Standards (NSPS)
Fugitive dust from activity on the main haul road and sales road are not subject to any NSPS.
2.2.3 Major Source Maximum Achievable Control Technology (MACT)
Fugitive dust from activity on the main haul road and sales road are not subject to any MACT.
2.2.4 National Emission Standards for Hazardous Air Pollutants (NESHAP)
Fugitive dust from activity on the main haul road and sales road are not subject to any
NESHAP.
2.3 Source Size Determination (Major, Minor, PSD)
The Cricket Mountain Lime Plant is a major source with respect to Title V of the 1990 Clean Air
Act Amendments and the Prevention of Significant Deterioration (PSD) regulations per 40 CFR
52.21.
4
3.0 NOI APPLICATION INFORMATION [R307-401]
3.1 Detailed Description of the Project and Source Process
Graymont is requesting to update the frequency of required chemical treatment applications on
the main haul road and sales road specified in permit condition II.B.22.a. This permit condition
requires at least 3 applications per year. Graymont is proposing to update the number of
applications to at least 2 times per year.
3.2 Discussion of Fuels, Raw Materials, and Products
Consumed/Produced
The main haul road connects the quarry to the plant and the sales road connects the offices to
State Highway 257.
3.3 Description of Equipment Used in the Process and Operating
Schedule
The proposed modification requested in this NOI application affects the main haul road and
sales road. No changes are requested to activity rates or associated control technology.
3.4 Description of Changes to the Process, Production Rates, etc.
Not applicable. No change to processes, production rates, equipment, or emissions is being
proposed.
3.5 Site Plan of Source with Building Dimensions, Stack Parameters, etc.
A site map showing the affected roads at Cricket Mt. are shown in Figure 1. The only emissions
from these roads are fugitive and no change to PTE is being requested. Therefore, modeling
parameters (building dimensions, stack parameters, etc.) are not provided with this NOI
application.
5
Figure 1. Cricket Mountain Roads Plan
3.6 Best Available Control Technology (BACT) Analysis [R307-401-8]
Not applicable. The only emissions from these sources are fugitive and there are no proposed
changes to either equipment or control technology.
3.7 Emissions Related Information: [R307-401-2(b)]
Form 5 in Appendix A provides a facility-wide summary of the potential emissions from the
Cricket Mountain Facility. There will be no change to facility PTE as a result of this NOI.
3.8 Emissions Impact Analysis – Approved Modeling Protocol [R307-410]
Not applicable. Because there will be no change to PTE as discussed in Section 3.7, no modeling
protocol or analysis is provided with this NOI application pursuant to R307-410-4.
3.9 Nonattainment/Maintenance Areas – Major NSR/Minor (Offsetting
Only) [R307-403]
Not applicable. Offsetting is not required for this modification because the Cricket Mountain is
not located in a nonattainment area.
6
3.10 Major Sources in Attainment or Unclassified Areas (PSD) [R307-405,
R307-406]
As discussed in Section 3.7, there is no change to emissions or PTE as a result of this
modifications. Therefore, PSD is not applicable.
3.11 Signature on Application
The responsible official’s signature is provided on Form 2 in Appendix A.
7
4.0 REFERENCES
EPA. 2021. "Current Nonattainment Counties for All Criteria Pollutants." United State
Environmental Protection Agency, October 31. Accessed November 30, 2021.
https://www3.epa.gov/airquality/greenbook/ancl.html#UT.
Appendix A – Applicable UDAQ NOI Forms
Page 1 of 1
Form 4 Company____________________________
Project Information Site ______________________________
Utah Division of Air Quality
New Source Review Section
Process Data - For Modification/Amendment ONLY
1. Permit Number_______________________________
If submitting a new permit, then use Form 3
Requested Changes
2. Name of process to be modified/added:
_______________________________
End product of this process:
_______________________________
3. Permit Change Type: New Increase*
Equipment
Process
Condition Change ____________________
Other ______________________________
Other ______________________________
Other ______________________________
4. Does new emission unit affect existing
permitted process limits?
Yes No
5. Condition(s) Changing:
6. Description of Permit/Process Change**
7.New or modified materials and quantities used in process. **
Material Quantity Annually
8. New or modified process emitting units **
Emitting Unit(s)Capacity(s)Manufacture Date(s)
*If the permit being modified does not include CO2e or PM2.5, the emissions need to be calculated and submitted to DAQ, which may result in an
emissions increase and a public comment period.
**If additional space is required, please generate a document to accommodate and attach to form.
Graymont Western US Inc.
Cricket Mountain Plant
2700005003
Dust Control application for gravel roads
N/A
N/A
✔
Change in frequency of chemical stabilizer
application.
Chemical stabilizer
N/A
Graymont will apply chemical stabilizer twice a year on the unpaved, gravel haul roads to
maintain dust control requirements in accordance with the Plant's Dust Control Plan.
Page 1 of 1
Company___________________________
6LWH_____________________________
Form
Emissions Information
Criteria/GHGs/ HAP’s
Utah Division of Air Quality
New Source Review Section
Potential to Emit* Criteria Pollutants & GHGs
Criteria Pollutants Permitted Emissions
(tons/yr)
Emissions Increases
(tons/yr)
Proposed Emissions
(tons/yr)
PM10 Total
PM10 Fugitive
PM2.5
NOx
SO2
CO
VOC
VOC Fugitive
NH3
Greenhouse Gases CO2e CO2e CO2e
CO2
CH4
N2O
HFCs
PFCs
SF6
Total CO2e
*Potential to emit to include pollution control equipment as defined by R307-401-2.
Hazardous Air Pollutants**(**Defined in Section 112(b) of the Clean Air Act )
Hazardous Air
Pollutant***
Permitted Emissions
(tons/yr)
Emission Increase
(tons/yr)
Proposed
Emission (tons/yr)
Emission Increase
(lbs/hr)
Total HAP
*** Use additional sheets for pollutants if needed
Graymont Western US Inc.
Cricket Mountain Lime Plant
611.87 0.00 611.87
0.00
610.78 0.00 610.78
3,883.85 0.00 3,883.85
760.29 0.00 760.29
7,821.19 0.00 7,821.19
117.84 0.00 117.84
887,964.00 0.00 887,964.00
10/24/23, 3:46 PM State of Utah Mail - Re: Graymont change
https://mail.google.com/mail/u/0/?ik=91115cbbfa&view=pt&search=all&permthid=thread-a:r-922613128478078174%7Cmsg-f:1778653709999628502…1/3
John Jenks <jjenks@utah.gov>
Re: Graymont change
1 message
Brandy Cannon <bcannon@utah.gov>Mon, Oct 2, 2023 at 8:18 AM
To: John Jenks <jjenks@utah.gov>
Hi John:
Thanks for waiting while I worked this language out with Nate. Can we make the following changes to II.B.4.b? This would
be in addition to what we discussed before.
II.B.4.b The owner/operator shall implement a fugitive dust control plan acceptable to the Director for control of all
dust sources associated with the Cricket Mountain Plant. Adherence to the most recently approved fugitive
dust control plan shall be monitored to demonstrate that appropriate measures are being implemented to
control fugitive dust. At least once during each permit term, the fugitive dust control plan shall be
reviewed and evaluated. If the plan review indicates changes to the dust control plan are necessary to
reflect current site operations, an updated fugitive dust control plan shall be submitted. The owner/operator
shall operate in accordance with the most current fugitive dust control plan approved by the Director. For
each plan review, a record of the date and results of the review shall be maintained. Records that
demonstrate compliance with the most recently approved fugitive dust control plan shall also be
maintained. [R307-401]
We decided this AO would be processed as an enhanced AO right? That saves them from having to submit a sig mod
application to me later. When you get the responsible official signature on the engineering review, will you email me a
copy?
Thanks,
Brandy Cannon
Environmental Engineer | Operating Permits Section
M: (385) 226-4139
P: (801) 536-4000
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
On Mon, Jul 31, 2023 at 2:57 PM John Jenks <jjenks@utah.gov> wrote:
I spoke with Jon and we're planning on keeping it as an admin. He agreed with me that the currently listed
requirements don't add a tangible benefit. Your other changes regarding the dust control rules, fuel tanks and the like
will all be incorporated. I will run the updated draft past him again so he can see the changes. Of course you and Tad
will also receive an updated copy.
Thanks a lot for the fugitive dust rule comment (I wasn't aware of that), and the other updates. I'm still awaiting Tad's
comments, and seeing if Teri has fixed the templates yet or not. I'll let you know when I have a new version.
- John
On Thu, Jul 27, 2023 at 7:21 AM Brandy Cannon <bcannon@utah.gov> wrote:
Hi John:
10/24/23, 3:46 PM State of Utah Mail - Re: Graymont change
https://mail.google.com/mail/u/0/?ik=91115cbbfa&view=pt&search=all&permthid=thread-a:r-922613128478078174%7Cmsg-f:1778653709999628502…2/3
Here are my comments plus a couple of things that showed up during the T5 renewal that do not line up with the AO.
Could we do this AO enhanced instead of as an admin and get those corrected?
1. Because Graymont is in the haze SIP, neither of the fugitive dust rules (R307-205, R307-309) applies to them
now. So you might want to remove condition II.B.4.g that references R307-205. My suggestion would be to
leave the fugitive dust conditions in the AO for now since the AO could serve as the authority in the T5 instead
of the rules and just give them the reduced frequency they requested. I think condition II.B.4.e could still be
removed though. That's been commented out of the T5 since 2006 because they are subject to a 20% opacity
limitation and reduction of drop distance is a standard work practice.
You also might want to add more of what you'd like to see contained in the dust control plan since neither rule
is applicable now and since approval of the plans submitted online is automatic. Just a suggestion though.
By the way, I talked to the rules people and emailed Jon, Alan, and Dave about R307-205 and R307-309 when
I first ran across it with Ash Grove.
2. They have 6 existing fuel storage tanks on site in addition to the 500-gal gasoline tank that is listed in the AO:
Four 10,150- and one 12,000-gallon diesel tanks, one 2,000-gallon gasoline tank.
3. II.A.48, II.A.51: Graymont told me R-1 is the primary crusher, not the loadout for the sugar stone system. The
ID for the sugar stone loadout is 203255SSS001.
4. II.B.3.b: Remove "DAQ Policy Document for Continuous Emission Monitoring Systems?" I have never been
able to find it so I comment it out of the T5. Do we need it or are references to R307-170, 40 CFR 60 subpart A
and appendix B specs good enough?
Thanks for considering these and let me know if you have any questions or want to discuss further.
Brandy Cannon
Environmental Engineer | Operating Permits Section
M: (385) 226-4139
P: (801) 536-4000
airquality.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
On Tue, Jul 25, 2023 at 11:47 AM John Jenks <jjenks@utah.gov> wrote:
Brandy,
I'm sending some errors over to Teri H on the engineering review changes, but I thought you could review the latest
changes for Graymont while I'm waiting for her corrections.
RN103130045-23 makes the following changes to their existing AO:
Condition II.B.1.c - removed subcondition P. This is an internal reference to Section II.B.4 which covers the
requirements for fugitive dust and haul roads. It has no specific compliance requirement by itself.
Conditions II.B.4.a through II.B.4.f have been removed and Conditions II.B.4.g and II.B.4.h have been
appropriately renumbered. These existing conditions are redundant with the requirement of existing condition
II.B.4.h (now renumbered as II.B.4.b) which outlines the need for a fugitive dust control plan.
I'd attach the actual RN document, but it has two major errors that need to be corrected: The permit history doesn't
seem to be working, and there is an extraneous sentence on the first page of the cover letter. If you'd like, you can
find the ER in tempo. Please let me know if you have any questions.
--
John D. Jenks
Environmental Engineer IV | NSR Major Source
New Phone #: (385) 306-6510
airquality.utah.gov
10/24/23, 3:46 PM State of Utah Mail - Re: Graymont change
https://mail.google.com/mail/u/0/?ik=91115cbbfa&view=pt&search=all&permthid=thread-a:r-922613128478078174%7Cmsg-f:1778653709999628502…3/3
--
John D. Jenks
Environmental Engineer IV | NSR Major Source
New Phone #: (385) 306-6510
airquality.utah.gov