DRAFT OKLAHOMA DEPARTMENT OF ENVIRONMENTAL ......grain loading factor of 0.015 gr/acf, used in Permit No. PSD-OK-61. E-21 is controlled by a 1,800 E-21 is controlled by a 1,800 acfm

DRAFT

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM December 16, 2019

TO: Phillip Fielder, P.E., Permits and Engineering Group Manager

THROUGH: Rick Groshong, Senior Environmental Manager

THROUGH: Eric Milligan, P.E., Engineering Section Manager

THROUGH: Peer Review, David Schutz, P.E.

FROM: Phil Martin, P.E., Existing Source Permits Section Manager

SUBJECT: Evaluation of Permit Application No. 2015-1720-TVR

Facility ID: 0910

Lone Star Industries, Inc., dba Buzzi Unicem USA

Pryor Cement Manufacturing Facility (SIC 3241)

2430 South 437 (Lat. 36.27211; Long. 95.22069)

Section 30, T21N, R19E, Mayes County

Located 5 miles east of Pryor on Highway 20 and 2 miles south.

SECTION I. INTRODUCTION

Lone Star Industries, Inc. dba Buzzi Unicem USA (applicant) submitted an application in October

2015 for the renewal of the current operating Permit No. 98-170-TV (M-8). The applicant operates

a cement manufacturing plant (SIC 3241) having three kilns, two raw mill circuits, three finish

mills, and two quarries located east of the city of Pryor, Mayes County, Oklahoma. The facility is

subject to Title V permitting requirements because it emits more than 100 TPY of a regulated

pollutant. Nitrous oxides (NOX), carbon monoxide (CO), sulfur dioxide (SO2) and PM all have an

estimated potential to emit (PTE) above the Prevention of Significant Deterioration (PSD)

threshold.

The following list of corrections and changes are taken from the application for this Title V renewal

permit and modified as necessary based on results of subsequent discussion between Buzzi and

DEQ and also based on the responses to DEQ’s Notice of Deficiencies issued September 7, 2018

and May 8, 2018. Due to the timing of previous permit issuances and Buzzi’s work on the TVR

application, there was some overlap of these events resulting in numerous changes that are

repetitive of those requested for Permits 98-170-TV (M-8) and 98-170-TV (M-12).

Permit No. 98-170-TV (M-8) currently reflects E-19, E-20, and E-21 being controlled by a single

2,000 acfm baghouse that vents to the atmosphere as emission point P-11. This is incorrect as

equipment has been updated multiple times. Emission point P-11 was grandfathered but likely lost

grandfathered status when the newer equipment was constructed in 1980 and 1981, and the current

PERMIT MEMORANDUM 2015-1720-TVR DRAFT 2

C-8 baghouse was installed on March 15, 1992. E-19 and E-20 are controlled by a 6,085 acfm

baghouse, C-8, that exhausts to emission point P-11a. This permit assigns limits calculated from a

grain loading factor of 0.015 gr/acf, used in Permit No. PSD-OK-61. E-21 is controlled by a 1,800

acfm baghouse, C-9, that exhausts to emission point P-11b. C-9 was a replacement baghouse that

was installed on March 20, 2005.

Permit No. 98-170-TV (M-8) currently reflects E-27, the “#5 A-Frame Tripper Belt Conveyor”

as having a 2-wall enclosure and venting to the atmosphere as emission point P-12. E-27 also

currently accounts for both the “#5 A-Frame Tripper Belt Conveyor” and the “A-Frame Storage”

building. The “#5 A-Frame Tripper Belt Conveyor” is actually controlled by a 1,800 acfm baghouse,

C-10, therefore applicant is requesting to split these sources into E-27, the “#5 A-Frame Tripper Belt

Conveyor”, and E-27a, the “A-Frame Storage” building as part of this renewal application. E-27, the

“#5 A-Frame Tripper Belt Conveyor,” should be included in the Part 70 Permit as being controlled

by a 1,800 acfm baghouse (C-10) that exhausts to emission point P-12b. E-27a, the “A-Frame

Storage” building, should be included in the Part 70 Permit as being within a 2-walled enclosure that

exhausts to the atmosphere as emission point P-18. Buzzi is accepting limits of 12 tons per year

(TPY) PM10 for the A-Frame storage pile and 1.4 TPY PM10 for the baghouse, which in considering

the total of 13.4 TPY, is a decrease from the previous limit of 19 tons per year for just the A-Frame

storage pile.

Permit No. 98-170-TV (M-8) currently reflects E-28, the “#5 Storage Hall Tripper Belt

Conveyor”, as having a 1-wall enclosure and venting to the atmosphere as emission point P-12. This

emission point has been changed to P-12a to avoid confusion with the emission point for E-27.

Permit No. 98-170-TV (M-8) currently reflects E-135a as being controlled by C-69, which

exhausts to emission point P-70. This is incorrect and has been corrected to reflect E-135a being

controlled by C-45, which exhausts to emission point P-69. In Permit No. 98-170-TV (M-8), P-69

and P-70 (Finish Mill #3 sources) have emission limits in Condition 1.D of the Specific Conditions

of 19 TPY PM10 and 18 TPY PM10, respectively, based on an emission factor of 0.01 gr/acf. The

Permit Memorandum section of Permit No. 98-170-TV (M-8) lists P-69 and P-70 as each having a

50,000 acfm baghouse.

In Permit No. 98-170-TV (M-12), no changes were proposed to P-69 and P-70; however, it appears

that they were mistakenly combined as Condition 1.D of the Specific Conditions lists them having a

combined PM10 limit of 19 TPY. Permit No. 98-170-TV (M-12) did incorporate other changes to

finish mill baghouses assessed under Applicability Determination No. 98-170-AD (M-9).

The error is corrected in this permit and P-69 and P-70 is listed as having separate baghouses both

within the Specific Conditions and within the Permit Memorandum. In addition, in the Title V

Renewal Application, Buzzi identified that the actual flowrates for the two large baghouses associated

with Finish Mill #3 should be corrected to 23,500 acfm for P-69 and 38,000 acfm for P-70. 50,000

acfm baghouses were originally permitted for these two sources, but slightly smaller baghouses were

actually installed and are currently operated. These lower flowrates with the 0.01 gr/acf emission rate

result in potential estimated PM/PM10 emissions of 8.8 TPY for P-69 and 14.3 TPY for P-70. The

Permit Memorandum is updated to reflect these revised emission rates and flowrates. The PM/PM10

emission limits for these sources in Condition 1.D of the Specific Conditions is lowered to 8.8 TPY


for P-69 and 14.3 TPY for P-70. This represents a reduction in permitted emission levels for these

two existing sources; therefore, no further evaluation is required.

Permit No. 98-170-TV (M-8) currently reflects E-146, NW Truck & Rail Loadout (P-78), as

having no controls. This is incorrect. The source actually is controlled by a 1,800 acfm baghouse C-

65. This is a grandfathered source. The emissions have been corrected in the memo to reflect this

correction.

Permit No. 98-170-TV (M-8) currently reflects E-157 as exhausting to the atmosphere as emission

point P-85, East Rail Loadout Spout, with no controls. This is incorrect. E-157 was modified in June

2012 to add a 1,800 acfm baghouse (C-59). This was documented in an April 5, 2012 letter to ODEQ.

The potential PM emissions for this source, per the letter, were estimated to be 158 TPY based on a

maximum hourly loading rate and a PM emission factor of 0.2 lb/ton cement. The addition of the

baghouse reduced the potential emissions for E-157 to 1.4 TPY PM and 1.1 TPY PM10 using an

emission rate of 0.02 gr/acf PM and assuming PM10 is 85% of PM. The permit memorandum and the

specific conditions have been adjusted to these levels.

Permit No. 98-170-TV (M-8) currently reflects E-149 [recirculating pump] as being controlled by

baghouse C-51 which vents to emission point P-75. This is incorrect. E-149 is a closed system having

no emissions.

Permit No. 98-170-TV (M-8) currently reflects E-172 [pack house fringe bin] as venting to

emission point P-91. E-172 is a closed bin that receives material from either West Packer Bucket

Elevator (E-165) or the East Packer Bucket Elevator (E-169) and thus can vent through either P-90

or P-91. Since the emissions are the same through either baghouse, there is no change in emissions.

Permit No. 98-170-TV (M-8) currently reflects E-103 (P-60) as “Clinker Storage – Inside Shed.”

This source is being renamed to the “Clinker Storage Hall.”

The following sources are located within the Clinker Storage Hall, therefore their emission point

IDs have all been changed to P-60 to reflect that they are located within this structure.

o E-34 Raw Mill Material Bins

o E-70 Clinker Bucket Elevator



o E-108 Clinker/Gypsum Bins (3)

o E-119 Clinker/Limestone/Gypsum Bins (5) 3 Used

o E-129 Clinker/Limestone/Gypsum Bins (3)

o E-33 Overhead Crane (used for clinker and finish mills)

Detailed review of the Permit No. 98-170-TV (M-8) determined that several sources controlled

by baghouses had incorrect flow rates listed. The following flow rate corrections are requested:

o P-69 (E-132 and E-135a) flow rate corrected from 50,000 acfm to 23,500 acfm


o P-70 (E-133, E-134, E-135, E-135b, E-136, E-137) flow rate corrected from 50,000 acfm to

38,000 acfm

o P-76 (E-141, E-143, E-144) flow rate corrected from 2,500 acfm to 4,500 acfm

o P-80 (E-150) flow rate corrected from 3,600 acfm to 9,000 acfm

o P-81 (E-150) flow rate corrected from 3,600 acfm to 9,000 acfm

o P-82 (E-151, E-158) flow rate corrected from 2,500 acfm to 4,500 acfm

The emissions changes associated with this change are addressed in more detail in Buzzi’s response

of December 4, 2018 to DEQ’s NOD of September 7, 2018. P-76, P-80, P-81, and P-82 were all

constructed prior to 1974 and Buzzi has no documentation that they have ever been modified.

The following sources are closed systems having no vents or exhaust, except to the kilns.

o E-95a Coal Mill to Kiln 1-a (P-42)

o E-95b Coal Mill to Kiln 1-b (P-42)

o E-95c Coal Mill to Kiln 2-a (P-42)

o E-95d Coal Mill to Kiln 2-b (P-42)

o E-95e Coal Mill to Kiln 3-a (P-58)

o E-95f Coal Mill to Kiln 3-b (P-58)

Currently Permit No. 98-170-TV (M-8) reflects the following Finish Mill #2 and Finish Mill #3

additive hoppers and feeders as having no controls. This is incorrect. These eight emission units are

all located within the Mill Building, which is a 4-walled enclosure. The fugitive emissions from the

Mill Building exhaust to the atmosphere as emission point P-262. Therefore, the emission points for

these eight sources have been revised to P-262.

o E-259 Finish Mill #2 additives hopper and feeder (P-262)

o E-260 Finish Mill #2 additives feeder to feed conveyor (P-262)







Also, Buzzi makes a correction to the calculations to base emissions on actual annual throughput of

15,000 tons instead of annualizing the hourly rate of 95 TPH. While this reduced the memo PTE, it

did not increase permitted emissions.

Currently Permit No. 98-170-TV (M-8) includes the following sources, which were determined

not to exist and therefore, should be removed from the permit.

o E-43 Clean-up Bucket Elevator (P-27)

o E-148 Material Handling Dust Collector (P-79)

o E-203 PHC Material Storage Pile (P-203)

o E-159 East Rail Aux Loadout (P-86)


In addition, changes were made to the language of Permit No. 98-170-TV (M-8) to more clearly

define that Permit No. 78-001-O (M-2) authorized Kiln No. 3 to utilize non-hazardous (NHSM)

secondary materials that are fuels and not solid wastes as described in 40 CFR 241. Finally, this

permit incorporates the Dry Sorbent Injection (DSI) System installed under Permit No. 98-170-

TV (M-14). The DSI system was installed to reduce hydrochloric acid (HCl) emissions,

particularly while producing Calcium Sulfoaluminate (CSA) cement to meet the new NESHAP

Subpart LLL standard.

SECTION II. PROCESS DESCRIPTION

The following discussion was composed by utilizing paraphrased text from AP-42, Fifth Edition,

Volume I, Chapter 11, Mineral Products Industry, Section 11.6, Portland Cement Manufacturing,

and incorporating information contained in the Title V permit application as well as additional

information based on Buzzi’s experience with cement manufacturing at various plants in the

United States. A list of equipment and associated emissions controls are included as Attachment

A of the Operating & Maintenance (O&M) Plan, included as Attachment E of the Title V permit

application. Buzzi states they have updated it again as of January 9, 2017. Detailed process flow

diagrams that identify and locate affected equipment and systems and unaffected equipment are

included as Attachment B of the O&M Plan.

Buzzi manufactures various grades and blends of Portland cement and has been equipped to do so

since the early permits were issued. Portland cement is a fine powder, gray or white in color,

consisting of a mixture of hydraulic cement materials comprised primarily of calcium silicates,

aluminates and aluminoferrites. More than 30 raw materials are known to be used in the

manufacture of Portland cement, and these materials can be divided into four distinct categories:

calcareous, siliceous, argillaceous, and ferriferous. These materials are chemically combined

through pyroprocessing and subjected to subsequent mechanical processing operations to form

gray and white Portland cement. Gray Portland cement is used for structural applications and is

the more common type of cement produced. White Portland cement has lower iron and manganese

contents than gray Portland cement and is used primarily for decorative purposes. Portland cement

manufacturing plants are part of hydraulic cement manufacturing, which also includes natural,

masonry, and pozzolanic cement.

One of the specialty cements produced at the facility is CSA cement. The primary raw materials

are limestone, bauxite (or an aluminous clay) and gypsum, although by-products such as fly ash

may be also used. The preparation of CSA clinker is achieved by burning the raw materials in the

kilns at temperatures lower than for manufacturing Portland cement.

The manufacturing process can be divided into the following primary components: raw materials

acquisition and handling, kiln feed preparation, pyroprocessing, and finished cement grinding.

The initial production step in Portland cement manufacturing is raw materials acquisition. The

raw materials for the kiln process include materials obtained from both on-site and off-site sources.

Four chemical constituents are needed to form the cement clinker (gray, glass-hard, spherically

shaped nodules that range from 0.125 to 2.0 inches in diameter) manufactured at this facility, which

is ground up with gypsum to make the final cement products. These ingredients include calcium,

silica, alumina, and iron.


Calcium, the element of highest concentration in Portland cement, can be obtained from a variety

of calcareous raw materials, including limestone, chalk, marl, sea shells, aragonite, and an impure

limestone known as "natural cement rock". Because a large fraction (approximately one third) of

the mass of this primary material is lost as carbon dioxide (CO2) in the kiln, Portland cement plants

are located close to a calcareous raw material source whenever possible. Some quarries produce

relatively pure limestone that requires the use of additional raw materials to provide the correct

chemical blend in the raw mix. Occasionally, pockets of pyrite, which can significantly increase

emissions of sulfur dioxide (SO2), are found in deposits of limestone, are also used as raw materials

for Portland cement. Other elements included in the raw mix are silicon, aluminum, and iron.

These elements are contained in ores and minerals such as sand, shale, clay, and iron ore.

Silica and alumina sources for this facility are provided from low calcium limestone, bottom ash,

bauxite, slag and other similar materials. Limestone and shale are mined from the adjacent

quarries. Iron scale and iron ore are shipped from various sources. The other ingredients are also

shipped from offsite sources.

The quarries are not within the scope of this permit. There are no specific requirements contained

in this permit that are applicable to the quarry mining operations. Regulated emissions commence

where materials handling is conducted. Onsite handling and storage of the raw materials generates

regulated emissions of particulate matter at the facility. Raw materials are processed first (Process

Flow Diagram B-1 of the Title V permit application) in the primary crusher. The material is then

sent through a primary screen/separator and the material is then processed in a secondary

crusher/ball mill and screen and then sent to storage piles. Some material from the primary screen

is sent directly to storage piles.

The Portland cement manufacturing industry is relying increasingly on replacing virgin materials

with non-hazardous secondary materials (NHSMs) from other manufacturing operations, to the

extent that such replacement can be implemented without adversely affecting plant operations,

product quality or the environment. Materials in this category that have been used at this facility

include bottom ash, mill scale, metal smelting slags, and non-hazardous raw material, such as fuel

contaminated soils.

Either gypsum or natural anhydrite, both of which are forms of calcium sulfate, is introduced to

the process during the raw and/or finish grinding operations. These materials, also excavated from

quarries or mines, are generally purchased from an external source rather than obtained directly

from a captive operation by the facility. At this facility, clinker is ground with gypsum to form

different types of cement. Some cement products also require the addition of minor amounts of

other mineral additives into the finish grinding operations.

Raw Mill System

The second production step in Portland cement manufacture is preparing the raw mix, or kiln feed,

for the pyroprocessing operation. Raw material preparation includes a variety of blending and

sizing operations that are designed to provide a feed with appropriate chemical and physical

properties. The raw material processing operations differ somewhat for wet and dry processes.

This facility uses the dry process. There are two raw mill systems at this facility that provide a


feed stream of various raw mineral ingredients to the kilns in the correct proportions and size

gradation, at the necessary moisture content.

Specific materials in the raw mill bins are transported to the raw mill. Moisture is usually reduced

to less than 1 percent before or during grinding. Drying at this facility is accomplished in the

separators and ball mills of the raw mill systems. The most efficient and widely used source of

heat for drying is the hot exit gases from the pyroprocessing system. The two raw mills at this

facility are equipped with an exhaust gas recovery system ducted off the clinker coolers with the

hot air furnaces supplying supplemental heated air.

Cement raw materials are received with an initial moisture content varying from 1 to more than 50

percent. Crushed limestone and additives are moved from the storage piles to the raw material

hoppers for additional processing. The raw materials are metered onto a conveyor belt according

to predetermined proportions through the use of weigh feeders located beneath the hoppers. From

the conveyor belt system, the raw materials are transferred to the raw mill bins. There are two sets

of raw mill bins and feeders, one for each of two raw mills. The weigh feeders transport the

proportioned raw material constituents to the raw mill feed belts, and then to bucket elevators,

which feed the mills. The two raw mills are utilized to grind the raw materials into a fine powder,

referred to as “raw mix.” Each raw mill system consists basically of a raw material feed bin with

weigh feeder, a bucket elevator, an 18-foot diameter classifier (separator) to separate the material

according to fineness, a hot air furnace for drying the materials, a 2,000-hp ball mill for grinding

raw materials into raw meal for the kilns, conveying equipment, a dust collection system consisting

of additional classifier cyclones and a baghouse, an induced draft fan, and a stack. The ball mills

are also equipped with a separate baghouse rated at 10,000-acfm. The two raw mill systems are

almost identical in equipment and functionality except that Circuit No. 2 does have an additional

baghouse for associated material handling. Clinker cooler exhaust supplies most of the heat

needed for drying. This utilization of waste heat minimizes heat generation required by the hot air

furnace.

In each raw mill circuit, the raw materials are fed from the feed bins through the bucket elevator

to the classifier. Clinker cooler exhaust gas and, to a lesser extent, heated ambient air are routed

through the classifiers to dry the raw materials before they are fed to the ball mill. The hot air

furnaces are direct fired by natural gas. The raw materials are heated to approximately 180o F.

The induced draft fan pulls the clinker cooler exhaust/heated air through the classifier and bucket

elevator at sufficient velocity to entrain suspended particles of raw materials in the system to the

dust collection system. At the classifier, material of suitable size for kiln feed blend separates out

and is pneumatically conveyed to one of three raw mix blending silos or the kiln feed storage silo

(Process Flow Diagrams B-3 and B-4 of the Title V permit application) where it is stored until it

is fed to the pyroprocessing system. Material too large is rejected back to the ball mill for

additional grinding. Suspended particulate matter collected at the cyclones/baghouses is returned

to the process cycle at the bucket elevator. Particulate too small to be removed by the baghouses

is discharged as emissions. From the blending and kiln feed storage silos, raw mix can be

pneumatically conveyed to one of the three kiln feed tanks or the kiln feed storage silo. Material

transport within the dry raw milling systems is accomplished by belt, screw conveyors, belt

conveyors, drag conveyors, bucket elevators, air slide conveyors, and pneumatic conveying


systems. The blending silos are vented to a single baghouse, the kiln feed storage silo is vented to

a single baghouse, and each kiln feed tank is controlled by a dedicated baghouse.

The material from the blend silos goes to the kiln feed tanks (Process Flow Diagrams B-5, B-6,

and B-7 of the Title V permit application). The material enters the back-end of the kiln for

pyroprocessing. The fuel enters the front-end of the kiln. The material flows countercurrent to

the fuel for more efficient heat transfer. The kilns are fired with coal, coke, tires, and other

approved alternate fuels.

Fuels and Solid Fuel Conveyance Systems

The kiln systems at this facility may use a variety of solid fuels to provide the heat necessary to

convert raw materials into cement clinker. A gas temperature of approximately 3,500ºF is

necessary to achieve the necessary material temperature. These fuels may include conventional

materials such as coal, petroleum coke, natural gas and whole tires. The use of NHSMs as

supplemental fuels such as tire-derived-fuel, plastics, wood, paper, rubber, carbon, and other

legitimate fuel type materials have been authorized by Permit No. 78-001-O (M-2) for use in Kiln

No. 3. This Title V authorizes the facility to utilize any equipment constructed for purposes of

fuels delivery, storage, and handling within the permitted emissions limits of that equipment. The

facility currently has a limit on the fuel feed stream percentage of coke fuel.

The most commonly used kiln fuels used at the facility are coal, petroleum coke, pipeline natural

gas, and tire-derived fuel (TDF). Currently, TDF is whole tires, injected at mid-kiln. These fuels

are brought in primarily by truck and stockpiled. The coal is loaded into a hopper by a front-end

loader. From there, it travels by belt conveyor to a coal crusher, which is an enclosed process.

From the crusher, the coal drops to another belt conveyor (enclosed). This belt transfers the coal

to the bunker. From the bunker, the coal is transferred to one of three weigh feeders (one for each

kiln). Coal from each feeder is pulverized by a coal mill and blown into the associated kiln via a

duct or pipe and a metal hose. The transfer points at the mill and the kiln are totally enclosed.

Only the coal conveying equipment between the coal mill blower discharge and the kiln is affected

by the Portland Cement MACT rule (40 CFR Part 63, Subpart LLL, a.k.a. NESHAP LLL). All

other coal storage, handling, and milling equipment are regulated under 40 CFR Part 60, Subpart

Y.

TDF consists of passenger-sized, individual whole tires. Tires are delivered to the tire feed bin by

trailer. The tires are dispensed from the trailer to a singulator. From the singulator, the tires are

conveyed to a point above the kiln. The tires are released from the final conveyor to fall through

an automatic gate in the kiln shell into the kiln where they are burned for fuel.

Cement Kiln System

Pyroprocessing transforms the raw mix into clinkers, which are gray, glass-hard, spherically

shaped nodules that typically range from 0.125 to 2.0 inches in diameter. There are five different

pyroprocesses used in the Portland cement industry (the wet process; the dry process, a.k.a. long

dry process; the semidry process; the dry process with a preheater; and the dry process with a

preheater/precalciner). The pyroprocessing system generally consists of the kiln through the


clinker cooler. They vary with respect to equipment design, method of operation, and fuel

consumption. Generally, fuel consumption decreases in the order of the processes listed. This

facility uses the long dry process. All of the pyroprocessing activity occurs in the rotary kiln. The

chemical reactions and physical processes that constitute the transformation are quite complex.

They are conveniently divided into the following four stages, as a function of location and

temperature of the materials in the rotary kiln.

1. Evaporation of uncombined water from raw materials, as material temperature increases to

212 °F;

2. Dehydration of combined water in the argillaceous (sedimentary rock that is made up of clay

or silt particles) components, as the material temperature increases from 212 °F to

approximately 800 °F to form oxides of silicon, aluminum, and iron;

3. Calcination of the calcium carbonate (CaCO3) to calcium oxide (CaO), during which carbon

dioxide (CO2) is evolved, between 1,650 °F and 1,800 °F, to form CaO; and

4. Reaction of the oxides in the burning zone of the rotary kiln, to form cement clinker at

temperatures of approximately 2,650 °F. This involves reaction of CaO with silica to form

dicalcium silicate, reaction of CaO with the aluminum and iron-bearing constituents to form

the liquid phase, evaporation of volatile constituents (e. g., sodium, potassium, chlorides,

and sulfates), and reaction of excess CaO with dicalcium silicate to form tricalcium silicate

and the formation of CaO, CaSO4 mixtures. During manufacture of CSA cement, the

temperature in in this step is approximately 250°F cooler.

Pyroprocessing is done at this facility in three kilns. The kilns are long, cylindrical, slightly

inclined furnaces that are lined with refractory to protect the steel shell and retain heat within the

kiln. Kilns No. 1 & 2 are 11 feet in diameter and 375 feet long, and Kiln No. 3 is 12 feet in

diameter and 400 feet long. As noted earlier, raw material mix enters the kilns at the elevated end

(feed entrance) and combustion fuels are introduced into the lower end of the kilns at the clinker

exit which results in a countercurrent flow of solid material and hot exhaust gases. As noted

earlier, a permit modification allows for the injection of whole tires at mid-kiln, in the calcining

zone. A curtain of chains suspended from the perimeter of the feed entrance in the drying/preheat

zone is used to improve heat transfer from the hot exhaust gases to the solid materials. The chains

are attached to the perimeter of the feed entrance such that as the kiln rotates the chains are raised

on the ascending side of the kiln causing them to hang across the feed entrance and are exposed to

the hot gases exiting past the raw material feed that is entering at the bottom edge of the kiln.

Further kiln rotation causes the hot chains on the descending side of the kiln to be lowered back

into the cooler materials at the bottom of the feed entrance, thereby transferring the heat to the

material load.

The materials are continuously and slowly moved to the lower end by rotation of the kiln and

gravitational force. As the materials move down the kiln, they are changed to cementitious or

hydraulic minerals as a result of the increasing temperature within the kiln. As detailed above,

any water in the raw mix is evaporated, and then the limestone is calcined, or broken down into

calcium oxide solid and carbon dioxide gas. The hot gasses from the kiln burner heat the raw mix

through three stages (evaporation/dehydration, calcination, clinker formation). The clinker is

discharged from the kiln into the clinker cooler where it is cooled by fan-forced air.


The exhaust gases exiting Kilns 1 and 2 pass through separate cyclones and separate baghouses

before discharging through a common stack. The exhaust gases from Kiln 3 pass through

dedicated cyclones and a baghouse before exiting through a different dedicated stack. Exhaust

gases from each kiln are cooled before they enter the baghouse. Cooling is accomplished by

admitting ambient air through dampers or by spraying water into the gas stream through a nozzle.

The cyclone/baghouse systems are designed to remove particulate matter (PM). The PM collected

by this equipment is returned to the kiln feed tanks via bucket elevators and screw conveyors and

is reused in the system as feed material or is removed from the system as cement kiln dust (CKD).

This also true for CSA cement production. Each stack is equipped with a particulate matter

continuous parametric monitoring system (PM-CPMS).

In manufacturing CSA cement, the preparation of clinker is achieved by burning the raw materials

in the kilns at temperatures lower than Portland cement. This can result in slightly higher levels

of HCl emissions than typical Portland cement. The DSI System reduces HCl to the NESHAP

LLL standards.

Clinker Cooler and Clinker Handling and Storage System

The last component of the pyroprocessing system is the clinker cooler. The material leaving the

kiln is called clinker and is in nodules. The clinker falls from the kiln into a clinker cooler. There

are three reciprocating grate clinker coolers that receive hot clinker from the three kilns. The

clinker leaves the kiln at a temperature of about 2,300o F. Each cooler is supplied with a number

of fans that force ambient air through the clinker to cool it. The air is passed through the bed of

clinker on the movable grate to cool the hot materials to approximately 300o F. This process step

recoups some of the heat input to the kiln system to be utilized for combustion air and for raw

material drying, locks in desirable product qualities by freezing mineralogy, and makes it possible

to handle the cooled clinker with conventional conveying equipment.

The hot gas is exhausted through an electrostatic precipitator at a temperature of about 400o F. A

“T” fitting with a butterfly damper is installed on top of the clinker cooler vent stack, to

accommodate the routing of gases from the cooler to either the atmosphere or to the raw mill

circuits via an insulated duct with a booster fan. This was the modification authorized under Permit

No. 98-170-C (M-2). Separate vent systems deliver the waste gas to each classifier of each raw

mill system. The location of the “T” fitting was selected to allow demonstration of compliance

with the 40 CFR Part 63, Subpart LLL standards for clinker cooler emissions prior to drawing the

gases to the raw mill systems. A particulate matter continuous parametric monitoring system (PM-

CPMS), and performance test ports are located upstream of the damper.

The clinker is moved through the cooler and transferred by drag chain and bucket elevator to the

clinker storage hall. The clinker storage hall is partially enclosed by one wall on its eastern side

and a roof. The northern and southern ends are open and the western side is bounded by a partial

wall that has formed over the years through buildup of hardened clinker around the steel structure

support beams. When absolutely necessary due to operational considerations, clinker may be

moved from inside the storage hall to an outside storage area located adjacent to the northwest

corner of the clinker storage hall. This outside storage area is bounded on its eastern side by the


partial (hardened clinker buildup) wall and on its northern and southern sides by berms that were

placed as protective barriers to wind erosion. The western side is open for loader access.

Part of the hot gases from the clinker cooler is utilized in the kiln as secondary combustion air.

The balance of the hot gases from all three coolers are combined and pass through an electrostatic

precipitator (ESP) for PM removal prior to release into the atmosphere through a common exhaust

stack. As discussed earlier for the raw mills, hot gas from the ESP stack can be diverted through

a duct to the raw mills where it can be used to aid in drying the raw materials.

Clinker from outside storage is transferred to inside storage by loader and truck. Clinker from

inside storage is reclaimed to clinker feed bins by an overhead crane. These bins discharge to the

finish mill feed conveyor belt to the finish grinding system. Emissions from the belt are controlled

by a baghouse.

Finish Mill System

The final step in Portland cement manufacturing involves a sequence of blending and grinding

operations that transforms clinker to finished Portland cement. There are three finish mill systems.

During finish milling, the intermediate product (clinker) is inter-ground with gypsum to produce

cement. Other specialty materials can be added as needed to impart specific product properties.

Gypsum is delivered primarily by truck and then stockpiled. The clinker and gypsum are metered

into the finish mill process according to predetermined proportions through the use of weigh

feeders located beneath the feed bins. There are three sets of bins and feeders, one for each finish

mill. The weigh feeders transport the proportioned cement constituents to the finish mill feed

belts, and then to bucket elevators, which feed the mills.

The finish mill systems are similar to the raw mill systems described above, except that each of

the three finish mill systems is slightly different from the others. The finish mills are utilized to

grind the clinker and gypsum into a fine powder, referred to as “cement.” Each of the finish mill

systems contains a bucket elevator, a classifier to separate the material according to fineness, a

ball mill, an induced draft fan, and an emissions stack. Mills 1 & 2 have a pre-cleaning cyclone

and two classifier cyclones. Mill 3 does not have a cyclone, but it has a second induced draft fan

and stack. Mills 1 & 3 each utilize two baghouse dust collectors. Mill 2 has only one baghouse

dust collector.

The clinker and gypsum enter the mill system via a belt conveyor that feeds the classifier. The

induced draft fan(s) pulls air through the mill system at a high enough velocity to entrain fine

particles of raw materials. These particles (or, cement) are removed from the air stream by the

classifier and directed by chute to the associated cement cooler(s). All of the particles of cement

removed from the air stream by the pre-cleaning cyclones of Mills 1 & 2 are conveyed to the

bucket elevator for return to the classifier. All of the particles of cement removed from the air

stream by the classifier cyclones and baghouse of Mills 1 & 2 are conveyed to the cement coolers.

There is a baghouse that controls emissions from material handling equipment associated with the

Mill 1 circuit. All of the particles of cement removed from the air stream by the baghouses of Mill

3 are conveyed to the bucket elevator and return to the classifier, or returned to the ball mill feed,

or pumped to the finish silos, or directed to the cement coolers. Finish Mill 1 has two cement


coolers; Mills 2 & 3 have one cement cooler each. All of the oversized particles of clinker and

gypsum leave the classifier and are directed through an air slide into the associated mill for

grinding and then back to the classifier. There is also a limestone bin and feeder that can add

outside clinker and/or limestone to the finish feed system.

Cement Handling System

The finished cement is pneumatically delivered from the cement coolers to the cement storage (or

finish) silos. The silos are vented through seven baghouses. The cement is transferred from the

silos to the packhouse, rail loadout stations, or to the truck loadout stations by a series of air slides

and bucket elevators. PM emissions from the loadout systems and associated transfer equipment

are abated by multiple baghouses. Cement is bagged or bulk stored for shipping to customers. It

can be shipped by truck or rail in bags or pneumatically loaded and shipped in bulk.

Cement Kiln Dust System

As stated previously, PM collected by the cyclone/baghouse controls on the kilns is returned to the

kiln feed tanks via bucket elevators and screw conveyors and is reused in the system as feed

material or is removed from the system as cement kiln dust (CKD). This also true for CSA cement

production. Each stack is equipped with a particulate matter continuous parametric monitoring

system (PM-CPMS). Some of the CKD collected is placed into a dust tank equipped with a dust

collector and is recycled into the finish mills. The alkali content of Portland cement is often limited

by product specifications because excessive alkali metals (i. e., sodium and potassium) can cause

deleterious reactions in concrete. Because these metals are contained in baghouse in the CKD, not

all of it is re-used in the pyroprocess or finish grinding process. Some of the baghouse dust is sold

and some also used on-site for mine reclamation.

The Cement Kiln Dust System was modified by Permit No. 98-170-C (M-4) to add Dust Tank #3,

to be used to route CKD to the Finish Mill System where it is used as a final blend at about 1% in

certain grades of cement manufactured at the facility. A side benefit was enhancement of the

“Blended Gypsum” system by adding the ability to add CKD to the gypsum before the blended

gypsum was mixed with the clinker. However, as noted below, the Blended Gypsum system has

been dismantled.

Some of this dust is used as feed and returned to the kiln feed pipe via a bucket elevator and a

series of screw conveyors. The CKD which is not recycled into the pyroprocessing system is

removed from the kiln system and conveyed to any one of three kiln dust tanks using pneumatic

conveyors, air slides, screw conveyors, and/or bucket elevators. From Dust Storage Tank #1, CKD

can be transferred to Blending Silo No.1, the CKD Addition System, truck loading, or Dust Storage

Tank #2. The CKD material from Dust Storage Tank # 2 can either be loaded into a truck for

offsite sales or disposal, or it can be blended with water in a pug mill for on-site disposal. Dust

Storage Tank #3 receives CKD from an incoming pipe that also feeds Tank #1 and Tank #2 by

pneumatic transfer. From Dust Storage Tank #3, CKD can be transferred to one of the three finish

mills where final product is blended and graded, using pressurized air to move CKD through a 3-

inch conveying line.


Pollutants and Controls

Particulate matter, nitrogen oxides (NOX), sulfur dioxide (SO2), carbon monoxide (CO), and

carbon dioxide (CO2) are the primary emissions in the manufacture of Portland cement. Small

quantities of volatile organic compounds (VOC), ammonia (NH3), chlorine, and hydrogen chloride

(HCl), also may be emitted. Emissions may also include residual materials from the fuel and raw

materials that may also include NHSMs or products of incomplete combustion that are considered

to be hazardous. Small quantities of additional hazardous organic pollutants may also be emitted

from the firing of these fuels. Also, raw material feeds and fuels typically contain trace amounts

of heavy metals that may be emitted as a particulate or vapor. Sources of PM at cement plants

include:

(1) quarrying and crushing;

(2) PM generated from hauling materials (road dust);

(3) raw material unloading and storage;

(4) grinding and blending (raw mills);

(5) clinker production (pyroprocessing) and storage piles;

(6) finish grinding (finish mills); and

(7) packaging and loading.

As noted earlier, quarrying activities are not the subject of this permit. The largest onsite emission

source of PM within cement plants is the pyroprocessing system that includes the kiln and clinker

cooler exhaust stacks. In the pyroprocessing units, PM emissions are controlled by fabric filters

and electrostatic precipitators (ESP). The DSI System reduces HCl to the NESHAP LLL

standards. The DSI system in use on the Pryor Plant kiln systems consists of a 3,800 cubic feet

storage silo with a bin vent and trifurcated hopper that feeds sorbent, either calcium hydroxide or

sodium bicarbonate, through three independent DSI feed trains with enclosed conveying lines

feeding each kiln exhaust prior to the baghouse. Collateral PM emissions in the form of unreacted

sorbent and products of reaction including CaCl2 and NaCl are captured by the baghouses serving

the kilns.

Additional sources of PM include material storage, handling and unloading facilities. Non-fugitive

PM is controlled by various dust collecting devices, partial enclosures and suppressant sprays. The

table illustrating emissions calculations in “SECTION IV, EMISSIONS”, specifies the control

device used to control emissions from each emissions unit listed in the tables.

Sulfur dioxide (SO2) may be generated both from the sulfur compounds in the raw materials and

from sulfur in the fuel. The sulfur content of both raw materials and fuels varies, depending on

the supply source. Cement kiln systems have highly alkaline internal environments that can absorb

up to 95 percent of potential SO2 emissions. However, in systems that have sulfide sulfur (pyrites)

in the kiln feed, the sulfur absorption rate may be as low as 70 percent without unique design

considerations or changes in raw materials. Calcium hydroxide (Ca(OH)2) is an effective

absorbent for reducing acid gases such as SO2. Cement kilns with fabric filter baghouses have

reported reductions in SO2. Cement kiln dust, rich in CaO, Ca(OH)2 and CaCO3, coats the fabric

filter and acts as an effective absorbent. It has been observed that as much as 50 percent of the

SO2 can be removed from the pyroprocessing system exhaust gases when this gas stream is used


in a raw mill for heat recovery and drying. In this case, moisture and calcium carbonate (CaCO3)

are simultaneously present for sufficient time to accomplish the chemical reaction with SO2.

The injection of Ca(OH)2 into the gas stream entering the fabric filter baghouse has also been

found as an effective way to reduce acid gases such as SO2 and HCl. As noted earlier, the

pyroprocessing system generally consists of the kiln through the clinker cooler. Routing of kiln

exhaust gases through the raw mill(s) is not done at Buzzi, although clinker cooler gas is, but that

alone has not been sufficient to reduce HCl emissions to the new standard. The new DSI System

utilizes injection of a sorbent material such as calcium hydroxide or sodium bicarbonate to control

HCl. Buzzi has observed collateral reduction of SO2 in the range of 70% to 95%.

Oxides of nitrogen are generated during fuel combustion by oxidation of chemically-bound

nitrogen in the fuel (fuel NOX) and by thermal fixation of nitrogen in the combustion air (thermal

NOX). In a correspondence to DEQ Compliance dated March 31, 2006, the applicant also

referenced feed NOX, which is formed from nitrogen contained in the feed stock (raw materials).

As flame temperature increases, thermal NOX increases. Fuel NOX increases with the quantity of

nitrogen in the fuel. NOX is generated in the burning zone of the kiln. In recent years a number

of plants have switched to systems that burn a combination of coal and NHSM fuel. The effect of

NHSM fuel use on NOX emissions is not clearly established. However on long dry kilns, mid-kiln

injection of fuel such as TDF has been shown to reduce NOX by 20%-40%. SECTION III,

EQUIPMENT DESCRIPTION, of this memorandum has a summary of the fuels types utilized.

Mid kiln injection of TDF was authorized for this facility under Permit No. 98-170-C (M-1). A

reduction in NOX was verified by stack testing but there have been no other permit actions in which

to apply credit for that reduction. At this time there are no add-on NOX controls or permit

conditions restricting nitrogen-containing fuels or materials.

As with most high-temperature, energy-intensive industrial processes, combusting fuels to

generate process energy releases substantial quantities of CO2. Substantial quantities of CO2 also

are generated through calcining of limestone or other calcareous material. Fuel combustion at

Portland cement plants can emit a wide range of other pollutants in smaller quantities. If the

combustion reactions do not reach completion, CO and volatile organic pollutants, typically

measured as total organic compounds (TOC), VOC, or organic condensable particulate, can be

emitted. Incomplete combustion also can lead to emissions of specific hazardous organic air

pollutants, although these pollutants are generally emitted at substantially lower levels than CO or

TOC. Most organic pollutants are minimized by the high temperatures achieved during

pyroprocessing, so these pollutants wouldn’t be a concern except during some type of short term

malfunction.

Emissions of metal compounds from Portland cement kilns can be grouped into three general

classes:

(1) volatile metals, including mercury (Hg) and thallium (Tl);

(2) semi-volatile metals, including cadmium (Cd), lead (Pb), selenium (Se), zinc (Zn),

potassium (K), and sodium (Na); and

(3) refractory or nonvolatile metals, including antimony (Sb), barium (Ba), chromium (Cr),

arsenic (As), nickel (Ni), vanadium (V), manganese (Mn), copper (Cu), and silver (Ag).


Although the partitioning of these metal groups is affected by kiln operating conditions, the

refractory metals tend to concentrate in the clinker, while the volatile and semi-volatile metals tend

to be discharged through the primary exhaust stack and the bypass stack, respectively.

Fugitive Emissions

Process fugitive emission sources include materials handling and transfer, raw milling operations

in dry process facilities, and finish milling operations. Non-process fugitive dust sources include

raw materials storage piles and clinker storage piles. The measures used to control emissions from

these fugitive dust sources are comparable to those used throughout the mineral products

industries. Vehicle traffic controls include only road wetting. No controls are used on open storage

piles.

SECTION III. EQUIPMENT DESCRIPTION

Emission units (EUs) have been arranged into Emission Unit Groups (EUGs) in the application.

These EUGs were modified and condensed, as illustrated in this section. Equipment having no

emissions, such as tire-derived fuel handling, are not listed since they are technically not emissions

units. There are several fuel-burning operating scenarios for the kilns, including NHSMs as fuels,

as outlined below. Specific NHSM fuels and limitations are contained in the permit.

Kilns No. 1 and 2:

1. Firing with coal.

2. Firing with natural gas

3. Firing with coal and/or natural gas and any combination of the following:

a. Fuel oil

b. Petroleum coke (up to 80% coke/coal blend)

c. Tire derived fuel

Kiln No. 3:

1. Firing with coal and/or natural gas.

2. Firing with coal and/or natural gas and any combination of the following:

a. Petroleum coke (up to 80% coke/coal blend)

b. Tire derived fuel

c. Non-hazardous secondary materials that are fuels and not solid wastes as described

in 40 CFR Part 241, Subpart B—Identification of Non-Hazardous Secondary

Materials That Are Solid Wastes When Used as Fuels or Ingredients in Combustion

Units. Per 40 CFR 241, secondary materials are any material that is not the primary

product of a manufacturing or commercial process, and can include post-consumer

material, off-specification commercial chemical products or manufacturing

chemical intermediates, post-industrial material, and scrap.

The facility can be fired with a mixture of the different types of fuel. Emission factors were

collected during 2002, 2003 and 2006. Emission samples were collected from the Kiln 1/2 and

Kiln 3 stacks during the use of coal/coke fuel mixture, both with and without the addition of TDF.


The resulting emission factors were used to evaluate the potential emissions in the permit

memorandum “Section IV Emissions” section. To remain consistent with limits proposed in

permit No. 98-170-TV (M-1), it was assumed TDF replaced 30% of all three kilns heat input needs

in order to develop the emission factors.

EUG 1a consists of the cement kilns and the new DSI System. Kilns No. 1 and 2 are grandfathered

from permit emissions limits except for CO and Subchapter 19, but still have enforceable standards

through NESHAP Subpart LLL. The “Actual” values in the following tables are production

numbers from the year 2008.

EUG 1a –Kilns and DSI System Silo

Size/Capacity

EU ID/ Manufacturer Construct

Date

Length

(FT)

Dia.

(FT)

Max.

Clinker

(TPH)

Actual

Clinker

(TPY)

Kiln No. 1/ (E-67, P-42) 1960 375-foot 11 – 12.5-foot 25 207,892

Kiln No. 2/ (E-75, P-42) 1961 375-foot 11-foot 25 200,106

Kiln No. 3/ (E-99, P-58) 7/1/1980 400-foot 12-13.5-foot 40 301,357

DSI System

Construct

Date

Height

(FT)

Storage Silo

Diameter

(FT)

Max. Fill

Rate

(TPH)

Annual

Fill Rate

(TPY)

DSI System Storage Silo

(E-272, P-42, P-58)) December 2016 47 12 24 8,760

EUG 1b consists of clinker coolers. Coolers No. 1 and 2 are grandfathered from permit emissions

limits, but still have enforceable standards through NESHAP Subpart LLL and Subchapter 19.

EUG 1b –Clinker Coolers

Size/Capacity

EU ID/ Manufacturer Construct

Date

Ht.

(FT)

Dia.

(FT)

Max.

(TPH)

Actual

(TPY)

Clinker Cooler No. 1 (E-68, P-43)/ 1960 90 9.0 25 207,892

Clinker Cooler No. 2 (E-76, P-43)/ 1961 90 9.0 25 200,106

Clinker Cooler No. 3 (E-100, P-43)/ 7/1/1980 90 9.0 40 301,357

EUG 1c consists of affected sources other than kilns; clinker coolers; new and reconstructed raw

material dryers subject to NESHAP Subpart LLL and Subchapter 19. Equipment grandfathered

from permit emissions limits will have enforceable standards through NESHAP Subpart LLL,

which applies to each new and existing Portland cement plant that is a major source or an area

source as defined in §63.2. Any equipment of the on-site nonmetallic mineral processing plant,

subject to 40 CFR Part 60 Subpart OOO, is not subject to this subpart per 40 CFR §63.1340(c). In

addition, the primary and secondary crushers of the on-site nonmetallic mineral processing plant

are not subject to this subpart.


EUG 1c – NESHAP Subpart LLL

Affected Sources Other Than Kilns; Clinker Coolers; New and Reconstructed Raw

Material Dryers

Size/Capacity

EQUIPMENT/EU/EP Construct

Date

Ht.

(FT)

Dia.

(FT)

Max.

(TPH)

Actual

(TPY)

Raw Mill No.1

Raw Material Hopper 101 / E-270 / P-254 2009 20 12

20 175,200






Raw Mill Material Bins/ E-34/ P-60 Pre 1974 NA NA 250 623,185

Raw Material Weigh Feeders/ E-35/ P-26 Pre 1974 90 3 126 623,185

Mill Feed Conveyor Belt/ E-36/ P-26 Pre 1974 90 3 207 623,185

Bucket Elevator/ E-37/ P-26 Pre 1974 90 3 600 623,185

Classifier/E-38/ P-26 Pre 1974 90 3 110 623,185

Raw Mill Pump/ E-40/ P-26 1961 90 3 110 623,185

#1 Raw Mill / E-41/ P-108 Pre 1974 90 3 110 623,185

19-inch Airslide/ E-42/ P-26 Pre 1974 90 3 480 NA

Raw Mill No. 2

Raw Mill Material Bins/ E-34/ P-60 Pre 1974 NA NA 250 572,800

Raw Material Weigh Feeders/ E-44/ P-28 7/1/1980 57 1.8 332 572,800

Mill Feed Conveyor Belt/ E-45/ P-28 7/1/1980 57 1.8 413 572,800

Bucket Elevator/ E-46/ P-28 7/1/1980 57 1.8 600 572,800

Classifier/E-47/ P-29 7/1/1980 100 4.5 95 572,800

Raw Mill Pump/ E-49/ P-29 7/1/1980 100 4.5 110 572,800

#2 Raw Mill / E-50/ P-109 7/1/1980 100 4.5 95 572,800

24-inch Airslide/ E-51/ P-28 7/1/1980 57/100 1.8/4.5 600 NA

Kiln Feed/Blending

14-inch Airslide/ E-54/ P-30 7/1/1980 75 2.9 240 NA

Blend Pumps (3)/ E-55/ P-30 1979 75 2.9 411 NA

Kiln Feed Storage Silo/ E-56/ P-31 7/1/1980 203 1.1 45 741,258

3 - Blending Silos/ E-52/ P-30 Pre 1974 75 2.9 300 1,188,416


Coal Handling

Coal Mill to Kiln 1-a/ E-95a/ P-42 1960 NA NA 6 27,515

Coal Mill to Kiln 1-b/ E-95b/ P-42 1960 NA NA 6 27,515

Coal Mill to Kiln 2-a/ E-95c/ P-42 1961 NA NA 6 28,235

Coal Mill to Kiln 2-b/ E-95d/ P-42 1961 NA NA 6 28,235

Coal Mill to Kiln 3-a/ E-95e/ P-58 1980 NA NA 6 44,465

Coal Mill to Kiln 3-b/ E-95f/ P-58 1980 NA NA 6 44,465

Kiln No. 1 Support Equipment

Kiln Feed Tank/ E-66/ P-41 Pre 1974 55 1.5 48 375,542

Feed Tank Bucket Elevator (Kiln 1)/ E-71/ P-41 Pre 1974 55 1.5 60 NA

Drag Chain Conveyor (clinker), 12-inch/ E-69/ P-43 Pre 1974 90 9.0 25 207,892

Clinker Bucket Elevator (clinker)/ E-70/ P-60 Pre 1974 NA NA 60 NA


Kiln Feed Tank/ E-74/ P-46 Pre 1974 42 1.5 48 335,627




Material Dryers

Size/Capacity


Date

Ht.

(FT)

Dia.

(FT)

Max.

(TPH)

Actual

(TPY)

Feed Tank Bucket Elevator (Kiln 2)/ E-81/ P-42 Pre 1974 NA NA 56 NA

Drag Chain Conveyor, 12-inch (clinker)/ E-77/ P-43 Pre 1974 90 9.0 25 200,106

Clinker Bucket Elevator (clinker)/ E-78/ P-60 Pre 1974 NA NA 60 NA


Kiln Feed Tank, 22-inch dia./ E-96/ P-57 7/1/1980 138 1.8 65 437,369

2 – Airslides, 12-inch/ E-97/ P-57 4/1/1987 138 1.8 200 NA

Feed Hopper for 031-3150 & 031-3694/ E-98/ P-57 7/1/1980 138 1.8 200 NA

Cyclone Dust Bucket Elevator (Kiln 3)/ E-105/ P-57 10/1/1984 138 1.8 100 NA


Drag Chain Conveyor (clinker), 12-inch/ E-101/ P-43 7/1/1980 90 9.0 40 301,357

Clinker Bucket Elevator/ E-102/ P-60 7/1/1980 NA NA 50 301,357

Kiln Dust Reclaim System

Baghouse Dust Pump (Kiln 3)/ E-106, P-58 1980 102 7.0 25 NA

#16 Screw Conveyor, 16-inch/ E-79/ P-42 6/23/1975 150 13.5 14 NA

#17 Screw Conveyor, 16-inch/ E-80/ P-48 4/1/1990 41 1.4 38 NA

Dust Tank Bucket Elevator/ E-82/ P-48 Pre 1974 41 1.4 100 NA

Kiln Dust Storage Tank #1, 14-foot dia./ E-83/ P-48 Pre 1974 41 1.4 30 33,602

12-inch Airslide/ E-84/ P-48 Pre 1974 41 1.4 200 NA

Kiln Dust Pump/ E-86/ P-48 1961 41 1.4 65 NA

FK Pump (Replaced Kiln Dust Conveying Pods in 2004)/ E-87/

P-48

4/1/1990

41 1.4 50

NA

Kiln Dust Storage Tank #2, 30-foot dia./ E-88/ P-51 Pre 1974 80 0.9 30 134,409


Kiln Dust Storage Tank#3 with Transport Vessel / E-209 / P-209 2007 40 12 8 0

CKD Truck Loadout/ E-90/ P-51 4/1/1990 80 0.9 150 NA

Finish Mill No. 1

3 - Clinker/Gypsum Bins/ E-108/ P-60 Pre 1974 NA NA 88 NA

3 - Weigh Feeders/ E-109/ P-66 Pre-1974 87 2.1 88 NA

Mill Feed Conveyor Belt/ E-110/ P-66 Pre-1974 87 2.1 110 NA

#1 Finish Mill, KVS/ E-111/ P-64 Pre-1974 90 2.9 35 212,357

19-inch Airslide/ E-111a/ P-64 Pre-1974 90 2.9 300 NA

Bucket Elevator/ E-113/ P-63 Pre-1974 87 2.1 350 NA

16-foot Classifier, Sturtevant/ E-114/ P-66 Pre-1974 82 2.5 350 212,357

Tailings Airslide/ E-114a/ P-66 12/1/1994 82 2.5 300 NA

Cement Coolers #1 and #2/ E-115/ P-63 Pre-1974 87 2.1 35 NA

12-inch Airslide/ E-116/ P-63 Pre-1974 87 2.1 200 NA

Finish Mill Pump/ E-117/ P-63 Pre-1974 87 2.1 35 212,357


Finish Mill No. 2

Overhead Crane, E-33/ P-60 (Used for Clinker and Finish Mills) Pre 1974 NA NA NA NA

5 (3 in Use) - Clinker/Limestone/Gypsum Bins/

E-119/ P-60

Pre-1974 NA NA 135 NA

Weigh Feeders/ E-120/ P-67 Pre-1974 88 2.5 135 NA

Mill Feed Conveyor Belt/ E-121/ P-67 Pre-1974 88 2.5 110 185,180

#2 Finish Mill, KVS/ E-122/ P-67 Pre-1974 88 2.5 35 185,180




Material Dryers

Size/Capacity


Date

Ht.

(FT)

Dia.

(FT)

Max.

(TPH)

Actual

(TPY)


Bucket Elevator/ E-125/ P-67 Pre-1974 88 2.5 350 NA

16-foot Classifier, Sturtevant/ E-126/ P-67 Pre-1974 88 2.5 350 185,180

Cement Cooler/ E-126b/ P-67 Pre-1974 88 2.5 35 NA

Finish Mill Pump/ E-128/ P-67 1960 88 2.5 35 185,180

Finish Mill #2 additives hopper and feeder / E-259 / P-262 2009 3 3 0.2 14


Finish Mill #2 additives feeder to feed conveyor / E-260 / P-262 2009 3 3 0.2 14


Finish Mill No. 3

3 - Clinker/Limestone/Gypsum Bins/ E-129/ P-60 Pre 1974 NA NA 165 NA

Weigh Feeders/ E-130/ P-70 6/23/1975 89 5.0 165 NA

Mill Feed Conveyor Belt/ E-131/ P-70 6/23/1975 89 5.0 190 NA

#3 Finish Mill/ E-132/ P-69 6/23/1975 89 5.0 55 368,140

19-inch Airslide/ E-132a/ P-270 6/23/1975 89 5.0 480 NA

Bucket Elevator/ E-133/ P-70 6/23/1975 89 5.0 500 NA


Classifier, , 18-foot/ E-135/ P-70 6/23/1975 90 3.0 500 368,140

Tailings Airslide/ E-135a/ P-69 6/23/1975 89 5.0 450 NA

Cement Cooler/ E-135b/ P-70 12/1/1994 89 5.0 55 NA


Finish Mill Pump, 125-hp, 8H F-K/ E-137/ P-70 1974 90 3.0 55 368,140





Finish Silos - Group 1

8 - Cement Storage Silos/ E-138/ P-71/72/73 Pre-1974 133 1.2 125 151,586

Fringe Bin Pump/ E-139/ P-74 Pre-1974 20 0.33 10 NA




Truck Loading Bucket Elevator/ E-143/ P-76 Pre-1974 20 0.9 150 NA

Loadout Spout/ E-144/ P-76 Pre-1974 20 0.9 540 NA

Rail Loading Bucket Elevator/ E-145/ P-77 Pre-1974 20 0.9 150 NA

NW Truck & Rail Loadout/ E-146/ P-78 Pre-1974 NA NA 75 NA

Silo/Packhouse Bucket Elevator/ E-147/ P-75 Pre-1974 20 0.9 150 NA

Recirculating Pump/ E-149/ P-271 1960 20 0.9 80 NA

Finish Silos – Group 2

11 - Cement Storage Silos/ E-150/ P-80/P-81 Pre-1974 133 1.2 125 288,851




Truck Loading Bucket Elevator/ E-154/ P-83 Pre-1974 37 1.1 200 NA

Loadout Spout/ E-155/ P-83 Pre-1974 37 1.1 540 NA




Material Dryers

Size/Capacity


Date

Ht.

(FT)

Dia.

(FT)

Max.

(TPH)

Actual

(TPY)

Rail Loading Bucket Elevator/ E-156/ P-84 Pre-1974 37 1.1 200 NA

East Rail Loadout Spout/ E-157/ P-85 2012 1 0.9 180 NA

East Rail Aux Bucket Elevator/ E-158/ P-82 Pre-1974 20 0.9 200 NA

Finish Silos – Group 3

Cement Storage Silo 15/ E-160a/ P-87a 7/1/1980 239 1.2 85 312,614

Cement Storage Silo 16/E160b/P-87b 7/1/1980 239 1.2

Loadout Spout/ E-161/ P-88 7/1/1980 37 1.4 540 NA


Loadout Spout/ E-163/ P-89 7/1/1980 37 1.4 540 156,307

Packhouse

Packer Bins A and B/ E-164/ P-90 Pre-1974 60 1.4 105 10,095

Portland Packer Bucket Elevator/ E-165/ P-90 Pre-1974 60 1.4 100 10,095

Portland Packer/ E-166/ P-90 Pre-1974 60 1.4 68 10,095

10-inch Airslide/ E-167/ P-90 Pre-1974 60 1.4 105 10,095

Packer Bins C and D/ E-168/ P-91 Pre-1974 60 1.4 105 19,960

Masonry Packer Bucket Elevator/ E-169/ P-91 Pre-1974 60 1.4 100 19,960

Masonry Packer/ E-170/ P-91 Pre-1974 60 1.4 68 19,960

10-inch Airslide/ E-171/ P-91 Pre-1974 60 1.4 105 19,960

Packhouse Fringe Bin/ E-172/ P-90/P-91 Pre-1974 NA NA 5 NA

Bag Palletizer/ E-174/ P-94** 1988 NA NA 48 NA

Chain Conveyors (Bag Drop)/ E-173/ P-93 Pre-1974 NA NA 24 NA

EUG 1d consists of existing raw material dryers subject to NESHAP Subpart LLL.

EUG 1d - Existing Raw Material Dryers

EQUIPMENT/EU/EP

Construct

Date

Heat Input Rating

(MMBTUH)

Controls

(% Efficiency)

Raw Mills

Hot Air Furnace/ E-39/ P-26 1961 20 Classifier cyclone (99)

Hot Air Furnace/ E-48/ P-29 7/1/1980 30 Classifier cyclone (99)

EUG 1e consists of open clinker storage piles subject to NESHAP Subpart LLL.

EUG 1e – Open Clinker Storage Piles Size/Capacity


Date

Ht.

(FT)

Dia.

(FT)

Max.

(TPH)

Actual

(TPY)


Clinker Storage Hall/ E-103/ P-60 1960 NA NA 225 NA

Clinker Storage Pile – Outside/ E-104/ P-61 NA NA NA 3 NA


EUG 2 consists of emissions units subject to 40 CFR Part 60, Subpart OOO (Nonmetallic Mineral

Processing Plants) that are not subject to NESHAP Subpart LLL. This subpart applies to crushers,

grinding mills, screening operations, bucket elevators, belt conveyors, bagging operations, storage

bins, and enclosed truck or rail car loading stations constructed, reconstructed, or modified at

nonmetallic mineral processing plants after August 31, 1983. The table below lists all of the

process components for this EUG 2. Most of the nonmetallic mineral processing equipment

constructed at the facility predates this rule and is included in a separate group below as “EUG 3

– OAC 252:100-25 Non-Metallic Mineral Processing Equipment.”

EUG 2 – Subpart OOO Non-Metallic Mineral Processing

Size/Capacity


Date Ht.

(FT)

Dia.

(FT)

Max.

(TPH)

Actual

(TPY)

#5 Storage Hall Tripper Conveyor Belt, 36-inch/ E-28/ P-

12a

10/1/84 NA NA 252 NA

Belt Conveyor BC1, 36-inch, Hopper Gathering / E-257 /

P-260

2009 5 3 160 92,305

Belt Conveyor BC2, 36-inch, Additive Transfer / E-258 /

P-261

2009 5 3 160 92,305

EUG 3 consists of emissions units that predate Subpart OOO, and are subject to OAC 252:100-25

and units that are not subject to Subpart OOO, but are subject to OAC 252:100-25. The table

below lists all of the process components for this EUG.

EUG 3 – OAC 252:100-25 Non-Metallic Mineral Processing Equipment

Size/Capacity


Date

Ht.

(FT)

Dia.

(FT)

Max.

(TPH)

Actual

(TPY)

Load Hopper to Wobbler Feeder (E-5, P-6) 4/24/1986 10 2 600 1,249,135

Wobbler Feeder (E-6, P-6) * 4/24/1986 10 2 600 1,249,135

Wobbler Fines Belt Conveyor (E-7, P-6) * 4/24/1986 10 2 1,000 1,249,135

Primary Crusher, 6185/ (E-8, P-6) 7/1/1980 10 2 600 1,249,135

#1 Primary Belt Conveyor, 36-inch/ (E-9, P-7) 7/1/1980 75 1.8 1,000 1,249,135

Primary Vibrating Screen (E-10, P-7) 7/1/1980 75 1.8 1,000 1,249,135

#2 Primary Belt Conveyor, 30-inch/ (E-11, P-7) 7/1/1980 23 1.8 750 NA

Load Hopper (E-12, P-9) Pre 1974 NA NA 300 NA

Wobbler Feeder (E-13, P-8) Pre 1974 23 1.8 300 NA

Secondary Crusher, 05NC/ (E-15, P-8) Pre-1974 23 1.8 300 627,722

#1 Secondary Belt Conveyor, 30-inch (E-16, P-8) Pre-1974 35 2.3 650 627,722

#2 Secondary Belt Conveyor, 24-inch (E-17, P-8) Pre-1974 23 1.8 360 NA

Secondary Vibrating Screen (E-18, P-10) Pre-1974 35 2.3 650 627,722

#3 Primary Belt Conveyor, 30-inch (E-19, P-11a) 7/1/1980 40 1.1 765 NA

#3 Secondary Belt Conveyor, 36-inch/ (E-20, P-11a) Pre-1974 40 1.1 550 NA

#4 Crossover Belt Conveyor, 36-inch/ (E-21, P-11b) 9/1/1981 40 1.1 1,000 1,249,135

A-Frame Storage E-27a/P-18 NA NA NA 251 1,249,135

#5 A-Frame Tripper Belt Conveyor, 30-inch/ E-27/ P-12b 7/1/1980 NA NA 251 1,249,135

6 - Belt Conveyors (3 Working)/ E-30/ P-21 7/1/1980 8 1.4 750 NA

#1 Reclaim Belt Conveyor, 30-foot/ E-31/ P-22 7/1/1980 NA NA 567 NA

#2 Reclaim Belt Conveyor, 30-foot/ E-32/ P-23 7/1/1980 NA NA 652 NA


EUG 3 – OAC 252:100-25 Non-Metallic Mineral Processing Equipment

Size/Capacity


Date

Ht.

(FT)

Dia.

(FT)

Max.

(TPH)

Actual

(TPY)

#3 Reclaim Belt Conveyor, 30-foot/ E-32a/ P-25 7/1/1980 NA NA 652 NA

* Exempt from the provisions of §§ 60.672, 60.674, and 60.675.

EUG 4 consists of coal processing and conveying equipment, breakers/crushers, coal storage

systems, and coal transfer and loading systems subject to 40 CFR Part 60, Subpart Y, Standards

of Performance for Coal Preparation Plants. All equipment was constructed after October 24,

1974, and is therefore subject to the requirements of this subpart.

EUG 4 - Subpart Y Coal Handling

Size/Capacity


Date

Ht.

(FT)

Dia.

(FT)

Max.

(TPH)

Actual

(TPY)

Coal Belt Conveyor #1/ E-60/ P-35 8/1/1977 NA NA 277 100,215

Coal Crusher/ E-61/ P-36 8/1/1977 21 0.9 27 236,520

Coal Belt Conveyor #2, 24-inch/ E-62/ P-37 8/1/1977 NA NA 27 236,520

Coal Bunker/ E-63/ P-38 8/1/1977 78 1.1 16 100,215

Coal Weigh Feeder/ E-64/ P-39 8/1/1977 NA NA 9 27,515

Coal Weigh Feeder, 24-inch/ E-72/ P-45 8/1/1977 NA NA 9 28,235

Coal Weigh Feeder, 24-inch/ E-94/ P-55 7/1/1980 NA NA 9 44,465

Coal Load Hopper/ E-59/ P-34 8/1/1977 NA NA 277 100,215

Coal Mill, E-65/ P-42 8/1/1977 150 13.5 6 27,515

Coal Mill, E-73/ P-42 8/1/1977 150 13.5 6 28,235

Coal Mill, E-95/ P-58 8/1/1980 102 7.0 6 44,465

EUG 5 consists of fugitive emissions from emissions sources not currently having a federal

standard.

EUG 5 – Fugitive PM Sources Size/Capacity


Date

Ht.

(FT)

Dia.

(FT)

Max.

(TPH)

Actual

(TPY)

Facility-Wide Various NA NA NA NA

Non-Metallic Mineral Processing Equipment

Load Hopper (E-5, P-5) 7/1/1980 10 2 600 1,249,135

Raw Material Storage

Gypsum Unloading (Belly Dumping)/ E-22/ P-13 NA NA NA 50 NA

Gypsum Pile/ E-23/ P-14 NA NA NA 35 35,000

Iron Source Pile/ E-24/ P-15 NA NA NA 30 9,400

Silica-Alumina Pile/ E-25/ P-16 NA NA NA 100 75,000

Gypsum, Iron Ore Unloading – (hoppers 101 through 106)/

E-26/ P-17

NA NA NA 340 92,305

Rock Reclaim - Onsite Acquired Raw Material

Limestone Outside Storage/ E-29/ P-20 NA NA NA 126 NA


CKD Storage Pile/ E-93/ P-54 NA NA NA 75 20,000


EUG 5 – Fugitive PM Sources Size/Capacity


Date

Ht.

(FT)

Dia.

(FT)

Max.

(TPH)

Actual

(TPY)

Miscellaneous Sources

Raw Material Storage Pile/ E-200/ P-200 NA NA NA NA NA

Plastics Storage Pile E-201/P-201 NA NA NA NA NA

Alternate Fuel Storage Area E-202/P-202 NA NA NA NA NA

Coal Handling

Coal Pile/E-57/P-32 NA NA NA 27 118,000

Haul Roads

CKD Haul Road E-92/P-53 NA NA NA NA NA

Coal Haul Roads E-58/P-33 NA NA NA NA NA

Limestone/Shale Haul Trucks/Roads E-4/P-4 NA NA NA NA NA

SECTION IV. EMISSIONS

Potential to emit (PTE) emissions are presented in the following tables for each EUG. Emission

limits, based partly on these calculations but also on existing permits and calculation methodology,

are discussed in a following subsection. Combustion pollutants generated by the kilns are based

partly on stack tests and partly on emissions factors obtained from AP-42, Section 11.6, Table

11.6-8 (rev. 1/95) at the estimated maximum clinker production rates. Emissions may vary,

depending on the fuel used. AP-42 does not account for variations in fuel type. The kilns are

currently permitted to burn a variety of hydrocarbon fuels and supplemental NHSM fuels that are

not wastes. The footnotes to the table provide further explanation concerning the use of TDF

during stack tests. Process PM emissions were calculated using various methods. The appropriate

reference for the emissions factor and calculation methodology for each source is footnoted.

Some emissions calculations in this section are for informational purposes only, not to demonstrate

compliance with applicable standards or existing permit limits. Emissions limits in the permit

specific conditions are taken from applicable state and federal standards, and from existing

permits. For those emissions units not subject to a standard or existing permit limit at the time

Permit No. 98-170-TV was issued, limits were assigned in that permit, except for emissions units

that were grandfathered and retained that status. The discussion for development of permit limits

was retained from the memorandum and can be found in the following section.

EUG 1a –Kilns (Estimated PTE in ton/yr)

Pollutant Emissions Factor

Kilns 1, 2 / Kiln 3

(lbs/ton clinker)

Kiln No. 1

@ 25 TPH (1)

Kiln No. 2

@ 25 TPH (1)

Kiln No. 3

@ 40 TPH

Total

PTE

TPY

NOX (2) 13.179 / 4.028 1443.1 1443.1 705.7 3,591.9

SO2 (2) 4.681 / 4.316 512.5 512.5 756.2 1,781.2

PM 0.098 / 0.029 53.7 (4) 53.7 (4) 86.3 (4) 193.7

CO (2) 3.654 / 3.340 400.1 400.1 585.1 1,385.3

VOC (2) 1.879 / 0.827 205.7 205.7 144.9 556.3

HCl (3) 0.14 15.33 15.33 24.53 55.19


EUG 1a –Kilns (Estimated PTE in ton/yr)

Pollutant Emissions Factor

Kilns 1, 2 / Kiln 3

(lbs/ton clinker)

Kiln No. 1

@ 25 TPH (1)

Kiln No. 2

@ 25 TPH (1)

Kiln No. 3

@ 40 TPH

Total

PTE

TPY

H2SO4 (3) 0.0072 (SO4) 0.79 0.79 1.26 2.84

D/F (3) 5.67 E-9 6.2 E-7 6.2 E-7 9.9 E-7 2.2 E-6

(1) Kilns No. 1 and 2 share a common stack.

(2) The most conservatively high emission factor data obtained from stack testing was used. For Kilns 1/2 NOX and

VOC emissions, this was for the condition of not using TDF. For Kilns 1/2 SO2 and CO emissions, this was for the

condition of using TDF. For Kiln 3 SO2, NOX, and VOC emissions, this was for the condition of not using TDF. For

Kiln 3 CO emissions, this was for the condition of using TDF. (3) Emission factor from AP-42 Table 11.6-9 kiln with fabric filter.

(4) Permit limits.

Basis for PM10 Emissions

The PM emissions factor is based on stack test data when using TDF in Kilns No. 1 and 2. This

yields the most conservatively high PM potential emissions estimate for those kilns. Actual

operations include periods of not using TDF, therefore actual PM emissions during those times

will be less. The PM10 emissions factor was calculated from the stack test PM emissions factor

assuming PM10 is 85% of PM per AP-42 Table 11.6-5 for Dry Kiln with fabric filter control.

(0.098 lb-PM/ton-kiln-feed with TDF * 0.85 PM10/PM ratio = 0.083 lb PM10 / ton clinker) For

Kiln No. 3, the PM emissions factor is based on stack test data when not using TDF. This yields

the most conservatively high PM potential emissions estimate for Kiln No. 3. Actual operations

include periods of using TDF, therefore actual PM emissions during these times will be less. The

PM10 emissions factor was calculated from the stack test PM emissions factor assuming PM10 is

85% of PM per AP-42 Table 11.6-5 for Dry Kiln with fabric filter control. (0.029 lb-PM/ton-kiln-

feed with TDF * 0.85 PM10/PM ratio = 0.025 lb PM10/ton clinker)

The DSI system has one emissions point consisting of a small bin vent (non-ventilated, 1,304

ACFM capacity, manufacturer specified emission rate of <0.003 gr/acf) located on the sorbent

storage tank. Emissions of particulate matter from the bin vent occur during unloading the sorbent

to the bin. However, a conservatively high assumption of 8,760 hours was used to calculate

emissions of 0.15 TPY-PM.

EUG 1a – Kilns and DSI System Silo

EMISSION

SOURCE/EU/EP

Max

Hourly Clinker

(ton/hr)

Emission

Factor (1)

(lbs PM10 /ton

clinker)

PTE

Controlled

(ton PM10 /yr)

PTE

Controlled

(ton PM/yr) (3)

Kiln No. 1 (E-67, P-42) 25 0.083 9.1 (2) 54

Kiln No. 2 (E-75, P-42) 25 0.083 9.1 (2) 54

Kiln No. 3 (E-99, P-58) 40 0.025 4.4 86

Max

Annual Sorbent

(ton/yr)

DSI System Silo (E-272,

P-42/P-58) (4) 24 0.003 (5) 0.15 0.15


EUG 1a – Kilns and DSI System Silo

EMISSION

SOURCE/EU/EP

Max

Hourly Clinker

(ton/hr)

Emission

Factor (1)

(lbs PM10 /ton

clinker)

PTE

Controlled

(ton PM10 /yr)

PTE

Controlled

(ton PM/yr) (3)

Totals 22.75 194.15 (1) For Kilns 1/2, stack test results show the PM emission factor is higher when using TDF. For Kiln 3 stack test

results show the PM emission factor is higher when not using TDF

(2) Kilns. 1 and 2 share a common stack. Emissions are illustrated for each kiln based on their individual process

rates.

(3) Permit limits for PM carried over from Permits No. 78-001-O and PSD-OK-61.

(4) Note that the primary purpose of the DSI system is to control HCl emissions from the kilns which have limits

under Subpart NESHAP LLL.

(5) Grains/acfm.

Based on the PM emission factor obtained from May 2006 test data using EPA Method 5, when

using TDF in Kilns, emissions of filterable PM would be about 1.12 tons per year. Permit limits

are 16.1 lbs/hr and 64 tons per year, for each cooler, carried over from Permit Application dated

March 18, 1980 and Permits No. 78-001-C and PSD-OK-61. Subpart LLL limits on PM10 would

likely prevent the coolers from reaching their PTE for PM emissions.


EMISSION

SOURCE/EU/EP

Max Hourly

Clinker

(ton/hr)

PTE

Controlled

(ton PM10 /yr)

PTE

Controlled

(ton PM /yr)

Clinker Cooler No. 1 (E-68, P-43)/ 25 48.6 64



Total 145.8 192

*PM10 emissions are assumed to be 76% of PM emissions per Table 11.6-6 of AP-42 Section 11.6.

The following emissions calculations are considered to be controlled PTE, i.e. they take into

account any controls utilized on the processes. Processes having a baghouse or dust collector type

device, where emissions are recovered by a capture system and routed through a filter, are based

on grain loading factors and discharge rates through the control system. Emissions having only

enclosures or sprays, such as foam, are based on material throughput and an emissions factor

believed to be best suited for material throughput, storage, or drop points. Processes adjusted using

the particle size distribution factors for PM<30, PM10, etc. are footnoted as such.


EUG 1c – Subpart LLL Affected Sources Other Than Kilns; Clinker Coolers; New and Reconstructed Raw Material Dryers

EMISSION SOURCE/EU/EP Flow

Rate

(acfm)

Max Hourly

Throughput

Material

(ton/hr)

Actual Annual

Throughput

Material

(ton/yr)

Controls

(%)

Emission Factor

(grain/ acf )

or (lbs/ton) (10)

PM PTE

Controlled

(ton/yr)

PM10 PTE

Controlled

(ton/yr)

Raw Mill No.1

Raw Material Hopper 101 / E-270 / P-254

NA 20 -- None 0.063 (9) 5.6 2.6






Raw Mill Material Bins/ E-34/ P-60 NA 252 NA 1-Wall Shed (24) 0.019/0.0087 (1) 21 7.3

Raw Material Weigh Feeders/ E-35/ P-26

42,000

126 623,185 Baghouse (95)

0.015 (2)

24 (11) 24

Mill Feed Conveyor Belt/ E-36/ P-26 207 623,185 Baghouse (95)

Bucket Elevator/ E-37/ P-26 600 NA Baghouse (95)

Classifier/E-38/ P-26 110 NA Cyclones/Dust

Collector (99 ) 0.015

Raw Mill Pump/ E-40/ P-26 110 623,185 Baghouse (95) 0.015(2)

19-inch Airslide/ E-42/ P-26 480 NA Baghouse (95)

#1 Raw Mill / (E-41, P-108) 10,000 110 623,185 Mill End Dust

Collector (99) 0.007(2) 2.6 2.6

Raw Mill No. 2 Raw Mill Material Bins/ E-34/ P-60 Common to Raw Mill No. 1 Raw Material Weigh Feeders/ E-44/ P-28

7,475

332 611,718

Baghouse (95) 0.015 (2) 5 5 Mill Feed Conveyor Belt/ E-45/ P-28 413 611,718

Bucket Elevator/ E-46/ P-28 600 NA

24-inch Airslide/ E-51/ P-28 600 NA

Classifier/E-47/ P-29 51,760

95 NA Baghouse (95) 0.015 (2) 30 30

Raw Mill Pump/ E-49/ P-29 110 611,718

#2 Raw Mill / (E-50, P-109) 10,000 95 611,718 Mill End Dust Collector (99)

0.007 (2) 2.6 2.6

Kiln Feed/Blending 3 - Blending Silos/ E-52/ P-30

23,000

300 1,235,430

Baghouse (95) 0.015 (2) 13 13 14-inch Airslide/ E-53/ P-30 240 NA


Blend Pumps (3)/ E-55/ P-30 411 NA

Kiln Feed Storage Silo/ E-56/ P-31 6,600 45 741,258 Baghouse (95) 0.015 (2) 4 4




Rate

(acfm)

Max Hourly

Throughput

Material

(ton/hr)

Actual Annual

Throughput

Material

(ton/yr)

Controls

(%)

Emission Factor

(grain/ acf )

or (lbs/ton) (10)

PM PTE

Controlled

(ton/yr)

PM10 PTE

Controlled

(ton/yr)

Kiln No. 1 Support Equipment Kiln Feed Tank/ E-66/ P-41

4,600 48 344,688

Baghouse (95) 0.02 (2) 4 4 Feed Tank Bucket Elevator (Kiln 1)/ E-71/ P-41 60 NA

Drag Chain Conveyor (clinker), 12-inch/ E-69/ P-43 241,700 25 200,099 ESP 0.0102 (5)

Included in

clinker cooler

emissions

Clinker Bucket Elevator (clinker)/ E-70/ P-60 NA 60 NA Enclosed (60) 0.15 (3) 19 16

Kiln No. 2 Support Equipment Kiln Feed Tank/ E-74/ P-46 4,600 48 327,355 Baghouse (95) 0.02 (2) 4 4

Feed Tank Bucket Elevator (Kiln 2)/ E-81/ P-42 NA 56 NA

Cyclones/ Dust Collector

(99)

Included in kiln

emissions

Drag Chain Conveyor, 12-inch (clinker)/ E-77/ P-43 241,700 25 190,037 ESP 0.0102 (5)

Included in

clinker cooler

emissions

Clinker Bucket Elevator (clinker)/ E-78/ P-60 NA 60 NA Enclosed (60) 0.15 (3) 19 16

Kiln No. 3 Support Equipment Kiln Feed Tank, 22-inch dia./ E-96/ P-57

7,475

65 561,518

Dust Collectors (95) 0.015 (2) 5 5

2 – Airslides, 12-inch/ E-97/ P-57 200 NA

Feed Hopper for 031-3150 & 031-3694/ E-98/ P-57 200 NA

Cyclone Dust Bucket Elevator (Kiln 3)/ E-105/ P-57 100 NA


Drag Chain Conveyor (clinker), 12-inch/ E-101/ P-43 241,700 40 325,974 ESP 0.0102 (5)

Included in

clinker cooler

emissions

Clinker Bucket Elevator/ E-102/ P-60 NA 50 NA Enclosed (60) 0.15 (3) 15 13


Baghouse Dust Pump (Kiln 3)/ E-106, P-58 186,000 25 NA Baghouse (95)

Included in kiln

emissions

#16 Screw Conveyor, 16-inch/ E-79/ P-42 150,000 14 NA Cyclone/

Dust Collector (99)

Included in kiln

emissions

#17 Screw Conveyor, 16-inch/ E-80/ P-48

4,600

38 NA

Dust Collectors (95) 0.015 (6) 2.6 2.6 Dust Tank Bucket Elevator/ E-82/ P-48 100 NA

Kiln Dust Storage Tank #1, 14-foot dia./ E-83/ P-48 30 33,602





Rate

(acfm)

Max Hourly

Throughput

Material

(ton/hr)

Actual Annual

Throughput

Material

(ton/yr)

Controls

(%)

Emission Factor

(grain/ acf )

or (lbs/ton) (10)

PM PTE

Controlled

(ton/yr)

PM10 PTE

Controlled

(ton/yr)

Kiln Dust Pump/ E-86/ P-48 65 NA

FK Pump (Replaced Kiln Dust Conveying Pods in

2004)/ E-87/ P-48 50 NA

Kiln Dust Storage Tank #2, 30-foot dia./ E-88/ P-51

3,000

30 134,409

Dust Collectors (95) 0.015 (6) 1.7 1.7 14-inch Airslide/ E-89/ P-51 160 NA

CKD Truck Loadout/ E-90/ P-51 150 NA

Kiln Dust Storage Tank#3 / E-209 / P-209 3,000 8 0 Dust Collector (99.99) 0.01 (6) 1 1

Finish Mill No. 1 3 - Clinker/Gypsum Bins/ E-108/ P-60 NA 88 NA 1-Wall Shed (24) 0.15 (3) 52 44

3 - Weigh Feeders/ E-109/ P-66 6,000

88 NA Baghouse (99) 0.002 (2) 0.5 0.5

Mill Feed Conveyor Belt/ E-110/ P-66 110 NA

Bucket Elevator/ E-113/ P-63

10,000

350 NA

Baghouse (99) 0.01 (2) 3.8 3.8

Cement Coolers #1 and #2/ E-115/ P-63 35 NA


Finish Mill Pump/ E-117/ P-63 35 215,363


16-foot Classifier, Sturtevant/ E-114/ P-66 24,000

350 215,363 Cyclone/ Dust Collector (99)

0.01 (2) 9 9 Tailings Airslide/ E-114a/ P-66 300 NA

#1 Finish Mill, KVS/ E-111/ P-64 18,000

35 215,363 Cyclone/Dust Collector (99)

0.01 (2) 6.8 6.8 19-inch Airslide/ E-111a/ P-64 300 NA

Finish Mill No. 2

Overhead Crane, 60-foot span/ E-33/ P-60 (Used

for Clinker and Finish Mills) NA NA 1,418,710 3-Wall Shed (40) 0.08 (8) 40 20


E-119/ P-60 NA 135 NA 1-Wall Shed (24) 0.15 (3) 79 67

Weigh Feeders/ E-120/ P-67 24,000

135 NA Baghouse (95) 0.01 (2) 9 9

Mill Feed Conveyor Belt/ E-121/ P-67 110 172,505

#2 Finish Mill, KVS/ E-122/ P-67

24,000

35 172,505 Cyclone/

Dust Collector (99)

0.01 (2) 9 9

19-inch Airslide/ E-124/ P-67 480 NA Baghouse (95)

Bucket Elevator/ E-125/ P-67 350 NA Baghouse (95)

16-foot Classifier, Sturtevant/ E-126/ P-67 350 172,505 Cyclone/

Dust Collector (99)

Cement Cooler/ E-126b/ P-67 35 NA Baghouse (95)

Finish Mill Pump/ E-128/ P-67 35 172,505 Baghouse (95)




Rate

(acfm)

Max Hourly

Throughput

Material

(ton/hr)

Actual Annual

Throughput

Material

(ton/yr)

Controls

(%)

Emission Factor

(grain/ acf )

or (lbs/ton) (10)

PM PTE

Controlled

(ton/yr)

PM10 PTE

Controlled

(ton/yr)

Finish Mill #2 additives hopper and feeder / E-259

/ P-262 NA

95 15,000

4-Wall Building - Control efficiency

accounted for in

derivation of emissions factor by using reduced

wind speed.

0.02 (7) 0.1 0.07


/ P-262 NA

Finish Mill #2 additives feeder to feed conveyor /

E-260 / P-262 NA


E-262 / P-262 NA

Finish Mill No. 3 3 - Clinker/Limestone/Gypsum Bins/ E-129/ P-60 NA 165 NA 1-Wall Shed (24) 0.15 (3) 97 82

#3 Finish Mill/ E-132/ P-69 23,500

55 365,255 Baghouse (99) 0.01 (2) 8.8 8.8

Tailings Airslide/ E-135a/ P-69 450 NA

Weigh Feeders/ E-130/ P-70 6,000

165 NA Baghouse (99.99) 0.002 (2) 0.5 0.5

Mill Feed Conveyor Belt/ E-131/ P-70 190 NA

19-inch Airslide/ E-132a/ P-270 1,500 480 NA Baghouse (99) 0.01 (6) 0.56 0.56


38,000

500 NA

Baghouse (99) 0.01 (2) 14.3 (11) 14.3 (11)


Classifier, , 18-foot/ E-135/ P-70 500 365,255

Cement Cooler/ E-135b/ P-70 55 NA


Finish Mill Pump, 125-hp, 8H F-K/ E-137/ P-70 55 365,255


/ P-262 NA 0.6

15,000

4-Wall Building Control efficiency accounted for

in derivation of emissions factor by using reduced

wind speed.

0.02 (7) 0.1 0.07


/ P-262 NA 0.08


E-265 / P-262 NA 0.6


E-266 / P-262 NA 0.08

Finish Silos - Group 1 8 - Cement Storage Silos/ E-138/ P-71/72/73 (3

baghouses)

9,000

Each 125 151,586 Dust Collectors (95) 0.02 (6) 20 17

Fringe Bin Pump/ E-139/ P-74 3,450 10 NA Baghouse (95) 0.02 (6) 3 2




Rate

(acfm)

Max Hourly

Throughput

Material

(ton/hr)

Actual Annual

Throughput

Material

(ton/yr)

Controls

(%)

Emission Factor

(grain/ acf )

or (lbs/ton) (10)

PM PTE

Controlled

(ton/yr)

PM10 PTE

Controlled

(ton/yr)

12-inch Airslide/ E-140/ P-75 2,500

200 NA Baghouse (95) 0.02 (6) 2 2

Silo/Packhouse Bucket Elevator/ E-147/ P-75 150 NA

12-inch Airslide/ E-141/ P-76

4,500

200 NA

Baghouse (95) 0.02 (6) 3 3 Loadout Spout/ E-144/ P-76 540 NA

Truck Loading Bucket Elevator/ E-143/ P-76 150 NA

Rail Loading Bucket Elevator/ E-145/ P-77 2,200

150 NA Baghouse (95) 0.02 (6) 2 1


NW Truck & Rail Loadout/ E-146/ P-78 1,800 75 NA Baghouse (95) 0.02 (6) 1 1

Finish Silos - Group 2 11 - Cement Storage Silos/ E-150/ P-80/P-81 (2

baghouses) 9,000 each

125 288,851 Dust Collectors (95) 0.02 (6) 14 12 (11)


200 NA Baghouse (95) 0.02 (6) 3 3

East Rail Aux Bucket Elevator/ E-158/ P-82 200 NA


4,500

200 NA

Baghouse (95) 0.02 (6) 3 3 Truck Loading Bucket Elevator/ E-154/ P-83 200 NA

Loadout Spout/ E-155/ P-83 540 NA

Rail Loading Bucket Elevator/ E-156/ P-84 4,500

200 NA Baghouse (95) 0.02 (6) 3 3


East Rail Loadout Spout/ E-157/ P-85 1,800 180 NA Baghouse (95) 0.02 (6) 1.4 1.4

Finish Silos - Group 3 Cement Storage Silo 15/ E-160a/ P-87a 3,900

85 312,614 Baghouse (99.997) 0.003 (2) 0.4 0.4

Cement Storage Silo 16/ E-160b/ P-87b 3,900 Baghouse (99.997) 0.003 (2) 0.4 0.4

Loadout Spout/ E-161/ P-88 1,725 540 NA Baghouse (95) 0.02 (2) 1 1


480 NA Baghouse (95) 0.015 (2) 1.4 1.4

Loadout Spout/ E-163/ P-89 540 156,307

Packhouse

Packer Bins A and B/ E-164/ P-90

12,000

105 22,210

Baghouse (95) 0.015 (6) 7 7

Portland Packer Bucket Elevator/ E-165/ P-90 100 22,210

Portland Packer/ E-166/ P-90 68 22,210


Packhouse Fringe Bin/ E-172/ P-90 5 NA

Packer Bins C and D/ E-168/ P-91 12,000

105 27,460 Baghouse (95) 0.015 (6) 7 7

Masonry Packer Bucket Elevator/ E-169/ P-91 100 27,460




Rate

(acfm)

Max Hourly

Throughput

Material

(ton/hr)

Actual Annual

Throughput

Material

(ton/yr)

Controls

(%)

Emission Factor

(grain/ acf )

or (lbs/ton) (10)

PM PTE

Controlled

(ton/yr)

PM10 PTE

Controlled

(ton/yr)

Masonry Packer E-170/ P-91 68 27,460


Packhouse Fringe Bin/ E-172/ P-91 5 NA

Chain Conveyors (Bag Drop)/ E-173/ P-93 NA 24 NA Enclosed (60) 0.2 (4) 10 8

Bag Palletizer/ E-174/ P-94 NA 48 NA Enclosed (60) 0.2 (4) 20 17

Totals 637.1 543.24

1 - AP-42 Section 11.19.2 emission factor in lb-PM per ton-material processed. Screening emission factor of 0.025 lb/ton PM and 0.0087 lb/ton PM10 used as

representative. The stated emission factor has been adjusted such that when the control efficiency is applied, the resulting emission factor equals what is listed in

AP-42 (i.e., 0.025 * (1- 24%) = 0.02).

2 - Outlet grain dust loading of baghouse, regardless of inlet loading, based on manufacturer performance guarantee. Emission factor units are grain/acf PM of

maximum baghouse exhaust flow rate. APCD control efficiency included in the factor. Per baghouse filter vendor, high efficiency baghouse filters are used in

these baghouses and therefore all particulate is assumed to be less than 10 microns. Therefore, PM10 emissions assumed to equal PM.

3 - SCC Factor. Source Classification Code which is an eight-digit code that identifies a particular process or operation, which is creating the emissions. A

listing of SCC’s can be found in the EPA document "Airs Facility Subsystem Source Classification Codes and Emission Factor Listing for Criteria Pollutants".

SCC EF for SCC 3-05-015-04, Gypsum Manufacturing Conveying of 0.15 lb/ton PM10. No PM emission factor provided so PM10 assumed to be 85% of PM per

AP-42 Appendix B.2 Category 4.

4 - SCC EF for SCC 3-05-006-19 Cement Loadout of 0.2 lb/ton PM10 used. No PM emission factor provided so PM10 assumed to be 85% of PM per AP-42

Appendix B.2 Category 4.

5 - PM emission factor based on stack May 2006 test data when using TDF in Kilns. Emission factor units are lb-PM per ton clinker.

6 - Grain loading and control efficiency based on manufacturer performance guarantee and plant particle size data. Per baghouse filter vendor, high efficiency

baghouse filters are not utilized in these baghouses. Therefore, PM10 emissions calculated as 85% of PM emissions based on AP-42 Appendix B.2 Category 4.

7 - Emission factor based on AP-42 Section 13.2.4.3 Eq. 1, wind speed = 1mph, moisture = 0.1%, This equipment will only be used for maximum annual production

of 15,000 TPY (max downstream finish mill capacity 90 TPH). PM emissions calculated using the PM<30 multiplier and PM10 emissions calculated using the

PM<10 multiplier. Building control is accounted for by 1 mph wind speed within emission factor calculation.

8 - Calculated using AP-42 Section 13.2.4.3 moisture = 0.3%, Wind = 10 mph. PM emissions calculated using the PM<30 multiplier and PM10 emissions

calculated using the PM<10 multiplier. Throughput = 2 x annual clinker produced (double handling).

9 - Emission factor based on AP-42 Section 13.2.4.3 Eq. 1 – wind speed = 15mph, moisture = 0.53%, (max downstream finish mill capacity 90 TPH). The equation

requires an input, k (particle size multiplier). The largest diameter PM is PM<30 with a k value of 0.74. PM emissions were calculated using the PM<30 multiplier

and PM10 emissions were calculated using the PM<10 multiplier.

10 - All emission factors listed are for PM filterable unless specified otherwise in the footnotes 1-9.

11 - Conventional rounding not used because limit too restrictive.


NOX and CO emissions, based on emissions factors from AP-42 Section 1.4, Table 1.4-1 for Natural Gas Combustion and the heat

ratings of the two furnaces are 20 MMBTUH and 30 MMBTUH respectively. Combustion emissions generated by the furnaces are

routed through the raw mill classifiers and discharged through raw mill baghouses P-26 and P-29.

EUG 1d - Existing Raw Material Dryer Furnaces

EMISSION SOURCE/EU/EP NOX

(TPY)

CO

(TPY)

VOC

(TPY)

PM/PM10

(TPY) (2)

SO2

(TPY)

Raw Mills

Hot Air Furnace/ E-39/ P-26 (1), 20 MMBTUH 8.6 7.2 0.47 0.65 0.052

Hot Air Furnace/ E-48/ P-29 (1), 30 MMBTUH 13 11 0.71 0.98 0.077

Total 21.6 18.2 1.18 1.63 0.129 1 - Emissions points P-26 and P-29 are emissions points for the raw mill classifiers. PM in this table are combustion PM. PM emissions from non-combustion

materials are included in EUG – 1c for emissions points P-26 and P-29.

2 Per AP-42 Section 1.4 all PM is assumed to be less than 1 micron so PM10 equals PM.

EUG 1e – Open Clinker Storage Piles

EMISSION SOURCE/EU/EP Max

Hourly

Actual

Annual

Thruput

(TPY)

Controls

(%)

PM Emissions

Factor

(lbs/ton)

PM PTE

Controlled

(TPY)

PM10 PTE

Controlled

(TPY)


Clinker Storage Pile – Outside/ E-104/ P-61 3 NA NA 0.03 (1) 0.3 0.2

Clinker Storage Hall/ E-103/ P-60 225 NA 1-Wall Shed (24) 0.063 (2) 47 22

Total 47.3 22.2

1- Emission factor based on AP-42 Section 13.2.4.3 Eq. 1 – wind speed = 15 mph, moisture = 1%. PM emissions calculated using the PM<30 multiplier and PM10

emissions calculated using the PM<10 multiplier.

2- Emission factor based on AP-42 Section 13.2.4.3 Eq. 1 – wind speed = 15 mph, moisture = 0.53%. PM emissions calculated using the PM<30 multiplier and

PM10 emissions calculated using the PM<10 multiplier.




Rate

(acfm)

Max

Hourly

Actual

Annual

Thruput

(TPY)

Controls

(%)

PM

Emissions

Factor

(lbs/ton)

PM PTE

Controlled

(TPY)

PM10 PTE

Controlled

(TPY)

#5 Storage Hall Tripper Conveyor Belt,

36-inch/E-28/ P-12a NA 252 1,110,612

1-Wall Shed

(24) 0.063 (1) 27 13

Belt Conveyor BC1, 36-inch, Hopper Gathering

/ E-257 / P-260 NA 90 (2) 92,305 None 0.063 (1) 2.9 1.4

Belt Conveyor BC2, 36-inch, Additive Transfer

/ E-258 / P-261 NA 90 (2) 92,305 None 0.063 12) 2.9 1.4

Totals 32.8 15.8 1 - Emission factor based on AP-42 Section 13.2.4.3 Eq. 1 – wind speed = 15mph, moisture = 0.53%. PM emissions calculated using the PM<30 multiplier and


2 –Max downstream finish mill capacity 90 TPH.

EUG 3 – OAC 252:100-25 Non-Metallic Mineral Processing EMISSION SOURCE/EU/EP Flow

Rate

(acfm)

Max

Hourly

(TPH)

Actual

Annual Thruput

(TPY)

Controls

(%)

PM Emiss.

Factor

(lbs/ton)

PM PTE

Controlled

(TPY)

PM10 PTE

Controlled

(TPY)

Load Hopper to Wobbler Feeder (E-5, P-6)

16,100

600 1,249,135

Baghouse &

Foam Spray (95) 0.01 (1) 6 6

Wobbler Feeder (E-6, P-6) 600 1,249,135

Wobbler Fines Belt Conveyor (E-7, P-6) 1,000 1,249,135

Primary Crusher, 6185/ (E-8, P-6) 600 1,249,135

#1 Primary Belt Conveyor, 36-inch/ (E-9, P-7)

11,500

1,000 1,249,135 Baghouse (95)

0.02 (1)

6.5 6.5 Primary Vibrating Screen (E-10, P-7) 1,000 1,249,135

#2 Primary Belt Conveyor, 30-inch/ (E-11, P-7) 750 NA

Load Hopper to Wobbler Feeder (E-12, P-9) NA 300 1,249,135 (4) Foam Spray (50) 0.003/0.0011 (2) 0.9 0.37

Wobbler Feeder (E-13, P-8)

12,000

300

749,481 Baghouse (95) 0.02 (1) 9 9 Secondary Crusher, 05NC/ (E-15, P-8) 300

#1 Secondary Belt Conveyor, 30-inch (E-16, P-8) 650

#2 Secondary Belt Conveyor, 24-inch (E-17, P-8) 360

Secondary Vibrating Screen (E-18, P-10) 10,000 650 749,481 Baghouse (95) 0.0031 (4) 1.2 0.99

#3 Primary Belt Conveyor, 30-inch (E-19, P-11a) 6,085

765 NA Baghouse (95) 0.015 (1) 3.43 3.43

#3 Secondary Belt Conveyor, 36-inch/ (E-20, P-11a) 550

#4 Crossover Belt Conveyor, 36-inch/ (E-21, P-11b) 1,800 1,000 1,249,135 Baghouse (95) 0.015 (1) 1.01 1.01

A-Frame Storage E-27a/P-18 251 1,249,135 2-Wall

Enclosure (36) 0.063 (3) 25 12


EUG 3 – OAC 252:100-25 Non-Metallic Mineral Processing EMISSION SOURCE/EU/EP Flow

Rate

(acfm)

Max

Hourly

(TPH)

Actual

Annual Thruput

(TPY)

Controls

(%)

PM Emiss.

Factor

(lbs/ton)

PM PTE

Controlled

(TPY)

PM10 PTE

Controlled

(TPY)

#5 A-Frame Tripper Belt Conveyor, 30-inch/ E-27/ P-

12b 1,800 251 1,249,135 Baghouse (95) 0.02 (1) 1.4 1.4

6 - Belt Conveyors (3 Working)/ E-30/ P-21 NA 750 1,139,238 Enclosure and Foam

(60) 0.003/0.0011 (2) 0.7 0.25

#1 Reclaim Belt Conveyor, 30-foot/ E-31/ P-22 NA 567 949,572 Enclosure and Foam

(60) 0.063 (3) 12 5.7

#2 Reclaim Belt Conveyor, 30-foot/ E-32/ P-23 NA 652 949,572 Enclosure and Foam

(60) 0.063 (3) 12 5.7

#3 Reclaim Belt Conveyor, 30-foot/ E-32a/ P-25 NA 652 949,572 Enclosure and Foam

(60) 0.063 (3) 12 5.7

Totals 91.14 58.05

1 - Outlet grain dust loading of baghouse, regardless of inlet loading, based on manufacturer data. This is a conservative emission factor and actual PM emissions

will be less under normal operations. Emission factor units are grain/acf PM of maximum baghouse exhaust flow rate. APCD control efficiency included in the

factor. Per baghouse filter vendor, high efficiency baghouse filters are used in these baghouses and therefore all particulate is assumed to be less than 10 microns.

Therefore, PM10 emissions assumed to equal PM.

2 - AP-42, Section 11-19.2 for conveyor transfer points, 0.003 lb/ton PM and 0.0011 lb/ton PM10.

3 - Emission factor based on AP-42 Section 13.2.4.3 Eq. 1 – wind speed = 15 mph, moisture = 0.53%. PM emissions calculated using the PM<30 multiplier and


4 - Outlet grain dust loading of baghouse, regardless of inlet loading, based on manufacturer data. Emission factor units are grain/acf PM of maximum baghouse

exhaust flow rate. APCD control efficiency included in the factor. Per baghouse filter vendor, high efficiency baghouse filters are not utilized in these baghouses.

Therefore, PM10 emissions calculated as 85% of PM emissions based on AP-42 Appendix B.2 Category 4.



Rate

(acfm)

Max

Hourly

(TPH)

Actual

Annual

Thruput

(TPY)

Controls

(%)

PM Emiss.

Factor

(lbs/ton)

PM PTE

Controlled

(TPY)

PM10 PTE

Controlled

(TPY)

Coal Handling

Coal Load Hopper/ E-59/ P-34 NA 277 112,602 None 0.0032 (1) 0.18 0.085

Coal Belt Conveyor #1/ E-60/ P-35 NA 277 112,602 Enclosure (60) 0.0032 (1) 0.071 0.034

Coal Crusher/ E-61/ P-36 NA 27 112,602 Enclosure (60) 0.02 (2) 0.5 0.1

Coal Belt Conveyor #2, 24-inch/ E-62/ P-37 NA 297 112,602 Enclosed (60) 0.02 (2) 0.5 0.1

Coal Bunker/ E-63/ P-38 NA 27 112,602 Enclosure (60) 0.02 (2) 0.5 0.1

#1 Kiln

Coal Weigh Feeder/ E-64/ P-39 NA 9 31,436 Enclosed (60) 0.02 (2) 0.1 0.04

Coal Mill, E-65/ P-42 150,000 6 31,436 Footnote (3) Footnote (3) Footnote (3) Included in

Kiln Stack


EUG 4 - Subpart Y Coal Handling EMISSION SOURCE/EU/EP Flow

Rate

(acfm)

Max

Hourly

(TPH)

Actual

Annual

Thruput

(TPY)

Controls

(%)

PM Emiss.

Factor

(lbs/ton)

PM PTE

Controlled

(TPY)

PM10 PTE

Controlled

(TPY)

#2 Kiln

Coal Weigh Feeder, 24-inch/ E-72/ P-45 NA 9 29,864 Enclosed (60) 0.02 (2) 0.1 0.04


Kiln Stack

#3 Kiln

Coal Weigh Feeder, 24-inch/ E-94/ P-55 NA 9 51,302 Enclosed (60) 0.02 (2) 0.2 0.06


Kiln Stack Total 2.151 0.559

1 - Emission factor based on AP-42 Section 13.2.4.3 Eq. 1 – wind speed = 15 mph, default coal moisture of 4.5% used. PM emissions calculated using the

PM<30 multiplier and PM10 emissions calculated using the PM<10 multiplier.

2 - SCC Factor. SCC 3-05-010-10 for coal crushing and also 3-05-010-08 for coal unloading. Emission factor of 0.02 lb/ton for PM and 0.006 lb/ton PM10

used.

3 - Emissions Counted In Kiln Stack/Totally Enclosed.

EUG 5 – Fugitive PM Sources EMISSION SOURCE/EU/EP Max

Hourly

Actual

Annual

Thruput

(TPY)

Controls

(%)

PM Emiss.

Factor

(lbs/ton)

PM PTE

Controlled

(TPY)

PM10 PTE

Controlled

(TPY)

Facility-Wide NA NA NA NA NA

Non-Metallic Mineral Processing

Load Hopper (E-5, P-5) NA 1,249,135

Foam

Spray

(50)

0.003/0.0011 (1)

0.9 0.34


Gypsum Unloading (Belly Dumping)/

E-22/ P-13 50 NA None 0.04 (4) 9 4

Gypsum Pile/ E-23/ P-14 35 35,000 None 0.004 (3) 0.6 0.3

Iron Source Pile/ E-24/ P-15 30 9,400 None 0.004 (3) 0.5 0.2

Silica-Alumina Pile/ E-25/ P-16 100 75,000 1-Wall

Shed (24) 0.004 (3) 1.33(10) 0.80(10)


EUG 5 – Fugitive PM Sources EMISSION SOURCE/EU/EP Max

Hourly

Actual

Annual

Thruput

(TPY)

Controls

(%)

PM Emiss.

Factor

(lbs/ton)

PM PTE

Controlled

(TPY)

PM10 PTE

Controlled

(TPY)

Gypsum, Iron Ore Unloading –

(hoppers 101 to 106)/E-26/ P-17 340 92,305 None 0.063 (8) 2.9 1.4

Rock Reclaim - Onsite Acquired Raw

Material

Limestone Outside Storage/ E-29/ P-20 126 NA None 0.063 (8) 35 17


CKD Storage Pile/ E-93/ P-54 75 20,000 NA 0.03 (7) 0.3 0.1


Raw Material Storage Pile/ E-200/ P-

200 NA NA NA NA(9) 10 10

Coal Handling kg/hectare-

day

Coal Pile/ E-57/ P-32 NA 118,000 None 10.86 (5) 3.58 1.79

Haul Roads VMT (Lbs

TSP/VMT)


CKD Haul Roads/ E-92/ P-53 NA 256.4

Water

Spray

(50)

6.72/21.97 (2) 1.4 0.43

Coal Handling

Coal Haul Roads/ E-58/ P-33 Paved NA 2,272 None 4.34/0.87 (6) 4.9 1.40

Coal Haul Roads/ E-58/ P-33 Un-Paved NA 1,136 Water

Spray 14.37/4.54 4.1 1.3

Total 131.18 68.37 1 - AP-42, Section 11-19.2 for conveyor transfer points, 0.003 lb/ton PM and 0.0011 lb/ton PM10.

2 - CKD Haul Road emissions determined using AP-42 Section 13.2.2 (Nov. 2006). The following values from the plant were utilized for the calculations: mean

vehicle weight of 102.75 tons, silt content of unpaved roads of 14.1%, number of days with a minimum of 0.01" of precipitation per year of 67, distance traveled

of 256.4 miles. PM emissions calculated using the k value for PM-30 and PM10 emissions calculated using the k value for PM-10. Calculated emission factors

of 6.72 lb/VMT PM10 and 21.97 lb/VMT PM used for unpaved. Control efficiency of 50% applied to unpaved roads to account for watering.

3 – Emission factor based on AP-42 Section 13.2.4.3 Eq. 1 – wind speed = 15 mph, moisture = 4.0%. PM emissions calculated using the PM<30 multiplier and



4 – Emission factor based on AP-42 Section 13.2.4.3 Eq. 1 – wind speed = 15mph, moisture = 0.7%. PM emissions calculated using the PM<30 multiplier and


5 – Emission factor units is kg TSP/hectare-day. Per Applicability Determination No. 98-170-AD (M-6) memo dated June 12, 2009, coal pile is 0.82 hectares.

Per memo, TSP EF is 10.86 kg TSP/hectare-day and PM10 is assumed to be 50% of TSP.

6 – Emissions determined using AP-42 Section 13.2.1 (Jan 2011) and Section 13.2.2 (Nov. 2006). The following values from Applicability Determination No.

98-170-AD (M-6) memo dated June 12, 2009 were utilized: Mean vehicle weight of 40 tons, silt loading of 12 g/m2 for paved roads, silt content of unpaved

roads of 14.1%, number of days with a minimum of 0.01" of precipitation per year of 67, annual throughput of 2272 VMT for paved roads and 1136 VMT for

unpaved roads. PM emissions calculated using the PM-30 multiplier and PM10 emissions calculated using the PM-10 multiplier. Calculated emission factors of

0.87 lb/VMT PM10 and 4.34 lb/VMT PM used for Paved road calculations. Calculated emission factors of 4.54 lb/VMT PM10 and 14.37 lb/VMT PM used for

unpaved. Control efficiency of 50% applied to unpaved roads to account for watering.

7- Emission factor based on AP-42 Section 13.2.4.3 Eq. 1 – wind speed = 15 mph, moisture = 1%. PM emissions calculated using the PM<30 multiplier and


8- Emission factor based on AP-42 Section 13.2.4.3 Eq. 1 – wind speed = 15 mph, moisture = 0.53%. PM emissions calculated using the PM<30 multiplier and


9 - Applicant has not submitted PTE calculations but states that the annual usage of these materials for the last five years has been zero. An assumed value of 10

TPY is used for PM and PM10 emissions.

10 – PTE emissions calculations for P-16 do not include the 24% control efficiency due to its 1-wall partial enclosure.

Facility Wide Total Emissions (TPY)

The following table is a summary of the results of the PTE calculations derived in the discussion above. Note that based on the permit

limit for TSP on EUG 1a, Kilns, of 193.7 TPY, the above calculated PTE for PM10 of 22.6 TPY, which was based on tests data and the

assumption from AP-42 Table 11.6-5 that PM10 is 85% of PM, appears to be conservatively low. A more realistic estimation of the PTE

for PM10 is likely 85% of the permitted TSP, which is 164.6 TPY

Emissions Summary

NOX

(TPY)

SO2

(TPY)

CO

(TPY)

VOC

(TPY)

PM

(TPY)

PM10

(TPY)

HCl

(TPY)

H2SO4

(TPY)

DF

(TPY) EUG 1a 3,591.9 1,781.2 1,385.3 556.3 194 22.6 55.2 2.8 0.1

EUG 1b 0 0 0 0 192.0 145.9 0 0 0

EUG 1c 0 0 0 0 637.1 543.24 0 0 0

EUG 2 0 0 0 0 77 37 0 0 0

EUG 3 0 0 0 0 114.8 70.71 0 0 0

EUG 4 0 0 0 0 2.151 0.559 0 0 0

EUG 5 0 0 0 0 131.18 67.67 0 0 0

EUG 1d 21.5 0.1 18 1.2 1.63 1.63 0 0 0

EUG 1e 0 0 0 0 47.3 22.2 0 0 0

Total 3,613.4 1,781.3 1,403.3 557.5 1,397.251 910.899 55.2 2.8 0.1


Development of Permit Limits

EUG 1a – Kilns and DSI System Silo: Permit No. 72-005-O established particulate matter (PM)

limits for Kilns No. 1 and 2 based on the following for each kiln: a discharge rate of 143,000 acfm

and grain loading of 0.01 gr/acf, which equates to 12.3 lbs/hr (or 53.7 tons per year) for each kiln.

Permit No. PSD-OK-61 established SO2 limits of 168 lbs/hr and PM limits of 19.7 lbs-TSP/hr for

Kiln No. 3. The PSD evaluation for Permit No. PSD-OK-61 was triggered by SO2 only and the

enforceable limits have been carried forward. Permit No. 98-170-C (M-1) authorized the

installation of mid-kiln tire derived fuel injection equipment and required stack testing that lead to

the request for enforceable limits on CO by Application No. 98-170-TV (M-1), which was

incorporated into Permit No. 98-170-TV. Limits for CO requested under Application No. 98-170-

TV (M-1) are 722.3 tons per year and were incorporated into Permit No. 98-170-TV. It appears

that no other pollutants had been assigned limits in permits issued before Permit No. 98-170-TV

and that Kilns No. 1 and 2 had maintained grandfathered status for all other combustion pollutants.

Kiln No. 3, which was constructed after permitting rules were in effect, was assigned limits for all

other pollutants by means of Permit No. 98-170-TV. The most conservatively high emission factor

data obtained from stack testing was used. Rounding was done in accordance with standard

rounding conventions, except where noted.

Emissions Limits: EUG 1a – Kilns Permit No. PSD-OK-61

Pollutant Kiln No. 1

and

Kiln No. 2

Kiln No. 3

NOX NA 705.7

SO2 NA 736

CO 722.3 both kilns combined 585.1

VOC NA 144.9

HCl NA 24.53

TSP 53.7 each kiln 86.3

Permit No. 98-270-TV (M-13) established limits on the DSI System of 0.15 TPY-PM10.

EUG 1b –Clinker Coolers: Permit No. PSD-OK-61 set limits on TSP on Clinker Cooler No. 3. It

appears that Clinker Coolers 1 and 2 were permitted, or at least rated in the application, at 16.1

lbs/hr PM (64 TPY-PM @ 7,920 hr/yr) based on a discharge rate of 208,000 acfm and grain loading

of 0.009 gr/acf in Permit No. 78-001-O. However, Permit No. PSD-OK-61 set limits for TSP and

throughput for all three clinker coolers combined. The PSD limits for all three coolers combined

were 16.1 lbs-TSP/hr (64 TPY-TSP) and a clinker throughput of 88.5 tons per hour.

EUG 1c – Subpart LLL: Kiln No. 1 Support Equipment, Kiln No. 2 Support Equipment, Finish

Silos Group 1, Finish Silos Group 2, and Packhouse. These emissions groups were all constructed

prior to permitting rules and have not been modified or reconstructed and are considered to retain

grandfathered status except when they are subject to Subchapter 19. These emissions units did not

have permit limits at the time the application was submitted for Permit No. 98-170-TV but are

required to maintain control equipment that is in place.


EUG 1c – Subpart LLL: Raw Mill No. 1. This emissions group (constructed mostly pre-1974)

had no numerical limits for particulate matter assigned in Permits issued before Permit No. 98-

170-TV. Grandfathered status was lost for Raw Mill No. 1 with issuance of Permit No. 98-170-C

(M-2), an applicability determination application converted to construction permit to install

ducting and additional baghouses to route exhaust gases from clinker cooler vent system to the

raw mill drying systems. Permit limits of 2.87 TPY for the Mill End Dust Collector were assigned

through that permit. Older permits had a tendency to incorporate applications rather than list limits

for each piece of equipment, but some applications did not have the complete derivation of

emissions. Therefore, for equipment in existence after the permitting rules were in effect for which

no apparent limit could be reconciled from DEQ records during the review of Permit No. 98-170-

TV, and which are controlled by a particulate filter control device, PM limits were derived by

normalizing the emissions calculations submitted in the Permit No. 98-170-TV application

(illustrated in the “Emissions” section of this memorandum) with the calculation method used for

Permit No. PSD-OK-61. This is based on a grain loading factor of 0.015 gr/acf, except for the two

baghouses installed and permitted under Permit No. 98-17-C (M-2), each having limits based on

an emissions factor of 0.01 gr/acf.

EUG 1c – Subpart LLL: Raw Mill No. 2. This emissions group (constructed mostly in 1980) had

no numerical limits for particulate matter assigned in permits issued before Permit No. 98-170-

TV. Permit limits of 2.87 TPY for the Mill End Dust Collector were assigned through Permit No.

98-170-C (M-4), an AD application converted to construction permit to install ducting and

additional baghouses to route exhaust gases from clinker cooler vent system to the raw mill drying

systems. For equipment in existence after the permitting rules were in effect for which no apparent

limit could be reconciled from DEQ records during the review of Permit No. 98-170-TV and which

are controlled by a particulate filter control device, PM limits were derived by normalizing the

emissions calculations submitted in the Permit No. 98-170-TV application (illustrated in the

“Emissions” section of this memorandum) with the calculation method used for Permit No. PSD-

OK-61. This is based on a grain loading factor of 0.015 gr/acf.

EUG 1c – Subpart LLL: Kiln Feed Blending. This emissions group (constructed 1979 to 1980),

which had no numerical limits for particulate matter assigned in permits issued before Permit No.

98-170-TV, was assigned limits based on the grain loading factor of 0.015 gr/acf, used in Permit

No. PSD-OK-61.

EUG 1c – Subpart LLL: Kiln No. 3 Support Equipment. This emissions group (constructed in

1980 to 1987) which had no numerical limits for particulate matter assigned in permits issued

before Permit No. 98-170-TV, was assigned limits based on the grain loading factor of 0.015

gr/acf, used in Permit No. PSD-OK-61, except for P-59 which utilizes a material throughput-based

factor in units of lbs/ton submitted in the TV application.

EUG 1c – Subpart LLL: Kiln Feed Blending. This emissions group (constructed in 1979 and

1980) had no numerical limits for particulate matter assigned in permits issued before Permit No.

98-170-TV. Permit No. 98-170-V assigned limits calculated from a grain loading factor of 0.015

gr/acf, used in Permit No. PSD-OK-61.


EUG 4 - Subpart Y Coal Handling. Emissions generated from Coal Mills 1, 2 and 3 are included

in the kiln stack emissions of Kilns 1, 2, and 3 respectively.

EUG 1c – Subpart LLL: Kiln Dust Reclaim System. The Kiln Dust Reclaim System (constructed

1961 and pre-1974 to 1990) lost grandfathered status with the construction/replacement of other

emissions units installed during 1975, 1980, 1990, and 2007. The original equipment had no

numerical limits for particulate matter assigned in permits issued before Permit No. 98-170-TV

and was assigned limits based on the grain loading factor of 0.015 gr/acf, used in Permit No. PSD-

OK-61, except for P-209 (Kiln Dust Tank No. 3), which utilizes the applicant’s factor of 0.01

gr/acf proposed during the comment period of Permit No. 98-170-TV, and except P-52 (CKD

Disposal - Dust/water blender) which utilizes the limit proposed in the application for Permit No.

98-170-TV based on material throughput. DEQ agrees that a grain loading factor of 0.005 gr/acf

for P-209 (Kiln Dust Tank No. 3) submitted in the application for Permit No. 98-170-C (M-4) is

unreasonably low.

EUG 1c – Subpart LLL: Finish Mill No. 1. This emissions group (constructed in pre-1974 with

a Tailings Airslide constructed in 1994) lost grandfathered status as a result of the Airslide installed

in 1994. Additionally, the installation of Kiln Dust Tank No. 3 was evaluated through Permit No.

98-170-C (M-4) as a modification to Finish Mill No. 1. It had no numerical limits for particulate

matter assigned in permits issued before Permit No. 98-170-TV. Permit No. 98-170-TV permit

assigned limits calculated from a grain loading factor of 0.01 gr/acf, as proposed in the application

which is more stringent than that used in Permit No. PSD-OK-61, except for P-62 which utilizes

the limit proposed in the application based on material throughput.

EUG 1c – Subpart LLL: Finish Mill No. 2. This emissions group (constructed in pre-1974 and

1980) lost grandfathered status as a result of the construction of equipment after permitting rules

were promulgated. Limits for P-62, P-262, P-263, and P-264 utilize the limits proposed in the

application for Permit No. 98-170-TV based on material throughput.

EUG 1c – Subpart LLL: Finish Mill No. 3. This emissions group (constructed in 1960, pre-1974,

1975 and 2009) lost grandfathered status through Applicabiity Determination No. 98-170-AD (M-

7), which allowed the work to be performed as a minor modification. Although limits were not

imposed, Buzzi was to submit an application to permit these emissions points. Permit No. 98-170-

TV assigned limits calculated from a grain loading factor of 0.01 gr/acf for P-69 as submitted in

the application for Permit No. 98-170-TV, which is more stringent than that used in Permit No.

PSD-OK-61, and assigned limits calculated from a grain loading factor of 0.015 gr/acf, as used in

Permit No. PSD-OK-61, for P-70. Permit No. 98-170-TV (M-12) combined P-69 and P-70 into

one emissions point for a combined emissions limit of 19 TPY PM10. However, Buzzi contends

that was an error, and states that P-69 and P-70 have always been two separate emissions points

served by separate baghouses, and that the two baghouses were replaced by ones having lower

discharge rates and a grain loading factor of 0.01 gr/acfm each. The limits established in this

permit for the two emissions points are 8.8 TPY PM10 for P-69 and 14.3 TPY PM10 for P-70. A

third emissions point and baghouse for P-70 which serves E-130 and E-131 was left out of Permit

No. 98-170-TV (M-12). It is listed as a separate point in that permit but with no emissions. This

permit adds 0.5 TPY PM10 for that point. Limits for P-62, P-266, P-267, P-268, and P-269 utilize

the limits proposed in the application for Permit No. 98-170-TV based on material throughput.


EUG 1c – Subpart LLL: Finish Silos – Group 3. This emissions group (constructed in 1980) had

no numerical limits for particulate matter assigned in permits previous to Permit No. 98-170-TV.

Permit No. 98-170-TV assigned limits calculated from a grain loading factor of 0.015 gr/acf, used

in Permit No. PSD-OK-61. Applicability Determination No. 98-170-AD (M-11) addressed

replacing the one baghouse numbered P-87 with two baghouses numbered P-87a and P-87b.

Emissions are based on a grain loading factor of 0.003 gr/acf.

EUG 1c – Subpart LLL: Packhouse. This emissions group (constructed in pre-1974 and 1988)

lost grandfathered status as a result of the construction of equipment after permitting rules were

promulgated. Permit No. 98-170-TV assigned limits calculated from a grain loading factor of

0.015 gr/acf, used in Permit No. PSD-OK-61. Limits for P-93 and P-94 utilize the limits proposed

in the application for Permit No. 98-170-TV based on material throughput.

The following table lists each emissions limit in tons per year for each emissions unit group

discussed above and the basis for calculating actual emissions to determine compliance with the

annual limits.

EUG 1c – Subpart LLL Raw Mills, Finish Mills, Storage, Conveyors, Bagging/Bulk Loading/Unloading

EMISSION SOURCE/EU/EP Compliance

Basis

Controls

(%)

Emission

Factor

PM10

(TPY)

Raw Mill No.1 Raw Material Hopper 101 / E-270 / P-254

Throughput (tons) None lbs/ton 2.6



Raw Material Hopper 104 / E-254 / P-257 Raw Material Hopper 105 / E-255 / P-258

Raw Material Hopper 106 / E-256 / P-259 Raw Mill Material Bins/ E-34/ P-60 Shared w/Raw Mill No. 2


Discharge (acf)

Cyclones/Dust Collector (99 )

Baghouse (95)

gr/acf 24 (1)

Mill Feed Conveyor Belt/ E-36/ P-26


Classifier/E-38/ P-26

Raw Mill Pump/ E-40/ P-26


#1 Raw Mill (E-41, P-108) Mill End Dust

Collector (99) gr/acf 2.6

Raw Mill No. 2

Raw Mill Material Bins/ E-34/ P-60 Throughput 1-Wall Shed (24) lbs/ton 7.3

Raw Material Weigh Feeders/ E-44/ Mill Feed Conveyor

Belt E-45/P-28/ Bucket Elevator/ E-46/ P-28 Discharge (acf) Baghouse (95) gr/acf 5


Classifier/E-47/ P-29 Discharge (acf) Baghouse (95) gr/acf 30


#2 Raw Mill (E-50, P-109) Discharge (acf) Mill End Dust


Kiln Feed/Blending All EUs served by P-30 Discharge (acf) Baghouse (95) gr/acf 13

Kiln Feed Storage Silo/ E-56/ P-31 Discharge (acf) Baghouse (95) gr/acf 4

Tire Derived Fuel Handling No or only trace emissions expected.





Basis

Controls

(%)

Emission

Factor

PM10

(TPY)

Grandfathered from

Subpart LLL but not

SC 19: All EUs

NA NA NA


Grandfathered from

Subpart LLL but not

SC 19: All EUs

NA NA NA

Kiln No. 3 Support Equipment Kiln Feed Tank, 22-inch dia./ E-96/ P-57

Discharge (acf) Baghouse (95)

Dust Collectors (95)

gr/acf

5

2 – Airslides, 12-inch/ E-97/ P-57

Feed Hopper for 031-3150 & 031-3694/ E-98/ P-57

Cyclone Dust Bucket Elevator (Kiln 3)/ E-105/ P-57


Drag Chain Conveyor (clinker), 12-inch/ E-101/ P-43 Discharge (acf) ESP gr/acf

Included in

clinker

cooler

emissions

Clinker Bucket Elevator/ E-102/ P-60 Throughput (tons) Enclosed (60) lbs/ton 13


Baghouse Dust Pump (Kiln 3)/ E-106, P-58 Discharge (acf) Baghouse (95) gr/acf

Included in

kiln

emissions

#16 Screw Conveyor, 16-inch/ E-79/ P-42 Discharge (acf) Cyclone/

Dust Collector (99) gr/acf

Included in

kiln

emissions


Discharge (acf)

Cyclone/ Dust Collector (95)

gr/acf

2.6

Dust Tank Bucket Elevator/ E-82/ P-48



Kiln Dust Pump/ E-86/ P-48

FK Pump (Replaced Kiln Dust Conveying Pods in

2004)/ E-87/ P-48


Baghouse (95) gr/acf

1.7


CKD Truck Loadout/ E-90/ P-51

Kiln Dust Storage Tank#3 / E-209 / P-209 Discharge (acf) Dust Collector

(99.99) gr/acf 1

Finish Mill No. 1 3 - Clinker/Gypsum Bins/ E-108/ P-60 Throughput (tons) 1-Wall Shed (24) lbs/ton 44

3 - Weigh Feeders/ E-109/ P-66 Discharge (acf) Baghouse (99) gr/acf 0.5



Discharge (acf)

Baghouse (99)

gr/acf

3.8

Cement Coolers #1 and #2/ E-115/ P-63


Finish Mill Pump/ E-117/ P-63


16-foot Classifier, Sturtevant/ E-114/ P-66 Cyclone/

Dust Collector (99) 9

Tailings Airslide/ E-114a/ P-66

#1 Finish Mill, KVS/ E-111/ P-64 Cyclone/Dust Collector (99)

6.8 19-inch Airslide/ E-111a/ P-64




Basis

Controls

(%)

Emission

Factor

PM10

(TPY)

Finish Mill No. 2

Overhead Crane, E-33/ P-60 (Used for Clinker and

Finish Mills) Throughput (tons) 3-wall Shed (40) lbs/ton 20


E-119/ P-60 Throughput (tons) 1-Wall Shed (24) lbs/ton 67

Weigh Feeders/ E-120/ P-67



gr/acf

9





16-foot Classifier, Sturtevant/ E-126/ P-67

Cement Cooler/ E-126b/ P-67


Finish Mill #2 additives hopper and feeder / E-259 / P-

262

Throughput (tons)

4-Wall Building

Control efficiency

accounted for in derivation of

emissions factor by

using reduced wind speed.

lbs/ton 0.07


262

Finish Mill #2 additives feeder to feed conveyor / E-260

/ P-262


/ P-262

Finish Mill No. 3 3 - Clinker/Limestone/Gypsum Bins/ E-129/ P-60 Throughput (tons) 1-Wall Shed (24) lbs/ton 82

#3 Finish Mill/ E-132/ P-69 Discharge (acf) Baghouse (99) gr/acf 8.8

Tailings Airslide/ E-135a/ P-69 Discharge (acf) Baghouse (99) gr/acf

Weigh Feeders/ E-130/ P-70 Discharge (acf) Baghouse (99) gr/acf 0.5


19-inch Airslide/ E-132a/ P-270 Discharge (acf) Baghouse (99) gr/acf 0.56


Discharge (acf)

Baghouse (99)

gr/acf 14.3

19-inch Airslide/ E-134/ P-70 Baghouse (99)

Classifier, , 18-foot/ E-135/ P-70 Baghouse (99)

Cement Cooler/ E-135b/ P-70 Baghouse (99)


Finish Mill Pump, 125-hp, 8H F-K/ E-137/ P-70 Baghouse (99)


262

Throughput (tons)

4-Wall Building

Control efficiency accounted for in

derivation of

emissions factor by using reduced wind

speed.

lbs/ton 0.07


262


/ P-262


/ P-262

Finish Silos - Group 1 8 - Cement Storage Silos/ E-138/ P-71/72/73

(3 baghouses)

Grandfathered from

Subpart LLL but not

SC 19: All EUs

Dust Collectors (95) gr/acf 25.9(1)

each

Fringe Bin Pump/ E-139/ P-74 Baghouse (95) gr/acf 19.2(1)

12-inch Airslide/ E-140/ P-75 Baghouse (95) gr/acf 58.5(1)

Silo/Packhouse Bucket Elevator/ E-147/ P-75



58.5(1)

Loadout Spout/ E-144/ P-76

Truck Loading Bucket Elevator/ E-143/ P-76

Rail Loading Bucket Elevator/ E-145/ P-77 Baghouse (95) gr/acf 58.5(1)




Basis

Controls

(%)

Emission

Factor

PM10

(TPY)


NW Truck & Rail Loadout/ E-146/ P-78 Baghouse (95) gr/acf 48.4(1)


baghouses)

Grandfathered from

Subpart LLL but not

SC 19: All EUs



East Rail Aux Bucket Elevator/ E-158/ P-82






East Rail Loadout Spout/ E-157/ P-85 Discharge (acf) Baghouse (95) gr/acf 1

Finish Silos - Group 3 Cement Storage Silo 15/ E-160a/ P-87a

Discharge (acf)

Baghouse (99.997) gr/acf 0.4

Cement Storage Silo 16/ E-160b/ P-87b Baghouse (99.997) gr/acf 0.4

Loadout Spout/ E-161/ P-88 Baghouse (95) gr/acf 1

20-inch Airslide/ E-162/ P-89 Baghouse (95) gr/acf 1.4


Packhouse


Discharge (acf)

Baghouse (95) gr/acf 7

Portland Packer Bucket Elevator/ E-165/ P-90

Portland Packer/ E-166/ P-90


Packhouse Fringe Bin/ E-172/ P-90

Packer Bins C and D/ E-168/ P-91


Masonry Packer Bucket Elevator/ E-169/ P-91

Masonry Packer/ E-170/ P-91



Chain Conveyors (Bag Drop)/ E-173/ P-93 Throughput (tons) Enclosed (60) lbs/ton

8

Bag Palletizer/ E-174/ P-94 17 (1) lb/hr limit of total particulate matter from Subchapter 19.

EUG 1d - Existing Raw Material Dryer Furnaces EMISSION SOURCE/EU/EP NOX

(TPY)

CO

(TPY)

VOC

(TPY)

PM/PM10

(TPY)

SO2

(TPY)

Raw Mills

Hot Air Furnace/ E-39/ P-26 (1),

20 MMBTUH

8.6 7.2 0.47 0.65 0.052

Hot Air Furnace/ E-48/ P-29 (1),

30 MMBTUH

13 11 0.71 0.98 0.077

Total 21.6 18.2 1.18 1.63 0.129

1 – Emissions points P-26 and P-29 are emissions points for the raw mill classifiers. PM in this table are

combustion PM. PM emissions from non-combustion materials are included in EUG – 1c for emissions points P-26

and P-29. PM filterable emission factor of 1.9 lb/MMscf used. Per AP-42 Section 1.4 all PM is assumed to be less

than 1 micron so PM10 equals PM.




Basis

Controls

(%)

Emiss.

Factor

PM10

(TPY)


Clinker Storage Pile – Outside/ E-104/ P-61 Throughput

(tons)

None lbs/ton 0.2

Clinker Storage Hall/ E-103/ P-60 1-Wall Shed

(24) lbs/ton 22.2

Subpart OOO Non-Metallic Mineral Processing. The #5 Storage Hall Tripper Conveyor Belt, 36-

inch/ E-28/ P-12a (constructed in 1984) had no numerical limits for particulate matter assigned in

permits issued before Permit No. 98-170-TV. Permit No. 98-170-TV assigned the limits proposed

in the application for Permit No. 98-170-TV based on material throughput.



Basis

Controls

(%)

Emiss.

Factor

PM10

(TPY)

#5 Storage Hall Tripper Conveyor Belt, 36-inch/

E-28/ P-12a

Throughput (tons)

1-Wall Shed (24)

lbs/ton

13

Belt Conveyor BC1, 36-inch, Hopper

Gathering / E-257 / P-260 None

1.4

Belt Conveyor BC2, 36-inch, Additive

Transfer / E-258 / P-261 1.4

OAC 252:100-25 Non-Metallic Mineral Processing. This emissions group was constructed in

1960, pre-1974, 1980, 1981, and 1986. Emission points P-8, P-9, and P-10 are grandfathered and

have no emissions limits. Emission point P-11 likely lost grandfathered status when the newer

equipment was constructed in 1980 and 1981. No emissions limits were found for anything in this

group of emissions units during the review of Permit No. 98-170-TV. For P-11, E-6/P-5, P-7 and

P-21, Permit No. 98-170-TV assigned limits calculated from a grain loading factor of 0.015 gr/acf,

used in Permit No. PSD-OK-61, except for P-6 and E-10/P-7, which utilizes grain loading factors

of 0.01 gr/acf and 0.0022 gr/acf, respectively, as submitted in the Permit No. 98-170-TV

application. Limits for E-7/P5, E5/P-5, E-27/P-12b, P-21, P-22, P-23, P-25, and P-94 utilize the

limits proposed in the application for Permit No. 98-170-TV based on material throughput. The

Raw Material Hoppers, P-254 through P-256 (constructed in 2009), were installed under

Applicability Determination No. 98-170-AD (M-7), which allowed the work to be performed as a

minor modification. They are not affected equipment under NSPS OOO. Permit No. 98-170-TV

assigned limits based on emissions calculations proposed in Applicability Determination No. 98-

170-AD (M-7), based on material throughput. For E-27/P-12b and E-27/P18, the A-Frame Tripper

Belt Conveyor and the A-Frame storage pile, Buzzi installed a baghouse to control emissions from

the drop point of the belt conveyor in 2005. Previous permits had only accounted for the A-Frame

storage pile. For this permit, Buzzi requested adding the A-Frame Tripper Belt Conveyor

baghouse and is willing to take a material throguhput limit of 1,249,135 TPY to keep total

combined emissions of these two emissions points below the currently permitted level of 19 TPY.

This throughput is consistent with the throughput of the #4 Crossover Belt Conveyor [36-inch/ (E-

21, P-11)] that feeds the A-Frame Tripper Belt Conveyor. The new limits of 12 TPY for the

storage pile and 1.4 TPY, will total of 13.4 TPY.


EUG 3 – OAC 252:100-25 Non-Metallic Mineral Processing EMISSION SOURCE/EU/EP Compliance

Basis

Controls

(%)

Emiss.

Factor

PM10

(TPY)


Discharge (acf)

Baghouse &

Foam Spray (95) gr/acf 6

Wobbler Feeder (E-6, P-6) *

Wobbler Fines Belt Conveyor (E-7, P-6) *

Primary Crusher, 6185/ (E-8, P-6)


Discharge (acf)

Baghouse (95)

gr/acf 6.5 Primary Vibrating Screen (E-10, P-7)


Load Hopper (E-12, P-9)

Grandfathered except for SC 19

Foam Spray (50) lbs/ton 63.0(1)

Wobbler Feeder (E-13, P-8) Baghouse &

Foam Spray (95) gr/acf 63.0(1)

Secondary Crusher, 05NC/ (E-15, P-8) Baghouse (95) gr/acf 63.0(1)

#1 Secondary Belt Conveyor, 30-inch (E-16, P-8) Baghouse (95) gr/acf 72.1(1)


Secondary Vibrating Screen (E-18, P-10) Baghouse (95) gr/acf 72.1(1)

#3 Primary Belt Conveyor, 30-inch (E-19, P-11a)

Discharge (acf)

Baghouse (95)

gr/acf 3.43

#3 Secondary Belt Conveyor, 36-inch/ (E-20, P-11a) Baghouse (95)

#4 Crossover Belt Conveyor, 36-inch/ (E-21, P-11b) Baghouse (95) 1.01


12b Discharge (acf) Baghouse (95) gr/acf 1.4

A-Frame Storage E-27a/P-18 Throughput (tons) 2-Wall

Enclosure (36) lbs/ton 12

6 - Belt Conveyors (3 Working)/ E-30/ P-21 Throughput (tons) Foam and Enclosure lbs/ton 0.25

#1 Reclaim Belt Conveyor, 30-foot/ E-31/ P-22 Throughput (tons) Enclosure and Foam

(60) lbs/ton 6

#2 Reclaim Belt Conveyor, 30-foot/ E-32/ P-23 Throughput (tons) Enclosure and Foam

(60) lbs/ton 6

#3 Reclaim Belt Conveyor, 30-foot/ E-32a/ P-25 Throughput (tons) Enclosure and Foam

(60) lbs/ton 6

None of these emissions units had numerical limits for particulate matter assigned in permits issued

before Permit No. 98-170-TV. Permit No. 98-170-TV assigned the limits proposed in the

application based on material throughput, except for P-36 and P-38, which were assigned limits

calculated from a grain loading factor of 0.015 gr/acf, used in Permit No. PSD-OK-61, a more

stringent limit than the proposed 0.02 gr/acf.

EUG 4 - Subpart Y Coal Handling EMISSION SOURCE/EU/EP Compliance

Basis

Controls

(%)

Emiss.

Factor

PM10

(TPY)

Coal Handling

Coal Load Hopper/ E-59/ P-34 Throughput (tons)

None lbs/ton

0.085

Coal Belt Conveyor #1/ E-60/ P-35 None 0.034

Coal Crusher/ E-61/ P-36 Throughput (tons) Enclosed (60) lbs/ton 0.1

Coal Belt Conveyor #2, 24-inch/ E-62/ P-37 Throughput (tons) Enclosed (60) lbs/ton 0.1

Coal Bunker/ E-63/ P-38 Throughput (tons) Enclosed (60) lbs/ton 0.1

#1 Kiln

Coal Weigh Feeder/ E-64/ P-39 Throughput (tons)

Enclosed (60)

lbs/ton

0.04

Coal Mill, E-65/ P-42 Enclosed Included

with Kiln

#2 Kiln

Coal Weigh Feeder, 24-inch/ E-72/ P-45

Throughput (tons)

Enclosed (60)

lbs/ton

0.04


with Kiln

#3 Kiln

Coal Weigh Feeder, 24-inch/ E-94/ P-55 Throughput (tons) Enclosed (60) lbs/ton 0.06


EUG 4 - Subpart Y Coal Handling EMISSION SOURCE/EU/EP Compliance

Basis

Controls

(%)

Emiss.

Factor

PM10

(TPY)


with Kiln

EUG 5 – Fugitive PM Sources. The occurrence of fugitive emissions sources was inherent to the

construction of emissions units, which occurred from 1960 until recent. There were no emissions

limits for particulate matter assigned in permits issued prior to Permit No. 98-170-TV. This permit

assigns the limits proposed in the application for Permit No. 98-170-TV based on material

throughput for process-related emisisons. Applicability Determination No. 98-170-AD (M-6)

authorized an increase of the onsite solid fuel storage from the existing limits of 30,000 tons as

allowed by Permit No. 76-032-O (M-1), to a new limit of 50,000 tons. There was no change in

the fuel-burning, solid fuel delivery system, or any other equipment related to emissions at the

facility as a result of that modification. Storage of the stockpiled fuel is done outdoors and the

facility has the storage area available. The only change under Permit No. 98-170-TV was the size

of the storage stock pile and a small increase in the associated fugitive particulate matter (PM)

emissions. These limits were incorporated into Permit No. 98-170-TV.

EUG 5 – Fugitive PM Sources


Basis

Controls

(%)

Emiss.

Factor

PM10

(TPY)


Load Hopper (E-5, P-5) Throughput (tons) Foam Spray (50) lbs/ton 0.34


Gypsum Unloading (Belly Dumping)/ E-

22/ P-13

Throughput

(tons)

None

lbs/ton

4

Gypsum Pile/ E-23/ P-14 None 0.3

Iron Source Pile/ E-24/ P-15 None 0.2

Silica-Alumina Source Pile/ E-25/ P-16 1-Wall Shed (24) 0.80

Gypsum, Iron Ore Unloading – (hoppers

101 to 106)/E-26/ P-17 None 1.4


Material

Limestone Outside Storage/ E-29/ P-20 None 17


CKD Storage Pile/ E-93/ P-54 Throughput

(tons) None lbs/ton 0.1


Raw Material Storage Pile/ E-200/ P-200 Throughput None N/A 10

Coal Handling

Coal Pile/ E-57/ P-32 Throughput None lbs/ton 1.79

Haul Roads

Kiln Dust Reclaim System VMT

CKD Haul Roads/ E-92/ P-53 256.4 Water Spray (50) lbs/VMT 0.43

Coal Handling

Coal Haul Roads/ E-58/ P-33 Paved VMT None 4.34/0.87 0.99

Coal Haul Roads/ E-58/ P-33 Un-Paved VMT Water Spray (50) 14.37/4.54 1.3


SECTION V. INSIGNIFICANT ACTIVITIES

The insignificant activities identified and justified in the application are duplicated below. Records

are available to confirm the insignificance of the activities. Appropriate recordkeeping of activities

indicated below with “*” is specified in the Specific Conditions. Any Activity to which a State or

federal applicable requirement applies is not insignificant even if it is included on this list.

1. Space heaters, boilers, process heaters, and emergency flares less than or equal to 5 MMBTU/hr

heat input (commercial natural gas). None were identified, but some could be used in the future.

2. * Emissions from fuel storage/dispensing equipment operated solely for facility owned vehicles

if fuel throughput is not more than 2,175 gallons/day, averaged over a 30-day period. There is

one 1,000-gallon gasoline storage/dispensing tank having an approximate annual throughput of

3,036 gallons, which is used for facility vehicle fuel.

3. * Storage tanks with less than or equal to 10,000 gallon capacity that store volatile organic

liquids with a true vapor pressure less than or equal to 1.0 psia at maximum storage temperature.

There is one 550-gallon diesel fuel storage tank, one 8,000-gallon diesel fuel storage tank and

one 10,000-gallon diesel fuel storage tank at the facility used for facility vehicle fuel.

4. Cold degreasing operations utilizing solvents that are denser than air. There is one parts washer

in this category.

5. * Welding and soldering operations utilizing less than 100 pounds of solder and 53 tons per

year of electrodes.

6. * Torch cutting and welding of under 200,000 tons of steel fabricated per year

7. Hazardous waste and hazardous materials drum staging areas.

8. Sanitary sewage collection and treatment facilities other than incinerators and Publicly Owned

Treatment Works (POTW).

9. Hand wiping and spraying of solvents from containers with less than 1 liter capacity used for

spot cleaning and/or degreasing in ozone attainment areas. Not normally conducted but may

be used in the future.

SECTION VI. OKLAHOMA AIR POLLUTION CONTROL RULES

OAC 252:100-1 (General Provisions) [Applicable]

Subchapter 1 includes definitions but there are no regulatory requirements.


OAC 252:100-2 (Incorporation by Reference) [Applicable]

This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal

Regulations listed in OAC 252:100, Appendix Q. These requirements are addressed in the

“Federal Regulations” section.

OAC 252:100-3 (Air Quality Standards and Increments) [Applicable]

Subchapter 3 enumerates the primary and secondary ambient air quality standards and the

significant deterioration increments. At this time, all of Oklahoma is in “attainment” of these

standards.

OAC 252:100-5 (Registration, Emissions Inventory and Annual Operating Fees) [Applicable]

Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission

inventories annually, and pay annual operating fees based upon total annual emissions of regulated

pollutants. Emission inventories were submitted and fees paid for previous years as required.

OAC 252:100-8 (Permits for Part 70 Sources) [Applicable]

Part 5 includes the general administrative requirements for Part 70 permits. Any planned changes

in the operation of the facility that result in emissions not authorized in the permit and that exceed

the “Insignificant Activities” or “Trivial Activities” thresholds require prior notification to AQD

and may require a permit modification. Insignificant activities refer to those individual emission

units either listed in Appendix I or whose actual calendar year emissions do not exceed the

following limits.

5 TPY of any one criteria pollutant

2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAP or 20% of

any threshold less than 10 TPY for a HAP that the EPA may establish by rule

Emission limitations and operational requirements necessary to assure compliance with all

applicable requirements for all sources are taken from the Title V operating permit application and

existing permits for the facility, or developed from the applicable requirement.

OAC 252:100-9 (Excess Emissions Reporting Requirements) [Applicable]

Except as provided in OAC 252:100-9-7(a)(1), the owner or operator of a source of excess

emissions shall notify the Director as soon as possible but no later than 4:30 p.m. the following

working day of the first occurrence of excess emissions in each excess emission event. No later

than thirty (30) calendar days after the start of any excess emission event, the owner or operator of

an air contaminant source from which excess emissions have occurred shall submit a report for

each excess emission event describing the extent of the event and the actions taken by the owner

or operator of the facility in response to this event. Request for mitigation, as described in OAC

252:100-9-8, shall be included in the excess emission event report. Additional reporting may be

required in the case of ongoing emission events and in the case of excess emissions reporting

required by 40 CFR Parts 60, 61, or 63.

OAC 252:100-13 (Open Burning) [Applicable]

Open burning of refuse and other combustible material is prohibited except as authorized in the

specific examples and under the conditions listed in this subchapter.


OAC 252:100-17 (Incinerators) [Not Applicable]

Part 3 applies to incinerators not subject to New Source Performance Standards (NSPS) or any

other Parts in this Subchapter. From Subchapter 1, “Incinerator" means a combustion device

specifically designed for the destruction, by high temperature burning, of solid, semi-solid, liquid,

or gaseous combustible wastes and from which the solid residues contain little or no combustible

material”.

The kilns and wastes burned in them do not meet the definition of incinerator.

Part 5 applies to municipal waste combustors. The kilns do not burn municipal waste but cement

kilns firing MSW are not subject to this Part.

Part 7 applies to hospital, medical, and infectious waste incinerators. The kilns do not burn any of

these wastes, but cement kilns firing hospital waste and/or medical/infectious waste are not subject

to this Part.

Part 9 applies to commercial and industrial solid waste incineration (CISWI) units for which

construction was commenced on or before November 30, 1999. Cement kilns that do not burn

solid waste and elect to be regulated under 40 CFR Part 63, Subpart LLL, (National Emission

Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry) are not

subject to this Part.

Part 11 applies to biomedical waste incinerators. The kilns do not burn biomedical waste, so they

are not subject to Part 11.

OAC 252:100-19 (Particulate Matter (PM)) [Applicable]

Section 19-4 regulates emissions of PM from the combustion of fuel in any new and existing fuel-

burning unit, with emission limits based on maximum design heat input rating. Fuel-burning unit

is defined in OAC 252:100-19 as any internal combustion engine or gas turbine, or other

combustion device used to convert the combustion of fuel into usable energy. Thus, the space

heaters and the hot air furnaces are subject to the requirements of this subchapter.


Date

Heat Input Rating

(MMBTUH)

Space Heaters

Various Various <5

Raw Mills

Hot Air Furnace/ E-39/ P-26 1961 20

Hot Air Furnace/ E-48/ P-29 7/1/1980 30

Appendix C specifies a PM emission limitation of 0.60 lb/MMBTU, 0.51 lb/MMBTU, and 0.46

lb/MMBTU for equipment having heat input ratings of 10 MMBTUH or less, 20 lb/MMBTUH,

and 30 lb/MMBTUH respectively. AP-42 (7/98) Table 1.4-1 lists natural gas TPM emissions to be

7.6 lbs/million scf or about 0.0076 lbs/MMBTU, which is in compliance.

Section 19-12 limits particulate emissions from new and existing directly fired fuel-burning units

and emission points in an industrial process based on process weight rate, as specified in Appendix

G. As shown in the following table, all emission points are in compliance with Subchapter 19

based on a comparison of the Appendix G allowable emission rates to the potential to emit as

calculated in the memorandum.


EMISSION SOURCE AND OPERATION

Maximum

Process Rate

(TPH)

PM PTE

Controlled

(lb/hr)

App “G”

Limit

(lb/hr)

EUG 1A – KILNS 0.000

Kiln No. 1 (E-67, P-42) 25 (clinker

output) 12 35


output) 12 35


output) 20 43

DSI System Silo (E-272, P-42/P-58) 24 0.03* 34.5

EUG 1B –CLINKER COOLERS

Clinker Cooler No. 1 (E-68, P-43)/ 25 15 35



EUG 1C – SUBPART LLL

Raw Mill No.1


20 1.3 31






Raw Mill Material Bins/ E-34/ P-60 250 4.8 72

Raw Material Weigh Feeders/ E-35/ P-26 126

5.4

64

Mill Feed Conveyor Belt/ E-36/ P-26 207 59

Bucket Elevator/ E-37/ P-26 600 71

Classifier/E-38/ P-26 110 52

Raw Mill Pump/ E-40/ P-26 110 52

19-inch Airslide/ E-42/ P-26 480 68

#1 Raw Mill / (E-41, P-108) 110 0.6 52

Raw Mill No. 2

Raw Mill Material Bins/ E-34/ P-60 Common to

Raw Mill No. 1

Raw Material Weigh Feeders/ E-44/ P-28 332

1

64




Classifier/E-47/ P-29 95 7

51

Raw Mill Pump/ E-49/ P-29 110 52

#2 Raw Mill / (E-50, P-109) 95 0.6 51

Kiln Feed/Blending

3 - Blending Silos/ E-52/ P-30 300

3

63



Blend Pumps (3)/ E-55/ P-30 411 67



Maximum

Process Rate

(TPH)

PM PTE

Controlled

(lb/hr)

App “G”

Limit

(lb/hr)

Kiln Feed Storage Silo/ E-56/ P-31 45 1 44


Kiln Feed Tank/ E-66/ P-41 48 0.8

44

Feed Tank Bucket Elevator (Kiln 1)/ E-71/ P-41 60 46

Drag Chain Conveyor (clinker), 12-inch/ E-69/ P-43 25

Included in

clinker

cooler

emissions

35

Clinker Bucket Elevator (clinker)/ E-70/ P-60 60 4.2 46


Kiln Feed Tank/ E-74/ P-46 48 0.8 44

Feed Tank Bucket Elevator (Kiln 2)/ E-81/ P-42 56

Included in

kiln

emissions

46

Drag Chain Conveyor, 12-inch (clinker)/ E-77/ P-43 25

Included in

clinker

cooler

emissions

35

Clinker Bucket Elevator (clinker)/ E-78/ P-60 60 4.2 46


Kiln Feed Tank, 22-inch dia./ E-96/ P-57 65

1

47

2 – Airslides, 12-inch/ E-97/ P-57 200 59

Feed Hopper for 031-3150 & 031-3694/ E-98/ P-57 200 59

Cyclone Dust Bucket Elevator (Kiln 3)/ E-105/ P-57 100 51

12-inch Airslide/ E-107/ P-57 200 59

Drag Chain Conveyor (clinker), 12-inch/ E-101/ P-43 40

Included in

clinker

cooler

emissions

43

Clinker Bucket Elevator/ E-102/ P-60 50 3.5 45


Baghouse Dust Pump (Kiln 3)/ E-106, P-58 25

Included in

kiln

emissions

35

#16 Screw Conveyor, 16-inch/ E-79/ P-42 14

Included in

kiln

emissions

24

#17 Screw Conveyor, 16-inch/ E-80/ P-48 38

0.6

42

Dust Tank Bucket Elevator/ E-82/ P-48 100 51

Kiln Dust Storage Tank #1, 14-foot dia./ E-83/ P-48 30 40


Kiln Dust Pump/ E-86/ P-48 65 47

FK Pump (Replaced Kiln Dust Conveying Pods in 2004)/ E-

87/ P-48 50 45

Kiln Dust Storage Tank #2, 30-foot dia./ E-88/ P-51 30 0.4 40



Maximum

Process Rate

(TPH)

PM PTE

Controlled

(lb/hr)

App “G”

Limit

(lb/hr)


CKD Truck Loadout/ E-90/ P-51 150 55

Kiln Dust Storage Tank#3 / E-209 / P-209 8 0.3 17

Finish Mill No. 1

3 - Clinker/Gypsum Bins/ E-108/ P-60 88 12 50

3 - Weigh Feeders/ E-109/ P-66 88 0.1

50


Bucket Elevator/ E-113/ P-63 350

0.9

65

Cement Coolers #1 and #2/ E-115/ P-63 35 41

12-inch Airslide/ E-116/ P-63 200 59

Finish Mill Pump/ E-117/ P-63 35 41


16-foot Classifier, Sturtevant/ E-114/ P-66 350 2

65

Tailings Airslide/ E-114a/ P-66 300 63

#1 Finish Mill, KVS/ E-111/ P-64 35 2

41

19-inch Airslide/ E-111a/ P-64 300 63

Finish Mill No. 2

Overhead Crane, 60-foot span/ E-33/ P-60 (Used for Clinker

and Finish Mills) 162 8 56


E-119/ P-60 135 18 54

Weigh Feeders/ E-120/ P-67 135

2

54


#2 Finish Mill, KVS/ E-122/ P-67 35 41

19-inch Airslide/ E-124/ P-67 480 68


16-foot Classifier, Sturtevant/ E-126/ P-67 350 65

Cement Cooler/ E-126b/ P-67 35 41

Finish Mill Pump/ E-128/ P-67 35 41

Finish Mill #2 additives hopper and feeder / E-259 / P-262

95 0.03 51

Finish Mill #2 additives hopper and feeder / E-261 / P-262

Finish Mill #2 additives feeder to feed conveyor / E-260 / P-

262


262

Finish Mill No. 3

3 - Clinker/Limestone/Gypsum Bins/ E-129/ P-60 165 22 56

#3 Finish Mill/ E-132/ P-69 55 2

45

Tailings Airslide/ E-135a/ P-69 450 68

Weigh Feeders/ E-130/ P-70 165 0.1

56


19-inch Airslide/ E-132a/ P-270 480 0.13 68


69

19-inch Airslide/ E-134/ P-70 480 68



Maximum

Process Rate

(TPH)

PM PTE

Controlled

(lb/hr)

App “G”

Limit

(lb/hr)

Classifier, 18-foot/ E-135/ P-70 500 69

Cement Cooler/ E-135b/ P-70 55 45


Finish Mill Pump, 125-hp, 8H F-K/ E-137/ P-70 55 45

Finish Mill #3 additives hopper and feeder / E-263 / P-262 0.6

0.03

2.9

Finish Mill #3 additives hopper and feeder / E-264 / P-262 0.08 0.75


262 0.6 2.9


262 0.08 0.75


8 - Cement Storage Silos/ E-138/ P-71/72/73 125 4.6 53

Fringe Bin Pump/ E-139/ P-74 10 0.6 19

12-inch Airslide/ E-140/ P-75 200 0.4

59

Silo/Packhouse Bucket Elevator/ E-147/ P-75 150 55

12-inch Airslide/ E-141/ P-76 200

0.8

59

Loadout Spout/ E-144/ P-76 540 70

Truck Loading Bucket Elevator/ E-143/ P-76 150 55

Rail Loading Bucket Elevator/ E-145/ P-77 150 0.4

55

12-inch Airslide/ E-142/ P-77 200 59

NW Truck & Rail Loadout/ E-146/ P-78 75 0.3 48


11 - Cement Storage Silos/ E-150/ P-80/P-81 125 3.1 53

12-inch Airslide/ E-151/ P-82 200 0.8

59

East Rail Aux Bucket Elevator/ E-158/ P-82 200 59

12-inch Airslide/ E-152/ P-83 200

0.8

59

Truck Loading Bucket Elevator/ E-154/ P-83 200 59


Rail Loading Bucket Elevator/ E-156/ P-84 200 0.8

59

12-inch Airslide/ E-153/ P-84 200 59

East Rail Loadout Spout/ E-157/ P-85 180 0.3 57


Cement Storage Silo 15/ E-160a/ P-87a 85

0.1 50

Cement Storage Silo 16/ E-160b/ P-87b 0.1

Loadout Spout/ E-161/ P-88 540 0.3 70

20-inch Airslide/ E-162/ P-89 480 0.4

68


Packhouse

Packer Bins A and B/ E-164/ P-90 105

2

52

Portland Packer Bucket Elevator/ E-165/ P-90 100 51

Portland Packer/ E-166/ P-90 68 47

10-inch Airslide/ E-167/ P-90 105 52



Maximum

Process Rate

(TPH)

PM PTE

Controlled

(lb/hr)

App “G”

Limit

(lb/hr)

Packhouse Fringe Bin/ E-172/ P-90 5 12

Packer Bins C and D/ E-168/ P-91 105

2

52

Masonry Packer Bucket Elevator/ E-169/ P-91 100 51

Masonry Packer/ E-170/ P-91 68 47

10-inch Airslide/ E-171/ P-91 105 52

Packhouse Fringe Bin/ E-172/ P-91 5 12

Chain Conveyors (Bag Drop)/ E-173/ P-93 24 2 34

Bag Palletizer/ E-174/ P-94 48 5 44

EUG 2 – SUBPART OOO NON-METALLIC

MINERAL PROCESSING


E-28/ P-12a 252 6.1 61

Belt Conveyor BC1, 36-inch, Hopper Gathering / E-257 / P-

260 90 0.7 40

Belt Conveyor BC2, 36-inch, Additive Transfer / E-258 / P-

261 90 0.7 40

EUG 3 – OAC 252:100-25 Non-Metallic Mineral

Processing

Load Hopper to Wobbler Feeder (E-5, P-6) 600

1

71

Wobbler Feeder (E-6, P-6) 600 71

Wobbler Fines Belt Conveyor (E-7, P-6) 1,000 78

Primary Crusher, 6185/ (E-8, P-6) 600 71


Primary Vibrating Screen (E-10, P-7)


1,000

2

78

1,000 78

750 74

Load Hopper (E-12, P-9) 300 0.5 63

Wobbler Feeder (E-13, P-8) 300

2

63

Secondary Crusher, 05NC/ (E-15, P-8) 300 63

#1 Secondary Belt Conveyor, 30-inch (E-16, P-8) 650 72

#2 Secondary Belt Conveyor, 24-inch (E-17, P-8) 360 65

Secondary Vibrating Screen (E-18, P-10) 650 0.27 72

#3 Primary Belt Conveyor, 30-inch (E-19, P-11a) 765 0.78

74

#3 Secondary Belt Conveyor, 36-inch/ (E-20, P-11a) 550 70

#4 Crossover Belt Conveyor, 36-inch/ (E-21, P-11b) 1,000 0.23 78

A-Frame Storage E-27a/P-18 251 10 61

#5 A-Frame Tripper Belt Conveyor, 30-inch/ E-27/ P-12b 251 0.3 61

6 - Belt Conveyors (3 Working)/ E-30/ P-21 750 0.9 74

#1 Reclaim Belt Conveyor, 30-foot/ E-31/ P-22 567 14 70

#2 Reclaim Belt Conveyor, 30-foot/ E-32/ P-23 652 16 72

#3 Reclaim Belt Conveyor, 30-foot/ E-32a/ P-25 652 16 72

EUG 4 - SUBPART Y COAL HANDLING

Coal Handling

Coal Load Hopper/ E-59/ P-34 277 0.88 62



Maximum

Process Rate

(TPH)

PM PTE

Controlled

(lb/hr)

App “G”

Limit

(lb/hr)

Coal Belt Conveyor #1/ E-60/ P-35 277 0.35 62

Coal Crusher/ E-61/ P-36 27 0.2 37

Coal Belt Conveyor #2, 24-inch/ E-62/ P-37 297 2 63

Coal Bunker/ E-63/ P-38 27 0.2 37

#1 Kiln

Coal Weigh Feeder/ E-64/ P-39 9 0.07 18

Coal Mill, E-65/ P-42 6 Included in

Kiln Stack 14

#2 Kiln

Coal Weigh Feeder, 24-inch/ E-72/ P-45 9 0.07 18


Kiln Stack 14

#3 Kiln

Coal Weigh Feeder, 24-inch/ E-94/ P-55 9 0.07 18


Kiln Stack 14

* Based on unloading 24 tons of sorbent to the silo in 1 hour:

0.003gr/acfm x 1,304 acfm x 1 lb/7,000 grains x 60 min/hour.

OAC 252:100-25 (Visible Emissions and Particulates) [Applicable]

No discharge of greater than 20% opacity is allowed except for short-term occurrences that consist

of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such

periods in any consecutive 24 hours. In no case shall the average of any six-minute period exceed

60% opacity.

The following emissions units are subject to Subchapter 25:

EUG 3 - Non-NSPS Non-Metallic Mineral Processing Equipment.

The permit will require maintenance of PM controls to ensure the opacity standard is met.

EUG 5 - Fugitive PM Sources

The following emissions units are not subject to Subchapter 25 since they are subject to an opacity

limitation of an NSPS or NESHAP subpart:

EUG 1a - Kilns

EUG 1b - Clinker Coolers

EUG 1c - Subpart LLL Affected Sources other than Kilns; Clinker Coolers; New and

Reconstructed Raw Material Dryers

EUG 1d - Existing Raw Material Dryers


EUG 2 - Subpart OOO Non-Metallic Mineral Processing



OAC 252:100-29 (Fugitive Dust) [Applicable]

No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the

property line on which the emissions originated in such a manner as to damage or to interfere with

the use of adjacent properties, or cause air quality standards to be exceeded, or to interfere with

the maintenance of air quality standards. The following emissions units are subject to this rule:


EQUIPMENT/EU/EP Facility-Wide

Non-Metallic Mineral Processing Equipment Load Hopper (E-5, P-5)


Gypsum Unloading (Belly Dumping)/ E-22/ P-13

Gypsum Pile/ E-23/ P-14

Iron Source Pile/ E-24/ P-15

Silica-Alumina Source Pile/ E-25/ P-16

Gypsum, Iron Ore Unloading – Edge of Shed (F-E Loaders)/

E-26/ P-17

Rock Reclaim - Onsite Acquired Raw Material

Limestone Outside Storage/ E-29/ P-20


CKD Storage Pile/ E-93/ P-54


Raw Material Storage Pile/ E-200/ P-200

Coal Handling

Coal Pile/ E-57/ P-32

HAUL ROADS Kiln Dust Reclaim System

CKD Haul Roads/ E-92/ P-53

Coal Handling

Coal Haul Roads/ E-58/ P-33

Limestone/Shale Haul Trucks/Roads E-4/P-4


EQUIPMENT/EU/EP Kiln No. 3 Support Equipment

Clinker Storage Hall/ E-103/ P-60

Clinker Storage Pile – Outside/ E-104/ P-61

Control of fugitive dusts on storage piles and haul roads is accomplished by the use of water spray.

Reasonable precautions to control fugitive dust emissions from the operations listed are contained

in the specific conditions of the permit.

OAC 252:100-31 (Sulfur Compounds) [Applicable]

Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1,

1972). The limitations on sulfur dioxide emissions (measured as sulfur dioxide) based on heat

input are 0.2 lb/MMBTU for gas-fired fuel-burning equipment, 0.8 lb/MMBtu for liquid-fired fuel-

burning equipment, and 1.2 lb/MMBtu for solid fuel-burning equipment. The averaging time for


the emission limits set in OAC 252:100-31-25(a) is 3 hours unless a solid fuel sampling and

analysis method is used to determine emission compliance. In that case, the averaging time is 24

hours. When different types of fuels are burned simultaneously in any combination, the applicable

standard (in lb/MMBtu) shall be determined by proration unless a secondary fuel is used in de

minimis quantities (less than 5% of total Btu input annually). Compliance shall be determined

using the following formula where X is the percent of total heat input derived from gas fuel, Y is

the percent of total heat input derived from liquid fuel, and Z is the percent of total heat input

derived from solid fuel:

SO2 limit = [X(0.2) + Y(0.8) + Z(1.2)]/(X + Y + Z)

Only Kiln No. 3 is subject to this rule. Kiln No. 3 is considered new and has a heat rating of

approximately 158 MMBTUH, depending on the fuel type and amount consumed. Kiln No. 3

fires mainly solid fuels. Various testing has been conducted throughout the recent life of the

facility beginning in the 1995, with more recent testing having been done to address various

compliance, permitting, and initial notification issues and requirements. No discussion of the tests

is included here because stack tests inherently include emissions from both the combustion of fuel

and also from chemical reactions of the raw materials. DEQ permitting has issued a recent opinion

by Interagency Memorandum dated May 14, 2010 that the limitations of this subchapter were

intended to apply only to the emissions resulting from the burning of fuel. In a direct fired process

such as this, the additional emissions of SO2 generated from the raw material are not included when

demonstrating compliance with the standard. A mass balance based on fuel sulfur content will likely

demonstrate compliance with the standard. Permit limits imposed on sulfur contents of the three

fuel categories as well as SO2 limits imposed on Kiln No. 3 will ensure compliance with any single

fuel standard or the limit for any mixture as derived from the aforementioned formula.

OAC 252:100-33 (Nitrogen Oxides) [Applicable]

This subchapter limits new fuel-burning equipment with rated heat input greater than or equal to

50 MMBTUH. The limitations on NOX based on heat input are 0.2 lb/MMBtu for gas-fired fuel-

burning equipment, 0.3 lb/MMBtu for liquid-fired fuel-burning equipment, and 0.7 lb/MMBtu for

solid fuel-burning equipment. New fuel-burning equipment for direct-fired processes means any

direct-fired fuel-burning equipment or processes that were not in being on July 1, 1977, or any

existing direct-fired fuel-burning equipment or processes that were altered, replaced, or rebuilt

after July 1, 1977, resulting in increased emissions of nitrogen oxides.

Only Kiln No. 3 is subject to this rule. Kiln No. 3 is considered new and has a heat rating of

approximately 158 MMBtu/hr, depending on the fuel type and amount consumed. Kiln No. 3 fires

mainly solid fuels. For solid fuels, Subchapter 33 limits the NOX emissions to 0.70 lb/MMBtu.

Testing performed in June 2003 and October 2004 for the TDF mid-kiln injection modification

exceeded this standard. The applicant has noted that, as a comparison, the emission factor from AP-

42, table 11.6-8 (1/95) would exceed the standard. That emission factor, 6.0 lbs- NOX/ton-clinker,

equates roughly to 1.52 lbs/MMBtu based on the applicant’s estimated clinker capacity of 40 tons

per hour and the above mentioned heat input capacity.


OAC 252:100-35 (Carbon Monoxide) [Not Applicable]

This subchapter affects gray iron cupolas, blast furnaces, basic oxygen furnaces, petroleum

catalytic cracking units, and petroleum catalytic reforming units. It requires removal of 93% or

more of CO by “complete secondary combustion” from new sources and also from existing sources

located in or significantly impacting a non-attainment area for CO. There are no affected sources.

OAC 252:100-37 (Volatile Organic Compounds) [Parts 3 and 7 Applicable]

Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons

or more and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a

permanent submerged fill pipe or with an organic vapor recovery system. The 1,000-gasoline

storage tank is subject to this rule. It is equipped with a submerged fill pipe.

Part 5 limits the VOC content of coating used in coating lines or operations. This facility will not

normally conduct coating or painting operations except for routine maintenance of the facility and

equipment, which is not an affected operation.

Part 7 requires fuel-burning equipment to be operated and maintained so as to minimize VOC

emissions. Temperature and available air must be sufficient to provide essentially complete

combustion. The kilns are designed to provide essentially complete combustion of organic

materials.

OAC 252:100-42 (Toxic Air Contaminants (TAC)) [Applicable]

This subchapter regulates toxic air contaminants (TAC) that are emitted into the ambient air in

areas of concern (AOC). Any work practice, material substitution, or control equipment required

by the Department prior to June 11, 2004, to control a TAC, shall be retained, unless a modification

is approved by the Director. Since no AOC has been designated there are no specific requirements

for this facility at this time.

OAC 252:100-43 (Testing, Monitoring, and Recordkeeping) [Applicable]

This subchapter provides general requirements for testing, monitoring and recordkeeping and

applies to any testing, monitoring or recordkeeping activity conducted at any stationary source. To

determine compliance with emissions limitations or standards, the Air Quality Director may

require the owner or operator of any source in the state of Oklahoma to install, maintain and operate

monitoring equipment or to conduct tests, including stack tests, of the air contaminant source. All

required testing must be conducted by methods approved by the Air Quality Director and under

the direction of qualified personnel. A notice-of-intent to test and a testing protocol shall be

submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests. Emissions

and other data required to demonstrate compliance with any federal or state emission limit or

standard, or any requirement set forth in a valid permit shall be recorded, maintained, and

submitted as required by this subchapter, an applicable rule, or permit requirement. Data from any

required testing or monitoring not conducted in accordance with the provisions of this subchapter

shall be considered invalid. Nothing shall preclude the use, including the exclusive use, of any

credible evidence or information relevant to whether a source would have been in compliance with

applicable requirements if the appropriate performance or compliance test or procedure had been

performed.

Each emissions unit must be evaluated for periodic testing in accordance with the Periodic Testing

Standardization guidance issued December 1, 2011, on a pollutant by pollutant basis. The


frequency of the periodic testing requirement is based on the quantity of the pollutant permitted.

Periodic testing requirements are not required for an emission unit that is subject to an applicable

requirement that already requires periodic testing, continuous emission monitoring (CEM), or

predictive emission monitoring (PEMS). For this facility, CO from Kilns No. 1 and 2, and NOX,

CO, SO2, and VOC from Kiln No. 3 are the only pollutants which are potentially subject to the

periodic testing requirements.

Periodic Testing Review

EU Pollutant TPY Current Monitoring Periodic Testing

Kiln No. 11,2

NOX 14431 None No1

CO 722.32 None

Yes, test each unit at least

every 2 years since the unit’s

PTE is between 250 and 500

TPY

SO2 5121 None No1

VOC 2061 None No1

Kiln No. 21,2

NOX 14431 None No1

CO 722.32 None


every 2 years since the unit’s


TPY

SO2 5121 None No1

VOC 2061 None No1

Kiln No. 3

NOX 705.7 None


every year since each unit’s

PTE is over 500 TPY

CO 585.1 None



PTE is over 500 TPY

SO2 736 None



PTE is over 500 TPY

VOC 144.9 None

Yes, test once during the term

of the permit since the unit’s


TPY 1 - Grandfathered emission units (constructed prior to 1972) and are not subject to emission limits for NOX, SO2,

and VOC. 2 – Kilns No. 1 & 2 are limited to a combined uncontrolled emission limits of 722.3 TPY of CO. However, Kiln

No. 1 has a PTE of 400 TPY CO and Kiln No. 2 has a PTE of 400 TPY CO.


The following Oklahoma Air Pollution Control Rules are not applicable to this facility:

OAC 252:100-11 Alternative Reduction not eligible

OAC 252:100-15 Mobile Sources not in source category

OAC 252:100-17 Incinerators not type of emission unit

OAC 252:100-23 Cotton Gins not type of emission unit

OAC 252:100-24 Feed & Grain Facility not in source category

OAC 252:100-39 Nonattainment Areas not in a subject area

OAC 252:100-47 Landfills not type of source category

SECTION VII. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Not Applicable to this Permit]

PSD does not apply to this permit since there are no proposed emission increases. Reported actual

emissions of NOX, CO, and SO2, and the PTE for NOX, CO, SO2, and PM10, are greater than the

major source threshold of 100 TPY of any single regulated pollutant. The facility is one of the

listed stationary sources with an emission threshold of 100 TPY (Portland cement plants).

Therefore, any future increases of emissions must be evaluated for PSD if they exceed a

significance level (CO - 100 TPY, NOX - 40 TPY, SO2 - 40 TPY, PM - 25 TPY, PM10 - 15 TPY,

PM2.5 - 10 TPY, VOC - 40 TPY. CO2e is evaluated only if an increase in a primary pollutant is

significant.

NSPS, 40 CFR Part 60 [Subparts F, Y, and OOO Applicable]

Subparts K, Ka, Kb, Standards of Performance for Petroleum Liquids and VOL Storage Vessels.

All tanks at the facility are less than the threshold capacities of these subparts.

Subpart F, Standards of Performance for Portland Cement Plants, applies to Kilns, clinker coolers,

raw mill systems, finish mill systems, raw mill dryers, raw material storage, clinker storage,

finished product storage, conveyor transfer points, bagging and bulk loading and unloading

systems in Portland cement plants that commenced construction or modification after August 17,

1971. If an affected source under this subpart has a different emissions limit or requirement for

the same pollutant under another regulation in title 40 of this chapter, once compliance is met for

the most stringent emissions limit or requirement, the affected source is not subject to the less

stringent requirement. Until then, the less stringent limit continues to apply.

The application states that all requirements of Subpart F, that would affect sources at the facility,

are met or exceeded by complying with the requirements of NESHAP Subpart LLL. Therefore

there are no additional requirements to be met under Subpart F at this time.

Subpart Y - Standards of Performance for Coal Preparation Plants, are applicable to any of the

following affected facilities that commenced construction or modification after October 24, 1974,

in coal preparation plants which process more than 181 Mg (200 tons) per day: Thermal dryers,

pneumatic coal-cleaning equipment (air tables), coal processing and conveying equipment

(including breakers and crushers), coal storage systems, and coal transfer and loading systems.

Subpart Y sets emissions and opacity standards for both thermal dryers and pneumatic coal

cleaning equipment. For coal processing and conveying equipment, coal storage system, or coal

transfer and loading system processing coal, opacity is limited to less than 20 percent. There are

no thermal dryers or pneumatic coal cleaning equipment at this facility. All other equipment is


subject to the 20% opacity standard. EUG 4, Subpart Y Coal Handling, located in the

memorandum, lists all equipment subject to this subpart.

Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants, applies to

crushers, grinding mills, screening operations, bucket elevators, belt conveyors, bagging

operations, storage bins, and enclosed truck or rail car loading stations constructed, reconstructed,

or modified at nonmetallic mineral processing plants after August 31, 1983.

NESHAP Subpart LLL exempts any affected source subject to the provisions of Subpart LLL from

any otherwise applicable standard contained in NSPS Subpart OOO. EUG 2 are the emissions

units affected by this subpart. Of the three units listed in EUG 2, only the Storage Hall Tripper

Conveyor Belt (36-inch/ E-28/ P-12a) is subject to an emissions standard. The Wobbler Feeder

(E-6, P-5) and Wobbler Fines Belt Conveyor (E-7, P-5) are equivalent replacements for existing

equipment and are exempt from the provisions of §§60.672, 60.674, and 60.675 and are included

in EUG 3.


Size/Capacity


Date Ht.

(FT)

Dia.

(FT)

Max.

(TPH)

Actual

(TPY)

#5 Storage Hall Tripper Conveyor Belt, 36-inch/ E-28/ P-12a 10/1/84 NA NA 252 NA

Belt Conveyor BC1, 36-inch, Hopper Gathering / E-257 / P-260 2009 5 3 160 92,305

Belt Conveyor BC2, 36-inch, Additive Transfer / E-258 / P-261 2009 5 3 160 92,305

Subpart CCCC, Commercial and Industrial Solid Waste Incineration (CISWI) Units. This subpart

affects CISWI for which construction is commenced after November 30, 1999, or for which

modification or reconstruction is commenced on or after June 1, 2001. Cement kilns regulated

under 40 CFR Part 63, Subpart LLL are exempt from this subpart per §60.2020(l).

Subpart EEEE, Other Solid Waste Incineration (OSWI) Units. This subpart affects OSWI for

which construction is commenced after December 9, 2004, or for which modification or

reconstruction is commenced on or after June 16, 2006. Cement kilns regulated under 40 CFR

Part 63, Subpart LLL are exempt from this subpart per §60.2887(a).

NESHAP, 40 CFR Part 61 [Not Applicable]

This facility is expected to have a very small amount of arsenic, beryllium, benzene, and mercury

emissions. However, this facility is not an affected source and is not subject to any standards under

Part 61.

NESHAP, 40 CFR Part 63 [Subpart LLL Applicable]

Subpart LLL, National Emission Standards for Hazardous Air Pollutants From the Portland

Cement Manufacturing Industry, applies to each new and existing Portland cement plant which is

a major source or an area source as defined in §63.2. The affected sources subject to this subpart

are:

(1) Each kiln including alkali bypasses and inline coal mills, except for kilns that burn hazardous

waste and are subject to and regulated under subpart EEE of this part;

(2) Each clinker cooler at any Portland cement plant;

(3) Each raw mill at any Portland cement plant;

(4) Each finish mill at any Portland cement plant;

(5) Each raw material dryer at any Portland cement plant;


(6) Each raw material, clinker, or finished product storage bin at any Portland cement plant that is

a major source;

(7) Each conveying system transfer point including those associated with coal preparation used to

convey coal from the mill to the kiln at any Portland cement plant that is a major source;

(8) Each bagging and bulk loading and unloading system at any Portland cement plant that is a

major source; and

(9) Each open clinker storage pile at any Portland cement plant.

Onsite sources that are subject to standards for nonmetallic mineral processing plants in subpart

OOO, part 60 of this chapter are not subject to this subpart. Crushers are not covered by this subpart

regardless of their location.

Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Major Sources:

Industrial, Commercial, and Institutional Boilers and Process Heaters, establishes national

emission limitations and work practice standards for hazardous air pollutants (HAP) emitted from

industrial, commercial, and institutional boilers and process heaters located at major sources of

HAP. This subpart also establishes requirements to demonstrate initial and continuous compliance

with the emission limitations and work practice standards. The 20 MMBTUH and 30 MMBTUH

Hot Air Furnaces that supply heat to the Raw Material Dryers are direct fired heaters, i.e. the

combustion gases come into direct contact with process materials, thus they do not meet the

definition of “process heater” nor do they meet the definition of boiler. They are, therefore, not

subject to this rule.

CAM, 40 CFR Part 64 [Not Applicable]

This part applies to any pollutant-specific emission unit at a major source that is required to obtain

an operating permit, for any application for an initial operating permit submitted after April 18,

1998, that addresses “large emissions units,” or any application that addresses “large emissions

units” as a significant modification to an operating permit, or for any application for renewal of an

operating permit, if it meets all of the following criteria.

It is subject to an emission limit or standard for an applicable regulated air pollutant

It uses a control device to achieve compliance with the applicable emission limit or standard

It has potential emissions, prior to the control device, of the applicable regulated air pollutant

of 100 TPY or 10/25 TPY of a HAP

The application for the initial TV permit was received after April 18, 1998. According to the

applicant’s emissions calculations, there are no “large emissions units”. EUGs No. 1a, 1b, and 1c

include equipment having pre-control emissions greater than 100 TPY that are subject to emission

limits and standards of NESHAP Subpart LLL for particulate matter and use control devices to

achieve compliance with the applicable emission limit or standard. The kilns are emissions units

that have emissions exceeding 100 TPY of NOx, CO, SO2, and VOC but no controls are used for

those pollutants, therefore there are no “large emission units”, i.e. emissions units having control

devices with post-control emissions of 100 TPY. Nevertheless, emissions units that are subject to

emission limitations or standards proposed by the Administrator after November 15, 1990 pursuant

to section 111 or 112 of the Act are exempt from the requirements of this part, therefore none of

this equipment is subject to CAM. Additionally, EUGs 2, 3, and 4 contain equipment that is not

subject to emission limitations or standards proposed by the Administrator after November 15,


1990, but the equipment has pre-control emissions less than 100 TPY, thus it is not subject to

CAM.

Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable]

This facility will not process or store more than the threshold quantity of any regulated substance

(Section 112r of the Clean Air Act 1990 Amendments). More information on this federal program

is available on the web page: www.epa.gov/rmp.

Stratospheric Ozone Protection, 40 CFR Part 82 [Subpart A and F Applicable]

These standards require phase out of Class I & II substances, reductions of emissions of Class I &

II substances to the lowest achievable level in all use sectors, and banning use of nonessential

products containing ozone-depleting substances (Subparts A & C); control servicing of motor

vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations

which meet phase out requirements and which maximize the substitution of safe alternatives to

Class I and Class II substances (Subpart D); require warning labels on products made with or

containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon

disposal (Subpart F); require producers to identify substitutes for ozone-depleting compounds

under the Significant New Alternatives Program (Subpart G); and reduce the emissions of halons

(Subpart H).

Subpart A identifies ozone-depleting substances and divides them into two classes. Class I

controlled substances are divided into seven groups; the chemicals typically used by the

manufacturing industry include carbon tetrachloride (Class I, Group IV) and methyl chloroform

(Class I, Group V). A complete phase-out of production of Class I substances is required by

January 1, 2000 (January 1, 2002, for methyl chloroform). Class II chemicals, which are

hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs.

Class II substances consist of 33 HCFCs. A complete phase-out of Class II substances, scheduled

in phases starting by 2002, is required by January 1, 2030.

Subpart F requires that any persons servicing, maintaining, or repairing appliances except for

motor vehicle air conditioners; persons disposing of appliances, including motor vehicle air

conditioners; refrigerant reclaimers, appliance owners, and manufacturers of appliances and

recycling and recovery equipment comply with the standards for recycling and emissions

reduction.

The facility does not produce, consume, recycle, import, or export any controlled substances or

controlled products as defined in this part. The application indicates that the facility may service

motor vehicles and air conditioners or use outside contractors. To the extent that the facility has

air-conditioning units that apply, the permit requires compliance with Part 82. Conditions

(contained in the attached Standard Conditions dated December 22, 2008) are included in the permit

to address the recordkeeping requirements specified at §82.13 of this regulation.

SECTION VIII. COMPLIANCE

Testing

The permit contains testing requirements related to 40 CFR Part 63, Subpart LLL, Part 60 Subparts

Y and OOOO, and substitute fuels analysis. No testing was required for issuance of this permit.

http://www.epa.gov/rmp


Inspection

A full compliance evaluation (FCE) was performed on June 28, 2018 by Corey Gum, AQD,

accompanied by Tom Guiliani, Buzzi Unicem. The FCE summary notes that the facility was in

non-compliance with Specific Condition No. 1(B) and 40 CFR § 63.1343(d) by failing to control

opacity at the kilns and Clinker Coolers during opacity excess emissions events.

Tier Classification

This application has been classified as Tier II per OAC 252:4-7-33(b) since it is a request for a

renewal of a Part 70 Operating Permit. The applicant has submitted an affidavit that they are not

seeking a permit for land use or for any operation upon land owned by others without their knowledge.

The affidavit certifies that the applicant owns the land.

The applicant published the “Notice of Tier II Permit Application Filing” on May 9, 2016, in The

Paper, Pryor Creek, Oklahoma, a weekly newspaper printed in Mayes County. The notice stated

that the application was available for public review at Harrison Public Library located at 505 East

Graham, Pryor, Oklahoma, or the AQD main office. The applicant will also publish a “Notice of

Draft Tier II Permit” in a local newspaper for a 30 day public review, a copy of the draft permit

will be available on the Air Quality section of the DEQ web page at www.deq.ok.gov.

This facility is located within 50 miles of the Oklahoma-Missouri and Oklahoma-Arkansas

borders. Those states will be notified of the draft permit. Any significant comments received

during the public notice period will be addressed in the version of the permit proposed to the EPA.

Information on all permit actions is available for review by the public in the Air Quality section of

the DEQ Web page at http://www.deq.ok.gov.

Fees Paid

A Part 70 operating permit renewal application fee of $7,500 was paid by the applicant.

SECTION IX. SUMMARY

EPA has an ongoing investigation regarding whether there were emissions increases associated

with the increased usage of petroleum coke that triggered additional air pollution control

requirements under the Prevention of Significant Deterioration (PSD) regulations in 40 CFR 52.21.

The PSD investigation is also looking at other physical modifications or operational changes made

at the facility. As a result of this investigation, additional CAA applicable requirements may apply

to the facility. There are no other active Air Quality compliance or enforcement issues that would

affect the issuance of this permit. Issuance of the operating permit is recommended, contingent

on the results of public and EPA reviews.

http://www.deq.ok.gov/


DRAFT

PERMIT TO OPERATE

AIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS

Lone Star Industries, Inc. Permit Number 2015-1720-TVR

Pryor Portland Cement Manufacturing Facility

The permittee is authorized to operate in conformity with the specifications submitted to Air Quality

in the application received October 14, 2016 and subsequent submittals by e-mail dated February 24

and 26, 2016; May 4, 18, 19 and 20, 2016; August 8, 18, 22 and 25, 2016; September 9, 22, 26 and

28, 2016; October 3, 4, 10 & 24, 2016; November 28, 2016; December 2, 2016; January 17 and 23,

2017; and May 25, 2018 and December 4, 2018. The Evaluation Memorandum dated December

16, 2019 explains the derivation of applicable permit requirements and estimates of emissions;

however, it does not contain operating limitations or permit requirements. Continuing operation

under this permit constitutes acceptance of, and consent to, the conditions contained herein.

1. Points of emission and emissions limitations. Permittee shall maintain and operate the facility

in a manner to prevent the exceedance of ambient air quality standards contained in OAC

252:100-3 and the limitations established by this permit. Where two emission limits with

different bases are given for a single emission point and pollutant, the source shall not exceed

either limit at any time. [OAC 252:100-8-6(a)(1)]

A. i. Compliance with emissions limits shall be monitored and determined based on the

averaging period(s) specified by the applicable rule or this permit.

ii. Unless otherwise specified or amended in a rule or regulation, compliance with each limit

and applicable averaging period is specified by the methods and procedures outlined in

this permit, including restrictions on storage, throughputs, raw material and fuel

specifications, emissions monitoring, and the monitoring and maintenance requirements

of this permit and the Operation and Maintenance Plan required by 40 CFR Part 63,

Subpart LLL and this permit.

iii. Except for limitations specified under 40 CFR Part 63, Subpart LLL, any testing done

to demonstrate compliance with particulate matter limits for combustion units shall

include the back half of the sampling train.

B. The facility is subject to the requirements of 40 CFR Part 63, Subpart LLL, including but

not limited to the following:

§63.1340 What parts of my plant does this subpart cover?

§63.1341 Definitions.

§63.1342 Standards: General.

§63.1343 What standards apply to my kilns, clinker coolers, raw material dryers, and open

clinker storage piles.

§63.1344 [Reserved]

§63.1345 Emission limits for affected sources other than kilns; clinker coolers, new and

reconstructed raw material dryers.

§63.1346 Operating limits for kilns.

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SPECIFIC CONDITIONS 2015-1720-TVR DRAFT 2

§63.1347 Operating and maintenance plan requirements.

§63.1348 Compliance requirements.

§63.1349 Performance testing requirements.

§63.1350 Monitoring requirements.

§63.1351 Compliance dates.

§63.1352 Additional test methods.

§63.1353 Notification requirements.

§63.1354 Reporting requirements.

§63.1355 Recordkeeping requirements.

§63.1356 Sources with multiple emissions limit or monitoring requirements.


§63.1358 Implementation and enforcement.


Table 1 to Subpart LLL of Part 63—Applicability of General Provisions

The facility is subject to the requirements of 40 CFR Part 60, Subpart F, including but not

limited to the following:

§60.60 Applicability and designation of affected facility.


§60.62 Standards.

§60.63 Monitoring of operations.

§60.64 Test methods and procedures.

§60.65 Recordkeeping and reporting requirements.

§60.66 Delegation of authority.

C. EUG 1a – Kilns.

i. Permittee shall comply with the following emissions limits established by existing

permits and this Title V permit. [Permit No. 78-001-O], [Permit No. PSD-OK-61]

Emissions Limits: EUG 1a – Kilns and DSI System Silo (ton/yr)

Pollutant Kilns No. 1 and 2

Kiln No. 3

NOX NA 705.7

SO2 NA 736

CO 722.3 both kilns combined 585.1

VOC NA 144.9

HCl NA 24.53

TSP (Total Suspended Particulate) 53.7 each kiln 86.3

PM10 DSI System 0.15

ii. Kilns No. 1, 2, & 3. [Permit No. 78-001-O (M-1) & (M-4)]

a. Permittee is authorized to utilize up to 75,000 tons per year of petroleum

hydrocarbon contaminated (PHC) rock and soil containing only diesel fuel,

gasoline, kerosene, or mixtures thereof through the cement kiln(s) and the

crushing, milling, and materials handling processes.



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b. The PHC material shall not exceed 6% of the total raw material blend processed

through the grinding and milling processes.

c. The petroleum hydrocarbon content in the PHC material shall be less than 1,000

mg/kg of material.

d. Emissions of volatile organic compounds (VOC) resulting from the grinding,

milling and handling of PHC material shall not exceed 17.76 pounds per hour

or 6.7 tons per year. Compliance with this limit shall be determined based on

the weight of VOCs in the PHC material, material throughput, and assuming

75% evaporation of the VOCs, making allowance for moisture content.

iii. Kilns No. 1 and 2. [Permit No. 72-005-C & O]

Emissions of particulate matter from Kilns No. 1 and 2 shall not exceed 12.2 lbs/hr

(53.7 tons per year) per kiln.

iv. Kilns No. 1 and 2. [OAC 252:100-8-6(a)(1)]

a. The application for Permit No. 98-170-TV (M-1) increased emissions of CO by

99 TPY to establish an enforceable limit after mid-kiln tire-derived fuel

injection equipment was constructed. Emission of CO from Kilns No. 1 and 2

shall not exceed 722.3 tons per year. The combined consumption of tire-derived

fuel in Kilns No. 1 and 2 shall not exceed 16,700 tons per year, 12-month rolling

cumulative.

v. Kiln No. 3 Only. [Permit No. PSD-OK-61]

The maximum sulfur dioxide (SO2) and total suspended particulate (TSP) emission

rates in lbs/hr shall not exceed the following:

SO2 (lbs/hr) TSP Emissions (lb/hr)

168 19.7

Note that the NESHAP LLL standard is a PM10 – based limit. This limit, a TSP limit,

is retained as a PSD limit

vi. Kilns No. 1, 2 and 3 [40 CFR Part 63 Subpart LLL]

a. Emissions from Kiln Nos 1, 2, and 3 shall not exceed the following emission

limits. The Permittee shall comply with 40 CFR §63.1349 for demonstrating

compliance with the following emissions limits:

Emissions Limits: EUG 1a – Kilns No. 1, 2 and 3

Pollutant Limit Compliance

Date

Filterable

Particulate

(PM)

0.07 lb/ton clinker 9/9/2015


Emissions Limits: EUG 1a – Kilns No. 1, 2 and 3

Pollutant Limit Compliance

Date Dioxin/Furan

(D/F) 0.2 ng per dscm (8.7 X 10 –11 gr per

dscf)(TEQ) corrected to seven percent

oxygen; or 0.4 ng per dscm (1.7 x 10-10 gr

dscf)(TEQ) corrected to seven percent

oxygen, when the temperature at the inlet to

the particulate matter air pollution control

device is 204°C (400°F) or less

9/9/2015

Hydrogen

Chloride (HCl) 3.0 ppmvd corrected to 7 percent oxygen,

on a 30-day rolling average

9/9/2016

Total

Hydrocarbon

(THC)

24.0 ppmvd corrected to 7 percent oxygen

on a 30-day rolling average or the Plant may

elect to comply with an alternative limit of

12.0 ppmvd for total organic HAP (O-HAP)

9/9/2015

Mercury (Hg) 55.0 lbs/MMton clinker, on a 30-day rolling

average

9/9/2016

b. The Permittee shall comply with the following monitoring requirements:

Filterable Particulate Matter shall be parametrically monitored with a

Continuous Parametric Monitoring System (CPMS) per 40 CFR §63.1350(b)

on each kiln stack. The CPMS will be used to establish a site-specific operating

limit corresponding to the results of the most recent annual Method 5 or 5I

performance test demonstrating compliance with the PM limit. Compliance

shall be demonstrated by not exceeding this site-specific operating limit on a 30

operating day CPMS rolling average basis.

Dioxin/Furans shall be parametrically monitored with a Continuous Monitoring

System (CMS) that monitors the temperature of the exhaust gases from the kilns

at the inlet of each kiln baghouse per 40 CFR §63.1350(g). The CMS will be

used to establish site-specific operating limits corresponding to the most recent

Dioxin/Furan performance test demonstrating compliance the Dioxin/Furan

limit. Compliance shall be demonstrated by not exceeding these site-specific

operating limits on a rolling 180-minute average basis.

HCl shall be monitored with a Continuous Emission Monitoring System

(CEMS) per 40 CFR §63.1350(l) on each kiln stack.

O-HAP shall be parametrically monitored with a THC CEMS per 40 CFR

§63.1350(j) on each kiln stack. The THC CEMS will be used to establish a

site-specific operating limit corresponding to the most recent O-HAP

performance test demonstrating compliance the O-HAP limit.

Hg shall be monitored with a CEMS per 40 CFR §63.1350(k) on each kiln


stack.

Kiln stack flow rate shall be monitored with a continuous flow rate monitoring

system per 40 CFR §63.1350(n).

Clinker production shall be monitored per the requirements of 40 CFR

§63.1350(d).

c. The Permittee shall comply with all applicable recordkeeping requirements per

40 CFR §63.1355.

d. The Permittee shall comply with all applicable reporting requirements per 40

CFR §63.1354.

vii. Kilns No. 1, 2 and 3 [40 CFR 98]

Kilns No. 1, 2, and 3 must comply with all applicable greenhouse gas (GHG)

reporting requirements and related monitoring and recordkeeping requirements per

40 CFR Part 98, Subpart H.

D. EUG 1b –Clinker Coolers.

i. Clinker Coolers No. 1, 2, & 3.

[Permit Application dated March 18, 1980], [Permit Nos. 78-001-C & PSD-OK-61]

The maximum total suspended particulate (TSP) emission rates from the following

sources shall not exceed the following limits:

EP # lbs/hr TPY

P-43 16.1 64

Note that the NESHAP LLL standard is a PM10 – based limit. This limit, a TSP

limit, is retained as a PSD limit.

ii. Clinker Coolers No. 1, 2, & 3. [40 CFR Part 63 Subpart LLL]

Emissions from Clinker Coolers No. 1, 2, and 3 shall not exceed 0.07 lb/ton clinker

of filterable particulate. The Permittee shall comply with 40 CFR §63.1349 for

demonstrating compliance this emissions limit.

Filterable Particulate Matter shall be parametrically monitored with a Continuous

Parametric Monitoring System (CPMS) per 40 CFR §63.1350(b) on each clinker

cooler stack. The CPMS will be used to establish a site-specific operating limit

corresponding to the results of the most recent annual Method 5 or 5I performance

test demonstrating compliance with the PM limit. Compliance shall be

demonstrated by not exceeding this site-specific operating limit on a 30 operating

day CPMS rolling average basis.

The Permittee shall comply with all applicable recordkeeping requirements per 40

CFR §63.1355.


The Permittee shall comply with all applicable reporting requirements per 40 CFR

§63.1354.

E. EUG 1c – Subpart LLL - Raw/Finish Mills, Storage, Conveyors, Bagging, Bulk

Loading & Unloading. EUG 1c consists of raw mills; finish mills; raw material, clinker

or finished product storage bins, conveying system transfer points including those

associated with coal preparation used to convey coal from the mill to the kiln, and

bagging/bulk loading/unloading which are subject to 40 CFR Part 63, Subpart LLL,

“National Emission Standards for Hazardous Air Pollutants From the Portland Cement

Manufacturing Industry.”

i. Per 40 CFR Part 63 Subpart LLL, all EUG 1c emission units are subject to the following

requirements:

a. Emissions from EUG 1c emission units shall not exceed 10% opacity. The

Permittee shall comply with 40 CFR §63.1349 for demonstrating compliance

this emissions limit.

b. All EUG 1c emission units other than raw and finish mills shall comply with

the following monitoring requirements:

Conduct monthly 10-minute Method 22 visible emissions tests per 40 CFR

§63.1350(f)(1). If visible emissions are observed, initiate corrective actions

within 1-hour and conduct a 30-minute Method 9 performance test. If no visible

emissions are observed for six consecutive monthly tests, then the Plant may

decrease the frequency of testing to semi-annually. If no visible emissions are

observed during the semi-annual test, the Plant may decrease the frequency of

testing to annually. If visible emissions are observed during any semi-annual

or annual testing, the Plant must resume monthly testing.

Totally enclosed conveying system transfer points are not subject to the

monthly testing requirements. Monthly testing is required for each partially

enclosed or unenclosed conveying system transfer point located in a building

or the building itself must have monthly testing performed for each side, roof

and vent of the building.

c. EUG 1c emission units that are raw or finish mills shall comply with the

following monitoring requirements:

Conduct daily 6-minute Method 22 visible emissions tests per 40 CFR

§63.1350(f)(2). If visible emissions are observed, initiate corrective actions

within 1-hour. Within 24-hours conduct a second Method 22 visible emissions

test. If visible emissions are observed during the second Method 22, conduct a

30-minute Method 9 performance test.

d. The Permittee shall comply with all applicable recordkeeping requirements per

40 CFR §63.1355.


e. The Permittee shall comply with all applicable reporting requirements per 40

CFR §63.1354.

ii. In addition to applicable requirements of Subpart LLL, permittee shall comply with the

following PM10 emissions limits established by existing permits and this Title V permit.



Basis

Controls

(%)

Emiss.

Factor

PM10

(TPY)

(lb/hr)(1)

Raw Mill No.1 Raw Material Hopper 101 / E-270 / P-254

Throughput







Raw Mill Material Bins/ E-34/ P-60 Shared w/Raw Mill No. 2 Raw Material Weigh Feeders


Discharge

(acf)

Cyclones/Dust

Collector (99 ) Baghouse (95)

gr/acf

24






#1 Raw Mill /(E-41, P-108) Mill End Dust

Collector (99) 2.6

Raw Mill No. 2

Raw Mill Material Bins/ E-34/ P-60 Throughput 1-Wall Shed (24) lbs/ton 7.3

Raw Material Weigh Feeders/ E-44/P-28

Discharge (acf) Baghouse (95) gr/acf 5 Mill Feed Conveyor Belt E-45



Classifier/E-47/ P-29 Discharge (acf) Baghouse (95) gr/acf 30


#2 Raw Mill /(E-50, P-109) Discharge (acf) Mill End Dust


Kiln Feed/Blending 3 - Blending Silos/ E-52/ P-30

Discharge (acf) Baghouse (95) gr/acf 13 14-inch Airslide/ E-53/ P-30


Blend Pumps (3)/ E-55/ P-30

Kiln Feed Storage Silo/ E-56/ P-31 Discharge (acf) Baghouse (95) gr/acf 4

Tire Derived Fuel Handling No or only trace emissions expected.


Kiln Feed Tank/ E-66/ P-41 Discharge (acf) Baghouse (95) gr/acf 44.2(1)

Feed Tank Bucket Elevator (Kiln 1)/ E-71/ P-41 Discharge (acf) Baghouse (95) gr/acf 46.3(1)

Drag Chain Conveyor (clinker)/ E-69/ P-43 ESP 0.0102

Included in

clinker cooler

emissions

Clinker Bucket Elevator (clinker)/ E-70/ P-60 Throughput Enclosed (60) lbs/ton 46.3(1)


Kiln Feed Tank/ E-74/ P-46 Discharge (acf) Baghouse (95) gr/acf 44.2(1)




Basis

Controls

(%)

Emiss.

Factor

PM10

(TPY)

(lb/hr)(1)

Feed Tank Bucket Elevator (Kiln 2)/ E-81/ P-42

Cyclones/ Dust Collector (99)

Included in

kiln emissions

Drag Chain Conveyor (clinker)/ E-77/ P-43 ESP

Included in

clinker cooler

emissions

Clinker Bucket Elevator (clinker)/ E-78/ P-60 Throughput

(tons) Enclosed (60) lbs/ton 46.3(1)


Kiln Feed Tank, 22-inch dia./ E-96/ P-57



gr/acf

5





Drag Chain Conveyor (clinker), 12-inch/ E-101/ P-43 Discharge (acf)

ESP gr/acf

Included in

clinker cooler

emissions

Clinker Bucket Elevator/ E-102/ P-60 Throughput

(tons) Enclosed (60) lbs/ton 13


Baghouse Dust Pump (Kiln 3)/ E-106, P-58 Discharge (acf) Baghouse (95) gr/acf Included in

kiln emissions

#16 Screw Conveyor, 16-inch/ E-79/ P-42 Discharge (acf) Cyclone/


Included in

kiln emissions


Discharge (acf)

Cyclone/


2.6

Dust Tank Bucket Elevator/ E-82/ P-48



Kiln Dust Pump/ E-86/ P-48

FK Pump (replaced Kiln Dust Conveying Pods in

2004)/ E-87/ P-48



1.7



Kiln Dust Storage Tank#3 / E-209 / P-209 Discharge (acf) Dust Collector

(99.99) gr/acf 1

Finish Mill No. 1

3 - Clinker/Gypsum Bins/ E-108/ P-60

Throughput

(tons)

1-Wall Shed (24) lbs/ton 44

3 - Weigh Feeders/ E-109/ P-66 Discharge

(acf) Baghouse (99) gr/acf 0.5



Discharge

(acf)

Baghouse (99)

gr/acf

3.8






Dust Collector (99)

9 Tailings Airslide/ E-114a/ P-66

#1 Finish Mill, KVS/ E-111/ P-64 Cyclone/Dust

Collector (99)

6.8 19-inch Airslide/ E-111a/ P-64

Finish Mill No. 2

Overhead Crane, E-33/ P-60 (Used for Clinker

and Finish Mills)

Throughput

(tons) 3-wall Shed (40) lbs/ton 20




Basis

Controls

(%)

Emiss.

Factor

PM10

(TPY)

(lb/hr)(1)


E-119/ P-60

Throughput

(tons) 1-Wall Shed (24) lbs/ton 67

Weigh Feeders/ E-120/ P-67



gr/acf

9








Finish Mill #2 additives hopper and feeder / E-

259 / P-262

Throughput

(tons)

4-Wall Building


derivation of


speed.

lbs/ton 0.07


261 / P-262


E-260 / P-262


E-262 / P-262

Finish Mill No. 3

3 - Clinker/Limestone/Gypsum Bins/ E-129/ P-60 Throughput

(tons) 1-Wall Shed (24) lbs/ton 82

#3 Finish Mill/ E-132/ P-69 Discharge (acf)

Baghouse (99) gr/acf 8.8

Tailings Airslide/ E-135a/ P-69 Baghouse (99)

Weigh Feeders/ E-130/ P-70 Discharge (acf) Baghouse (99) gr/acf 0.5


19-inch Airslide/ E-132a/ P-270 Discharge (acf) Baghouse (99) gr/acf 0.56


Discharge (acf)

Baghouse (99)

gr/acf 14.3







263 / P-262

Throughput

(tons)

4-Wall Building


derivation of


speed.

lbs/ton 0.07


264 / P-262


E-265 / P-262


E-266 / P-262

Finish Silos - Group 1 8 - Cement Storage Silos/ E-138/ P-71/72/73

(3 baghouses)

Discharge (acf)


each

Fringe Bin Pump/ E-139/ P-74 Baghouse (95) gr/acf 19.2(1)


Silo/Packhouse Bucket Elevator/ E-147/ P-75


Baghouse (95) gr/acf 58.5(1) Loadout Spout/ E-144/ P-76






Basis

Controls

(%)

Emiss.

Factor

PM10

(TPY)

(lb/hr)(1)


NW Truck & Rail Loadout/ E-146/ P-78 Baghouse (95) gr/acf 48.4(1)


baghouses)

Discharge (acf)



East Rail Aux Bucket Elevator/ E-158/ P-82






East Rail Loadout Spout/ E-157/ P-85 Baghouse (95) gr/acf 1.4

Finish Silos - Group 3 Cement Storage Silo 15/ E-160a/ P-87a

Discharge (acf)

Baghouse (99.997) gr/acf 0.4

Cement Storage Silo 16/ E-160b/ P-87b Baghouse (99.997) gr/acf 0.4

Loadout Spout/ E-161/ P-88 Baghouse (95) gr/acf 1

20-inch Airslide/ E-162/ P-89 Baghouse (95) gr/acf 1.4


Packhouse


Discharge (acf)


Portland Packer Bucket Elevator/ E-165/ P-90






Masonry Packer Bucket Elevator/ E-169/ P-91




Chain Conveyors (Bag Drop)/ E-173/ P-93 Throughput

(tons) Enclosed (60) lbs/ton

8

Bag Palletizer/ E-174/ P-94 17 (2) lb/hr limit of total particulate matter from Subchapter 19.

a. Compliance with these emission limits shall be documented by maintaining a

copy of the manufacturer’s design specifications verifying that the total airflow

rate through the baghouses is limited by design to the specified limits, and by

operating and maintaining the baghouses and associated equipment in

accordance with the most current version of the Operation & Maintenance Plan

required by Subpart LLL.

iii. Raw Mill/Dryer No. 1 Mill End Dust Collector (E-41/ P-108) and Raw

Mill/Dryer No. 2 Mill End Dust Collector (E-50/ P-109) [Permit No. 98-170-C (M-2)]

a. The Raw Mill/Dryer No. 1 Mill End Dust Collector and Raw Mill/Dryer No. 2

Mill End Dust Collector are also subject to the following permit limits for PM10.


EU

ID#

EU Name Control Device

Name

Emission

Point ID#

Air Flow

Rate

(SCFM)

Emissions

Factor

(gr/dscf)

PM10

Emiss.

(TPY)

E-41 #1 Raw Mill

Dryer

Mill End Dust

Collector P-108 7,657 0.007 2.6

E-50 #2 Raw Mill

Dryer

Mill End Dust

Collector P-109 7,657 0.007 2.6

b. Compliance with these emission limits shall be documented by maintaining a

copy of the manufacturer’s design specifications verifying that the total airflow

rate through the baghouses is limited by design to the specified limits, and by

operating and maintaining the baghouses and associated equipment in

accordance with the most current version of the Operation & Maintenance Plan

required by Subpart LLL.

iv. Raw Mill/Dryer No. 2, Finish Mill No. 2, and associated control equipment.

[Permit Nos. 78-001-C & PSD-OK-61]

a. The maximum total suspended particulate (TSP) emission rates from the

following sources shall not exceed the following limits: [Letter dated October

23, 1979]

Source EP#/EU# lbs/hr TPY

Primary Crusher 03-170/E-8 1.81 2.40

Primary Screen 03-320/E-10 1.29 1.69

Limestone Storage 04-400 (P-21)/E-30 0.54 0.71

Raw Mill No. 2 Classifier 05-310 (P-29)/ E-48, 49, 50 5.14 18.66

Blend Silo/Feed Silo Roof 06-270 2.60 9.30

K-3 Kiln Feed Tank 07-170/E-96 0.82 1.70

Cement Silo Roof Group 3 09-230/E-160a&b 0.32 0.11

Loadout Silos Group 1 09-420/E-138 0.28 0.09

Loadout Silos Group 2 09-400/E-150 0.19 0.06

Raw Mill 2 Auxiliary DC 05-342 (P-28)/ E-45 & E-46 0.75 2.70

b. The maximum TSP emission rates from the following sources shall not exceed the

following limits. [Letter dated March 18, 1980]

Source EP#/EU# lbs/hr TPY

Feeders (6) 04-280 - 330/E-30 1.89 2.41

#1 Reclaim Belt Conveyor

& Raw Mill #2 Feed Belt

Conveyor

04-370/E-31

05-160/E-45 0.83 2.25


The maximum total throughput shall not exceed the following limits.

Source EP#/EU# Throughput

Capacity (TPH)

#3 Reclaim Belt Conveyor 04-390/E-32a 500

Raw Mill No. 2 05-230/E-50 95.0

c. Compliance with emission limits for sources not controlled by a baghouse shall be

documented by maintaining records of annual throughputs and by operating and

maintaining the associated equipment in accordance with the most current version

of the Operation & Maintenance Plan required by Subpart LLL.

F. EUG 1d - Existing Raw Material Dryers. EUG 1d consists of combustion emissions

from existing raw material dryers subject to 40 CFR Part 63, Subpart LLL. These sources

are also subject to the requirements of OAC 252:100-19, 25, & 31. Hot Air Furnace E-39

lost grandfathered status with issuance of Permit No. 98-170-C (M-2).

[40 CFR Part 63 Subpart LLL]


Date

Heat Input Rating

(MMBTUH)

Controls

(% Efficiency)

Raw Mills

Hot Air Furnace/ E-39/ P-26 1961 20 Classifier cyclone (99)

Hot Air Furnace/ E-48/ P-29 7/1/1980 30 Classifier cyclone (99)

i. Existing Raw Material Dryers. Per 40 CFR Part 63 Subpart LLL, all EUG 1d

existing raw material dryers are subject to the following requirements:

a. Emissions from EUG 1d existing raw material dryers shall not exceed the

following emission limits. The Permittee shall comply with 40 CFR §63.1349

for demonstrating compliance with these emissions limits.

Emissions Limits: EUG 1d – Existing Raw Material Dryers

Pollutant Limit

Opacity 10%

Total Hydrocarbons (THC) 24.0 ppmvd, not corrected for

oxygen, on a 30-day rolling

average

b. The Permittee shall comply with the following monitoring requirements:

THC shall be monitored with a CEMS per 40 CFR §63.1350(i) on each raw

material dryer stack.

Opacity shall be monitored by conducting monthly 10-minute Method 22

visible emissions tests per 40 CFR §63.1350(f)(1). If visible emissions are

observed, initiate corrective actions within 1-hour and conduct a 30-minute


Method 9 performance test. If no visible emissions are observed for six

consecutive monthly tests, then the Plant may decrease the frequency of testing

to semi-annually. If no visible emissions are observed during the semi-annual

test, the Plant may decrease the frequency of testing to annually. If visible

emissions are observed during any semi-annual or annual testing, the Plant must

resume monthly testing.

c. The Permittee shall comply with all applicable recordkeeping requirements per

40 CFR §63.1355.

d. The Permittee shall comply with all applicable reporting requirements per 40

CFR §63.1354.

ii. EUG 1d - Existing Raw Material Dryers [40 CFR Part 98]

All existing raw material dryers must comply with all applicable greenhouse gas

(GHG) reporting requirements and related monitoring and recordkeeping

requirements per 40 CFR Part 98, Subpart C.

The following emissions limits apply to the existing Raw Material Dryer Furnaces.

EUG 1d - Existing Raw Material Dryer Furnaces

EMISSION

SOURCE/EU/EP

NOX

(TPY)

CO

(TPY)

VOC

(TPY)

PM/PM10 (2)

(TPY)

SO2

(TPY)

Raw Mills

Hot Air Furnace/ E-39/ P-

26 (1), 20 MMBTUH

8.6 7.2 0.47 0.65 0.052

Hot Air Furnace/ E-48/ P-

29 (1), 30 MMBTUH

13 11 0.71 0.98 0.077

Total 21.6 18.2 1.18 1.63 0.129 1 - Emissions points P-26 and P-29 are emissions points for the raw mill classifiers. PM in this

table is from combustion. PM emissions from non-combustion materials are included in EUG

– 1c for emissions points P-26 and P-29.

2 Per AP-42 Section 1.4 all PM is assumed to be less than 1 micron so PM10 & PM2.5 = PM.

G. EUG 1e – Open Clinker Storage Piles. EUG 1e consists of fugitive emissions from

open clinker storage piles subject to 40 CFR §63, Subpart LLL. They are also subject

to the requirements of OAC 252:100-29 and the following PM10 emissions limits.

[40 CFR §63, Subpart LLL and OAC 252:100-29]

Emissions Limits: EUG 1e – Open Clinker Storage Piles


Basis

Controls

(%)

Emiss.

Factor

Basis

PM10

(TPY)


Clinker Storage Pile – Outside/ E-104/ P-

61 Throughput


Clinker Storage Hall/ E-103/ P-60 Throughput

(tons)

1-Wall Shed

(24)

lbs/ton 22.2


a. Compliance with emission limits for clinker storage piles shall be documented by

maintaining records of annual throughput and by operating and maintaining the piles in

accordance with the most current version of the Operation & Maintenance Plan required

by Subpart LLL.

H. EUG 2 – Subpart OOO Non-Metallic Mineral Processing. EUG 2 consists of emissions

units subject to 40 CFR Part 60, Subpart OOO (Nonmetallic Mineral Processing Plants),

that are not subject to 40 CFR Part 63, Subpart LLL. Permittee shall comply with all

applicable requirements of 40 CFR Part 60, Subpart OOO and the following permit PM10

emissions limits. [40 CFR Part 60 Subpart OOO]

Emissions Limits: EUG 2 – Subpart OOO Non-Metallic Mineral Processing


Basis

Controls

(%)

Emiss.

Factor

PM10

(TPY)


E-28/ P-12a

Throughput

(tons)

1-Wall Shed (24)

lbs/ton

13

Belt Conveyor BC1, 36-inch, Hopper Gathering / E-

257 / P-260 None

1.4

Belt Conveyor BC2, 36-inch, Additive Transfer / E-

258 / P-261 1.4

a. Compliance with emission limits for sources in this group shall be documented by

maintaining records of annual throughputs and by operating and maintaining the

associated equipment as recommended by the manufacturer.

The facility is subject to the requirements of 40 CFR Part 60, Subpart OOO, including but

not limited to the following:

Subpart OOO—Standards of Performance for Nonmetallic Mineral Processing Plants

§60.670 Applicability and designation of affected facility.


§60.672 Standard for particulate matter (PM).

§60.673 Reconstruction.

§60.674 Monitoring of operations.

§60.675 Test methods and procedures.

§60.676 Reporting and recordkeeping.

Table 1 to Subpart OOO of Part 60—Exceptions to Applicability of Subpart A to Subpart

OOO

Table 2 to Subpart OOO of Part 60—Stack Emission Limits for Affected Facilities With

Capture Systems

Table 3 to Subpart OOO of Part 60—Fugitive Emission Limits

I. EUG 3 – OAC 252:100-25 Non-Metallic Mineral Processing Equipment. EUG 3

consists of emissions units that predate Subpart OOO, and are subject to OAC 252:100-19

& 25. The permittee shall comply with all applicable requirements including standards,

monitoring and test methods and the following PM10 emissions limits. [OAC 252:100-25]

http://www.ecfr.gov/cgi-bin/text-idx?SID=fb4155187c86c0970368abdfca47281b&mc=true&node=sp40.7.60.ooo&rgn=div6#se40.7.60_1670







http://www.ecfr.gov/cgi-bin/text-idx?SID=fb4155187c86c0970368abdfca47281b&mc=true&node=sp40.7.60.ooo&rgn=div6#ap40.7.60_1676.1






Emissions Limits: EUG 3 – OAC 252:100-25 Non-Metallic Mineral Processing EMISSION SOURCE/EU/EP Compliance

Basis

Controls

(%)

Emiss.

Factor

Basis

PM10

(TPY)


Discharge (acf)

Baghouse &

Foam Spray (95)

Enclosed & Foam Spray (80)

gr/acf 6


Wobbler Fines Belt Conveyor (E-7, P-6)

Primary Crusher, 6185/ (E-8, P-6)


Discharge (acf) Baghouse (95) gr/acf 6.5 Primary Vibrating Screen (E-10, P-7)


Load Hopper (E-12, P-9) Throughput (tons) Foam Spray (50) lbs/ton 63.0(1)


Discharge (acf)

Baghouse & Foam Spray (95)

gr/acf 63.0(1)

Secondary Crusher, 05NC/ (E-15, P-8) Baghouse (95) gr/acf 63.0(1)



Secondary Vibrating Screen (E-18, P-10) Discharge (acf) Baghouse (95) gr/acf 72.1(1)

#3 Primary Belt Conveyor, 30-inch (E-19, P-11a)

Discharge (acf)

Baghouse (95)

gr/acf 3.43

#3 Secondary Belt Conveyor, 36-inch/ (E-20, P-11a) Baghouse (95)

#4 Crossover Belt Conveyor, 36-inch/ (E-21, P-11b) Baghouse (95) 1.01

A-Frame Storage E-27a/P-18 Throughput (tons) 2-Wall

Enclosure (36) lbs/ton 12


12b Discharge (acf) Baghouse (95) gr/acf 1.4

6 - Belt Conveyors (3 Working)/ E-30/ P-21 Throughput (tons) Foam and Enclosure

(60) lbs/ton 0.25

#1 Reclaim Belt Conveyor, 30-foot/ E-31/ P-22

Throughput (tons)

Foam and Enclosure

(60)

lbs/ton

6

#2 Reclaim Belt Conveyor, 30-foot/ E-32/ P-23 Foam and Enclosure

(60) 6

#3 Reclaim Belt Conveyor, 30-foot/ E-32a/ P-25 Foam and Enclosure

(60) 6

(1) lb/hr limit of total particulate matter from Subchapter 19.


maintaining records of annual throughputs and by operating and maintaining the

associated equipment as recommended by the manufacturer.

b. Wobbler Feeder (E-6, P-5) and Wobbler Fines Belt Conveyor (E-7, P-5) meet the

criteria of §60.670(d)(1) and are therefore exempt from the provisions of §60.672,

Standard for particulate matter, §60.674, Monitoring of operations, and §60.675, Test

methods and procedures but remain subject to OAC 252:100-19, Control of Emissions

of Particulate Matter & OAC 252:100-25, Visible Emissions And Particulates.

J. EUG 4 - Subpart Y Coal Handling. EUG 4 consists of coal processing and conveying

equipment, breakers/crushers, coal storage systems, and coal transfer and loading systems

subject to 40 CFR Part 60, Subpart Y, Standards of Performance for Coal Preparation

Plants and OAC 252:100-19, Control of Emissions of Particulate Matter. Permittee shall

comply with all applicable requirements of 40 CFR Part 60, Subpart Y including standards,

monitoring and test methods and the following PM10 emissions limits.

[OAC 252:100-19], [40 CFR Part 60 Subpart Y]


Emissions limits: EUG 4 - Subpart Y Coal Handling EMISSION SOURCE/EU/EP Compliance

Basis

Controls

(%)

Emiss.

Factor

Basis

PM10

(TPY)

Coal Handling

Coal Load Hopper/ E-59/ P-34 Throughput (tons)

None lbs/ton

0.085

Coal Belt Conveyor #1/ E-60/ P-35 Enclosed (60) 0.034

Coal Crusher/ E-61/ P-36 Throughput (tons) Enclosed (60) lbs/ton 0.1

Coal Belt Conveyor #2, 24-inch/ E-62/ P-37 Throughput (tons) Enclosed (60) lbs/ton 0.1

Coal Bunker/ E-63/ P-38 Throughput (tons) Enclosed (60) lbs/ton 0.1

#1 Kiln

Coal Weigh Feeder/ E-64/ P-39 Throughput (tons)

Enclosed (60)

lbs/ton

0.04


with Kiln

#2 Kiln


Throughput (tons)

Enclosed (60)

lbs/ton

0.04


with Kiln

#3 Kiln


Throughput (tons)

Enclosed (60)

lbs/ton

0.06


with Kiln


maintaining records of annual throughputs and by operating and maintaining the associated

equipment as recommended by the manufacturer.

i. The permittee is authorized to store up to 50,000 tons of solid fuel at their facility in

Pryor, Oklahoma. [Applicability Determination No. 98-170-AD (M-6)]

K. EUG 5 – Fugitive PM Sources. EUG 5 consists of fugitive emissions from emissions

sources not currently having a federal standard. They are subject to the requirements of

OAC 252:100-29 and the following PM10 emissions limits. [OAC 252:100-29]

Emissions Limits: EUG 5 – Fugitive PM Sources


Basis

Controls

(%)

Emiss.

Factor

Basis

PM10

(TPY)


Load Hopper (E-5, P-5) Throughput

(tons) Foam Spray

(50) lbs/ton 0.34


Gypsum Unloading (Belly Dumping)/ E-

22/ P-13

Throughput

(tons)

None

lbs/ton

4

Gypsum Pile/ E-23/ P-14 None 0.3

Iron Source Pile/ E-24/ P-15 None 0.2

Silica-Alumina Source Pile/ E-25/ P-16 1-Wall Shed

(24) 0.8

Gypsum, Iron Ore Unloading – (hoppers

101 to 106)/E-26/ P-17 None 1.4


Material

Limestone Outside Storage/ E-29/ P-20 None 17


Emissions Limits: EUG 5 – Fugitive PM Sources


Basis

Controls

(%)

Emiss.

Factor

Basis

PM10

(TPY)


CKD Storage Pile/ E-93/ P-54 Throughput

(tons) NA lbs/ton 0.1

Coal Handling

Coal Pile/ E-57/ P-32 Throughput


Haul Roads


CKD Haul Roads/ E-92/ P-53 VMT Water Spray

(50) lbs/VMT 0.43

Coal Handling Coal Haul Roads/ E-58/ P-33 Paved VMT None lbs/VMT 1.0

Coal Haul Roads/ E-58/ P-33 Un-Paved VMT Water Spray

(50) lbs/VMT 1.3

i. The limit on coal pile emissions includes emissions from all solid fuels stored in this

area.

2. Fuels and Monitoring.

A. Kilns No. 1, 2, & 3. Gaseous fuels. Gas-fired fuel-burning equipment shall be fired with

pipeline natural gas as defined in Part 72 having 0.5 grains/100 scf or less total sulfur.

Compliance can be shown by the following methods: for gaseous fuel, a current gas

company bill, lab analysis, stain-tube analysis, gas contract, tariff sheet, or other approved

methods. Compliance shall be demonstrated at least once per calendar year.

[OAC 252:100-31-25]

B. Kilns No. 1, 2, & 3. Solid Fuels. [Permit No. 78-001-O (M-2) and (M-3)]

i. Permittee shall not use any single solid fuel or blend of solid fuels having an average

sulfur content greater than 2.8%W sulfur per hour. (Note that certain assumptions,

primarily that there is an inherent reduction in emissions in the cement kilns, are built

into this limit which is based on the OAC 252:100-31 standard of 1.2 lbs-

SO2/MMBTU.) [OAC 252:100-31-25]

ii. Petroleum coke may be substituted for up to 80 percent coal as a fuel for the kilns.

iii. The quantity of coke and coal fed to the kilns shall be recorded on a daily basis. The

sulfur content (weight percent) of coke and coal burned as fuel shall be determined and

recorded on a weekly basis. [OAC 252:100-31]

C. Kilns No. 1 and 2. Fuel Oil. [Permit No. 76-032-C]

The fuel sulfur content of fuel oil shall not exceed 0.05%.

D. Kilns No. 1, 2, and 3. Tire-Derived-Fuel (TDF).

i. The feed rate of the Tire-Derived-Fuel shall not exceed 30% by heat content of the

total kiln fuel stream. The ratio of petroleum coke fuel to coal fuel shall not exceed

80% coke. [Permit Nos. 78-001-O (M-2); 78-001-O (M-3); & 98-170-C (M-1)]


ii. The Tire-derived Fuel shall arrive at the facility in such condition and shall be

handled in such a manner as to prevent emissions of particulate matter. Opacity

resulting from emissions of particulate matter from handling of Tire-derived fuel

shall be no greater than 0%. [98-170-C (M-1)]

iii. Kilns No. 1 and 2 Only. [Permit No. 98-170-C (M-1)]

a. The feed rate of the Tire-Derived-Fuel into Kiln 1 and 2 combined shall not

exceed 16,700 tons in any 12-month rolling average period.

iv. Kiln No. 3 Only. [Permit No. 78-001-O (M-2)]

a. This permit condition contains requirements specific to the three categories of

plastics authorized by Permit No. 78-001-O (M-2), and are NHSMs not

considered wastes per 40 CFR Part 241, Subpart B—Identification of Non-

Hazardous Secondary Materials That Are Solid Wastes When Used as Fuels or

Ingredients in Combustion Units, which include:

1) Plastic materials, all categories.

2) Polybutylene.

3) Ethylene vinyl acetate copolymer.

4) Mixtures of ethylene vinyl alcohol copolymer and ethylene vinyl acetate

copolymer.

The facility shall not accept any waste identified under 40 CFR Part 261 as

hazardous waste.

b. The following emissions limits apply when burning coal and NHSMs:

Pollutant lb/hr TPY

Particulate Matter 19.7 82.3

Sulfur Dioxide 168.0 735.9

NOX 105.0 459.9

c. Non-hazardous plastic materials may be substituted for coal at a rate of up to

2.85 tons per hour or 75 million Btu/hour, whichever is less.

1) Plastic materials, all categories.

(A) The maximum sulfur content of authorized plastic materials shall not

exceed 0.5%, or 0.25 pounds of sulfur per million Btu heat input rating.

(B) The maximum amount of chlorine introduced into the kiln as a

constituent contained in the plastic materials shall not exceed 34.2

pounds per hour.

2) Polybutylene.

(A) The heat input value of polybutylene materials fuels shall be no less than

19,365 Btu/lb.

(B) The sulfur content of the polybutylene materials shall not result in an

input rate of sulfur exceeding 5,000 ppmw or 28.5 lbs/hr.

(C) The chlorine content of the polybutylene materials shall not result in an

input rate of chlorine exceeding 2,000 ppmw or 11.4 lbs/hr.


(D) The sulfur content of the polybutylene materials shall not result in an

input rate of sulfur exceeding 2,000 ppmw or 11.4 lbs/hr.

(E) The chlorine content of the polybutylene materials shall not result in an

input rate of chlorine exceeding 6,000 ppmw or 34.2 lbs/hr.

3) Ethylene vinyl acetate copolymer.

(A) The heating value of the acetate copolymer shall be no less than 11,400

Btu/ lb.

4) Mixtures of ethylene vinyl alcohol copolymer and ethylene vinyl acetate

copolymer.

(A) The heat input value of this mixed material shall be no less than 9,560

Btu/lb.

v. Kiln No. 3 Only. [Permit No. 78-001-O (M-3)]

a. Permit No. 78-001-O (M-3) and this permit condition expand the scope of

authorization for plastic materials authorized by Permit No. 78-001-O (M-2) to

include additional non-hazardous secondary material fuel streams. Per 40 CFR

Part 241, Subpart B—Identification of Non-Hazardous Secondary Materials

(NHSM) That Are Solid Wastes When Used as Fuels or Ingredients in

Combustion Units, Secondary material means any material that is not the

primary product of a manufacturing or commercial process, and can include

post-consumer material, off-specification commercial chemical products or

manufacturing chemical intermediates, post-industrial material, and scrap.

Examples of the materials are listed in e.

b. The following emissions limits apply when burning coal or coal/coke with a

mixture of non-hazardous fuels.

Pollutant lb/hr TPY

Particulate Matter 19.70 82.29

Sulfur Dioxide 168.00 735.84

NOX 105.00 459.90

c. The total feed rate of sulfur from all fuel sources is limited to 336 lbs/hr. The

weight percent sulfur shall be recorded on the Substitute Fuels Evaluation

Form, incorporated from Permit No. 78-001-O (M-3) and included as

Attachment No. 2 of this permit, and compared with the appropriate limit.

d. The maximum amount of chlorine introduced into the kiln with the NHSM fuel

shall be 34.2 pounds per hour. The chlorine content shall be documented on

the Substitute Fuels Evaluation Form and compared with the appropriate limit.

e. Non-hazardous secondary material fuel streams (except mid-kiln injection of

TDF) may be substituted for coal at a rate of up to 75 MMBTUH. The substitute

fuels shall have a minimum heat input value of 5,000 Btu/lb. Acceptable

substitute fuels include materials, which are not classified as hazardous

according to the RCRA definition of “hazardous waste” in 40 CFR Part 261 and

are NHSM that are not solid wastes as defined in 40 CFR 241, Subpart B—

Identification of Non-Hazardous Secondary Materials That Are Solid Wastes

When Used as Fuels or Ingredients in Combustion Units. These NHSMs are

an addendum and separate from the plastic materials permitted under Permit


No. 78-001-O (M-2) (memorandum dated July 29, 1994, page 2, paragraph 1).

The following are examples of the types of materials added by this condition

that may be used, provided evaluation procedures set forth in the application

and this permit are met and meet the legitimacy requirements of 40 CFR 241.

1) Plastic: materials including post-consumer.

2) Wood.

3) Paper: materials including post-consumer.

4) Rubber: natural and synthetic.

5) Polymers and resins.

6) Pharmaceuticals: off-spec and out-of-date.

7) Grease, oil, and waxes: waste and off-spec.

8) Textile material: rags, synthetic and natural.

9) Absorbents: natural and synthetic (booms and loose).

10) Filter media: natural and synthetic.

11) Inks: water-based.

12) Surfactants

13) Personal protection equipment: suits and gloves.

14) Carbon: printer toner and activated carbon.

f. No substitute fuels covered by condition D.v.e. shall be fed to the kiln unless

the kiln is at full operating temperature for producing clinker.

g. Evaluations shall be performed in accordance with the procedures set forth in

the application for Permit No. 78-001-O (M-3), the “Substitute Fuel Program”

document dated December 2, 1993, and this permit. All non-hazardous

secondary material to be used as fuels shall meet the legitimacy requirements

of 40 CFR §241.3(d). All potential NHSM fuels shall be evaluated prior to any

shipment of the material to the facility and recorded on the Prequalification

Material Profile Form. A sample of the form is incorporated from Permit No.

78-001-O (M-3) as Attachment No. 1 of this permit. Permittee shall obtain all

information necessary to evaluate and characterize the chemical makeup of the

NHSM fuels and to accurately complete the Prequalification Material Profile

Form. This procedure shall include verification of the data submitted by the

generator and calculations to demonstrate emission rates of all HAP.

h. Permittee shall maintain a complete record keeping and tracking system of

NHSM fuels covered by Specific Condition D.v.e. brought on-site. Adequate

records shall be maintained to track NHSM fuels from the initial fuel profiling

through shipping, handling and final utilization in the cement kiln. To meet

these requirements, at a minimum, the following records, or equivalent shall be

maintained on- site:

1) The Prequalification Material Profile Form (sample included as Attachment

No. 1) shall be completed by the generator for each NHSM stream. Data

from additional analyses shall also be included.

2) The Substitute Fuels Evaluation Form (sample included as Attachment No.

2) for each NHSM stream, shall be used to determine whether a NHSM

submitted by a generator is acceptable for use as a substitute fuel.

Information shall include the maximum allowable feed rate, concentrations


of all volatile organic compounds, hazardous air pollutant constituents, and

emission rates.

3) The Daily Substitute Fuels Report (sample included as Attachment No. 3)

shall list shipments of NHSM fuels received on-site for each day and

provide accounting of NHSM fuels in storage and NHSM fuels used in Kiln

No. 3. Information reported shall include the NHSM sample I.D. numbers

for the fingerprint tests, the NHSM fuel profile I.D. number, the generator

name, and quantity of NHSM received in pounds.

4) The Monthly Substitute Fuels Report (sample included as Attachment No.

4) shall summarize the monthly activities of NHSM fuel substitution in Kiln

No. 3 based on the daily reports and includes the “certificate of resource

recovery” identification numbers.

5) The Yearly Substitute Fuels Report (sample included as Attachment No. 5)

shall summarize the total substitute NHSM fuel unloaded for the year and

provide an accounting of material in storage and accounting of materials fed

to Kiln No. 3. The following records shall also be kept.

6) All records required by 1) through 5) of this condition may be kept in

electronic form.

i. A list of NHSM fuels that have remained in storage for more than 12 months

shall be maintained.

j. The weight of NHSM fuel used in Kiln No. 3, 12-month rolling cumulative.

vi. Supplemental fuels authorized by this permit are delivered and handled similar to solid

fuels (coal and coke) but do not require grinding before being pneumatically conveyed

to the kiln through a pipe via hopper, screw feeder and blower. Several equipment

items authorized by Permit No. 78-001-O (M-2) for handling NHSM fuels were

dismantled as a result of the equipment installed for Tire-Derived-Fuel under Permit

No. 98-170-C (M-1). The facility may utilize any equipment constructed for purposes

of fuels delivery, storage, and handling within the permitted emissions limits of that

equipment. [Permit Nos. 78-001-O (M-2) and (M-3)]

3. Hours of Operation. [OAC 252:100-8-6(a)(1)]

A. The facility is authorized to operate 24-hours per day, every day of the year.

B. PHC - Kilns No. 1, 2, & 3. [Permit No. 78-001-O (M-1)]

The permittee is authorized to process petroleum hydrocarbon (PHC) contaminated

material through the crushing system a maximum of 2,080 hours per year and through the

grinding process and the cement kiln(s) 24 hours per day, 365 days per year.

4. Emissions Controls and Monitoring Requirements. [OAC 252:100-43]

A. All Emissions Units (EUs). Each EU control device shall be clearly labeled with the EU

numbers of the controlled equipment on the unit in a conspicuous location that can be easily

accessed for inspection. A site drawing is acceptable for stockpiles and other EUs where

it is not practical to install a label, sign, or other identifier. [OAC 252:100-43]


B. All Emissions Units (EUs). Air pollution control devices may be modified or replaced,

upon prior approval of the Air Quality Division, provided that it can be demonstrated that

the replacement equipment is at least as efficient as the previous pollution control device.

C. Permittee shall comply with all requirements of the Operating and Maintenance Plan.

[40 CFR Part 63 Subpart LLL]

D. Permittee shall operate, maintain, and monitor the following pollution control devices in

accordance with Subpart LLL and this permit.

[OAC 252:100-19, 25-3, & 43], [40 CFR Part 63 Subpart LLL],

[Applicability Determination No. 98-170-AD (M13)]

EUG 1a – Kilns

Emission

Source

Emission

Point

Controls

Type

% PM10 Control

Efficiency Kiln No. 1

P-42 Cyclones/Baghouse 99

Kiln No. 2 Cyclones/Baghouse 99 Kiln No. 3 P-58 Cyclone/Baghouse 99 DSI System

Storage Silo* System (E-272, P-42/P-58) Bin Vent – Pocket Filters 99.99

* Note that the primary purpose of the DSI system is to control HCl emissions from the

kilns which have limits under Subpart LLL.

i. Additional requirements. [Permit No. 78-001-O (M-1)]

a. During normal operations, the temperature of the cement kiln(s) processing

Petroleum Hydrocarbon (PHC) contaminated material shall be 2,000º

Fahrenheit or greater with a retention time of at least two seconds at this

temperature.

b. During periods of kiln start-up or shutdown or emergency or upset conditions,

PHC contaminated material remaining in the kiln shall be retained for at least 2

seconds at temperatures that exceed 1,000º Fahrenheit.


Emission

Source

Emission

Point

Controls

Type

% Control

Efficiency Clinker Cooler No. 1

Clinker Cooler No. 2

Clinker Cooler No. 3

P-43

Hamon Research Cottrell

Electrostatic Precipitator (ESP)

99*

*Actual emission factors from clinker coolers are based on stack test data


EUG 1c – Subpart LLL

Raw/Finish Mills, Storage, Conveyors, Bagging/Bulk Loading/Unloading

Emission

Source

Emission

Point

Controls

Type

% Control

Efficiency

Raw Mill No. 1

Raw Material Hopper 101 / E-270 / P-254 P-254 None (0)






5 - Raw Mill Material Bins/ E-34 P-60 1-Wall Shed (24) Raw Material Weigh Feeders/ E-35

Mill Feed Conveyor Belt/ E-36

Bucket Elevator/ E-37

Classifier/ E-38

Raw Mill Pump/ E-40

19-inch Airslide/ E-42

P-26 Baghouse (95)

#1 Raw Mill (E-41, P-108) P-108 Baghouse 99

Raw Mill No. 2

5 – Raw Mill Material Bins/ E-34 P-60 None * Common to

Raw Mill No. 1 Raw Material Weigh Feeders/ E-44




P-28 Cyclones/Dust

Collector

(99)

Classifier/ E-47

Non-combustion PM emissions

Raw Mill Pump/ E-49

P-29 Baghouse

#2 Raw Mill/ E-50 P-109 Baghouse

Kiln Feed/Blending

3 - Blending Silos/ E-52



Blend Pumps (3)/ E-55

P-30 Baghouse 95

Kiln Feed Storage Silo/ E-56 P-31 Baghouse (95)

Coal Handling Coal Mill to Kiln 1-a/ E-95a

Coal Mill to Kiln 1-b/ E-95b

Coal Mill to Kiln 2-a/ E-95c

Coal Mill to Kiln 2-b/ E-95d

P-42 Enclosed (100)

Coal Mill to Kiln 3-a/ E-95e

Coal Mill to Kiln 3-b/ E-95f P-58 Enclosed (100)

Kiln No. 1 Support Equipment Kiln Feed Tank/ E-66

Feed Tank Bucket Elevator (Kiln 1)/ E-71 P-41 Baghouse 95

Drag Chain Conveyor (clinker), 12-inch/ E-69

Drag Chain Conveyor, 12-inch (clinker)/ E-77/ P-43 ESP Filter 92.5

Clinker Bucket Elevator (clinker)/ E-70/ P-60 Enclosed 60




Emission

Source

Emission

Point

Controls

Type

% Control

Efficiency


Kiln Feed Tank/ E-74 P-46 Baghouse (95)

Feed Tank Bucket Elevator (Kiln 2)/ E-81 P-42 Baghouse

Clinker Bucket Elevator (clinker)/ E-78 P-60 Enclosed (60)


Kiln Feed Tank, 22-inch dia./ E-96

2 – Airslides, 12-inch/ E-97

Feed Hopper for 031-3150 & 031-3694/ E-98

Cyclone Dust Bucket Elevator (Kiln 3)/ E-105


P-57 Baghouse (95)

Drag Chain Conveyor (clinker), 12-inch/ E-101 P-43 ESP Filter (92.5)

Clinker Bucket Elevator/ E-102/ P-60 Enclosed (60)


Baghouse Dust Pump (Kiln 3)/ E-106, P-58 Included in Kiln

Emissions

#17 Screw Conveyor, 16-inch/ E-80

Dust Tank Bucket Elevator/ E-82

Kiln Dust Storage Tank #1, 14-foot dia./ E-83


Kiln Dust Pump/ E-86

FK Pump/ E-87

P-48

Baghouse (95)




P-51 Baghouse (95)

Kiln Dust Storage Tank#3 w/Transport Vessel / E-209 /

P-209

P-209 Bin Vent Dust

Collector

99.99a

Finish Mill No. 1

3 - Clinker/Gypsum Bins/ E-108 P-60 1-Wall Shed (24)

3 - Weigh Feeders/ E-109

Mill Feed Conveyor Belt/ E-110 P-66 Baghouse (99)


Cement Coolers #1 and #2/ E-115




P-63 Baghouse (99)


19-inch Airslide/ E-111a/ P-64

P-64 Baghouse (99)

16-foot Classifier, Sturtevant/ E-114/

Tailings Airslide/ E-114a/ P-66 P-66 Baghouse 99

Finish Mill No. 2

Overhead Crane, 60-foot span/ E-33 (Used for Clinker

and Finish Mills) P-60 Wall Shed (40)

5 (3 in Use) - Clinker/Limestone/Gypsum Bins/E-119 P-60 1-Wall Shed (24)




Emission

Source

Emission

Point

Controls

Type

% Control

Efficiency Weigh Feeders/ E-120


#2 Finish Mill, KVS/ E-122



16-foot Classifier, Sturtevant/ E-126

Cement Cooler/ E-126b

Finish Mill Pump/ E-128

P-67 Baghouse (95)

Finish Mill No. 3

3 - Clinker/Limestone/Gypsum Bins/ E-129/ P-60 1-Wall Shed (24)

#3 Finish Mill/ E-132

Tailings Airslide/ E-135a P-69 Baghouse (99)

Weigh Feeders/ E-130

Mill Feed Conveyor Belt/ E-131 P-70 Baghouse (99)

19-inch Airslide/ E-132a P-270 Baghouse (99)



Classifier, , 18-foot/ E-135

Cement Cooler/ E-135b


Finish Mill Pump, 125-hp, 8H F-K/ E-137

P-70 Baghouse (99)


8 - Cement Storage Silos/ E-138

P-71, 72, &

73

Baghouse (95)

Fringe Bin Pump/ E-139 P-74 Baghouse (95)


Silo/Packhouse Bucket Elevator/ E-147 P-75 Baghouse (95)

Recirculating Pump/ E-149 P-271 Enclosed (100)


Truck Loading Bucket Elevator/ E-143

Loadout Spout/ E-144

P-76 Baghouse (95)


Rail Loading Bucket Elevator/ E-145 P-77 Baghouse (95)

NW Truck & Rail Loadout/ E-146 P-78 Baghouse (95)


11 - Cement Storage Silos/ E-150/ P-80 & 81 Baghouse (95)


East Rail Aux Bucket Elevator/ E-158 P-82 Baghouse (95)


Truck Loading Bucket Elevator/ E-154

Loadout Spout/ E-155

P-83

Baghouse (95)


Rail Loading Bucket Elevator/ E-156 P-84 Baghouse (95)

East Rail Loadout Spout/ E-157 P-85 Baghouse (95)


Cement Storage Silo 15/ E-160a P-87a Baghouse 99.997

Cement Storage Silo 16/ E-160b P-87b Baghouse 99.997




Emission

Source

Emission

Point

Controls

Type

% Control

Efficiency

Loadout Spout/ E-161 P-88 Baghouse 95


Loadout Spout/ E-163 P-89 Baghouse 95

Packhouse

Packer Bins A and B/ E-164

Portland Packer Bucket Elevator/ E-165

Portland Packer/ E-166


Packhouse Fringe Bin/E-172

P-90 Baghouse 95

Packer Bins C and D/ E-168

Masonry Packer Bucket Elevator/ E-169

Masonry Packer/ E-170

10-inch Airslide/ E-171 Packhouse Fringe Bin/E-172

P-91 Baghouse 95

Bag Palletizer/ E-174 P-94 Enclosed 60

Chain Conveyors (Bag Drop)/ E-173 P-93 Enclosed 60

ii. Raw Mills No. 1 & 2, Finish Mill Nos. 1 & 2 & 3 - Daily monitoring requirements.

Permittee shall either:

a. Conduct daily opacity monitoring of all sources using EPA Method 22 and EPA

Method 9 in accordance with §63.1350(e).

OR

b. Install and operate a continuous opacity monitor or bag leak detection system

in accordance with §63.1350(m).

E. EUG 2. Permittee shall operate, maintain, and monitor the following pollution control

devices in accordance with Subpart OOO and this permit.

[OAC 252:100-19, 25-3, & 43], [40 CFR Part 60 Subpart OOO]


Emission

Source

Emission

Point

Controls

Type

% Control

Efficiency #5 Storage Hall Tripper Conveyor Belt, 36-inch/

E-28 P-12a 1-Wall Shed (24)

Belt Conveyor BC1, 36-inch, Hopper Gathering /

E-257 P-260 None (0)

Belt Conveyor BC2, 36-inch, Additive Transfer /

E-258 P-261 None (0)

F. EUG 3. Permittee shall operate, maintain, and monitor the following pollution control

devices in accordance with OAC 252:100-25 and this permit.

[OAC 252:100-19, 25-3, & 43]


EUG 3 – OAC 252:100-25 Non-Metallic Mineral Processing

Emission

Source

Emission

Point

Controls

Type

% Control

Efficiency Load Hopper to Wobbler Feeder/ E-5

Wobbler Feeder/ E-6

Wobbler Fines Belt Conveyor/ E-7

P-6 Baghouse & Foam

Spray (95)

Primary Crusher, 6185/ E-8 P-6 Baghouse & Foam

Spray (95)

#1 Primary Belt Conveyor, 36-inch/ -9

Primary Vibrating Screen E-10

#2 Primary Belt Conveyor, 30-inch/ E11

P-7 Baghouse (95)

Load Hopper/ E-12 P-9 Foam Spray (50)

Wobbler Feeder/ E-13

Secondary Crusher, 05NC/15

#1 Secondary Belt Conveyor, 30-inch/ E16

#2 Secondary Belt Conveyor, 24-inch/ E-17

P-8 Baghouse (95)

Secondary Vibrating Screen/ E-18 P-10 Baghouse (95)

#3 Primary Belt Conveyor, 30-inch (E-19)

#3 Secondary Belt Conveyor, 36-inch/ E-20 P-11a Baghouse (95)

#4 Crossover Belt Conveyor, 36-inch/ E-21 P-11b Baghouse (95)

A-Frame Storage E-27a P-18 2-Wall Enclosure (36)

#5 A-Frame Tripper Belt Conveyor, 30-inch/ E-27 P-12b Baghouse (95)

6 - Belt Conveyors (3 Working)/ E-30 P-21 Foam and

Enclosure (60)

#1 Reclaim Belt Conveyor, 30-foot/ E-31 P-22 Enclosed (100)

#2 Reclaim Belt Conveyor, 30-foot/ E-32 P-23 Foam and

Enclosed (100)

#3 Reclaim Belt Conveyor, 30-foot/ E-32a P-25 Foam and

Enclosed (100)

i. Additional requirements. [Permit No. 78-001-C], [Letter dated January 19, 1978]

a. Conveyor belts shall be covered or enclosed.

b. Material transfer points in the crusher building and the screen building shall be

vented to baghouses.

c. Water spray shall be used at the transfer points on the conveyor line to the raw

material storage hall.

d. The storage hall shall be constructed with divider walls.

G. EUG 4. Permittee shall operate, maintain, and monitor the following pollution control

devices in accordance with Subpart Y and this permit.

[OAC 252:100-19, 25-3, & 43], [40 CFR 60 Subpart Y]


Emission

Source

Emission

Point

Controls

Type

% Control

Efficiency

Coal Handling Coal Load Hopper/ E-59 P-34 None 0

Coal Belt Conveyor #1/ E-60 P-35 None 0

Coal Crusher/ E-61 P-36 Enclosed (60)



Emission

Source

Emission

Point

Controls

Type

% Control

Efficiency Coal Belt Conveyor #2, 24-inch/ E-

62 P-37 Enclosed (60)

Coal Bunker/ E-63 P-38 Enclosed (60)

#1 Kiln

Coal Weigh Feeder/ E-64 P-39 Enclosed (60)

Coal Mill, E-65 P-42 Enclosed

Vented Through Kiln

Stack

#2 Kiln

Coal Weigh Feeder, 24-inch/ E-72 P-45 Enclosed (60)

Coal Mill, E-73 P-42 Enclosed

Vented Through Kiln

Stack

#3 Kiln

Coal Weigh Feeder, 24-inch/ E-94 P-55 Enclosed (60)

Coal Mill, E-95 P-58 Enclosed Vented Through Kiln

Stack

i. Conveyor belts shall be covered or enclosed. [Letter dated June 28, 1976]

H. EUG 5. Permittee shall operate, maintain, and monitor the following equipment in a

manner so as to minimize fugitive dust emissions from all activities.

[OAC 252:100-29 & 43]


Emission

Source

Emission

Point

Controls

Type

% Control

Efficiency Facility-Wide NA NA NA


Equipment

Load Hopper E-5 P-5 Foam Spray (50)


Gypsum Unloading (Belly Dumping)/ E-22 P-13 Specific Condition

No. H.i.

Gypsum Pile/ E-23 P-14 Specific Condition

No. H.i.

Iron Source Pile/ E-24 P-15 Specific Condition

No. H.i.

Shale Pile/ E-25 P-16

Wall Shed

Specific Condition

No. H.i.

(24)

Gypsum, Iron Ore Unloading – Edge of Shed

(F-E Loaders)/E-26 P-17

Specific Condition

No. H.i.


Material

Limestone Outside Storage/ E-29 P-20 Specific Condition

No. H.i.


CKD Storage Pile/ E-93 P-54 Specific Condition

No. H.i.



Emission

Source

Emission

Point

Controls

Type

% Control

Efficiency Miscellaneous Sources

Raw Material Storage Pile/ E-200 P-200 Specific Condition

No. H.i.

Plastics Storage Pile/ E-201 P-201 Specific Condition

No. H.i.

Alternative Fuels Storage Pile/ E-202 P-202 Specific Condition

No. H.i.

Coal Handling

Coal Pile/ E-57 P-32 Specific Condition

No. H.i.

Quarry

Limestone/Shale Haul Trucks/Roads/ E-4 P-4

Water Spray

Specific Condition

No. H.i.

(50)


CKD Haul Roads/ E-92 P-53

Water Spray

Specific Condition

No. H.i.

(50)

Coal Handling

Coal Haul Roads/ E-58 Paved P-33

Water Spray

(Unpaved Only)

NA

Coal Haul Roads/ E-58/ P-33 Un-Paved P-33

Water Spray (50)

Specific Condition

No. H.i.

(50)

i. Reasonable precautions shall be taken to minimize fugitive dust emissions from all

activities. [OAC 252:100-29 & 43]

These precautions shall include, but not be limited to:

a. Use of water or chemicals on roads, stockpiles, material processing and transfer

operations.

b. Apply coatings or coverings to substances susceptible to becoming air-borne or

wind-borne.

c. Cover or wet material in trucks.

d. Plant and maintain vegetation coverings or windbreaks.

e. Locate stockpiles so as to provide minimum exposure to high wind and avoid

open spaces near neighboring homes or businesses.

f. Curtail operations as required to comply with emission limitations.

ii. Petroleum Hydrocarbon Contaminated (PHC) Material. Runoff or leachate from

the stored PHC contaminated material shall not be allowed to leave the site.

[Permit No. 78-001-O (M-1)]

iii. When necessary, timely clean up procedures of fugitive NHSMs from the solid fuel

storage area shall be implemented. [Permit No. 76-032-O (M-1)]

iv. Tires and/or Tire-Derived-Fuel (TDF) shall arrive at the facility in such condition

and shall be handled in such a manner as to prevent emissions of particulate matter.


Emissions of particulate matter from handling of this fuel shall be no greater than

0%. [Permit No. 98-170-C (M-1)]

v. The permittee shall conduct an opacity monitoring program for emissions from

each storage pile and discharge point on enclosures on the same frequency as that

required for EUG 1.c by 40 CFR Part 63 Subpart LLL, §63.1350(f), using EPA

Method 22, with any reductions in frequency also allowed for this EUG. When

discharge points are located inside a building, the VE observations shall be done on

the building ventilation discharges or other dominant as well as any visible

discharge points.

I. EUG 1e. Permittee shall operate, maintain, and monitor the following equipment in a

manner so as to minimize fugitive dust emissions from all activities.

[40 CFR Part 63, Subpart LLL and OAC 252:100-29 & 43]


Emission

Source

Emission

Point

Controls

Type

% Control

Efficiency Kiln No. 3 Support Equipment

Clinker Storage Pile – Outside/ E-104 P-61 Specific Condition

No. H.i.

Clinker Storage Hall/ E-103 P-60

1-Wall Shed

Specific Condition

No. H.i.

(24)

i. Reasonable precautions shall be taken to minimize fugitive dust emissions from all

activities. [OAC 252:100-29 & 43]

These precautions shall include, but not be limited to:

a. Use of water or chemicals on roads, stockpiles, material processing and transfer

operations.

b. Apply coatings or coverings to substances susceptible to becoming air-borne or

wind-borne.

c. Cover or wet material in trucks.

d. Plant and maintain vegetation coverings or windbreaks.

e. Locate stockpiles so as to provide minimum exposure to high wind and avoid

open spaces near neighboring homes or businesses.

f. Curtail operations as required to comply with emission limitations.

J. Baghouses and Dust Collectors - EUGs 1c, 2, 3, and 4 which have a calculated uncontrolled

potential to emit of greater than 100 tons per year. Permittee shall conduct a pressure

monitoring program for the Baghouses and Dust Collectors listed in the following table.

Exclusions to this requirement are specified in the conditions that follow.[OAC 252:100-

43]

EMISSION SOURCE/EU/EP Controls

(%)

Raw Mill No.1



(%)


Cyclones/Dust

Collector (99 )

Baghouse (95)







Collector (99)

Raw Mill No. 2

Raw Material Weigh Feeders/ E-44/ Mill Feed Conveyor Belt/

Bucket Elevator/ E-46/ P-28 Baghouse (95)

Classifier/E-47/ P-29 Cyclones/Dust

Collector (99)

Raw Mill Pump/ E-49/ P-29 Baghouse (95)

24-inch Airslide/ E-51/ P-28 Cyclones/Dust Collector (99)


Collector (99)

Kiln Feed/Blending

All EUs served by P-30 Baghouse (95)


Kiln Feed Tank, 22-inch dia./ E-96/ P-57

Baghouse (95)







Kiln Dust Storage Tank#3 / E-209 / P-209 Dust Collector (99.99)

Finish Mill No. 1

3 - Weigh Feeders/ E-109/ P-66 Baghouse (99)



Baghouse (99)






Dust Collector (99) Tailings Airslide/ E-114a/ P-66

#1 Finish Mill, KVS/ E-111/ P-64 Cyclone/Dust

Collector (99) 19-inch Airslide/ E-111a/ P-64

Finish Mill No. 2


E-119/ P-60 1-Wall Shed (24)

Weigh Feeders/ E-120/ P-67 Baghouse (95)

Cyclone/

Dust Collector (99)





(%)






Finish Mill No. 3

#3 Finish Mill/ E-132/ P-69 Baghouse (99)

Weigh Feeders/ E-130/ P-70 Baghouse (99)

Mill Feed Conveyor Belt/ E-131/ P-70 Baghouse (99)

19-inch Airslide/ E-132a/ P-270 Baghouse (99)

Bucket Elevator/ E-133/ P-70 Baghouse (99)



Tailings Airslide/ E-135a/ P-69 Baghouse (99)





11 - Cement Storage Silos/ E-150/ P-80/P-81 Dust Collectors (95)

Packhouse


Baghouse (95) Portland Packer Bucket Elevator/ E-165/ P-90




Baghouse (95) Masonry Packer Bucket Elevator/ E-169/ P-91



i. This condition does not apply to emissions points monitored with CEMS, COMS,

Bag Leak Detection Systems, or daily Method 22 observations. The pressure drop

across the filter media in pollution control equipment serving the emissions points

listed in the table shall be monitored weekly for pressure drop across the filter

media. All other pollution control equipment using filter media shall be monitored

monthly for pressure drop.

a. The pressure across the filters shall be recorded weekly.

b. The capture system and the housing for the filters shall be constructed, operated,

and maintained such that no bypass of unfiltered emissions occurs.

c. A visual inspection of each pollution control device shall be performed at a

frequency recommended by the manufacturers but no less than weekly.

d. The pollution control devices for equipment subject to 40 CFR Part 63 Subpart

LLL shall be maintained and operated as provided in the Operation and

Maintenance Plan required by LLL and approved by AQD, in such as manner

as to maintain the required efficiency and pressure drop across the filter as


recommended by the filter manufacturer and as required to meet the limits of

this permit.

e. The filter shall be replaced on a frequency recommended by the manufacturer,

or sooner if necessary.

f. A complete preventive maintenance inspection of the pollution control device

shall be performed as provided in the Operation and Maintenance Plan.

K. Electrostatic Precipitator (ESP) – Clinker Coolers 1, 2, & 3.

i. The ESP shall be operated, maintained, and monitored in accordance with the

manufacturer’s recommendations and the Operation and Maintenance Plan,

including all operating parameters, to ensure that the system is achieving an overall

control efficiency of no less than 99% for emission of PM10.

ii. At a minimum, monitoring parameters shall include those in the Operation and

Maintenance (O & M) Plan required by NESHAP LLL.

5. A. Testing requirements. [40 CFR Part 63 Subpart LLL]

Permittee shall comply with the applicable requirements of §63.1349, Performance testing

requirements.

B. Coal Fuel Sampling & Analyses. [Permit No. PSD-OK-61, Permit No. 78-001-O (M-2)]

i. The sulfur content (weight percent) of coke and coal burned as fuel shall be determined

and recorded on a weekly basis.

ii. The fuel supplier’s certification of these analyses will be accepted by AQD.

C. Substitute Fuel Sampling Other than TDF. [Permit No. 78-001-O (M-2) & (M-3)]

i. Upon arrival of each NHSM fuel at the plant, a sample of each load shall be taken. The

sample shall be used to compare the physical properties of the received NHSM material

to the analyses in the Prequalification Material Profile Form for that specific NHSM

fuel to prevent unauthorized NHSM from being unloaded and used. Approval or

disapproval of each load shall be recorded in the Daily Substitute Fuels Report, a

sample form incorporated from Permit No. 78-001-O (M-3) as Attachment No. 3 of

this permit.

ii. All potential fuel streams shall undergo extensive evaluations prior to shipment and

shall be checked upon arrival. In the event a NHSM fuel is for any reason unacceptable,

the entire load shall be rejected and sent back to the generator or responsible party. If

a discrepancy involving inadequate shipping documents occurs, the generator shall be

contacted to resolve the questions. If an acceptable resolution is not achieved, the

NHSM shipment shall be returned to the generator. Non-scheduled shipments of

approved NHSM streams shall be rejected if the facility is unable to offload. Sampling

and physical analysis shall be performed and the bill of lading shall be reviewed prior

to acceptance of any load of NHSM fuel to ensure that the material received is an

authorized NHSM. Split samples shall be retained on-site for 30 days. NHSM fuels

not meeting the criteria of this permit shall be rejected. No hazardous waste shall be

accepted.

iii. Sampling and analytical methods shall be performed in accordance with Test Methods

for the Evaluation of Solid Waste, SW-846, published by the U.S. EPA Office of Solid


Waste; ASTM Physical/Chemical Methods, or other methods approved by EPA and

AQD. The most recent methods shall be utilized.

iv. A representative sample of each potential fuel stream shall be obtained that will provide

a reproducible laboratory analysis. Solids shall be sampled using the appropriate

device to retrieve representative samples from the load. A minimum of six grab

samples shall be taken throughout the load and mixed to form a composite sample for

lab testing and/or analysis. The samples shall be kept in glass jars with Teflon lids and

hand carried or sent to the lab for testing. When necessary, the sample shall be

submitted to the appropriate laboratory in an appropriate container. Samples sent to

the lab shall be properly preserved, packed and accompanied by a chain-of-custody

form. All of the QA/OC procedures of the laboratory shall be adopted. The laboratory

performing the testing and/or analysis shall follow any applicable regulatory

requirements for maintaining, updating, and obtaining approvals for QA/QC plan.

D. Except for demonstrating compliance with 40 CFR Part 63 Subpart LLL, stack testing to

determine compliance with any state standard for total particulate matter shall include the

sum of all filterable and condensable particulate matter (back half) emitted to the ambient

air as measured by applicable reference method(s). [OAC 252:100-19]

6. The following records shall be maintained on-site to verify Insignificant Activities. No

recordkeeping is required for those operations, which qualify as Trivial Activities.

[OAC 252:100-8-6 (a)(3)(B)]

A. Emissions from fuel storage/dispensing equipment operated solely for facility owned

vehicles if fuel throughput is not more than 2,175 gallons/day, averaged over a 30-day

period. Daily throughput, averaged over a 30-day period for the 1000-gallon gasoline

storage/dispensing tank.

B. Storage tanks with less than or equal to 10,000 gallons capacity that store volatile organic

liquids with a true vapor pressure less than or equal to 1.0 psia at maximum storage

temperature. Records of capacity of the tanks and contents for the 550-gallon, 8,000 gallon

and 10,000-gallon diesel fuel storage tanks.

C. Welding and soldering operations utilizing less than 100 pounds of solder and 53 tons per

year of electrodes. Annual consumption of welding and soldering material used.

D. Torch cutting and welding of under 200,000 tons of steel fabricated per year. Annual usage

of steel fabricated by torch cutting and welding.

7. The permittee shall keep records of facility operations as listed below. These records shall be

retained on-site for a period of at least five years following the dates of recording and shall be

made available to regulatory personnel upon request. [OAC 252:100-8-6 (a)(3)(B)]

A. For emissions points having PM limits specified in this permit that use throughput as a

compliance basis, daily, monthly, and 12-month rolling cumulative total amounts of

throughput of process materials (e.g., raw materials, kiln feed, clinker and cement, vehicle

miles travelled). Compliance with hourly limits can be demonstrated using a daily average,

i.e. daily throughput or emissions divided by the daily operating hours.

B. Kiln feed (weight) and fuel consumed (weight and Btu) for each kiln (actual daily).


[Permit No. 98-170-C(M-1)]

C. Analysis of current fuel sulfur content and heat content in BTU/lb (updated whenever the

supply changes). [Permit No. 98-170-C(M-1)]

D. Records of the quantity of solid fuel stored on site shall be maintained on site and shall be

made available to AQD personnel. The records shall be retained for a period of at least five

years after the time they are made. [Permit No. 76-032-O (M-1)]

E. The amount of PHC contaminated material processed per hour and per year; the PHC

content of each barge-load of this material; the volatile content of this material; the hourly

and annual process rate of uncontaminated material; the hours of operation; and the

calculations of the hourly emission rate of volatile material from the grinding, milling and

materials handling processes. These records shall be maintained for a period of five years

after the date they are made. [Permit No. 78-001-O (M-1)]

F. The quantity of coke and coal fed to the kilns shall be recorded on a daily basis. The sulfur

content (weight percent) of coke and coal burned as fuel shall be determined and recorded

on a weekly basis. [Permit No. 78-001-O (M-2)]

G. Permittee shall maintain a complete record keeping and tracking system of Tire-derived

Fuels brought on-site. Adequate records shall be maintained to track NHSM fuels from

the initial fuel profiling through shipping, handling and final utilization in the cement kiln.

H. Where throughput or products cannot be measured, process equipment operating hours,

daily, monthly, 12-month rolling cumulative.

I. Records of monitoring and inspection of all air pollution control equipment required by the

conditions of this permit.

J. Calculations showing compliance with all specific conditions that require calculations

(monthly and 12-month rolling total).

K. For the fuel(s) burned, the appropriate document(s) as required by the conditions of this

permit.

L. Records required by NSPS F, NSPS Y, NSPS OOO, and NESHAP LLL.

M. Records required for COMS operations.

N. Records as required by OAC 252:100-36.2(c).

O. Records of required stack testing from SC 8.

8. At least every two years, the permittee shall conduct performance testing for CO on Kilns No.

1 and 2 stacks and submit a written report of the results to the AQD.

At least every year, the permittee shall conduct performance testing for NOx, CO, and SO2 on

the Kiln No. 3 stack and submit a written report of the results to the AQD.

At least once during the term of the permit, the permittee shall conduct performance testing for

VOC on the Kiln No. 3 stack and submit a written report of the results to the AQD.

A. Performance testing by the permittee shall use the following test methods specified in 40

CFR Part 60.

Method 1: Sample and Velocity Traverses for Stationary Sources.

Method 2: Determination of Stack Gas Velocity and Volumetric Flow Rate.

Method 3: Gas Analysis for Carbon Dioxide, Excess Air, and Dry Molecular Weight.

Method 4: Determination of Moisture in Stack Gases.

Method 6C: Determination of SO2 Emissions from Stationary Sources.

Method 7E: Determination of NOx Emissions from Stationary Sources.

Method 10: Determination of CO Emissions from Stationary Sources.


Method 25A: Determination of VOC Emissions from Stationary Sources.

B. A copy of the test plan shall be provided to AQD at least 30 days prior to each test date.

C. Performance testing shall be conducted while each kiln is operating within 10% of the rate

at which operating permit authorization will be sought.

9. The Permit Shield (Standard Conditions, Section VI) is extended to the following requirements

that have been determined to be inapplicable to this facility.

[OAC 252:100-8-6(d)(2)]

a. OAC 252:100-7 Permits for Minor Facilities

b. OAC 252:100-11 Alternative Emissions Reduction

c. OAC 252:100-15 Mobile Sources

d. OAC 252:100-17 Incinerators

e. OAC 252:100-23 Cotton Gins

f. OAC 252:100-24 Particulate Emissions From Grain, Feed, or Seed Operations

g. OAC 252:100-35 Carbon Monoxide

h. OAC 252:100-39 Nonattainment Areas

i. 40 CFR Part 72 Acid Rain

10. No later than 30 days after each anniversary date of the issuance of the original Title V permit,

the permittee shall submit to Air Quality Division of DEQ, with a copy to the US EPA, Region

6, certification of compliance with the terms and conditions of this permit.

[OAC 252:100-8-6(c)(5)(A), (C), & (D)]

11. This permit supersedes all previous air quality operating permits for the facility which are now

cancelled, except Permit No. PSD-OK-61.

ATTACHMENT NO. 1

SAMPLE PREQUALIFICATION MATERIAL PROFILE

(consisting of 4 pages)

ATTACHMENT NO. 2

SAMPLE SUBSTITUTE FUELS EVALUATION FORM

(consisting of 1 page)

ATTACHMENT NO. 3

SAMPLE DAILY SUBSTITUTE FUELS REPORT


ATTACHMENT NO. 4

SAMPLE MONTHLY SUBSTITUTE FUELS REPORT


ATTACHMENT NO. 5

SAMPLE ANNUAL SUBSTITUTE FUELS REPORT


MAJOR SOURCE AIR QUALITY PERMIT

STANDARD CONDITIONS

(June 21, 2016)

SECTION I. DUTY TO COMPLY

A. This is a permit to operate / construct this specific facility in accordance with the federal Clean

Air Act (42 U.S.C. 7401, et al.) and under the authority of the Oklahoma Clean Air Act and the

rules promulgated there under. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

B. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma

Department of Environmental Quality (DEQ). The permit does not relieve the holder of the

obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or

ordinances. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

C. The permittee shall comply with all conditions of this permit. Any permit noncompliance shall

constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement action,

permit termination, revocation and reissuance, or modification, or for denial of a permit renewal

application. All terms and conditions are enforceable by the DEQ, by the Environmental

Protection Agency (EPA), and by citizens under section 304 of the Federal Clean Air Act

(excluding state-only requirements). This permit is valid for operations only at the specific

location listed.

[40 C.F.R. §70.6(b), OAC 252:100-8-1.3 and OAC 252:100-8-6(a)(7)(A) and (b)(1)]

D. It shall not be a defense for a permittee in an enforcement action that it would have been

necessary to halt or reduce the permitted activity in order to maintain compliance with the

conditions of the permit. However, nothing in this paragraph shall be construed as precluding

consideration of a need to halt or reduce activity as a mitigating factor in assessing penalties for

noncompliance if the health, safety, or environmental impacts of halting or reducing operations

would be more serious than the impacts of continuing operations. [OAC 252:100-8-6(a)(7)(B)]

SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMS

A. Any exceedance resulting from an emergency and/or posing an imminent and substantial

danger to public health, safety, or the environment shall be reported in accordance with Section

XIV (Emergencies). [OAC 252:100-8-6(a)(3)(C)(iii)(I) & (II)]

B. Deviations that result in emissions exceeding those allowed in this permit shall be reported

consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements.

[OAC 252:100-8-6(a)(3)(C)(iv)]

C. Every written report submitted under this section shall be certified as required by Section III

(Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

[OAC 252:100-8-6(a)(3)(C)(iv)]

MAJOR SOURCE STANDARD CONDITIONS June 21, 2016 2

SECTION III. MONITORING, TESTING, RECORDKEEPING & REPORTING

A. The permittee shall keep records as specified in this permit. These records, including

monitoring data and necessary support information, shall be retained on-site or at a nearby field

office for a period of at least five years from the date of the monitoring sample, measurement,

report, or application, and shall be made available for inspection by regulatory personnel upon

request. Support information includes all original strip-chart recordings for continuous monitoring

instrumentation, and copies of all reports required by this permit. Where appropriate, the permit

may specify that records may be maintained in computerized form.

[OAC 252:100-8-6 (a)(3)(B)(ii), OAC 252:100-8-6(c)(1), and OAC 252:100-8-6(c)(2)(B)]

B. Records of required monitoring shall include:

(1) the date, place and time of sampling or measurement;

(2) the date or dates analyses were performed;

(3) the company or entity which performed the analyses;

(4) the analytical techniques or methods used;

(5) the results of such analyses; and

(6) the operating conditions existing at the time of sampling or measurement.

[OAC 252:100-8-6(a)(3)(B)(i)]

C. No later than 30 days after each six (6) month period, after the date of the issuance of the

original Part 70 operating permit or alternative date as specifically identified in a subsequent Part

70 operating permit, the permittee shall submit to AQD a report of the results of any required

monitoring. All instances of deviations from permit requirements since the previous report shall

be clearly identified in the report. Submission of these periodic reports will satisfy any reporting

requirement of Paragraph E below that is duplicative of the periodic reports, if so noted on the

submitted report. [OAC 252:100-8-6(a)(3)(C)(i) and (ii)]

D. If any testing shows emissions in excess of limitations specified in this permit, the owner or

operator shall comply with the provisions of Section II (Reporting Of Deviations From Permit

Terms) of these standard conditions. [OAC 252:100-8-6(a)(3)(C)(iii)]

E. In addition to any monitoring, recordkeeping or reporting requirement specified in this permit,

monitoring and reporting may be required under the provisions of OAC 252:100-43, Testing,

Monitoring, and Recordkeeping, or as required by any provision of the Federal Clean Air Act or

Oklahoma Clean Air Act. [OAC 252:100-43]

F. Any Annual Certification of Compliance, Semi Annual Monitoring and Deviation Report,

Excess Emission Report, and Annual Emission Inventory submitted in accordance with this permit

shall be certified by a responsible official. This certification shall be signed by a responsible

official, and shall contain the following language: “I certify, based on information and belief

formed after reasonable inquiry, the statements and information in the document are true, accurate,

and complete.”

[OAC 252:100-8-5(f), OAC 252:100-8-6(a)(3)(C)(iv), OAC 252:100-8-6(c)(1), OAC

252:100-9-7(e), and OAC 252:100-5-2.1(f)]


G. Any owner or operator subject to the provisions of New Source Performance Standards

(“NSPS”) under 40 CFR Part 60 or National Emission Standards for Hazardous Air Pollutants

(“NESHAPs”) under 40 CFR Parts 61 and 63 shall maintain a file of all measurements and other

information required by the applicable general provisions and subpart(s). These records shall be

maintained in a permanent file suitable for inspection, shall be retained for a period of at least five

years as required by Paragraph A of this Section, and shall include records of the occurrence and

duration of any start-up, shutdown, or malfunction in the operation of an affected facility, any

malfunction of the air pollution control equipment; and any periods during which a continuous

monitoring system or monitoring device is inoperative.

[40 C.F.R. §§60.7 and 63.10, 40 CFR Parts 61, Subpart A, and OAC 252:100, Appendix Q]

H. The permittee of a facility that is operating subject to a schedule of compliance shall submit to

the DEQ a progress report at least semi-annually. The progress reports shall contain dates for

achieving the activities, milestones or compliance required in the schedule of compliance and the

dates when such activities, milestones or compliance was achieved. The progress reports shall

also contain an explanation of why any dates in the schedule of compliance were not or will not

be met, and any preventive or corrective measures adopted. [OAC 252:100-8-6(c)(4)]

I. All testing must be conducted under the direction of qualified personnel by methods approved

by the Division Director. All tests shall be made and the results calculated in accordance with

standard test procedures. The use of alternative test procedures must be approved by EPA. When

a portable analyzer is used to measure emissions it shall be setup, calibrated, and operated in

accordance with the manufacturer’s instructions and in accordance with a protocol meeting the

requirements of the “AQD Portable Analyzer Guidance” document or an equivalent method

approved by Air Quality.

[OAC 252:100-8-6(a)(3)(A)(iv), and OAC 252:100-43]

J. The reporting of total particulate matter emissions as required in Part 7 of OAC 252:100-8

(Permits for Part 70 Sources), OAC 252:100-19 (Control of Emission of Particulate Matter), and

OAC 252:100-5 (Emission Inventory), shall be conducted in accordance with applicable testing or

calculation procedures, modified to include back-half condensables, for the concentration of

particulate matter less than 10 microns in diameter (PM10). NSPS may allow reporting of only

particulate matter emissions caught in the filter (obtained using Reference Method 5).

K. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required

by 40 C.F.R. Part 60, 61, and 63, for all equipment constructed or operated under this permit

subject to such standards. [OAC 252:100-8-6(c)(1) and OAC 252:100, Appendix Q]

SECTION IV. COMPLIANCE CERTIFICATIONS

A. No later than 30 days after each anniversary date of the issuance of the original Part 70

operating permit or alternative date as specifically identified in a subsequent Part 70 operating

permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a certification

of compliance with the terms and conditions of this permit and of any other applicable

requirements which have become effective since the issuance of this permit.

[OAC 252:100-8-6(c)(5)(A), and (D)]


B. The compliance certification shall describe the operating permit term or condition that is the

basis of the certification; the current compliance status; whether compliance was continuous or

intermittent; the methods used for determining compliance, currently and over the reporting

period. The compliance certification shall also include such other facts as the permitting authority

may require to determine the compliance status of the source.

[OAC 252:100-8-6(c)(5)(C)(i)-(v)]

C. The compliance certification shall contain a certification by a responsible official as to the

results of the required monitoring. This certification shall be signed by a responsible official, and

shall contain the following language: “I certify, based on information and belief formed after

reasonable inquiry, the statements and information in the document are true, accurate, and

complete.” [OAC 252:100-8-5(f) and OAC 252:100-8-6(c)(1)]

D. Any facility reporting noncompliance shall submit a schedule of compliance for emissions

units or stationary sources that are not in compliance with all applicable requirements. This

schedule shall include a schedule of remedial measures, including an enforceable sequence of

actions with milestones, leading to compliance with any applicable requirements for which the

emissions unit or stationary source is in noncompliance. This compliance schedule shall resemble

and be at least as stringent as that contained in any judicial consent decree or administrative order

to which the emissions unit or stationary source is subject. Any such schedule of compliance shall

be supplemental to, and shall not sanction noncompliance with, the applicable requirements on

which it is based, except that a compliance plan shall not be required for any noncompliance

condition which is corrected within 24 hours of discovery.

[OAC 252:100-8-5(e)(8)(B) and OAC 252:100-8-6(c)(3)]

SECTION V. REQUIREMENTS THAT BECOME APPLICABLE DURING THE

PERMIT TERM

The permittee shall comply with any additional requirements that become effective during the

permit term and that are applicable to the facility. Compliance with all new requirements shall be

certified in the next annual certification. [OAC 252:100-8-6(c)(6)]

SECTION VI. PERMIT SHIELD

A. Compliance with the terms and conditions of this permit (including terms and conditions

established for alternate operating scenarios, emissions trading, and emissions averaging, but

excluding terms and conditions for which the permit shield is expressly prohibited under OAC

252:100-8) shall be deemed compliance with the applicable requirements identified and included

in this permit. [OAC 252:100-8-6(d)(1)]

B. Those requirements that are applicable are listed in the Standard Conditions and the Specific

Conditions of this permit. Those requirements that the applicant requested be determined as not

applicable are summarized in the Specific Conditions of this permit. [OAC 252:100-8-6(d)(2)]


SECTION VII. ANNUAL EMISSIONS INVENTORY & FEE PAYMENT

The permittee shall file with the AQD an annual emission inventory and shall pay annual fees

based on emissions inventories. The methods used to calculate emissions for inventory purposes

shall be based on the best available information accepted by AQD.

[OAC 252:100-5-2.1, OAC 252:100-5-2.2, and OAC 252:100-8-6(a)(8)]

SECTION VIII. TERM OF PERMIT

A. Unless specified otherwise, the term of an operating permit shall be five years from the date of

issuance. [OAC 252:100-8-6(a)(2)(A)]

B. A source’s right to operate shall terminate upon the expiration of its permit unless a timely and

complete renewal application has been submitted at least 180 days before the date of

expiration. [OAC 252:100-8-7.1(d)(1)]

C. A duly issued construction permit or authorization to construct or modify will terminate and

become null and void (unless extended as provided in OAC 252:100-8-1.4(b)) if the construction

is not commenced within 18 months after the date the permit or authorization was issued, or if

work is suspended for more than 18 months after it is commenced. [OAC 252:100-8-1.4(a)]

D. The recipient of a construction permit shall apply for a permit to operate (or modified operating

permit) within 180 days following the first day of operation. [OAC 252:100-8-4(b)(5)]

SECTION IX. SEVERABILITY

The provisions of this permit are severable and if any provision of this permit, or the application

of any provision of this permit to any circumstance, is held invalid, the application of such

provision to other circumstances, and the remainder of this permit, shall not be affected thereby.

[OAC 252:100-8-6 (a)(6)]

SECTION X. PROPERTY RIGHTS

A. This permit does not convey any property rights of any sort, or any exclusive privilege.

[OAC 252:100-8-6(a)(7)(D)]

B. This permit shall not be considered in any manner affecting the title of the premises upon which

the equipment is located and does not release the permittee from any liability for damage to persons

or property caused by or resulting from the maintenance or operation of the equipment for which

the permit is issued. [OAC 252:100-8-6(c)(6)]

SECTION XI. DUTY TO PROVIDE INFORMATION

A. The permittee shall furnish to the DEQ, upon receipt of a written request and within sixty (60)

days of the request unless the DEQ specifies another time period, any information that the DEQ

may request to determine whether cause exists for modifying, reopening, revoking, reissuing,


terminating the permit or to determine compliance with the permit. Upon request, the permittee

shall also furnish to the DEQ copies of records required to be kept by the permit.

[OAC 252:100-8-6(a)(7)(E)]

B. The permittee may make a claim of confidentiality for any information or records submitted

pursuant to 27A O.S. § 2-5-105(18). Confidential information shall be clearly labeled as such and

shall be separable from the main body of the document such as in an attachment.

[OAC 252:100-8-6(a)(7)(E)]

C. Notification to the AQD of the sale or transfer of ownership of this facility is required and shall

be made in writing within thirty (30) days after such sale or transfer.

[Oklahoma Clean Air Act, 27A O.S. § 2-5-112(G)]

SECTION XII. REOPENING, MODIFICATION & REVOCATION

A. The permit may be modified, revoked, reopened and reissued, or terminated for cause. Except

as provided for minor permit modifications, the filing of a request by the permittee for a permit

modification, revocation and reissuance, termination, notification of planned changes, or

anticipated noncompliance does not stay any permit condition.

[OAC 252:100-8-6(a)(7)(C) and OAC 252:100-8-7.2(b)]

B. The DEQ will reopen and revise or revoke this permit prior to the expiration date in the

following circumstances: [OAC 252:100-8-7.3 and OAC 252:100-8-7.4(a)(2)]

(1) Additional requirements under the Clean Air Act become applicable to a major source

category three or more years prior to the expiration date of this permit. No such reopening

is required if the effective date of the requirement is later than the expiration date of this

permit.

(2) The DEQ or the EPA determines that this permit contains a material mistake or that the

permit must be revised or revoked to assure compliance with the applicable requirements.

(3) The DEQ or the EPA determines that inaccurate information was used in establishing the

emission standards, limitations, or other conditions of this permit. The DEQ may revoke

and not reissue this permit if it determines that the permittee has submitted false or

misleading information to the DEQ.

(4) DEQ determines that the permit should be amended under the discretionary reopening

provisions of OAC 252:100-8-7.3(b).

C. The permit may be reopened for cause by EPA, pursuant to the provisions of OAC 100-8-

7.3(d). [OAC 100-8-7.3(d)]

D. The permittee shall notify AQD before making changes other than those described in Section

XVIII (Operational Flexibility), those qualifying for administrative permit amendments, or those

defined as an Insignificant Activity (Section XVI) or Trivial Activity (Section XVII). The

notification should include any changes which may alter the status of a “grandfathered source,” as

defined under AQD rules. Such changes may require a permit modification.

[OAC 252:100-8-7.2(b) and OAC 252:100-5-1.1]


E. Activities that will result in air emissions that exceed the trivial/insignificant levels and that

are not specifically approved by this permit are prohibited. [OAC 252:100-8-6(c)(6)]

SECTION XIII. INSPECTION & ENTRY

A. Upon presentation of credentials and other documents as may be required by law, the permittee

shall allow authorized regulatory officials to perform the following (subject to the permittee's right

to seek confidential treatment pursuant to 27A O.S. Supp. 1998, § 2-5-105(17) for confidential

information submitted to or obtained by the DEQ under this section):

(1) enter upon the permittee's premises during reasonable/normal working hours where a

source is located or emissions-related activity is conducted, or where records must be kept

under the conditions of the permit;

(2) have access to and copy, at reasonable times, any records that must be kept under the

conditions of the permit;

(3) inspect, at reasonable times and using reasonable safety practices, any facilities, equipment

(including monitoring and air pollution control equipment), practices, or operations

regulated or required under the permit; and

(4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times

substances or parameters for the purpose of assuring compliance with the permit.

[OAC 252:100-8-6(c)(2)]

SECTION XIV. EMERGENCIES

A. Any exceedance resulting from an emergency shall be reported to AQD promptly but no later

than 4:30 p.m. on the next working day after the permittee first becomes aware of the exceedance.

This notice shall contain a description of the emergency, the probable cause of the exceedance,

any steps taken to mitigate emissions, and corrective actions taken.

[OAC 252:100-8-6 (a)(3)(C)(iii)(I) and (IV)]

B. Any exceedance that poses an imminent and substantial danger to public health, safety, or the

environment shall be reported to AQD as soon as is practicable; but under no circumstance shall

notification be more than 24 hours after the exceedance. [OAC 252:100-8-6(a)(3)(C)(iii)(II)]

C. An "emergency" means any situation arising from sudden and reasonably unforeseeable events

beyond the control of the source, including acts of God, which situation requires immediate

corrective action to restore normal operation, and that causes the source to exceed a technology-

based emission limitation under this permit, due to unavoidable increases in emissions attributable

to the emergency. An emergency shall not include noncompliance to the extent caused by

improperly designed equipment, lack of preventive maintenance, careless or improper operation,

or operator error. [OAC 252:100-8-2]

D. The affirmative defense of emergency shall be demonstrated through properly signed,

contemporaneous operating logs or other relevant evidence that: [OAC 252:100-8-6 (e)(2)]

(1) an emergency occurred and the permittee can identify the cause or causes of the emergency;


(2) the permitted facility was at the time being properly operated;

(3) during the period of the emergency the permittee took all reasonable steps to minimize

levels of emissions that exceeded the emission standards or other requirements in this

permit.

E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an

emergency shall have the burden of proof. [OAC 252:100-8-6(e)(3)]

F. Every written report or document submitted under this section shall be certified as required by

Section III (Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

[OAC 252:100-8-6(a)(3)(C)(iv)]

SECTION XV. RISK MANAGEMENT PLAN

The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop and

register with the appropriate agency a risk management plan by June 20, 1999, or the applicable

effective date. [OAC 252:100-8-6(a)(4)]

SECTION XVI. INSIGNIFICANT ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate individual emissions units that are either on the list in Appendix I to OAC Title 252,

Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below. Any

activity to which a State or Federal applicable requirement applies is not insignificant even if it

meets the criteria below or is included on the insignificant activities list.

(1) 5 tons per year of any one criteria pollutant.

(2) 2 tons per year for any one hazardous air pollutant (HAP) or 5 tons per year for an aggregate

of two or more HAP's, or 20 percent of any threshold less than 10 tons per year for single

HAP that the EPA may establish by rule.

[OAC 252:100-8-2 and OAC 252:100, Appendix I]

SECTION XVII. TRIVIAL ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate any individual or combination of air emissions units that are considered inconsequential

and are on the list in Appendix J. Any activity to which a State or Federal applicable requirement

applies is not trivial even if included on the trivial activities list.

[OAC 252:100-8-2 and OAC 252:100, Appendix J]

SECTION XVIII. OPERATIONAL FLEXIBILITY

A. A facility may implement any operating scenario allowed for in its Part 70 permit without the

need for any permit revision or any notification to the DEQ (unless specified otherwise in the

permit). When an operating scenario is changed, the permittee shall record in a log at the facility

the scenario under which it is operating. [OAC 252:100-8-6(a)(10) and (f)(1)]


B. The permittee may make changes within the facility that:

(1) result in no net emissions increases,

(2) are not modifications under any provision of Title I of the federal Clean Air Act, and

(3) do not cause any hourly or annual permitted emission rate of any existing emissions unit

to be exceeded;

provided that the facility provides the EPA and the DEQ with written notification as required

below in advance of the proposed changes, which shall be a minimum of seven (7) days, or twenty

four (24) hours for emergencies as defined in OAC 252:100-8-6 (e). The permittee, the DEQ, and

the EPA shall attach each such notice to their copy of the permit. For each such change, the written

notification required above shall include a brief description of the change within the permitted

facility, the date on which the change will occur, any change in emissions, and any permit term or

condition that is no longer applicable as a result of the change. The permit shield provided by this

permit does not apply to any change made pursuant to this paragraph. [OAC 252:100-8-6(f)(2)]

SECTION XIX. OTHER APPLICABLE & STATE-ONLY REQUIREMENTS

A. The following applicable requirements and state-only requirements apply to the facility unless

elsewhere covered by a more restrictive requirement:

(1) Open burning of refuse and other combustible material is prohibited except as authorized

in the specific examples and under the conditions listed in the Open Burning Subchapter.

[OAC 252:100-13]

(2) No particulate emissions from any fuel-burning equipment with a rated heat input of 10

MMBTUH or less shall exceed 0.6 lb/MMBTU. [OAC 252:100-19]

(3) For all emissions units not subject to an opacity limit promulgated under 40 C.F.R., Part

60, NSPS, no discharge of greater than 20% opacity is allowed except for:

[OAC 252:100-25]

(a) Short-term occurrences which consist of not more than one six-minute period in any

consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours.

In no case shall the average of any six-minute period exceed 60% opacity;

(b) Smoke resulting from fires covered by the exceptions outlined in OAC 252:100-13-7;

(c) An emission, where the presence of uncombined water is the only reason for failure to

meet the requirements of OAC 252:100-25-3(a); or

(d) Smoke generated due to a malfunction in a facility, when the source of the fuel

producing the smoke is not under the direct and immediate control of the facility and

the immediate constriction of the fuel flow at the facility would produce a hazard to

life and/or property.

(4) No visible fugitive dust emissions shall be discharged beyond the property line on which

the emissions originate in such a manner as to damage or to interfere with the use of


adjacent properties, or cause air quality standards to be exceeded, or interfere with the

maintenance of air quality standards. [OAC 252:100-29]

(5) No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2

lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur

dioxide. [OAC 252:100-31]

(6) Volatile Organic Compound (VOC) storage tanks built after December 28, 1974, and with

a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia or

greater under actual conditions shall be equipped with a permanent submerged fill pipe or

with a vapor-recovery system. [OAC 252:100-37-15(b)]

(7) All fuel-burning equipment shall at all times be properly operated and maintained in a

manner that will minimize emissions of VOCs. [OAC 252:100-37-36]

SECTION XX. STRATOSPHERIC OZONE PROTECTION

A. The permittee shall comply with the following standards for production and consumption of

ozone-depleting substances: [40 CFR 82, Subpart A]

(1) Persons producing, importing, or placing an order for production or importation of certain

class I and class II substances, HCFC-22, or HCFC-141b shall be subject to the

requirements of §82.4;

(2) Producers, importers, exporters, purchasers, and persons who transform or destroy certain

class I and class II substances, HCFC-22, or HCFC-141b are subject to the recordkeeping

requirements at §82.13; and

(3) Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons,

HBFCs, carbon tetrachloride, trichloroethane (methyl chloroform), and bromomethane

(Methyl Bromide). Class II substances (listed at Appendix B to Subpart A) include

HCFCs.

B. If the permittee performs a service on motor (fleet) vehicles when this service involves an

ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air

conditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term

“motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the

vehicle has not been completed. The term “MVAC” as used in Subpart B does not include the air-

tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger buses

using HCFC-22 refrigerant. [40 CFR 82, Subpart B]

C. The permittee shall comply with the following standards for recycling and emissions reduction

except as provided for MVACs in Subpart B: [40 CFR 82, Subpart F]

(1) Persons opening appliances for maintenance, service, repair, or disposal must comply with

the required practices pursuant to § 82.156;

(2) Equipment used during the maintenance, service, repair, or disposal of appliances must

comply with the standards for recycling and recovery equipment pursuant to § 82.158;

(3) Persons performing maintenance, service, repair, or disposal of appliances must be


certified by an approved technician certification program pursuant to § 82.161;

(4) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply

with record-keeping requirements pursuant to § 82.166;

(5) Persons owning commercial or industrial process refrigeration equipment must comply

with leak repair requirements pursuant to § 82.158; and

(6) Owners/operators of appliances normally containing 50 or more pounds of refrigerant must

keep records of refrigerant purchased and added to such appliances pursuant to § 82.166.

SECTION XXI. TITLE V APPROVAL LANGUAGE

A. DEQ wishes to reduce the time and work associated with permit review and, wherever it is not

inconsistent with Federal requirements, to provide for incorporation of requirements established

through construction permitting into the Source’s Title V permit without causing redundant

review. Requirements from construction permits may be incorporated into the Title V permit

through the administrative amendment process set forth in OAC 252:100-8-7.2(a) only if the

following procedures are followed:

(1) The construction permit goes out for a 30-day public notice and comment using the

procedures set forth in 40 C.F.R. § 70.7(h)(1). This public notice shall include notice to

the public that this permit is subject to EPA review, EPA objection, and petition to EPA,

as provided by 40 C.F.R. § 70.8; that the requirements of the construction permit will be

incorporated into the Title V permit through the administrative amendment process; that

the public will not receive another opportunity to provide comments when the

requirements are incorporated into the Title V permit; and that EPA review, EPA

objection, and petitions to EPA will not be available to the public when requirements

from the construction permit are incorporated into the Title V permit.

(2) A copy of the construction permit application is sent to EPA, as provided by 40 CFR §

70.8(a)(1).

(3) A copy of the draft construction permit is sent to any affected State, as provided by 40

C.F.R. § 70.8(b).

(4) A copy of the proposed construction permit is sent to EPA for a 45-day review period as

provided by 40 C.F.R.§ 70.8(a) and (c).

(5) The DEQ complies with 40 C.F.R. § 70.8(c) upon the written receipt within the 45-day

comment period of any EPA objection to the construction permit. The DEQ shall not

issue the permit until EPA’s objections are resolved to the satisfaction of EPA.

(6) The DEQ complies with 40 C.F.R. § 70.8(d).

(7) A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8(a).

(8) The DEQ shall not issue the proposed construction permit until any affected State and

EPA have had an opportunity to review the proposed permit, as provided by these permit

conditions.

(9) Any requirements of the construction permit may be reopened for cause after

incorporation into the Title V permit by the administrative amendment process, by DEQ

as provided in OAC 252:100-8-7.3(a), (b), and (c), and by EPA as provided in 40 C.F.R.

§ 70.7(f) and (g).


(10) The DEQ shall not issue the administrative permit amendment if performance tests fail

to demonstrate that the source is operating in substantial compliance with all permit

requirements.

B. To the extent that these conditions are not followed, the Title V permit must go through the

Title V review process.

SECTION XXII. CREDIBLE EVIDENCE

For the purpose of submitting compliance certifications or establishing whether or not a person

has violated or is in violation of any provision of the Oklahoma implementation plan, nothing shall

preclude the use, including the exclusive use, of any credible evidence or information, relevant to

whether a source would have been in compliance with applicable requirements if the appropriate

performance or compliance test or procedure had been performed.

[OAC 252:100-43-6]


Attn: Mr. Terrence P. Byrne, Plant Manager

P.O. Box 68

Pryor, OK 74362

Re: Permit No. 2015-1720-TVR; Facility ID: 0910



Dear Mr. Bryne:

Enclosed is the permit authorizing operation of the referenced facility. Please note that this permit

is issued subject to standard and specific conditions, which are attached. These conditions must

be carefully followed since they define the limits of the permit and will be confirmed by periodic

inspections.

Also note that you are required to annually submit an emission inventory for this facility. An

emission inventory must be completed on approved AQD forms and submitted (hardcopy or

electronically) every year by April 1st. Any questions concerning the form or submittal process

should be referred to the Emission Inventory Staff at 405-702-4100.

Thank you for your cooperation in this matter. If we may be of further service, please contact

David Pollard at (918) 293-1617 or by mail at DEQ Regional Office at Tulsa, 3105 East Skelly

Drive, Suite 200, Tulsa, Oklahoma, 74105.

Sincerely,

Phillip Fielder, P.E.

Chief Engineer



Attn: Mr. Terrence P. Byrne, Plant Manager

P.O. Box 68

Pryor, OK 74362

Re: Permit No. 2015-1720-TVR



Facility ID: 0910

Dear Mr. Byrne:

Air Quality has received the permit application for the referenced facility and completed initial

review. This application has been determined to be a Tier II application. In accordance with 27A

O.S. 2-14-301 and 302 and OAC 252:4-7-13(c), the enclosed draft permit is now ready for public

review. The requirements for public review of the draft permit include the following steps, which

you must accomplish.

1. Publish at least one legal notice (one day) in at least one newspaper of general circulation

within the county where the facility is located. (Instructions enclosed)

2. Provide for public review, for a period of 30 days following the date of the newspaper

announcement, a copy of the application and draft permit at a convenient location

(preferentially at a public location) within the county of the facility.

3. Send AQD a signed affidavit of publication for the notice(s) from Item #1 above within 20

days of publication of the draft permit. Any additional comments or requested changes you

have for the draft permit or the application should be submitted within 30 days of publication.

Thank you for your cooperation in this matter. If we may be of further service, please contact

David Pollard at (918) 293-1617 or by mail at 3105 E. Skelly Dr., Suite 200, Tulsa Oklahoma

74105.

Sincerely,

Phillip Fielder, P.E.

Chief Engineer


December 16, 2019

Missouri Department of Natural Resources

Air Pollution Control Program

Construction Permits

P. O. Box 176

Jefferson City, MO 65102-1076

SUBJECT: Permit Number: 2015-1720-TVR

Facility: Lone Star Industries, Inc., dba Buzzi Unicem USA


Facility ID: 0910

Location: 2430 South 437 (Lat. 36.27211; Long. 95.22069)


5 miles east of Pryor on Highway 20 and 2 miles south

Permit Writer: David Pollard

Dear Sir / Madame:

The subject facility has requested a permit to renew their Title V operating permit under 40 CFR

Part 70. Air Quality Division has completed the initial review of the application and prepared a

draft permit for public review. Since this facility is within 50 miles of the Oklahoma – Missouri

border, a copy of the proposed permit will be provided to you upon request. A copy of the draft

permit is also posted on the Air Quality section of the DEQ web page: www.deq.state.ok.us

Thank you for your cooperation. If you have any questions, please refer to the permit number

above and contact me at (405) 702-4100 or the permit writer (David Pollard) at (918) 293-1617.

Sincerely,

Phillip Fielder, P.E., Chief Engineer


December 16, 2019

Arkansas Dept. of Pollution Control and Ecology

P. O. Box 8913

Little Rock, AR 72219-8913

SUBJECT: Permit Number: 2015-1720-TVR

Facility: Lone Star Industries, Inc., dba Buzzi Unicem USA


Facility ID: 0910

Location: 2430 South 437 (Lat. 36.27211; Long. 95.22069)


5 miles east of Pryor on Highway 20 and 2 miles south

Permit Writer: David Pollard

Dear Sir / Madame:

The subject facility has requested a permit to renew their Title V operating permit under 40 CFR

Part 70. Air Quality Division has completed the initial review of the application and prepared a

draft permit for public review. Since this facility is within 50 miles of the Oklahoma – Arkansas

border, a copy of the proposed permit will be provided to you upon request. A copy of the draft

permit is also posted on the Air Quality section of the DEQ web page: www.deq.state.ok.us

Thank you for your cooperation. If you have any questions, please refer to the permit number

above and contact me at (405) 702-4100 or the permit writer (David Pollard) at (918) 293-1617.

Sincerely,

Phillip Fielder, P.E., Chief Engineer


PART 70 PERMIT


STATE OF OKLAHOMA

DEPARTMENT OF ENVIRONMENTAL QUALITY

707 N. ROBINSON, SUITE 4100

P.O. BOX 1677

OKLAHOMA CITY, OKLAHOMA 73101-1677

Permit No. 2015-1720-TVR

Lone Star Industries, dba Buzzi Unicem USA,

having complied with the requirements of the law, is hereby granted permission to operate

all the sources within their boundaries in Pryor, Mayes County, Oklahoma,

subject to standard conditions dated June 21, 2016 and specific conditions, both attached.

This permit shall expire five (5) years from the date below, except as authorized under

Section VIII of the Standard Conditions.

_________________________________

Eddie Terrell, Division Director Date

Air Quality Division

Documents

DRAFT OKLAHOMA DEPARTMENT OF ENVIRONMENTAL ......grain loading factor of 0.015 gr/acf, used in Permit No. PSD-OK-61. E-21 is controlled by a 1,800 E-21 is controlled by a 1,800 acfm