Preliminary Determination - Carolinas Cement Company

NORTH CAROLINA DIVISION OF AIR QUALITY PSD Preliminary Review – modification 300 construction/operation permit (Revision 4, September 9, 2009) Permit Issue Date: XXXX, 2009 “Draft Revision 4” Facility Data

Region: Wilmington Regional Office County: New Hanover NC Facility ID: 6500296 Inspector’s Name: Terry McCall Date of Last Inspection: 10/22/2007 Compliance Code: 3/In Compliance - Inspection Permit Applicability (this application only)

Applicant (Facility’s Name): Carolinas Cement Company LLC Formally known as Roanoke Cement Company, LLC

SIP: 15A NCAC 2D .0510, 2D .0513, 2D .0515, 2D .0516, 2D .0530, 2D .0540, 2D .0524, 2D .1100, 2D .1111

Facility Address: Carolinas Cement Company LLC 6411 Ideal Cement Road Castle Hayne, North Carolina 28429

NSPS: 40 CFR Part 60, Subpart F, Subpart OOO, Subpart IIII, Subpart Y

SIC: 3241 / Cement, Hydraulic NAICS: 327310 / Cement Manufacturing Facility Classification: Before: Small After: Title V Fee Classification: Before: Small After: Title V Contact Data Facility Contact James S. Willis Corporate Environ. Mgr. 6071 Catawba Road Troutville, Va. 24175 (540) 992-3674

Authorized Contact Russell A. Fink Vice President, General Council, and Secretary 1151 Azalea Garden Rd. Norfolk, Va. 23502 ((757) 858-6523

Technical Contact James S. Willis Corporate Environ. Mgr. 6071 Catawba Road Troutville, Va. 24175 (540) 992-3674

[email protected]

[email protected]

[email protected]

Consultant: Environmental Management, Inc. Review Engineer: Booker Pullen Regional Engineer: Dean Carroll Review Engineer’s Signature:

I.

NESHAP: 40 CFR Part 63, Subpart LLL PSD: for PM, PM10, PM2.5, SO2, NOx, CO, & VOCs PSD Avoidance: N/A NC Toxics: Modeling required 112(r): N/A Other: N/A Application Data Application Number: 6500296.08A Date Initial Application Rec’d: 02/26/2008 Application Type: Modification Application Schedule: PSD Existing Permit Data Existing Permit Number: 07300R07 Existing Permit Issue Date: 01/24/2007 Existing Permit Expiration Date: 01/01/2012

Contact: John Carroll

Begin Date: May 12, 2008

Phone: (919) 489-5299 email: [email protected] Comments / Recommendations: Issue: 07300R08 Permit Issue Date: XXXX, XXXXX Permit Expiration Date: January 1, 2012

Introduction/Description : The Division of Air Quality received a copy of this proposed Prevention of Significant Deterioration (PSD) modification request from Titan America LLC/Carolinas Cement Company LLC on February 26, 2008. The application was considered complete for processing on this date. An amendment to the application was received on October 21, 2008. The amendment included the results of onsite testing of the raw materials from the mine that indicated the sulfide content in the materials was higher than originally estimated. This higher sulfide content will produce a higher sulfur dioxide emission rate emitted from the manufacturing process than was originally estimated. Also included in the amendment was the removal of the proposed barge loading equipment and the associated emissions points (cement storage, transfer, and loading spouts). This permit will be processed as a 300 State Permit to construct and operate that includes a 30-day public notice only. A condition will be placed in the permit that states that the applicant shall submit the application meeting the Title V requirements within 12 months of operation of the facility. This facility will be located in Castle Hayne, North Carolina, at an existing cement storage terminal that is currently operated by the Roanoke Cement Company. Titan America owns both The Carolinas Cement Company (CCC) and the existing Roanoke Cement Company. CCC will take over all operations at the site (including new and existing sources) when the new plant is constructed. Thus, this is a major modification to an existing facility. This location previously manufactured Portland cement under the name of Ideal Cement. Ideal Cement stopped operation in 1982.

Review 07300R08 -Draft Revision 4, Page 2 I.

Introduction/Description – Continued Titan America, LLC/Carolinas Cement Company, LLC (CCC) proposes to construct a modern, “state of the art”, Portland Cement manufacturing facility. The proposed Portland Cement plant will include a multi-stage preheaterprecalciner kiln with an in-line raw mill, coal mill, and clinker cooler system that will vent through a common main stack. Production will be limited in the permit to 6000 tons per day (tons/day) and 2,190,000 tons per year (tons/yr) of clinker and 2,400,000 tons/yr of cement. The fuels burned at this facility will include coal and petroleum coke. The raw materials for clinker production will include limestone/marl, clay, quarry spoils, bauxite, flyash/bottom ash, sand, and/or mill scale. Synthetic gypsum or natural gypsum will be milled with the clinker to produce cement. Associated processes will include mining, blasting, crushing, blending, grinding, material handling, storage for raw materials, fuels, clinker, finished cement, and cement packing and bulk loadout. Cement will be shipped by rail, or truck. The project will also include one diesel-fired emergency generator. The Castle Hayne area is in attainment with all the National Ambient Air Quality Standards (NAAQS). The existing Roanoke Cement terminal is considered a minor source under North Carolina’s PSD rules in accordance with 15A NCAC 02D.0530 for all PSD pollutants. A modification to a PSD minor source is subject to PSD if the modification itself exceeds the major source threshold for any PSD regulated pollutant. In the case of Portland cement plants, the major source threshold is 100 tons/yr, which includes all quantifiable fugitive emissions. The following table shows the criteria pollutants that will exceed the PSD major source emissions rates. Table 1-1 (values include the estimated rates from the amended application received on 10/21/2008) Pollutant Future Potential PSD Major Source Review Required Emissions Emission Rate (tons/yr) (Yes/No) (tons/yr) 1,861 100 Yes NOx 663 100 Yes PM (TSP) 527 100 Yes PM10 348 100 Yes PM 2.5 1,456 100 Yes SO2 3,068 100 Yes CO 175 100 Yes VOCs 0.09 100 No Lead 1.0 100 No Fluorides

II.

Purpose and Scope The purpose of this application is to build a Portland Cement Manufacturing facility. The following equipment will be added: • Quarry crushing and handling (ID No. FQ) • Raw material unloading, handling, and storage (ID No. RMHS) • Raw mill and kiln feed (ID No. RMKF) with associated fabric filters (ID Nos. CD5 through 13) • Coal/coke handling and storage (ID No. Coal) with associated fabric filters (ID No. CD1 through 4, CD14 through 18, and CD44B) • Kiln system (ID No. KS) with associated fabric filters (ID No. CD44A) • Clinker handling and storage (ID No. CHS) with associated fabric filters (ID Nos. CD19 through 21) • Finish mills (ID No. FM) with associated fabric filters (ID Nos. CD22 through 31 & CD45 through 47) • Cement handling, storage, and loadout (ID No. FM) with associated fabric filters (CD32 through 43) • Emergency generator (ID No. GEN) • Storage piles (ID No. SP) • Mining operations (ID No. MINE) • Plant roads (ID No. PLTRD) • Quarry roads (QURD)

Review 07300R08 -Draft Revision 4, Page 3 III.

Detailed Process Description: Portland cement is used in almost all construction applications including homes, public buildings, roads, industrial plants, dams, bridges, and many other structures. Therefore, the quality of Portland Cement must meet very demanding standards. The manufacture of a high quality Portland Cement begins with the use of a high quality calcium carbonate material (i.e., marl or limestone) and the production of a high quality cement clinker. In the Portland Cement manufacturing process, raw materials such as limestone, marl, clay, sand, and iron ore are heated to their fusion temperature, typically 1,400º to 1,500ºC (2,550º to 2,750ºF), in a refractory lined kiln by burning various fuels such as coal, coke, and natural gas. Burning an appropriately proportioned mixture of raw materials at a suitable temperature produces hard fused nodules called "clinker," which are cooled and then mixed with calcium sulfate (gypsum) and ground to a desired fineness. Different types of cements are produced by using appropriate kiln feed composition, blending the clinker with the desired amount of gypsum, and grinding the product mixture to appropriate fineness. The manufacture of cements of all types involves the same basic high temperature fusion, clinkering and fine grinding process. There are four primary types of refractory lined kilns used in the Portland cement industry. These are long wet kilns, long dry kilns, preheater kilns, and preheater/precalciner kilns. The long wet, long dry, and most preheater kilns, have only one fuel combustion zone. The newer preheater kilns with a riser duct and the preheater/precalciner kilns have two or more fuel combustion zones. These newer designs of dry pyroprocessing systems increase the overall energy efficiency of the cement plant. The energy efficiency of the cement making process is important as it determines the amount of heat input needed to produce a unit quantity of cement clinker. A high thermal efficiency leads to less consumption of heat and fuel, with correspondingly lower emissions. CCC will be using a multi-stage preheater/ precalciner kiln system with an in-line raw mill, clinker cooler, and coal mill. Note: The following website offers a very good general description of the process at a Portland Cement plant Some of the specific details and functions will be different from the CCC facility proposed for the Castle Hayne Plant. [http://www.cement.org/basics/images/flashtour.html] A.

Mining Operations: The initial production step in Portland Cement manufacturing is the raw material acquisition. CCC will obtain the required limestone/marl from a quarry that is located on the property. The raw materials will be removed from the quarry (overburden, spoils, and rock). The rock is removed from the quarry by blasting, drilling, and ripping the material from the rock face using large dozers. The limestone “vein” at this facility is approximately 80 feet in height and contains a high level of moisture. The large pieces of rock will be collected by large front-end loaders and transferred to haul trucks. The haul trucks will transfer the large pieces of rock to the primary jaw crushers located in the mine/quarry area that will reduce the rock to smaller sizes. These smaller stones are then conveyed to the secondary crusher that is located near the plant.

B.

Proportioning, Blending, & Grinding: Cement uses minerals containing the four essential elements for its creation: calcium, silicon, aluminum, and iron. The most common combination of ingredients is limestone (for calcium) coupled with much smaller quantities of clay and sand. The raw materials for clinker production at this facility may include limestone/marl, clay, quarry spoils, bauxite (principal ore of aluminum), fly ash/bottom ash, sand, and mill scale (iron). Synthetic gypsum or natural gypsum will be milled with the clinker to produce cement. The bauxite, flyash/bottom ash, mill scale will be brought in from the outside and will be added to the mixture. Flyash will be received wet and will be stored in piles inside the raw material storage building, thus minimizing fugitive emissions from material handling and wind erosion.

Review 07300R08 -Draft Revision 4, Page 4 III.

Detailed Process Description: (Continued) B. Proportioning, Blending, & Grinding: (Continued) Rock ripped or blasted from the limestone mine in the quarry is transported to the primary crusher, where chair size rocks are broken into pieces the size of baseballs. Per the CCC PSD application, 50% of the material crushed (mostly overburden – dirt and other materials) will be waste and would not be conveyed to the plant. This material would be returned to the quarry. A secondary crusher located near the plant reduces the baseballsized rock to the size of gravel. The next step in Portland Cement manufacturing 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. Cement raw materials are received with an initial moisture content varying from 1 to more than 50 percent. After the material blending, the raw material is ground using large wheel type grinders that crush the materials against a rotating table that sends the powder to the preheater tower. C.

Preheater Tower: The preheater tower at this facility contains a series of vertical cyclone chambers through which the raw materials pass on their way to the kiln. To save energy, the exhaust gases from the kiln rises some 200 feet and is used to preheat the raw materials as they swirl through the preheater cyclones. In the preheater/precalciner stage, materials are heated up to temperatures just below the melting or fusion point. Material transport associated with dry raw milling systems can be accomplished by a variety of mechanisms, including screw conveyors, belt conveyors, drag conveyors, bucket elevators, air slide conveyors, and pneumatic conveying systems. Approximately 60% of the heat input for this Portland Cement manufacturing facility occurs at the calciner. Powdered coal and/or possibly petroleum coke is injected and burned in the calciner. This is a direct-fired process.

D.

Kiln (Clinker Production): Central to the Portland Cement manufacturing process is the pyroprocessing system. CCC uses a preheater/ precalciner dry process system. Raw preheated material enters the huge rotating furnace called a kiln. The raw material mix enters the kiln at the elevated end, and the combustion fuels are introduced into the lower end of the kiln in a countercurrent manner. The materials are continuously and slowly moved to the lower end by rotation of the kiln. This horizontally sloped steel cylinder, lined with firebrick, turns from one to three revolutions per minute. As the materials move down the kiln, the material passes through progressively hotter zones toward the flame. At the lower end of the kiln (hottest part) the material may become partially molten. This system transforms the raw mix into red hot clinkers, which are gray, glass-hard, spherically shaped nodules that range from 0.32 to 5.1 centimeters (cm) (0.125 to 2.0 inches [in.]) in diameter. The chemical reactions and physical processes that constitute the transformation are quite complex, but they can be viewed conceptually as the following sequential events: 1. Evaporation of free water; 2. Evolution of combined water in the argillaceous components; 3. Calcination of the calcium carbonate (CaCO3) to calcium oxide (CaO); 4. Reaction of CaO with silica to form dicalcium silicate; 5. Reaction of CaO with the aluminum and iron-bearing constituents to form the liquid phase; 6. Formation of the clinker nodules; 7. Evaporation of volatile constituents (e. g., sodium, potassium, chlorides, and sulfates); and 8. Reaction of excess CaO with dicalcium silicate to form tricalcium silicate.

Review 07300R08 -Draft Revision 4, Page 5 III.

Detailed Process Description: (Continued) D. Kiln (Clinker Production): (Continued) This sequence of events may be conveniently divided into 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 100°C (212°F); 2. Dehydration, as the material temperature increases from 100°C to approximately 430°C (800°F) to form oxides of silicon, aluminum, and iron; 3. Calcination (conversion of limestone fraction to lime), carbon dioxide (CO2) is evolved, between 900°C (1650°F) and 982°C (1800°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 1510°C (2750°F). From raw material storage & blending

Raw materials Raw Mill Homogenizer & Kiln feed Silos

Flyash, limestone, gypsum silos Vertical cyclones (Preheater Tower)

Calciner Coal and pet coke firing to add heat (60% of total heat input to the system) Finish grinder/mixer to storage Kiln Coal and pet coke firing (40% of total heat input)

Clinker silos

Clinker cooler Gases go back through the raw mill (mill on condition) before going to the baghouse or the gases go straight to the baghouse (raw mill off condition) prior to going to main stack E.

Clinker Cooler: The last component of the pyroprocessing system is the clinker cooler. This process step recoups up to 30 percent of the heat input to the kiln system by recirculating some of the exhaust air back into the intake air of the kiln. The clinker cooler removes enough heat from the product so that it can be handled with conventional conveying equipment. The more common types of clinker coolers are (1) reciprocating grate, (2) planetary, and (3) rotary. In these coolers, the clinker is cooled from about 1100°C to 93°C (2000°F to 200°F) by ambient air that passes through the clinker and into the rotary kiln for use as combustion air.

Review 07300R08 -Draft Revision 4, Page 6 F.

Finish Grinding: The clinker tumbles onto a grate cooled by forced air. Once cooled, the clinker is ready to ground into the gray power called Portland Cement. The clinker is ground in a ball mill (a horizontal steel tube filled with steel balls). As the tube rotates, the steel balls tumble and crush the clinker into a super-fine power. The cement is ground so fine that it will easily pass through a sieve that is fine enough to hold water. Up to 5 percent gypsum or natural anhydrite is added to the clinker during grinding to control the cement setting time. Other specialty chemicals are added as needed to impart specific product properties. Typically, finishing is conducted in a closed circuit system, with product sizing by air separation.

G.

Storage and Shipping: From the grinding mills, the Portland Cement is conveyed to domes where it awaits shipment. CCC will ship cement offsite by rail or truck.

H.

Emissions: Particulate matter (PM and PM10), nitrogen oxides (NOx), sulfur dioxide (SO2), carbon monoxide (CO), and 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. Sources of PM at cement plants include (1) quarrying and crushing, (2) raw material storage, (3) grinding and blending (in the dry process only), (4) clinker production, (5) finish grinding, and (6) packaging and loading. The largest emission source of PM within cement plants is the pyroprocessing system that includes the kiln and clinker cooler exhaust stacks. Often, dust from the kiln is collected and recycled into the kiln, thereby producing clinker from the dust. However, if the alkali content of the raw materials is too high, some or all of the dust is discarded or leached before being returned to the kiln. In many instances, the maximum allowable cement alkali content of 0.6 percent (calculated as sodium oxide) restricts the amount of dust that can be recycled. Bypass systems sometimes have a separate exhaust stack. Additional sources of PM are raw material storage piles, conveyors, storage silos, and unloading facilities. Emissions from portland cement plants constructed or modified after August 17, 1971 are regulated to limit PM emissions from portland cement kilns to 0.15 kg/Mg (0.30 lb/ton) of feed (dry basis), and to limit PM emissions from clinker coolers to 0.050 kg/Mg (0.10 lb/ton) of feed (dry basis). Oxides of nitrogen are generated during fuel combustion by oxidation of chemically-bound nitrogen in the fuel and by thermal fixation of nitrogen in the combustion air. As flame temperature increases, the amount of thermally generated NOx increases. The amount of NOx generated from fuel increases with the quantity of nitrogen in the fuel. In the cement manufacturing process, NOx is generated in both the burning zone of the kiln and the burning zone of a precalcining vessel. Fuel usage affects the quantity and type of NOx generated. For example, in the kiln, natural gas combustion with a high flame temperature and low fuel nitrogen generates a larger quantity of NOx than does oil or coal, which have higher fuel nitrogen but which burn with lower flame temperatures. Sulfur dioxide 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 from plant to plant and with geographic location. However, the alkaline nature of the cement provides for direct absorption of SO2 into the product, thereby mitigating the quantity of SO2 emissions in the exhaust stream. Depending on the process and the source of the sulfur, SO2 adsorption ranges from about 70 percent to more than 95 percent.

Review 07300R08 -Draft Revision 4, Page 7 III.

Detailed Process Description: (Continued) H. Emissions: (Continued) The CO2 emissions from portland cement manufacturing are generated by two mechanisms. 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. This calcining process thermally decomposes CaCO3 to CaO and CO2. Typically, portland cement contains the equivalent of about 63.5 percent CaO. Consequently, about 1.135 units of CaCO3 are required to produce 1 unit of cement, and the amount of CO2 released in the calcining process is about 500 kilograms (kg) per Mg of portland cement produced (1,000 pounds [lb] per ton of cement). Total CO2 emissions from the pyroprocess depend on energy consumption and generally fall in the range of 0.85 to 1.35 Mg of CO2 per Mg of clinker. In addition to CO2 emissions, fuel combustion at portland cement plants can emit a wide range of 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. Emissions of metal compounds from portland cement kilns can be grouped into three general classes: volatile metals, including mercury (Hg) and thallium (Tl); semivolatile metals, including antimony (Sb), cadmium (Cd), lead (Pb), selenium (Se), zinc (Zn), potassium (K), and sodium (Na); and refractory or nonvolatile metals, including 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 semivolatile metals tend to be discharged through the primary exhaust stack and the bypass stack, respectively. Fugitive Dust Sources (Haul roads, etc.) Fugitive dust sources in the industry include quarrying and mining operations, vehicle traffic during mineral extraction and at the manufacturing site, 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 paving and road wetting. Controls that are applied to other open dust sources include water sprays with and without surfactants, chemical dust suppressants, wind screens, and process modifications to reduce drop heights or enclose storage operations.

Simple (Word Description) Flow Diagram of Portland Cement Manufacturing Process Quarrying Raw Material

IV. Old page

Raw Material Preparation

Dry Mixing And Blending

Preheater/Precalciner Kiln System

Clinker Cooler

Finish Grinding Mill

Product Storage, Shipping.

Summary of Permit Changes to permit No. 07300R08 per application 6500296.08A: New page

Page 1

Page 1

Page 2

Page 2

Condition No. Change Cover Letter Cover page Name change of facility, responsible official name change, changed issue date, added “PSD modification” to first sentence of the first paragraph, changed revision No. T08, placed permit into Title V format Cover letter Changed date in heading, changed effective date of the Permit, changed permit into Title V format, changed review engineer’s name and contact information

Review 07300R08 -Draft Revision 4, Page 8

Old page

New page

Page 3 Page 4

Page 3 Page 4

Page 1

Page 1

Page 2

Page 2

Page 1

Pages 1 - 2

All pages N/A

All pages Pages 3 - end

V.

Condition No. Change Cover Letter Cover letter Added ‘insignificant activities” list Cover letter Added “changes to the permit” table to reflect modification in application 6500296.08A Body of the Permit, Part I Cover Page Changed: cover letter layout, date of permit, permit revision number, name of the applicant per the application, the “complete application” received date, and name of responsible official Cover letter Changed: date in heading, responsible official, effective date, engineer’s name and contact number, signature person of letter Body of Permit Changed: date of permit, permit revision number, name of the applicant per the application, the “complete application” received date, application number, added new sources to table and applicable regulation per the application Heading of Permit Revised permit number Revised entire permit Added permitted equipment list, applicable regulations, specific conditions and limitations for PSD modification

Table of Sources added per application No. 6500296.08A:

The following table contains a summary of all permitted emission sources and associated pollution control devices/appurtenances:

Emission Source ID ES-Mine1 PSD

ES-Mine2 PSD

ES-FQSP1, PSD ES-FQSP2, PSD ES-FQSP4, PSD ES-QURD, PSD ES-FQ6, PSD ES-FQ1PC1

Emission Source Description

Control Device ID No. Mining/Quarrying Operations (MINE/FQ) Rock /limestone removal using heavy None equipment, drilling, and blasting Rock/limestone loading operations (front end None loader rock pickup, loader to haul truck, haul truck to jaw crusher) Limestone/marl pile located in the quarry None Spoils/other pile located in the quarry None Overburden located in the quarry None Quarry roads None Spoils/other stacker pile None Quarry Operation (FQ) Primary crusher #1 None

Control Device Description

None None

None None None None None None

NSPS OOO, PSD

ES-FQ3PC2

Primary crusher #2 (spoils/other)

None

None

Secondary crusher (quarry blend)

None

None

Belt conveyor transfer

None

None

Conveyor #1 transfer (limestone/marl)

None

None

Conveyor #1 transfer (spoils/other)

None

None

Conveyor #2 transfer (limestone/marl)

None

None

Conveyor #2 transfer (spoils/other)

None

None

NSPS OOO, PSD

ES-FQ8SC NSPS OOO, PSD

ES-FQ8BC NSPS OOO, PSD

ES-FQ2MC1 NSPS OOO, PSD

ES-FQ7SC NSPS OOO, PSD

ES-FQ1MC2 NSPS OOO, PSD

ES-FQ3SC2 NSPS OOO, PSD

-Table continued on the next page-

Review 07300R08 -Draft Revision 4, Page 9 The following table contains a summary of all permitted emission sources and associated pollution control devices/appurtenances: -Cont.-

Emission Source ID ES-FQ4SC3

Emission Source Description

Control Device ID No. Quarry Operation (FQ) - Continued Conveyor #3 transfer (spoils/other) None

Control Device Description

Secondary crusher feeder (quarry blend)

None

None

Hopper/feeder #1 (limestone/marl)

None

None

Hopper/feeder #2 (spoils/other)

None

None

Radial stacker transfer (spoils/other)

None

None

Coal/Coke System (COAL) Coal/coke hopper/feeder #2 None

None

Coal/coke belt conveyor transfer

None

None

Coal/coke enclosed hopper w/dust suppression (water spray) Coal/coke belt to tripper belt

None

None

None

None

Coal/coke tripper belt to piles

None

None

Coal/coke pile reclaimer

None

None

Coal/coke reclaimer to belt

None

None

Coal unloading by rail to hopper/transport system Coal unloading by truck to hopper/transport system Coal transport to storage

CD1 (211.BF320) CD2 (231.BF310) CD3 (231.BF330)

One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf

Coal transport from storage

CD4 (241.BF120) CD16 (461.BF350) CD17 (461.BF650) CD18 (461.BF750) CD14 (461.BF130) CD15 (461.BF230) CD44B (461.BF500)

One bagfilter with outlet grain loading of 0.01 grains/SCF One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf

None

NSPS OOO, PSD

ES-FQ8SCF NSPS OOO, PSD

ES-FQ1HF NSPS OOO, PSD ES-FQ3HF2 NSPS OOO, PSD

ES-FQ5RS NSPS OOO, PSD

ES-COALF1HF2 NSPS Y, PSD

ES-COALF1BCT NSPS Y, PSD

ES-COALF2EH NSPS Y, PSD

ES-COALF3B NSPS Y, PSD

ES-COALF3TB NSPS Y, PSD

ES-COALF3PR NSPS Y, PSD

ES-COALFERB NSPS Y, PSD

ES-COALE1 NSPS Y, PSD

ES-COALE2 NSPS Y, PSD

ES-COALE3 NSPS Y, PSD

ES-COALE4 NSPS Y, PSD

ES-COALE16 NSPS Y, PSD ES-COALE17

Coal mill feed transport Fine coal bin

MACT LLL, PSD

ES-COALE18

Fine coal bin

MACT LLL, PSD

ES-COALE14 NSPS Y, PSD ES-COALE15 NSPS Y, PSD ES-COAL NSPS Y, PSD ES-PLTRD, PSD

Coal mill feed bin Coal mill feed bin Coal mill

Plant Roadways Vehicular traffic on paved plant roads None -Table continued on the next page-

None

Review 07300R08 -Draft Revision 4, Page 10 The following table contains a summary of all permitted emission sources and associated pollution control devices/appurtenances: Cont.

Emission Source ID

ES-SPCoal1, PSD ES-SPCoal2, PSD ES-SPBlend1, PSD ES-SPBlend2, PSD ES-SPMillscale, PSD ES-SPBauxite, PSD ES-SPAsh, PSD ES-SPLimestone, PSD ES-SPGypsum, PSD ES-GEN NSPS IIII MACT ZZZZ, PSD

ES-F1HF1

Emission Source Description Storage Piles Coal/coke storage pile at the plant Coal/coke storage pile at the plant Blended stone pile at the plant Blended stone pile at the plant Mill scale storage pile at the plant Bauxite storage pile at the plant Bottom ash storage pile at the plant Limestone storage pile at the plant Gypsum storage pile at the plant Emergency Generator Diesel-fired emergency generator (800 kW, 1072.82 hp output)

Control Device ID No.

Control Device Description

None None None None None None None None None

None None None None None None None None None

None

None

Plant additives unloading and handling Additives hopper/feeder None

None

Additives belt conveyor transfer

None

None

Additives belt conveyor transfer

None

None

Additives belt conveyor transfer

None

None

Bottom Ash conveyor to silo

None

None

Bottom ash silo to enclosed belt

None

None

MACT LLL, PSD

ES-F1BCT MACT LLL, PSD

ES-F5 MACT LLL, PSD

ES-F7 MACT LLL, PSD

ES-F7C MACT LLL, PSD

ES-F7D MACT LLL, PSD

ES-RMHF3B NSPS OOO, PSD ES-RMHF3TB, PSD ES-RMHF3PR

Raw Material Unloading & Handing (RMH) Quarry blend belt to tripper belt None

None

Quarry blend tripper belt to piles Quarry blend pile reclaimer

None None

None None

Quarry blend reclaimer to belt

None

None

Additives belt to tripper belt

None

None

Additives tripper belt to piles

None

None

Additives pile reclaimer

None

None

Additives reclaimer to belt

None

None

Quarry blend belt conveyor transfer

None

None

Quarry blend conveyor to silo

None

None

Quarry blend silo to enclosed belt

None

None

MACT LLL, PSD

ES-RMHF3R MACT LLL, PSD

ES-RMHF3ABT MACT LLL, PSD

ES-RMHF3ATB MACT LLL, PSD

ES-RMHF3APR MACT LLL, PSD

ES-RMHF3RB MACT LLL, PSD

ES-RMHF6BCT MACT LLL, PSD

ES-RMHF7A MACT LLL, PSD

ES-RMHF7B MACT LLL, PSD

-Table continued on the next page-

Review 07300R08 -Draft Revision 4, Page 11 The following table contains a summary of all permitted emission sources and associated pollution control devices/appurtenances: Cont.

Emission Source ID ES-RMHSE5 MACT LLL, PSD

ES-RMHSE6 MACT LLL, PSD

ES-RMHSE7 MACT LLL, PSD

ES-RMHSE8 MACT LLL, PSD

ES-RMHSE9 MACT LLL, PSD

ES-RMHSE10 MACT LLL, PSD

ES-RMHSE11 MACT LLL, PSD

ES-RMHSE12 MACT LLL, PSD

ES-RMHSE13 MACT LLL, PSD

ES-CHSE19 MACT LLL, PSD

ES-CHSE20 MACT LLL, PSD

ES-CHSE21 MACT LLL, PSD

ES-FME22 MACT LLL, PSD

ES-FME23 MACT LLL, PSD

ES-FME24 MACT LLL, PSD

ES-FME25 MACT LLL, PSD

ES-FME26 MACT LLL, PSD

ES-FME27 MACT LLL, PSD

ES-FME28 MACT LLL, PSD

Emission Source Description

Control Device ID No. Raw Mill and Raw Mill Feed System (RMHS) Raw mill feed bin CD5 (143.BF650) Raw mill feed transport CD6 (311.BF750) Raw mill feed CD7 (321.BF470) Raw mill reject CD8 (321.BF950) Kiln dust bin CD9 (331.BF400) Raw mill transport to silo CD10 (341.BF410) Raw mill silo CD11 (341.BF350) Raw mill silo extraction CD12 (351.BF440) Kiln feed CD13 (351.BF470) Clinker Handling and Storage (CHS) Clinker discharge from cooler CD19 (441.BF540) Clinker dome CD20 (471.BF150) Off-spec bin CD21 (471.BF240) Finish Mills (FM) Cement mill #1 feed bin CD22 (511.BF090) Cement mill #2 feed bin CD23 (512.BF050) Cement mill #1 feed CD24 (531.BF290) Cement mill #1 recirculation bin CD25 (531.BF020) Cement mill #1 reject CD26 (531.BF215) Cement mill #1 transport CD27 (531.BF615) Cement mill #2 feed CD28 (532.BF290) -Table continued on the next page-

Control Device Description

One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/SCF One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/SCF One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf

Review 07300R08 -Draft Revision 4, Page 12 The following table contains a summary of all permitted emission sources and associated pollution control devices/appurtenances: (Cont.)

Emission Source ID ES-FME29

Emission Source Description

Gypsum/limestone unloading Gypsum/limestone hopper/feeder

Control Device ID No. CD29 (532.BF020) CD30 (532.BF215) CD31 (532.BF615) CD45A (531.BF500) CD45B (532.BF500) CD46 (511.BF300) CD47 (232.BF150) None None

One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf One bagfilter with outlet grain loading of 0.01 grains/scf None None

Gypsum/limestone belt conveyor transfer

None

None

Cement mill #2 recirculation bin

MACT LLL, PSD

ES-FME30

Cement mill #2 reject

MACT LLL, PSD

ES-FME31

Cement mill #2 transport

MACT LLL, PSD

ES-FM45A

Exhaust from finish mill #1

MACT LLL, PSD

ES-FM45B

Exhaust from finish mill #2

MACT LLL, PSD ES-FME46 MACT LLL, PSD

Cement additive bin

ES-FME47

Cement additive intake

MACT LLL, PSD ES-FMEF8TU, PSD

ES-FMF8HF

Control Device Description

MACT LLL, PSD

ES-FMF8BCT MACT LLL, PSD

Cement Handling, Storage, and Loadout (CHSL) CD32 One bagfilter with outlet grain loading of 0.01 grains/scf (611.BF600) MACT LLL, PSD ES-CHSLE33 Cement dome extraction rail CD33 One bagfilter with outlet grain loading of 0.01 grains/SCF (621.BF305) MACT LLL, PSD ES-CHSLE34 Cement dome extraction truck CD34 One bagfilter with outlet grain loading of 0.01 grains/scf (621.BF315) MACT LLL, PSD ES-CHSLE40 Cement silo CD40 One bagfilter with outlet grain loading of 0.01 grains/SCF (612.BF600) MACT LLL, PSD ES-CHSLE41 Cement silo extraction CD41 One bagfilter with outlet grain loading of 0.01 grains/scf (612.BF620) MACT LLL, PSD ES-CHSLE42 Cement transport CD42 One bagfilter with outlet grain loading of 0.01 grains/scf (622.BF410) MACT LLL, PSD ES-CHSLE43 Packaging plant CD43 One bagfilter with outlet grain loading of 0.01 grains/scf (641.BF150) MACT LLL, PSD ES-4 ** Cement silo (2,200 tons est. capacity) CDP43 One bagfilter (540 square feet of filter surface area) MACT LLL ES-R33 ** Screw conveyor and truck load-out spout CDP30 One bagfilter with outlet grain loading of 0.01 grains/scf MACT LLL ES-1 ** Railcar/truck unloading system CDP1 One bagfilter (339 square feet of filter (screw/pneumatic) in partially enclosed surface area) building Kiln System (including preheater/precalciner kiln /in-line raw mill/coal mill/clinker cooler ES-KS One preheater/precalciner kiln (coal, petro- CD44N Selective non-catalytic reduction MACT LLL, PSD leum coke)/ in-line raw mill/coal mill with (SNCR) system baghouse (CD-44B)/clinker cooler CD44S Lime injection system ES-CHSLE32

Cement dome

** Existing sources (all other sources are proposed);

CD44A One bagfilter with outlet grain loading (331.BF200) of 0.0126 grains/scf ES-1 to be removed from service prior to startup of cement plant

Review 07300R08 -Draft Revision 4, Page 13 VI. Regulatory Summary A.

Mining/Quarry Operations (Mine/FQ): • Rock/limestone removal using heavy equipment, drilling, and blasting (ID No. ES-Mine1) • Rock/limestone loading operations (rock from front end loader to haul truck, unloading haul truck to jaw crusher, ID No. ES-Mine2) • Limestone/marl pile located in quarry area (ID No. ES-FQSP1) • Spoils/other pile located in quarry area (ID No. ES-FQSP2) • Overburden pile located in quarry area (ID No. ES-FQSP4) • Quarry roads (ID No. ES-QURD) • Spoils/other stacker pile (ID No. ES-FQ6) 1. Description: The rock will be removed from the quarry by ripping the material from the rock face using large dozers or by blasting. The large pieces of rock will be collected by a large front-end loader and transferred into the beds of haul trucks. The haul trucks will transfer the large pieces of rock to the primary jaw crushers that will reduce the rock to softball-sized pieces. 2. Applicable Regulatory Requirements: NSPS, Subpart F “Standards of Performance for Portland Cement Plants” does not cover the sources that are located in the quarry/mining area at this facility. Subpart F covers the processes located at the plant site (beginning with the raw material storage through to the finished product bulk loading and unloading systems) where the raw materials are blended, ground up, heated to form the Portland Cement, finished, and shipped. These quarry/mining operations are not subject to the Portland Cement MACT, Subpart LLL because this MACT does not cover the equipment in this portion of a Nonmetallic Mineral Processing Plant. The first affected source that the MACT (Subpart LLL) covers in the sequence of material handling operations will be the raw material storage that is just prior to the raw mill at the plant site. [40 CFR §63.1340(c)] These quarry/mining operations are not subject 15A NCAC 2D .0513 “Particulates From Portland Cement Plants” because this regulation does not cover mining and quarrying operations. The following provides a summary of limits and/or standards for the emission source(s) described above.

Regulated Pollutant Fugitive dust emissions

Particulate emissions

B.

Limits/Standards Avoid fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. State Enforceable Only (See Multiple Emissions Section VII) BACT Best management practices for drilling, blasting, stone removal, and truck loading operations (See Multiple Emissions Section VII B)

Applicable Regulation 15A NCAC 2D .0540

15A NCAC 2D .0530 PSD

Quarry Operations (FQ): • Primary crusher #1 (limestone/marl, ID No. ES-FQ1PC1, NSPS Subpart OOO) • Primary crusher #2 (spoils/other, ID No. ES-FQ3PC2, NSPS Subpart OOO) • Secondary crusher (quarry blend, ID No. ES-FQ8SC, NSPS Subpart OOO) • Mining conveyor #1 transfer (limestone/marl, ID No. ES-FQ2MC1, NSPS Subpart OOO) • Spoils conveyor #1 transfer (spoils/other, ID No. ES-FQ7SC, NSPS Subpart OOO) • Mining conveyor #2 transfer (limestone/marl, ID No. ES-FQ1MC2, NSPS Subpart OOO) • Spoils conveyor #2 transfer (spoils/other, ID No. ES-FQ3SC2, NSPS Subpart OOO) • Spoils conveyor #3 transfer (spoils/other, ID No. ES-FQ4SC3, NSPS Subpart OOO) • Secondary crusher feeder (Quarry blend, ID No. ES-FQ8SCF, NSPS Subpart OOO) • Hopper/feeder #1 (limestone/marl, ID No. ES-FQ1HF, NSPS Subpart OOO) • Hopper/feeder #2 (spoils/other, ID No. ES-FQ3HF2, NSPS Subpart OOO) • Radial stacker transfer (spoils/other, ID No. ES-FQ5RS, NSPS Subpart OOO)

Review 07300R08 -Draft Revision 4, Page 14 1. Description: The large pieces of rock will be collected by a large front end loader and transferred into the beds of haul trucks. The haul trucks will transfer the large pieces of rock to the primary jaw crushers that will reduce the rock to softball sized pieces. These smaller stones are then conveyed to a secondary crusher and then to the main plant to begin the cement making process. 2. Applicable Regulatory Requirements: The Quarry/Mining operations (beginning with the primary jaw crushers up to the raw meal storage) will be subject to NSPS, Subpart OOO “Standards of Performance for Nonmetallic Mineral Processing Plants” because this equipment will be constructed or modified after August 31, 1983 and will be used for processing of limestone using crushers, screens, bucket elevators, belt conveyors, grinding mills, bagging operations, storage bins, enclosed truck or railcar loading stations. The “final” rule for this NSPS was revised and placed into the Federal Register on April 28, 2009 (74 FR 19309). This NSPS applies to quarry/mining operations from the quarry up to the raw mill that is located at the plant site. The Quarry/Mining operations are not subject to NSPS, Subpart F “Standards of Performance for Portland Cement Plants” because Subpart F only covers the processes located at the plant site (beginning with the raw material storage through to the finished product bulk loading and unloading systems) where the raw materials are blended, ground up, heated to form the Portland Cement, finished, and shipped. The Quarry/mining operations at this site are not subject to the Portland Cement MACT, Subpart LLL because this MACT does not cover the equipment in this portion of a Nonmetallic Mineral Processing Plant. The first affected source that the MACT (Subpart LLL) covers in the sequence of material handling operations will be the raw material storage just prior to the raw mill at the plant site. [40 CFR §63.1340(c)] The Quarry/mining operations at this site are not subject to 15A NCAC 2D .0513 “Particulates From Portland Cement Plants” because this regulation does not cover this section of the plant site. The following provides a summary of limits and/or standards for the emission source(s) described above.

Regulated Pollutant Particulate emissions Fugitive dust emissions

Fugitive dust emissions

Limits/Standards Best management practices (See Multiple Emissions Section VII B) • Crushers without a capture system No owner/operator shall cause to be discharged into the atmosphere from any crusher, at which a capture system is not used, fugitive emissions which exhibit greater than 12 percent opacity. • Any transfer point on belt conveyor not enclosed in a building No owner/operator shall cause to be discharged into the atmosphere from any transfer point on belt conveyors or from any other affected facility any fugitive emissions which exhibit greater than 7 percent opacity. • Any transfer point on belt conveyors or any other affected facility No owner/operator shall cause to be discharged into the atmosphere from any transfer point on belt conveyors or from any other affected facility, any emissions which exhibit greater than 7 percent opacity. Avoid fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. State Enforceable Only (See Multiple Emissions Section VII)

Applicable Regulation 15A NCAC 2D .0530 PSD (BACT)

15A NCAC 2D .0524 40 CFR Part 60, Subpart OOO

15A NCAC 2D .0524 40CFR Part 60, Subpart OOO

15A NCAC 2D .0524 40 CFR Part 60, Subpart OOO

15A NCAC 2D .0540

Review 07300R08 -Draft Revision 4, Page 15 a.

15A NCAC 2D .0524, 40 CFR Part 60, Subpart OOO “Standards of Performance for Nonmetallic Mineral Processing Plants” i.

15A NCAC 02D .0524: NEW SOURCE PERFORMANCE STANDARDS - The Permittee shall comply with all applicable provisions, including the notification, testing, recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 02D .0524 "New Source Performance Standards" (NSPS) as promulgated in 40 CFR Part 60 Subpart OOO, including Subpart A "General Provisions" for affected facilities that commence construction, modification, or reconstruction after April 22, 2008.

ii. NSPS Test Methods and Procedures [40 CFR §60.675] On and after the sixtieth day after achieving the maximum production rate at which the affected facility will be operated, but not later than 180 days after initial startup as required under 40 CFR §60.11 of this Part 60, the owner or operator shall perform an initial performance test. (A) The owner or operator shall use as reference methods and procedures the test methods in appendices A–1 through A–7 of 40 CFR Part 60 or other methods and procedures as specified in Subpart OOO except as provided in 40 CFR §60.8(b). (B) The owner or operator shall determine compliance with the PM standards in 40 CFR §60.672(a) as follows: (1) Method 5 of Appendix A–3 of Part 60 or Method 17 of Appendix A–6 of Part 60 shall be used to determine the particulate matter concentration. The sample volume shall be at least 1.70 dscm (60 dscf). For Method 5 (40 CFR part 60, Appendix A–3), if the gas stream being sampled is at ambient temperature, the sampling probe and filter may be operated without heaters. If the gas stream is above ambient temperature, the sampling probe and filter may be operated at a temperature high enough, but no higher than 121 °C (250 °F), to prevent water condensation on the filter. (2) Method 9 of Appendix A–4 of this part and the procedures in 40 CFR §60.11 shall be used to determine opacity. (3) In determining compliance with the particulate matter standards in §60.672(b), the owner or operator shall use Method 9 of Appendix A–4 of Part 60 and the procedures in 40 CFR §60.11, with the following additions: (a) The minimum distance between the observer and the emission source shall be 4.57 meters (15 feet). (b) The observer shall, when possible, select a position that minimizes interference from other fugitive emission sources ( e.g., road dust). The required observer position relative to the sun (Method 9 of Appendix A–4 of Part 60, Section 2.1) must be followed. (c) When determining compliance with the fugitive emissions standard for any affected facility described under §60.672(b) of Subpart OOO the duration of the Method 9 (40 CFR part 60, Appendix A–4) observations must be 30 minutes (five 6-minute averages). Compliance with the applicable fugitive emission limits in Table 3 of Subpart OOO must be based on the average of the five 6-minute averages. iii. Standards For Particulate Matter [40 CFR §60.672] (A) On and after the date on which the performance test required to be conducted by 40 CFR §60.8 is completed, no owner or operator subject to the provisions of this subpart shall cause to be discharged into the atmosphere, any fugitive emissions (from the following affected facilities constructed after April 22, 2008) that exhibit greater than 7 percent opacity. • Grinding mill • Screening operation (wet screening operations are exempt) • Bucket elevator • Transfer points on belt conveyors • Bagging operations • Storage bins • Enclosed truck or railcar loading stations

Review 07300R08 -Draft Revision 4, Page 16

(B) On and after the date on which the performance test required to be conducted by 40 CFR §60.8 is completed, no owner or operator subject to the provisions of this subpart shall cause to be discharged into the atmosphere, any fugitive emissions (from crushers without capture systems that are constructed after April 22, 2008) that exhibit greater than 12 percent opacity. • Primary crusher #1 (ID Nos. ES-FQ1PC) • Primary crusher #2 (ES-FQ3PC2) • Secondary crusher (ES-FQ8SC) (C) Truck dumping of nonmetallic minerals into any screening operation, fed hopper, or crusher is exempt from the requirements of section 40 CFR §60.672. (D) Static non-agitating grizzlies are exempt from the requirements of section 40 CFR §60.672. (E) Dropping of nonmetallic minerals from a conveyor to a pile is not defined as a transfer point and is exempt from the requirements of section 40 CFR §60.672. (F) Equipment that breaks up clumps but does not reduce the size of the materials is not a crusher and is exempt from the requirements of section 40 CFR §60.672. iv. Reporting [40 CFR §60.674] (A) The owner or operator of any affected facility shall submit written reports of the results of all performance tests conducted to demonstrate compliance with the standards set forth in 40 CFR §60.672 of Subpart OOO, including reports of opacity observations made using Method 9 (40 CFR Part 60, Appendix A–4) to demonstrate compliance with 40 CFR §60.672(b). (B) The subpart A requirement under §60.7(a)(1) for notification of the date construction or reconstruction commenced is waived for affected facilities under this subpart. (C) A notification of the actual date of initial startup of each affected facility shall be submitted to the Administrator. (1) For a combination of affected facilities in a production line that begin actual initial startup on the same day, a single notification of startup may be submitted by the owner or operator to the Administrator. The notification shall be postmarked within 15 days after such date and shall include a description of each affected facility, equipment manufacturer, and serial number of the equipment, if available. C. Coal/Coke Handling System (COAL) and associated control devices • Coal/coke hopper/feeder #2 (ID No. ES-COALF1HF2, NSPS Subpart Y) • Coal/coke belt conveyor transfer (ID No. ES-COALF1BCT, NSPS Subpart Y) • Coal/coke enclosed hopper w/dust suppression (water spray) (ID No. ES-COALF2EH, NSPS Subpart Y) • Coal/coke belt to tripper belt (ID No. ES-COALF3B, NSPS Subpart Y) • Coal/coke tripper belt to piles (ID No. ES-COALF3TB, NSPS Subpart Y) • Coal/coke pile reclaimer (ID No. ES-COALF3PR, NSPS Subpart Y) • Coal/coke reclaimer to belt (ID No. ES-COALFERB, NSPS Subpart Y) • Coal unloading by rail (ID No. ES-COALE1, NSPS Subpart Y) with associated bagfilter (CD1) • Coal unloading by truck (ID No. ES-COALE2, NSPS Subpart Y) with associated bagfilter (CD2) • Coal transport to storage (ID No. ES-COALFE3, NSPS Subpart Y) with associated bagfilter (CD3) • Coal transport from storage (ID No. ES-COALE4, NSPS Subpart Y) with associated bagfilter (CD4) • Coal mill feed bin (ID No. ES-COALE14, NSPS Subpart Y) with associated bagfilter (CD14) • Coal mill feed bin (ID No. ES-COALE15, NSPS Subpart Y) with associated bagfilter (CD15) • Coal mill feed transport (ID No. ES-COALE16, NSPS Subpart Y) with associated bagfilter (CD16) • Fine coal bin (ID No. ES-COALE17, MACT Subpart LLL) with associated bagfilter (CD17) • Fine coal bin (ID No. ES-COALE18, MACT Subpart LLL) with associated bagfilter (CD18) • Coal mill (ES-COAL, NSPS Subpart Y) with associated bagfilter (CD44B) venting to the main stack

Review 07300R08 -Draft Revision 4, Page 17

1.

2.

Description: The process of making cement clinker requires heat. Coal or petroleum coke is used as the fuel for providing heat. Raw coal/petroleum coke received by truck or rail is stored in a coal yard. Raw coal/coke is dropped on a belt conveyor from a hopper and is taken to and crushed in a crusher. Crushed coal or pet coke discharged from the Coal Crusher is stored in a longitudinal stockpile from where it is reclaimed by a reclaimer and taken to the coal mill hoppers for grinding into fine coal. The coal/pet coke will be ground to a powder and burned as fuel in the preheat tower calciner and in the kiln. Applicable Regulatory Requirements: This coal handling system is subject to NSPS, 40 CFR Part 60, Subpart Y “Standards of Performance for Coal Preparation Plants” from the coal unloading stations to the transfer point after the coal mill that is used to convey coal to the kiln. This system is subject to NSPS Subpart Y because it will be built after October 24, 1974 and has a design processing capacity greater than 200 tons per day. A portion (from the coal mill to the kiln) of the coal handling system is subject to 40 CFR Part 63, Subpart LLL “National Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing Industry”. [see 40 CFR §63.1356 (b)]. Neither the NSPS, Subpart Y or MACT LLL currently has a particulate emission rate standard for the emission points (stacks) in this system. But since 15A NCAC 2D .0530 has a BACT outlet grain loading to control the emissions of PM, State Regulation 15A NCAC 2D .0515 will not apply. The following provides a summary of limits and/or standards for the emission source(s) described above.

Regulated Pollutant Particulate

Limits/Standards Bagfilter with outlet grain loading of 0.01 gr/scf

Applicable Regulation 15A NCAC 2D .0530

Visible Emissions

20 percent opacity

15A NCAC 2D .0524 40 CFR Part 60, Subpart Y

PSD (BACT) (For ES-COALE1, COALE2, COALFE3, COALE4, COALE14, COALE15, COALE16, ES-COAL)

10 percent opacity

15A NCAC 2D .1111

(For ES-COAL, COALE17, & COALE18)

40 CFR Part 60, Subpart LLL

(See Multiple Emissions Section VII D) a.

Bagfilters with outlet grain loading of 0.01 grains/standard cubic foot • Coal unloading by rail (ID No. ES-COALE1, NSPS Subpart Y) with associated bagfilter CD1) • Coal unloading by truck (ID No. ES-COALE2, NSPS Subpart Y) with associated bagfilter (CD2) • Coal transport to storage (ID No. ES-COALFE3, NSPS Subpart Y) with associated bagfilter (CD3) • Coal transport from storage (ID No. ES-COALE4, NSPS Subpart Y) with associated bagfilter (CD4) • Coal mill feed bin (ID No. ES-COALE14, NSPS Subpart Y) with associated bagfilter (CD14) • Coal mill feed bin (ID No. ES-COALE15, NSPS Subpart Y) with associated bagfilter (CD15) • Coal mill feed transport (ID No. ES-COALE16, NSPS Subpart Y) with associated bagfilter (CD16) • Fine coal bin (ID No. ES-COALE17, MACT Subpart LLL) with associated bagfilter (CD17) • Fine coal bin (ID No. ES-COALE18, MACT Subpart LLL) with associated bagfilter (CD18) • Coal mill (ES-COAL, NSPS Subpart Y) with associated bagfilter (CD44B) venting to the main stack These sources are controlled by a bagfilter having an outlet grain loading of 0.01 grains/standard cubic foot (scf). The standard gas flow rate is the gas flow rate expressed at standard conditions [68 degrees F (528 degrees Rankine) and 14.7 psia (407 inches water)]. Standard gas flow rates are useful when material balances are prepared, for calculations in which the gas stream may undergo chemical reactions, and for comparing the flow rate in a system with the flow rate capacity of a fan. The maximum inlet airflow rate of each bagfilter is given in actual cubic feet per minute (ACFM). In order to calculate the PM output from each bagfilter, the following equation shall be used.

⎡T ⎤ ⎡ P ACFM = SCFM × ⎢ actual ⎥ × ⎢ STP ⎢⎣ TSTP ⎥⎦ ⎢⎣ Pactual

⎤ ⎥ ⎥⎦

Review 07300R08 -Draft Revision 4, Page 18

Where:

Tactual TSTP Pactual PSTP

= actual temperature at the outlet of the bagfilter = standard temperature at the outlet of the bagfilter (68 degrees F) = actual pressure at the outlet of the bagfilter (14.7 psia or 407 inches W.C.) = standard pressure at the outlet of the bagfilter (14.7 psia or 407 inches W.C.)

Solve equation for SCF

⎡ TSTP ⎤ ⎡ PActual ⎤ ⎥×⎢ ⎥ ⎢⎣ T Actual ⎥⎦ ⎢⎣ PSTP ⎥⎦

SCFM = ACFM × ⎢

Example Calculation using source (Coal unloading by rail, ES-COALE1) controlled by bagfilter (CD1)

⎡ ( 460 + 68) STP ⎤ ⎡ ( 407 inches water column) Actual ⎤ = 5442.23 SCFM ⎥×⎢ ⎥ ⎢⎣ ( 460 + 77) Actual ⎥⎦ ⎣⎢ ( 407 inches water column) STP ⎦⎥

SCFM = 5535 ACFM × ⎢

Outlet grain loading for each bagfilter = 0.01 grains/SCF

Maximum emissions of PM (lbs / hr ) =

0.01 grains s tan dard cubic foot

×

5442.23 s tan dard cubic feet min ute

×

60 min utes hour

×

1 lb 7000 grains

=

0.47 lbs hour

Potential PM emissions including bagfilter efficiency from the Coal/Coke Handling System using the equations above Source

ACFM to bagfilter

Actual Temp.

Stand. Pressure

Actual Pressure

PM Output * (lbs/hr)

Coal unloading by rail (CD1) 5535 acfm 68 0F 77 0F 0 Coal unloading by truck (CD2) 5535 acfm 68 F 77 0F 0 Coal transport to storage (CD3) 6868 acfm 68 F 77 0F Coal transport from storage (CD4) 6868 acfm 68 0F 77 0F 0 Coal mill feed bin (CD14) 1540 acfm 68 F 90 0F 0 Coal mill feed bin (CD15) 1540 acfm 68 F 90 0F 0 Coal mill feed transport (CD16) 6100 acfm 68 F 90 0F 0 Fine coal bin (CD17) 175 acfm 68 F 140 0F 0 Fine coal bin (CD18) 175 acfm 68 F 140 0F 0 Coal mill (CD44B) 30,000 acfm 68 F 435 0F Total * PM10 is 84% of the PM number in accordance with AP-42 Table 11.6-5

14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia

14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia

0.47 lbs/hr 0.47 lbs/hr 0.58 lbs/hr 0.58 lbs/hr 0.13 lbs/hr 0.13 lbs/hr 0.50 lbs/hr 0.01 lbs/hr 0.01 lbs/hr 1.52 lbs/hr 4.4 lbs/hr

i.

Stand. Temp.

Monitoring/Recordkeeping [Bagfilter monitoring will be added in condition 15A NCAC 2D .0530 in the permit] Particulate matter emissions from the some of the coal handling system shall be controlled by bagfilters (ID Nos. CD1, 2, 3, 4, 14, 15, 16, 17, 18). To assure compliance, the Permittee shall perform inspections and maintenance as recommended by the manufacturer. In addition to the manufacturer’s inspection and maintenance recommendations, or if there is no manufacturer’s inspection and maintenance recommendations, as a minimum, the inspection and maintenance requirement shall include the following: (A) a monthly visual inspection of the system ductwork and material collection unit for leaks; and (B) an annual (for each 12 month period following the initial inspection) internal inspection of the bagfilter's structural integrity.

Review 07300R08 -Draft Revision 4, Page 19

ii. The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) on-site and made available to an authorized representative upon request. The logbook shall record the following: (A) the date and time of each recorded action; (B) the results of each inspection; (C) the results of any maintenance performed on the bagfilters; and (D) any variance from manufacturer’s recommendations, if any, and corrections made.

Reporting [15A NCAC 02Q .0508(f)] iii. The Permittee shall maintain a monthly summary report, acceptable to the Regional Air Quality Supervisor, of monitoring and recordkeeping listed above and shall submit the results within 30 days of a written request by the DAQ. b.

15A NCAC 2D .0524, 40 CFR Part 60, Subpart Y “Standards of Performance For Coal Preparation Plants” -- Visible Emissions -• Coal/coke hopper/feeder #2 (ID No. ES-COALF1HF2, NSPS Subpart Y) • Coal/coke belt conveyor transfer (ID No. ES-COALF1BCT, NSPS Subpart Y) • Coal/coke enclosed hopper w/dust screen (ID No. ES-COALF2EH, NSPS Subpart Y) • Coal/coke belt to tripper belt (ID No. ES-COALF3B, NSPS Subpart Y) • Coal/coke tripper belt to piles (ID No. ES-COALF3TB, NSPS Subpart Y) • Coal/coke pile reclaimer (ID No. ES-COALF3PR, NSPS Subpart Y) • Coal/coke reclaimer to belt (ID No. ES-COALFERB, NSPS Subpart Y) • Coal unloading by rail (ID No. ES-COALE1, NSPS Subpart Y) with associated bagfilter (CD1) • Coal unloading by truck (ID No. ES-COALE2, NSPS Subpart Y) with associated bagfilter (CD2) • Coal transport to storage (ID No. ES-COALFE3, NSPS Subpart Y) with associated bagfilter (CD3) • Coal transport from storage (ID No. ES-COALE4, NSPS Subpart Y) with associated bagfilter (CD4) • Coal mill feed bin (ID No. ES-COALE14, NSPS Subpart Y) with associated bagfilter (CD14) • Coal mill feed bin (ID No. ES-COALE15, NSPS Subpart Y) with associated bagfilter (CD15) • Coal mill feed transport (ID No. ES-COALE16, NSPS Subpart Y) with associated bagfilter (CD16) • Coal mill (ES-COAL, NSPS Subpart Y) with associated bagfilter (CD44B) venting to the main stack (Subject to more stringent MACT LLL visibility requirements since vented to a common stack) The Permittee shall comply with all applicable provisions, including the notification, testing, recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 02D .0524 "New Source Performance Standards" (NSPS) as promulgated in 40 CFR Part 60 Subpart Y, including Subpart A "General Provisions." i. On an after the date on which the performance test required to be conducted by 40 CFR §60.8 is completed, an owner or operator subject to the provisions of this Subpart shall not cause to be discharged into the atmosphere from any coal processing and conveying equipment, coal storage system, or coal transfer and loading system constructed after October 24, 1974 processing coal, gases which exhibit 20 percent opacity or greater.

Testing ii. The Permittee shall conduct an initial performance test of the affected sources to demonstrated compliance with the visible emission standards in accordance with 40 CFR §60.252, within 60 days of achieving the maximum sustained production rate, but not later than 180 days after initial start-up. Testing shall be conducted in accordance with 40 CFR §60.254, included but not limited to the following: (A) Method 9 and the procedures in 40 CFR §60.11 shall be used to determine opacity. Monitoring [15A NCAC 2Q .0508(f)] iii. To assure compliance, once a month the Permittee shall observe the exhaust from the emissions points for visible emissions above normal. The monthly observation must be made for each month of the calendar year period to ensure compliance with this requirement. The Permittee shall establish a Αnormal≅ opacity for the source in the first 30 days following startup. If visible emissions from this source are observed to be above normal, the Permittee shall either:

Review 07300R08 -Draft Revision 4, Page 20

(A) take appropriate action to correct the above-normal emissions as soon as practicable and within the monitoring period and record the action taken as provided in the recordkeeping requirements below, or (B) demonstrate that the percent opacity from the emission points of the emission source in accordance with 15A NCAC 2D .0501(c)(8), (Method 9) for 12 minutes, is below the limit given in Section VI. C. 2. b. i. above.

Recordkeeping [15A NCAC 2Q .0508(f)] iv. The results of the monitoring shall be maintained in a logbook (written or electronic format) on-site and made available to an authorized representative upon request. The logbook shall record the following: (A) the date and time of each recorded action; (B) the results of each observation and/or test noting those sources with emissions that were observed to be in noncompliance along with any corrective actions taken to reduce visible emissions; and (C) the results of any corrective actions performed. c.

15A NCAC 2D .0614 “Compliance Assurance Monitoring (CAM)” • Coal unloading by rail (ID No. ES-COALE1, NSPS Subpart Y) with associated bagfilter CD1) • Coal unloading by truck (ID No. ES-COALE2, NSPS Subpart Y) with associated bagfilter (CD2) • Coal transport to storage (ID No. ES-COALFE3, NSPS Subpart Y) with associated bagfilter (CD3) • Coal transport from storage (ID No. ES-COALE4, NSPS Subpart Y) with associated bagfilter (CD4) • Coal mill feed bin (ID No. ES-COALE14, NSPS Subpart Y) with associated bagfilter (CD14) • Coal mill feed bin (ID No. ES-COALE15, NSPS Subpart Y) with associated bagfilter (CD15) • Coal mill feed transport (ID No. ES-COALE16, NSPS Subpart Y) with associated bagfilter (CD16) • Coal mill (ES-COAL, NSPS Subpart Y) with associated bagfilter (CD44B) NSPS Subpart Y “Standards of Performance for Coal Preparation Plants” does not have a particulate emission standard in the current finalized version of this regulation. A proposal to this regulation was placed in the Federal Register in April 2008 that does contain a particulate emission limit. However, because this regulation has not become final, the proposed emission limits will not be placed into the permit. Therefore, the sources listed above will require CAM plans for the particulate control device. Since this is a PSD permit that will be processed under a State 300 schedule, the CAM plan will be required in the Title V permit, unless the proposed NSPS standard has been finalized by the EPA prior to the issuance of the Title V permit.

D. Plant Roads (PLTRD), Storage piles (SP) • ES-PLTRD (Vehicular traffic on paved plant roads) • ES-SPCoal1 (Coal/coke storage pile at the plant) • ES-SPCoal2 (Coal/coke storage pile at the plant) • ES-SPBlend1 (Blended stone pile at the plant) • ES-SPBlend2 (Blended stone pile at the plant) • ES-SPMillscale (Mill scale storage pile at the plant) • ES-SPBauxite (Bauxite storage pile at the plant) • ES-SPAsh (Bottom ash storage pile at the plant) • ES-SPLimestone (Limestone storage pile at the plant) • ES-SPGypsum (Gypsum storage pile at the plant) 1.

Description: The roads on the plant site will be paved. There will be some onsite storage piles of raw material.

2.

Applicable Regulatory Requirements: 15A NCAC 2D .0513 “Particulates From Portland Cement Plants” does not cover the fugitive particulate emissions caused by vehicular travel on plant roads or fugitive particulate emissions from raw material storage piles. NSPS, Subpart F “Standards of Performance for Portland Cement Plants” does not cover the fugitive particulate emissions caused by vehicular travel on plant roads or fugitive particulate emissions from raw material storage piles.

Review 07300R08 -Draft Revision 4, Page 21 NSPS, Subpart OOO “Standards of Performance for Nonmetallic Mineral Processing Plants” does not cover the fugitive particulate emissions caused by vehicular travel on plant roads or fugitive particulate emissions from raw material storage piles. The following provides a summary of limits and/or standards for the emission source(s) described above.

Regulated Pollutant

Limits/Standards

Fugitive dust emissions

Avoid fugitive dust emissions to cause or contribute to substantive complaints or excess visible emissions beyond the property boundary. State Enforceable Only (See Multiple Emissions Section VII A) BACT for paved roads Vacuum sweeping and/or water flushing of paved road surfaces (See Multiple Emissions Section VII B)

Particulate emissions

Applicable Regulation 15A NCAC 2D .0540

15A NCAC 2D .0530 PSD

E. Emergency generator (diesel-fired, 800 kW, 1072.8 hp, GEN-1) 1. Description: This generator is an emergency generator which shall not exceed 500 hours of operation per year. All emissions from this generator are uncontrolled. 2.

Applicable Regulatory Requirements: Generator (GEN-1) will be installed after July 1, 1971 and will be subject to 20% opacity. NSPS, 40 CFR Part 60, Subpart IIII does apply to the compression ignition, diesel-fired emergency generator (GEN-1). This unit is by definition a “new” generator because it will be manufactured after April 1, 2006. MACT, 40 CFR Part 63, Subpart ZZZZ (as revised in the January 18, 2008 Federal Register) does apply to emergency generator GEN-1. This unit has a capacity rating greater than 500 brake horsepower and will be considered “new” because the final installation date on-site will be after December 19, 2002. The final rule for this MACT (Subpart ZZZZ) was revised, and re-published in the Federal Register on January 18, 2008 with an effective date of March 18, 2008. Per 40 CFR §63.6590(b), new RICE engines used as emergency generators at major sources of HAPs, must only meet the initial notification requirements of §63.6645(h). [40 CFR §63.6590(b)] The following provides a summary of limits and/or standards for the emission source(s) described above.

Regulated Pollutant Sulfur dioxide

Visible emissions Hazardous Air Pollutants NMHC + NOx, HC, NOx, CO, PM Nitrogen dioxide Particulate emissions Sulfur dioxide emissions

Limits/Standards 500 parts per million sulfur fuel content beginning 10/01/2007 15 parts per million sulfur fuel content beginning 10/01/2010 20 percent opacity Initial notification requirements Purchase engine certified to meet the applicable engine design emission limits NSPS Subpart IIII limits and standards

Applicable Regulation 15A NCAC 2D .0524 40 CFR Part 60, Subpart IIII

15A NCAC 2D .0521 15A NCAC 2D .1111 40 CFR Part 63, Subpart ZZZZ 15A NCAC 2D .0524 40 CFR Part 60, Subpart IIII 15A NCAC 2D .0530 PSD (BACT)

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a.

15A NCAC 2D .0524, NSPS, 40 CFR Part 60, Subpart IIII Regulation Analysis: i. Diesel fuel sulfur content used in generator (ID No. GEN-1) shall not exceed 500 parts per million sulfur content beginning 10/01/2007. Diesel fuel sulfur content used in generator (ID No. GEN-1) shall not exceed 15 parts per million sulfur content beginning 10/01/2010. Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)] ii. No monitoring, recordkeeping, or reporting is required for sulfur dioxide emissions from the firing of diesel fuel in generator (GEN-1). • Owner/operators who purchase an emergency generator that is less than 30 liters per cylinder must purchase units that are certified by the manufacturer to meet the applicable engine design emission limits. {§60.4211 (c)}. • Owners/operators must operate and maintain engines and control devices in accordance with the manufacturer’s written instructions or procedures developed by the owner or operator that are approved by the engine manufacturer, over the life of the engine. {§60.4206 and §60.4211 (a)}. • No testing is required for units less than 30 liter per cylinder displacement that have been certified by the manufacturer to meet design limits. • Install a nonresettable hour meter {(§60.4209(a)}. • Engines built after July 11, 2005 must burn diesel fuel with less than or equal to 500 ppm sulfur content beginning October 1, 2007 {§60.4207(a)}. • Engines built after July 11, 2005 must burn diesel fuel with less than or equal to 15 ppm sulfur content beginning October 1, 2010 {§60.4207(a)}.

b. 15A NCAC 2D .0521"Control Of Visible Emissions” Regulation Analysis: i. Generator (GEN-1) will be installed after July 1, 1971, and is therefore subject to the State regulation 15A NCAC 2D .0521(d). Per this regulation visible emissions shall not be more than 20 percent opacity when averaged over a six-minute period except that six-minute periods averaging more than 87 percent opacity may occur not more than once in any hour nor more than four times in any 24-hour period. Compliance is expected with this regulation because this generator will be firing diesel fuel only. Monitoring/Recordkeeping/Reporting [15A NCAC 2Q .0508(f)] ii. No monitoring, recordkeeping, or reporting is required for visible emissions from the firing of diesel fuel in generator (GEN-1) because it should always be in compliance with the opacity standard during normal operation.

c.

15A NCAC 2D .1111, 40 CFR Part 63, Subpart ZZZZ “National Emission Standards for Hazardous Air Pollutants For Stationary Reciprocating Internal Combustion Engines” •

GEN-1 (800 kW, 1072.8 brake horsepower)

i.

General Provisions [40 CFR §63.6665]: The Permittee shall comply with the requirements of 40 CFR part 63 Subpart A “General provisions,” according to the applicability of Subpart A to such sources, as identified in Table No. 8 in Subpart ZZZZ, “Applicability Of General Provisions to Subpart ZZZZ”.

ii. Compliance/Notification Procedures [40 CFR §63.6645] Stationary RICE that are emergency generators are subject to limited requirements of Subpart ZZZZ and do not have to meet the requirements of Subpart ZZZZ and of Subpart A of this part, except for the initial notification requirements. Notification should include the following information:

Review 07300R08 -Draft Revision 4, Page 23 The owner or operator of an affected source that has an initial startup before the effective date of a relevant standard under this part shall notify the Administrator in writing that the source is subject to the relevant standard. The notification, which shall be submitted not later than 120 calendar days after startup of the emergency generator and shall provide the following: (A) (B) (C) (D) (E) (F)

The name and address of the owner or operator; The address (i.e., physical location) of the affected source; An identification of the relevant standard, or other requirement, that is the basis of the notification and the source’s compliance date; A brief description of the nature, size, design, and method of operation of the source and an identification of the types of emission points within the affected source subject to the relevant standard and types of hazardous air pollutants emitted; A statement of whether the affected sources is a major source or an area source. A statement that the generators have no additional requirements and explain the basis for the exclusion (for example, that the units operate exclusively as emergency stationary RICE).

Recordkeeping Requirement For Applicability Determination [40 CFR §63.10(b)(3)] iii. The applicability determination for exclusion of these generators from the requirements of 40 CFR Part 63, Subpart ZZZZ and Subpart A of this part, shall be maintained on site for a period of 5 years after the determination, or until the source changes its operations to become an affected source, whichever comes first. The analyses, or other information, that demonstrates the exemption from the requirements of Subpart ZZZZ and part A of this subpart, shall be signed by the person making the determination. F. Plant additives unloading and handling • ES-F1HF1 (Additives hopper/feeder, 40 CFR Part 63, Subpart LLL) • ES-F1BCT (Additives belt conveyor transfer, 40 CFR Part 63, Subpart LLL) • ES-F5 (Additives belt conveyor transfer, 40 CFR Part 63, Subpart LLL) • ES-F7 (Additives belt conveyor transfer, 40 CFR Part 63, Subpart LLL) • ES-F7C (Bottom Ash conveyor to silo, 40 CFR Part 63, Subpart LLL) • ES-F7D (Bottom ash silo to enclosed belt, 40 CFR Part 63, Subpart LLL) 1.

Description: The plant additives unloading and handling system.

2.

Applicable Regulatory Requirements: The plant additives unloading and handling system is subject to MACT, 40 CFR Part 63, Subpart LLL “National Emission Standards for Hazardous Air Pollutant From the Portland Cement Manufacturing Industry”. The Plant additives unloading and handling system is exempt from the requirements of NSPS, 40 CFR Part 60, Subpart F “Standards Of Performance For Portland Cement Plants” in accordance with 40 CFR Part 63, Subpart LLL §63.1356(a). The following provides a summary of limits and/or standards for the emission source(s) described above.

Regulated Pollutant Visible Emissions

Limits/Standards 10 percent opacity (See Multiple Emissions Section VII D)

Applicable Regulation 15A NCAC 2D .1111 40 CFR Part 63, Subpart LLL

G. Raw Material Unloading & Handling (RMH) • ES-RMHF3B (Quarry blend belt to tripper belt, 40 CFR 63, Subpart LLL) • ES-RMHF3TB (Quarry blend tripper belt to piles, 40 CFR Part 63, Subpart LLL) • ES-RMHF3PR (Quarry blend pile reclaimer, 40 CFR Part 63, Subpart LLL) • ES-RMHF3R (Quarry blend reclaimer to belt, 40 CFR Part 63, Subpart LLL) • ES-RMHF3ABT (Additives belt to tripper belt, 40 CFR Part 63, Subpart LLL) • ES-RMHF3ATB (Additives tripper belt to piles, 40 CFR Part 63, Subpart LLL) • ES-RMHF3APR (Additives pile reclaimer, 40 CFR Part 63, Subpart LLL) • ES-RMHF3RB (Additives reclaimer to belt, 40 CFR Part 63, Subpart LLL) • ES-RMHF6BCT (Quarry blend belt conveyor transfer, 40 CFR Part 63, Subpart LLL) • ES-RMHF7A (Quarry blend conveyor to silo, 40 CFR Part 63, Subpart LLL) • ES-RMHF7B (Quarry blend silo to enclosed belt, 40 CFR Part 63, Subpart LLL)

Review 07300R08 -Draft Revision 4, Page 24 1.

Description: Area where raw materials from the quarry and materials that are transported in by truck or rail car are stored and handled.

2.

Applicable Regulatory Requirements: Raw Material Storage is subject MACT, 40 CFR Part 63, Subpart LLL “National Emission Standards for Hazardous Air Pollutant From the Portland Cement Manufacturing Industry” and Fugitive Dust Emissions. The following provides a summary of limits and/or standards for the emission source(s) described above.

Regulated Pollutant Visible Emissions Particulate emissions

Limits/Standards 10 percent opacity (See Multiple Emissions Section VII D) MACT Subpart LLL limits

Applicable Regulation 15A NCAC 2D .1111 40 CFR Part 63, Subpart LLL

15A NCAC 2D .0530 PSD (BACT)

H. Raw Mill Handling System (RMHS) • ES-RMHSE5 (Raw mill feed bin, 40 CFR 63, Subpart LLL) with associated bagfilter (CD5) • ES-RMHSE6 (Raw mill feed transport, 40 CFR 63, Subpart LLL) with associated bagfilter (CD6) • ES-RMHSE7 (Raw mill feed, 40 CFR 63, Subpart LLL) with associated bagfilter (CD7) • ES-RMHSE8 (Raw mill reject, 40 CFR 63, Subpart LLL) with associated bagfilter (CD8) • ES-RMHSE9 (Kiln dust bin, 40 CFR 63, Subpart LLL) with associated bagfilter (CD9) • ES-RMHSE10 (Raw mill transport to silo, 40 CFR 63, Subpart LLL) with associated bagfilter (CD10) • ES-RMHSE11 (Raw mill silo, 40 CFR 63, Subpart LLL) with associated bagfilter (CD11) • ES-RMHSE12 (Raw mill silo extraction, 40 CFR 63, Subpart LLL) with associated bagfilter (CD12) • ES-RMHSE13 (Kiln feed, 40 CFR 63, Subpart LLL) with associated bagfilter (CD13) 1.

Description: The system stores and transports the raw materials and reusable kiln dust to the raw mill for the Portland Cement process.

2.

Applicable Regulatory Requirements: The raw mill feed system is subject to MACT, Part 63, Subpart LLL “National Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing Industry”. [see 40 CFR §63.1340(b)]. MACT Subpart LLL currently does not have a particulate emission rate standard. But since 15A NCAC 2D .0530 has a BACT outlet grain loading to control the emissions of PM, State Regulation 15A NCAC 2D .0515 will not apply. The following provides a summary of limits and/or standards for the emission source(s) described above.

Regulated Pollutant Particulate emissions

Limits/Standards Bagfilter with outlet grain loading of 0.01 gr/SCF

Applicable Regulation 15A NCAC 2D .0530

Visible Emissions

10 percent opacity

15A NCAC 2D .1111

(See Multiple Emissions Section VII D)

40 CFR Part 60, Subpart LLL

PSD (BACT)

These sources are controlled by a bagfilter using an outlet grain loading of 0.01 grains/standard cubic foot (SCF). The standard gas flow rate is the gas flow rate expressed at standard conditions [(68 degrees F (528 degrees Rankine) and 14.7 psia (407 inches water)]. Standard gas flow rates are useful when material balances are prepared, for calculations in which the gas stream may undergo chemical reactions, and for comparing the flow rate in a system with the flow rate capacity of a fan. The maximum inlet airflow rate of each bagfilter is given in actual cubic feet per minute (ACFM). In order to calculate the PM output from each bagfilter, the following equation shall be used.

Review 07300R08 -Draft Revision 4, Page 25

⎡T ACFM = SCFM × ⎢ actual ⎢⎣ TSTP Where: Tactual TSTP Pactual PSTP

⎤ ⎡ PSTP ⎤ ⎥ ⎥×⎢ ⎥⎦ ⎢⎣ Pactual ⎥⎦

= actual temperature at the outlet of the bagfilter = standard temperature at the outlet of the bagfilter (68 degrees F) = actual pressure at the outlet of the bagfilter (14.7 psia or 407 inches W.C.) = standard pressure at the outlet of the bagfilter (14.7 psia or 407 inches W.C.)

Solve equation for SCF

⎡ TSTP ⎤ ⎡ PActual ⎤ ⎥×⎢ ⎥ ⎢⎣ T Actual ⎥⎦ ⎢⎣ PSTP ⎥⎦

SCFM = ACFM × ⎢

Example Calculation using source (Raw mill feed bin controlled by bagfilter CD5)

⎡ ( 460 + 68) STP ⎤ ⎡ ( 407 inches water column) Actual ⎤ = 8357.54 SCFM ⎥×⎢ ⎥ ⎢⎣ ( 460 + 77) Actual ⎥⎦ ⎣⎢ ( 407 inches water column) STP ⎦⎥

SCFM = 8500 ACFM × ⎢

Outlet grain loading for each bagfilter = 0.01 grains/SCF

Maximum emissions of PM (lbs / hr ) =

0.01 grains s tan dard cubic foot

×

8357.54 s tan dard cubic feet min ute

×

60 min utes hour

×

1 lb 7000 grains

=

0.72 lbs hour

Potential PM emissions including bagfilter efficiency from the Coal/Coke Handling System using the equations above Source

ACFM to bagfilter

Stand. Temp.

Actual Temp.

Raw mill feed bin (CD5) 8500 acfm 68 0F 77 0F 0 Raw mill feed transport (CD6) 7750 acfm 68 F 77 0F 0 Raw mill feed (CD7) 10800 acfm 68 F 77 0F Raw mill reject (CD8) 11700 acfm 68 0F 90 0F 0 Kiln dust bin (CD9) 4200 acfm 68 F 302 0F 0 Raw mill transport to silo (CD10) 4000 acfm 68 F 150 0F 0 Raw mill silo (CD11) 4200 acfm 68 F 150 0F 0 Raw mill silo extraction (CD12) 4760 acfm 68 F 150 0F 0 Kiln feed (CD13) 4300 acfm 68 F 150 0F Total * PM10 is 84% of the PM number in accordance with AP-42 Table 11.6-5 a.

Stand. Pressure

Actual Pressure

PM Output * (lbs/hr)

14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia

14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia

0.72 lbs/hr 0.65 lbs/hr 0.91 lbs/hr 0.96 lbs/hr 0.25 lbs/hr 0.30 lbs/hr 0.31 lbs/hr 0.35 lbs/hr 0.32 lbs/hr 4.77 lbs/hr

Regulatory Requirements: i. Monitoring/Recordkeeping [Bagfilter monitoring will be added in condition 15A NCAC 2D .0530 in the permit] Particulate matter emissions from the Raw Mill Handling System shall be controlled by bagfilters (ID Nos. CD5 through CD13). To assure compliance, the Permittee shall perform inspections and maintenance as recommended by the manufacturer. In addition to the manufacturer’s inspection and maintenance recommendations, or if there is no manufacturer’s inspection and maintenance recommendations, as a minimum, the inspection and maintenance requirement shall include the following:

Review 07300R08 -Draft Revision 4, Page 26 (A). a monthly visual inspection of the system ductwork and material collection unit for leaks; and (B) an annual (for each 12 month period following the initial inspection) internal inspection of the bagfilter's structural integrity. ii. The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) on-site and made available to an authorized representative upon request. The logbook shall record the following: (A) the date and time of each recorded action; (B) the results of each inspection; (C) the results of any maintenance performed on the bagfilters; and (D) any variance from manufacturer’s recommendations, if any, and corrections made.

Reporting [15A NCAC 02Q .0508(f)] iii. The Permittee shall maintain a monthly summary report, acceptable to the Regional Air Quality Supervisor, of monitoring and recordkeeping listed above and shall submit the results within 30 days of a written request by the DAQ. b. 15A NCAC 2D .0614 “Compliance Assurance Monitoring (CAM)” • ES-RMHSE5 (Raw mill feed bin, 40 CFR 63, Subpart LLL) with associated bagfilter (CD5) • ES-RMHSE6 (Raw mill feed transport, 40 CFR 63, Subpart LLL) with associated bagfilter (CD6) • ES-RMHSE7 (Raw mill feed, 40 CFR 63, Subpart LLL) with associated bagfilter (CD7) • ES-RMHSE8 (Raw mill reject, 40 CFR 63, Subpart LLL) with associated bagfilter (CD8) • ES-RMHSE9 (Kiln dust bin, 40 CFR 63, Subpart LLL) with associated bagfilter (CD9) • ES-RMHSE10 (Raw mill transport to silo, 40 CFR 63, Subpart LLL) with associated bagfilter (CD10) • ES-RMHSE11 (Raw mill silo, 40 CFR 63, Subpart LLL) with associated bagfilter (CD11) • ES-RMHSE12 (Raw mill silo extraction, 40 CFR 63, Subpart LLL) with associated bagfilter (CD12) • ES-RMHSE13 (Kiln feed, 40 CFR 63, Subpart LLL) with associated bagfilter (CD13) MACT, Subpart LLL does not have a particulate emission standard in the current finalized version of this regulation. Therefore, the sources listed above will require CAM plans for the particulate control devices. Since this is a PSD permit that will be processed under a State 300 schedule, the CAM plan will be required in the Title V permit, unless the proposed MACT Subpart LLL standard has been finalized by the EPA and contains a particulate emission standard in the final version.

I.

Clinker handling and Storage (CHS) • Clinker discharge and cooler with associated bagfilter (CD19) • Clinker dome with associated bagfilter (CD20) • Off spec bin with associated bagfilter (CD21) 1.

Description: The clinker handling process is the final process in the production of Portland Cement prior to the finish mills. PM/PM10 emissions are controlled by bagfilters that vent directly to the atmosphere versus being routed to the main stack.

2.

Applicable Regulatory Requirements: The clinker handling system is subject to 40 CFR Part 63, Subpart LLL “National Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing Industry”. [see 40 CFR §63.1340(b)(6)]. The following provides a summary of limits and/or standards for the emission source(s) described above.

Regulated Pollutant Particulate emissions

Limits/Standards Bagfilter with outlet grain loading of 0.01 gr/SCF

Visible Emissions

10 percent opacity (See Multiple Emissions Section VII D)

Applicable Regulation 15A NCAC 2D .0530 PSD (BACT)

15A NCAC 2D .1111 40 CFR Part 63, Subpart LLL

Review 07300R08 -Draft Revision 4, Page 27 These sources are controlled by a bagfilter using an outlet grain loading of 0.01 grains/standard cubic foot (SCF). The standard gas flow rate is the gas flow rate expressed at standard conditions [68 degrees F (528 degrees Rankine) and 14.7 psia (407 inches water)]. Standard gas flow rates are useful when material balances are prepared, for calculations in which the gas stream may undergo chemical reactions, and for comparing the flow rate in a system with the flow rate capacity of a fan. The maximum inlet airflow rate of each bagfilter is given in actual cubic feet per minute (ACFM). In order to calculate the PM output from each bagfilter, the following equation shall be used to convert ACFM to SCF.

⎡T ACFM = SCFM × ⎢ actual ⎣⎢ TSTP Where: Tactual TSTP Pactual PSTP

⎤ ⎡ PSTP ⎤ ⎥ ⎥×⎢ ⎦⎥ ⎣⎢ Pactual ⎦⎥

= actual temperature at the outlet of the bagfilter = standard temperature at the outlet of the bagfilter (68 degrees F) = actual pressure at the outlet of the bagfilter (14.7 psia or 407 inches W.C.) = standard pressure at the outlet of the bagfilter (14.7 psia or 407 inches W.C.)

Solve equation for SCF

⎡ TSTP ⎤ ⎡ PActual ⎤ ⎥×⎢ ⎥ ⎣⎢ T Actual ⎦⎥ ⎣⎢ PSTP ⎦⎥

SCFM = ACFM × ⎢

Example Calculation using source (Clinker discharge and cooler) controlled by bagfilter (CD19)

⎡ ( 460 + 68) STP ⎤ ⎡ ( 407 inches water column) Actual ⎤ = 3,387 SCFM ⎥×⎢ ⎥ ⎢⎣ ( 460 + 257) Actual ⎥⎦ ⎢⎣ ( 407 inches water column) STP ⎥⎦

SCFM = 4,600 ACFM × ⎢

Outlet grain loading for each bagfilter = 0.01 grains/SCF Maximum emissions of PM (lbs / hr ) =

0.01 grains s tan dard cubic foot

×

3,387 s tan dard cubic feet min ute

×

60 min utes hour

×

1 lb 7000 grains

=

0.29 lbs hour

Potential PM emissions including bagfilter efficiency from the Clinker handling and Storage System using the equations above Source

ACFM to bagfilter

Stand. Temp.

Actual Temp.

Stand. Pressure

Actual Pressure

PM Output * (lbs/hr)

Clinker discharge and cooler (bagfilter CD19) 4,600 ACFM 68 0F 257 0F 0 Clinker dome (bagfilter CD20) 3,672 ACFM 68 F 257 0F 0 Off spec bin (bagfilter CD21) 2,260 ACFM 68 F 257 0F Total * PM10 is 84% of the PM number in accordance with AP-42 Table 11.6-5

14.7 psia 14.7 psia 14.7 psia

14.7 psia 14.7 psia 14.7 psia

0.29 lbs/hr 0.23 lbs/hr 0.14 lbs/hr 0.66 lbs/hr

Review 07300R08 -Draft Revision 4, Page 28 a.

Regulatory Requirements [Bagfilter monitoring will be added in condition 15A NCAC 2D .0530 in the permit] i.

Monitoring/Recordkeeping [15A NCAC 02Q .0508(f)] Particulate matter emissions from the Clinker Handling and Storage System shall be controlled by bagfilters (ID Nos. CD19, 20, and 21). To assure compliance, the Permittee shall perform inspections and maintenance as recommended by the manufacturer. In addition to the manufacturer’s inspection and maintenance recommendations, or if there is no manufacturer’s inspection and maintenance recommendations, as a minimum, the inspection and maintenance requirement shall include the following: (A) a monthly visual inspection of the system ductwork and material collection unit for leaks; and (B) an annual (for each 12 month period following the initial inspection) internal inspection of the bagfilter's structural integrity.

ii. The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) on-site and made available to an authorized representative upon request. The logbook shall record the following: (A) the date and time of each recorded action; (B) the results of each inspection; (C) the results of any maintenance performed on the bagfilters; and (D) any variance from manufacturer’s recommendations, if any, and corrections made. iii.

J.

Reporting [15A NCAC 02Q .0508(f)] The Permittee shall maintain a monthly summary report, acceptable to the Regional Air Quality Supervisor, of monitoring and recordkeeping listed above and shall submit the results within 30 days of a written request by the DAQ.

Finish Mills (FM) • Cement mill #1 feed bin with associate bagfilter CD22 • Cement mill #2 feed bin with associate bagfilter CD23 • Cement mill #1 feed with associate bagfilter CD24 • Cement mill #1 recirculation bin associate bagfilter CD25 • Cement mill #1 reject with associate bagfilter CD26 • Cement mill #1 transport with associate bagfilter CD27 • Cement mill #2 feed with associate bagfilter CD28 • Cement mill #2 recirculation bin associate bagfilter CD29 • Cement mill #2 reject with associate bagfilter CD30 • Cement mill #2 transport with associate bagfilter CD31 • Exhaust from finish mill #1 with associate bagfilter CD45A • Exhaust from finish mill #2 with associate bagfilter CD45B • Cement additive bin with associate bagfilter CD446 • Cement additive intake from finis mill #1 with associate bagfilter CD47 • Gypsum/limestone unloading • Gypsum/limestone hopper/feeder • Gypsum/limestone belt conveyor transfer 1. Description: The finish mills take the cooled clinker and grinds it into a fine gray powder. Gypsum and other materials are added to the powder add special properties to the cement. PM/PM10 emissions are controlled by bagfilters that vent directly to the atmosphere versus being routed to the main stack. 2. Applicable Regulatory Requirements: The finishing mill system is subject to 40 CFR Part 63, Subpart LLL “National Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing Industry”. [see 40 CFR §63.1340(b)(4)].

Review 07300R08 -Draft Revision 4, Page 29 The following provides a summary of limits and/or standards for the emission source(s) described above.

Regulated Pollutant Particulate emissions

Limits/Standards Bagfilter with outlet grain loading of 0.01 gr/SCF

Visible emissions

10 percent opacity (See Multiple Emissions in Section VII D)

Applicable Regulation 15A NCAC 2D .0530 PSD (BACT)

15A NCAC 2D .1111 40 CFR Part 63, Subpart LLL

All of these sources are controlled by a bagfilter using an outlet grain loading of 0.01 grains/standard cubic foot (SCF). The standard gas flow rate is the gas flow rate expressed at standard conditions [68 degrees F (528 degrees Rankine) and 14.7 psia (407 inches water)]. Standard gas flow rates are useful when material balances are prepared, for calculations in which the gas stream may undergo chemical reactions, and for comparing the flow rate in a system with the flow rate capacity of a fan. The maximum inlet airflow rate of each bagfilter is given in actual cubic feet per minute (ACFM). In order to calculate the PM output from each bagfilter, the following equation shall be used to convert ACFM to SCF.

⎡T ACFM = SCFM × ⎢ actual ⎢⎣ TSTP Where: Tactual TSTP Pactual PSTP

⎤ ⎡ PSTP ⎤ ⎥ ⎥×⎢ ⎥⎦ ⎣⎢ Pactual ⎦⎥

= actual temperature at the outlet of the bagfilter = standard temperature at the outlet of the bagfilter (68 degrees F) = actual pressure at the outlet of the bagfilter (14.7 psia or 407 inches W.C.) = standard pressure at the outlet of the bagfilter (14.7 psia or 407 inches W.C.)

Solve equation for SCF

⎡ TSTP ⎤ ⎡ PActual ⎤ ⎥×⎢ ⎥ ⎣⎢ T Actual ⎦⎥ ⎢⎣ PSTP ⎥⎦

SCFM = ACFM × ⎢

Example Calculation using finishing mill #1 (ID No. ES-FME22) controlled by bagfilter (CD22)

⎡ ( 460 + 68) STP ⎤ ⎡ ( 407 inches water column) Actual ⎤ = 8417 SCFM ⎥×⎢ ⎥ ⎢⎣ ( 460 + 156) Actual ⎥⎦ ⎣⎢ ( 407 inches water column) STP ⎦⎥

SCFM = 9,820 ACFM × ⎢

Outlet grain loading for each bagfilter = 0.01 grains/SCF Maximum emissions of PM (lbs / hr ) =

0.01 grains s tan dard cubic foot

×

8, 417 s tan dard cubic feet min ute

×

60 min utes hour

×

1 lb 7000 grains

=

0.72 lbs hour

Review 07300R08 -Draft Revision 4, Page 30 Potential PM emissions including bagfilter efficiency from the Finish Mills (FM) using the equations above Source

ACFM to bagfilter

Cement mill #1 feed bin (bagfilter CD22) Cement mill #2 feed bin (bagfilter CD23) Cement mill #1 feed (bagfilter CD24) Cement mill #1 recirculation bin (bagfilter CD25) Cement mill #1 reject (bagfilter CD26) Cement mill #1 transport (bagfilter CD27) Cement mill #2 feed (bagfilter CD28) Cement mill #2 recirculation bin (bagfilter CD29) Cement mill #2 reject (bagfilter CD30) Cement mill #2 transport (bagfilter CD31) Exhaust from finish mill #1 (bagfilter CD45A) Exhaust from finish mill #2 (bagfilter CD45B) Cement additive bin (bagfilter CD46) Cement additive intake (bagfilter CD47)

9,820 ACFM 8,830 ACFM 4,697 ACFM 2,719 ACFM 5,262 ACFM 2,154 ACFM 5,580 ACFM 2,719 ACFM 5,262 ACFM 2,154 ACFM 125,438 ACFM 4,810 ACFM 10,587 ACFM

Stand. Temp.

68 0F 68 0F 68 0F 68 0F 68 0F 68 0F 68 0F 68 0F 68 0F 68 0F

Actual Temp.

68 0F

156 0F 156 0F 156 0F 212 0F 212 0F 212 0F 178 0F 212 0F 212 0F 212 0F 210 0F

68 0F 68 0F

156 0F 77 0F

Stand. Pressure

Actual Pressure

PM Output * (lbs/hr)

14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia

14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia

14.7 psia

14.7 psia

0.72 lbs/hr 0.65 lbs/hr 0.35 lbs/hr 0.18 lbs/hr 0.35 lbs/hr 0.15 lbs/hr 0.40 lbs/hr 0.18 lbs/hr 0.35 lbs/hr 0.15 lbs/hr 8.47 lbs/hr

14.7 psia 14.7 psia

14.7 psia 14.7 psia Total

0.35 lbs/hr 0.89 lbs/hr 13.19 lbs/hr

* PM10 is 84% of the PM number in accordance with AP-42 Table 11.6-5

Regulatory Requirements [Bagfilter monitoring will be added in condition 15A NCAC 2D .0530 in the permit] i. Monitoring/Recordkeeping [15A NCAC 02Q .0508(f)] Particulate matter emissions from the Finish Mill System shall be controlled by bagfilters (ID Nos. CD22 through 31, 45A, 45B, 46, and 47). To assure compliance, the Permittee shall perform inspections and maintenance as recommended by the manufacturer. In addition to the manufacturer’s inspection and maintenance recommendations, or if there is no manufacturer’s inspection and maintenance recommendations, as a minimum, the inspection and maintenance requirement shall include the following: (A) a monthly visual inspection of the system ductwork and material collection unit for leaks; and (B) an annual (for each 12 month period following the initial inspection) internal inspection of the bagfilter's structural integrity. ii The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) on-site and made available to an authorized representative upon request. The logbook shall record the following: (A) the date and time of each recorded action; (B) the results of each inspection; (C) the results of any maintenance performed on the bagfilters; and (D) any variance from manufacturer’s recommendations, if any, and corrections made. a.

iii.

K.

Reporting [15A NCAC 02Q .0508(f)] The Permittee shall maintain a monthly summary report, acceptable to the Regional Air Quality Supervisor, of monitoring and recordkeeping listed above and shall submit the results within 30 days of a written request by the DAQ.

Cement handling, Storage, and Loadout (CHSL) • Cement dome with associated bagfilter (CD32) • Cement dome extraction rail with associated bagfilter (CD33) • Cement dome extraction truck with associated bagfilter (CD34) • Cement silo with associated bagfilter (CD40) • Cement silo extraction with associated bagfilter (CD41) • Cement transport with associated bagfilter (CD42) • Packaging plant with associated bagfilter (CD43) • Cement silo with associated bagfilter (CDP43) • Screw conveyor and truck load-out spout

Review 07300R08 -Draft Revision 4, Page 31

1. Description: The cement handling, storage, and load out system prepares the final product for shipment offsite. PM/ PM10 emissions are controlled by bagfilters that vent directly to the atmosphere versus being routed to the main stack. 2.

Applicable Regulatory Requirements: The cement handling, storage, and loadout system is subject to 40 CFR Part 63, Subpart LLL “National Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing Industry”. [see 40 CFR §63.1340(b)(6)]. The following provides a summary of limits and/or standards for the emission source(s) described above.

Regulated Pollutant Particulate emissions

Limits/Standards Bagfilter with outlet grain loading of 0.01 gr/SCF

Visible emissions

10 percent opacity (See Multiple Emissions Section VII D)

Applicable Regulation 15A NCAC 2D .0530 PSD (BACT) 15A NCAC 2D .1111 40 CFR Part 63, Subpart LLL

All of these sources are controlled by a bagfilter using an outlet grain loading of 0.01 grains/standard cubic foot (SCF). The standard gas flow rate is the gas flow rate expressed at standard conditions [68 degrees F (528 degrees Rankine) and 14.7 psia (407 inches water)]. Standard gas flow rates are useful when material balances are prepared, for calculations in which the gas stream may undergo chemical reactions, and for comparing the flow rate in a system with the flow rate capacity of a fan. The maximum inlet airflow rate of each bagfilter is given in actual cubic feet per minute (ACFM). In order to calculate the PM output from each bagfilter, the following equation shall be used to convert ACFM to SCF.

⎡T ACFM = SCFM × ⎢ actual ⎢⎣ TSTP Where: Tactual TSTP Pactual PSTP

⎤ ⎡ PSTP ⎤ ⎥ ⎥×⎢ ⎥⎦ ⎢⎣ Pactual ⎥⎦

= actual temperature at the outlet of the bagfilter = standard temperature at the outlet of the bagfilter (68 degrees F) = actual pressure at the outlet of the bagfilter (14.7 psia or 407 inches W.C.) = standard pressure at the outlet of the bagfilter (14.7 psia or 407 inches W.C.)

Solve equation for SCF

⎡ TSTP ⎤ ⎡ PActual ⎤ ⎥×⎢ ⎥ ⎢⎣ T Actual ⎥⎦ ⎢⎣ PSTP ⎥⎦

SCFM = ACFM × ⎢

Example Calculation using the cement silo (ES-CHSLE40) controlled by bagfilter (CD40)

⎡ ( 460 + 68) STP ⎤ ⎡ ( 407 inches water column) Actual ⎤ = 17,875 SCFM ⎥×⎢ ⎥ ⎣⎢ ( 460 + 212) Actual ⎦⎥ ⎣⎢ ( 407 inches water column) STP ⎦⎥

SCFM = 22,750 ACFM × ⎢

Review 07300R08 -Draft Revision 4, Page 32 Outlet grain loading for each bagfilter = 0.01 grains/SCF Maximum emissions of PM (lbs / hr ) =

0.01 grains s tan dard cubic foot

×

17,875 s tan dard cubic feet min ute

×

60 min utes hour

×

1 lb 7000 grains

=

1.53 lbs hour

Potential PM emissions including bagfilter efficiency from the Cement handling, Storage, and Loadout (CHSL) System using the equations above Source

ACFM to bagfilter

Stand. Temp.

Actual Temp.

Stand. Pressure

Actual Pressure

Cement dome (bagfilter CD32) Cement dome extraction rail (bagfilter CD33) Cement dome extraction truck (bagfilter CD34) Cement silo (bagfilter CD40) Cement silo extraction (bagfilter CD41) Cement transport (bagfilter CD42) Packaging plant (bagfilter CD43)

26,910 ACFM 1,800 ACFM 1,800 ACFM 22,750 ACFM 1,271 ACFM 2,578 ACFM 7,416 ACFM

68 0F 68 0F 68 0F 68 0F 68 0F 68 0F 68 0F

0

14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia

14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia 14.7 psia Total

F F 0 F 0 F 0 F 0 F 0 F 0

PM Output * (lbs/hr)

1.81 lbs/hr 0.12 lbs/hr 0.12 lbs/hr 1.53 lbs/hr 0.09 lbs/hr 0.17 lbs/hr 0.50 lbs/hr 4.35 lbs/hr

* PM10 is 84% of the PM number in accordance with AP-42 Table 11.6-5

a.

Regulatory Requirements [Bagfilter monitoring will be added in condition 15A NCAC 2D .0530 in the permit] i.

Monitoring/Recordkeeping [15A NCAC 02Q .0508(f)] Particulate matter emissions cement handling, storage, and loadout system shall be controlled by bagfilters (ID Nos. CD32, 33, 34, 40, 41, 42, and 43). To assure compliance, the Permittee shall perform inspections and maintenance as recommended by the manufacturer. In addition to the manufacturer’s inspection and maintenance recommendations, or if there is no manufacturer’s inspection and maintenance recommendations, as a minimum, the inspection and maintenance requirement shall include the following: (A) a monthly visual inspection of the system ductwork and material collection unit for leaks; and (B) an annual (for each 12 month period following the initial inspection) internal inspection of the bagfilter's structural integrity. ii. The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) on-site and made available to an authorized representative upon request. The logbook shall record the following: (A) the date and time of each recorded action; (B) the results of each inspection; (C) the results of any maintenance performed on the bagfilters; and (D) any variance from manufacturer’s recommendations, if any, and corrections made. Reporting [15A NCAC 02Q .0508(f)] iii. The Permittee shall maintain a monthly summary report, acceptable to the Regional Air Quality Supervisor, of monitoring and recordkeeping listed above and shall submit the results within 30 days of a written request by the DAQ.

Review 07300R08 -Draft Revision 4, Page 33 L.

Kiln System (ID No. ES-KS) {Preheater/precalciner kiln (Coal-fired, petroleum coke, 675 million Btu per hour heat input)/in-line raw mill/clinker cooler with associated selective non-catalytic reduction (SNCR, CD44N), lime injection system (CD44S)} routed to bagfilter (CD44A), and the Coal Mill system (ID No. ES-COAL) routed to bagfilter (CD44B), 1.

Description: The preheater tower at this facility contains a series of vertical cyclone chambers through which the raw materials pass on their way to the kiln. To save energy, the exhaust gases from the kiln rises some 200 feet and is used to preheat the raw materials as they swirl through the preheater cyclones. In the preheater/precalciner stage, materials are heated up to temperatures just below the melting or fusion point. Powdered coal or pet coke is injected and burned in the preheater/precalciner section. 60% of the total heat input for the system occurs here. Material transport associated with dry raw milling systems can be accomplished by a variety of mechanisms, including screw conveyors, belt conveyors, drag conveyors, bucket elevators, air slide conveyors, and pneumatic conveying systems. The most common combination of ingredients is limestone (for calcium) coupled with much smaller quantities of clay and sand. The raw materials for clinker production at this facility include limestone/marl, bauxite (principal ore of aluminum), bottom ash, sand, and mill scale (iron). Synthetic gypsum or natural gypsum will be milled with the clinker to produce cement. The bauxite, fly ash/bottom ash, mill scale will be brought in from the outside and will be added to the mixture. Raw preheated material enters the huge rotating furnace called a kiln. The raw material mix enters the kiln at the elevated end, and the combustion fuels are introduced into the lower end of the kiln in a countercurrent manner. The materials are continuously and slowly moved to the lower end by rotation of the kiln. This horizontally sloped steel cylinder, lined with firebrick, turns from one to three revolutions per minute. As the materials move down the kiln, the material passes through progressively hotter zones toward the flame. At the lower end of the kiln (hottest part) the material may become partially molten. This system transforms the raw mix into red-hot clinkers, which are gray, glass-hard, spherically shaped nodules that range from 0.32 to 5.1 centimeters (cm) (0.125 to 2.0 inches [in.]) in diameter. Emissions from the preheater/precalciner kiln/in-line raw mill/clinker cooler system exit the main stack after being routed through bagfilter CD44A. Emissions from the coal mill exit the main stack after being routed through bagfilter CD44B.

2.

Applicable Regulatory Requirements: The kiln system (ES-KS) is subject to MACT, 40 CFR Part 63, Subpart LLL “National Emission Standards for Hazardous Air Pollutant From the Portland Cement Manufacturing Industry”. The kiln system (preheater/precalciner kiln/in-line raw mill/clinker cooler) is subject to 15A NCAC 2D .0513 “Particulates From Portland Cement Plants” because this regulation contains requirements for particulate emissions for kilns located at Portland Cement Plants. However, the PSD BACT limit is more stringent for the emissions of particulate from the kiln than 2D .0513 which requires that PM from the kiln be controlled by at least 99.7 percent and that the emission rate not exceed 0.327 lb/barrel of cement. The proposed BACT limit for the kiln system is a baghouse with an outlet grain loading of 0.012 grains/scf. NSPS (40 CFR Part 60, Subpart F) “Standards Of Performance For Portland Cement Plants” does not apply to the kiln system and raw mill system in accordance with MACT (40 CFR Part 63, Subpart LLL), §63.1356 (a). This regulation states that “any affected sources subject to the provisions of 40 CFR Part 63, Subpart LLL are exempt from any otherwise applicable new sources performance standards contained in NSPS Subpart F and NSPS Subpart OOO.” NSPS (40 CFR Part 60, Subpart UUU) “Standards Of Performance For Calciners and Dryers in Mineral Industries” does not apply to this Portland Cement manufacturing plant because this cement plant does not process or produce any of the following seventeen minerals, their concentrates or any mixture of which the majority (greater than 50%). The minerals are: alumina, ball clay, bentonite, diatomite, feldspar, fire clay, fuller’s earth, gypsum, industrial sand, kaolin, lightweight aggregate, magnesium compounds, perlite, roofing granules, talc, titanium dioxide, and vermiculite.

Review 07300R08 -Draft Revision 4, Page 34 NSPS (40 CFR Part 60, Subpart CCCC) “ Standards of Performance for Commercial and Industrial Solid Waste Incineration Units (CISWI) for which construction is commenced after November 30, 1999” does not apply to this system. The kiln is specifically exempted from this regulation. [40 CFR §60.2020(l)] The calciner that is located upstream of the kiln, was proposed in the application to also burn pet coke (currently classified as a solid waste) as a fuel. NSPS (40 CFR Part 60, Subpart CCCC) does not specifically exempt the calciner from this regulation. However, in a preheater/ precalciner/kiln system, the calciner is an integral part of the kiln and is considered to be part of the kiln. Therefore, the calciner is also exempt from the requirements of the Subpart CCCC for solid waste incinerators. Note:

Petroleum coke is a carbonaceous solid derived from oil refinery coker units or other cracking processes. (RCRA defines the term “solid waste” to mean …any garbage, refuse, sludge from a waste treatment plant, water supply treatment plant, or air pollution control facility and other discard material including solid, liquid, semisolid, or contained gaseous material resulting from industrial, commercial, mining, and agricultural operation….” On July 30, 2007, the United States Court of Appeals for the District of Columbia Circuit issued a mandate partially vacating the Federal Performance Standards for Commercial and Industrial Solid Waste Incinerators, “CISWI NSPS” (40 CFR Part 60 Subpart CCCC). The partial vacatur of the CISWI NSPS is for the amendment to the CISWI NSPS that was promulgated in 2005 (sometimes called the “Definitions Rule”). One January 2, 2009, the EPA issued an Advanced Notice of Proposed Rulemaking (NAPR) seeking comment on amending the definition of solid waste. [74 Federal Register 41] The partial vacatur of this rule does not change or affect the exemption of kilns from the Commercial and Industrial Solid Waste Incineration regulations. When the new proposed and final revision to this rule are issued, EPA may change the definition of “solid waste as it pertains to waste used as fuel. While the court vacated the CISWI Definitions Rule, the CISWI rule, as promulgated in December 2000, is still in place. Likewise, the Federal plan, as promulgated in October 2003, is still in place. Regardless of the status of the pet coke, the kiln system is exempt from the CISWI rule per 40 CFR §60.2020(l).

The following provides a summary of limits and/or standards for the emission source(s) described above.

Regulated Pollutant Particulate emissions

PM10

Visible emissions

Limits/Standards Emissions from the kiln/inline raw mill shall not exceed 0.30 pounds PM per ton of feed (on dry basis) to the kiln Emissions from the clinker cooler shall not exceed 0.10 pounds per ton of feed (on dry basis) to kiln Emissions from the kiln shall not exceed 0.30 pounds PM per ton of feed (on dry basis) to the kiln Emissions from the clinker cooler shall not exceed 0.10 pounds PM per ton of feed (on dry basis) to the kiln Combined filterable emissions from the kiln/inline raw mill/ clinker cooler bagfilter (CD44A) shall not exceed 0.012 grains/scf outlet grain loading Filterable emissions from the coal mill bagfilter (CD44B) shall not exceed 0.01 grains/scf outlet grain loading Combined emissions from the kiln/inline raw mill shall not exceed 20 percent opacity as measured by a Continuous Opacity Monitor on the main stack Emissions from the clinker cooler shall not exceed 10 percent opacity as measured by a Continuous Emissions Monitor on the common main stack Emissions from the kiln shall not exceed 20 percent opacity Emissions from the clinker cooler shall not exceed 10 percent opacity -Table continued on the next page-

Applicable Regulation 15A NCAC 2D .1111 40 CFR Part 63, Subpart LLL

15A NCAC 2D .0524 40 CFR Part 60, Subpart F 15A NCAC 2D .0530 PSD (BACT)

15A NCAC 2D .1111 40 CFR Part 63, Subpart LLL

15A NCAC 2D .0524 40 CFR Part 60, Subpart F

Review 07300R08 -Draft Revision 4, Page 35 The following provides a summary of limits and/or standards for the emission source(s) described above.

Regulated Pollutant Sulfur dioxide emissions

Dioxins and Furans

Mercury

Limits/Standards Combined emissions from the kiln/inline raw mill/clinker cooler/coal mill shall not exceed 1.33 lbs per ton of clinker, 30 day rolling average as measured by a Continuous Emissions Monitor Combined emissions from the kiln/inline raw mill/clinker cooler/coal mill shall not exceed 1.80 lbs per ton of clinker, maximum 24-hour rolling average as measured by a Continuous Emissions Monitor Combined emissions from the kiln/inline raw mill/clinker cooler/coal mill shall not exceed 8.7 x 10-11 gr per dscf on a dry basis, corrected to 7 percent oxygen, or 1.7 x 10-10 on a dry basis, corrected to 7 percent oxygen, when the average of the performance test run average temperature at the inlet to the particulate matter control device is 400 degrees F or less Combined emissions from the kiln/inline raw mill/clinker cooler/coal mill shall not exceed 0.720 lbs per day 41 µg per dscm on a dry basis, corrected to 7 percent oxygen

Applicable Regulation 15A NCAC 2D .0530 PSD (BACT)

15A NCAC 2D .1111 40 CFR Part 63, Subpart LLL

15A NCAC 2D .1100 15A NCAC 2D .1111 40 CFR Part 63, Subpart LLL

Nitrogen Dioxide

Total hydrocarbons (THC) Volatile organic compounds (VOCs) Carbon monoxide

Combined emissions from the kiln/inline raw mill/clinker cooler/coal mill shall not exceed 1.70 pounds per ton clinker, 30 day rolling average as measured by a Continuous Emissions Monitor 20 ppmv with hourly block averaging or demonstrate a 98 percent reduction of THC emissions from the exit of the kiln to discharge to the atmosphere, 30 day rolling average as measured by a Continuous Emission Monitor Good combustion practices and 0.16 pounds per ton of clinker, 30 day rolling average as measured by a Continuous Emissions Monitor Good combustion practices and 2.80 pounds per ton of clinker, 30 day rolling average as measured by a Continuous Emissions Monitor Modeled emission rates

Ammonia (State Enforceable Only, See Multiple Emissions Section VIIB) Benzene Fluorides Hydrogen chloride Formaldehyde Arsenic Beryllium Cadmium Chromium VI * Manganese Mercury * modeled against the AAL for bioavailabel chromate pigments

15A NCAC 2D .0530 PSD (BACT) 15A NCAC 2D .1111 40 CFR Part 63, Subpart LLL

15A NCAC 2D .0530 PSD (BACT) 15A NCAC 2D .0530 PSD (BACT) 15A NCAC 2D .1100

Review 07300R08 -Draft Revision 4, Page 36 a.

15A NCAC 2D .1111, 40 CFR Part 63, Subpart LLL “National Emissions Standards For Hazardous Air Pollutants From the Portland Cement Manufacturing Industry” • Kiln System (ID No. ES-KS) {Preheater/precalciner kiln (Coal-fired, petroleum coke, 675 million Btu per hour heat input)/in-line raw mill/clinker cooler with associated selective non-catalytic reduction (SNCR, CD44N), lime injection system (CD44S)} routed to bagfilter (CD44A), and the Coal Mill system (ID No. ES-COAL) routed to bagfilter (CD44B Amendments to Maximum Achievable Control Technology (MACT) standards, Subpart LLL were proposed in the Federal Register on May 6, 2009 for all affected facilities that are constructed after May 6, 2009. The Permittee shall comply with all applicable provisions contained in the final rule promulgated pursuant to the May 6, 2009 proposal {includes pollutants Mercury (Hg), total hydrocarbons (THC), particulate matter (PM), dioxins/furans (DF), and hydrochloric acid (HCl)}. i.

The Permittee shall comply with all applicable provisions, including the reporting, record keeping, and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D .1111 “Maximum Achievable Control Technology” (MACT) as promulgated in 40 CFR 63, Subpart LLL “National Emission Standards For Hazardous Air Pollutants From the Portland Cement Manufacturing Industry”, including Subpart A “General Provisions.

ii. PM Emission Standards for kiln/in-line raw mill and inline clinker cooler : • Emissions from the kiln/inline raw mill shall not exceed 0.30 pounds PM per ton of feed (on dry basis) to the kiln [40 CFR §63.1343(c)1)] • Emissions from the clinker cooler shall not exceed 0.10 pounds per ton of feed (on dry basis) to kiln 40 CFR §63.1345(a)(1)] Amendments to MACT Subpart LLL were proposed in the Federal Register by the EPA on May 6, 2009 for all affected facilities that are constructed after this date. The proposed MACT states in 40 CFR §63.1356 that “if an affected facility subject to this subpart has a different emissions limit or requirement for the same pollutant under another regulation in title 40 of this chapter, the owner or operator of the affected facility must comply with the most stringent emissions limit or requirement is exempt from the less stringent requirement.” The proposed MACT LLL has a PM standard for “new” kiln/inline raw mill systems of 0.08 lbs PM/ton of clinker). The EPA has also proposed an amendment to NSPS regulation Subpart F “Standards of Performance for Portland Cement Plants” that contains PM requirement for kilns built after June 18, 2008 of 0.086 lbs PM/ton clinker. In the case of these two standards, the MACT standard is more stringent. Upon the operation of this facility, Carolina Cement Company will have to comply with the most stringent final standards. At this time, the most stringent standard is 0.10 lbs per ton of feed (on a dry basis) to the kiln since the cooler is in-line to the kiln/the raw mill and they exit a common stack. From the application, the maximum feed input into the kiln = 420 tons per hour From the application, the maximum clinker output = 6000 tons per day (250 tons per hour) Allowable emissions (current MACT – kiln/inline raw mill): 0.30 lbs PM/ton feed x 420 tons feed/hr = 126 lbs PM/hour (552 tpy) Allowable emissions (current MACT – clinker cooler): 0.10 lbs PM/ton feed x 420 tons feed/hr = 42.0 lbs PM/hour (184 tpy) Allowable emissions (proposed MACT – kiln/inline raw mill): 0.08 lbs/ton clinker x 250 tons/hr = 20 lbs PM/hr (87.6 tpy) Allowable emissions (proposed MACT – kiln/inline raw mill/inline clinker cooler): inline kiln/raw mills that combine the clinker cooler exhaust with the kiln exhaust for energy efficiency purposes and send the combined exhausts to the PM control device as a single stream my meet an alternative PM emission limit. The limit is to be calculated using the following equation. PMalt = 0.0063 x 1.65 x (Qk + Qc)/7000

Equation 2

Review 07300R08 -Draft Revision 4, Page 37 Per the proposed MACT Subpart LLL (40 CFR §63.1356 “Sources with multiple emission limits or monitoring requirements”), Carolinas Cement Company, LLC will be required to use the more stringent “finalized” allowable emission rate upon startup that is listed under a Chapter 40 CFR regulation. The kiln system is controlled by a bagfilter (CD44A) with an outlet grain loading of 0.012 grains/scf that vents to the main stack. The Coal mill is controlled by a bagfilter with an outlet grain loading of 0.01 grains/scf that vents to the main stack. The airflow into bagfilter CD44A is approximately 645,000 acfm (total of 673,804 acfm – 30,000 acfm going to coal mill). In order to calculate the maximum design PM output from this each bagfilter, the following equation shall be used.

⎡T ACFM = SCFM × ⎢ actual ⎢⎣ TSTP Where: Tactual TSTP Pactual PSTP

⎤ ⎡ PSTP ⎤ ⎥ ⎥×⎢ ⎥⎦ ⎢⎣ Pactual ⎥⎦

= actual temperature at the outlet of the bagfilter (435 degree F) = standard temperature at the outlet of the bagfilter (68 degrees F) = actual pressure at the outlet of the bagfilter (14.7 psia or 407 inches W.C.) = standard pressure at the outlet of the bagfilter (14.7 psia or 407 inches W.C.)

Solve equation for SCF

⎡ TSTP ⎤ ⎡ PActual ⎤ ⎥×⎢ ⎥ ⎢⎣ T Actual ⎥⎦ ⎢⎣ PSTP ⎥⎦

SCFM = ACFM × ⎢

⎡ ( 460 + 68) STP ⎤ ⎡ ( 407 inches water column) Actual ⎤ = 380,514 SCFM ⎥×⎢ ⎥ ⎢⎣ ( 460 + 435) Actual ⎥⎦ ⎣⎢ (407 inches water column) STP ⎦⎥

SCFM = 645,000 ACFM × ⎢

Outlet grain loading for bagfilter = 0.012 grains/SCF Maximum PM (lbs / hr ) =

0.012 grains s tan dard cubic foot

×

380,514 s tan dard cubic feet min ute

×

60 min utes hour

×

1 lb 7000 grains

=

39.14 lbs hour

Since the proposed MACT has not been finalized as of the date of this review and the issuance of the Air permit, the clinker cooler limit of 0.10 lbs PM/ton of kiln feed (42.0 lbs PM10/hour) is the more stringent PM emissions limit from the main stack. Compliance is indicated since the potential emissions are less than the allowable emissions. The total emissions from the main stack are the combination of the PM from the kiln system and the coal mill. (39.14 lbs PM/hour + 1.52 lbs/hour (calculated in Section C. 2. a.) = 40.66 lbs/hour) iii.

Visible Emission Standard (kiln/in-line raw mill) [40 CFR §63.1343(c)(2)]: • Opacity – No more than 20 percent opacity from the main exhaust of the kiln/inline raw mill. Compliance will be indicated using a Continuous Opacity Monitor.

Review 07300R08 -Draft Revision 4, Page 38 iv.

Dioxins and Furans Emission Standard (kiln/in-line raw mill) [40 CFR §63.1343(c)(3)]: • No more than 8.7 x 10-11 gr per dscf (TEQ) on a dry basis, corrected to 7 percent oxygen, or 1.7 x 10-10 gr per dscf (TEQ) on a dry basis, corrected to 7 percent oxygen, when the average of the performance test run average temperature at the inlet to the particulate matter control device is 400 degrees F Hydrocarbons (THC) from the main exhaust of the kiln/inline raw mill.

v.

Total Hydrocarbon Emission Standard (kiln/in-line raw mill) [40 CFR §63.1343(c)(4)]: • No more than 20 ppmv total hydrocarbon emission from the exhaust of the kiln/inline raw mill. As an alternative to meeting the 20 ppmv standard, the facility may demonstrate a 98 percent reduction of THC emission from the exit of the kiln to discharge to the atmosphere.

vi.

Mercury Emission Standard (kiln/in-line raw mill) [40 CFR §63.1343(c)(5)]: • No more than 41 µg/dscm from the exhaust of the kiln/inline raw mill. As an alternative to meeting the 41 µg/dscm, the facility can route the emissions through a packed bed or spray tower wet scrubber with a liquid-to-gas (l/g) ratio of 30 gallon per 1000 actual cubic feet per minute (acfm) or more and meet a site-specific emissions limit based on the measured performance of the wet scrubber. The applicant has not requested the alternative method of compliance. Note: Amendments to MACT Subpart LLL were proposed in the Federal Register by the EPA on May 6, 2009 for all affected facilities that are constructed after this date. A lower mercury emission rate was proposed. Upon the final issuance of the proposed MACT listed in Subpart LLL, Carolina Cement will be required to meet the most stringent requirements that are applicable for mercury emissions from Portland Cement Plants. The mercury emissions that will be emitted from the kiln System {Preheater/precalciner kiln/in-line raw mill/in-line clinker cooler} will come from three sources, the coal/pet coke, the raw material from the mine, and the flyash/bottom ash used in the process. (Flyash is added in the “Raw Material Proportioning, Blending, and Grinding Process”). In accordance with 40 CFR 63, Subpart LLL: No kiln and in-line kiln/raw mill may use as a raw material or fuel any fly ash where the mercury content of the fly ash has been increased through the use of activated carbon, or any other sorbent unless the facility can demonstrate that the use of that fly ash will not result in an increase in mercury emissions over baseline emissions (i.e. emissions not using the fly ash). The facility has the burden of proving there has been no emissions increase over baseline. [40 CFR §63.1344(g)] For kilns and in-line kilns/raw mills complying with the requirements in Section 63.1344(g), each owner or operator must obtain a certification from the supplier for each shipment of fly ash received to demonstrate that the fly ash was not derived from a source in which the use of activated carbon, or any other sorbent, is used as a method of mercury emissions control. The certification shall include the name of the supplier and a signed statement from the supplier confirming that the fly ash was not derived from a source in which the use of activated carbon, or any other sorbent, is used as a method of emission control. [40 CFR §63.1344(g)] If the facility opts to use a fly ash derived from a source in which the use of activated carbon, or any other sorbent, is used as a method of mercury emissions control and demonstrate that the use of this fly ash does not increase mercury emissions, they must obtain daily fly ash samples, composites monthly, and analyze the samples for mercury. [40 CFR §63.1350(o)] Carolina Cement Company, LLC performed site-specific sampling of the raw material at the proposed site during the initial stages of modeling. The samples ranged in mercury content from 1 part per billion (ppb) to 14 ppb. The higher limit was used for the following calculation.

Review 07300R08 -Draft Revision 4, Page 39 Maximum raw material input rate into kiln = 3,677,010 tons feed per year (from application) 3, 677 ,010 tons raw mat ' l

year

×

2000 lbs raw mat ' l

tons raw mat ' l

×

14 lbs Hg 1 × 109 lbs raw mat ' l

=

102.96 lb Hg

year

( from raw material )

The following calculations were used to estimate the mercury content from coal that will be used at the Cement Carolinas Portland Cement Plant. These values were obtained from data that was used for the Sutton coal-fired power plant.

LV Sutton lbs Hg/hour

µg Hg/dscm @ 7% O2

Mean

lbs Hg/trillion Btu 7.41

0.005002

8.07

95%

10.02

0.006764

10.91

Max

10.93

0.007378

11.91

10.93 lbs Hg 1 × 1012

6 675 × 10 Btu

×

hour

×

8760 hours

year

=

64.6 lb Hg

year

( from coal )

From the application (page 17 of 48, Tab C, “Plantwide Potential Emissions Inventory”), the mercury content in the bottom ash was listed as 0.24 ppm. The tons of fly ash/bottom ash used per year for this plant = 332,633 tons per year (page 6 of 48, Tab C, “Plantwide Potential Emissions Inventory”). 332,633 tons ash

year

×

0.24 tons Hg 1 × 106 tons ash

×

2000 lbs Hg 1 ton Hg

=

159.66 lbs Hg

year

( from bottom ash / flyash )

The total calculated mercury emissions using the most conservative values = (102.96 + 64.6 + 159.66 = 327.22 lbs per year). The applicant estimates that the Carolinas Cement Company will emit 263 lbs per year or mercury. The DAQ feels that the bagfilter will have a capture efficiency of at least 20%, thereby reducing the calculated amount (327.22 x (1- 0.20) = 261.8 lbs Hg/year to less than the estimated amount of the applicant. Mercury emission rate compliance with MACT, Subpart LLL allowable emission rate of 41 µg/dscm. The following spreadsheet calculations were submitted by the applicant.

Gas Conditions Raw Mill On

Value 689,272 195 555,627 15.6 468,949 12.2 293,515 498,685

Units ACFM deg F WSCFM %Moisture DSCFM %O2 DSCFM @ 7% O2 DSCM/H @7% O2

Raw Mill Off

-Table continued on the next page-

Value 629,307 372 399,368 15.6 337,067 12.2 210,970 358,440

Units ACFM deg F WSCFM %M DSCFM %O2 DSCFM @ 7% O2 DSCM/H @7% O2

Review 07300R08 -Draft Revision 4, Page 40

Raw Mill Value Mercury (Hg) Limit =

41

ER =

0.03 262.8 13.61

Conc = Conc =

Units Raw Mill

Value

Units

ug/dscm @ 7% O2 lb/hr Hg lb/yr Hg g/hr Hg

27.3 ug/dscm @ 7% O2 38.0 ug/dscm @ 7% O2

Raw Mill On Raw Mill Off

(Pass) (Pass)

Calculations for the worse case condition (mill off)

⎡ TSTP ⎤ ⎡ PActual ⎤ ⎥×⎢ ⎥ ⎢⎣ T Actual ⎥⎦ ⎢⎣ PSTP ⎥⎦

SCFM = ACFM × ⎢

⎡ ( 460 + 68) STP ⎤ ⎡ ( 407 inches water column) Actual ⎤ = 399,368 scfm ⎥×⎢ ⎥ ⎣⎢ ( 460 + 372) Actual ⎦⎥ ⎣⎢ ( 407 inches water column) STP ⎦⎥

scfm = 629,307 acfm × ⎢

Moisture correction 399,368 s tan dard cubic feet min ute

×

(100 − 15.6) 100

=

337 ,067 dscf min ute

Oxygen correction 337,067 dry s tan dard cubic feet min ute

×

( 20.9% − 12.2% O ) 210,970 dscf 2 = min ute ( 20.9% − 7.0% O ) 2

Convert to meters 210,970 dry s tan dard cubic feet min ute

×

60 min utes

hour

×

1 m3 (3.28084 ft )3

=

358, 440 dscm

hour

Convert dscf flowrate to ug/dscm @ 7% O using the mercury emission rate of 262.8 lbs/year 262.8 lbsHg

year

×

1 year 8760 hours

×

453.59 gram 1 lb

×

1 × 106 microgram

gram

×

1 358, 440 dscm

=

38 micrograms

dscm

Compliance with the mercury allowable limit (41 micrograms per dscm or less) is indicated.

( mill off condition )

Review 07300R08 -Draft Revision 4, Page 41 vii.

Performance Testing Requirement [40 CFR §63.1349] (A) The owner or operator of an affected source subject to this subpart shall demonstrate initial compliance with the emission limits of §63.1343 and §§63.1345 through 63.1348 using the test methods and procedures in paragraph (b) of this section and §63.7. Performance test results shall be documented in complete test reports that contain the information required by paragraphs (a)(1) through (a)(10) of this section, as well as all other relevant information. The plan to be followed during testing shall be made available to the Administrator prior to testing, if requested. (1) A brief description of the process and the air pollution control system; (2) Sampling location description(s); (3) A description of sampling and analytical procedures and any modifications to standard procedures; (4) Test results; (5) Quality assurance procedures and results; (6) Records of operating conditions during the test, preparation of standards, and calibration procedures; (7) Raw data sheets for field sampling and field and laboratory analyses; (8) Documentation of calculations; (9) All data recorded and used to establish parameters for compliance monitoring; and (10) Any other information required by the test method. (B) Performance tests to demonstrate initial compliance with Subpart LLL shall be conducted. (1) The owner or operator of an in-line kiln/raw mill subject to limitations on particulate matter emissions shall demonstrate initial compliance by conducting separate performance tests as specified in §63.1349(b)(1)(i) through (b)(1)(iv) while the raw mill of the in-line kiln/raw mill is under normal operating conditions and while the raw mill of the in-line kiln/raw mill is not operating. The owner or operator of a clinker cooler subject to limitations on particulate matter emissions shall demonstrate initial compliance by conducting a performance test as specified in paragraphs §63.1349 (b)(1)(i) through (b)(1)(iii). The opacity exhibited during the period of the Method 5 of Appendix A to Part 60 of this chapter performance tests required by paragraph §63.1349 (b)(1)(i) shall be determined as required in paragraphs §63.1349 (b)(1)(v) through (vi). (a) Method 5 of appendix A to Part 60 of Subpart LLL shall be used to determine PM emissions. Each performance test shall consist of three separate runs under the conditions that exist when the affected source is operating at the representative performance conditions in accordance with §63.7(e). Each run shall be conducted for at least 1 hour, and the minimum sample volume shall be 0.85 dscm (30 dscf). The average of the three runs shall be used to determine compliance. A determination of the PM collected in the impingers (“back half”) of the Method 5 particulate sampling train is not required to demonstrate initial compliance with the PM standards of this subpart. However, this shall not preclude the permitting authority from requiring a determination of the “back half” for other purposes. (b) Suitable methods shall be used to determine the kiln or inline kiln/raw mill feed rate, except for fuels, for each run. (c) The emission rate, E, of PM shall be computed for each run using equation 1:

⎛ C s Qsd ⎞ ⎟⎟ P ⎠ ⎝

E = ⎜⎜

(Eq. 1)

Where: E = emission rate of particulate matter, kg/Mg of kiln feed. cs = concentration of PM, kg/dscm. Qsd = volumetric flow rate of effluent gas, dscm/hr. P = total kiln feed (dry basis), Mg/hr.

Review 07300R08 -Draft Revision 4, Page 42

(d) Except as provided in §63.1349(b)(1)(vi), the opacity exhibited during the period of the Method 5 performance tests required by §63.1349 (b)(1)(i) shall be determined through the use of a continuous opacity monitor (COM). The maximum six-minute average opacity during the three Method 5 test runs shall be determined during each Method 5 test run, and used to demonstrate initial compliance with the applicable opacity limits of §63.1343(b)(2), §63.1343(c)(2), or §63.1345(a)(2). (2)

The owner or operator of an affected source subject to limitations on D/F emissions under this subpart shall demonstrate initial compliance with the D/F emission limit by conducting a performance test using Method 23 of appendix A to part 60 of this chapter. The owner or operator of an in-line kiln/raw mill shall demonstrate initial compliance by conducting separate performance tests while the raw mill of the in-line kiln/raw mill is under normal operating conditions and while the raw mill of the in-line kiln/raw mill is not operating. (a) Each performance test shall consist of three separate runs; each run shall be conducted under the conditions that exist when the affected source is operating at the representative performance conditions in accordance with §63.7(e). The duration of each run shall be at least 3 hours, and the sample volume for each run shall be at least 2.5 dscm (90 dscf). The concentration shall be determined for each run, and the arithmetic average of the concentrations measured for the three runs shall be calculated and used to determine compliance. (b) The temperature at the inlet to the kiln or in-line kiln/raw mill PMCD, and where applicable, the temperature at the inlet to the alkali bypass PMCD, must be continuously recorded during the period of the Method 23 test, and the continuous temperature record(s) must be included in the performance test report. (c) One-minute average temperatures must be calculated for each minute of each run of the test. (d) The run average temperature must be calculated for each run, and the average of the run average temperatures must be determined and included in the performance test report and will determine the applicable temperature limit in accordance with §63.1344(b). (e) If activated carbon injection is used for D/F control, the rate of activated carbon injection to the kiln or in-line kiln/raw mill exhaust, and where applicable, the rate of activated carbon injection to the alkali bypass exhaust, must be continuously recorded during the period of the Method 23 test, and the continuous injection rate record(s) must be included in the performance test report. In addition, the performance test report must include the brand and type of activated carbon used during the performance test and a continuous record of either the carrier gas flow rate or the carrier gas pressure drop for the duration of the test. Activated carbon injection rate parameters must be determined in accordance with paragraphs (b)(3)(vi) of this section. (f) The run average injection rate must be calculated for each run, and the average of the run average injection rates must be determined and included in the performance test report and will determine the applicable injection rate limit in accordance with §63.1344(c)(1).

(3) (a)

The owner or operator of an affected source subject to limitations on emissions of THC shall demonstrate initial compliance with the THC limit by operating a continuous emission monitor in accordance with Performance Specification 8A of appendix B to part 60 of this chapter. The duration of the performance test shall be three hours, and the average THC concentration (as calculated from the one-minute averages) during the threehour performance test shall be calculated. The owner or operator of an in-line kiln/raw mill shall demonstrate initial compliance by conducting separate performance tests while the raw mill of the in-line kiln/raw mill is under normal operating conditions and while the raw mill of the in-line kiln/raw mill is not operating.

Review 07300R08 -Draft Revision 4, Page 43 (b) The owner or operator of an affected source subject to limitations on emissions of THC who elects to demonstrate compliance with the alternative THC emission limit of 98 percent weight reduction must demonstrate compliance by also operating a continuous emission monitor in accordance with Performance Specification 8A of appendix B to part 60 at the inlet to the THC control device of the kiln, inline kiln raw mill, or raw materials dryer in the same manner as prescribed in paragraph (i) above. Alternately, you may elect to demonstrate a 98 weight percent reduction in THC across the control device using the performance test requirements in 40 CFR part 63, subpart SS. (4) The owner or operator of a kiln or in-line kiln/raw mill subject to the 41 µg/dscm mercury standard shall demonstrate compliance using EPA Method 29 of 40 CFR part 60. ASTM D6784–02, Standard Test Method for Elemental, Oxidized, Particle-Bound and Total Mercury Gas Generated from Coal-Fired Stationary Sources (Ontario Hydro Method), is an acceptable alternative to EPA Method 29 (portion for mercury only). If the kiln has an in-line raw mill, you must demonstrate compliance with both raw mill off and raw mill on. You must record the hourly recycle rate of CKD during both test conditions and calculate an average hourly rate for the three test runs for each test condition. (C) Except as provided in section §63.1349(e), performance tests required under paragraphs (b)(1) and (b)(2) of this section shall be repeated every five years, except that the owner or operator of a kiln, in-line kiln/raw mill or clinker cooler is not required to repeat the initial performance test of opacity for the kiln, in-line kiln/raw mill or clinker cooler. (D) Performance tests required under paragraph (b)(3) of this section shall be repeated every 30 months. (E) (1) If a source plans to undertake a change in operations that may adversely affect compliance with an applicable D/F standard under this subpart, the source must conduct a performance test and establish new temperature limit(s) as specified in paragraph (b)(3) of this section. (2) If a source plans to undertake a change in operations that may adversely affect compliance with an applicable PM standard under §63.1343, the source must conduct a performance test as specified in paragraph (b)(1) of this section. (3) In preparation for and while conducting a performance test required in paragraph (e)(1) of this section, a source may operate under the planned operational change conditions for a period not to exceed 360 hours, provided that the conditions in paragraphs (e)(3)(i) through (iv) of this section are met. The source shall submit temperature and other monitoring data that are recorded during the pretest operations. (a) The source must provide the Administrator written notice at least 60 days prior to undertaking an operational change that may adversely affect compliance with an applicable standard under this subpart, or as soon as practicable where 60 days advance notice is not feasible. Notice provided under this paragraph shall include a description of the planned change, the emissions standards that may be affected by the change, and a schedule for completion of the performance test required under paragraph (e)(1) of this section, including when the planned operational change period would begin. (b) The performance test results must be documented in a test report according to paragraph (a) of this section. (c) A test plan must be made available to the Administrator prior to testing, if requested. (d) The performance test must be conducted, and it must be completed within 360 hours after the planned operational change period begins. ix.

Monitoring Requirements [40 CFR §63.1350] (A) The owner or operator of each Portland Cement plant shall prepare for each affected source subject to the provisions of this subpart, a written operations and maintenance plan. The plan shall be submitted to the Administrator for review and approval as part of the application for a part 70 permit and shall include the following information: (1) Procedures for proper operation and maintenance of the affected source and air pollution control devices in order to meet the emission limits and operating limits of §§63.1343 through 63.1348;

Review 07300R08 -Draft Revision 4, Page 44 (2) Corrective actions to be taken when required by paragraph (e) of this section; (3) Procedures to be used during an inspection of the components of the combustion system of each kiln and each in-line kiln raw mill located at the facility at least once per year; and (4) Procedures to be used to periodically monitor affected sources subject to opacity standards under §§63.1346 and 63.1348. Such procedures must include the provisions of paragraphs (a)(4)(i) through (a)(4)(iv) of §63.1350. (a) The owner or operator must conduct a monthly 1-minute visible emissions test of each affected source in accordance with Method 22 of Appendix A to Part 60 of this chapter. The test must be conducted while the affected source is in operation. (b) If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner or operator may decrease the frequency of testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semiannual test, the owner or operator must resume testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (c) If no visible emissions are observed during the semi-annual test for any affected source, the owner or operator may decrease the frequency of testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual test, the owner or operator must resume testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (d) If visible emissions are observed during any Method 22 test, the owner or operator must conduct a 6-minute test of opacity in accordance with Method 9 of appendix A to part 60 of this chapter. The Method 9 test must begin within one hour of any observation of visible emissions. (e) The requirement to conduct Method 22 visible emissions monitoring under this paragraph shall not apply to any totally enclosed conveying system transfer point, regardless of the location of the transfer point. “Totally enclosed conveying system transfer point” shall mean a conveying system transfer point that is enclosed on all sides, top, and bottom. The enclosures for these transfer points shall be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. (e) If any partially enclosed or unenclosed conveying system transfer point is located in a building, the owner or operator of the Portland Cement plant shall have the option to conduct a Method 22 visible emissions monitoring test according to the requirements of §63.1350 (a)(4)(i) through (iv) for each such conveying system transfer point located within the building, or for the building itself, according to paragraph (a)(4)(vii) of this section. (f) If visible emissions from a building are monitored, the requirements of §63.1350 (a)(4)(i) through (iv) apply to the monitoring of the building, and you must also test visible emissions from each side, roof and vent of the building for at least 1 minute. The test must be conducted under normal operating conditions. (A) Failure to comply with any provision of the operations and maintenance plan developed in accordance with paragraph (a) of this section shall be a violation of the standard. (B) The owner or operator of a kiln or in-line kiln/raw mill shall monitor opacity at each point where emissions are vented from these affected sources including alkali bypasses in accordance with §63.1350 (c)(1) through (c)(3). (1) Except as provided in §63.1350 (c)(2), the owner or operator shall install, calibrate, maintain, and continuously operate a continuous opacity monitor (COM) located at the outlet of the PM control device to continuously monitor the opacity. The COM shall be installed, maintained, calibrated, and operated as required by subpart A, general provisions of this part, and according to PS–1 of appendix B to Part 60. (2) To remain in compliance, the opacity must be maintained such that the 6-minute average opacity for any 6-minute block period does not exceed 20 percent. If the average opacity for any 6minute block period exceeds 20 percent, this shall constitute a violation of the standard.

Review 07300R08 -Draft Revision 4, Page 45 (C) The owner or operator of a clinker cooler shall monitor opacity at each point where emissions are vented from the clinker cooler in accordance with §§63.1350 (d)(1) through (d)(3). (1) Except as provided in paragraph (d)(2) of this section, the owner or operator shall install, calibrate, maintain, and continuously operate a COM located at the outlet of the clinker cooler PM control device to continuously monitor the opacity. The COM shall be installed, maintained, calibrated, and operated as required by subpart A, general provisions of this part, and according to PS–1 of appendix B to part 60 of this chapter. (2) To remain in compliance, the opacity must be maintained such that the 6-minute average opacity for any 6-minute block period does not exceed 10 percent. If the average opacity for any 6minute block period exceeds 10 percent, this shall constitute a violation of the standard. (D) The owner or operator of an affected source subject to a limitation on D/F emissions shall monitor D/F emissions in accordance with paragraphs (f)(1) through (f)(6) of this section. (1) The owner or operator shall install, calibrate, maintain, and continuously operate a continuous monitor to record the temperature of the exhaust gases from the kiln, in-line kiln/raw mill and alkali bypass, if applicable, at the inlet to, or upstream of, the kiln, in-line kiln/raw mill and/or alkali bypass PM control devices. (a) The recorder response range must include zero and 1.5 times either of the average temperatures established according to the requirements in §63.1349(b)(3)(iv). (b) The reference method must be a National Institute of Standards and Technology calibrated reference thermocouple-potentiometer system or alternate reference, subject to approval by the Administrator. (2) The owner or operator shall monitor and continuously record the temperature of the exhaust gases from the kiln, in-line kiln/raw mill and alkali bypass, if applicable, at the inlet to the kiln, in-line kiln/raw mill and/or alkali bypass PMCD. (3) The three-hour rolling average temperature shall be calculated as the average of 180 successive one-minute average temperatures. (4) Periods of time when one-minute averages are not available shall be ignored when calculating three-hour rolling averages. When one-minute averages become available, the first one-minute average is added to the previous 179 values to calculate the three-hour rolling average. (5) When the operating status of the raw mill of the in-line kiln/raw mill is changed from off to on, or from on to off the calculation of the three-hour rolling average temperature must begin anew, without considering previous recordings. (5) The calibration of all thermocouples and other temperature sensors shall be verified at least once every three months. (E) The owner or operator of an affected source subject to an emissions limitation on D/F, THC or mercury emissions that employs carbon injection as an emission control technique shall comply with the monitoring requirements of §§63.1350 (f)(1) through (f)(6) and (g)(1) through (g)(6) to demonstrate continuous compliance with the D/F, THC or mercury emissions standard. (1) Install, operate, calibrate and maintain a continuous monitor to record the rate of activated carbon injection. The accuracy of the rate measurement device must be ±1 percent of the rate being measured. (2) Verify the calibration of the device at least once every three months. (3) The three-hour rolling average activated carbon injection rate shall be calculated as the average of 180 successive one-minute average activated carbon injection rates. (4) Periods of time when one-minute averages are not available shall be ignored when calculating three-hour rolling averages. When one-minute averages become available, the first one-minute average is added to the previous 179 values to calculate the three-hour rolling average. (5) When the operating status of the raw mill of the in-line kiln/raw mill is changed from off to on, or from on to off, the calculation of the three-hour rolling average activated carbon injection rate must begin anew, without considering previous recordings. (6) The owner or operator must install, operate, calibrate and maintain a continuous monitor to record the activated carbon injection system carrier gas parameter (either the carrier gas flow rate or the carrier gas pressure drop) established during the mercury, THC or D/F performance test in accordance with §§63.1350 (g)(6)(i) through (g)(6)(iii).

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(a) The owner or operator shall install, calibrate, operate and maintain a device to continuously monitor and record the parameter value. (b) The owner or operator must calculate and record three-hour rolling averages of the parameter value. (c) Periods of time when one-minute averages are not available shall be ignored when calculating three-hour rolling averages. When one-minute averages become available, the first one-minute average shall be added to the previous 179 values to calculate the threehour rolling average. (F) The owner or operator of an affected source subject to a limitation on THC emissions under this subpart shall comply with the monitoring requirements of §§63.1350 (h)(1) through (h)(3) to demonstrate continuous compliance with the THC emission standard: (1) The owner or operator shall install, operate and maintain a THC continuous emission monitoring system in accordance with Performance Specification 8A, of appendix B to part 60 of this chapter and comply with all of the requirements for continuous monitoring systems found in the general provisions, subpart A of this part. (2) For new facilities complying with the 20 ppmv THC emissions limit, any hourly average THC concentration in any gas discharged from a raw material dryer, the main exhaust of a greenfield kiln, or the main exhaust of a kiln or in-line kiln/raw mill, exceeding 20 ppmvd, reported as propane, corrected to seven percent oxygen, is a violation of the standard. (G) The owner or operator of any kiln or in-line kiln/raw mill subject to a D/F emission limit under this subpart shall conduct an inspection of the components of the combustion system of each kiln or in-line kiln raw mill at least once per year. (H) The owner or operator of an affected source subject to a particulate matter standard under §63.1343 shall install, calibrate, maintain, and operate a particulate matter continuous emission monitoring system (PM CEMS) to measure the particulate matter discharged to the atmosphere. All requirements relating to installation, calibration, maintenance, operation or performance of the PM CEMS and implementation of the PM CEMS requirement are deferred pending further rulemaking. (I) An owner or operator may submit an application to the Administrator for approval of alternate monitoring requirements to demonstrate compliance with the emission standards of this subpart, except for emission standards for THC, subject to the provisions of paragraphs (l)(1) through (l)(6) of this section. (1) The Administrator will not approve averaging periods other than those specified in this section, unless the owner or operator documents, using data or information, that the longer averaging period will ensure that emissions do not exceed levels achieved during the performance test over any increment of time equivalent to the time required to conduct three runs of the performance test. (2) If the application to use an alternate monitoring requirement is approved, the owner or operator must continue to use the original monitoring requirement until approval is received to use another monitoring requirement. (3) The owner or operator shall submit the application for approval of alternate monitoring requirements no later than the notification of performance test. The application must contain the information specified in §§63.1350 (l)(3)(i) through (l)(3)(iii) (a) Data or information justifying the request, such as the technical or economic infeasibility, or the impracticality of using the required approach; (b) A description of the proposed alternative monitoring requirement, including the operating parameter to be monitored, the monitoring approach and technique, the averaging period for the limit, and how the limit is to be calculated; and (d) Data or information documenting that the alternative monitoring requirement would provide equivalent or better assurance of compliance with the relevant emission standard.

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(4) The Administrator will notify the owner or operator of the approval or denial of the application within 90 calendar days after receipt of the original request, or within 60 calendar days of the receipt of any supplementary information, whichever is later. The Administrator will not approve an alternate monitoring application unless it would provide equivalent or better assurance of compliance with the relevant emission standard. Before disapproving any alternate monitoring application, the Administrator will provide: (a) Notice of the information and findings upon which the intended disapproval is based; and (b) Notice of opportunity for the owner or operator to present additional supporting information before final action is taken on the application. This notice will specify how much additional time is allowed for the owner or operator to provide additional supporting information. (5) The owner or operator is responsible for submitting any supporting information in a timely manner to enable the Administrator to consider the application prior to the performance test. Neither submittal of an application, nor the Administrator's failure to approve or disapprove the application relieves the owner or operator of the responsibility to comply with any provision of this subpart. (6) The Administrator may decide at any time, on a case-by-case basis that additional or alternative operating limits, or alternative approaches to establishing operating limits, are necessary to demonstrate compliance with the emission standards of this subpart. (J) The requirements under paragraph (e) of this section to conduct daily Method 22 testing shall not apply to any specific raw mill or finish mill equipped with a continuous opacity monitor COM or bag leak detection system (BLDS). If the owner or operator chooses to install a COM in lieu of conducting the daily visual emissions testing required under paragraph (e) of this section, then the COM must be installed at the outlet of the PM control device of the raw mill or finish mill, and the COM must be installed, maintained, calibrated, and operated as required by the general provisions in subpart A of this part and according to PS–1 of appendix B to part 60 of this chapter. To remain in compliance, the opacity must be maintained such that the 6-minute average opacity for any 6minute block period does not exceed 10 percent. If the average opacity for any 6-minute block period exceeds 10 percent, this shall constitute a violation of the standard. If the owner or operator chooses to install a BLDS in lieu of conducting the daily visual emissions testing required under §63.1350(e), the requirements in §§63.1350(m)(1) through (9) apply to each BLDS: (1) The BLDS must be certified by the manufacturer to be capable of detecting PM emissions at concentrations of 10 milligrams per actual cubic meter (0.0044 grains per actual cubic foot) or less. “Certify” shall mean that the instrument manufacturer has tested the instrument on gas streams having a range of particle size distributions and confirmed by means of valid filterable PM tests that the minimum detectable concentration limit is at or below 10 milligrams per actual cubic meter (0.0044 grains per actual cubic foot) or less. (2) The sensor on the BLDS must provide output of relative PM emissions. (3) The BLDS must have an alarm that will activate automatically when it detects a significant increase in relative PM emissions greater than a preset level. (4) The presence of an alarm condition should be clearly apparent to facility operating personnel. (5) For a positive-pressure fabric filter, each compartment or cell must have a bag leak detector. For a negative-pressure or induced-air fabric filter, the bag leak detector must be installed downstream of the fabric filter. If multiple bag leak detectors are required (for either type of fabric filter), detectors may share the system instrumentation and alarm. (6) All BLDS must be installed, operated, adjusted, and maintained so that they are based on the manufacturer's written specifications and recommendations. The EPA recommends that where appropriate, the standard operating procedures manual for each bag leak detection system include concepts from EPA's “Fabric Filter Bag Leak Detection Guidance” (EPA–454/R–98– 015, September 1997). (7) The baseline output of the system must be established as follows:(i) Adjust the range and the averaging period of the device; and(ii) Establish the alarm set points and the alarm delay time.

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(8) After initial adjustment, the range, averaging period, alarm set points, or alarm delay time may not be adjusted except as specified in the operations and maintenance plan required by paragraph (a) of this section. In no event may the range be increased by more than 100 percent or decreased by more than 50 percent over a 1 calendar year period unless a responsible official as defined in §63.2 certifies in writing to the Administrator that the fabric filter has been inspected and found to be in good operating condition. (9) The owner or operator must maintain and operate the fabric filter such that the bag leak detector alarm is not activated and alarm condition does not exist for more than 5 percent of the total operating time in a 6-month block period. Each time the alarm activates, alarm time will be counted as the actual amount of time taken by the owner or operator to initiate corrective actions. If inspection of the fabric filter demonstrates that no corrective actions are necessary, no alarm time will be counted. The owner or operator must continuously record the output from the BLDS during periods of normal operation. Normal operation does not include periods when the BLDS is being maintained or during startup, shutdown or malfunction. (K) Any kiln or kiln/in-line raw mill using a control device (other then ACI) to comply with a mercury emissions limit or equipment standard will monitor the control device parameters as specified in 40 CFR part 63 subpart SS. (L) For kilns and in-line kilns/raw mills complying with the requirements in §63.1350 63.1344(g), each owner or operator must obtain a certification from the supplier for each shipment of fly ash received to demonstrate that the fly ash was not derived from a source in which the use of activated carbon, or any other sorbent, is used as a method of mercury emissions control. The certification shall include the name of the supplier and a signed statement from the supplier confirming that the fly ash was not derived from a source in which the use of activated carbon, or any other sorbent, is used as a method of emission control. (M) If the facility opts to use a fly ash derived from a source in which the use of activated carbon, or any other sorbent, is used as a method of mercury emissions control and demonstrate that the use of this fly ash does not increase mercury emissions, they must obtain daily fly ash samples, composites monthly, and analyze the samples for mercury. x.

Reporting [40 CFR §63.1354] (A) The reporting provisions of Subpart A of 40 CFR Part 63, Subpart LLL that apply and those that do not apply to owners or operators of affected sources subject to this Subpart are listed in Table 1 of 40 CFR Part 63, Subpart LLL. If any State requires a report that contains all of the information required in a report listed in this section, the owner or operator may send the Administrator a copy of the report sent to the State to satisfy the requirements of this section for that report. (B) The owner or operator of an affected source shall comply with the reporting requirements specified in 40 CFR §63.10 of the general provisions of this Part 63, Subpart A as follows: (1) As required by 40 CFR §63.10(d)(2), the owner or operator shall report the results of performance tests as part of the notification of compliance status. (2) As required by 40 CFR §63.10(d)(3), the owner or operator of an affected source shall report the opacity results from tests required by 40 CFR §63.1349. (3) As required by 40 CFR §63.10(d)(4), the owner or operator of an affected source who is required to submit progress reports as a condition of receiving an extension of compliance under 40 CFR §63.6(i) shall submit such reports by the dates specified in the written extension of compliance. (4) As required by 40 CFR §63.10(d)(5), if actions taken by an owner or operator during a startup, shutdown, or malfunction of an affected source (including actions taken to correct a malfunction) are consistent with the procedures specified in the source's startup, shutdown, and malfunction plan specified in 40 CFR §63.6(e)(3), the owner or operator shall state such information in a semiannual report. Reports shall only be required if a startup, shutdown, or malfunction occurred during the reporting period. The startup, shutdown, and malfunction report may be submitted simultaneously with the excess emissions and continuous monitoring system performance reports; and

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(5)

(6)

(7)

(8)

(9)

xi.

Any time an action taken by an owner or operator during a startup, shutdown, or malfunction (including actions taken to correct a malfunction) is not consistent with the procedures in the startup, shutdown, and malfunction plan, the owner or operator shall make an immediate report of the actions taken for that event within 2 working days, by telephone call or facsimile (FAX) transmission. The immediate report shall be followed by a letter, certified by the owner or operator or other responsible official, explaining the circumstances of the event, the reasons for not following the startup, shutdown, and malfunction plan, and whether any excess emissions and/or parameter monitoring exceedances are believed to have occurred. As required by 40 CFR §63.10(e)(2), the owner or operator shall submit a written report of the results of the performance evaluation for the continuous monitoring system required by 40 CFR §63.8(e). The owner or operator shall submit the report simultaneously with the results of the performance test. As required by 40 CFR §63.10(e)(2), the owner or operator of an affected source using a continuous opacity monitoring system to determine opacity compliance during any performance test required under 40CFR §63.7 and described in 40 CFR §63.6(d)(6) shall report the results of the continuous opacity monitoring system performance evaluation conducted under 40 CFR §63.8(e). As required by 40 CFR §63.10(e)(3), the owner or operator of an affected source equipped with a continuous emission monitor shall submit an excess emissions and continuous monitoring system performance report for any event when the continuous monitoring system data indicate the source is not in compliance with the applicable emission limitation or operating parameter limit. The owner or operator shall submit a summary report semi-annually which contains the information specified in 40 CFR §63.10(e)(3)(vi). In addition, the summary report shall include: (a) All exceedences of maximum control device inlet gas temperature limits specified in 40 CFR §63.1344(a) and (b); (b) All failures to calibrate thermocouples and other temperature sensors as required under 40 CFR §63.1350(f)(7) of this subpart; and (c) All failures to maintain the activated carbon injection rate, and the activated carbon injection carrier gas flow rate or pressure drop, as applicable, as required under 40 CFR §63.1344(c). (d) The results of any combustion system component inspections conducted within the reporting period as required under 40 CFR §63.1350(i). (e) All failures to comply with any provision of the operation and maintenance plan developed in accordance with 40 CFR §63.1350(a).

Recordkeeping Requirements [40 CFR §63.1355] (A) The owner or operator shall maintain files of all information (including all reports and notifications) required by this section recorded in a form suitable and readily available for inspection and review as required by 40 CFR §63.10(b)(1). The files shall be retained for at least five years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. At a minimum, the most recent two years of data shall be retained on site. The remaining three years of data may be retained off site. The files may be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche. (B) The owner or operator shall maintain records for each affected source as required by 40 CFR §63.10(b)(2) and (b)(3) of this part; and (1) All documentation supporting initial notifications and notifications of compliance status under 40 CFR §63.9; (2) All records of applicability determination, including supporting analyses; and (3) If the owner or operator has been granted a waiver under 40 CFR §63.8(f)(6), any information demonstrating whether a source is meeting the requirements for a waiver of recordkeeping or reporting requirements.

Review 07300R08 -Draft Revision 4, Page 50 b. 15A NCAC 2D .0516 “SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES” i. Emissions of sulfur dioxide from the preheater-precalciner/kiln system shall not exceed 2.3 pounds per million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels, wastes, ores, and other substances shall be included when determining compliance with this standard. [15A NCAC 2D .0516] The maximum Btu rating of the kiln is 675 million Btu per hour heat input Allowable SO2 = 2.3 lbs/million Btu heat input x 675 million Btu heat input /hour = 1552.5 lbs SO2/hr The maximum sulfur content of the coal or pet coke will be 5% sulfur The maximum coal input into the kiln from the application is 30 tons per hour The molecular wt of sulfur (S) = 32 grams/mole The molecular wt of sulfur dioxide (SO2) = {32 + (2 x 16)}= 64 grams/mole Calculation of SO2:

30 tons coal

×

5.0 tons sulfur

64 tons SO

2000 lbs SO

2 = 6000 lbs 100 tons coal hour tons SO hour 2 Per the application, the preheater/precalciner/kiln system, the calciner portion of the preheat tower and the kiln has inherent scrubbing of SO2 such that all of the SO2 generated by combustion of coal or pet coke is absorbed into the product. In the kiln, sulfur in the fuel is oxidized to SO2 in the kiln flame and is reacted with NA2O and K2O in the fuel ash or calcined meal forming NA2SO4 and K2SO4. These species are soluble in the liquid phase of the clinker and exit the kiln with clinker product. Where sulfur exceeds the available alkali content of the meal, sulfur is reacted with calcined meal (CAO) forming calcium sulfate (CaSO4) which is soluble in the clinker liquid phase. In the calciner, fuel is combusted at temperatures of about 1800 degrees F. Kiln carbonate in the in the feed is simultaneously heated and decarbonized to calcium oxide (CAO) and carbon dioxide (CO2). This process occurs in suspension with the fired coal fuel. As a result sulfur is oxidized and reacted with CaO simultaneously. Because of the excess CaO and intimate contact, SO2 is almost completely captured. Compliance is expected with this regulation. SO2 =

×

2 × 32 tons sulfur

From the application, the maximum clinker output = 6000 tons per day (250 tons per hour) SO2 allowable emissions (proposed BACT): 1.33 lbs SO2/ton clinker x 250 tons clinker/hr = 332.5 lbs SO2/hour (1456.35 tpy) Note: The proposed BACT limit for SO2 from the preheater/kiln system is 1.33 lbs SO2/ton clinker on a 30 day rolling average and 1.80 lbs SO2/ton clinker on a maximum 24-hour average. The BACT limit is more stringent than regulation 2D .0516 and will be placed into the permit.

c.

15A NCAC 2D .0530 “Prevention of Significant Deterioration (PSD)”, 40 CFR 51.166 • Kiln System {Preheater/precalciner kiln (Coal-fired, petroleum coke, 675 million Btu per hour heat input)/in-line raw mill/clinker cooler with associated Selective non-catalytic reduction (SNCR, CD44N), lime injection system (CD44S); ID No. ES-KS} all routed to bagfilter (CD44A), PSD regulations apply to major “sources” of pollutants. In the case of Portland cement plants, the major stationary source threshold is 100 tons/yr, which includes all quantifiable fugitive emissions. Carolinas Cement Company, LLC is considered a major source with regards to PSD because it will emit greater than 100 tons per year of a regulated NSR pollutant. To comply with the best available control technology determination pursuant to 15A NCAC 2D .0530, "Prevention of Significant Deterioration," PM, PM10, nitrogen dioxide (NOx), sulfur dioxide (SO2), carbon monoxide (CO), and volatile organic compound (VOCs) emissions from the preheater/precalciner kiln system, shall not exceed:

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1,861 663 527 1,456 3,068 175

tons NOx /year per consecutive 12-month period tons PM/year per consecutive 12-month period tons PM10/year per consecutive 12-month period tons SO2/year per consecutive 12-month period tons CO/year per consecutive 12-month period tons VOCs/year per consecutive 12-month period

i.

Pursuant to 15A NCAC 2D .0530 “Prevention of Significant Deterioration” the facility shall comply with the following limits: (A) Less than or equal to 6000 tons per day clinker production (B) Less than or equal to 2,190,000 tons per year of clinker production (C) Less than or equal to 2,400,000 tons per year of cement production

ii. Best Available Control Technology (A) BACT for filterable PM10 emissions from the preheater/precalciner/kiln/inline raw mill/clinker cooler bagfilter is an outlet grain loading of 0.012 grains/scf. (B) BACT for filterable PM10 emissions from the coal mill bagfilter is an outlet grain loading of 0.01 grains/scf. (C) BACT for carbon monoxide (CO) emissions from the preheater/precalciner kiln/inline raw mill/clinker cooler main stack is 2.80 lbs CO per ton of clinker, 30-day rolling average, as measured using a Continuous Emission Rate Monitor in accordance with Appendix F of Part 60 and Approved Division of Air Quality protocol. (D) BACT for sulfur dioxide (SO2) emissions from the preheater/precalciner kiln/inline raw mill/clinker cooler/ coal mill main stack is 1.33 lbs SO2 per on of clinker, 30-day rolling average and 1.80 lb/ton of clinker, maximum 24-hour average, as measured using a Continuous Emission Rate Monitor in accordance with Appendix F of Part 60 and Approved Division of Air Quality protocol. (E) BACT for nitrogen dioxide (NOx) emissions from the preheater/precalciner kiln/inline raw mill/clinker cooler/ coal mill main stack is 1.70 lbs NOx per ton of clinker, 30-day rolling average, as measured using a Continuous Emission Rate Monitor in accordance with Appendix F of Part 60 and Approved Division of Air Quality protocol. (F) BACT for volatile organic compounds (VOCs) emissions from the preheater/precalciner/ kiln/inline raw mill/clinker cooler/coal mill emissions from the main stack is using good combustion practices and 0.16 lbs VOCs per ton of clinker as measured by a CEMs in accordance with Appendix F of Part 60 and Approved Division of Air Quality protocol. iii Monitoring/Recordkeeping [15A NCAC 02Q .0508(f)] (A) The maximum sulfur content of any coal or pet coke burned in the preheater-precalciner/kiln system shall not exceed 5.0 percent by weight. The Permittee shall be deemed in noncompliance with if the sulfur content of the coal or pet coke exceeds this limit. (1) To assure compliance, the Permittee shall monitor the sulfur content of the coal and/or pet coke by using coal supplier certification per total shipment received. The coal supplier certification shall be recorded in a logbook (written or electronic format) per total shipment and include the following information: (a) the name of the coal and/or pet coke supplier; (b) the maximum sulfur content of the coal and/or pet coke received per total shipment; (c) a statement verifying that the methods used to determine the maximum sulfur content of the coal and/or pet coke was in accordance with the following: (i) sampling -- ASTM Method D 2234; (ii) preparation -- ASTM Method D 2013; (iii) gross calorific value (Btu) -- ASTM Method D-5865 (iv) moisture content --ASTM Method D 3173; and (v) sulfur content -- ASTM Method D 3177 or ASTM Method D 4239

Review 07300R08 -Draft Revision 4, Page 52 (B) The Permittee has stated that the inline precalciner/kiln/inline raw mill/inline clinker cooler system has inherent scrubbing capability of sulfur dioxide (SO2) emissions from fuel. Prior to utilizing a fuel source with a sulfur content greater than 2%, the Permittee shall conduct a demonstration to show (if any) the variability of SO2 emissions from the firing of coal and/or pet coke with sulfur contents between 2.0% by weight and 5.0% by weight in the precalciner/kiln/inline raw mill/inline clinker cooler system. The Permittee shall monitor and record the following: (1) the sulfur content of the coal/and or pet coke being burned, and (2) the sulfur dioxide emissions from the stack on an hourly basis. The Permittee shall submit a test protocol to the director prior to the demonstration. If this demonstration indicates that sulfur dioxide emissions have a statistically significant increase or decrease as defined in the protocol with the increase or decrease in fuel sulfur content, the permit will be administratively revised and the allowable fuel sulfur content shall be limited to 2.0% or less. (C) Particulate matter emissions from the preheater/precalciner/kiln/inline raw mill/clinker cooler/coal mill system shall be controlled by bagfilters (CD44A and CD44B). To assure compliance, the Permittee shall perform inspections and maintenance as recommended by the manufacturer. In addition to the manufacturer’s inspection and maintenance recommendations, or if there is no manufacturer’s inspection and maintenance recommendations, as a minimum, the inspection and maintenance requirement shall include the following: (1) a monthly visual inspection of the system ductwork and material collection unit for leaks; and (2) an annual (for each 12 month period following the initial inspection) internal inspection of the bagfilter's structural integrity. (D) The results of inspection and maintenance shall be maintained in a logbook (written or electronic format) onsite and made available to an authorized representative upon request. The logbook shall record the following: (1) the date and time of each recorded action; (2). the results of each inspection; (3) the results of any maintenance performed on the bagfilters; and (4) any variance from manufacturer’s recommendations, if any, and corrections made.

Reporting Requirements [15A NCAC 2Q .0508(f)] iv. The Permittee shall maintain a monthly summary report, acceptable to the Regional Air Quality Supervisor, of monitoring and recordkeeping listed above and shall submit the results within 30 days of a written request by the DAQ. d. 15A NCAC 2D .0524, 40 CFR Part 60, Subpart F “Portland Cement Plants” The Permittee shall comply with all applicable provisions, including the notification, testing, recordkeeping, and monitoring requirements contained in Environmental Management Commission Standard 15A NCAC 2D .0524 "New Source Performance Standards (NSPS) For Cement Plants” as promulgated in 40 CFR Part 60 Subpart F, including Subpart A "General Provisions."[15A NCAC 2D .0524] •

Kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw mill storage, clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and unloading systems. Currently this facility is subject to New Source Performance Standards, Subpart F “Cement Plants”. However compliance with the monitoring, recordkeeping, reporting, and testing for Subpart F shall be met in accordance with the requirements listed in Section VI. L. 2. a. of this review. Amendments to New Source Performance Standards, Subpart F, were proposed in the Federal Register on June 16, 2008 for all affected facilities that are constructed after June 16, 2008. The Permittee shall comply with all applicable provisions contained in the final rule promulgated pursuant to the June 16, 2008 proposal {includes pollutants PM, SO2, and NOx}.

Review 07300R08 -Draft Revision 4, Page 53

VII.

MULTIPLE EMISSIONS: A. 15A NCAC 2D .0540 “Particulates From Fugitive Dust Emission Sources” (State Enforceable Only) Mining/Quarry Operations (Mine/FQ) • Rock/limestone removal using heavy equipment, drilling, and blasting (ID No. ES-Mine1) • Rock/limestone loading operations (rock from front end loader to haul truck, unloading haul truck to jaw crusher, ID No. ES-Mine2) • Limestone/marl pile located in quarry area (ID No. ES-FQSP1) • Spoils/other pile located in quarry area (ID No. ES-FQSP2) • Overburden pile located in quarry area (ID No. ES-FQSP4) • Quarry roads (ID No. ES-QURD) • Spoils/other stacker pile (ID No. ES-FQ6) Paved Plant Roads (PLTRD), Storage piles (SP) • • • • • • • • • •

ES-PLTRD (Vehicular traffic on paved plant roads) ES-SPCoal1 (Coal/coke storage pile at the plant) ES-SPCoal2 (Coal/coke storage pile at the plant) ES-SPBlend1 (Blended stone pile at the plant) ES-SPBlend2 (Blended stone pile at the plant) ES-SPMillscale (Mill scale storage pile at the plant) ES-SPBauxite (Bauxite storage pile at the plant) ES-SPAsh (Bottom ash storage pile at the plant) ES-SPLimestone (Limestone storage pile at the plant) ES-SPGypsum (Gypsum storage pile at the plant)

This facility relied upon air dispersion modeling for rock quarries to demonstrate compliance with the ambient air quality standards for total suspended particulate (TSP) and particulate matter with an aerodynamic diameter of less than 10 microns (PM-10). The Fugitive Dust Control Plan provides control and recordkeeping methods that will be used at the facility to reduce fugitive dust emissions in a manner that is consistent with the modeling. The plan is required pursuant to 15A NCAC 2D .0540(e)(1) which provides that, if dispersion modeling shows the potential to violate an ambient air quality standard, the facility may be required to develop and submit a Fugitive Dust Control Plan. This plan will be included in the body of the Title V permit after the facility has constructed the roads, etc. Fugitive emissions are generated in the pit during the loading of the raw materials into trucks or onto conveyors. Generally, the material being excavated in the pit has high moisture content and fugitive dust emissions from these processes are inherently low.

PLAN MAINTENANCE A copy of this Fugitive Dust Control Plan will be retained on-site, and it will be made available to an authorized NC DAQ representative upon request. Any revisions to the Plan shall be submitted to the NC DAQ Regional Supervisor for approval. NC DAQ shall notify the Permittee if the revisions are NOT approved within 30 days or receipt. If no such notification is provided, the Permittee may assume the revised plan is approved as submitted

STAFF TRAINING All facility staff that are responsible or fugitive dust suppression activities shall be made aware of this plan and its contents, including control methods and associated recordkeeping requirements. Staff should immediately be made aware of any revisions to the plan. A copy of the plan shall be maintained in a location that is accessible to facility staff (e.g., in this main office).

Review 07300R08 -Draft Revision 4, Page 54 B. 15A NCAC 2D .0530 “Prevention of Significant Deterioration” a. To comply with the best available control technology determination pursuant to 15A NCAC 2D .0530, "Prevention of Significant Deterioration”, particulate emissions from the Mining/Quarry Operations and the Paved Plant Roads shall be controlled by: i. Mining/Quarry Operations = best management practices for the drilling, blasting, stone removal, and truck loading operations, ii. Plants Roads = vacuum sweeping and/or water flushing b. c.

C.

Monitoring and Recordkeeping [15A NCAC 2Q .0508(f)] The Permittee shall maintain operations data on a daily basis and record in a monthly log book. Reporting [15A NCAC 2Q .0508(f)] The Permittee shall maintain a monthly summary report, acceptable to the Regional Air Quality Supervisor, of monitoring and recordkeeping listed above and shall submit the results within 30 days of a written request by the DAQ.

15A NCAC 2D .1100 “Toxic Air Pollutants” (STATE ONLY REQUIREMENT) Facility-wide air toxic pollutant modeling was performed for those air toxics with emission rates greater than the TPER limits. • Kiln system • Raw mill and kiln feed • Solid fuel system • Clinker transfer and storage • Finish mills • Cement transfer & storage • Existing terminal • Quarry equipment • Process fugitive • Storage piles • Mining operation Carolinas Cement modeled 11 toxic pollutants using AERMOD with the same receptor array and meteorology as in the NAAQS analysis. A list of the facility sources and emission rates used are attached to this document. All the modeled pollutants demonstrated compliance with the applicable NC Acceptable Ambient Levels (AAL). Modeled results are presented in the table below. Mercury emissions from the cement kiln reflects the amount of mercury in the kiln's feedstock and fuel inputs. The amounts of mercury in these inputs and their relative contributions to overall mercury kiln emissions vary by site. In many cases the majority of the mercury emissions result from the mercury present as a trace constituent in the limestone. Limestone is the single largest input, by mass, to a cement kiln's total mass input, typically making up 80 percent of that loading. Mercury is also found as a trace constituent in the other inputs to the kiln such as the additives that supply the required silica, alumina, and iron. Mercury is also present in the coal and petroleum coke typically used to fuel cement kilns. Based on current information, mercury levels in limestone can vary significantly, both within a single quarry and between quarries. Since quarries are generally proprietary, this variability is inherent and sitespecific. Mercury levels in additives and fuels likewise vary significantly, although mercury emissions attributable to limestone often dominate the total due to the larger amount of mass input contributed by limestone. For modern preheater/precalciner kilns with in-line raw mills, mercury is captured in the ground raw meal in the in-line raw mill and this raw meal (containing mercury) is returned as feed to the kiln. Mercury emissions may remain low during such recycling operations. However, as part of normal kiln operation raw mills must be periodically shut down for maintenance, and mercury-containing exhaust gases from the kiln are then bypassed directly to the main air pollution control device resulting in significantly increased mercury emissions at the stack.

Review 07300R08 -Draft Revision 4, Page 55 The result is that at any given time, mercury emissions from such cement kilns are either low or high, but rarely in equilibrium, so that single stack tests are likely to either underestimate or overestimate cement kilns' performance over time. The applicant estimated that this cement plant would produce less than 262.8 lbs/year of mercury. See the site specific calculations for mercury in Section L. 2. a. ii. of this review. The facility wide potential to emit for arsenic is 29.6 lbs/year of which 26.2 lbs/year (88.5%) is from the main stack and 3.4% lbs/year (11.5%) is from miscellaneous dust collectors and fugitive sources. The air toxics modeling indicated that arsenic was at 47.83% of the Significant Ambient Air Concentration (SAAC) at some locations along the facility property line. The arsenic in the raw meal mix affects the arsenic concentrations in the pollutants from the main stack, however, the majority of arsenic input to the kiln will remain with the final product. The applicant states that the modeled arsenic emission rate is a conservative value.

a.

Pursuant to 15A NCAC 2D .1100 and in accordance with the approved application for an air toxic compliance demonstration, the following toxic air pollutant modeled emission rates shall not be exceeded:

Toxics Modeling Results Source Descriptions Pollutant

Kiln system & Emergency generator

Ammonia Benzene Fluorides Fluorides HCL Formaldehyde

Averaging Period 1-hr Annual 1-hr 24-hr 1-hr 1-hr

Modeled Emission Rate 2.5 lbs/hr 6792.04 lbs/yr 0.225 lbs/hr 5.4 lbs/day 7.175 lbs/hr 0.1156 lbs/hr

Max Impact (ug/m3) 7.16E-01 3.13E-03 6.45E-02 6.96E-03 2.06E-00 3.35E-02

AAL

Percent of AAL

2.70E+03 1.20E-01 2.50E+02 1.60E+01 7.00E+02 1.50E+02