A. General Requirements

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					                               Michigan Department Of Environmental Quality
                                           Air Quality Division
State Registration Number                                                               RO Permit Number

        B1743                RENEWABLE OPERATING PERMIT                              MI-ROP-B1743-2004


                                         IS HEREBY ISSUED TO

                                             Holcim (US), Inc.

                                               SRN: B1743

                                              LOCATED AT

                            15215 Day Rd., Dundee Township, Michigan 48131

                                  Permit Number:     MI-ROP-B1743-2004

                                  Effective Date:    April 27, 2004

                                  Expiration Date:   April 27, 2009

This permit is issued in accordance with and subject to Part 5506(3) of Article II, Chapter 1, Part 55 (Air
Pollution Control) of P.A. 451 of 1994. Pursuant to Air Pollution Control Rule 336.1210(1), this permit
constitutes the permittee’s authority to operate the major stationary source identified above in
accordance with the general conditions, special conditions and attachments contained herein.
Operation of the major stationary source and all emission unit/process groups listed in the permit are
subject to all applicable future or amended rules and regulations pursuant to P.A. 451 and the Clean Air
Act.

This permit does not relieve the permittee from the responsibility to obtain the necessary permits to
install pursuant to Air Pollution Control Rule 336.1201 for new or modified process or process
equipment. In addition, issuance of this renewable operating permit does not obviate the necessity of
obtaining such permits or approvals from other units of government as required by law.

This permit does not relieve the permittee from any responsibilities or obligations imposed on the
permittee, at this source, under Consent Order No. 22-1999, entered on August 11, 1999, between the
MDEQ and the permittee and Consent Judgment 00-11363-CZ, entered on July 14, 2000.

The conditions contained in this Renewable Operating Permit for which a Consent Judgment or
Consent Order identified applicable requirement shall be considered null and void upon the effective
date of termination of the Consent Judgment or Consent Order. The effective date of termination is
defined for the purposes of this condition as the date upon which the Termination Order is signed by the
Chief of the Air Quality Division.

Michigan Department of Environmental Quality


______________________________________
G. Vinson Hellwig, Chief
Air Quality Division
                                                          Permit Number: MI-ROP-B1743-2004
                                                                 Expiration Date: April 27, 2009


                                      Table of Contents

A. GENERAL REQUIREMENTS                                                                       4

 Enforceability                                                                               4

 General Conditions                                                                           4

 Recordkeeping and Reporting                                                                  6

 Compliance Reporting and Certification                                                       7

 Permit Shield                                                                                7

 Stratospheric Ozone Protection                                                               8

 Risk Management Plan                                                                         8


B. SOURCE-WIDE REQUIREMENTS                                                                 10

C.   EMISSION UNIT/PROCESS GROUP SUMMARY TABLE                                              12

D. FLEXIBLE GROUPINGS SUMMARY TABLE                                                         16

E. EMISSION UNIT/PROCESS GROUP REQUIREMENTS                                                 17

 TABLE E-1.1 EG001-9                                                                         18

 TABLE E-1.2 EG013                                                                           20

 TABLE E-1.3 EG014                                                                           22

 TABLE E-1.4 EG023                                                                           24

 TABLE E-1.5 EG024                                                                           26

 TABLE E-1.6 EG030                                                                           28

 TABLE E-1.7 EG031                                                                           30

 TABLE E-1.8 EG035                                                                           32


F. FLEXIBLE GROUPING REQUIREMENTS                                                           34

 TABLE F-1.1 FG001                                                                           35

 TABLE F-1.2 FG002                                                                           37

 TABLE F-1.3 FG003                                                                           40

 TABLE F-1.4 FG004                                                                           43



                                          Page 2 of 131
                                                           Permit Number: MI-ROP-B1743-2004
                                                                  Expiration Date: April 27, 2009
 TABLE F-1.5 FG005                                                                            45

 TABLE F-1.6 FG006                                                                            47

 TABLE F-1.7 FG007                                                                            49

 TABLE F-1.8 FG008                                                                            51

 TABLE F-1.9 FG009                                                                            65

 TABLE F-1.10 FG010                                                                           67

 TABLE F-1-11 FG011                                                                           69

 TABLE F-1.12 FG012                                                                           71

 TABLE F-1.13 FGCOLDCLEANERS                                                                  73

 TABLE F-1.14 FG014                                                                           76

 TABLE F-1.15 FG015                                                                           78


G. NON-APPLICABLE REQUIREMENTS                                                               81

APPENDICES                                                                                   83

 Appendix 1. Abbreviations Used in This Permit                                                83

 Appendix 2. Schedule of Compliance                                                           85

 Appendix 3. Monitoring Requirements                                                          86

 Appendix 4. Recordkeeping                                                                   104

 Appendix 5. Testing Procedures                                                              105

 Appendix 6. Permits to Install/Operate                                                      114

 Appendix 7. Emission Calculations                                                           115

 Appendix 8. Reporting                                                                       116




                                           Page 3 of 131
                                                                                Permit Number: MI-ROP-B1743-2004
                                                                                       Expiration Date: April 27, 2009


A. General Requirements
For the purpose of this Renewable Operating (RO) Permit, the permittee is defined as any person who owns or
operates a process or process equipment at a stationary source for which a RO Permit has been issued. This
permit is issued to Holcim (US), Inc. Manufacturer of Portland Cement, hereinafter the permittee for this RO Permit.
The department is defined in R 336.1104(d) as the Director of the Department of Environmental Quality or his or her
designee.

Enforceability

All conditions in this permit are both federally enforceable and state enforceable unless otherwise noted. Those
requirements which are enforceable by the state only are designated by an asterisk. (R 336.1213(5))

General Conditions

1.      A challenge by any person, the Administrator of the EPA, or the department to a particular condition or a
        part of this RO Permit shall not set aside, delay, stay, or in any way affect the applicability or enforceability
        of any other condition or part of this RO Permit. (R 336.1213(1)(f))

2.      Except as provided in subrules 2, 3, and 4 of R 336.1301, a person shall not cause or permit to be
        discharged into the outer air from an emission unit/process group a visible emission of a density greater
        than the most stringent of R 336.1301(1)(a) or (b) unless otherwise specified in this RO Permit. The
        grading of visible emissions shall be determined in accordance with R 336.1303. (R 336.1301(1) in
        pertinent part):
        a)      A 6-minute average of 20% opacity, except for one 6-minute average per hour of not more than
                27% opacity.
        b)      A limit specified by an applicable federal new source performance standard.

3.      Any collected air contaminants shall be removed as necessary to maintain the equipment at the required
        operating efficiency. The collection and disposal of air contaminants shall be performed in a manner so as
        to minimize the introduction of contaminants to the outer air. Transport of collected air contaminants in
        Priority I and II areas requires the use of material handling methods specified in R 336.1370(2).
        (R 336.1370)

4.      Any air cleaning device shall be installed, maintained, and operated in a satisfactory manner and in
        accordance with the Michigan Air Pollution Control rules and existing law. (R 336.1910)

5.      The department may require the owner or operator of any source of an air contaminant to conduct
        acceptable performance tests, at the owner’s or operator’s expense, in accordance with R 336.2001 and
        R 336.2003, under any of the conditions listed in R 336.2001(1). (R 336.2001)

6.      A change in ownership or operational control of a stationary source covered by a RO Permit shall be made
        pursuant to R 336.1216(1). (R 336.1219(3))

7.      The permittee shall not cause or permit the emission of an air contaminant or water vapor in quantities that
        cause, alone or in reaction with other air contaminants, either of the following:
        a)      Injurious effects to human health or safety, animal life, plant life of significant economic value, or
                property. (R 336.1901(a)*)
        b)      Unreasonable interference with the comfortable enjoyment of life and property. (R 336.1901(b)*)

8.      The permittee shall comply with all conditions of this RO Permit. Any permit noncompliance constitutes a
        violation of Act 451 of 1994, as amended, Part 55, (Air Pollution Control) and is grounds for enforcement
        action, for permit revocation or revision, or for denial of the renewal of the RO Permit. All terms and
        conditions of this RO Permit that are designated as federally enforceable are enforceable by the
        Administrator of the EPA and by citizens under the provisions of the CAA. Any terms and conditions based
        on applicable requirements which are designated as “state only” are not enforceable by the EPA or citizens
        pursuant to the CAA. (R 336.1213(1)(a))


                                                    Page 4 of 131
                                                                            Permit Number: MI-ROP-B1743-2004
                                                                                   Expiration Date: April 27, 2009
9.    It shall not be a defense for the permittee in an enforcement action that it would have been necessary to
      halt or reduce the permitted activity in order to maintain compliance with the conditions of this RO Permit.
      (R 336.1213(1)(b))

10.   This RO Permit may be modified, revised, or revoked for cause. The filing of a request by the permittee for
      a permit modification, revision, or termination, or a notification of planned changes or anticipated
      noncompliance does not stay any permit condition. Pursuant to R 336.1215 and R 336.1216 the permittee
      may make changes at a stationary source at his/her own risk. (R 336.1213(1)(c))

11.   The permittee shall furnish to the department, within a reasonable time, any information the department
      may request, in writing, to determine whether cause exists for modifying, revising, or revoking the RO
      Permit or to determine compliance with this RO Permit. Upon request, a person shall also furnish to the
      department copies of any records that are required to be kept as a term or condition of this RO Permit.
      (R 336.1213(1)(e))

12.   The permittee shall allow the department, or an authorized representative of the department, upon
      presentation of credentials and other documents as may be required by law and upon stating the authority
      for and purpose of the investigation, to perform any of the following activities (R 336.1213(1)(d)):
      a)      Enter, at reasonable times, a stationary source or other premises where emissions-related activity
              is conducted or where records must be kept under the conditions of the permit.
      b)      Have access to and copy, at reasonable times, any records that must be kept under the conditions
              of the permit.
      c)      Inspect, at reasonable times, any of the following:
              i)       Any stationary source
              ii)      Any process
              iii)     Any process equipment, including monitoring and air pollution control equipment.
              iv)      Any work practices or operations regulated or required under the RO Permit.
      d)      As authorized by Section 5526 of the act, sample or monitor at reasonable times substances or
              parameters for the purpose of assuring compliance with the permit or applicable requirements.

13.   The permittee shall pay fees consistent with the fee schedule and requirements pursuant to Part 5522 of
      Act 451, P.A. 1994. (R 336.1213(1)(g))

14.   This RO Permit does not convey any property rights or any exclusive privilege. (R 336.1213(1)(h))

15.   For renewal of this RO Permit, an administratively complete application shall be considered timely if it is
      received by the department not more than 18 months, but not less than 6 months, before the expiration date
      of the RO Permit. (R 336.1210(7))

16.   For modifications to this RO Permit, an administratively complete application shall be considered timely if it
      is received by the department in accordance with the time frames specified in R 336.1216. (R 336.1210(9))

17.   For changes to any process or process equipment covered by this RO Permit that do not require a revision
      of the RO Permit pursuant to R 336.1216, the permittee must comply with R 336.1215. (R 336.1215,
      R 336.1216)

18.   A RO Permit shall be reopened by the department prior to the expiration date and revised by the
      department under any of the following circumstances:
      a)     If additional requirements become applicable to this stationary source with three or more years
             remaining in the term of the permit, but not if the effective date of the new applicable requirement is
             later than the RO Permit expiration date. (R 336.1217(2)(a)(i))
      b)     If additional requirements pursuant to Title IV of the CAA become applicable to this stationary
             source. (R 336.1217(2)(a)(ii))
      c)     If the department determines the permit contains a material mistake, that information required by
             any applicable requirement was omitted, or that inaccurate statements were made in establishing
             emission limits or the terms or conditions of the permit. (R 336.1217(2)(a)(iii))
      d)     If the department determines the permit must be revised to ensure compliance with the applicable
             requirements. (R 336.1217(2)(a)(iv))
19.   Any required performance testing shall be conducted in accordance with Rule 1001(2), Rule 1001(3) and
      Rule 1003. (R 336.2001(2), R336.2001(3), R336.2003(1))


                                                 Page 5 of 131
                                                                             Permit Number: MI-ROP-B1743-2004
                                                                                    Expiration Date: April 27, 2009

20.   Any required test results shall be submitted to the AQD in the format prescribed by the applicable reference
      test method within 60 days following the last date of the test. (R 336.2001(4))

Recordkeeping and Reporting

21.   Records of any periodic emission or parametric monitoring required by Parts B, E, F and Appendices of this
      RO Permit, shall include the following information specified in R 336.1213(3)(b)(i), where appropriate.
      (R 336.1213(3)(b)):
      a)      The date, location, time and method of sampling or measurements.
      b)      The dates analyses of the samples were performed.
      c)      The company or entity that performed the analyses of the samples.
      d)      The analytical techniques or methods used.
      e)      The results of the analyses.
      f)      The related process operating conditions or parameters that existed at the time of sampling or
              measurement.

22.   All required monitoring data, support information and all reports, including reports of all instances of
      deviation from permit requirements, shall be kept and furnished to the department upon request for a period
      of not less than 5 years from the date of the monitoring sample, measurement, report or application.
      Support information includes all calibration and maintenance records and all original strip-chart recordings,
      or other original data records for continuous monitoring instrumentation and copies of all reports required by
      the RO Permit. (R 336.1213(1)(e), R 336.1213(3)(b)(ii))

23.   Semiannually for the term of the permit as detailed in the requirement tables, or more frequently if specified
      in an applicable requirement in this RO Permit, the permittee shall submit certified reports of any required
      monitoring to the appropriate District Office of the AQD. All instances of deviations from permit
      requirements during the reporting period shall be clearly identified in the reports. (R 336.1213(3)(c)(i))

24.   The permittee shall promptly report any deviations from permit requirements and certify the reports. The
      prompt reporting of deviations from permit requirements is defined in R 336.1213(3)(c)(ii) as follows, unless
      otherwise described in this RO Permit: (R 336.1213(3)(c)):
      a)      For deviations that exceed the emissions allowed under the RO Permit, prompt reporting means
              reporting consistent with the requirements of R 336.1912 as detailed in Condition 26. All reports
              submitted pursuant to this paragraph shall be promptly certified as specified in R 336.1213(3)(c)(iii).
      b)      For deviations which exceed the emissions allowed under the RO Permit and which are not
              reported pursuant to R 336.1912 due to the duration of the deviation, prompt reporting means the
              reporting of all deviations in the semi-annual reports required by R 336.1213(3)(c)(i). The report
              shall describe reasons for each deviation and the actions taken to minimize or correct each
              deviation.
      c)      For deviations that do not exceed the emissions allowed under the RO Permit, prompt reporting
              means the reporting of all deviations in the semi-annual reports required by R 336.1213(3)(c)(i).
              The report shall describe the reasons for each deviation and the actions taken to minimize or
              correct each deviation.

      For reports required pursuant to R 336.1213(3)(c)(ii), prompt certification of the reports is described in
      R 336.1213(3)(c)(iii) as either of the following (R 336.1213(3)(c)):
      d)     Submitting a certification by a responsible official with each report which states that, based on
             information and belief formed after reasonable inquiry, the statements and information in the report
             are true, accurate, and complete.
      e)     Submitting, within 30 days following the end of a calendar month during which one or more prompt
             reports of deviations from the emissions allowed under the permit were submitted to the
             department pursuant to R 336.1213(3)(c)(ii), a certification by a Responsible Official which states
             that, based on information and belief formed after reasonable inquiry, the statements and
             information contained in each of the reports submitted during the previous month were true,
             accurate, and complete. The certification shall include a listing of the reports that are being
             certified. Any report submitted pursuant to R 336.1213(3)(c)(ii) that will be certified on a monthly
             basis pursuant to this paragraph shall include a statement that certification of the report will be
             provided within 30 days following the end of the calendar month.



                                                  Page 6 of 131
                                                                              Permit Number: MI-ROP-B1743-2004
                                                                                     Expiration Date: April 27, 2009
25.   Except for the alternate certification schedule provided in R 336.1213(3)(c)(iii)(B), any document required to
      be submitted to the department as a term or condition of this RO Permit shall contain a certification by a
      responsible official which states that, based on information and belief formed after reasonable inquiry, the
      statements and information in the document are true, accurate, and complete. (R 336.1213(3)(c))

26.   The permittee shall provide notice of an abnormal condition, start-up, shutdown, or malfunction that results in
      emissions of a hazardous or toxic air pollutant which continue for more than one hour in excess of any
      applicable standard or limitation, or emissions of any air contaminant continuing for more than two hours in
      excess of an applicable standard or limitation, as required in R 336.1912, to the appropriate District Office of
      the AQD. The notice shall be provided not later than two business days after the start-up, shutdown, or
      discovery of the abnormal conditions or malfunction. Notification shall be by any reasonable means, including
      electronic, telephonic, or oral communication. Written reports, if required under R 336.1912, must be
      submitted to the appropriate District Supervisor within 10 days after the start-up or shutdown occurred, within
      10 days after the abnormal conditions or malfunction has been corrected, or within 30 days of discovery of the
      abnormal conditions or malfunction, whichever is first. The written reports shall include all of the information
      required in R 336.1912(5) and shall be certified by a Responsible Official in a manner consistent with the Clean
      Air Act. (R 336.1912)

27.   On an annual basis, the permittee shall report the actual emissions, or the information necessary to
      determine the emissions, of each regulated air pollutant as defined in R 336.1212(7) for each emission
      unit/process group utilizing the emissions inventory forms provided by the department. (R 336.1212(7))

Compliance Reporting and Certification

28.   A Responsible Official shall certify to the appropriate District Office of the AQD and the EPA, that the
      stationary source is and has been in compliance with all terms and conditions contained in the RO Permit
      except for deviations that have been or are being reported to the appropriate District Office of the AQD
      pursuant to Condition 24. This certification shall include all the information specified in R 336.1213(4)(c)(i)
      through (v) and shall state that, based on information and belief formed after reasonable inquiry, the
      statements and information in the certification are true, accurate, and complete. The EPA address is: US
      EPA, Air Compliance Data - Michigan, Air and Radiation Division, 77 West Jackson Boulevard, Chicago, IL,
      60604 (R 336.1213(4)(c))

29.   The certification of compliance shall be submitted annually for the term of this RO Permit as detailed in the
      requirement tables, or more frequently if specified in an applicable requirement or in this RO Permit.
      (R 336.1213(4)(c))

Permit Shield

30.   Compliance with the conditions of the RO Permit shall be considered compliance with any applicable
      requirements as of the date of RO Permit issuance, if either of the following provisions is satisfied
      (R 336.1213(6)(a)(i)and (ii):
      a)      The applicable requirements are included and are specifically identified in the permit.
      b)      The permit includes a determination or concise summary of the determination by the department
              that other specifically identified requirements are not applicable to the stationary source.
      Any requirements identified in Part G of this RO Permit have been identified as non-applicable to this RO
      Permit and are included in the permit shield.

31.   Nothing in this RO Permit shall alter or affect any of the following:
      a)      The provisions of Section 303 of the CAA, emergency orders, including the authority of the EPA
              under Section 303 of the Act. (R 336.1213(6)(b)(i))
      b)      The liability of the owner or operator of this stationary source for any violation of applicable
              requirements prior to or at the time of this permit issuance. (R 336.1213(6)(b)(ii))
      c)      The applicable requirements of the acid rain program, consistent with Section 408(a) of the CAA.
              (R 336.1213(6)(b)(iii))
      d)      The ability of the EPA to obtain information from a source pursuant to Section 114 of the CAA.
              (R 336.1213(6)(b)(iv))




                                                  Page 7 of 131
                                                                              Permit Number: MI-ROP-B1743-2004
                                                                                     Expiration Date: April 27, 2009
32.   The permit shield shall not apply to provisions incorporated into this permit through procedures for any of
      the following:
      a)       Changes for operational flexibility made pursuant to R 336.1215. (R 336.1215(5))
      b)       Administrative amendments made pursuant to R 336.1216(1)(a)(i-iv) until the changes have been
               approved by the department. (R 336.1216(1)(b)(iii))
      c)       Administrative amendments made pursuant to R 336.1216(1)(a)(v) until the amendment has been
               approved by the department. (R 336.1216(1)(c)(iii))
      d)       Minor permit modifications made pursuant to R 336.1216(2). (R 336.1216(2)(f))
      e)       State-only modifications made pursuant to R 336.1216(4) until the changes have been approved by
               the department. (R 336.1216(4)(e))

33.   Expiration of this RO Permit results in the loss of the permit shield. If a timely and administratively complete
      application for renewal is submitted not more than 18 months, but not less than 6 months before the
      expiration date of the RO Permit, but the department fails to take final action before the end of the permit
      term, the existing RO Permit does not expire until the renewal is issued or denied, and the permit shield
      shall extend beyond the original permit term until the department takes final action. (R 336.1217(1)(c),
      R 336.1217(1)(a))

Stratospheric Ozone Protection

34.   If the permittee is subject to 40 CFR Part 82 and services, maintains, or repairs appliances except for motor
      vehicle air conditioners (MVAC), or disposes of appliances containing refrigerant, including MVAC and small
      appliances, or if the permittee is a refrigerant reclaimer, appliance owner or a manufacturer of appliances or
      recycling and recovery equipment, the permittee shall comply with all applicable standards for recycling and
      emissions reduction pursuant to 40 CFR Part 82, Subpart F.

35.   If the permittee is subject to 40 CFR Part 82 and performs a service on motor (fleet) vehicles when this
      service involves refrigerant in the MVAC, the permittee is subject to all the applicable requirements as
      specified in 40 CFR Part 82, Sub-part B, Servicing of Motor Vehicle Air Conditioners. The term “motor
      vehicle” as used in Subpart B does not include a vehicle in which final assembly of the vehicle has not been
      completed by the original equipment manufacturer. The term MVAC as used in Subpart B does not include
      the air-tight sealed refrigeration system used for refrigerated cargo or an air conditioning system on
      passenger buses using HCFC-22 refrigerant.

Risk Management Plan

36.   If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall register and submit to the
      EPA the required data related to the risk management plan (RMP) for reducing the probability of accidental
      releases of any regulated substances listed pursuant to Section 112(r)(3) of the CAA as amended in
      68.130. The list of substances, threshold quantities, and accident prevention regulations promulgated
      under Part 68 do not limit in any way the general duty provisions under section 112(r)(1).

37.   If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall comply with the
      requirements of Part 68 no later than the latest of the following dates as provided in 68.10(a):
      a)      June 21, 1999,
      b)      Three years after the date on which a regulated substance is first listed under 68.130, or
      c)      The date on which a regulated substance is first present above a threshold quantity in an emission
              unit.

38.   If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall submit any additional
      relevant information requested by any regulatory agency necessary to ensure compliance with the
      requirements of 40 CFR Part 68.

39.   If subject to Section 112(r) of the CAA and 40 CFR Part 68, the permittee shall annually certify compliance
      with all applicable requirements of Section 112(r) as detailed in Conditions 28 and 29 of this RO Permit.
      (40 CFR Part 68)




                                                  Page 8 of 131
                                                                             Permit Number: MI-ROP-B1743-2004
                                                                                    Expiration Date: April 27, 2009
Alternative Operating Scenarios

   The permittee shall maintain contemporaneous records at the facility of any changes from one operating
   scenario to another. This can be any means of recording information associated with the scenario in question,
   including but not limited to: batch records, fuel records, operating schedule, or emission unit/process group
   records. (R 336.1213(8)(a))

Consent Orders

   The conditions contained in this RO Permit for which a Consent Order is the only identified applicable
   requirement shall be considered null and void upon the effective date of termination of the Consent Order. The
   effective date of termination is defined for the purposes of this condition as the date upon which the Termination
   Order is signed by the Chief of the Air Quality Division.

Consent Judgment

   The conditions contained in this RO Permit for which a Consent Judgment is the only identified applicable
   requirement shall be considered null and void upon the effective date of termination of the Consent Judgment.
   The effective date of termination is defined for the purposes of this condition as the date upon which the
   Stipulation and Order for Termination is signed by a Circuit Court Judge.




                                                  Page 9 of 131
                                                                             Permit Number: MI-ROP-B1743-2004
                                                                                    Expiration Date: April 27, 2009


B. Source-Wide Requirements
The table in Part B outlines the source-wide applicable requirements which apply to all emission unit/process
groups at this stationary source. The permittee is subject to these requirements for the stationary source in
addition to the General Requirements in Part A and any other terms and conditions contained in this RO Permit.

The stationary source shall meet the design parameters, material usage/emission limitations, monitoring,
recordkeeping, reporting and testing requirements, operational parameters, and any other requirements listed in
the following table as well as other terms and conditions specified in this RO Permit to assure compliance with all
applicable requirements. The permittee shall comply with all specific details in the special conditions and the
underlying applicable requirements cited in the table. The underlying applicable requirements for the material
usage/emission limitations, monitoring, recordkeeping, reporting and testing requirements, operational parameters,
and any other requirements are identified in parentheses. If a specific requirement type does not exist for the
stationary source, NA (not applicable) has been used in the table. Those requirements which are enforceable by
the state only are designated by an asterisk.




                                                  Page 10 of 131
                                                                                    Permit Number: MI-ROP-B1743-2004
                                                                                           Expiration Date: April 27, 2009


TABLE B
SOURCE-WIDE REQUIREMENTS
I. DESIGN PARAMETERS
A. Pollution Control                  NA
   Equipment
B. Stack/Vent Parameters             Exhaust gases shall be discharged unobstructed vertically upwards unless
                                     otherwise noted.
       Stack/Vent              a. Minimum      b. Maximum Exhaust    c. Temp     d. Air Flow      Applicable
           ID                  Height (feet)   Dimension (inches)       (°F)     Rate (acfm)     Requirement
NA

C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                               Maximum Usage Rate
NA
         B. Pollutants                                            Maximum Emission Limit
NA
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                                 A. MONITORING/RECORDKEEPING (R 336.1213(3))
                                    In Addition to General Requirements in Part A
1. Continuous Emission              NA
  Monitoring (CEM) System
  and Recordkeeping
2. Process Monitoring               NA
  System and
  Recordkeeping
3. Other Monitoring and/or          NA
  Recordkeeping
                                   B. TESTING/RECORDKEEPING (R 336.1213(3))
                                   In Addition to General Requirements in Part A
1. Parameter to be Tested/          NA
  Recorded
2. Method/Analysis                  NA
3. Frequency and Schedule           NA
  of Testing/Recordkeeping
IV. REPORTING
Reports and Schedules               NA
V. OPERATIONAL PARAMETERS
NA

VI. OTHER REQUIREMENTS
The facility shall not build, erect, install, or use any article, machine equipment, or other contrivance if the sole
purpose is to dilute or conceal an emission without resulting in a reduction in the total release of air contaminated
into the atmosphere. This rule does not apply to the control of odors.                                         (R336.1906)

* This requirement is state enforceable only.




                                                      Page 11 of 131
                                                                                                                   Permit Number: MI-ROP-B1743-2004
                                                                                                                          Expiration Date: April 27, 2009



  C. Emission Unit/Process Group Summary Table

 Unit/Group ID         Emission Unit/Process Group              Installation/   Control Device Description           Stack/Vent ID     Requirement
                                 Description                 Modification Date                                                           Table No.
EG001-9          DV001-9-1, Additive Silo No. 1,             09/01/1997        DV001-9-2 Mikro Pulsaire            SV045               E-1.1
                 24,000 cubic ft                                               baghouse, 3,000 acfm
EG013            DV013-1 Primary crusher                     01/01/1958        NA                                  NA                  E-1.2
EG014            DV014-1 Limestone transfer from             01/01/1958        DV014-2 surfactant and spray        N/A                 E-1.3
                 secondary crusher building to stock belt    06/19/2001        system DV014-3 extended
                 no. 3                                       01/31/2002        spout piling system

EG023            DV023-1 20,000 gallon fixed roof No. 2      10/11/1992            NA                              SV037               E-1.4
                 diesel oil storage tank
EG024            DV024-1 1,200 gallon fixed roof water       01/01/1986            NA                              SV038               E-1.5
                 treatment chemicals storage tank
EG030            DV030-1 Leach dust (CKD product) silo  01/01/1958                 DV030-2 baghouse-pulse jet      SV033               E-1.6
                 11,780 ft3                             01/19/1992                 5,000 acfm
EG031            DV031-1 & DV031-2 Two fuel reclaim     01/01/1958                 DV031-4 baghouse, reverse       SV034               E-1.7
                 systems (coal & coke) and six silos    04/01/1992                 air 7,000 acfm
                                                        12/1/2002
EG035            DV035-1 Clinker Baghouse Dust Transfer 7/1/2000                   DV035-2 Mikropul pulsaire       SV046               E-1.8
                                                                                   baghouse 7947 acfm
EG001-1          DV001-1-1 No. 1 Finish Mill-Grinding of     10/15/1958            DV001-1-3, Norblo reverse air   SV-004              F-1.1
                 clinker & additives to produce cement                             baghouse, 16,000 acfm
EG001-2          DV001-2-1 No. 2 Finish mill-grinding of     10/15/1958            DV001-2-3 Norblo reverse air    SV-005              F-1.1
                 clinker & additives to produce cement                             baghouse, 16,000 acfm
EG001-3          DV001-3-1 No. 3 Finish mill-grinding of     10/15/1958            DV001-3-3 Norblo pulse jet      SV-006              F-1.1
                 clinker & additives to produce cement       4/1/2001              baghouse, 16,000 acfm
EG001-4          DV001-4-1 No. 1 Finish mill feed end        10/15/1958            DV001-4-3 Reverse air           SV028               F-1.1
                 separator                                   10/01/1997            baghouse, 35,000 acfm
EG001-5          DV001-5-1 No. 2 Finish mill feed end        10/15/1958            DV001-5-3 Reverse air           SV029               F-1.1
                 separator                                   01/01/1967            baghouse 35,000 acfm
EG001-6          DV001-6-1 No. 3 Finish mill feed end        10/15/1958            DV001-6-3 Reverse air           SV030               F-1.1
                 separator                                                         baghouse 35,000 acfm
EG004            DV004-1 Additive silo No. 2, 20,000 cu ft   01/01/1958            DV004-2 Buell norblo,           SV007               F-1.2
                                                             10/30/1973            baghouse 3,000 acfm
EG005-1          DV005-1-1 One customer cement silo          01/01/1958            DV005-1-2 Reverse air           SV008               F-1.2
                 (North section) (Silo No. 20)                                     baghouse 3,500 acfm
EG005-2          DV005-2-1 Eleven customer cement silos      01/01/1958            DV005-2-2 Reverse air           SV009 and/or        F-1.2
                 Nos. 9-19                                                         baghouse and/or DV005-2-3       SV010


                                                                  Page 12 of 131
                                                                                                                Permit Number: MI-ROP-B1743-2004
                                                                                                                       Expiration Date: April 27, 2009

 Unit/Group ID        Emission Unit/Process Group             Installation/      Control Device Description       Stack/Vent ID     Requirement
                              Description                   Modification Date                                                        Table No.
                                                                                 Reverse air baghouse each
                                                                                 3,500 acfm
EG006-1          DV006-1-1 Packhouse cement silo no. 1      01/01/1958           DV006-1-2 Reverse air          SV017               F-1.2
                                                                                 baghouse 3,500 acfm
EG006-2          DV006-2-1 Packhouse cement silo no. 2      01/01/1958           DV006-2-2 Reverse air          SV015               F-1.2
                                                                                 baghouse 3,500 acfm
EG006-3          DV006-3-1 Packhouse cement silo no. 3      01/01/1958           DV006-3-2 Reverse air          SV013               F-1.2
                                                                                 baghouse 3,500 acfm
EG006-4          DV006-4-1 Packhouse cement silo no. 4      01/01/1958           DV006-4-2 Reverse air          SV011               F-1.2
                                                                                 baghouse 3,500 acfm
EG006-5          DV006-5-1 Packhouse cement silo no. 5      01/01/1958           DV006-5-2 Reverse air          SV018               F-1.2
                                                                                 baghouse 3,500 acfm
EG006-6          DV006-6-1 Packhouse cement silo no. 6      01/01/1958           DV006-6-2 Reverse air          SV016               F-1.2
                                                                                 baghouse 3,500 acfm
EG006-7          DV006-7-1 Packhouse cement silo no. 7      01/01/1958           DV006-7-2 Reverse air          SV014               F-1.2
                                                                                 baghouse 3,500 acfm
EG006-8          DV006-8-1 Packhouse cement silo no. 8      01/01/1958           DV006-8-2 Reverse air          SV012               F-1.2
                                                                                 baghouse 3,500 acfm
EG009-2          DV009-2 Dust silo, D-1                     01/01/1958           DV009-2-2 pulse jet baghouse   SV026               F-1.2
                                                            8/1/2000             16,000 acfm
EG009-3          DV009-3-1 Dust silo, D-2                   01/01/1958           DV009-3-2 pulse jet baghouse   SV027               F-1.2
                                                            8/1/2000             16,000 acfm
EG029            DV029-1 Additive 5.40 No. 3, 2,500 cu ft   01/01/1958           DV004-2 Buell Norblo           SV007               F-1.2
                                                            10/30/1973           baghouse reverse air
                                                                                  3,000 acfm
EG011-1          DV0011-1-1 Bulk cement loading to          01/01/1958           DV011-1-2 cartridge filter     SV019               F-1.3
                 trucks NW scale #1 (Packhouse silos)       05/05/2003           pulse jet air 1,800 acfm
EG011-2          DV011-2 -1 Bulk cement loading to trucks   01/01/1958           DV011-2-2 cartridge filter     SV020               F-1.3
                 NE scale #2 (Packhouse silos)              05/05/2003           pulse jet 1,800 acfm
EG011-3          DV011-3-1 Bulk cement loading to trucks    01/01/1958           DV011-3-2 cartridge filter     SV021               F-1.3
                 (SW scale #3) (Packhouse silos)            05/05/2003           pulse jet 1,800 acfm
EG011-4          DV011-4-1 Bulk cement loading to trucks    01/01/1958           DV011-4-2 cartridge filter     SV022               F-1.3
                 SE scale #4 (Packhouse silos)              05/05/2003           pulse jet 1,800 acfm
EG012            DV012-1 Secondary crusher-stone quarry     01/01/1958           DV012-3 material screening,    SV025               F-1.4
                                                            10/01/1993           DV008-2 baghouse, pulse jet
                                                                                 19,000 acfm
EG015            EV015-1 Tertiary crusher-stone quarry      01/01/1958           DV008-2 baghouse, pulse jet    SV025               F-1.4
                                                            10/01/1993           19,000 acfm
EG032            DV032-1 Cement bagging (3 units)           09/15/1993           DV032-2 baghouse, pulse jet    SV035               F-1.5
                                                                                 6,600 acfm



                                                                Page 13 of 131
                                                                                                                Permit Number: MI-ROP-B1743-2004
                                                                                                                       Expiration Date: April 27, 2009

 Unit/Group ID       Emission Unit/Process Group                 Installation/  Control Device Description        Stack/Vent ID     Requirement
                             Description                     Modification Date                                                        Table No.
EG033            DV033-1 Cement bagging (3 units)            9/15/1993         DV033-2 baghouse, pulse jet      SV036               F-1.5
                                                                               6,600 acfm
EG011-7          DV011-7 Bulk cement loading to trucks       01/01/1958        DV011-7-2 pulse jet              SV041               F-1.6
                 scale #5 (customer silos)                   3/1/1984          baghouse, 1,000 acfm
EG011-8          DV0110801 Bulk cement loading to trucks 01/01/1958            DV011-8-2 pulse jet baghouse     SV042               F-1.6
                 scale #6 (customer silos)                   3/1/1984          1,000 acfm
EG002-1          DV002-1 Clinker Cooler No. 1                10/08/1958        DV002-2 Procedaire pulse jet     SV002-1             F-1.7
                                                             06/09/2000        baghouse 106,000 acfm
EG002-2          DV002-4 Clinker Cooler No. 2                10/10/1958        DV002-3 Procedaire pulse jet     SV002-2             F-1.7
                                                             06/09/2000        baghouse 106,000 acfm
EG003-1          DV003-1 Cement Kiln No. 1                   10/08/1958        DV003-5 Dry scrubber             SV001               F-1.8
                                                             05/08/2000        (carbon), DV003-2 baghouse,
                                                                               260,000 acfm, DV003-3 wet
                                                                               scrubber-packed tower,
                                                                               DV003-4 (3) thermal oxidizers
EG003-2          DV003-6 Cement Kiln No. 2                   10/08/1958        DV003-10 Dry scrubber            SV001               F-1.8
                                                             05/08/2000        (carbon) DV003-7 baghouse,
                                                                               260,000 acfm, DV003-8 wet
                                                                               scrubber packed tower,
                                                                               DV003-9 (3) thermal oxiders
EG011-5          DV011-5-1 Bulk cement loading to rail       1/01/01958        DV011-5-2 norblo baghouse,       SV023               F-1.9
                 cars N scale #1                             1/1/1966          reverse air 4,400 acfm
EG011-6          DV011-6-1 Bulk cement loading to rail       01/01/1958        DV011-6-2 norblo baghouse,       SV024               F-1.9
                 cars S scale # 2                            1/1/1966          reverse air 4,400 acfm
EG008            DV008-1 Raw materials reclaim system        01/01/1958        DV008-2 baghouse, pulse jet      SV025               F-1.10
                 gypsum, limestone, coal, petroleum coke 10/01/1993            19,000 acfm
EG010            DV010- Raw material conveyor (belt #2)      01/01/1958        DV008-2 baghouse, pulse jet      SV025               F-1.10
                 (limestone, coal, coke, gypsum              10/01/1993        19,000 acfm
EG021            DV021-1 Gypsum, ashes, coal, limestone, 01/01/1958            DV008-2 baghouse, pulse jet      SV025               F-1.10
                 shale and coke transfer from belt 2 to belt 10/01/1993        19,000 acfm
                 5
EG DRYER – 1     DVDRYER-1 Natural gas fired solid fuel      8/1//2001         DV003-5 dry scrubber             SV001               F-1.11
                 dryer (feeding DV003-1, No. 1 kiln)                           (carbon), DV003-2 baghouse
                                                                               reverse air, 260,000 acfm,
                                                                               DV003-3 wet scrubber-packed
                                                                               tower, DV003-4(3)
                                                                               regenerative thermal oxidizers
EGDRYER-2        DVDRYER-2 natural gas fired solid fuel      8/1/2001          DV003-10 dry scrubber            SV001               F-1.11
                 dryer (feeding DV003-2, No. 2 kiln                            (carbon), DV003-7 baghouse,
                                                                               reverse air, 260,000 acfm,
                                                                               DV003-8 wet scrubber-packed


                                                                Page 14 of 131
                                                                                                                   Permit Number: MI-ROP-B1743-2004
                                                                                                                          Expiration Date: April 27, 2009

 Unit/Group ID        Emission Unit/Process Group              Installation/         Control Device Description      Stack/Vent ID     Requirement
                              Description                    Modification Date                                                          Table No.
                                                                                     tower, DV003-9 (3)
                                                                                     regenerative thermal oxidizers
EG009-1          DV009-1-1 Clinker transfer, bucket          01/01/1958              DV009-1-2 baghouse, reverse SV003                 F-1.12
                 elevators                                                           air 7,000 acfm
EG009-4          DV009-4-1 Clinker transfer, apron           01/01/1958              DV009-4-2 baghouse, pulsejet SV032                F-1.12
                 conveyors                                   8/1/2000                6,000 acfm
EG025-1          DV025-1 Open top cold cleaner               12/11/1987                                                                F-1.13
                                                             7/1/2002
EG025-2          DV025-2 Open top cold cleaner               12/18/198                                                                 F-1.13
                                                             7/1/2002
EG018            DV018-1 Quarry drilling                     01/01/1958              DV018-2 baghouse, pulse jet   SV031               F-1.14
                                                             02/13/1980              550 acfm
                                                             9/28/1986
                                                             01/01/1996
EG034            DV034-1 Clinker Storage Hall approx.        8/1/2000                DV034-2 baghouse pulse jet    SV047               F-1.15
                 114,000 sq ft and 200,000 tons storage                              3,000 acfm                    &
                 capacity                                                            DV034-3 baghouse pulse jet    SV048
                                                                                     collector 3,000 acfm
                                                                                     DV034-4 baghouse pulse jet
                                                                                     collector 3,000 acfm

EG036            DV036-1 No. 1 Open top clinker storage      1959                                                  SV047               F-1.15
                 silo No. 1 – 1,000 ton capacity & No. 3                                                           &
                 Open top clinker storage silo No. 3 –                                                             SV048
                 1,000 ton capacity
EG037            DV037 Clinker discharge or clinker well –   1959                                                  SV047               F-1.15
                 30 ft wide x 18 ft deep x 66 ft high                                                              &
                                                                                                                   SV048
EG038            DV038 Crane/Clam Bucket & Mobile            1959                                                  SV047               F-1.15
                 Equipment                                                                                         &
                                                                                                                   SV048




                                                                    Page 15 of 131
                                                                   Permit Number: MI-ROP-B1743-2004
                                                                          Expiration Date: April 27, 2009


D. Flexible Groupings Summary Table

Flexible Grouping ID   Emission Unit/Process Groups Included in Flexible Grouping     Requirement
                                                                                        Table No.
FG001                  EG001-1                                                        F-1.1
                       EG001-2
                       EG001-3
                       EG001-4
                       EG001-5
                       EG001-6
FG002                  EG004                                                          F-1.2
                       EG005-1
                       EG005-2
                       EG006-1
                       EG006-2
                       EG006-3
                       EG006-4
                       EG006-5
                       EG006-6
                       EG006-7
                       EG006-8
                       EG009-2
                       EG009-3
                       EG029
FG003                  EG011-1                                                        F-1.3
                       EG011-2
                       EG011-3
                       EG011-4
FG004                  EG012                                                          F-1.4
                       EG015
FG005                  EG032                                                          F-1.5
                       EG033
FG006                  EG011-7                                                        F-1.6
                       EG011-8                                                        F-1.6
FG007                  EG002-1                                                        F-1.7
                       EG002-2
FG008                  EG003-1                                                        F-1.8
                       EG003-2
FG009                  EG011-5                                                        F-1.9
                       EG011-6
FG010                  EG008                                                          F-1.10
                       EG010
                       EG021
FG011                  EGDRYER-1                                                      F-1.11
                       EGDRYER-2
FG012                  EG009-1                                                        F-1.12
                       EG009-4
FGCOLDCLEANERS         EG025-1                                                        F-1.13
                       EG025-2
FG014                  EG018                                                          F-1.14
FG015                  EG034                                                          F-1.15
                       EG036
                       EG037
                       EG038



                                           Page 16 of 131
                                                                              Permit Number: MI-ROP-B1743-2004
                                                                                     Expiration Date: April 27, 2009



E. Emission Unit/Process Group Requirements
The tables in Part E outline the applicable requirements for each emission unit/process group listed in the Emission
Unit/Process Group Summary Table. The permittee is subject to the requirements for each emission unit/process
group in addition to the General Requirements in Part A and any other terms and conditions contained in this RO
Permit.

Each emission unit/process group shall meet the design parameters, material usage/emission limitations,
monitoring, recordkeeping, reporting and testing requirements, operational parameters, and any other requirements
listed in Tables E-1.1 through E-1.9 as well as other terms and conditions specified in this RO Permit to assure
compliance with all applicable requirements. The permittee shall comply with all specific details in the special
conditions and the underlying applicable requirements cited in the tables. The underlying applicable requirements
for the material usage/emission limitations, monitoring, recordkeeping, reporting and testing requirements,
operational parameters, and any other requirements are identified in parentheses. If a specific requirement type
does not exist for the emission unit/process group, NA (not applicable) has been used in the table. Those
requirements which are enforceable by the state only are designated by an asterisk.




                                                  Page 17 of 131
                                                                                  Permit Number: MI-ROP-B1743-2004
                                                                                         Expiration Date: April 27, 2009




TABLE E-1.1 EG001-9
EMISSION UNIT/PROCESS GROUP REQUIREMENTS
EMISSION UNIT                           EG001-9 Additive Silo No. 1
Flexible Grouping ID                    NA
I. DESIGN PARAMETERS
A. Pollution Control Equipment          DV001-9-2 Fabric filter
B. Stack/Vent Parameters                Exhaust gases shall be discharged unobstructed vertically upwards unless
                                        otherwise noted.
           Stack/Vent ID                 a. Minimum         b. Maximum               c.         d. Air         Applicable
                                            Height       Exhaust Dimension        Temp       Flow Rate        Requirement
                                            (feet)            (inches)             .(°F)       (acfm)
SV045                                        NA                   NA               NA           NA                NA

C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
            A. Material                                 Maximum Usage Rate
NA
           B. Pollutant                               Maximum Emission Limit
1. Particulate matter         0.02 lbs/1000 lbs exhaust gas, calculated on a dry basis
                                                                                                         (R336.1201(3))
2. Particulate matter                   1.9 lbs/hr                                                       (R336.1201(3))
3. PM (Opacity)                         10% opacity
                                                      (R336.1201(3)) & (40 CFR 63, Subpart LLL, Section 63.1348)
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                           A. MONITORING/RECORDKEEPING (R 336.1213(3))
                              In Addition To General Requirements in Part A
1.   Continuous Emission            NA
     Monitoring (CEM) System
     and Recordkeeping
2.   Process Monitoring System      The pressure drop across the fabric filter shall be monitored and recorded
     and Recordkeeping              once per day when filling. Recordings reflecting values outside of the range
                                    set forth in V-OPERATIONAL PARAMETERS will require the facility to
                                    initiate corrective action per the facility’s operations and maintenance plan.
                                                                                                     (R336.1213(3))
3.   Other Monitoring and/or        NA
     Recordkeeping
                             B. TESTING/RECORDKEEPING (R 336.1213(3))
                               In Addition to General Requirements in Part A
1.   Parameter to be Tested/        Opacity                    (40 CFR 63, subpart LLL, Section 63.1350 (a)(4))
     Recorded
2.   Method/Analysis                1. EPA Method 22                                    (40 CFR 60, Appendix A-7)

                                        2. EPA Method 9                                (40 CFR 60, Appendix A-4)
3. Frequency and Schedule of            1. Monthly 1-minute visible emissions test in accordance with Method 22.
   Testing/Recordkeeping                                       (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(i))
                                        2. If no emissions are observed in six consecutive months (utilizing
                                            Method 22), testing may be decreased from monthly to semiannually.
                                            If visible emissions are observed during any semiannual test, the
                                            facility must resume testing on a monthly basis until no visible


                                                     Page 18 of 131
                                                                                Permit Number: MI-ROP-B1743-2004
                                                                                       Expiration Date: April 27, 2009


 TABLE E-1.1 EG001-9
 EMISSION UNIT/PROCESS GROUP REQUIREMENTS
                                           emissions are observed in six consecutive monthly tests.
                                                            (40 CFR 63, Subpart LLL, Section 63.1350 (a) (4) (ii))
                                        3. If no visible emissions are observed during the semi-annual test
                                           (utilizing Method 22) the facility may decrease the frequency of testing
                                           to annually. If visible emissions are observed during any annual test,
                                           the facility must resume testing on a monthly basis and maintain that
                                           schedule until no visible emissions are observed in six consecutive
                                           months.           (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))
                                        4. If visible emissions are observed during any Method 22 test, the facility
                                           must conduct a 6-minute test of opacity in accordance with Method 9.
                                           The Method 9 test must begin within one hour of any observation of
                                           visible emissions.
                                                            (40 CFR 63, Subpart LLL, Section 63.150 (a)(4)(iv)
                                        5. The facility shall maintain files of the required visible emission records
                                           in a form suitable and readily available for inspection and review as
                                           required by 40 CFR 63, Subpart A, Section 63.10 (b)(1). The files shall
                                           be retained for at least five years following the date of each occurrence
                                           and measurement. At a minimum, the most recent two years of data
                                           shall be retained on site. The files may be maintained on microfilm, on
                                           a computer, on floppy disks, on magnetic tape, or on microfiche.
                                                                      (40 CFR 63, Subpart LLL, Section 63.155(a))
 IV. REPORTING
 Reports and Schedules                  1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                        (R 336.1213(3)(c)(ii))

                                        2. Semiannual reporting of deviations pursuant to Condition 23 of Part A.
                                           Due March 15 for reporting period July 1 to December 31 and
                                           September 15 for reporting period January 1 to June 30.
                                                                                            (R 336.1213(3)(c)(i))

                                        3. Annual certification of compliance pursuant to Conditions 28 and 29 of
                                           Part A. Due annually by March 15 for the previous calendar year.
                                                                                              (R 336.1213(4)(c))

                                        See Appendix 8.
  V. OPERATIONAL PARAMETERS
  Normal operating pressure drop range for the fabric filter will be provided to the appropriate District Office of the
  AQD within 90 days of the effective date of the ROP.                                                (R336.1213(2))
  VI. OTHER REQUIREMENTS
  1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be
      procedures for proper operation and maintenance of the source and air pollution control devices in order to
      meet the emission and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the
      source-subject to the opacity standards set forth under 40 CFR 63.1348. Such procedures shall also include
      provisions of paragraphs 63.1350 (a)(4)(i) thru (iv).          (40 CFR 63, Subpart LLL, Section 63.1350(a))
  2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for
      Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.
                                                         (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)
* This requirement is state enforceable only.




                                                    Page 19 of 131
                                                                                    Permit Number: MI-ROP-B1743-2004
                                                                                           Expiration Date: April 27, 2009



TABLE E-1.2 EG013
EMISSION UNIT/PROCESS GROUP REQUIREMENTS
EMISSION GROUP                     EG013 Primary crusher quarried limestone
Flexible Grouping ID               NA
I. DESIGN PARAMETERS
A. Pollution Control          NA
Equipment
B. Stack/Vent Parameters      NA
Stack/Vent ID           a. Minimum            b. Maximum Exhaust          c. Temp (°F)      d. Air Flow       Applicable
                        Height (feet)         Dimension (inches)                            Rate (acfm)       Requirement
NA
C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                               Maximum Usage Rate
NA
         B. Pollutant                                             Maximum Emission Limit
NA
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                                 A. MONITORING/RECORDKEEPING (R 336.1213(3))
                                    In Addition To General Requirements in Part A
1. Continuous Emission             NA
Monitoring (CEM) System
and Recordkeeping
2. Process Monitoring              NA
System and Recordkeeping
3. Other Monitoring and/or         NA
Recordkeeping
                                   B. TESTING/RECORDKEEPING (R 336.1213(3))
                                   In Addition to General Requirements in Part A
1. Parameter to be                 NA
Tested/Recorded
2. Method/Analysis                 NA
3. Frequency and Schedule          NA
of Testing/Recordkeeping
IV. REPORTING
Reports and Schedules              1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                                  (R 336.1213(3)(c)(ii))

                                   2. Semi-annual reporting of deviations pursuant to Condition 23 of Part A. Due
                                   March 15 for reporting period July 1 to December 31 and September 15 for reporting
                                   period January 1 to June 30.                                   (R 336.1213(3)(c)(i))

                                   3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A.
                                   Due annually by March 15 for the previous calendar year.         (R 336.1213(4)(c))

                                   See Appendix 8.
V. OPERATIONAL PARAMETERS
NA



                                                      Page 20 of 131
                                                                             Permit Number: MI-ROP-B1743-2004
                                                                                    Expiration Date: April 27, 2009


TABLE E-1.2 EG013
EMISSION UNIT/PROCESS GROUP REQUIREMENTS
VI. OTHER REQUIREMENTS
Fugitive emissions control addressed in the “Fugitive Dust Plan” Attachment 1.                      (R336.1201(3))
* This requirement is state enforceable only.




                                                  Page 21 of 131
                                                                                    Permit Number: MI-ROP-B1743-2004
                                                                                           Expiration Date: April 27, 2009



TABLE E-1.3 EG014
EMISSION UNIT/PROCESS GROUP REQUIREMENTS
EMISSION GROUP                     EG014 Transfer of limestone from secondary crusher building onto stock belt no. 3
Flexible Grouping ID               NA
I. DESIGN PARAMETERS
A. Pollution Control          Surfactant spray system with extended spout piling system
Equipment
B. Stack/Vent Parameters      NA
Stack/Vent ID           a. Minimum      b. Maximum Exhaust c. Temp (°F) d. Air Flow                           Applicable
                        Height (feet) Dimension (inches)                          Rate (acfm)                 Requirement
NA
C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                               Maximum Usage Rate
NA
       B. Pollutant                                             Maximum Emission Limit
PM (Opacity)                       20% opacity utilizing reference method 9D (Appendix 5).                      (R336.1301)
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                                 A. MONITORING/RECORDKEEPING (R 336.1213(3))
                                    In Addition To General Requirements in Part A
1. Continuous Emission             NA
Monitoring (CEM) System
and Recordkeeping
2. Process Monitoring              The surfactant spray system shall be monitored daily, when limestone stockpiling is
System and Recordkeeping           being conducted. The liquid flow rate and liquid concentration shall be recorded and
                                   made available, upon request by AQD.                                  (R336.1213(3))
3. Other Monitoring and/or         NA
Recordkeeping
                                   B. TESTING/RECORDKEEPING (R 336.1213(3))
                                   In Addition to General Requirements in Part A
1. Parameter to be                 NA
Tested/Recorded
2. Method/Analysis                 NA
3. Frequency and Schedule          NA
of Testing/Recordkeeping
IV. REPORTING
Reports and Schedules              1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                                 (R 336.1213(3)(c)(ii))

                                   2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. Due
                                   March 15 for reporting period July 1 to December 31 and September 15 for reporting
                                   period January 1 to June 30.                                   (R 336.1213(3)(c)(i))

                                   3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A.
                                   Due annually by March 15 for the previous calendar year.         (R 336.1213(4)(c))

                                   See Appendix 8.
V. OPERATIONAL PARAMETERS
NA


                                                      Page 22 of 131
                                                                            Permit Number: MI-ROP-B1743-2004
                                                                                   Expiration Date: April 27, 2009


TABLE E-1.3 EG014
EMISSION UNIT/PROCESS GROUP REQUIREMENTS
VI. OTHER REQUIREMENTS
1. Fugitive emission control addressed in the “Fugitive Dust Plan” Attachment 1.                   (R336.1201(3))
* This requirement is state enforceable only.




                                                 Page 23 of 131
                                                                                    Permit Number: MI-ROP-B1743-2004
                                                                                           Expiration Date: April 27, 2009



TABLE E-1.4 EG023
EMISSION UNIT/PROCESS GROUP REQUIREMENTS
                                                                    3
EMISSION GROUP                     EG023 20,000 gallon (75.7 m ) above ground No. 2 Diesel Oil Tank
Flexible Grouping ID               NA
I. DESIGN PARAMETERS
A. Pollution Control          NA
Equipment
B. Stack/Vent Parameters      Exhaust gases are discharged via a u-shaped rain deflector.
Stack/Vent ID           a. Minimum     b. Maximum Exhaust c. Temp (°F) d. Air Flow                            Applicable
                        Height (feet) Dimension (inches)                        Rate (acfm)                   Requirement
SV037                   NA             NA                       NA              NA                            NA
C. Other Design Parameters
                                            3
Storage vessels greater or equal to 75 m with liquid V.P. of ≤ 15.0 KPa
                                                                             (40 CFR 60, Subpart Kb, Section 60.110(c))
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                               Maximum Usage Rate
NA
         B. Pollutant                                             Maximum Emission Limit
NA
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                                 A. MONITORING/RECORDKEEPING (R 336.1213(3))
                                    In Addition To General Requirements in Part A
1. Continuous Emission             NA
Monitoring (CEM) System
and Recordkeeping
2. Process Monitoring              NA
System and Recordkeeping
3. Other Monitoring and/or         The facility shall have accessible records showing the dimensions of the storage
Recordkeeping                      tank and an analysis showing the capacity of the storage tank.
                                                                    (40 CFR 60, Subpart Kb, Section 60.116b (a)&(b))
                                   B. TESTING/RECORDKEEPING (R 336.1213(3))
                                    In Addition to General Requirements in Part A
1. Parameter to be                 NA
Tested/Recorded
2. Method/Analysis                 NA
3. Frequency and Schedule          NA
of Testing/Recordkeeping
IV. REPORTING
Reports and Schedules              1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                                 (R336.1213(3)(c)(ii))
                                   2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. Due
                                      March 15 for reporting period July 1 to December 31 and September 15 for
                                      reporting period January 1 to June 30.                      (R336.1213(3)(c)(ii))
                                   3. Annual Certification of compliance pursuant to conditions 28 and 29 of Part A.
                                      Due annually March 15 for the previous calendar year.         (R336.1213(4)(c))

                                   See Appendix 8.
V. OPERATIONAL PARAMETERS
NA



                                                      Page 24 of 131
                                                                 Permit Number: MI-ROP-B1743-2004
                                                                        Expiration Date: April 27, 2009


TABLE E-1.4 EG023
EMISSION UNIT/PROCESS GROUP REQUIREMENTS
VI. OTHER REQUIREMENTS
NA
* This requirement is state enforceable only.




                                                Page 25 of 131
                                                                                    Permit Number: MI-ROP-B1743-2004
                                                                                           Expiration Date: April 27, 2009



TABLE E-1.5 EG024
EMISSION UNIT/PROCESS GROUP REQUIREMENTS
EMISSION GROUP                        EG024 1,200 gallon Water Treatment Chemicals Tank
Flexible Grouping ID                  NA
I. DESIGN PARAMETERS
A. Pollution Control          NA
Equipment
B. Stack/Vent Parameters      Exhaust gases are discharged via a u-shaped rain deflector.
Stack/Vent ID           a. Minimum     b. Maximum Exhaust c. Temp (°F) d. Air Flow                            Applicable
                        Height (feet) Dimension (inches)                        Rate (acfm)                   Requirement
SV038                   NA             NA                       NA              NA                            NA
C. Other Design Parameters
                                  3
Storage vessels less than 75 m                                             (40 CFR 60, Subpart Kb, Section 60.110b(b))
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                               Maximum Usage Rate
NA
         B. Pollutant                                             Maximum Emission Limit
NA
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                                 A. MONITORING/RECORDKEEPING (R 336.1213(3))
                                    In Addition To General Requirements in Part A
1. Continuous Emission             NA
Monitoring (CEM) System
and Recordkeeping
2. Process Monitoring                 NA
System and Recordkeeping
3. Other Monitoring and/or            The facility shall keep accessible records showing the dimension of the storage tank
Recordkeeping                         and an analysis showing the capacity of the storage tank.
                                                                       (40 CFR 60, Subpart Kb, Section 60.116b (a)&(b))
                                      B. TESTING/RECORDKEEPING (R 336.1213(3))
                                       In Addition to General Requirements in Part A
1. Parameter to be                    NA
Tested/Recorded
2. Method/Analysis                    NA
3. Frequency and Schedule             NA
of Testing/Recordkeeping
IV. REPORTING
Reports and Schedules                 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                                     (R336.1213(3)(c)(ii))
                                      2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. Due
                                         March 15 for reporting period July 1 to December 31 and September 15 for
                                         reporting period January 1 to June 30.                      (R336.1213(3)(c)(ii))
                                      3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A.
                                         Due annually March 15 for the previous calendar year.         (R336.1213(4)(c))

                                      See Appendix 8.
V. OPERATIONAL PARAMETERS
NA




                                                        Page 26 of 131
                                                                 Permit Number: MI-ROP-B1743-2004
                                                                        Expiration Date: April 27, 2009


TABLE E-1.5 EG024
EMISSION UNIT/PROCESS GROUP REQUIREMENTS
VI. OTHER REQUIREMENTS
NA
* This requirement is state enforceable only.




                                                Page 27 of 131
                                                                                    Permit Number: MI-ROP-B1743-2004
                                                                                           Expiration Date: April 27, 2009



TABLE E-1.6 EG030
EMISSION UNIT/PROCESS GROUP REQUIREMENTS
EMISSION GROUP                     EG030 CKD Product Silo
Flexible Grouping ID               NA
I. DESIGN PARAMETERS
A. Pollution Control               DV030-2 Fabric Filter
Equipment
B. Stack/Vent Parameters           Exhaust gases shall be discharged unobstructed vertically upwards unless
                                   otherwise noted.
Stack/Vent ID                a. Minimum      b. Maximum Exhaust c. Temp (°F) d. Air Flow              Applicable
                             Height (feet) Dimension (inches)                        Rate (acfm)      Requirement
SV033                        NA              NA                      NA              NA               NA
C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                               Maximum Usage Rate
NA
         B. Pollutant                                          Maximum Emission Limit
1. Particulate Matter              0.1 lbs/1000 lbs exhaust gas, calculated on a dry gas basis      (R336.1201(3))
2. PM (Opacity)                    10% opacity
                                                        (R336.1201(3)) & (40 CFR 63, Subpart LLL, Section 63.1348)
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                                 A. MONITORING/RECORDKEEPING (R 336.1213(3))
                                    In Addition To General Requirements in Part A
1. Continuous Emission             NA
Monitoring (CEM) System
and Recordkeeping
2. Process Monitoring              The pressure drop across the fabric filter shall be monitored and recorded once per
System and Recordkeeping           day when filling. Recordings reflecting values outside of the range set forth in V-
                                   OPERATIONAL PARAMETERS will require the facility to initiate corrective action
                                   per the facility’s operations and maintenance plan.                   (R336.1213(3))
3. Other Monitoring and/or         NA
Recordkeeping
                                   B. TESTING/RECORDKEEPING (R 336.1213(3))
                                   In Addition to General Requirements in Part A
1. Parameter to be                 Opacity                      (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4))
Tested/Recorded
2. Method/Analysis                 1. EPA Method 22                                         (40 CFR 60, Appendix A-7)
                                   2. EPA Method 9                                          (40 CFR 60, Appendix A-4)
3. Frequency and Schedule          1. Monthly 1-minute visible emissions test in accordance with Method 22 .
of Testing/Recordkeeping                                          (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(i))
                                   2. If no visible emissions are observed in six consecutive months (utilizing Method
                                       22), testing may be decreased from monthly to semi-annually. If visible
                                       emissions are observed during any semi-annual test, the facility must resume
                                       testing on a monthly basis until no visible emissions are observed in six
                                       consecutive monthly tests.
                                                                 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))
                                   3. If no visible emissions are observed during the semi-annual test (utilizing
                                       Method 22), the facility may decrease the frequency of testing to annually. If
                                       visible emissions are observed during any annual test, the facility must resume
                                       testing on a monthly basis and maintain that schedule until no visible emissions


                                                      Page 28 of 131
                                                                                Permit Number: MI-ROP-B1743-2004
                                                                                       Expiration Date: April 27, 2009


TABLE E-1.6 EG030
EMISSION UNIT/PROCESS GROUP REQUIREMENTS
                                    are observed in six consecutive readings.
                                                               (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))
                                 4. If visible emissions are observed during any Method 22 test, the facility must
                                    conduct a 6-minute test of opacity in accordance with Method 9. The Method 9
                                    test must begin within one hour of any observation of visible emissions.
                                                                   (40 CFR 63, Subpart LLL, Section 63.150 (a)(4)(iv)
                                 5. The facility shall maintain files of the required visible emission records in a form
                                    suitable and readily available for inspection and review as required by 40 CFR
                                    63, Subpart A, Section 63.10 (b)(1). The files shall be retained for at least five
                                    years following the date of each occurrence and measurement. At a minimum,
                                    the most recent two years of data shall be retained on site. The files may be
                                    maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or
                                    on microfiche.                       (40 CFR 63, Subpart LLL, Section 63.155(a))
IV. REPORTING
Reports and Schedules                 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                               (R 336.1213(3)(c)(ii))

                                      2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. Due
                                         March 15 for reporting period July 1 to December 31 and September 15 for
                                         reporting period January 1 to June 30.                 (R 336.1213(3)(c)(i))

                                      3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part
                                         A. Due annually by March 15 for the previous calendar year.
                                                                                                  (R 336.1213(4)(c))

                                 See Appendix 8.
V. OPERATIONAL PARAMETERS
Normal operating pressure drop range for the fabric filter will be provided to the appropriate District Office of the AQD
within 90 days of the effective date of the ROP                                                            (R336.1213(2))
VI. OTHER REQUIREMENTS
1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be
    procedures for proper operation and maintenance of the source and air pollution control devices in order to meet
    the emission and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the source-
    subject to the opacity standards set forth under 40 CFR 63.1348. Such procedures shall also include provisions
    of paragraphs 63.1350 (a)(4)(i) thru (iv).
                                                    (40 CFR 63, Subpart LLL, Section 63.1350 (a)) & (R336.1201(3))
2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for
    Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.
                                                          (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)
* This requirement is state enforceable only.




                                                    Page 29 of 131
                                                                                    Permit Number: MI-ROP-B1743-2004
                                                                                           Expiration Date: April 27, 2009



TABLE E-1.7 EG031
EMISSION UNIT/PROCESS GROUP REQUIREMENTS
EMISSION GROUP                     EG031 Two Fuel Reclaim Systems (coal and coke)
Flexible Grouping ID               NA
I. DESIGN PARAMETERS
A. Pollution Control          DV031-4 – Fabric Filter
Equipment
B. Stack/Vent Parameters      Exhaust gases discharged horizontally.
Stack/Vent ID           a. Minimum     b. Maximum Exhaust c. Temp (°F)                      d. Air Flow       Applicable
                        Height (feet) Dimension (inches)                                    Rate (acfm)       Requirement
SV034                   NA             NA                      NA                           NA                NA
C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                               Maximum Usage Rate
NA
       B. Pollutant                                               Maximum Emission Limit
PM (Opacity)                       10% opacity
                                                          (R336.1201(3)) & (40 CFR 63, Subpart LLL, Section 63.1348)
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                                 A. MONITORING/RECORDKEEPING (R 336.1213(3))
                                    In Addition To General Requirements in Part A
1. Continuous Emission             NA
Monitoring (CEM) System
and Recordkeeping
2. Process Monitoring              The pressure drop across the fabric filter shall be monitored and recorded once per
System and Recordkeeping           day during coal/coke transfer. Recordings reflecting values outside of the range set
                                   forth in V-OPERATIONAL PARAMETERS will require the facility to initiate corrective
                                   action per the facility’s operations and maintenance plan.            (R336.1213(3))
3. Other Monitoring and/or         NA
Recordkeeping
                                   B. TESTING/RECORDKEEPING (R 336.1213(3))
                                   In Addition to General Requirements in Part A
1. Parameter to be                 Opacity                       40 CFR 63, Subpart LLL, Section 63.1350(a)(4))
Tested/Recorded
2. Method/Analysis                 1. EPA Method 22                                       (40 CFR 60, Appendix A-7)
                                   2. EPA Method 9                                         (40 CFR 60, Appendix A-4)
3. Frequency and Schedule          1. Monthly 1-minute visible emissions test in accordance with Method 22.
of Testing/Recordkeeping                                          (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(i))
                                   2. If no emissions are observed in six consecutive months (utilizing Method 22),
                                      testing may be decreased from monthly to semi-annually. If visible emissions
                                      are observed during any semi-annual test, the facility must resume testing on a
                                      monthly basis until no visible emissions are observed in six consecutive monthly
                                      tests.                      (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))
                                   3. If no visible emissions are observed during the semi-annual test (utilizing
                                      Method 22), the facility may decrease the frequency of testing to annually. If
                                      visible emission are observed during any annual test, the facility must resume
                                      testing on a monthly basis and maintain that schedule until no visible emission
                                      are observed in six consecutive readings.
                                                                 (40 CFR 63, Subpart LLL, Section 63.1350(a)(4)(iii))
                                   4. If visible emission are observed during any Method 22 test, the facility must


                                                      Page 30 of 131
                                                                                Permit Number: MI-ROP-B1743-2004
                                                                                       Expiration Date: April 27, 2009


TABLE E-1.7 EG031
EMISSION UNIT/PROCESS GROUP REQUIREMENTS
                                     combat a 6-minute test of opacity in accordance with Method 9. The Method 9
                                     test must begin within one hour of any observation of visible emissions.
                                                                  (40 CFR 63, Subpart LLL, Section 63.150 (a)(4)(iv))
                                  5. The facility shall maintain files of the required visible emission records in a form
                                     suitable and readily available for inspection and review as required by 40 CFR
                                     63, Subpart A, Section 63.10 (b)(1). The files shall be retained for at least five
                                     years following the date of each occurrence and measurement. At a minimum,
                                     the most recent two years of data shall be retained on site. The files may be
                                     maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or
                                     on microfiche.                       (40 CFR 63, Subpart LLL, Section 63.155(a))
IV. REPORTING
Reports and Schedules             1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                                (R 336.1213(3)(c)(ii)

                                  2. Quarterly reporting of deviations pursuant to Condition 23 of Part A. Due June
                                     15 for reporting period January 1 to March 31, September 15 for reporting
                                     period April 1 to June 30, December 15 for reporting period July 1 to September
                                     30, and March 15 for reporting period October 1 to December 31.
                                                                                                 (R 336.1213(3)(c)(i))

                                  3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A.
                                     Due annually by March 15 for the previous calendar year.     (R 336.1213(4)(c))

                                  See Appendix 8.
V. OPERATIONAL PARAMETERS
Normal operating pressure drop range for the fabric filter will be provided to the appropriate District Office of the AQD
within 90 days of the effective date of the ROP.                                                           (R336.1213(2))
VI. OTHER REQUIREMENTS
1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be
    procedures for proper operation and maintenance of the source and air pollution control devices in order to meet
    the emission and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the source-
    subject to the opacity standards set forth under 40 CFR 63.1348. Such procedures shall include provisions of
    paragraphs 63.1350 (a)(4)(i) thru (iv).
                                                                     (40 CFR 63, Subpart LLL, Section 63.1350 (a))
2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for
    Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.
                                                          (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)
* This requirement is state enforceable only.




                                                    Page 31 of 131
                                                                                    Permit Number: MI-ROP-B1743-2004
                                                                                           Expiration Date: April 27, 2009


TABLE E-1.8 EG035
EMISSION UNIT/PROCESS GROUP REQUIREMENTS
EMISSION UNIT                             EG035 Clinker Baghouse Dust Transfer
Flexible Grouping ID
I. DESIGN PARAMETERS
A. Pollution Control Equipment            Pulsejet Baghouse
A. Stack/Vent Parameters                  Exhaust gases discharged horizontally vertically.
          Stack/Vent ID                    a. Minimum           b. Maximum             c. Temp        d. Air     Applicable
                                           Height (feet)     Exhaust Dimension            (°F)      Flow Rate   Requirement
                                                                  (inches)                           (acfm)
SV046                                     30                 22                       392          7947         NA

C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
           A. Material                                                   Maximum Usage Rate
NA
          B. Pollutant                                                 Maximum Emission Limit
PM (Opacity)                   10% opacity
                                                             (R336.1201(3)) & (40 CFR 63, Subpart LLL, Section 63.1348)
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                             A. MONITORING/RECORDKEEPING (R 336.1213(3))
                                In Addition To General Requirements in Part A
1.   Continuous Emission             NA
     Monitoring (CEM) System and
     Recordkeeping
2.   Process Monitoring System       The pressure drop across the fabric filters shall be monitored and recorded once
     and Recordkeeping               per day when filling bags. Recordings reflecting values outside of the range set
                                     forth in V-OPERATIONAL PARAMETERS will require the facility to initiate
                                     corrective action per the facility’s operations and maintenance plan.
                                                                                                          (R336.1213(3)
3.   Other Monitoring and/or         NA
     Recordkeeping
                               B. TESTING/RECORDKEEPING (R 336.1213(3))
                                 In Addition to General Requirements in Part A
1.   Parameter to be                 Opacity                         (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4))
     Tested/Recorded
2.   Method/Analysis                 EPA Method 22                                         (40 CFR 60, Appendix A-7)
                                     EPA Method 9                                          (40 CFR 60, Appendix A-4)
3.   Frequency and Schedule of       1. Monthly 1-minute visible emissions test in accordance with Method 22.
     Testing/Recordkeeping                                        (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(i))
                                     2. If no visible emissions are observed in six consecutive months (utilizing
                                          Method 22), testing may be decreased from monthly to semiannually. If
                                          visible emissions are observed during any semiannual test, the facility must
                                          resume testing on a monthly basis until no visible emissions are observed in
                                          six consecutive monthly tests.
                                                                  (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))
                                     3. If no visible emissions are observed during the semiannual test (utilizing
                                          Method 22), the facility may decrease the frequency to testing to annually. If
                                          visible emissions are observed during any annual test, the facility must
                                          resume testing on a monthly basis and maintain that schedule until no visible
                                          emissions are observed in six consecutive readings.
                                                                 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))


                                                      Page 32 of 131
                                                                                Permit Number: MI-ROP-B1743-2004
                                                                                       Expiration Date: April 27, 2009


TABLE E-1.8 EG035
EMISSION UNIT/PROCESS GROUP REQUIREMENTS
                                        4. If visible emissions are observed during any Method 22 test, the facility must
                                           conduct a 6-minute test of opacity in accordance with Method 9. The Method
                                           9 test must begin within one hour of any observation of visible emissions.
                                                                  (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iv))
                                        5. The facility shall maintain files of the required visible emission records in a
                                           form suitable and readily available for inspection and review as required by
                                           40 CFR 63, Subpart A, Section 63.10 (b)(1). The files shall be retained for at
                                           least five years following the date of each occurrence and measurement. At
                                           a minimum, the most recent two years of data shall be retained on site. The
                                           files may be maintained on microfilm, on a computer, on floppy disks, on
                                           magnetic tape, or on microfiche.
                                                                            (40 CFR 63, Subpart LLL, Section 63.155(a))
IV. REPORTING
Reports and Schedules                   1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                                 (R 336.1213(3)(c)(ii))

                                        2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. Due
                                           March 15 for reporting period July 1 to December 31 and September 15 for
                                           reporting period January 1 to June 30.                 (R 336.1213(3)(c)(i))

                                        3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part
                                           A. Due annually March 15 for the previous calendar year.
                                                                                                      R336.1213(4)(c))
                                        See Appendix 8.
V. OPERATIONAL PARAMETERS
Normal operating pressure drop range for the fabric filter will be provided to the appropriate District Office of the AQD
within
90 days of the effective date of the ROP.                                                                     (R336.1213(2))
VI. OTHER REQUIREMENTS
1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be procedures
    for proper operations and maintenance of the source and air pollution control devices in order to meet the emission
    and operating limits under 40 CFR 63.1348. Procedures will be set forth to periodically monitor the source-subject
    to the opacity standards set forth under 40 CFR 63.1348. Such procedures shall also include provisions of
    paragraphs 63.1350 (a)(4)(i) thru (iv).                               (40 CFR 63, Subpart LLL, Section 63.1350(a))
2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for
    Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.
                                                            (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)
3. Fugitive emissions control addressed in the “Fugitive Dust Plan” Attachment 1.                            (R336.1201(3))
* This requirement is state enforceable only.




                                                   Page 33 of 131
                                                                                Permit Number: MI-ROP-B1743-2004
                                                                                       Expiration Date: April 27, 2009



F. Flexible Grouping Requirements
The tables in Part F outline the applicable requirements for each flexible grouping listed in the Flexible Groupings
Summary Table. The permittee is subject to the requirements for each flexible grouping in addition to the General
Requirements in Part A and any other terms and conditions contained in this RO Permit.

Each flexible grouping shall meet the design parameters, material usage/emission limitations, monitoring,
recordkeeping, reporting and testing requirements, operational parameters, and any other requirements listed in
Tables F-1.1 through F-1.4 as well as other terms and conditions specified in this RO Permit to assure compliance
with all applicable requirements. The permittee shall comply with all specific details in the special conditions and the
underlying applicable requirements cited in the tables. The underlying applicable requirements for the material
usage/emission limitations, monitoring, recordkeeping, reporting and testing requirements, operational parameters,
and any other requirements are identified in parentheses. If a specific requirement type does not exist for the
flexible grouping , NA (not applicable) has been used in the table. Those requirements which are enforceable by the
state only are designated by an asterisk.




                                                    Page 34 of 131
                                                                                    Permit Number: MI-ROP-B1743-2004
                                                                                           Expiration Date: April 27, 2009


TABLE F-1.1 FG001
FLEXIBLE GROUPING REQUIREMENTS
FLEXIBLE GROUPING                  FG001 No. 1, No. 2, & No. 3 Finish Mill Systems
Emission Unit/Process              EG001-1 No. 1 Finish Mill Grinding Operation,
Groups
                                   EG001-2 No. 2 Finish Mill Grinding Operation
                                   EG001-3 No. 3 Finish Mill Grinding Operation
                                   EG001-4 No. 1 Finish Mill feed end separator
                                   EG001-5 No. 2 Finish Mill feed end separator
                                   EG001-6 No. 3 Finish Mill feed end separator
I. DESIGN PARAMETERS
A. Pollution Control               DV001-1-3 Fabric filter for No. 1 Finish Mill grinding operation
Equipment
                              DV001-2-3 Fabric filter for No. 2 Finish Mill grinding operation
                              DV001-3-3 Fabric filter for No. 3 Finish Mill grinding operation
                              DV001-4-3 Fabric filter on No. 1 Finish Mill feed end separator
                              DV001-5-3 Fabric filter for No. 2 Finish Mill feed end separator
                              DV001-6-3 Fabric filter for No. 3 Finish Mill feed end separator
B. Stack/Vent Parameters      Exhaust gases shall be discharged unobstructed vertically upwards unless
                              otherwise noted.
Stack/Vent ID           a. Minimum      b. Maximum Exhaust c. Temp (°F) d. Air Flow              Applicable
                        Height (feet) Dimension (inches)                             Rate (acfm) Requirement
SV004                   52              24                         NA                NA          NA
SV005                   52              24                         NA                NA          NA
SV006                   52              24                         NA                NA          NA
SV028                   100             40                         NA                NA          NA
SV029                   100             40                         NA                NA          NA
SV030                   100             40                         NA                NA          NA
C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                               Maximum Usage Rate
NA
       B. Pollutant                                               Maximum Emission Limit
PM (Opacity)                       10% Opacity                            (40 CFR63, Subpart LLL, Section 63.1347)
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                                 A. MONITORING/RECORDKEEPING (R 336.1213(3))
                                    In Addition To General Requirements in Part A
1. Continuous Emission             NA
Monitoring (CEM) System
and Recordkeeping
2. Process Monitoring              NA
System and Recordkeeping
3. Other Monitoring and/or         NA
Recordkeeping
                                   B. TESTING/RECORDKEEPING (R 336.1213(3))
                                   In Addition to General Requirements in Part A
1. Parameter to be                 Opacity                      (40 CFR 63, Subpart LLL, Section 63.1350)(a)(4))
Tested/Recorded
2. Method/Analysis                 1. EPA Method 22                                             (40 CFR 60, Appendix A-7)
                                   2. EPA Method 9                                              (40 CFR 60, Appendix A-4)


                                                      Page 35 of 131
                                                                              Permit Number: MI-ROP-B1743-2004
                                                                                     Expiration Date: April 27, 2009


TABLE F-1.1 FG001
FLEXIBLE GROUPING REQUIREMENTS
3. Frequency and Schedule       1. The facility will conduct daily visual emissions observations of each finish mill
of Testing/Recordkeeping           sweep and air separator PMCDs in accordance with Method 22. The Method 22
                                   test shall be conducted while the affected source is operating at the highest load
                                   expected that day. The duration of the Method 22 test shall be six minutes.
                                                                      (40 CFR 63, Subpart LLL, Section 63.1350(e))
                                2. If visible emissions are observed during the Method 22 test, the facility must
                                   initiate, within one hour, the corrective actions specified in the site specific
                                   operating and maintenance plan.
                                                                   (40 CFR 63, Subpart LLL, Section 63.1350(e)(1))
                                3. Within 24 hours of the end of the Method 22 test in which visible emissions were
                                   observed, conduct a follow up Method 22 test of each stack from which visible
                                   emissions were observed during the previous Method 22 test. If visible
                                   emissions are observed during the follow up Method 22 test from any stack from
                                   which visible emissions were observed during the previous Method 22 test,
                                   conduct a visual opacity test of each stack from which emissions were observed
                                   during the follow up Method 22 test in accordance with Method 9 of Appendix A,
                                   Part 60. The duration of the Method 9 test shall be 30 minutes.
                                                                   (40 CFR 63, Subpart LLL, Section 63.1350(e)(2))
                                4. The facility shall maintain files of the required visible emission records in a form
                                   suitable and readily available for inspection and review as required by 40 CFR
                                   63, Subpart A, Section 63.10 (b)(1). The files shall be retained for at least five
                                   years following the date of each occurrence and measurement. At a minimum,
                                   the most recent two years of data shall be retained on site. The files may be
                                   maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or
                                   on microfiche.
                                                                        (40 CFR 63, Subpart LLL, Section 63.155(a))
IV. REPORTING
Reports and Schedules           1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                             (R 336.1213(3)(c)(ii))

                                2. Quarterly reporting of deviations pursuant to Condition 23 of Part A. Due June
                                   15 for reporting period January 1 to March 31, September 15 for reporting
                                   period April 1 to June 30, December 15 for reporting period July 1 to September
                                   30, and March 15 for reporting period October 1 to December 31.
                                                                                               (R 336.1213(3)(c)(i))

                                3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A.
                                   Due annually by March 15 for the previous calendar year. (R 336.1213(4)(c))

                                See Appendix 8.
V. OPERATIONAL PARAMETERS
NA
VI. OTHER REQUIREMENTS
1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be
    procedures for proper operation and maintenance of the source and air pollution control devices in order to meet
    the emission and operating limits under 40 CFR 63.1347 and procedures for periodic monitoring of the source-
    subject to the opacity standards set forth under 40 CFR 63.1347. Such procedures shall include provisions to
    address paragraphs in 63.1350 (e).                               (40 CFR 63, Subpart LLL, Section 63.1350 (a))
2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for
    Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.
                                                         (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)
* This requirement is state enforceable only.




                                                  Page 36 of 131
                                                                        Permit Number: MI-ROP-B1743-2004
                                                                               Expiration Date: April 27, 2009



TABLE F-1.2 FG002
FLEXIBLE GROUPING REQUIREMENTS
FLEXIBLE GROUPING             FG002 Storage Silos
Emission Unit/Process         EG004 Additive Silo No. 2
Groups
                              EG005-1 One Customer Cement Silo (North Section) (No. 20)
                              EG005-2 Eleven Customer Cement Silos (Middle South Sections) (Nos. 9 thru 19)
                              EG006-1 Packhouse Cement Silo No. 1
                              EG006-2 Packhouse Cement Silo No. 2
                              EG006-3 Packhouse Cement Silo No. 3
                              EG006-4 Packhouse Cement Silo No. 4
                              EG006-5 Packhouse Cement Silo No. 5
                              EG006-6 Packhouse Cement Silo No. 6
                              EG006-7 Packhouse Cement Silo No. 7
                              EG006-8 Packhouse Cement Silo No. 8
                              EG009-2 Insulflation (CKD) Silo, D-1
                              EG009-3 Insulflation (CKD) Silo, D-2
                              EG029 Additive Silo No. 3
I. DESIGN PARAMETERS
A. Pollution Control          DV004-2 Fabric Filter
Equipment
                              DV005-1-2 Fabric Filter
                              DV005-2-2 Fabric Filter
                              DV005-2-3 Fabric Filter
                              DV006-1-2 Fabric Filter
                              DV006-2-2 Fabric Filter
                              DV006-3-2 Fabric Filter
                              DV006-4-2 Fabric Filter
                              DV006-5-2 Fabric Filter
                              DV006-6-2 Fabric Filter
                              DV006-7-2 Fabric Filter
                              DV006-8-2 Fabric Filter
                              DV009-2-2 Fabric Filter
                              DV009-3-2 Fabric Filter
B. Stack/Vent Parameters      Exhaust gases shall be discharged unobstructed vertically upwards unless
                              otherwise noted.
Stack/Vent ID           a. Minimum      b. Maximum Exhaust c. Temp (°F) d. Air Flow              Applicable
                        Height (feet) Dimension (inches)                        Rate (acfm)      Requirement
SV007                   90              13                      NA              NA               NA
SV008                   167             12                      NA              NA               NA
SV009                   167             12                      NA              NA               NA
SV010                   167             12                      NA              NA               NA
SV017                   160             14                      NA              NA               NA
SV015                   160             14                      NA              NA               NA
SV013                   160             14                      NA              NA               NA
SV011                   160             14                      NA              NA               NA
SV018                   160             14                      NA              NA               NA
SV016                   160             14                      NA              NA               NA
SV014                   160             14                      NA              NA               NA
SV012                   160             14                      NA              NA               NA
SV026                   100             36                      NA              NA               NA
SV027                   100             36                      NA              NA               NA


                                               Page 37 of 131
                                                                                    Permit Number: MI-ROP-B1743-2004
                                                                                           Expiration Date: April 27, 2009


TABLE F-1.2 FG002
FLEXIBLE GROUPING REQUIREMENTS
C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                               Maximum Usage Rate
NA
       B. Pollutant                                               Maximum Emission Limit
PM (Opacity)                       10% Opacity                           (40 CFR63, Subpart LLL, Section 63.1348)
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                                 A. MONITORING/RECORDKEEPING (R 336.1213(3))
                                    In Addition To General Requirements in Part A
1. Continuous Emission             NA
Monitoring (CEM) System
and Recordkeeping
2. Process Monitoring              The pressure drop across the fabric filters shall be monitored and included once per
System and Recordkeeping           day when filling. Recordings reflecting values outside of the range-set forth in V-
                                   OPERATIONAL PARAMETERS will require the facility to initiate corrective action
                                   per the facility’s operations and maintenance plan.                  (R336.1213 (3))
3. Other Monitoring and/or         NA
Recordkeeping
                                   B. TESTING/RECORDKEEPING (R 336.1213(3))
                                   In Addition to General Requirements in Part A
1. Parameter to be                 Opacity                      (40 CFR 63, Subpart LLL, Section 63.150 (a)(4))
Tested/Recorded
2. Method/Analysis                 1. EPA Method 22                                            (40 CFR 60, Appendix A-7)
                                   2. EPA Method 9                                             (40 CFR 60, Appendix A-4)
3. Frequency and Schedule          1. Monthly 1-minute visible emissions test in accordance with Method 22.
of Testing/Recordkeeping                                          (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(i))
                                   2. If no emissions are observed in six consecutive months (utilizing Method 22),
                                      testing may be decreased from monthly to semi-annually. If visible emissions
                                      are observed during any semi-annual test, the facility must resume testing on a
                                      monthly basis until no visible emissions are observed in six consecutive monthly
                                      tests.                      (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))
                                   3. If no visible emissions are observed during the semi-annual test (utilizing
                                      Method 22), the facility may decrease the frequency of testing to annually. If
                                      visible emissions are observed during any annual test, the facility must resume
                                      testing on a monthly basis and maintain that schedule until no visible emissions
                                      are observed in six consecutive readings.
                                                                 (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))
                                   4. If visible emissions are observed during any Method 22 test, the facility must
                                      conduct a 6-minute test of opacity in accordance with Method 9. The Method 9
                                      test must begin within one hour of any observation of visible emissions.
                                                                   (40 CFR 63, Subpart LLL, Section 63.150(a)(4)(iv))
                                   5. The facility shall maintain files of the required visible emission records in a form
                                      suitable and readily available for inspection and review as required by 40 CFR
                                      63, Subpart A, Section 63.10 (b)(1). The files shall be retained for at least five
                                      years following the date of each occurrence and measurement. At a minimum,
                                      the most recent two years of data shall be retained on site. The files may be
                                      maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or
                                      on microfiche.                       (40 CFR 63, Subpart LLL, Section 63.155(a))
IV. REPORTING
Reports and Schedules                   1. Prompt reporting of deviations pursuant to Condition 24 of Part A.


                                                      Page 38 of 131
                                                                               Permit Number: MI-ROP-B1743-2004
                                                                                      Expiration Date: April 27, 2009


TABLE F-1.2 FG002
FLEXIBLE GROUPING REQUIREMENTS
                                                                                                 (R 336.1213(3)(c)(ii))

                                     2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. Due
                                        March 15 for reporting period July 1 to December 31 and September 15 for
                                        reporting period January 1 to June 30.                (R 336.1213(3)(c)(i))

                                     3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part
                                        A. Due annually by March 15 for the previous calendar year.
                                                                                                 (R 336.1213(4)(c))

                                 See Appendix 8.
V. OPERATIONAL PARAMETERS
Normal operating pressure drop range for the fabric filters will be provided to the appropriate District Office of the
ROP within 90 days of the effective date of the ROP.                                                       (R336.1213(2)
VI. OTHER REQUIREMENTS
1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be
    procedures for proper operation and maintenance of the source and air pollution control devices in order to meet
    the emission and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the source-
    subject to the opacity standards set forth under 40 CFR 63.1348. Such procedures shall include provisions of
    paragraphs 63.1350 (a)(4)(i) thru (iv).                          (40 CFR 63, Subpart LLL, Section 63.1350(a))
2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for
    Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.
                                                          (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)
* This requirement is state enforceable only.




                                                   Page 39 of 131
                                                                                    Permit Number: MI-ROP-B1743-2004
                                                                                           Expiration Date: April 27, 2009



TABLE F-1.3 FG003
FLEXIBLE GROUPING REQUIREMENTS
FLEXIBLE GROUPING                  FG003 Cement Loading to Trucks (Packhouse Silos)
Emission Unit/Process              EG011-1 Bulk Cement Loading to Trucks – NW Scale No. 1 loading spout with cone
Groups                             including lump crusher
                                   EG011-2 Bulk Cement Loading to Trucks – NE Scale No. 2 loading spout with cone
                                   including lump crusher
                                   EG011-3 Bulk Cement Loading to Trucks – SW Scale No. 3 loading spout with cone
                                   including lump crusher
                                   EG011-4 Bulk Cement Loading to Trucks – SE Scale No. 4 loading spout with cone
                                   including lump crusher
I. DESIGN PARAMETERS
A. Pollution Control               DV011-1-2 Cartridge Fabric Filter
Equipment
                              DV011-2-2 Cartridge Fabric Filter
                              DV011-3-2 Cartridge Fabric Filter
                              DV011-4-2 Cartridge Fabric Filter
B. Stack/Vent Parameters      Horizontal vent discharge
Stack/Vent ID           a. Minimum      b. Maximum Exhaust                c. Temp (°F)      d. Air Flow       Applicable
                        Height (feet) Dimension (inches)                                    Rate (acfm)       Requirement
SV019                   18              10                                NA                NA                (R336.1201(3))
SV020                   18              10                                NA                NA                (R336.1201(3))
SV021                   18              10                                NA                NA                (R336.1201(3))
SV022                   18              10                                NA                NA                (R336.1201(3))
C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                               Maximum Usage Rate
NA
         B. Pollutant                                             Maximum Emission Limit
1. Particulate Matter              0.04 lbs/1000 lbs exhaust gas, calculated on a dry gas basis      (R336.1201(3))
                                   0.32 #/hr per loading scale                                       (R336.1201(3))
                                   5.6 ton/yr for total loading operation.               (R336.1213(2)), (Appendix 7)
2. PM Opacity                      10% Opacity                             (40 CFR63, Subpart LLL, Section 63.1348)
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                                 A. MONITORING/RECORDKEEPING (R 336.1213(3))
                                    In Addition To General Requirements in Part A
1. Continuous Emission             NA
Monitoring (CEM) System
and Recordkeeping
2. Process Monitoring              1. The pressure drop across the cartridge filter collectors shall be monitored and
System and Recordkeeping              recorded once per day when filling. Recordings reflecting values outside of the
                                      range set forth in V-OPERATIONAL PARAMETERS will require the facility to
                                      initiate corrective action per the facility’s operations and maintenance plan.
                                                                                                          (R336.1213(3))

                                   2. The facility shall keep a written record of the following information for each filter
                                      collector each calendar month.
                                           - Daily recording of the pressure drop reading across each cartridge filter
                                           dust collector.
                                           - The permittee shall keep the records in a format acceptable to the AQD


                                                      Page 40 of 131
                                                                           Permit Number: MI-ROP-B1743-2004
                                                                                  Expiration Date: April 27, 2009


TABLE F-1.3 FG003
FLEXIBLE GROUPING REQUIREMENTS
                                     District Supervisor. The facility shall keep these records on file for a period
                                     of at least five years and made them available to AQD upon request.
                                                                                      (R336,1201(3)), (R336.1213(3))
3. Other Monitoring and/or   The facility shall keep records of emission information and operating maintenance
Recordkeeping                information for the collector/material feed systems to comply with the visible
                             emission standards as set forth in 40 CFR 63, Subpart LLL, Section 63.1348. The
                             permittee shall keep all source emissions and operating and maintenance
                             information on file for a period of at least five years and make the information
                             available to the AQD upon request.                        (R336.1201(3)) (R336.1213(3))
                             B. TESTING/RECORDKEEPING (R 336.1213(3))
                              In Addition to General Requirements in Part A
1. Parameter to be           Opacity                              (40 CFR 63, Subpart LLL, Section 63.150 (a)(4))
Tested/Recorded
2. Method/Analysis           1. EPA Method 22.                                          (40 CFR 60, Appendix A-7)
                             2. EPA Method 9.                                            (40 CFR 60, Appendix A-4)
3. Frequency and Schedule    1. Monthly 1-minute visible emissions test in accordance with Method 22.
of Testing/Recordkeeping                                    (40 CFR 63, Subpart LLL Section 63.1350 (a)(4))(i))
                             2. If no emissions are observed in six consecutive months (utilizing Method 22),
                                testing may be decreased from monthly to semi-annually. If visible emissions
                                are observed during any semi-annual test, the facility must resume testing on a
                                monthly basis until no visible emissions are observed in six consecutive monthly
                                tests.                     (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))
                             3. If no visible emissions are observed during the semi-annual test (utilizing
                                Method 22) , the facility may decrease the frequency to testing to annually. If
                                visible emissions are observed during any annual test, the facility must resume
                                testing on a monthly basis and maintain that schedule until no visible emissions
                                are observed in six consecutive readings.
                                                           (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))
                             4. If visible emissions are observed during any Method 22 test, the facility must
                                conduct 6-minute test of opacity in accordance with Method 9. The Method 9
                                test must begin within one hour of any observation of visible emissions.
                                                             (40 CFR 63, Subpart LLL, Section 63.150 (a)(4)(iv))
                             5. The facility shall maintain files of the required visible emission records in a form
                                suitable and readily available for inspection and review as required by 40 CFR
                                63, Subpart A, Section 63.10 (b)(1). The files shall be retained for at least five
                                years following the date of each occurrence and measurement. At a minimum,
                                the most recent two years of data shall be retained on site. The files may be
                                maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or
                                on microfiche.                       (40 CFR 63, Subpart LLL, Section 63.155(a))
1. Parameter to be           Opacity                               (40 CFR 63, Subpart LLL, Section 63.1349(a))
Tested/Recorded
2. Method/Analysis           EPA Method 9 (as modified) – The performance test shall be conducted at the
                             highest load or capacity as reasonably can be expected. The maximum six-minute
                             average opacity exhibited during the test period shall determine compliance. The
                             duration of the Method 9 Performance Test shall be 3-hours (30-6 minute
                             averages), except that the duration of the Method 9 Performance Test may be
                             reduced to 1-hour if it is found that no individual readings greater than 10 percent
                             opacity and there are no more than three readings of 10 percent for the first 1-hour
                             period.
                             (40 CFR 60, Appendix A-4), (40 CFR 63, Subpart LLL, Section 63.1349 (b)(2))
3. Frequency and Schedule    Performance tests shall be conducted in accordance with Method 9 (as modified)
of Testing/Recordkeeping     within 180 days after initial startup. Visible emission observation procedure must
                             have prior approval by the AQD.                  (40 CFR 63, Subpart A, Sections
                             63.7(a)(2)), (40 CFR 63, Subpart LLL, Section 63.1349(a)), (R336.1213(3))



                                               Page 41 of 131
                                                                                Permit Number: MI-ROP-B1743-2004
                                                                                       Expiration Date: April 27, 2009


TABLE F-1.3 FG003
FLEXIBLE GROUPING REQUIREMENTS
IV. REPORTING
Reports and Schedules                 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                               (R 336.1213(3)(c)(ii))

                                      2. Semiannual reporting of deviations pursuant to Condition 23 of Part a> Due
                                         March 15 for reporting period July 1 to December 31 and September 15 for
                                         reporting period January 1 to June 30.                (R 336.1213(3)(c)(i))

                                      3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part
                                         A. Due annually by March 15 for the previous calendar year.
                                                                                                  (R 336.1213(4)(c))

                                      4. The results of opacity or visible emission evaluations as required under
                                         performance test requirements utilizing EPA Method 9 (as modified) shall
                                         be submitted to AQD within 60 days following the last date of the evaluation.
                                         (See Appendix 5)
                                                                        (40 CFR 63, Subpart A, Section 63.7 (g)(1)

                                  See Appendix 8.
V. OPERATIONAL PARAMETERS
Normal operating pressure drop range for the fabric filter will be provided to the appropriate District Office of the AQD
at the effective date of the ROP.                                                                          (R336.1213(2))
VI. OTHER REQUIREMENTS
1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be
    procedures for proper operation and maintenance of the source and air pollution control devices in order to meet
    the emission and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the source-
    subject to the opacity standards set forth under 40 CFR 63.1348. Such procedures shall include provisions of
    paragraphs 63.1350 (a)(4)(i) thru (iv).                           (40 CFR 63, Subpart LLL, Section 63.1350(a))
2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for
    Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.
                                                          (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)
3. The facility shall install and maintain devices for the measurement of pressure drop across each fabric filter. The
    monitoring device shall be certified by the manufacturer to be accurate within ± 1 inch water gauge pressure and
    must be calibrated on an annual basis in accordance with manufacturer’s instruction.               (R336.1201(3))
* This requirement is state enforceable only.




                                                    Page 42 of 131
                                                                                    Permit Number: MI-ROP-B1743-2004
                                                                                           Expiration Date: April 27, 2009



TABLE F-1.4 FG004
FLEXIBLE GROUPING REQUIREMENTS
FLEXIBLE GROUPING                  FG004 Stone Quarry Crushing
Emission Unit/Process              EG012 Secondary Crusher
Groups
                                   EG015 Tertiary Crusher
I. DESIGN PARAMETERS
A. Pollution Control          DV008-2 Baghouse, Pulse Jet
Equipment
B. Stack/Vent Parameters      Horizontal exhaust.
Stack/Vent ID           a. Minimum      b. Maximum Exhaust                c. Temp (°F)      d. Air Flow       Applicable
                        Height (feet) Dimension (inches)                                    Rate (acfm)       Requirement
SV025                   30              32                                NA                NA                NA
C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                               Maximum Usage Rate
NA
         B. Pollutant                                             Maximum Emission Limit
NA
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                                 A. MONITORING/RECORDKEEPING (R 336.1213(3))
                                    In Addition To General Requirements in Part A
1. Continuous Emission             NA
Monitoring (CEM) System
and Recordkeeping
2. Process Monitoring              NA
System and Recordkeeping
3. Other Monitoring and/or         NA
Recordkeeping
                                   B. TESTING/RECORDKEEPING (R 336.1213(3))
                                   In Addition to General Requirements in Part A
1. Parameter to be                 NA
Tested/Recorded
2. Method/Analysis                 NA
3. Frequency and Schedule          NA
of Testing/Recordkeeping
IV. REPORTING
Reports and Schedules              1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                                 (R 336.1213(3)(c)(ii))

                                   2. Semi-annual reporting of deviations pursuant to Condition 23 of Part A. Due
                                   March 15 for reporting period July 1 to December 31 and September 15 for reporting
                                   period January 1 to June 30.                                  (R 336.1213(3)(c)(i))

                                   3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A.
                                   Due annually by March 15 for the previous calendar year.         (R 336.1213(4)(c))
                                   See Appendix 8.
V. OPERATIONAL PARAMETERS
NA


                                                      Page 43 of 131
                                                                             Permit Number: MI-ROP-B1743-2004
                                                                                    Expiration Date: April 27, 2009


TABLE F-1.4 FG004
FLEXIBLE GROUPING REQUIREMENTS
VI. OTHER REQUIREMENTS
Fugitive emissions control addressed in the “Fugitive Dust Plan” Attachment 1.                      (R336.1201(3))
* This requirement is state enforceable only.




                                                  Page 44 of 131
                                                                                    Permit Number: MI-ROP-B1743-2004
                                                                                           Expiration Date: April 27, 2009



TABLE F-1.5 FG005
FLEXIBLE GROUPING REQUIREMENTS
FLEXIBLE GROUPING                  FG005 Cement Bagging Operation
Emission Unit/Process              EG032 Masonry bagging (3 units)
Groups
                                   EG033 Cement bagging (3 units)
I. DESIGN PARAMETERS
A. Pollution Control               DV032-2 Fabric Filter
Equipment
                                   DV033-2 Fabric Filter
B. Stack/Vent Parameters           Exhaust gases shall be discharged unobstructed vertically upwards unless
                                   otherwise noted.
Stack/Vent ID                a. Minimum      b. Maximum Exhaust c. Temp (°F) d. Air Flow              Applicable
                             Height (feet) Dimension (inches)                        Rate (acfm)      Requirement
SV035                        53              18                      NA              NA               NA
SV036                        53              18                      NA              NA               NA
C. Other Design Parameters
Collectors DV032-2 & DV033-2 will each be equipped with pressure drop gauge approved by District Staff
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                               Maximum Usage Rate
Cement, Mortar                     140,000 tpy                                                                (R336.1201(3))
         B. Pollutant                                          Maximum Emission Limit
1. Particulate Matter              0.04 lbs/1000 lbs exhaust gas, calculated on a dry basis.                  (R336.1201(3))
2. PM (Opacity)                    5% Opacity                                                                 (R336.1201(3))
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                                 A. MONITORING/RECORDKEEPING (R 336.1213(3))
                                    In Addition To General Requirements in Part A
1. Continuous Emission             NA
Monitoring (CEM) System
and Recordkeeping
2. Process Monitoring              The pressure drop across the fabric filters shall be monitored and recorded once per
System and Recordkeeping           day when filling bags. Recordings reflecting values outside of the range set forth in
                                   V-OPERATIONAL PARAMETERS will require the facility to initiate corrective action
                                   per the facility’s operations and maintenance plan.                   (R336.1213(3))
3. Other Monitoring and/or         NA
Recordkeeping
                                   B. TESTING/RECORDKEEPING (R 336.1213(3))
                                   In Addition to General Requirements in Part A
1. Parameter to be                 Opacity                      (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4))
Tested/Recorded
2. Method/Analysis                 1. EPA Method 22                                        (40 CFR 60, Appendix A-7)
                                   2. EPA Method 9                                         (40 CFR 60, Appendix A-4)
3. Frequency and Schedule          1. Monthly 1-minute visible emissions test in accordance with Method 22.
of Testing/Recordkeeping                                          (40 CFR 63, Subpart LLL Section 63.1350 (a)(4))(i))
                                   2. If no emissions are observed in six consecutive months (utilizing Method 22),
                                      testing may be decreased from monthly to semi-annually. If visible emissions
                                      are observed during any semi-annual test, the facility must resume testing on a
                                      monthly basis until no visible emissions are observed in six consecutive monthly
                                      tests.                     (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))
                                   3. If no visible emissions are observed during the semi-annual test (utilizing
                                      Method 22) , the facility may decrease the frequency to testing to annually. If

                                                      Page 45 of 131
                                                                               Permit Number: MI-ROP-B1743-2004
                                                                                      Expiration Date: April 27, 2009


TABLE F-1.5 FG005
FLEXIBLE GROUPING REQUIREMENTS
                                    visible emissions are observed during any annual test, the facility must resume
                                    testing on a monthly basis and maintain that schedule until no visible emissions
                                    are observed in six consecutive readings.
                                                               (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))
                                 4. If visible emissions are observed during any Method 22 test, the facility must
                                    conduct a 6-minute test of opacity in accordance with Method 9. The Method 9
                                    test must begin within one hour of any observation of visible emissions.
                                                                 (40 CFR 63, Subpart LLL, Section 63.150 (a)(4)(iv))
                                 5. The facility shall maintain files of the required visible emission records in a form
                                    suitable and readily available for inspection and review as required by 40 CFR
                                    63, Subpart A, Section 63.10 (b)(1). The files shall be retained for at least five
                                    years following the date of each occurrence and measurement. At a minimum,
                                    the most recent two years of data shall be retained on site. The files may be
                                    maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or
                                    on microfiche.                       (40 CFR 63, Subpart LLL, Section 63.155(a))
IV. REPORTING
Reports and Schedules            1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                              (R 336.1213(3)(c)(ii))

                                 2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. Due
                                    March 15 for reporting period July 1 to December 31 and September 15 for
                                    reporting period January 1 June 30.                       (R 336.1213(3)(c)(i))

                                 3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A.
                                    Due annually by March 15 for the previous calendar year.     (R 336.1213(4)(c))

                                 See Appendix 8.
V. OPERATIONAL PARAMETERS
Normal operating pressure drop range for the fabric filters will be provided to the appropriate District Office of the
AQD within 90 days of the effective date of the ROP.                                    (R336.1201(3) & R336.1213(2))
VI. OTHER REQUIREMENTS
1. The facility shall immediately clean up and properly dispose of any product spillage.               (R336.1201(3))
2. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be
    procedures for proper operation and maintenance of the source and air pollution control devices in order to meet
    the emission and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the source-
    subject to the opacity standards set forth under 40 CFR 63.1348. Such procedures shall also include provisions
    of paragraphs 63.1350 (a)(4)(i) thru (iv).       (40 CFR 63, Subpart LLL, Section 63.1350 (a) & (R336.1201(3))
3. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for
    Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.
                                                         (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)
* This requirement is state enforceable only.




                                                   Page 46 of 131
                                                                                    Permit Number: MI-ROP-B1743-2004
                                                                                           Expiration Date: April 27, 2009



TABLE F-1.6 FG006
FLEXIBLE GROUPING REQUIREMENTS
FLEXIBLE GROUPING                  FG006 Bulk cement loading to trucks (customer silos)
Emission Unit/Process              EG011-7 Bulk cement loading to trucks – Scale No. 5
Groups
                                   EG011-8 Bulk cement loading to trucks – Scale No. 6
I. DESIGN PARAMETERS
A. Pollution Control               DV011-7-2 Fabric Filter
Equipment
                              DV011-8-2 Fabric Filter
B. Stack/Vent Parameters      Exhaust gases discharged horizontally.
Stack/Vent ID           a. Minimum     b. Maximum Exhaust c. Temp (°F)                      d. Air Flow       Applicable
                        Height (feet) Dimension (inches)                                    Rate (acfm)       Requirement
SV041                   52             20                      NA                           NA                NA
SV042                   52             20                      NA                           NA                NA
C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                               Maximum Usage Rate
NA
       B. Pollutant                                               Maximum Emission Limit
PM (Opacity)                       10% Opacity                           (40 CFR 63, Subpart LLL, Section 63.1348)
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                                 A. MONITORING/RECORDKEEPING (R 336.1213(3))
                                    In Addition To General Requirements in Part A
1. Continuous Emission
Monitoring (CEM) System
and Recordkeeping
2. Process Monitoring              The pressure drop across the fabric filters shall be monitored and recorded once per
System and Recordkeeping           day when filling bags. Recordings reflecting values outside of the range set forth in
                                   V-OPERATIONAL PARAMETERS will require the facility to initiate corrective action
                                   per the facility’s operations and maintenance plan.                   (R336.1213(3))
3. Other Monitoring and/or
Recordkeeping
                                   B. TESTING/RECORDKEEPING (R 336.1213(3))
                                   In Addition to General Requirements in Part A
1. Parameter to be                 Opacity                      (40 CFR 63, Subpart LLL, Section 63.150 (a)(4))
Tested/Recorded
2. Method/Analysis                 EPA Method 22                                           (40 CFR 60, Appendix A-7)
                                   EPA Method 9                                            (40 CFR 60, Appendix A-4)
3. Frequency and Schedule          1. Monthly 1-minute visible emissions test in accordance with Method 22.
of Testing/Recordkeeping                                         (40 CFR 63, Subpart LLL Section 63.1350 (a)(4))(i))
                                   2. If no emissions are observed in six consecutive months (utilizing Method 22),
                                      testing may be decreased from monthly to semi-annually. If visible emissions
                                      are observed during any semi-annual test, the facility must resume testing on a
                                      monthly basis until no visible emissions are observed in six consecutive monthly
                                      tests.                    (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))
                                   3. If no visible emissions are observed during the semi-annual test (utilizing
                                      Method 22) , the facility may decrease the frequency to testing to annually. If
                                      visible emissions are observed during any annual test, the facility must resume
                                      testing on a monthly basis and maintain that schedule until no visible emissions


                                                      Page 47 of 131
                                                                                Permit Number: MI-ROP-B1743-2004
                                                                                       Expiration Date: April 27, 2009


TABLE F-1.6 FG006
FLEXIBLE GROUPING REQUIREMENTS
                                    are observed in six consecutive readings.
                                                               (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))
                                 4. If visible emissions are observed during any Method 22 test, the facility must
                                    conduct a 6-minute test of opacity in accordance with Method 9. The Method 9
                                    test must begin within one hour of any observation of visible emissions.
                                                                 (40 CFR 63, Subpart LLL, Section 63.150 (a)(4)(iv))
                                 5. The facility shall maintain files of the required visible emission records in a form
                                    suitable and readily available for inspection and review as required by 40 CFR
                                    63, Subpart A, Section 63.10 (b)(1). The files shall be retained for at least five
                                    years following the date of each occurrence and measurement. At a minimum,
                                    the most recent two years of data shall be retained on site. The files may be
                                    maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or
                                    on microfiche.                       (40 CFR 63, Subpart LLL, Section 63.155(a))
IV. REPORTING
Reports and Schedules            1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                              (R 336.1213(3)(c)(ii))

                                 2. Semiannual reporting of deviations pursuant to Condition 23 of Part A. Due
                                    March 15 for reporting period July 1 to December 31 and September 15 for
                                    reporting period January 1 to June 30.                    (R 336.1213(3)(c)(i))

                                 3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part A.
                                    Due annually by March 15 for the previous calendar year.     (R 336.1213(4)(c))

                                 See Appendix 8.
V. OPERATIONAL PARAMETERS
Normal operating pressure drop range of the fabric filters will be provided to the appropriate District Office of the AQD
within 90 days of the effective date of the ROP.                                                         (R336.1213(2))
VI. OTHER REQUIREMENTS
1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be
    procedures for proper operation and maintenance of the source and air pollution control devices in order to meet
    the emission and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the source-
    subject to the opacity standards set forth under 40 CFR 63.1348. Such procedures shall also include provisions
    of paragraphs 63.1350 (a)(4)(i) thru (iv).                       (40 CFR 63, Subpart LLL, Section 63.1350(a))
2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for
    Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.
                                                         (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)
* This requirement is state enforceable only.




                                                    Page 48 of 131
                                                                                    Permit Number: MI-ROP-B1743-2004
                                                                                           Expiration Date: April 27, 2009



TABLE F-1.7 FG007
FLEXIBLE GROUPING REQUIREMENTS
FLEXIBLE GROUPING                  FG007 Clinker Coolers
Emission Unit/Process              EG002-1 Clinker Cooler No. 1
Groups
                                   EG002-2 Clinker Cooler No. 2
I. DESIGN PARAMETERS
A. Pollution Control          DV002-2 Baghouse on No. 1 Clinker Cooler (Consent Judgment 00-1363-CZ, Part
Equipment                     IV 4.1.C.)
                              DV002-3 Baghouse on No. 2 Clinker Cooler (Consent Judgment 00-1363-CZ, Part
                              IV 4.1.C.)
B. Stack/Vent Parameters      Exhaust gases shall be discharged unobstructed vertically upwards unless
                              otherwise noted.
Stack/Vent ID           a. Minimum       b. Maximum Exhaust c. Temp (°F) d. Air Flow             Applicable
                        Height (feet) Dimension (inches)                        Rate (acfm)      Requirement
SV002-1                 92               78                     NA              NA               NA
SV002-2                 92               78                     NA              NA               NA
C. Other Design Parameters
N/A, not necessary due to COM
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                               Maximum Usage Rate
NA
         B. Pollutant                                           Maximum Emission Limit
1. Particulate Matter              1. 0.10 lbs/1000 lbs exhaust gas, calculated on a dry basis.
                                                   (R336.331(a)(1) & Consent Judgment 00-1363-CZ, Part IV 4.1.D)
                                   2. 0.050 Kg per Mg of dry feed to the kiln
                                                                     (40 CFR 63, Subpart LLL, Section 63.1345 (a)(1))
                                   3. 0.1 lb per ton of dry feed to the kiln
                                                                     (40 CFR 63, Subpart LLL, Section 63.1345 (a)(1))
2. PM (Opacity)                    10% Opacity          (R336.1213(3) (40 CFR 63, Subpart LLL, Section 63.1345(2))
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                                 A. MONITORING/RECORDKEEPING (R 336.1213(3))
                                    In Addition To General Requirements in Part A
1. Continuous Emission             NA
Monitoring (CEM) System
and Recordkeeping
2. Process Monitoring              NA
System and Recordkeeping
3. Other Monitoring and/or         COMs shall be installed, calibrated, maintained, and operated in accordance with
Recordkeeping                      the procedures in 40 CFR 60.13 and Performance Specification 1 (“PS1”) of
                                   Appendix B, 40 CFR Part 60. The span value shall be 2.0 times the lowest emission
                                   standard or as specified in the federal regulations.
                                   (Consent Judgment 00-1363-CZ, Part 4.3.A.) & (40 CFR 63, Subpart LLL,
                                   Section 63.1350(d)(1)&(40CFR60, Subpart F 60.63(b))
                                   B. TESTING/RECORDKEEPING (R 336.1213(3))
                                    In Addition to General Requirements in Part A
1. Parameter to be                 NA
Tested/Recorded
2. Method/Analysis                 NA
3. Frequency and Schedule          NA
of Testing/Recordkeeping


                                                      Page 49 of 131
                                                                              Permit Number: MI-ROP-B1743-2004
                                                                                     Expiration Date: April 27, 2009


TABLE F-1.7 FG007
FLEXIBLE GROUPING REQUIREMENTS
IV. REPORTING
Reports and Schedules                1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                              (R 336.1213(3)(c)(ii))
                                     2. Quarterly reporting of EER and summary report, due 30 days at the end of
                                        each calendar quarter.      (Consent Judgment 00-1363-CZ, Part 4.3.B.),
                                        (R336.1213(3)(c)(i), (40 CFR 63, Subpart A, Section 63.10(e)(3))

                                     3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part
                                        A. Due annually by March 15 for the previous calendar year.
                                                                                                  (R 336.1213(4)(c))

                                 See Appendix 8.
V. OPERATIONAL PARAMETERS
NA
VI. OTHER REQUIREMENTS
1. The facility will have in place a Preventative Maintenance/Malfunction Abatement Program for the baghouse
    control system.                                          (R336.911) (Consent Judgment 00-1363-CZ, Part 4.1.E)
2. The facility will have in place a written operations and maintenance plan which will include:
    Procedures for proper operation and maintenance of the affected source and baghouse control devices in order
    to meet the emission limits and operating limits noted in 63.1345.
                                                                        (40 CFR 63, Subpart LLL, Section 63.1350(a))
3. The facility shall have in place a written “startup, shutdown, and malfunction plan,” that describes in detail,
    procedures for operating and maintaining the source during periods of startup, shutdown, and malfunction and a
    program of corrective action for malfunctioning process and air pollution control equipment used to comply with
    the relevant standard. The plan shall identify all routine or otherwise predictable CMS malfunctions.
                                                                              (40 CFR 63, Subpart A, Section 63.6 (e))
4. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for
    Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.
                                                            (R336.1201(a))&(R336.1205(1)) (40 CFR 63, Subpart LLL)
5. The facility shall perform an annual audit of the COMs using the procedures set forth in the USEPA publication
    No. 450/4-92-010, “Performance Audits Procedures for Opacity Monitors,” and all amendments thereto. The
    results of the annual audit shall be submitted to the AQD Jackson District Supervisor within 30 days of
    completion.                                                           (Consent Judgment 00-1363-CZ, Part 4.3.C)
* This requirement is state enforceable only.




                                                   Page 50 of 131
                                                                          Permit Number: MI-ROP-B1743-2004
                                                                                 Expiration Date: April 27, 2009


TABLE F-1.8 FG008
FLEXIBLE GROUPING REQUIREMENTS
FLEXIBLE GROUPING                    FG008 No. 1 & No. 2 Wet process cement kilns
Emission Unit/Process Groups         EG003-1 No. 1 Cement Kiln
                                     EG003-2 No. 2 Cement Kiln
I. DESIGN PARAMETERS
A. Pollution Control Equipment       DV003-5 Dry Scrubber (with activated carbon) & DV003-2 Baghouse;
                                     or
                                     DV003-2 Baghouse & DV003-3 Limestone Slurry Scrubber-Packed Tower &
                                     DV003-4 Three RTO’s in Parallel

                                     DV003-10 Dry Scrubber (with activated carbon) & DV003-7 Baghouse
                                     or
                                     DV003-7 Baghouse & DV003-8 Limestone Slurry Scrubber-Packed Tower &
                                     DV003-9 Three RTO’s in Parallel
B. Stack/Vent Parameters             Exhaust gases shall be discharged unobstructed vertically upwards unless
                                     otherwise noted.
          Stack/Vent ID              a.   Minimum       b. Maximum           c. Temp      d. Air       Applicable
                                          Height      Exhaust Dimension         (°F)       Flow       Requirement
                                           (feet)          (inches)                        Rate
                                                                                          (acfm)
1. SV001                        350                180                                               R336.1225
C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
            A. Material                                      Maximum Usage Rate
1. Kiln Feed                    1. 2,237,596 tons of dry feed in both kilns, DV003-1 & DV003-6 per year based
                                    on a 12-month rolling time period as determined at the end of each calendar
                                    month. Dry feed shall be defined as any dry material fed to the kiln(s),
                                    including: limestone, clay, flyash, bottom ash, silica gel, by-product and
                                    excluding solid fuels such as coal and pet coke.
                                                                              (R336.1201(1)(a)) & (R336.1205(1))
2. TDF                          1. < 4.6 tph per kiln, based upon a 24-hour average calculated at the and of
                                    each hour. (Conventional Firing Mode). (R336.1201(1)(a)) & (R336.1205(1))
                                2. < 21% of the total fuel heat input to a kiln (Conventional Firing Mode)
                                                                             (R336.1201(1)(a)) & (R336.1205(1))
                                3. ≥ 4.6% tph fuel or ≥ 21% of the total fuel heat input to a kiln (AFM Firing
                                    Mode)                                      (R336.1201(1)(a)) & (R336.1205(1))
3. Coke                         1. 25% of the total hourly fuel heat input to a kiln (Conventional Firing Mode)
                                                                             (R336.1201(1)(a)) & (R336.1205(1))
                                2. >25% of the total fuel heat input to a kiln (AFM Firing Mode)
                                                                               (R336.1201(1)(a)) & (R336.1205(1))
4. Coal                         Up to 100% of the total fuel heat input to a kiln.
                                                                              (R336.1201(1)(a)) & (R336.1205(1))
5. Used/Waste Oil               1. Specification used oil generated onsite and offsite for kiln startups.
                                    (Conventional Firing Mode) (See Appendix 5)
                                                                              (R336.1201(1)(a)) & (R336.1205(1))
                                2. Up to 100% of the total fuel heat input to a kiln (AFM Firing Mode)
                                                                               (R336.1201(1)(a)) & (R336.1205(1))
6. Asbestos                     No detectable amounts (AFM Firing Mode)                               (R336.1225)
7. Chloride                     Content in the fuels (AFM Firing Mode) shall be ≤ 5,000 ppm.          (R336.1225)
8. Hazardous Waste              1. No fuels shall contain such materials as defined in RCRA.
                                                                          (See Appendix 5) (RCRA 40 CFR 261)
                                2. No fuels shall be applicable to F, K, P, or U Hazardous Waste Listing
                                    Description of RCRA.                                      (RCRA 40 CFR 261)


                                               Page 51 of 131
                                                                           Permit Number: MI-ROP-B1743-2004
                                                                                  Expiration Date: April 27, 2009


TABLE F-1.8 FG008
FLEXIBLE GROUPING REQUIREMENTS
9. Radioactive Materials             No fuels shall contain such materials          (R336.1201(1)(a)) & (R336.1205(1))
10. Biological or Infectious Waste   No fuels shall contain such materials including but not limited to hospital or
                                     medical wastes.                                (R336.1201(1)(a)) & (R336.1205(1))
11. PCB                              Content in fuels shall be ≤ 49 ppm                              (RCRA 40 CFR 261)
12. Heating Content                  No fuels, in the AFM Firing Mode, shall have a heat content of <4,000 BTU’s per
                                     pound.                                         (R336.1201(1)(a)) & (R336.1205(1))
13. Municipal Solid Waste            No fuels shall contain such materials.         (R336.1201(1)(a)) & (R336.1205(1))
14. Natural Gas                      Up to 100% of the total fuel heat input to a kiln.
                                                                                     (R336.1201(1)(a)) & (R336.1205(1))
15. Diesel Fuel                      Up to 100% of the total fuel heat input to a kiln.
                                                                                     (R336.1201(1)(a)) & (R336.1205(1))
           B. Pollutants                                         Maximum Emission Limit
1. Particulate Matter                1. 0.30 lbs/ton of dry feed to the kiln, based on a 12-month rolling time period
                                         as determined at the end of each calendar month.
                                         (40 CFR 63, Subpart LLL, Section 63.1343(b)(1)) & (R336.1201(1)(a)) &
                                         (R336.1205(1))
                                     2. 0.15 Kg per Mg of dry feed to the kiln
                                                                    (40 CFR 63, Subpart LLL, Section 63.1343(b)(1))
2. PM (Opacity)                      Except as provided in V OPERATIONAL PARAMETERS, Article 7, visible
                                     emissions from the kilns shall not exceed a 6-minute average of 15 percent
                                     opacity in the stack based on the continuous opacity monitoring system. When
                                     there is a detached plume from the kilns during, but not limited to, visible
                                     emission monitoring outages, malfunction and/or calibrations, the visible
                                     emissions shall not exceed a 6-minute average of 20 percent opacity at the
                                     stack. If the COM downtime, during daylight hours, exceeds 6 hours, Holcim
                                     (US) Inc. staff or representatives certified in performing visible emission
                                     evaluations in accordance with 40 CFR Part 60, Appendix A, Reference Method
                                     9, as modified to read only at the top of the kiln stack, shall conduct visual
                                     opacity observations in accordance with 40 CFR 63, Subpart LLL, Section
                                     63.1350(c)(2). The duration of the Method 9 observation shall be for at least 30
                                     minutes in duration for each day.
                                                                 (R336.1201(1)(a)) & (R336.1205(1)), (R336.1213(2))
3. SO2                               11,940 tpy based on a 12-month rolling period as determined at the end of each
                                     calendar month for both kilns DV003-1 & DV003-6.
                                                                                     (R336.1201(1)(a)) & (R336.1205(1))
4. NOx                               1. 3,377 tpy based on a 12-month rolling period as determined at the end of
                                         each calendar month for kilns DV003-1 & DV003-6.
                                                                                    (R336.1201(1)(a)) & (R336.1205(1))
                                     2. 6 lbs of NOx per ton of clinker produced. Compliance shall be attained after
                                         May 31, 2004. Compliance with this emission limit shall be maintained
                                         between the time period of May 1 thru September 30 for year 2004 and
                                         future years.       (R336.1201(1)(a)) & (R336.1205(1)), (R336.1817(5)(b)(i))
5. CO                                3,515 tpy, based on a 12-month rolling period as determined at the end of each
                                     calendar month.                                 (R336.1201(1)(a)) & (R336.1205(1))
6. VOC                               7,217 tpy, based on a 12-month rolling period as determined at the end of each
                                     calendar month.                                 (R336.1201(1)(a)) & (R336.1205(1))
                                                                      -11
7. D/F                               1. 0.20 ng per dscm (8.7 x 10 gr per dscf)(TEQ) corrected to 7% O2 for inlet
                                         temperatures to the baghouse of >204°C (400°F). Compliance shall be
                                         based on inlet temperatures to the baghouse control system average over
                                         the performance tests, utilizing EPA Method 23.               (See Appendix 5)
                                                    (R336.1205(1), (40 CFR 63, Subpart LLL, Section 63.1343(d)(1))
                                                                      -10
                                     2. 0.40 ng per dscm (1.7 x 10 gr per dscf) (TEQ) corrected to 7% O2 for inlet
                                         temperatures to the baghouse of ≤ 204°C (400°F). Compliance shall be
                                         based on inlet temperatures to the baghouse control system average over


                                               Page 52 of 131
                                                            Permit Number: MI-ROP-B1743-2004
                                                                   Expiration Date: April 27, 2009


TABLE F-1.8 FG008
FLEXIBLE GROUPING REQUIREMENTS
                            the performance tests, utilizing EPA Method 23. See Appendix 5)
                            (R336.1201(1)(a)) & (R336.1205(1)), (40 CFR 63, Subpart LLL, Section
                            63.1343(d)(2))
8. Hg                  115 ppy for both kilns DV003-1 & DV003-6. (AFM Firing Mode), based on a 12-
                       month rolling time period, as determined at the end of each calendar month.
                       Compliance with the limit shall be demonstrated by the methodology contained
                       in Table F-1.8, V.18 OPERATIONAL PARAMETERS.                        (R336.1225)
9. Pb                  0.6 tpy, for both kilns, (AFM Firing Mode), based on a 12-month rolling time
                       period, as determined at the end of each calendar month compliance with the
                       limit shall be demonstrated by the methodology contained in Table F-1.8, V.18
                       OPERATIONAL PARAMETERS.                                             (R336.1225)
10. Sb                 0.2 µg/cubic meter, based on a 24 hour averaging period for both kilns. (AFM
                       Firing Mode) (expressed as a maximum ambient concentration) compliance
                       with the limit shall be demonstrated by the methodology contained in Table F-
                       1.8, V.18 OPERATIONAL PARAMETERS.                                   (R336.1225)

                       5.6 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack
                       concentration)                                                    (R336.1225)
11. As                 0.0002 µg/cubic meter, based on a 12-month rolling time period as determined
                       at the end of each calendar month. (AFM Firing Mode) (expressed as a
                       maximum ambient concentration) compliance with the limit shall be
                       demonstrated by the methodology contained in Table F-1.8, V.18
                       OPERATIONAL PARAMETERS.                                           (R336.1225)

                       67.2 µg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack
                       concentration.                                                    (R336.1225)
12. Ba                 5 µg/cubic meter, based on a 8-hour averaging period. (AFM Firing Mode)
                       (expressed as a maximum ambient concentration) compliance with the limit
                       shall be demonstrated by the methodology contained in Table F-1.8, V.18
                       OPERATIONAL PARAMETERS.                                           (R336.1225)

                       65.2 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack
                       concentration.                                                   (R336.1225)
13. Be                 0.02 µg/cubic meter, based on a 24-hour averaging period. (AFM Firing Mode)
                       (expressed as a maximum ambient concentration) compliance with the limit
                       shall be demonstrated by the methodology contained in Table F-1.8, V.18
                       OPERATIONAL PARAMETERS.                                          (R336.1225)

                       560 µg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack
                       concentration).                                                   (R336.1225)
14. Cd                 0.0006 µg/cubic meter, based on a 12-month rolling time period as determined
                       at the end of each calendar month. (AFM Firing Mode) (expressed as a
                       maximum ambient concentration) compliance with the limit shall be
                       demonstrated by the methodology contained in Table F-1.8, V.18
                       OPERATIONAL PARAMETERS.                                           (R336.1225)

                       201.6 µg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack
                       concentration).                                                   (R336.1225)
15. Cr                 0.000083 µg/cubic meter, based on a 12-month rolling time period as
                       determined at the end of each calendar month. (AFM Firing Mode) (expressed
                       as a maximum ambient concentration) compliance with the limit shall be
                       demonstrated by the methodology contained in Table F-1.8, V.18
                       OPERATIONAL PARAMETERS.                                           (R336.1225)

                       27.9 µg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack


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FLEXIBLE GROUPING REQUIREMENTS
                       concentration).                                                  (R336.1225)
16. Cu                 2 µg/cubic meter, based on an 8-hour averaging period. (AFM Firing Mode)
                       (expressed as a maximum ambient concentration) compliance with the limit
                       shall be demonstrated by the methodology contained in Table F-1.8, V.18
                       OPERATIONAL PARAMETERS.                                          (R336.1225)

                       26.1 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack
                       concentration).                                                  (R336.1225)
17. Mn                 0.05 µg/cubic meter, based on a 24-hour averaging period. (AFM Firing Mode)
                       (expressed as a maximum ambient concentration) compliance with the limit
                       shall be demonstrated by the methodology contained in Table F-1.8, V.18
                       OPERATIONAL PARAMETERS.                                          (R336.1225)

                       1.4 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack
                       concentration).                                                   (R336.1225)
18. Ni                 0.0042 µg/cubic meter, based on a 12 month rolling time period as determined
                       at the end of each calendar month. (AFM Firing Mode) (expressed as a
                       maximum ambient concentration) compliance with the limit shall be
                       demonstrated by the methodology contained in Table F-1.8, V.18
                       OPERATIONAL PARAMETERS.                                           (R336.1225)

                       1.4 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack
                       concentration).                                                   (R336.1225)
19. Se                 2 µg/cubic meter, based on an 8-hour averaging period. (AFM Firing Mode)
                       (expressed as a maximum ambient concentration) compliance with the limit
                       shall be demonstrated by the methodology contained in Table F-1.8, V.18
                       OPERATIONAL PARAMETERS.                                           (R336.1225)

                       26.1 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack
                       concentration).                                                   (R336.1225)
20. Ag                 0.1 µg/cubic meter, based on an 8-hour averaging period. (AFM Firing Mode)
                       (expressed as a maximum ambient concentration) compliance with the limit
                       shall be demonstrated by the methodology contained in Table F-1.8, V.18
                       OPERATIONAL PARAMETERS.                                           (R336.1225)

                       1.3 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack
                       concentration).                                                    (R336.1225)
21. Tl                 0.1 µg/cubic meter, based on a 12- month rolling time period as determined at
                       the end of each calendar month. (AFM Firing Mode) (expressed as a maximum
                       ambient concentration) compliance with the limit shall be demonstrated by the
                       methodology contained in Table F-1.8, V.18 OPERATIONAL PARAMETERS.
                                                                                          (R336.1225)

                       33.6 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack
                       concentration).                                                    (R336.1225)
22. Zn                 0.1 µg/cubic meter, based on a 12-month rolling time period as determined at
                       the end of each calendar month. (AFM Firing Mode) (expressed as a maximum
                       ambient concentration) compliance with the limit shall be demonstrated by the
                       methodology contained in Table F-1.8, V.18 OPERATIONAL PARAMETERS.
                                                                                          (R336.1225)

                       33.6 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack
                       concentration).                                                   (R336.1225)
23. C10H7NH2           436.8 µg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack
                       concentration).                                                   (R336.1225)


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FLEXIBLE GROUPING REQUIREMENTS
24. C6H3ClNH2C6H3ClNH2                     6.7 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack
                                           concentration).                                                   (R336.1225)
25. BrCH2CH2Br                             16.8 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack
                                           concentration).                                                   (R336.1225)
26. C6Cl6                                  6.7 mg/cubic meter (AFM Firing Mode) (Limit is expressed as an in stack
                                           concentration).                                                   (R336.1225)
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                           A. MONITORING/RECORDKEEPING (R 336.1213(3))
                              In Addition to General Requirements in Part A
1. Continuous Emission            1. Facility shall monitor and record the sulfur dioxide, nitrogen dioxide, carbon
   Monitoring (CEM) System and        monoxide, and total hydrocarbon emissions from the cement kiln’s common
   Recordkeeping                      exhaust duct or stack on a continuous basis in a manner and with
                                      instrumentation acceptable to the AQD.
                                                                                   (R336.1201(1)(a)) & (R336.1205(1))
                                  2. The NOx CEM shall be installed, calibrated, maintained, and operated in
                                      accordance with the procedures set forth in 40 CFR 60.13 and PS2 of
                                      Appendix B of 40 CFR Part 60 and quality assurance procedures in
                                      Appendix F, 40 CFR Part 60; or utilize 40 CFR, Part 75 and Appendices A &
                                      B for these similar requirements. The span value shall be 2.0 times the
                                      lowest emission standard or as specified in the federal regulations.
                                                          (R336.1201(1)(a)) & (R336.1213(3)) & (R336.1817(8)(b))
                                  3. The SO2 CEM shall be installed, calibrated, maintained, and operated in
                                      accordance with the procedures set forth in 40 CFR 60.13 and PS2 of
                                      Appendix B of 40 CFR Part 60. Quality assurance procedures shall be in
                                      place utilizing 40 CFR Part 60, Appendix F. The span value shall be 2.0
                                      times the lowest emission standard or as specified in the federal
                                      regulations.                                (R336.1201(1)(a)) & (R336.1213(3))
                                  4. The CO CEM shall be installed, calibrated, maintained, and operated in
                                      accordance with the procedures set forth in 40 CFR 60.13 and PS4B of
                                      Appendix B of 40 CFR Part 60. Quality assurance procedures shall be in
                                      place utilizing 40 CFR Part 60, Appendix F. The span value shall be 2.0
                                      times the lowest emission standard or as specified in the federal
                                      regulations.                                 (R336.1201(1)(a)) & (R336.1213(3))
                                  5. The THC CEM shall be installed, calibrated, maintained, and operated in
                                      accordance with the procedures set forth in 40 CFR 60.13 and PS8A of
                                      Appendix B of 40 CFR Part 60. Quality assurance procedures shall be in
                                      place utilizing 40 CFR Part 60, Appendix F. The span value shall be 2.0
                                      times the lowest emission standard or as specified in the federal
                                      regulations.                                 (R336.1201(1)(a)) & (R336.1213(3))
                                  6. Installation and operation of the SO2, NOx, CO and the CEM monitoring
                                      systems shall meet the following timelines:
                                      a. Upon issuance of the ROP, the facility shall submit two copies of a
                                           Monitoring Plan to the AQD, for review and approval. The Monitoring
                                           Plan shall include drawings on specifications showing proposed
                                           locations and descriptions of the required CEMS. The CEMS
                                           monitoring system will replace the proposed scrubber/RTO CEMS
                                           monitoring system required under Permit 60-71L as proposed in the
                                           monitoring plan previously submitted under Permit 60-71L on
                                           October 18, 2000.
                                      b. By April 24, 2004, the facility shall submit two copies of a complete test
                                           plan for the CEMS to the AQD for approval.
                                      c. Within 90 calendar days after AQD’s approval of the test plan, the
                                           facility shall complete the installation and testing of the CEMS.
                                      d. Within 60 days after completion and testing of the CEMS, the facility


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FLEXIBLE GROUPING REQUIREMENTS
                                       shall submit to the AQD two copies of the final report demonstrating
                                       the CEMS comply with the requirements of Performance.
                                       Specifications PS2 for NOx and SO2, Performance Specification PS4B
                                       for CO and Performance Specification PS8A for THC.
                                  e. Each calendar quarter, the facility shall perform QAP of the CEMS as
                                       set forth in Appendix F of 40 CFR, Part 60.
                                  f. In accordance with 40 CFR 60.7(c) & (d), and 40 CFR 63.10 (e)(3) the
                                       facility shall generate an EER and Summary Report in an acceptable
                                       format to the AQD. The Summary Report shall follow the format of
                                       Figure 1 in 40 CFR 60.7 (d). The EER shall include the following
                                       information.
                                       1.        A report of each exceedance above the limits specified in II.B. 2
                                                 & 3. MATERIAL USAGE/EMISSION LIMITS – POLLUTANTS.
                                                 This includes the date, time, magnitude, cause and corrective
                                                 actions of all occurrences.
                                       2.        A report of all periods of CEMS downtime and corrective action.
                                       3.        A report of the total operating time of the cement kilns during
                                                 the reporting period.
                                       4.        If no exceedances or CEMS downtime occurred during the
                                                 reporting period, the facility shall report that fact.
                                       5.        A report of any periods that the CEMS exceed the instrument
                                                 range.
                                  g. The SO2, NO2, and CO CEMS shall be used to determine compliance
                                       with the respective limits noted in II.B. MATERIAL USAGE/EMISSION
                                       LIMITS- POLLUTANTS.
                                  h. The THC CEM shall be used to determine compliance with the VOC
                                  emission limit, as noted in II.B. MATERIAL USAGE/EMISSION LIMITS-
                                  POLLUTANTS. The date collected from the THC CEM will be adjusted to
                                  subtract non-VOC emissions. Within 60 days from issuance of the ROP the
                                  facility shall submit to the District Supervisor, AQD for approval a protocol
                                  depicting the method of converting THC CEM data to VOC emissions.
                                                                               (R336.1201(1)(a)) & (R336.1205(1))
2. Process Monitoring System   1. Facility shall monitor and record hourly the amount of TDF and coal/coke
   and Recordkeeping              mixture fired in the kilns and calculate the TDF 24-hour average usage rate
                                  in a manner and with instrumentation acceptable to the AQD. All records
                                  including the measured TDF and coal/coke mixture hourly usage rate, the
                                  calculated TDF and coke hourly heat input rates, and the calculated TDF
                                  24-hour average usage rate shall be kept on file for a period of at least five
                                  years and made available to the AQD upon request.
                                                                               (R336.1201(1)(a)) & (R336.1205(1))
                               2. Facility shall monitor and record the kiln feed rate every two hours in a
                                  manner and with instrumentation acceptable to the AQD. Facility shall use
                                  the kiln feed rate to calculate bi-hourly production rates. All records shall be
                                  kept on file for a period of at least five years and made available to the AQD
                                  upon request.                                (R336.1201(1)(a)) & (R336.1205(1))
                               3. Facility shall monitor and record the gas temperature at the inlet of the kiln’s
                                  particulate control device on a continuous basis in a manner and with
                                  instrumentation acceptable to the AQD. All records shall be kept on file for
                                  a period of at least five years and made available to the AQD upon request.
                                  (40 CFR 63, Subpart LLL, Section 1350 (f)(1)&(f)(2), (R336.1201(1)(a)) &
                                  (R336.1205(1))

                                   - The recorder response range must include zero and 1.5 times the average
                                   temperatures established from performance tests as required under 40 CFR
                                   63, Subpart LLL, Section 1349(b)(3)(iv).



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FLEXIBLE GROUPING REQUIREMENTS
                                                                   (40 CFR 63, Subpart LLL, Section 1350 (f)(1)(i)
                                    - The reference method must be a National Institute of Standards and
                                    Technology calibrated reference thermo couple potentiometer system or
                                    alternate reference, subject to approval by AQD.
                                                                     (40 CFR 63, Subpart lll, Section 1350(f)(1)(ii))
                                    - The three-hour rolling average temperature shall be calculated as the
                                    average of 180 successive one-minute average temperatures.
                                                                     (40 CFR 63, Subpart LLL, Section 1350(f)(3))
                                    - 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.
                                                                      (40 CFR 63, Subpart LLL, Section 1350(f)(4))
                                    - The calibration of all thermocouples and other temperatures sensors shall
                                    be verified at least once every three months.
                                                                      (40 CFR 63, Subpart LLL, Section 1350(f)(6))
                               4.   Facility shall keep a record of the monthly usage rate of specification used
                                    oil (Conventional Firing Mode). Such records shall be kept on file for a
                                    period of at least five years and made available to the AQD upon request.
                                                                                                       (R336.1213(3))
                               5.   The facility shall 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 ± l percent of the rate being measured.
                                                                     (40 CFR 63, Subpart LLL, Section 1350(g)(1))
                                    - The facility will verify the calibration of the device at least once every three
                                    months.                         (40 CFR 63, Subpart LLL, Section 1350(g)(2))
                                    - 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.         (40 CFR 63, Subpart LLL, Section 1350(g)(3))
                                    - 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.
                                                                     (40 CFR 63, Subpart LLL, Section 1350(g)(4))
                                    - The facility 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 D/F performance tests.
                                                                   (40 CFR 63, Subpart LLL, Section 1350(g)(6)(i))
                                    - The facility must calculate and record three-hour rolling averages of the
                                    parameter value.              (40 CFR 63, Subpart LLL, Section 1350(g)(6)(ii))
                                    - The 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 three-hour rolling average.
                                                                 (40 CFR 63, Subpart LLL, Section 1350(g)(6)(iii))
3.   Other Monitoring and/or   1.   The facility shall monitor and record the visible emissions from the cement
     Recordkeeping                  kilns on a continuous basis. The COM shall be installed, calibrated,
                                    maintained and operated in accordance with the procedures in 40 CFR
                                    60.13 and Performance Specification 1 (“PS1”) of Appendix B, 40 CFR Part
                                    60. The span value shall be 2.0 times the lowest emission standard as
                                    specified in the federal regulations.
                                                                 (40 CFR 63, Subpart LLL, Section 63.1350 (c)(1).
                               2.   Data collected by the opacity monitoring system shall be collected for a
                                    minimum of 95 percent of the operating hours of kiln(s) per month and in a


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FLEXIBLE GROUPING REQUIREMENTS
                                       manner and with instrumentation acceptable to the District Supervisor AQD.
                                       The facility shall use all reasonable measures necessary to operate the
                                       continuous opacity monitoring systems during periods of startup, shutdown
                                       and malfunction. In accordance with 40 CFR Parts 60.7 and 60.13(h) the
                                       magnitude, in actual percent opacity, of all six minute averages of opacity
                                       greater than 15 percent and the time period represented by such averages
                                       and any deficiencies of the opacity monitoring system up-time shall be
                                       submitted in an acceptable format to the District Supervisor, AQD, within 30
                                       days following the end of the quarter. The facility shall perform an annual
                                       audit of the COM using the procedures put forth in U.S. EPA publication No.
                                       A50/4-92-010, “Performance Audits Procedures for Opacity Monitors,” and
                                       all amendments thereto. The results of the annual audit shall be submitted
                                       to the District Supervisor within 15 days of receipt. Further, all monitoring
                                       data shall be kept on file for a period of at least five years and made
                                       available to the District Supervisor upon request.
                                                                                    (R336.1201(1)(a)) & (R336.1205(1))
                                  3. The facility shall keep the following records during AFM firing mode and
                                       shall be in a format acceptable to the District Supervisor, and shall be kept
                                       on file for a period of at least five years.
                                       a. Date and time
                                       b. Operating mode of the kiln(s)
                                       c. Heat input of all AFM used in the kilns and relative contribution of each
                                            components heat input.
                                       d. Amount of AFM combusted.
                                       e. Kiln feed rate.
                                       f. Visible emissions
                                       g. Oxygen content at the outlet of the kiln
                                       h. Temperature at the inlet of the PMCD
                                       i. SO2 emission rate
                                       j. NOx emission rate
                                       k. VOC emission rate
                                       l. CO emission rate
                                       m. Results of AFM Quality Analysis.
                                                                                   (R336.1201(1)(a)) & (R336.1205(1))
                             B. TESTING/RECORDKEEPING (R 336.1213(3))
                              In Addition to General Requirements in Part A
1. Parameter to be Tested/        Heat content and metal content (Mn, Hg, Ni, as a minimum).
    Recorded                                                                        (R336.1201(1)(a)) & (R336.1205(1))
2. Method/Analysis                Analyze TDF, coal and coke fuels using methods acceptable to AQD.
                                                                                   (R336.1201(1)(a)) & (R336.1205(1))
3. Frequency and Schedule of      Analyzed on a semiannual basis with analyses kept on file for a period of at
    Testing/Recordkeeping         least five years and made available to the AQD upon request. After two years
                                  from the date of approval of this ROP the facility may apply for a change in
                                  frequency of testing. The change in testing frequency request shall be
                                  submitted to and approved by the District Supervisor, AQD.
                                                                                   (R336.1201(1)(a)) & (R336.1205(1))
1. Parameter to be                Metal content (Mn, Hg, Ni, as a minimum). (R336.1201(1)(a)) & (R336.1205(1))
Tested/Recorded
2. Method/Analysis                Analyze raw materials fed to the kilns utilizing method(s) acceptable to the AQD,
                                  testing/analysis procedures(s) protocol shall be submitted to the District
                                  Supervisor, AQD, for approval. (See Appendix 5 for list of raw materials).
                                                                                    (R336.1201(1)(a)) & (R336.1205(1))
3. Frequency and Schedule of      Analyzed on a semiannual basis with analyses kept on file for a period of at
Testing/Recordkeeping             least five years and made available to the AQD, upon request. After two years
                                  from the date of approval of this ROP, the facility may apply for a change in


                                                 Page 58 of 131
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FLEXIBLE GROUPING REQUIREMENTS
                               frequency of testing. The change in testing frequency request shall be
                               submitted to and approved by the District Supervisor, AQD.
                                                                               (R336.1201(1)(a)) & (R336.1205(1))
1. Parameter to be             As, Cd, Cr, Pb, PCBs, Total Halogen, and Flashpoint.
Tested/Recorded                                                                (R336.1201(1)(a)) & (R336.1205(1))
2. Method/Analysis             Sampling procedures and analytical techniques, including quality assurance
                               procedures, acceptable to the AQD. To verify the physical and chemical
                               properties of the used oil comply with the specifications listed in Appendix 5.
                                                                               (R336.1201(1)(a)) & (R336.1205(1))
3. Frequency and Schedule of   Samples shall be collected at least twice per calendar year for used oil
Testing/Recordkeeping          generated “onsite.” For used oil generated “offsite,” all shipments to the facility
                               will be analyzed and screened per “Alternative Fuels and Materials Management
                               Process” referenced in Appendix 5. Upon request of the AQD, the facility shall
                               collect and analyze representative individual samples of each category of the
                               used oil. All sampling records and analytical results shall be kept on file for a
                               period of at least five years and made available to the AQD upon request.
                                                                               (R336.1201(1)(a)) & (R336.1205(1))
1. Parameter to be             PM, SO2, NOx, CO, all heavy metals & VOC.
Tested/Recorded                                                                (R336.1201(1)(a)) & (R336.1205(1))
2. Method/Analysis             Verification of emission rates from the kilns by testing, at owner’s expense, in
                               accordance with Department requirements, may be required. (See Rule 1004,
                               Appendix 5) Verification of emission rates includes the submittal of a complete
                               report of the test results. If testing is required, a complete test plant must be
                               submitted to the AQD. The final plan must be approved by the Division prior to
                               testing.                                         (R336.1201(1)(a)) & (R336.1205(1))
3. Frequency and Schedule of   Testing shall be conducted within 60 days following the receipt of the written
Testing/Recordkeeping          notification of the requirement. A complete report of test results must be
                               submitted to the Division within 60 days following the last date of testing.
                                                                                       (R336.1001, 1003, and 1004)
1. Parameter to be             AFM Materials                                    (R336.1201(1)(a)) & (R336.1205(1))
Tested/Recorded
2. Method/Analysis             Procedures set forth in Appendix 5, titled “Alternative Fuels and Materials
                               Management Process.”                              (R336.1201(1)(a)) & (R336.1205(1))
3. Frequency and Schedule of   Ongoing program when system is in place.
Testing/Recordkeeping                                                           (R336.1201(1)(a)) & (R336.1205(1))
1. Parameter to be             Destruction Efficiency
Tested/Recorded                                                                 (R336.1201(1)(a)) & (R336.1205(1))
2. Method/Analysis             Testing will be conducted at either kiln to verify the destruction removal
                               efficiency by testing in accordance with Department requirements. The purpose
                               of the testing is to verify that the kiln is capable of achieving a destruction
                               removal efficiency of 99.99% DRE testing shall be conducted at representation
                               operating conditions, agreed to in the test plan. The test plan shall also address
                               all points on the kiln where AFM’s will be introduced.
                                                                                 (R336.1201(1)(a)) & (R336.1205(1))
3. Frequency and Schedule of   Previous to processing AFM in the kilns, and upon issuance of the ROP,
Testing/Recordkeeping          verification of the destruction removal efficiency of either kiln shall have been
                               determined. No less than 60 days prior to testing, a complete test plan shall
                               have been submitted to AQD for approval. The final plan must be approved by
                               AQD prior to testing. The facility shall not operate in the AFM mode until the
                               results of the destruction efficiency tests have been approved by the AQD.
                                                                                                        336.1205(1))
1. Parameter to be             SO2, CO, & VOC
Tested/Recorded                             (Consent Judgment No. 00-1163-CZ(Modification), Article 4.4(B)
2. Method/Analysis             Emission rates from the kilns, with emissions being controlled by the baghouse,


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TABLE F-1.8 FG008
FLEXIBLE GROUPING REQUIREMENTS
                                         slurry scrubber, and RTO’s Methods. Test Methods are referenced in Appendix
                                         5. Any method deviating from mentioned must have approval from AQD.
                                                     (Consent Judgment No. 00-1163-CZ(Modification), Article 4.4(B)
3. Frequency and Schedule of             The tests will be completed by March 31, 2004, unless an extension is approved
Testing/Recordkeeping                    by AQD due to “Force Majeure.”
                                                     (Consent Judgment No. 00-1163-CZ(Modification), Article 4.4(B)
IV. REPORTING
1. Reports and Schedules                 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                            (R 336.1213(3)(c)(ii))

                                          2. Semiannual reporting of deviations pursuant to Condition 23 of Part A.
                                             Due March 15 for reporting period July 1 to December 31 and September
                                             15 for reporting period January 1 to June 30.     (R 336.1213(3)(c)(i))

                                         3. Annual certification of compliance pursuant to Conditions 28 and 29 of Part
                                            A. Due March 15.                                        (R 336.1213(4)(c))

                                         4. The facility shall report the results of the QAP of the CEMS, within 30 days
                                            following the end of each calendar quarter, the facility shall submit the
                                            results to the AQD in the format of the data assessment report.
                                                                                       (Figure 1, 40 CFR 60, Appendix F)

                                         5. The results of the annual audit of the COM shall be submitted to the AQD
                                            within 30 days after completion of the audit.  (40 CFR 60, Appendix F)

                                         6. The facility shall submit the copies of an EER and Summary Report in
                                            addressing CEMS data recording. It shall be submitted to AQD within 30
                                            days following the end of each calendar quarter. (40 CFR 63.10 (e)(3)(v))

                                             In addition, the summary report shall include:

                                             - All exceedances of maximum control device inlet gas temperature limits
                                             specified in 40 CFR 63, Subpart LLL, Section 63.144 (a) & (b).

                                             - All failures to calibrate thermocouples and other temperature sensors as
                                             required under 40 CFR 63, Subpart LLL, Section 63.1350 (f)(7).

                                             - All failures to maintain the activated carbon injection carrier gas flow rate
                                             or pressure drop, as applicable, as required under 40 CFR 63, Subpart
                                             LLL, Section 63.1344 (c).

                                             - The results of any combustion system component inspections conducted
                                             within the reporting period as required under 40 CFR 63, Subpart LLL,
                                             Section 63.1350(i).

                                             - All failures to comply with any provision of the operation and maintenance
                                             plan developed in accordance with 40 CFR 63, Subpart LLL, Section
                                             63.1350 (a).          (40 CFR 63, Subpart LLL, Section 63.1354 (b)(9))

                                         See Appendix 8.
V. OPERATIONAL PARAMETERS
1. “Conventional Mode” is defined as those times that a kiln is being fired with the following materials, alone or in
combination with each other.
- Coal, up to 100% of the total heat released to a kiln
- Pet Coke, up to 25% of the total heat released to the kiln


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                                                                                             Expiration Date: April 27, 2009


TABLE F-1.8 FG008
FLEXIBLE GROUPING REQUIREMENTS
- TDF, less than 4.6 tons/hr/kiln or less than 21% of the total heat released to the kiln
- Used oil generated onsite and offsite that meets specifications contained in Appendix 5, including during startup.
- Natural gas
- Silica Gel
- Diesel Fuel
                                                                                        (R336.1201(1)(a)) & (R336.1205(1))

2. “AFM” mode is defined as those times that a kiln is being fired with any of the following fuels, alone or in combination
with any alternative fuel(s)/material(s) listed in Appendix 5 and materials listed for “Conventional Mode” of this ROP.
- Petroleum Coke greater than 25% of the total heat input to a kiln
- TDF, greater than 4.6 tons per hour, or greater than 21% of the total heat input to a kiln
- Used oil other than that under “Conventional Mode”above.
                                                                                         (R336.1201(1)(a)) & (R336.1205(1))

3. The facility shall not operate a kiln unless the respective fabric filter collector and either the activated carbon
absorbent injection system or the limestone slurry scrubber and three RTO’s are installed and operating properly.
                                                                                          (R336.1201(1)(a)) & (R336.1205(1))

4. The fabric filter collectors shall be operating when the fabric filter inlet temperature is between 280 and 475
degrees F., except during startup when the fabric filter inlet temperature is less than 310 degrees F.
                                                                                          (R336.1201(1)(a)) & (R336.1205(1))

5. Bypassing of the collector, will be allowed during start-up, as outlined in Article 4 above, provided no raw materials
are fed to the kiln(s) and firing is either with natural gas, diesel, or used oil. Bypassing of the collectors due to high
temperatures (above 475 degrees F.) will be permitted, provided all raw materials and fuels fed to the kiln(s) cease.
                                                                                          (R336.1201(1)(a)) & (R336.1205(1))

6. Raw material input feed to the kilns shall cease immediately, consistent with safe operating procedures, upon an
initiation of the fabric filter collector bypass. Input feed to the kilns shall not restart until the fabric filter collector is back
on line and functioning properly. The fabric filter collector(s) may be routinely bypassed only during the portion of startup
as outlined in Article 4 above.                                                              (R336.1201(1)(a)) & (R336.1205(1))

7. The visible emission limitations in VI. OTHER REQUIREMENTS, Article 11, shall not be applicable during periods of
startup and shutdown. Startup shall be defined as the period of time when only natural gas, fuel oil, or used oil is put to
the burner pipe for the purpose of heating up the kiln and no other raw materials or AFM is being introduced. Shutdown
shall be defined as a halting of the production.                                     (R336.1201(1)(a)) & (R336.1205(1))

8. The facility must operate the kilns such that the temperature of the gas at the inlet to the kiln PMCD does not exceed
the average of the run average temperature calculated for each run as determined during performance tests.
                                                   (40 CFR 63, Subpart LLL, Sections 63.1344(a) & 63.1349 (b)(3)(iv))

9. During times that the carbon injection system is being operated, the nominal amount of carbon injected into each kiln
exhaust ahead of the fabric filter collector shall be uniformly distributed throughout the hour, not including startup and
shutdown and shall not be less than 295 pounds per hour calculated as a five-hour rolling average updated each hour,
or less than 280 pounds for any individual hour for each operating kiln. For purposes of calculating the five-hour rolling
average, all hourly carbon injection feeds in excess of 305 pounds shall be set equal to 305 pounds. Alternate
substances and/or injection rates may be established by the Department after an acceptable demonstration has been
made by the facility that compliance with the particulate emission and visible emission limitations will be achieved.
                                                                         (R336.1201(1)(a)) & (R336.1205(1)) (R336.1213(3))

10. The activated carbon injection rate shall be based on a three-hour rolling average that is equal to or greater than the
average of the run average injection rates determined during performance testing.
                                                 (40 CFR 63, Subpart LLL, Sections 63.1344(c)(1) & 63.1349(b)(3)(vi))

11. The facility shall maintain the minimum carbon injection carrier gas flow rate as a three-hour rolling average, based
on the manufactures specifications and documents during test plan development, or maintain the minimum activated


                                                       Page 61 of 131
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TABLE F-1.8 FG008
FLEXIBLE GROUPING REQUIREMENTS
carbon injection carrier gas pressure drop, as a three hour rolling average, based on the manufacturer’s specifications
and document during test plan development.                             (40 CFR 63, Subpart LLL, Section 63.1344(c)(2))

12. The facility must specify and use the brand and type of activated carbon used during the performance test. A
complete copy of these specifications supplied by the vendor shall be submitted to the District Supervisor. Changes to
the brand or type of activated carbon may necessitate subsequent performance tests unless the replacement has
equivalent or improved properties compared to the activated carbon specifications cited during performance tests. The
facility must maintain documentation that the substitute activated carbon will provide the same or better level of control
as the original activated carbon. This documentation shall be submitted to the District Supervisor immediately upon
delivery of such new material.
                            (R336.1201(1)(a)) & (R336.1205(1) & (40CFR 63, Subpart LLL, Sections 63.1344 (d) & (e))
13. The facility shall only inject AFM into the hot end of the kilns; which means that portion of the mid kiln injection to the
flame.                                                                                 (R336.1201(1)(a)) & (R336.1205(1))

14. The facility is allowed to burn AFM in the kilns when the following conditions are being met:
- The NO2, SO2. CO, and THC CEMs are installed and are operating properly.
- The COM is installed and is operating properly.
- The excess O2 monitor is installed and operating properly and O2 as measured at the kiln gas exit is maintained at
0.5% or greater, based upon a 60-minute rolling average period, updated each minute.
- The kiln temperature, as measured in the combustion zone of the kiln is operating at or above, 2100°F or greater
based upon a 60-minute rolling average period, updated each minute.
- The device measuring exhaust gas temperature at the inlet to air pollution control device is installed and is operating
properly. The temperature shall be measured on a 3-hour rolling average updated every minute per 40 CFR 63, Subpart
LLL requirements.
- A negative pressure is established and maintained at the kiln inlet measured as a 60-minute rolling average updated
every minute.                                                          (R336.1201(1)(a)) & (R336.1205(1)) & (R336.1225)

15. The facility shall automatically and immediately discontinue operating in the AFM mode per kiln under any one of the
following conditions:
- Clinker production in the kilns is halted
- The carbon injection system, or the limestone slurry scrubber RTO’s are malfunctioning
- During periods of startup, shutdown, or malfunction
- Kiln fabric filter collector bypass mode.                                         (R336.1201(1)(a)) & (R336.1205(1))

16. The facility shall automatically and immediately take corrective action if there is a measured opacity of 15% or
greater. If the measured opacity reading is over two hours in duration, the facility will discontinue the use of AFM.
                                                                                        (R336.1201(1)(a)) & (R336.1205(1))
17. The facility shall not process any AFM in the kilns which has not been through the Qualification Analysis of the
“Alternative Fuels and Materials Management Process.” (See Appendix 3)                  (R336.1201(1)(a)) & (R336.1205(1))

18. The facility shall not process any AFM in the kilns which has not been recorded in POMS and shown to be in
compliance with the appropriate screening levels. (See Appendix 3)                     (R336.1201(1)(a)) & (R336.1205(1))
VI. OTHER REQUIREMENTS
1. The facility shall develop a “Written Operations and Maintenance Plan.” It shall be submitted to the AQD for
    approval and shall include the following information:
    - Procedures for proper operation and maintenance of the kiln process and all air pollution control devices in order to
    meet the emission limits and operating limits
    - Procedures to be used during an inspection of the components of the combustion system of each kiln at least once
    per year.                                                      (40 CFR 63, Subpart LLL, Section 63.1350 (a)(1) & (3))
2. The facility shall not operate the kilns unless the program for continuous fugitive dust control for all plant roadways,
    the plant yard, all material storage piles and all material handling operations specified in Attachment 1 has been
    implemented and maintained. Daily records will be kept, addressing noted conditions of operations listed in the
    referenced program and warranted actions taken to abate fugitive emissions.
                                                                          (R336.371) & (R336.1201(1)(a)) & (R336.1205(1))
3. The facility shall not operate the kilns unless the malfunction abatement plan/preventative maintenance program


                                                     Page 62 of 131
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                                                                                        Expiration Date: April 27, 2009


TABLE F-1.8 FG008
FLEXIBLE GROUPING REQUIREMENTS
      specified in Attachment 2 for the dry injection (absorbent materials) scrubber and handling system and fabric filter
      control system has been implemented and is maintained.               (R336.1911) & (R336.1201(1)(a)) & (R336.1205(1))
4.    The facility shall abide by the Supplemental Preventative Maintenance Program referenced in Attachment 3. Each
      inspection required by this program will have an appropriate log entry and be available upon request by the AQD
      District Supervisor.             (Consent Order AQD No. 22-1999, Article 10) & (R336.1201(1)(a)) & (R336.1205(1))
5.    Facility shall not make any changes to the POMS without the written approval of the District Supervisor.
                                                                                           (R336.1201(1)(a)) & (R336.1205(1))
6.    Upon issuance of the ROP, the facility shall have provided the District Supervisor with an updated copy of the
      Parametric Operating Monitoring System, which will be used by the facility for recordkeeping and for demonstrating
      compliance with the appropriate emission limitations. The Parametric Operating Monitoring System shall be based
      upon the AERMOD dispersion model. The permittee shall modify POMS to incorporate any subsequent EPA
      approved AERMOD modification which has impact on the predicted ambient concentrations used in POMS within 90
      days of such modification. Any modifications to the POMS shall be provided to the District Supervisor within 60 days
      of the AERMOD model modifications becoming effective.                                (R336.1201(1)(a)) & (R336.1205(1))
7.    The AQD reserves the right to obtain samples of any AFM used at the facility and to have sample(s) independently
      tested.                                                                              (R336.1201(1)(a)) & (R336.1205(1))
8.    Upon issuance of the ROP, the facility shall have submited to the District Supervisor a notification protocol for AFM
      which qualify for use under the “Materials Management Plan.” The notification protocol shall have the written
      approval of the District Supervisor.                                                 (R336.1201(1)(a)) & (R336.1205(1))
9.    The facility shall notify the District Supervisor whenever there are unanticipated interruptions in the use of AFM to
      the kilns as a result of any type of malfunction or equipment failure not covered under the facility’s startup,
      shutdown, and malfunction abatement plan. The notification of the actions taken must occur within two working
      days from commencing such actions and shall include:
      - Date
      - Time
      - Materials being fired in the kiln(s)
      -Reason for interrupting AFM to the kiln
      - Corrective action(s) taken to address the malfunction              (R336.1912) & (R336.1201(1)(a)) & (R336.1205(1))
10.   Upon issuance of the ROP, the facility shall have in place a Malfunction Abatement Plan/Preventative Maintenance
      Program for the scrubber/oxidizer controls on the kilns.            (R336.1911) & (R336.1201(1)(a)) & (R336.1205(1))
11.   The facility shall monitor and/or calculate, and record the annual emissions (tons/year) of each calculated NSR
      pollutant that could increase as a result of this project. Annual emissions, as used in this special condition, means
      12 consecutive calendar months beginning with initial operation of either kiln in AFM mode. Annual emissions shall
      be maintained for a period of at least 5 years after initial use of AFM in either kiln.
                                                                                           (R336.1201(1)(a)) & (R336.1205(1))
12.   The facility shall comply with all applicable provisions of R336.1817 – Emission limitations and restrictions for
      Portland cement kilns.                                                (R336.1201(1)(a)) & (R336.1205(1)) & (R336.1817)
13.   The facility shall comply with all applicable provisions of Subpart LLL – National Emission Standards for Hazardous
      Air Pollutants from the Portland Cement Manufacturing Industry.
                                                                 (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)
14.   In the event that annual emissions (tons/year) of each NSR pollutant, as indicated below, exceeds baseline actual
      emissions by a significant amount as a result of this project, the facility shall submit a report to the Administrator.
      The report shall contain the following information:
            The name, address, and telephone number of the stationary source.
            The annual emissions calculated pursuant to Article 12 above,
            An explanation as to why annual emissions exceeded the pre-construction projected actual emissions.

          This information shall be submitted to the MDEQ-AQD within 60 days after the end of such calendar year.

          Following are the projected actual emissions for this project which are not emission limits but are only for
          purposes of indicating when the reporting requirements for this article are applicable. The projected actual
          emissions of CO are capped at the current allowable level.                   (R336.1201(1)(a)) & (R336.1205(1))

           NSR Pollutant              Baseline Emissions           PSD Significant Level            Baseline &
                                         (tons/year)                   (tons/year)               Significance Level


                                                     Page 63 of 131
                                                                               Permit Number: MI-ROP-B1743-2004
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TABLE F-1.8 FG008
FLEXIBLE GROUPING REQUIREMENTS
                                                                                                  (tons/year)
             SO2                         11,309.2                         40                       11,349.2
             NOx                          2,400.2                         40                        2,440.2
             CO                           3,427.3                        100                         3,515
            VOC                           4,187.2                         40                        4.227.2
           PM, total                       143.5                          25                         168.5
        PM 10, filterable                   45.6                          15                          60.6
            Lead                             0.1                         0.6                           0.7

15. No later than August 1, 2004, the facility shall conduct POMS validation according to an approved test plan. No less
    than 60 days prior to testing, a complete test plan shall be submitted to the AQD. The final plan must be approved
    by the AQD prior to testing. The test results shall be submitted to the AQD within 60 days of completion testing.
    The purpose of the testing is to document the validity of POMS for mercury. POMS shall be the means for
    assessing compliance with the annual limit in Condition II.B.8. which applies at all times. After initial testing,
    subsequent tests shall be conducted on a schedule concurrent with the facility’s PC MACT kiln testing requirements.
                                                                                          (R336.1201(a)) & (R336.1205(1))

* This requirement is state enforceable only.




                                                    Page 64 of 131
                                                                                  Permit Number: MI-ROP-B1743-2004
                                                                                         Expiration Date: April 27, 2009


TABLE F-1.9 FG009
FLEXIBLE GROUPING REQUIREMENTS
FLEXIBLE GROUPING                      FG009 Cement Loading to Railcars
Emission Unit/Process Groups           EG 011-5 Bulk cement loading to railcars – N scale No. 1
                                       EG 011-6 Bulk cement loading to railcars – S scale No. 2
I. DESIGN PARAMETERS
A. Pollution Control Equipment         DV011-5-2 Fabric filter
                                       DV011-6-2 Fabric filter
B. Stack/Vent Parameters               Exhaust gases shall be discharged unobstructed vertically upwards unless
                                       otherwise noted.
           Stack/Vent ID               a. Minimum          b. Maximum              c.          d. Air          Applicable
                                          Height        Exhaust Dimension        Temp.      Flow Rate         Requirement
                                          (feet)                                  (F)         (acfm)
                                                              (inches)
1. SV023                         52                              20               NA             NA                NA
2. SV024                         52                              20                NA            NA                NA
C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                                 Maximum Usage Rate
NA
         B. Pollutants                                            Maximum Emission Limit
PM (Opacity)                 10% Opacity                              (40 CFR 63, Subpart LLL, Section 63.1348)
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                           A. MONITORING/RECORDKEEPING (R 336.1213(3))
                              In Addition to General Requirements in Part A
1.   Continuous Emission          NA
     Monitoring (CEM) System
     and Recordkeeping
2.   Process Monitoring System The pressure drop across the fabric filters shall be monitored and recorded
     and Recordkeeping            once per day if rail car silos are being filled. Recordings reflecting values
                                  outside of the range set forth in V-OPERATIONAL PARAMETERS will
                                  require the facility to initiate corrective action per the facility’s operations and
                                  maintenance plan.                                                    (R336.1213(3))
3.   Other Monitoring and/or      NA
     Recordkeeping
                             B. TESTING/RECORDKEEPING (R 336.1213(3))
                              In Addition to General Requirements in Part A
1.   Parameter to be Tested/      NA
     Recorded
2.   Method/Analysis              EPA Method 22                                        (40 CFR 60, Appendix A-7)
                                  EPA Method 9                                         (40 CFR 60, Appendix A-4)
3.   Frequency and Schedule of 1. Monthly 1-minute visible emissions test in accordance with Method 22.
     Testing/Recordkeeping                                  (40 CFR 63, Subpart LLL Section 63.1350 (a)(4))(i))
                                  2. If no emissions are observed in six consecutive months (utilizing
                                       Method 22), testing may be decreased from monthly to semi-annually.
                                       If visible emissions are observed during any semiannual test, the facility
                                       must resume testing on a monthly basis until no visible emissions are
                                       observed in six consecutive monthly tests.
                                                            (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))
                                  3. If no visible emissions are observed during the semiannual test (utilizing
                                       Method 22) , the facility may decrease the frequency to testing to
                                       annually. If visible emissions are observed during any annual test, the


                                                     Page 65 of 131
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 TABLE F-1.9 FG009
 FLEXIBLE GROUPING REQUIREMENTS
                                           facility must resume testing on a monthly basis and maintain that
                                           schedule until no visible emissions are observed in six consecutive
                                           readings.         (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))

                                       4. If visible emissions are observed during any Method 22 test, the facility
                                          must conduct a 6-minute test of opacity in accordance with Method 9.
                                          The Method 9 test must begin within one hour of any observation of
                                          visible emissions.
                                                              (40 CFR 63, Subpart LLL, Section 63.150 (a)(4)(iv))
                                       5. The facility shall maintain files of the required visible emission records in
                                          a form suitable and readily available for inspection and review as
                                          required by 40 CFR 63, Subpart A, Section 63.10 (b)(1). The files shall
                                          be retained for at least five years following the date of each occurrence
                                          and measurement. At a minimum, the most recent two years of data
                                          shall be retained on site. The files may be maintained on microfilm, on
                                          a computer, on floppy disks, on magnetic tape, or on microfiche.
                                                                     (40 CFR 63, Subpart LLL, Section 63.155(a))
 IV. REPORTING
 Reports and Schedules                 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                       (R 336.1213(3)(c)(ii))

                                       2. Semiannual reporting of deviations pursuant to Condition 23 of Part A.
                                          Due March 15 for reporting period July 1 to December 31 and
                                          September 15 for reporting period January 1 to June 30.
                                                                                          (R 336.1213(3)(c)(i))

                                       3. Annual certification of compliance pursuant to Conditions 28 and 29 of
                                          Part A. Due annually by March 15 for the previous calendar year.
                                                                                             (R 336.1213(4)(c))

                                         See Appendix 8.
  V. OPERATIONAL PARAMETERS
  Normal operating pressure drop range for the fabric filter will be provided to the appropriate District Office of the
  AQD within 90 days of the effective date of the ROP.                                              (R336.1213(2))
  VI. OTHER REQUIREMENTS
  1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be
      procedures for proper operation and maintenance of the source and air pollution control devices in order to
      meet the emission and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the
      source-subject to the opacity standards set forth under 40 CFR 63.1348. Such procedures shall also include
      provisions of paragraphs 63.1350 (a)(4)(i) thru (iv).
                                                                    (40 CFR 63, Subpart LLL, Section 63.1350(a))
  2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for
      Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.
                                                        (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)
* This requirement is state enforceable only.




                                                    Page 66 of 131
                                                                                  Permit Number: MI-ROP-B1743-2004
                                                                                         Expiration Date: April 27, 2009


TABLE F-1.10 FG010
FLEXIBLE GROUPING REQUIREMENTS
FLEXIBLE GROUPING                      FG010 Raw Material Transfer
Emission Unit/Process Groups           EG008 Raw materials reclaim
                                       EG010 Raw material conveyor (belt #2)
                                       EG021 Raw material transfer (belt #2 to belt #5)
I. DESIGN PARAMETERS
A. Pollution Control Equipment         DV008-2 Fabric filter
B. Stack/Vent Parameters               Exhaust gases discharged horizontally.
           Stack/Vent ID               a. Minimum        b. Maximum Exhaust        c.          d. Air          Applicable
                                          Height             Dimension           Temp.      Flow Rate         Requirement
                                          (feet)              (inches)            (F)         (acfm)
SV025                            30                              32               NA            NA                NA
C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                                 Maximum Usage Rate
NA
         B. Pollutants                                            Maximum Emission Limit
PM (Opacity)                 10% Opacity                              (40 CFR 63, Subpart LLL, Section 63.1348)
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                           A. MONITORING/RECORDKEEPING (R 336.1213(3))
                              In Addition to General Requirements in Part A
1.   Continuous Emission          NA
     Monitoring (CEM) System
     and Recordkeeping
2.   Process Monitoring System The pressure drop across the fabric filters shall be monitored and recorded
     and Recordkeeping            once per day when material is being transferred. Recordings reflecting
                                  values outside of the range set forth in V-OPERATIONAL PARAMETERS
                                  will require the facility to initiate corrective action per the facility’s operations
                                  and maintenance plan.                                                (R336.1213(3))
3.   Other Monitoring and/or      NA
     Recordkeeping
                             B. TESTING/RECORDKEEPING (R 336.1213(3))
                              In Addition to General Requirements in Part A
1.   Parameter to be Tested/      Opacity                      (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4))
     Recorded
2.   Method/Analysis              EPA Method 22                                          (40 CFR 60, Appendix A-7)
                                  EPA Method 9                                           (40 CFR 60, Appendix A-4)

3. Frequency and Schedule of           1. Monthly 1-minute visible emissions test in accordance with Method 22.
   Testing/Recordkeeping                                      (40 CFR 63, Subpart LLL Section 63.1350 (a)(4))(i))
                                       2. If no emissions are observed in six consecutive months (utilizing
                                          Method 22), testing may be decreased from monthly to semiannually. If
                                          visible emissions are observed during any semiannual test, the facility
                                          must resume testing on a monthly basis until no visible emissions are
                                          observed in six consecutive monthly tests.
                                                             (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))
                                       3. If no visible emissions are observed during the semi-annual test
                                          (utilizing Method 22) , the facility may decrease the frequency to testing
                                          to annually. If visible emissions are observed during any annual test,
                                          the facility must resume testing on a monthly basis and maintain that


                                                     Page 67 of 131
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TABLE F-1.10 FG010
FLEXIBLE GROUPING REQUIREMENTS
                                          schedule until no visible emissions are observed in six consecutive
                                          readings.        (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))

                                      4. If visible emissions are observed during any Method 22 test, the facility
                                         must conduct a 6-minute test of opacity in accordance with Method 9.
                                         The Method 9 test must begin within one hour of any observation of
                                         visible emissions.
                                                             (40 CFR 63, Subpart LLL, Section 63.150 (a)(4)(iv))
                                      5. The facility shall maintain files of the required visible emission records in
                                         a form suitable and readily available for inspection and review as
                                         required by 40 CFR 63, Subpart A, Section 63.10 (b)(1). The files shall
                                         be retained for at least five years following the date of each occurrence
                                         and measurement. At a minimum, the most recent two years of data
                                         shall be retained on site. The files may be maintained on microfilm, on
                                         a computer, on floppy disks, on magnetic tape, or on microfiche.
                                                                     (40 CFR 63, Subpart LLL, Section 63.155(a))
IV. REPORTING
Reports and Schedules                 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                          (R 336.1213(3)(c)(ii))

                                      2. Semiannual reporting of deviations pursuant to Condition 23 of Part A.
                                         Due March 15 for reporting period July 1 to December 31 and
                                         September 15 for reporting period January 1 to June 30.
                                                                                          (R 336.1213(3)(c)(i))

                                      3. Annual certification of compliance pursuant to Conditions 28 and 29 of
                                         Part A. Due annually by March 15 for the previous calendar year.
                                                                                            (R 336.1213(4)(c))
                                      See Appendix 8.
V. OPERATIONAL PARAMETERS
Normal operating pressure drop range for the fabric filter will be provided to the appropriate District Office of the
AQD within 90 days of the effective date of the ROP.                                                (R336.1213(2))
VI. OTHER REQUIREMENTS
1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be
    procedures for proper operation and maintenance of the source and air pollution control devices in order to
    meet the emission and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the
    source-subject to the opacity standards set forth under 40 CFR 63.1348. Such procedures shall also
    include provisions of paragraphs 63.1350 (a)(4)(i) thru (iv).
                                                                   (40 CFR 63, Subpart LLL, Section 63.1350(a))
2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for
    Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.
                                                      (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)
3. Fugitive emissions control addressed in the “Fugitive Dust Plan” Attachment 1.                  (R336.1201(3))




                                                  Page 68 of 131
                                                                                  Permit Number: MI-ROP-B1743-2004
                                                                                         Expiration Date: April 27, 2009


TABLE F-1-11 FG011
FLEXIBLE GROUPING REQUIREMENTS
FLEXIBLE GROUPING                      FG011 Natural Gas-Fired Solid Fuel Dryers
Emission Unit/Process Groups           EGDRYER-1, 8.5 mm BTU/Hr gas-fired solid fuel dryer for No. 1 kiln
                                       EGDRYER-2, 8.5 mm BTU/Hr gas-fired solid fuel dryer for No. 2 kiln
I. DESIGN PARAMETERS
A. Pollution Control Equipment         DRYER-1, DV03-5 Dry Scrubber (Carbon), DV003-2 Baghouse or DV003-2
                                       Baghouse, DV003-3 Limestone slurry scrubber, DV003-4 Three (3) RTOs
                                       DRYER-2 , DV003-10 Dry Scrubber (Carbon), DV003-7 Baghouse, or
                                       DV003-7 Baghouse, DV003-8 Limestone slurry scrubber, DV003-9 Three
                                       (3) RTOs
B. Stack/Vent Parameters               Exhaust gases shall be discharged unobstructed vertically upwards unless
                                       otherwise noted.
           Stack/Vent ID               a. Minimum          b. Maximum              c.          d. Air          Applicable
                                          Height        Exhaust Dimension        Temp.      Flow Rate         Requirement
                                          (feet)                                  (F)         (acfm)
                                                              (inches)
1. SV001                          350              180              NA           NA        (R336.1225)
C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                 Maximum Usage Rate
NA
         B. Pollutants                              Maximum Emission Limit
NOx                          3,377 Tons/Yr per 12-month rolling time period. (Included under Table F-
                             1.8)                                  (R336.1201(1)(a)) & (R336.1205(1))
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                         A. MONITORING/RECORDKEEPING (R 336.1213(3))
                            In Addition to General Requirements in Part A
1. Continuous Emission          For audit and reporting requirements, see Table F-1.8 III.A.1.
    Monitoring (CEM) System
    and Recordkeeping
2. Process Monitoring System NA
    and Recordkeeping
3. Other Monitoring and/or      NA
    Recordkeeping
                           B. TESTING/RECORDKEEPING (R 336.1213(3))
                            In Addition to General Requirements in Part A
1. Parameter to be Tested/      NA
    Recorded
2. Method/Analysis              NA
3. Frequency and Schedule of NA
    Testing/Recordkeeping
IV. REPORTING
Reports and Schedules           1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                     (R 336.1213(3)(c)(ii))

                                       2. The facility shall submit the copies of an EER and Summary Report in
                                          addressing the NO2 CEMS data recording. It shall be submitted to
                                          AQD within 30 days following the end of each calendar quarter.
                                          (Reference in Table F-1.8 IV. G. REPORTING)
                                                                   (40 CFR 63.10(c)(3)(v)) & (R 336.1213(3)(c)(i))



                                                     Page 69 of 131
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 TABLE F-1-11 FG011
 FLEXIBLE GROUPING REQUIREMENTS

                                       3. Annual certification of compliance pursuant to Conditions 28 and 29 of
                                          Part A. Due annually by March 15 for the previous calendar year.
                                                                                               (R 336.1213(4)(c))

                                       4. The facility shall report the results of the QAP of the NO2 CEM, with 30
                                          days following the end of each calendar quarter, the facility shall submit
                                          the results to the AQD in the format of the data assessment report.
                                          (Referenced in Table F-1.8 IV.4. REPORTING.)
                                                                                 (Figure 1, 40 CFR 60, Appendix F)

                                       See Appendix 8.
  V. OPERATIONAL PARAMETERS
  NA
  VI. OTHER REQUIREMENTS
  1. The solid fuel dryers shall be fired with pipeline natural gas (or equivalent) only.
      (R336.1201(1)(a)) & (R336.1205(1))
  2. The solid fuel dryers shall not operate unless the exhaust gases are directed to the kilns, through the kiln(s)
      emission control system and exhausted through the existing kiln stack.
      (R336.1201(1)(a)) & (R336.1205(1))
* This requirement is state enforceable only.




                                                   Page 70 of 131
                                                                                  Permit Number: MI-ROP-B1743-2004
                                                                                         Expiration Date: April 27, 2009


TABLE F-1.12 FG012
FLEXIBLE GROUPING REQUIREMENTS
FLEXIBLE GROUPING                      FG012 Clinker Transfer
Emission Unit/Process Groups           EG009-1 – Clinker transfer, bucket elevators
                                       EG009-4 – Clinker transfer, apron conveyors
I. DESIGN PARAMETERS
A. Pollution Control Equipment         DV009-1-2 Fabric filter
                                       DV009-4-2 Fabric filter
B. Stack/Vent Parameters               Exhaust gases shall be discharged unobstructed vertically upwards for
                                       SV003 and horizontal for SV032.
           Stack/Vent ID               a. Minimum          b. Maximum              c.          d. Air          Applicable
                                          Height        Exhaust Dimension        Temp.      Flow Rate         Requirement
                                          (feet)                                  (F)         (acfm)
                                                              (inches)
1. SV003                         NA                              NA               NA            NA                NA
2. SV032                         NA                              NA               NA            NA                NA
C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                               Maximum Usage Rate
NA
         B. Pollutants                                            Maximum Emission Limit
PM (Opacity)                 10%                                      (40 CFR 63, Subpart LLL, Section 63.1348)
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                           A. MONITORING/RECORDKEEPING (R 336.1213(3))
                              In Addition to General Requirements in Part A
1.   Continuous Emission          NA
     Monitoring (CEM) System
     and Recordkeeping
2.   Process Monitoring System The pressure drop across the fabric filters shall be monitored and recorded
     and Recordkeeping            once per day during material transfer. Recordings reflecting values outside
                                  of the range set forth in V-OPERATIONAL PARAMETERS will require the
                                  facility to initiate corrective action per the facility’s operations and
                                  maintenance plan.                                           (R336.1213(3))
3.   Other Monitoring and/or      NA
     Recordkeeping
                             B. TESTING/RECORDKEEPING (R 336.1213(3))
                              In Addition to General Requirements in Part A
1.   Parameter to be Tested/      Opacity                  (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4))
     Recorded
2.   Method/Analysis              EPA Method 22                                 (40 CFR 60, Appendix A-7)
                                  EPA Method 9                                  (40 CFR 60, Appendix A-4)

3. Frequency and Schedule of           1. Monthly 1-minute visible emissions test in accordance with Method 22.
   Testing/Recordkeeping                                  (40 CFR 63, Subpart LLL Section 63.1350 (a)(4))(i))
                                       2. If no emissions are observed in six consecutive months (utilizing
                                          Method 22), testing may be decreased from monthly to semi-annually.
                                          If visible emissions are observed during any semi-annual test, the
                                          facility must resume testing on a monthly basis until no visible
                                          emissions are observed in six consecutive monthly tests.
                                                            (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(ii))
                                       3. If no visible emissions are observed during the semi-annual test
                                          (utilizing Method 22) , the facility may decrease the frequency to testing


                                                     Page 71 of 131
                                                                                 Permit Number: MI-ROP-B1743-2004
                                                                                        Expiration Date: April 27, 2009


 TABLE F-1.12 FG012
 FLEXIBLE GROUPING REQUIREMENTS
                                            to annually. If visible emissions are observed during any annual test,
                                            the facility must resume testing on a monthly basis and maintain that
                                            schedule until no visible emissions are observed in six consecutive
                                            readings.          (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4)(iii))

                                       4. If visible emissions are observed during any Method 22 test, the facility
                                          must conduct 6-minute test of opacity in accordance with Method 9.
                                          The Method 9 test must begin within one hour of any observation of
                                          visible emissions.
                                                              (40 CFR 63, Subpart LLL, Section 63.150 (a)(4)(iv))
                                       5. The facility shall maintain files of the required visible emission records in
                                          a form suitable and readily available for inspection and review as
                                          required by 40 CFR 63, Subpart A, Section 63.10 (b)(1). The files shall
                                          be retained for at least five years following the date of each occurrence
                                          and measurement. At a minimum, the most recent two years of data
                                          shall be retained on site. The files may be maintained on microfilm, on
                                          a computer, on floppy disks, on magnetic tape, or on microfiche.
                                                                      (40 CFR 63, Subpart LLL, Section 63.155(a))
 IV. REPORTING
 Reports and Schedules                 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                       (R 336.1213(3)(c)(ii))

                                       2. Semiannual reporting of deviations pursuant to Condition 23 of Part A.
                                          Due March 15 for reporting period July 1 to December 31 and
                                          September 15 for reporting period January 1 to June 30.
                                                                                          (R 336.1213(3)(c)(i))

                                       3. Annual certification of compliance pursuant to Conditions 28 and 29 of
                                          Part A. Due annually by March 15 for the previous calendar year.
                                                                                             (R 336.1213(4)(c))
                                       See Appendix 8.
  V. OPERATIONAL PARAMETERS
  Normal operating pressure drop range for the fabric filters will be provided to the appropriate District Office of the
  AQD within 90 days of the effective date of the ROP.                                                (R336.1213(2))
  VI. OTHER REQUIREMENTS
  1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be
      procedures for proper operation and maintenance of the source and air pollution control devices in order to
      meet the emission and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the
      source-subject to the opacity standards set forth under 40 CFR 63.1348. Such procedures shall also include
      provisions of paragraphs 63.1350 (a)(4)(i) thru (iv).          (40 CFR 63, Subpart LLL, Section 63.1350(a))
  2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for
      Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.
                                                        (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)
* This requirement is state enforceable only.




                                                    Page 72 of 131
                                                                             Permit Number: MI-ROP-B1743-2004
                                                                                    Expiration Date: April 27, 2009



TABLE F-1.13 FGCOLDCLEANERS
FLEXIBLE GROUPING REQUIREMENTS
FLEXIBLE GROUPING                   FGCOLDCLEANERS - Any existing cold cleaner (placed into operation prior to
                                    7/1/79) or new cold cleaner (placed into operation after 7/1/79) that is exempt
                                    from NSR permitting by R 336.1281(h) or R 336.1285 (r)(iv).
Emission Unit/Process Groups        EG025-1 & EG025-2
I. DESIGN PARAMETERS
A. Pollution Control                NA
Equipment
B. Stack/Vent Parameters            NA
           Stack/Vent               a.   Minimum         b. Maximum             c.          d. Air      Applicable
               ID                         Height      Exhaust Dimension       Temp       Flow Rate     Requirement
                                          (feet)           (inches)            (°F)        (acfm)
1. NA                                     NA                  NA               NA          NA              NA
C. Other Design Parameters
1. A cover shall be installed and the cover shall be closed whenever parts are not being handled in the cleaner.
                                                                             (R 336.1611(2)(a), R 336.1707(3)(a))

2. The cover shall be mechanically assisted if the Reid vapor pressure of the solvent is more than 0.3 psia, or if
   the solvent is agitated or heated.                                                          (R 336.1707(3)(a))

3. A device shall be available for draining cleaned parts.                       (R 336.1611(2)(b), R 336.1707(3b))
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                             Maximum Usage Rate
Cleaning Solvents                   The facility shall not use cleaning solvents containing more than 5 percent by
                                    weight of the following halogenated compounds: methylene chloride,
                                    perchloroethylene, trichloroethylene, 1,1,1-trichloroethane, carbon
                                    tetrachloride, chloroform, or any combination thereof.           (R 336.1213(3))
          B. Pollutant                                          Maximum Emission Limit
NA                                  NA
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                             A. MONITORING/RECORDKEEPING (R 336.1213(3))
                                In Addition To General Requirements in Part A
1. Continuous Emission              NA
     Monitoring (CEM) System
     and Recordkeeping
2. Process Monitoring               NA
     System and
     Recordkeeping
3. Other Monitoring and/or          1. The date of installation of each cold cleaner.                (R 336.1213(3))
     Recordkeeping
                                    2. The identification name/number, air/vapor interface area and type of
                                         solvent used (including Reid vapor pressure and VOC content) shall be
                                         maintained for each cold cleaner.                           (R 336.1213(3))

                                    3. As noted in R 336.1611(2)(c) and R 336.1707(3)(c), if applicable, an initial
                                       demonstration that the waste solvent is a safety hazard shall be made prior
                                       to storage in non-closed containers. If the waste solvent is a safety hazard
                                       and is stored in non-closed containers, verification that the waste solvent is
                                       disposed of so that not more than 20%, by weight, is allowed to evaporate
                                       into the atmosphere shall be made on a monthly basis.        (R 336.1213(3))



                                                 Page 73 of 131
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                                                                                    Expiration Date: April 27, 2009


TABLE F-1.13 FGCOLDCLEANERS
FLEXIBLE GROUPING REQUIREMENTS
                                    4. For new cold cleaners, if the solvent is heated, the solvent temperature
                                       shall be monitored and recorded on a monthly basis, during peak operating
                                       conditions.                                                  (R 336.1213(3))

                                   5. As noted in R 336.1707(2), if applicable, the option chosen to comply with
                                      R 336.1707(2) shall be recorded.                           (R 336.1213(3))
                                B. TESTING/RECORDKEEPING (R 336.1213(3))
                                In Addition to General Requirements in Part A
1. Parameter to be                 NA
    Tested/Recorded
2. Method/Analysis                  NA
3. Frequency and Schedule           NA
    of Testing/Recordkeeping
IV. REPORTING
Reports and Schedules               1. Prompt reporting of deviations pursuant to condition 24 of Part A, using
                                       the format in Appendix 8.                            (R 336.1213(3)(c)(ii))

                                    2. Semi-annual reporting of deviations pursuant to condition 23 of Part A,
                                       using the format in Appendix 8. Due March 15 for reporting period July 1
                                       to December 31 and September 15 for reporting period January 1 to
                                       June 30.                                            (R 336.1213(3)(c)(i))

                                     3. Annual certification of compliance pursuant to conditions 28 and 29 of Part
                                          A. Due annually by March 15 for the previous calendar year.
                                                                                                (R 336.1213(4)(c))
                                     See Appendix 8.
V. OPERATIONAL PARAMETERS
1. The facility may install or construct an unlimited number of new cold cleaners that meet one of the following
   requirements:

    a. The air/vapor interface of the cold cleaner is no more than 10 square feet.                 (R 336.1281(h))

    b. The cold cleaner is used for cleaning metal parts and the emissions are released to the general in-plant
       environment.                                                                           (R 336.1285(r)(iv))

2. Waste solvent shall be stored only in closed containers, unless the stored solvent is demonstrated to be a
   safety hazard and is disposed so that not more than 20%, by weight, is allowed to evaporate into the
   atmosphere.                                                              (R 336.1611(2)(c), R 336.1707(3)(c))

3. Parts shall be drained for not less than 15 seconds or until dripping ceases.
                                                                               (R 336.1611(2)(b),(R 336.1707(3b))

4. The facility shall perform routine maintenance on each cold cleaning machine as recommended by the
   manufacturer.                                                                             (R 336.1213(3))

5. Each new cold cleaner shall not be operated using a solvent having a Reid vapor pressure of more than 0.6
   psia or heated above 120 degrees Fahrenheit, unless at least one of the following is met:    (R 336.1707(2))

    a. The cold cleaner is designed such that the ratio of the freeboard height to the width of the cleaner is equal
       to or greater than 0.7.                                                                    (R 336.1707(2)(a))

    b. The solvent bath is covered with water if the solvent is insoluble and has a specific gravity of more than
       1.0.                                                                                        (R 336.1707(2)(b))



                                                 Page 74 of 131
                                                                               Permit Number: MI-ROP-B1743-2004
                                                                                      Expiration Date: April 27, 2009


 TABLE F-1.13 FGCOLDCLEANERS
 FLEXIBLE GROUPING REQUIREMENTS

     c.  The cold cleaner is controlled by a carbon adsorption system, condensation system, or other method of
         equivalent control approved by the AQD.                                                (R 336.1707(2)(c))
 VI. OTHER REQUIREMENTS
 1. The facility shall maintain written procedures to demonstrate compliance with the requirements of
     R 336.1611 and R 336.1707. Such procedures shall be posted in an accessible, conspicuous location near
      each machine.                                                                 (R 336.1611(3), R 336.1707(4))

 2. The facility may construct, reconstruct, modify, install or commence operation of any new or existing emission
    units under FGCOLDCLEANERS without modifying the RO Permit providing that it is not defined as a minor or
    significant modification to the RO Permit, as defined by R 336.1216(2) and R 336.1216(3), respectively, and
    the following provisions are met:

     a. It is not a major stationary source or major modification as defined in the prevention of significant
        deterioration regulations in 40 CFR 52.21.                                                    (R 336.1278(a))

     b. It is not a major offset source or a major offset modification as defined in R 336.1113(c) and (b),
        respectively, for which volatile organic compounds, particulate matter, PM-10, carbon monoxide, nitrogen
        oxides, sulfur dioxide, or lead is a non-attainment air contaminant.                         (R 336.1278(b))

     c.   It does not have actual emissions of volatile organic compounds, particulate matter, carbon monoxide,
          nitrogen oxides, sulfur dioxide, or lead above the significance levels as defined in R 336.1119.
                                                                                                       (R 336.1278(c))

     d. It is not a major source as defined in the National Emission Standards for Hazardous Air Pollutants for
        source categories, 40 CFR 63.2, and it is subject to the provisions of 40 CFR 63.40 through 63.44.
                                                                                                  (R 336.1278(d))

* This requirement is state enforceable only.




                                                   Page 75 of 131
                                                                               Permit Number: MI-ROP-B1743-2004
                                                                                      Expiration Date: April 27, 2009

TABLE F-1.14 FG014
FLEXIBLE GROUPING REQUIREMENTS
FLEXIBLE GROUPING                      FG014 The existing portable quarry drilling system (placed into operation
                                       in 1996) and any new or replacement or backup system that would be
                                       considered exempt from NSR permitting (R336.1285(t)), while meeting the
                                       design parameters and emission limits below.
Emission Unit/Process Groups
I. DESIGN PARAMETERS
A. Pollution Control Equipment         Fabric Filter
B. Stack/Vent Parameters               Exhaust gases shall be discharged horizontally.
           Stack/Vent ID               a. Minimum          b. Maximum              c.        d. Air       Applicable
                                          Height        Exhaust Dimension        Temp.       Flow        Requirement
                                          (feet)                                  (F)        Rate
                                                              (inches)
                                                                                            (acfm)
SV031                            4.0                10.0             NA         550      (R336.1201(3))
C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
           A. Material                                   Maximum Usage Rate
NA
          B. Pollutants                               Maximum Emission Limit
1. Particulate Matter        0.10 lbs/1,000 lbs. exhaust gas calculated on a dry gas basis.
                                                                                         (R336.1201(3))
2. PM (Opacity)              1. 20% opacity for the drill face.                       (R336.1301(1)(a))
                             2. 10% opacity from the exhaust stack.                   (R336.1301(1)(c))
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                           A. MONITORING/RECORDKEEPING (R 336.1213(3))
                              In Addition to General Requirements in Part A
1.   Continuous Emission          NA
     Monitoring (CEM) System
     and Recordkeeping
2.   Process Monitoring System The pressure drop across the fabric filter shall be monitored and recorded in
     and Recordkeeping            4 hour intervals when drilling for later installed explosive charges.
                                  Recordings reflecting values outside of the range set forth in V-
                                  OPERATIONAL PARAMETERS will require the facility to initiate corrective
                                  action per the facility’s operations and maintenance plan.   (R336.1213(3))
3.   Other Monitoring and/or      NA
     Recordkeeping
                             B. TESTING/RECORDKEEPING (R 336.1213(3))
                              In Addition to General Requirements in Part A
1.   Parameter to be Tested/      Visible emissions (opacity)
     Recorded
2.   Method/Analysis              Method 9                                         (40 CFR 60, Appendix A-4)
3.   Frequency and Schedule of 1. Visible emission observations will be made for a minimum 6 minute
     Testing/Recordkeeping             period at the exhaust outlet and at the drilling face during a drilling
                                       project.
                                  2. If the opacity limits are exceeded, as set forth in II IV-OTHER
                                       REQUIREMENTS, the drilling process will cease operation until such
                                       time repairs/corrections have been made. A 6-minute observation shall
                                       subsequently be made to assure compliance with the opacity limits set
                                       forth.
                                  3. Record logs will be kept of all observations and any repairs or remedial
                                       actions taken to address exceedances in opacity or operational in

                                                   Page 76 of 131
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                                                                                    Expiration Date: April 27, 2009

 TABLE F-1.14 FG014
 FLEXIBLE GROUPING REQUIREMENTS
                                           opacity or operational ranges.                             (R336.1213(3))

 IV. REPORTING
 Reports and Schedules                 1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                       (R 336.1213(3)(c)(ii))

                                       2. Semiannual reporting of deviations pursuant to Condition 23 of Part A.
                                          Due March 15 for reporting period July 1 to December 31 and
                                          September 15 for reporting period January 1 to June 30.
                                                                                          (R 336.1213(3)(c)(i))

                                       3. Annual certification of compliance pursuant to Conditions 28 and 29 of
                                          Part A. Due annually by March 15 for the previous calendar year.
                                                                                             (R 336.1213(4)(c))

                                       See Appendix 8.
  V. OPERATIONAL PARAMETERS
  Normal operating pressure drop range for the fabric filter will be provided to the appropriate District Office of the
  AQD within 90 days of the effective date of the ROP.
  VI. OTHER REQUIREMENTS
  NA
* This requirement is state enforceable only.




                                                  Page 77 of 131
                                                                               Permit Number: MI-ROP-B1743-2004
                                                                                      Expiration Date: April 27, 2009

TABLE F-1.15 FG015
FLEXIBLE GROUPING REQUIREMENTS
FLEXIBLE GROUPING                      FG015 Clinker storage and handling operation.
Emission Unit/Process Groups           EG034 Clinker storage hall
                                       EG036 No. 1 & No. 3 Open top clinker storage silos
                                       EG037 Hot clinker discharge/well
                                       EG038 Crane/clam bucket & mobile equipment
I. DESIGN PARAMETERS
A. Pollution Control Equipment         DV-034-2 Fabric Filter
                                       DV-034-3 Fabric Filter
                                       DV-034-4 Fabric Filter
B. Stack/Vent Parameters               Filtered exhausts and emissions from clinker transfer operations exhausted
                                       horizontally through natural draft storage hall louvered ventilator (SV047) or
                                       horizontally from openings at the point where the containment walls meet
                                       the descending roof, and the mobile vehicle openings to the hall (SV048).
           Stack/Vent ID               a. Minimum          b. Maximum              c.        d. Air       Applicable
                                          Height        Exhaust Dimension        Temp.       Flow        Requirement
                                          (feet)                                  (F)        Rate
                                                              (inches)
                                                                                            (acfm)
SV047                                   Approx 50        960 x 48 louvered        NA          NA              NA
                                                                 vent
SV048                                  1. NA            1. 2 - 264 x 348          NA          NA              NA
                                       2. 8             door openings
                                                        2. 52 x 9,660
                                                        ventilation opening
C. Other Design Parameters
NA
II. MATERIAL USAGE/EMISSION LIMITS
          A. Material                                Maximum Usage Rate
NA
         B. Pollutants                             Maximum Emission Limit
1. PM (Opacity)              10% Opacity (EG036 & EG037)
                                         (R336.1201(3)) & (40CFR63, Subpart LLL, Section 63.1348)
2. PM (Opacity)              20% Opacity (EG034 & EG038)                           (R336.1301(a))
III. COMPLIANCE EVALUATION
Records of all of the following shall be maintained on file for a period of 5 years. (R 336.1213(3)(b)(ii))
                         A. MONITORING/RECORDKEEPING (R 336.1213(3))
                            In Addition to General Requirements in Part A
1. Continuous Emission          NA
Monitoring (CEM) System and
Recordkeeping
2. Process Monitoring System    NA
and Recordkeeping
3. Other Monitoring and/or      NA
Recordkeeping
                           B. TESTING/RECORDKEEPING (R 336.1213(3))
                            In Addition to General Requirements in Part A
1. Parameter to be              Opacity (EG036 & EG037) (40 CFR 63, Subpart LLL, Section 63.1349(a))
Tested/Recorded
2. Method/Analysis              EPA Method 9 (as modified) – The performance test shall be conducted
                                under representative performance conditions in accordance with 40 CFR
                                63, Subpart A, Section 60.7(c) per revised (12/2002) 40 CFR 63, Subpart
                                LLL, Section 63.1349(b)(2). The maximum six-minute average opacity
                                exhibited during the test period shall determine compliance either from the
                                                   Page 78 of 131
                                                                     Permit Number: MI-ROP-B1743-2004
                                                                            Expiration Date: April 27, 2009

TABLE F-1.15 FG015
FLEXIBLE GROUPING REQUIREMENTS
                               hall louvered vent, access openings or ventilation openings. The duration of
                               the Method 9 Performance Test shall be 3-hours (30-6 minute averages),
                               except that the duration of the Method 9 Performance Test may be reduced
                               to 1-hour if it is found that no individual readings greater than 10 percent
                               opacity and there are no more than three readings of 10 percent for the first
                               1-hour period.
                               (40 CFR 60, Appendix A-4), (40 CFR 63, Subpart LLL, Section
                               63.1349(b)(2))
3. Frequency and Schedule of   Performance tests shall be conducted in accordance with Method 9 (as
Testing/Recordkeeping          modified within 180 days after initial startup. Visible emission observation
                               procedure must have prior approval by the AQD. (40 CFR 63, Subpart A,
                               Sections 63.7(a)(2)), (40 CFR 63, Subpart LLL, Section 63.1349(a)),
                               (R336.1213(3))
1. Parameter to be             Opacity (EG036 & EG037)
Tested/Recorded                                              (40 CFR 63, Subpart LLL, Section 63.150(a)(4))
2. Method/Analysis             1. EPA Method 22                                    (40 CFR 60, Appendix A-7)
                               2. EPA Method 9                                     (40 CFR 60, Appendix A-4)
3. Frequency and Schedule of   1. Monthly 1-minute visible emissions test in accordance with Method 22.
Testing/Recordkeeping                          (40 CFR 63, Subpart LLL, Section 63.1350(a)(4)(i))&(4)(vi))
                               2. If no emissions are observed in six consecutive months (utilizing
                                    Method 22), testing may be decreased from monthly to semi-annually.
                                    If visible emissions are observed during any semi-annual test, the
                                    facility must resume testing on a monthly basis until no visible
                                    emissions are observed in six consecutive monthly tests.
                                                       (40 CFR 63, Subpart LLL, Section 63. 1350 (a)(4)(ii))
                               3. If no visible emissions are observed during the semi-annual test
                                    (utilizing Method 22), the facility may decrease the frequency of testing
                                    to annually. If visible emissions are observed during any annual test,
                                    the facility must resume testing on a monthly basis and maintain that
                                    schedule until no visible emissions are observed in six consecutive
                                    readings.
                                                        (40 CFR 63, Subpart LLL, Section 63.1350 (a)(4(iii))
                               4. If visible emissions are observed during any Method 22 test, the facility
                                    must conduct a 6-minute test of opacity in accordance with Method 9.
                                    The Method 9 test must begin within one hour of any observation of
                                    visible emissions.
                                                         (40 CFR 63, Subpart LLL, Section 63.150(a)(4)(iv))
                               5. The facility shall maintain files of the required visible emission records in
                                    a form suitable and readily available for inspection and review as
                                    required by 40 CFR 63, Subpart A, Section 63.10 (b)(1). The files shall
                                    be retained for at least five years following the date of each occurrence
                                    and measurement. At a minimum, the most recent two years of data
                                    shall be retained on site. The files may be maintained on microfilm, on
                                    a computer, on floppy disks, on magnetic tape, or on microfiche.
                                                                (40 CFR 63, Subpart LLL, Section 63.155(a))
IV. REPORTING
Reports and Schedules          1. Prompt reporting of deviations pursuant to Condition 24 of Part A.
                                                                                    (R 336.1213(3)(c)(ii))

                               2. Semiannual reporting of deviations pursuant to Condition 23 of Part A.
                                  Due March 15 for reporting period July 1 to December 31 and
                                  September 15 for reporting period January 1 to June 30.
                                                                                    (R 336.1213(3)(c)(i))

                               3. Annual certification of compliance pursuant to Conditions 28 and 29 of

                                          Page 79 of 131
                                                                         Permit Number: MI-ROP-B1743-2004
                                                                                Expiration Date: April 27, 2009

 TABLE F-1.15 FG015
 FLEXIBLE GROUPING REQUIREMENTS
                                         Part A. Due annually March 15 for the previous calendar year.
                                                                                             R336.1213(4)(c))

                                     4. The results of opacity or visible emission evaluations as required under
                                        performance test requirements utilizing EPA Method 9 (as modified)
                                        shall be submitted to AQD within 60 days following the last date of the
                                        evaluation.
                                        (See Appendix 5)        (40 CFR 63, Subpart A, Section 63.7 (g)(1))
                                     See Appendix 8.
 V. OPERATIONAL PARAMETERS
 NA
 VI. OTHER REQUIREMENTS
 1. The facility shall have in place a written operations and maintenance plan. Included in this plan shall be
     procedures for proper operation and maintenance of the source and air pollution control devices in order to
     meet the emission and operating limits under 40 CFR 63.1348 and procedures for periodic monitoring of the
     source-subject to the opacity standards set forth under 40 CFR 63.1348. Such procedures shall also include
     provisions of paragraphs 63.1350 (a)(4)(i) thru (iv).        (40 CFR 63, Subpart LLL, Section 63.1350(a))
 2. The facility shall comply with all applicable requirements in Subpart LLL – National Emission Standards for
     Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.
                                                     (R336.1201(a)) & (R336.1205(1)) (40 CFR 63, Subpart LLL)

* This requirement is state enforceable only.




                                                Page 80 of 131
                                                                           Permit Number: MI-ROP-B1743-2004
                                                                                  Expiration Date: April 27, 2009

G. Non-Applicable Requirements
{CHOOSE: FIRST PARAGRAPH AND TABLE }

At the time of issuance, the AQD has determined the following requirements are not applicable to this source.
This determination is incorporated into the permit shield provision set forth in Part A (Conditions 30 through 33)
of this RO Permit pursuant to R 336.1213(6)(a)(ii).


                                 NON-APPLICABLE REQUIREMENTS TABLE

    Unit/Group ID        Rule/Regulation       Requirement Description                      Justification
                             Citation
FG008                    40 CFR 60,         Standards for particulate             Exempt from this subpart as the
                         Subpart F, Section emission limits & opacity limits for  kilns are now applicable to 40
                         60.60(b)           cement kilns with related testing,    CFR 63, Subpart LLL,
                                            monitoring and recordkeeping.         promulgated June 14, 1999
                                                                                  (reference Section 63.1356 for
                                                                                  exemption)
FG008                    Rule 336.1801        Schedule of NOx control and         Revised December 4, 2002, to
                         Article 4(e) & 8     CEM requirement for cement          only include non-sip sources.
                                              kilns.                              Rule 336.1817 now supercedes
                                                                                  as to applicability.
FG010                    40 CFR 60,           Particulate emission and opacity Not applicable as construction,
                         Subpart OOO,         limit standards for screening and reconstruction or modification was
                         Section 60.670(e)    conveyance of materials.            prior to August 31, 1983.
FG010                    40 CFR 60,           Opacity limit standard for material Exempt from this subpart as the
                         Subpart F, Section   conveyance.                         operations are now applicable to
                         60.60(b)                                                 40 CFR 63, subpart LLL
                                                                                  promulgated June 14, 1999.
                                                                                  (reference Section 63.1356 for
                                                                                  exemption)
FG012                    40 CFR 60,           Particulate emission and opacity Not applicable as constructing
                         Subpart OOO,         limit standards for bucket          reconstruction or modification was
                         Section 60.670(e)    elevator and conveyor material      prior to August 31, 1983.
                                              transfer.
FG012                    40 CFR 60            Opacity limit standards for the     Exempt from this subpart as the
                         Subpart F, Section   bucket elevator and conveyor        operations are now applicable to
                         60.60(b)             material transfer                   40 CFR 63, Subpart LLL,
                                                                                  promulgated June 14, 1999
                                                                                  (reference Section 63.1356 for
                                                                                  exemption).
FG003 & FG006            40 CFR 60,           Particulate emission and opacity Not applicable as construction,
                         Subpart OOO,         limit standards for an enclosed     reconstruction or modification was
                         Section 60.670(e)    truck loading station.              prior to August 31, 1983.
FG003 & FG006            40 CFR 60,           Opacity limit standards for a truck Exempt from this subpart as the
                         Subpart F, Section   bulk loading system.                operation is now applicable to 40
                         60.60(b)                                                 CFR 63, Subpart LLL,
                                                                                  promulgated June 14, 1999
                                                                                  (reference Section 63.1356 for
                                                                                  exemption)
FG009                    40 CFR 60,           Particulate emission and opacity Not applicable as construction,
                         Subpart OOO,         limit standards for enclosed        reconstruction or modification was
                         Section 60.670(e)    railcar station.                    prior to August 31, 1983.
FG009                    40 CFR 60,           Opacity limit standards for a       Exempt from this subpart as the
                         Subpart F, Section   railcar bulk loading system         system is now applicable to 40
                         60.60b                                                   CFR 63, Subpart LLL,
                                                                                  promulgated June 14, 1999
                                                 Page 81 of 131
                                                                      Permit Number: MI-ROP-B1743-2004
                                                                             Expiration Date: April 27, 2009
                                                                            (reference section 63.156 for
                                                                            exemption)
FG004 & EG013     40 CFR 60,           Particulate emission and opacity Not applicable as construction,
                  Subpart OOO,         limit standards for limestone        reconstruction or modification was
                  Section 60.670(e)    crushing.                            prior to August 31, 1983.
EG035             40 CFR 60            Particulate emission opacity limit Not applicable as operation is
                  Subpart OOO          standards for material convey or subject to the provisions in
                  Section 60.670(b)    transfer                             Subpart F.
EG035             40 CFR 60            Opacity limit standards for          Exempt from this subpart as the
                  Subpart F, Section   conveyor material transfer           operations are now applicable to
                  60.60(b)                                                  40 CFR 63, Subpart LLL,
                                                                            promulgated June 14, 1999,
                                                                            (reference Section 63.1356 for
                                                                            exemption).
EG034 & EG001-9   40 CFR 60            Particulate emission and opacity Not applicable as operation is
                  Subpart OOO          limit standards for storage bins     subject to the provisions in
                  Section 60.670(b)    (silos)                              Subpart F.
EG034 & EG001-9   40 CFR 60            Opacity limit standards for          Exempt from this subpart as the
                  Subpart F, Section   storage bins (silos)                 operations are now applicable to
                  60.60(b)                                                  40 CFR 63, Subpart LLL
                                                                            promulgated June 14, 1999
                                                                            (reference section 63.1356 for
                                                                            exemption).
FG002 & EG030 &   40 CFR 60,           Particulate emission and opacity Not applicable as construction,
EG031             Subpart OOO,         limit standards for storage bins     reconstruction or modification was
                  Section 60.670(e)    (silos)                              prior to August 31, 1983.
FG002 & EG030 &   40 CFR 60,           Opacity limit standards for          Exempt from this subpart as the
EG031             Subpart F, Section   storage bins (silos)                 operations are now applicable to
                  60.60(b)                                                  40 CFR 63, Subpart LLL,
                                                                            promulgated June 14, 1999
                                                                            (reference Section 63.1356 for
                                                                            exemption).
FG005             40 CFR 60,           Particulate emission and opacity Exempt from this subpart as the
                  Subpart OOO,         limit standards for bagging          systems were applicable to 40
                  Section 60.670(b)    operations.                          CFR 60, Subpart F.
FG005             40 CFR, Subpart      Standards for opacity limits for     Exempt from this subpart as the
                  F, Section           bagging systems.                     systems are now applicable to 40
                  60.60(b)                                                  CFR 63, Subpart LLL promulgated
                                                                            June 14, 1999 (reference section
                                                                            63.1356 for exemption).
FG001             40 CFR 60,           Particulate emission and opacity Not applicable as construction,
                  Subpart OOO          limit standards for grinding mills. reconstruction or modification was
                  Section 60.670(e)                                         prior to August 31, 1983.
FG001             40 CFR, Subpart      Opacity limit standards for finish Exempt from this subpart as the
                  F, Section           mill systems.                        operations are now applicable to
                  60.60(b)                                                  40 CFR 63, Subpart LLL,
                                                                            promulgated June 14, 1999
                                                                            (reference Section 63.156 for
                                                                            exemption).
FG007             40 CFR 60,           Standards for particulate            Exempt from this subpart as the
                  Subpart F, Section   emission limits for clinker coolers clinker coolers are now applicable
                  60.60(b)             with related testing monitoring      to 40 CFR 63, Subpart LLL,
                                       and recordkeeping.                   promulgated June 14, 1999
                                                                            (reference Section 63.1356 for
                                                                            exemption)




                                          Page 82 of 131
                                                                            Permit Number: MI-ROP-B1743-2004
                                                                                   Expiration Date: April 27, 2009

Appendices

Appendix 1. Abbreviations Used in This Permit

The following is an alphabetical listing of all abbreviations/acronyms used in this RO Permit.

acfm                     Actual cubic feet per minute
AFM                      Alternative Fuel/Material
Ag                       Silver
AQD                      Air Quality Division
As                       Arsenic
Ba                       Barium
Baghouse                 Fabric Filter Collector
Be                       Beryllium
BrCH2CH2Br               Ethylene Dibromide
BTU                      British Thermal Unit
CAA                      Federal Clean Air Act
C6Cl6                    Hexachlorobenzene
Cd                       Cadmium
CDDs                     Chlorinated Dibenzo-p-dioxins
CDFs                     Chlorinated Dibenzofurans
CEM                      Continuous Emission Monitor(ing)
CFR                      Code of Federal Regulations
C6H3ClNH2C6H3ClNH2       3,3-Dichlorobenzidine
C10H7NH2                 2-Naphthylamine
CKD                      Cement Kiln Dust
°C                       Degrees Centigrade
CMS                      Continuous Monitoring System (Emissions or Opacity)
CO                       Carbon Monoxide
COM                      Continuous Opacity Monitoring
Cr                       Chromium
Cu                       Copper
DEQ                      Michigan Department of Environmental Quality
D/F                      Dioxin Furan
DRE                      Destructive Removal Efficiency
dscf                     Dry Standard Cubic Foot
dscm                     Dry Standard Cubic Meter
DV                       Process or Control Device ID
EER                      Excess Emission Report
EG                       Emission Unit/Process Group ID
EPA                      United States Environmental Protection Agency
°F                       Degree Fahrenheit
FG                       Flexible Group ID
gr                       Grain (7000 gr= 1 lb.)
HCFC                     Hydrochlorofluorocarbon
Hg                       Mercury
hr                       Hour
ID                       Identification (Number)
Kg                       Kilogram (1000 grams)
lbs                      Pounds
  3
M                        Cubic Meters
Mg                       Megagram (1 million grams)
                                         -6
µg                       Microgram (10 grams)
MMBTU                    1 million BTUs
MVAC                     Motor vehicle air conditioner
Mn                       Manganese

                                                  Page 83 of 131
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Ni      Nickel
NA      Not applicable
                         -g
Ng      Nanograms (10 grams)
NOx     Oxides of Nitrogen
NO2     Nitrogen Dioxide
O2      Oxygen
Pb      Lead
PCB     Polychlorinated Biphenyl
Pet     Petroleum
PM      Particulate Matter
PMCD    Particulate Matter Control Device
POMS    Parametric Operating Monitoring System
pph     Pounds per hour
ppm     Parts per million
ppy     Pounds per year
QAP     Quality Assurance Procedures
RCRA    Resource Conservation and Recovery Act
RMP     Risk Management Plan
RO      Renewable Operating Plan
RTO     Regenerative Thermal Oxydizer
Sb      Antimony
Se      Selenium
SRN     State Registration Number
SV      Stack/Vent ID
SO2     Sulfur Dioxide
TEQ     International method of expressing toxicity equivalents for dioxins and furans as defined
        in U.S.E.P.A., Interim Procedures for Estimating Risks Associated with Exposures to
        Mixtures of CDDs and CDFs, 1989.
TDF     Tire Derived Fuel
THC     Total Hydrocarbon
Tl      Thallium
Tonne   Metric ton (2,205 lbs)
tpy     Tons per year
VOC     Volatile Organic Compound
yr      Year
Zn      Zinc
≤       Less than or equal to
≥       Greater than or equal to
<       Less than
>       Greater than




                                Page 84 of 131
                                                                         Permit Number: MI-ROP-B1743-2004
                                                                                Expiration Date: April 27, 2009

Appendix 2. Schedule of Compliance

The permittee has certified that this source is in compliance with all applicable requirements as of the date of
issuance of this RO Permit and the permittee shall continue to comply with all applicable requirements listed in
this RO Permit. A detailed Schedule of Compliance is not required.       (R 336.1213(4)(a), R 336.1119(a)(ii))




                                                Page 85 of 131
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                                                                                 Expiration Date: April 27, 2009


Appendix 3. Monitoring Requirements

The following monitoring procedures, methods, or specifications are the details to the monitoring requirements
and referenced in Table F-1.8.




       ALTERNATIVE FUELS AND MATERIALS
            MANAGEMENT PROCESS




                                                Page 86 of 131
                                                                             Permit Number: MI-ROP-B1743-2004
                                                                                    Expiration Date: April 27, 2009
Executive Summary

The Dundee Plant of Holcim (US) Inc., located in Monroe County, Michigan, is supplying additional information to
clarify the Alternative Fuels and Materials Management Program. The AFM Management Program would be used
to assure all non-hazardous alternative fuels and materials are having a quality control process through the three (3)
process controls prior to Co-processing these AFM into the kiln. The three(3) quality process control are: Potential
AFM Qualification Analysis, Individual Shipments, and POMS Control.

In the Qualification Analysis Process, the potential AFM is thoroughly reviewed for non-hazardous characteristics,
consistency with generator information, requirements for handling and storage, ability to meet POMS requirements,
internal use fitness for use, and approval by the plant manager. Basically this is the first screening level for the
potential use of the AFM from a specific source.

The Individual Shipment Module will screen the incoming AFM to assure conformance with the non-hazardous
characteristics and to verify that the characteristics of the material are the same as analyzed previously.

Finally, the POMS Control Module will control the final AFM blend ready to be co-processed in to the kiln, and to
assure a consistent quality of the AFM stream.

The proposed AFM Management Process will be used for all AFM assuring a controlled and documented system,
and will provide a system easily audited by MDEQ.




                                                   Page 87 of 131
                                                                              Permit Number: MI-ROP-B1743-2004
                                                                                     Expiration Date: April 27, 2009
                                         AFM MANAGEMENT PROCESS

The AFM Management Program (see Figure 1) would be used to assure all non-hazardous fuels and materials are
thoroughly reviewed using the three (3) process controls prior to co-processing. The three- (3) process controls are:
Potential AFM Pre-Qualification Analysis, Individual Shipments, and POMS Control.

QUALIFICATION ANALYSIS

In the Potential AFM Qualification Analysis process control (see Figure 2), the potential AFM is thoroughly reviewed
prior to being approved for its usage. This module has many steps included to assure that all potential issues can be
identified and considered in the ultimate use, or rejected from consideration. The steps are:

        1) AFM Generator identified as a potential candidate.
           Generator is a producer of a non-hazardous industrial waste (e.g. car that generates used oil).
           In this step, a Generator, could be previously identified by the Plant, or can be a company, which ask for
           an environmental way of disposal of their by-products.
           At this point all the information related with this potential AFM must be documented in a proper manner,
           following a consecutive order on the file numbering.


        2) Non-Hazardous review performed.
           The potential AFM must be analyzed under the MI Act 451 Part III, [40 CFR Part 261], to determine if the
           material is considered a non-hazardous waste material. In case that this material falls under the hazardous
           waste classification, the AFM candidate must be rejected and documented in their respective file.

        3) Complete AFM Profile Form to identify generator information and additional chemical characteristics.
           See attached Holcim Material Profile (Attachment A)

        4) Completeness checks of AFM Profile Form.
           At this point the evaluation of the Profile must have: (1) The business activity or process type of waste
           generation, (2) Storage and current treatment,
           (3) physical and chemical characteristics of the AFM candidate, (4) Health and Safety data (MSDS if
           available), (5) Existing stock volumes and monthly generated volumes, (6) Transport conditions

        5) Perform analysis of AFM candidate for consistency with AFM Profile Form.
           Take a representative sample from the projected generated volume, and run a laboratory test to confirm
           the data provided at the Profile. If the laboratory results shows a sustainable difference with the data
           provided from the Generator and the AFM results hazardous the candidate must be rejected, documenting
           with all this information.

        6) Review the handling and storage requirements based on chemical characteristics to determine
           cost/benefit.
           The AFM candidate must be reviewed under the applicable regulations for its handling requirements,
           storage conditions, and under the MSHA rules.
           Once that all this requirements are reviewed, a cost-benefit evaluation must be performed in order to
           determine the feasibility of accepting this AFM at the Plant.

        7) Perform applicable requirement review using the POMS
           Feed the Parametric Operating Monitoring System with the information of the AFM candidate and
           determine if the material is suitable to co-process in the kiln




                                                   Page 88 of 131
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                                                                                         Expiration Date: April 27, 2009
        8) Perform an internal acceptance review including Quality Department, Environmental Health and Safety
           Department, and the Kiln Processing Area.
           A process review must be performed in all the areas related with the cement manufacturing process at the
           plant level. At this material the AFM candidate can be rejected for any of the involved areas.

        9) Present to Plant Manager for AFM approval.
           With all the 8 steps documented, the file is submitted to the Plant Manager for review and further approval
           or rejection

        10) Address financial and logistics issues with AFM Generator.
            At this point a financial analysis is performed in order to determine the disposal fee.

        11) Approved AFM
            A contract and arrangement for AFM deliveries must be created.

At any point in the above process, the AFM Candidate could be rejected from consideration in the AFM Program, for
every AFM candidate there has to be a file, even if the material is rejected all of the information must be documented.

INDIVIDUAL SHIPMENTS

The Individual Shipment Module (see Figure 1) will provide on-site screening of the incoming AFM to assure
conformance with the AFM Profile characteristics. Individual shipments will have a fingerprint analysis performed to
verify that the AFM received meets the original characteristics defined in the Qualification Analysis process control.
AFM that passes the fingerprint analysis will be accepted on-site. AFM that fails the fingerprint analysis will be rejected
and the proper notifications made to the appropriate MDEQ agency and the AFM Generator.

Periodic quality control checks will be performed to assure that the fingerprint analysis accurately identifies the AFM
characteristics.

Every load of AFM that comes to the plant must be documented with a consecutive number indicating all the
information that corresponds to that shipment.

                   PARAMETRIC OPERATING AND MONITORING SYSTEM (“POMS”) Control

The POMS Control Module (see Figure 1) will control the final AFM blend previous to be co-processed in to the kiln.
Each individual shipment that passes the fingerprint analysis will be blended with other approved AFM. The final blend
will be input into the POMS for final confirmation with applicable requirements.

An analysis of the blending material must be perform in order to assure the compliance with all applicable regulations
and process control, to assure health and safety standards and to prevent any environmental risks.

Once confirmed using POMS, the AFM will be co-processed in to the kiln

                                                       SUMMARY

The AFM Management Plan is a systematic approach that will review and check all potential AFM candidates. All
AFM received by Holcim will be pre-approved according to procedures identified in Holcim’s AFM Management
Process. By taking a potential AFM through the Qualification Analysis Module, Holcim will insure that the approved
AFM will be non-hazardous, and storage and handling requirements identified. The analysis of individual shipments
will verify conformance with previous approval. A final use of the POMS will control and document the introduction
of the AFM in the kiln co-processing.



                                                     Page 89 of 131
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                                                                                        Expiration Date: April 27, 2009




                                   MATERIAL PROFILE FORM

                                  Profile No. _______________

                                          I. General Information

1. Material Common Name:

2. Provide a description of the process(es) generating this material:




3. Estimated Volume of Material available (total & per month):                               Units:

4. Location of Material:

                                        II. Generator Information

1. Generator Name:                                                 2. Telephone No.:

3. Address:                                                        4. Fax No.:

                                                                   5. Email Address:

6. Contact:                                                        7. Title:

                                          III. Billing Information

1. Invoicing Name:                                                 2. Telephone No.:

3. Address:                                                        4. Fax No:

                                                                   5. Email Address:

6. Contact:                                                        6. Title:

7. Purchase Order No.




                                        IV. Sampling Information

                                                   Page 90 of 131
                                                                                               Permit Number: MI-ROP-B1743-2004
                                                                                                      Expiration Date: April 27, 2009
Sample Instructions:
1.       A representative one-quart sample of the material must accompany this profile form to initiate the
         approval process.
2.       The sample taken should be representative of the material intended for shipment.
3.       Sampling of the material should be completed as per standard regulatory guidelines.
4.       Sampling equipment used must be those specified in standard regulatory guidance.
5.       The sample label must include generator name, profile number and material description.
6.       A completed sample custody transfer record must accompany the sample.

Sampling completed by (print):
Sampler signature:
Date sample was collected:

                                              V. Physical Characteristics
                                                                      o
1. Select one or more general descriptions for the material at 70 F:
                        Powdery Solid                                         Sludge (non pumpable)
                        Dry Solid                                             Liquid (pumpable)
                        Solids with free liquid                               Liquid (multi-phase)
                        Debris or Other                                       Soils

Describe additional physical characteristics:



2. Does the waste have a characteristic odor(s)?                          (     ) Strong   (     ) Moderate    (   ) Slight   (   )

None

Describe characteristic odor(s):

3. Color description:

4. Heat value (Btu/lb):

5. Density:                                           Units:

6. pH:                                                Water Extract pH:

7. Flash Point (°F):

8. Reactive with air or water?      (   ) Yes     (   ) No

                                                  V. Chemical Parameters
1. Based upon lab analyses and/or knowledge of the process(es) generating the material, list the chemical
  components with the minimum and maximum concentrations expected.
                             Constituent                                    Minimum                  Maximum




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                                                                                     Expiration Date: April 27, 2009




   Total




2. Water Content (%):                              3. Sulfur Content (ppm):

4. Halogen Content (ppm):

5. Total Metal Concentration (MI Air Toxics):
Metal Constituent (mg/Kg)                                    Minimum                 Maximum

Antimony (Sb)

Arsenic (As)

Barium (Ba)

Beryllium (Be)

Cadmium (Cd)

Chromium (Cr)
                                                Page 92 of 131
                                              Permit Number: MI-ROP-B1743-2004
                                                     Expiration Date: April 27, 2009

Copper (Cu)

Lead (Pb)

Manganese (Mn)

Mercury (Hg)

Nickel, soluble salts (Ni)

Selenium (Se)

Silver (Ag)

Thallium (Tl)

Zinc (Zn)




                             Page 93 of 131
                                                                                                 Permit Number: MI-ROP-B1743-2004
                                                                                                        Expiration Date: April 27, 2009

                                               VI. Material Hazards
1. Based upon RCRA Hazardous Waste Regulations (40 CFR 261):

Does this waste meet any F, K, P or U Hazardous Waste Listing Description(s)?                (        ) Yes     (       ) No

        List any applicable Listed Waste Code(s):

Does this waste exhibit Ignitability (D001), Corrosivity (D002) or Reactivity (D003)?             (     ) Yes       (     ) No

        List any applicable Characteristic Waste Code(s):

Does this waste contain cyanide amenable to chlorination above 250 ppm?                                       (         ) Yes    (   ) No

Does this waste contain reactive sulfide above 500 ppm?            (   ) Yes   (      ) No



    Is this a California List hazardous waste containing halogenated organic compounds found in
    Appendix III of 40 CFR 268 in total concentrations greater than or equal to 1000 mg/L? ( )
    Yes ( ) No


    2. Does the waste exhibit Toxicity characteristics defined by the Toxicity Characteristic Leaching
    Procedure (TCLP) test (See 40 CFR 261.24, Table 1, D004 – D043)? ( ) Yes ( ) No

3. Other regulated waste materials:

Does the waste contain any radioactive material?        (     ) Yes    (   ) No

Does the waste contain any biological or infectious waste(s)?          (   ) Yes      (   ) No

Does the waste contain asbestos?      (   ) Yes     (       ) No

Does this waste contain PCBs greater than 49 ppm?            (     ) Yes   (   ) No

If “Yes” indicate which TCLP constituent has been tested (Attach laboratory results). For those constituents not tested
mark “No”. If the reason that the waste has not been tested is because the constituent is not believed to be applicable to
the material mark “N/A”. Either “Yes”, “No” or “N/A” MUST be checked for each and every constituent.




                                                            Page 94 of 131
                                                                    Permit Number: MI-ROP-B1743-2004
                                                                           Expiration Date: April 27, 2009

                                   40 CFR, Part   MI R 299.4114   TCLP Analytical        Testing:
Code          Constituent             261.24       Regulatory       Test Level         Yes, No, N/A
                                    Regulatory         Limit          (mg/l)
                                       Limit          (mg/l)
                                      (mg/l)
Metals
D004            Arsenic                5.0             0.5

 D005            Barium               100.0           10.0

 D006          Cadmium                 1.0             0.1

 D007          Chromium                5.0             0.5

                 Copper                N/A            10.0

 D008             Lead                 5.0             0.5

              Manganese                N/A             0.5

 D009     Mercury (inorganic)          0.2            0.02

          Nickel (soluble salts)       N/A             1.0

 D010           Selenium               1.0             0.1

 D011             Silver               5.0             0.5

                  Zinc                 N/A            50.0

Organic
   s
 D012            Endrin                0.02

 D013           Lindane                0.04

 D014        Methoxychlor              10.0

 D015          Toxaphene               0.5

 D016             2,4-D                10.0

 D017           2,4,5-TP               1.0

 D018           Benzene                0.5            0.05

 D019     Carbon Tetrachloride         0.5            0.05

 D020          Chlordane               0.03

 D021       Chlorobenzene             100.0           10.0

 D022          Chloroform              6.0             0.6

 D023           o-Cresol              200.0           20.0

 D024           m-Cresol              200.0            20.0
                                         Page 95 of 131
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                                                                Expiration Date: April 27, 2009

D025         p-Cresol          200.0           20.0

D026          Cresol           200.0           20.0

D027   1,4-Dichlorobenzene      7.5            0.75

D028    1,2-Dichloroethane      0.5            0.05

D029   1,1-Dichloroethylene     0.7            0.07

D030    2,4-Dinitrotoluene     0.13

D031        Heptachlor         0.008

D032   Hexachlorobenzene       0.13

D033   Hexachlorobutadiene      0.5

D034    Hexachloroethane        3.0

D035   Methyl Ethyl Ketone     200.0           10.0

D036      Nitrobenzene          2.0

D037    Pentachlorophenol      100.0           10.0

D038         Pyridine           5.0

D039   Tetrachloroethylene      0.7            0.07

D040     Tricholorethylene      0.5            0.05

D041   2,4,5-Trichlorophenol   400.0           40.0

D042   2,4,6-Trichlorophenol    2.0                0.2

D043      Vinyl Chloride        0.2            0.02




                                  Page 96 of 131
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                                                                                               Expiration Date: April 27, 2009

                                             VII. List Of Attachments
List and attach all analytical data, MSDSs or other information that will help to characterize this waste material.

Informational Instructions:

1.      All forwarded analytical data must be applicable to the actual material intended to be shipped and come from a
        representative sample of that material.
2.      Please attach all applicable QA/QC and chain of custody documentation for the sample data must also be
        forwarded with the data.
3.      Please attach information about the laboratory conducting of any of the reported analyses including the name,
        address, phone number and laboratory contact.

     Attachment                                                       Description




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                                                                                              Expiration Date: April 27, 2009



                                         VIII. Generator Certifications
I, the Supplier, certify, represent and warrant that the material presented and described herein is not a listed or
characteristic hazardous waste and that the information presented in this profile and any attachment is complete and
accurate to the best of my knowledge. I further certify that the analytical data and other information submitted with this
AFR profile is applicable to the material intended for shipment and was obtained according to proper sampling and
analytical guidelines.

I further certify, represent and warrant that, to the best of its knowledge, there have been no changes in the process
generating the waste that would alter the characterization of the material described herein and in any of the attachments.

I certify that based upon my knowledge of the waste material and the process generating the waste, the TCLP constituents
listed as N/A in Section VI Material Hazards are not present in the waste in concentrations above hazardous classification
levels.

I understand that it is my obligation to immediately inform Holcim of any changes in the generating process that may alter
the characteristics of the material described herein.

For brokered account, the brokering agent must include a signed affidavit from the generating company authorizing the
broker to act as the representative of the generating company for the purpose of profiling the waste material and
contracting with Holcim for it deliver to the facility.



Date:


Name:                                                      Signature:


Company:                                                   Title:




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                                                                                      Permit Number: MI-ROP-B1743-2004
                                                                                             Expiration Date: April 27, 2009


Holcim’s Acceptance is based on the information provided by your company on this Certification Form, the associated test
data and other representations of your company. Your company shall absolutely and unconditionally protect, defend,
indemnify and save harmless Holcim and its present and future officers, directors, shareholders, agents and employees of
Holcim from and against any and all fines, loss, damage, injury, liability to or death of any person, costs of response to any
governmental inquiry, request, or requirement or for loss of or damage to property or for loss or damage arising from
attachments, liens or claims of material men or laborers, claims and reasonable attorneys’ fees and costs relating to any of
the foregoing (“Claims”), resulting from Company’s activities, from Company’s tender of Non-conforming Materials or from
Company’s breach of the Agreement, whether or not Holcim, or its officers, directors, shareholders, agents or employees
was or is claimed to be concurrently or comparatively negligent, and regardless of whether liability without fault is imposed,
or sought to be imposed, on Holcim. The foregoing indemnification shall not apply to the extent that such indemnity is void
or otherwise unenforceable under applicable law in effect on or validly retroactive to the date of this Agreement, or the date
of the claim, and shall not apply where such Claims are the result of the sole negligence or willful misconduct of Holcim. It
is intended that the foregoing indemnity shall be broad and comprehensive. This indemnity shall survive the expiration or
other termination of this Agreement. This indemnity is for the sole benefit of Holcim and not for the benefit of any third
party.




                                                       Page 99 of 131
                           Permit Number: MI-ROP-B1743-2004
                                  Expiration Date: April 27, 2009




1 AFM Management Program




       Page 100 of 131
                  Permit Number: MI-ROP-B1743-2004
                         Expiration Date: April 27, 2009




Page 101 of 131
                               Permit Number: MI-ROP-B1743-2004
                                      Expiration Date: April 27, 2009


2 Potential AFM Qualification Analysis




             Page 102 of 131
                  Permit Number: MI-ROP-B1743-2004
                         Expiration Date: April 27, 2009




Page 103 of 131
                                                                           Permit Number: MI-ROP-B1743-2004
                                                                                  Expiration Date: April 27, 2009



Appendix 4. Recordkeeping

Specific recordkeeping requirement formats and procedures are detailed in Part A or the appropriate Requirement
Tables. Therefore, this appendix is not applicable.




                                                Page 104 of 131
                                                                                 Permit Number: MI-ROP-B1743-2004
                                                                                        Expiration Date: April 27, 2009


Appendix 5. Testing Procedures

The facility shall use the following test method to measure the visible emissions for the applicable requirements
referenced in Table E-1.3.

R 336.2034 REFERENCE METHOD 9D

Rule 1034 Reference Method 9D, Opacity Measurement for Fugitive Dust Sources Reads as Follows:

(A) Visible emissions of fugitive dust shall be determined according to Test Method 9 as set forth in the “Appendix
on Test Methods” in 40 CFR, Part 60, “Standards of Performance for New Stationary Sources” as such appendix
existed on October 31, 1984, with the following modifications:

(i) The data reduction provisions of Section 2.5 of Method 9 shall be based on an average of 12 consecutive
readings recorded at 15 second intervals.

(ii) For roadways and parking lots, opacity observations shall be made from a position such that the observer’s line
of vision is approximately perpendicular to the plume direction and approximately 4 feet directly above the surface of
the road or parking area from which the emission are being generated. The observer shall not look continuously at
the plume, but instead shall observe the plume momentarily at 15-second intervals at the point of maximum plume
density. Consecutive readings must be suspended for any 15-second period if a vehicle is in the observer’s line of
sight. If this occurs, a “V” shall be used in lieu of a numerical value, and a footnote shall be made to indicate that
“V” signifies that the observer’s view was obstructed by a vehicle. Readings shall continue at the next 15-second
period, and they shall be considered consecutive to the reading immediately preceeding the 15-second period
denoted by a “V.” Consecutive readings also must be suspended for any 15-second period if a vehicle passes
through the area traveling in the opposite direction and creates a plume that is intermixed with the plume being
read. If this occurs, an “I” shall be used in lieu of a numerical value, and a footnote shall be made to indicate that “I”
signifies that the readings were terminated due to interference from intermixed plumes. Readings shall continue
when, in the judgment of the observer, the plume created by the vehicle traveling in the opposite direction no longer
interferes with the plume originally being read; and they shall be considered consecutive to the reading immediately
preceeding the 15-second period denoted by an “I.” Intermixing of plumes from vehicles traveling in the same
direction represents the road conditions, and reading shall continue in the prescribed manner. A reading
encompassing an unusual condition (such as a broken bag of cement of the pavement) cannot be used to represent
the entire surface condition involved. In such cases, another set of reading, encompassing the average surface
condition, must be conducted. For all other sources of fugitive dust except roadways and parking lots, opacity
observations shall be made from a position that provides the observer a clear view of the source and the fugitive
dust with the sun behind the observer. A position at least 15 feet from the source is recommended. To the extent
possible, the line of sight should be approximately perpendicular to the flow of fugitive dust and to the longer axis of
the emissions. Opacity observations shall be made for the point of highest opacity within the fugitive dust. Since
the highest opacity usually occurs immediately above or downwind of the source, the observer should normally
concentrate on the area or areas of the plume close to the source.




                                                    Page 105 of 131
                                                                                Permit Number: MI-ROP-B1743-2004
                                                                                       Expiration Date: April 27, 2009
APPENDIX 5. Testing Procedures (continued)

The facility shall use the following approval test plans, procedures, and average times to measure the visible
emissions for the applicable requirements referenced in Table F-1.3

The source will run at the highest load or capacity level reasonably expected to occur. The maximum 6 minute
average will be utilized to determine initial compliance. The duration of the performance test shall be 3-hours (thirty
(30) 6-minute averages. This duration may be reduced to 1-hour if no individual reading are greater than 10 percent
opacity and there are no more than three readings of 10 percent for the first 1-hour period.

The facility shall use the following procedures and specifications in measuring material limits for the applicable
requirements referenced in Table F-1.8.

                                         USED OIL FUEL SPECIFICATION


Constituent/Property                                       Allowable Level*


Arsenic                                                    ≤ 5 parts per million (PPM) by weight

Cadium                                                     ≤ 2 ppm

Chromium                                                   ≤ 10 ppm

Lead                                                       ≤ 100 ppm

Flash Point                                                ≤ 100°F

Total Halogens                                             ≤ 1,000 ppm

PCB’s                                                      ≤ 49 ppm


*These values are maximums, except for flash point which is a minimum. A halogen level exceeding 1000 ppm is
presumed to be a hazardous waste unless otherwise demonstrated. Used oil that has been contaminated with any
halogenated solvents shall not be used as supplemental fuel.




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                                                                                         Expiration Date: April 27, 2009



                                            Definition of Hazardous Waste


A chemical waste is considered to be hazardous if the waste exhibits any of the following characteristics:

Ignitability

A substance is considered to be ignitable if it exhibits any of the following properties


1. It is a liquid, other than an aqueous solution containing less than 24% alcohol by volume and has a flash point
   less than 60 degree C (140 degrees F), as determined by the Pensky-Martens Closed Cup Tester.
2. It is not a liquid and is capable, under standard temperature and pressure, of causing fire through friction,
   absorption of moisture or spontaneous chemical changes and, when ignited, burns so vigorously and
   persistently that it creates a hazard.
3. It is a flammable compressed gas.
4. It is an oxidizer such as chlorates, permanaganates, inorganic peroxides, or nitrates that yield oxygen readily to
   stimulate the combustion of organic matter.


Corrosivity

A substance if considered to be corrosive if it exhibits any of the following properties:

1. It is aqueous and has a pH less than or equal 2 or greater than or equal 12.5 as determined by a pH meter
   using either en EPA or equivalent test method.
2. It is a liquid and corrodes steel (SAE 1020) at a rate greater than 6.35 mm/year at 55 degrees C.


Reactivity

A substance is considered to be reactive if it exhibits any of the following properties:

1.   It is normally unstable and readily undergoes violating change without detonating.
2.   It reacts violently with water.
3.   It forms potentially explosive mixtures with water.
4.   When mixed with water, it generates toxic gases, vapors, or fumes in a quantity sufficient to present a danger to
     human health or the environment.
5.   It is a cyanide of sulfide bearing waste which, when exposed to Ph conditions between 2 and 12.5, can generate
     toxic gases, vapors, or fumes in a quantity sufficient to present danger to human health of the environment.
6.   It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under
     confinement.
7.   It is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure.
8.   It is a forbidden explosive as defined by 49 CFR 173.53, or a class B explosive as defined in 49 CFR 173.88.




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                                                                                    Expiration Date: April 27, 2009

                              Toxicity Characteristic Leaching Procedure (TCLP)

This characteristic identifies wastes from which certain toxic materials could be leached into groundwater supplies
and is defined by a prescribed test procedure for water extraction of the waste. The extract us analyzed for
concentrations of eight elements or ions; Arsenic, Barium, Cadmium, Chromium (VI), Lead, Mercury, Selenium, and
Silver: and the thirty-one organic substances listed below.

Benzene
Carbon Tetrachloride
Chlordane
Chlorobenzene
Chloroform
o-Cresol
m-Cresol
p-Cresol
1,4-Dichlorobenzene
1,2-Dichloroethylene
1,1-Dichloroethylene
2,4-Dinitrotoluene
Endrin
Heptachlor
Hexachlorobenzene
Hexachloro-1,3-butadiene
Hexachloroethane
Lindane
Methoxychlor
Methyl ethyl ketone
Nitrobenzene
Pentachlorphenol
Pyridine
Tetrachloroethylene
Toxaphene
Trichloroethylene
Toxaphene
Trichloroethylene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Vinyl chloride
2,4-D
2,4,5-TP Silvex




                                                 Page 108 of 131
                                                                         Permit Number: MI-ROP-B1743-2004
                                                                                Expiration Date: April 27, 2009
                          Acceptable Fuels and Materials Generated Offsite


Waste Type                       Process of Generation                    Typical Waste
Liquid (Non-hazardous)           Waste from machining, lubricating,        Waste machine oils
                                 and cooling operations                    Waste machining oils (not
                                                                               emulsioned)
                                                                           Waste machining emulsions
                                                                           Synthetic machining oils
Liquid (non-hazardous)           Waste hydraulic oils and brake fluids     Hydraulic oils (not emulsions)
                                                                           Emulsions
                                                                           Hydraulic oils containing only
                                                                               mineral oil
                                                                           Other hydraulic oils
Liquid (non-hazardous)           Waste engine, gear and lubricating       Waste engine, gear and lubricating
                                 oils                                     oils
Liquid (non-hazardous)           Waste insulating and heat                 Insulating and heat transmission
                                 transmission oils and other liquids           oils and other liquids
                                                                           Synthetic insulating and heat
                                                                               transmission oils and other
                                                                               liquids
                                                                           Mineral insulating and heat
                                                                               transmission oils and other
                                                                               liquids
Liquid (non-hazardous)           Bilge Oils                                Bilge oils from inland navigation
                                                                           Bilge oils from jetty sewers
                                                                           Bilge oils from other navigation
Liquid (non-hazardous)           Waste from organic dyes and               Aqueous washing liquids and
                                 pigments                                      mother liquids.
                                                                           Aqueous liquids containing
                                                                               adhesive and sealants
Liquid (non-hazardous)           Wastes from the manufacturing of         Aqueous washing liquids and mother
                                 plastics, synthetic rubber and man-      liquids.
                                 made fibers
Liquid (non-hazardous)           Wastes from the manufacturing of         Aqueous washing liquids and mother
                                 pharmaceuticals                          liquids.
Liquid (non-hazardous)           Wastes from the manufacturing of         Aqueous washing liquids and mother
                                 fats, grease, detergents,                liquids.
                                 disinfectants and cosmetics.
Liquid (non-hazardous)           Waste from oil regeneration              Aqueous liquid waste from oil
                                                                          regeneration.
                                 Agricultural oils and wastes              Vegetable oil, soy bean oil,
                                                                              canola oil, sunflower oil, etc.
                                                                           Products from animal and food
                                                                              rendering industry
Liquid (non-hazardous)           Petroleum refinery wastes                Waste oils
Liquid (non-hazardous)           Iron and steel manufacturing wastes      Waste oils and liquids
Liquid (non-hazardous)           Food Processing Wastes                   Liquid food processing wastes
Sludges (non-hazardous)          Oil/water separator contents              Oil/water separator sludges
                                                                           Interceptor sludges
                                                                           Desalter sludges or emulsions
                                                                           Other emulsions
Sludges (non-hazardous)          Waste paint and coatings from            Paint and coating sludges
                                 manufacturing and productions
                                 operations
Sludges (non-hazardous)          Wastes from the manufacture and          Adhesive and sealants wastes
                                 application of printing inks
Sludges (non-hazardous)          Wastes from pulp, paper and                 Sludges from paper recycling


                                              Page 109 of 131
                                                                 Permit Number: MI-ROP-B1743-2004
                                                                        Expiration Date: April 27, 2009
                          cardboard productions and                  Fiber, pulp, and paper sludges
                          processing
Sludges (non-hazardous)   Wastes from the manufacturing and       Ink wastes
                          application or printing inks.
Sludges (non-hazardous)   Wastes from anaerobic treatment of      Anaerobic treatment sludges of
                          wastes                                  municipal and similar wastes
Sludges (non-hazardous)   Wastes from wastewater treatment        Grease and oil mixture from
                          plants                                  oil/waste water separation
Sludges (non-hazardous)   Wastes from the manufacturing of        Sludges
                          fats, grease, soaps, detergents,
                          disinfectants and cosmetics
Sludges (non-hazardous)   Wood preservation waste                 Waste organic wood preservatives
Sludges (non-hazardous)   Waste from transport and storage         Oil wastes from marine transport
                          tank cleaning                                tank cleaning
                                                                   Oily wastes from railway and
                                                                       tanker tank transport tank
                                                                       cleaning
                                                                   Oily wastes from storage tank
                                                                       cleaning
Sludges (non-hazardous)   Petroleum refinery waste                Waste water treatment sludges
Sludges (non-hazardous)   Food processing wastes                  Food processing waste sludges
Solids (non-hazardous)    Non-metallic wastes from inorganic       Spent activated carbon (except
                          chemical processes                           from chlorine production)
                                                                   Carbon black
Solids (non-hazardous)    Oil/water separator contents            Oil/water separator solids
Solids (non-hazardous)    Absorbents, filter materials, wiping    Absorbents, filter materials, wiping
                          cloths and protective clothing          cloths and protective clothing
Solids (non-hazardous)    Wastes from wastewater treatment        Grease and oil mixture for oil/water
                          plants                                  separation
Solids (non-hazardous)    Organic packaging wastes                 Paper and cardboard
                                                                   Plastic
                                                                   Wooden
                                                                   Composite packing
                                                                   Mixed
Solids (non-hazardous)    Wastes from synthetic materials and     Waste plastics, rubbers, and other
                          rubbers manufacturing and               synthetic materials, including, but not
                          processing                              limited to:
                                                                   Automobile and parts
                                                                       manufacturing
                                                                   Plastics manufacturing
                                                                   Tire and rubber manufacturing
Solids (non-hazardous)    Wastes from textile industry            Wastes from unprocessed textile
                                                                  fibers
Solids (non-hazardous)    Agricultural wastes                      Sugar beet waste
                                                                   Seed corn waste
                                                                   Animal and food rendering
                                                                       waste
                                                                   Other organic agriculture wastes
Solids (non-hazardous)    Printer toner waste                     Waste printer toner
Solids (non-hazardous)    Wastes from wood processing and          Waste bark and cork
                          the production of furniture products     Sawdust
                                                                   Shavings, cuttings
Solids (non-hazardous)    Wastes from pulp, paper and             Solids from pulp, paper and
                          cardboard production and                cardboard industry
                          processing
Solids (non-hazardous)    Waste from water and waste water        Solids from water and wastewater
                          treatment plants                        treatment plants
                                                                                   1
Solids (non-hazardous)    Salvage and recycling industry          Salvage material


                                    Page 110 of 131
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                                                                                      Expiration Date: April 27, 2009
Solids (non-hazardous)                  Wastes from the manufacturing and        Wood waste
                                                                                 Salvage material
                                                                                                     1
                                        production of construction materials
Solids (non-hazardous)                  Petroleum refinery waste                Waste solids including spent catalyst
                                                                                and caustics
Solids (non-hazardous)                  Iron, steel, and foundry wastes         Waste solids
Solids (non-hazardous)                  Food processing wastes                  Food processing waste solids


1
 ”Salvage material” is defined as items reclaimed before or after mixing/grinding/disposal/storage where multiple
components have been mixed together, and the products are easily separated into lesser components and the
components were not exposed to asbestos, lead mercury or PCB containing materials. Specifically excluded from
this definition are such materials as “auto fluff.” Included in the definition are items such as “oil filter fluff.”




                                                  Page 111 of 131
                                                                              Permit Number: MI-ROP-B1743-2004
                                                                                     Expiration Date: April 27, 2009
The facility shall use the following approved test plans, procedures, specifications, and averaging times to measure
the pollutant emissions for the applicable requirements referenced in Table F-1.8.


R 336.2004 Appendix A; reference test methods; adoption of federal reference test methods.

Rule 1004. (1) The following federal reference test methods, described in the provisions of 40 C.F.R. part 60,
appendix A (2000), are the reference test methods for performance tests required pursuant to the provisions of this
part:

(a) Method 1 – Sample and velocity traverse for stationary sources.
(b) Method 1A – Sample and velocity traverses for stationary sources with small stacks or ducts.
(c) Method 2 – Determination of stack gas velocity and volumetric flow rate (type-S pitot tube).
(d) Method 2A – Direct measurement of gas volume through pipes and small ducts.
(e) Method 2C – Determination of stack gas velocity and volumetric flow rate in small stacks and ducts (standard
    pitot tube).
(f) Method 2D – Measurement of gas volumetric flow rates in small pipes and ducts.
(g) Method 3 – Gas analysis for the determination of dry molecular weight.
(h) Method 4 – Determination of moisture content in stack gases.
(i) Method 6 – Determination of sulfur dioxide emissions from stationary sources.
(j) Method 7 – Determination of nitrogen oxide emissions from stationary sources.
(k) Method 8 – Determination of sulfuric acid mist and sulfur dioxide emissions from stationary sources.
(l) Method 9 – Visual determination of the opacity of emissions from stationary sources.
(m) Method 10 – Determination of carbon monoxide emissions from stationary sources.
(n) Method 10B – Determination of carbon monoxide emissions from stationary sources.
(o) Method 18 – Measurement of gaseous organic compound emissions by gas chromatography.
(p) Method 21 – Determination of volatile organic compound leaks.
(q) Method 23 – Determination of Polychlorinated Dibenzo-p-Dioxins and Polychlorinated Dibenzofurans from
    stationary sources.
(r) Method 24 – Determination of volatile matter content, water content, density, volume solids and weight solids of
    surface coatings.
(s) Method 24A – Determination of volatile matter content and density of printing inks and related coatings.
(t) Method 25 – Determination of total gaseous nonmethane organic emissions as carbon.
(u) Method 25A – Determination of total gaseous organic concentration using a flame ionization analyzer.
(v) Determinations of particulate emission rates for stationary sources shall be conducted as specified in 1 or more
    of the following reference test methods:
    (a) Reference test method 5B which is described in R336.2011.
    (b) Reference test method 5C, which is described in R336.2012.
    (c) Reference test method 5D, which is described in R336.2013
    (d) Reference test method 5E, which is described in R336.2014.




                                                  Page 112 of 131
                                                                              Permit Number: MI-ROP-B1743-2004
                                                                                     Expiration Date: April 27, 2009

This permit allows the use of only the following materials and fuels listed below:

Raw Materials

Limestone
Clay/Shale
Sand
Gypsum
Clinkers
Recycled kiln dust
Leached kiln dust


Alternate Raw Materials

Conditioned flyash
Bottom ash


Fuels

Natural Gas
Pulverized coal
Petroleum coke
Specification used oil
Tire-derived fuel (TDF)
Silica Gel

This condition does not preclude the use of alternative raw materials and fuels allowed by Rule 285 (b) and (c).




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                                                                                 Permit Number: MI-ROP-B1743-2004
                                                                                        Expiration Date: April 27, 2009



Appendix 6. Permits to Install/Operate

The following table lists the Permits to Install and/or Operate which relate to the identified Emission Units or Flexible
Grouping:

       Permit to                                                                         Corresponding Emission
    Install/Operate                       Description of Equipment                                  Unit
       Number                                                                                        or
                                                                                           Flexible Grouping ID
 60-71O                   Cement Kilns                                                  FG008
                          Primary crusher quarried limestone                            EG013
                          Transfer of limestone from secondary crusher building         EG014
                          onto stock belt no. 3
 60-71O                   Raw Materials Reclaim                                         FG010
 60-71O                   Raw Materials Conveyor (Belt No. 2)                           FG010
 60-71O                   Raw Material Transfer (Belt No. 2 to No. 5)                   FG010
 4-80, 519-86             Quarry drilling                                               FG014
 824-90                   CKD Product Silo                                              EG030
 60-71N                   Natural Gas-Fired Solid Fuel Dryers (2)                       EGDRYERS
 4-03                     Cement Loading to Trucks                                      FG003
 721-93                   Cement Bagging                                                FG005
 60-71J                   Slag Storage Silo                                             EG001-9
 224-73                   Clinker Coolers                                               FG007
 352-73                   Flyash Storage Silo                                           FG002




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                                                                                 Permit Number: MI-ROP-B1743-2004
                                                                                        Expiration Date: April 27, 2009



Appendix 7. Emission Calculations


In calculating the tons per year emission in Table F-1.3, II.B., the actual operating hours will be calculated using the
following information:


        - truck cycle time (minutes/truck)
        - average cement truck load (tonnes/truck)
        - calculate the cement truck loading timer per load (minutes/tonne)
        - annual tonnes of cement loaded (tonnes/yr)
        - calculate the actual cement loading time (minutes/yr or hours/yr)
        - calculate the actual emissions based on particulate matter emission limit rate of either 0.32 lb/hr or
          emission rate from source test data and the actual cement loading time (hours/yr)




                                                   Page 115 of 131
                                                                              Permit Number: MI-ROP-B1743-2004
                                                                                     Expiration Date: April 27, 2009


Appendix 8. Reporting

A. Annual and Deviation Certification Reporting

The permittee shall use the DEQ Report Certification form (EQP 5736) and DEQ Deviation Report form (EQP 5737)
for the annual and deviation certification reporting referenced in Section IV of the Requirement Tables. Alternative
formats must meet the provisions of R 336.1213(4)I and R 336.1213(3)I(i), respectively, and be approved by the
AQD District Supervisor.

B. Other Reporting

The permittee shall use the following approved formats and procedures for the reporting requirements referenced in
Table F-1.7. Alternative formats must be approved by the AQD District Supervisor.

The following reporting requirement from Table F-1.7, IV.4. :

   In accordance with 40 CFR 60.7I and (d), Holcim shall submit a written EER and summary report in an
    acceptable format to the AQD Jackson District Supervisor within 30 days of the end of each calendar quarter.
    The EER shall include the magnitude, in actual percent opacity, of each six-minute average of opacity greater
    than the permit limit and the time period represented by such averages. The EER shall include the cause of the
    excess emission, if known, period of COMS downtime, any corrective actions taken, and total operating time of
    the source. If no exceedances of COMS downtime occurred during the time period, Holcim shall report that
    fact.

The following reporting requirement from Table F-1.7, IV.5. :

   Under 40 CFR 63, Subpart A, Section 63.10 (e)(3), EER could be submitted on an semiannual basis for a CMS.
    That presently is not applicable as Consent Judgment 60-1363-CZ, Part 4.3.B. requires a quarterly submittal. If
    at some point this Consent Order is voided and one full year (four (4) quarterly periods) of reports demonstrate
    continual compliance and continues to comply with recordkeeping requirements, the facility may request that the
    reporting frequency be on a semiannual basis

    As soon as CMS data indicates that the source is not in compliance with opacity limitations, emissions limits for
    operating parameters specified in the permit, the frequency of reporting will revert back to a quarterly basis.
    The facility can petition the reporting frequency to be reduced after one full year of ongoing compliance.




                                                  Page 116 of 131
                                                                                          Permit Number: MI-ROP-B1743-2004
                                                                                                 Expiration Date: April 27, 2009
                                                            Attachment 1
                                                     FUGITIVE DUST PLAN


  Section     Equipment                Location                    Control Methods/Control                   Operation
                Item                                                       Equipment
Stockpiles   Limestone       South end of plant under Belt      Discharge onto pile is from a       Low fines content.
                             Conveyor #3.                       tube spout that has auto controls
                             Average 50,000 tons                to raise/lower spout. Dust
                                                                Suppression System
                                                                 Residual Foaming Dust
                                                                  Suppressant
                                                                 Applied after tertiary crusher
                                                                 Normal Operating Range
                                                                 Water = 800 to 1100 gph
                                                                 Chemical = 0.8 to 2 gph
Stockpiles   Bottom Ash      South Quarry Stockpile Area.       Delivery in covered trucks.         High moisture.
                             Average 10,000 tons
Stockpiles   Gypsum          West of Limestone Stockpile.       Deliver in covered trucks.          Gypsum 2X size.
             (Natural and    Average 5,000 tons                                                     Very low fines content.
             Synthetic)
Stockpiles   Clinker         Main storage hall.                 Discharge into hall is through      Storage crane bucket
                             Storage hall capacity 200,000      gravity controlled discharge        operation is restricted to low
                             tons.                              doors. Transport conveyors at       level discharge.
                                                                transfer points are dedusted with
                                                                baghouse collection. Hall is
                                                                partially enclosed.
Stockpiles   Outside         South of Clinker Storage Hall.     Clinker forms hard covering         Very low fines content.
(inactive)   Clinker                                            which stabilize the pile.           Removal of clinker is
                                                                                                    performed in a manner that
                                                                                                    minimizes dust generation.
Stockpiles   Conditioned     South Quarry Stockpile Area.       Delivery in covered trucks and      Minimize inventories.
             Flyash                                             material has been wetted.
Transport    Gypsum          From stockpile to feeder 4.                                            Material is purchased as 2X
                                                                                                    size.
                                                                                                    Low fines content.
Transport    Limestone       Haulage from rockface to                                               Average (D50) size is 10”.
                             primary crusher.                                                       Low fines content.
Transport    Clay            Haulage is from stripping to                                           Material typically contains 9
                             clay crusher.                                                          to 13% moisture.
Transport    Top Stripping   Haulage to stripping dump.                                             High moisture material.




                                                            Page 117 of 131
                                                                                            Permit Number: MI-ROP-B1743-2004
                                                                                                   Expiration Date: April 27, 2009

 Section         Equipment                 Location                  Control Methods/Control                   Operation
                     Item                                                  Equipment
Conveying       Belt 1          Quarry crusher to belt 2.                                              Completely enclosed in an
                                                                                                       underground tunnel.
Conveying       Belt 2          Belt 2 to secondary and           Crushing system dedusted by a        Completely enclosed in a
                                tertiary crushing.                baghouse collector.                  gallery structure.
Conveying       Belt 3          Tertiary crushing to stockpile.   Tube Spout and Dust                  Completely enclosed in a
                                                                  Suppression System.                  gallery structure.
Conveying       Belt 4          Reclaim conveyor from             Transfer point dedusted by a         Completely enclosed in a
                                stockpile.                        baghouse collector.                  gallery structure.
Conveying       Belt 5          Reclaim conveyor from             Initial transfer point dedusted by   Completely enclosed in a
                                secondary building to feed        a baghouse collector.                gallery structure.
                                silos.
Conveying       Belt 6          Short transfer in secondary       Transfer point dedusted by a         Low fines content.
                                crusher building to Road          baghouse collector.
                                Stone Pile.
Conveying       Belt 7          Short transfer in secondary       Transfer point dedusted by a         Low fines content.
                                crusher building to outside       baghouse collector.
                                silo.
Road            Quarry Roads    Main Entrance road to quarry.     Gravel construction sealed with a    Treatment with agent at
                                Clay haul road.                   road stabilization agent.            least 4 times per year.
                                Stone haul road.
Road            Temporary       Road to overburdened dump.        Graded regularly and usage of        Once per day and more
                Road                                              water to control fugitive dust.      during dry weather stripping
                                                                                                       operations.(1)
Road            Landfill Road   Landfill perimeter.               Graded regularly and usage of        Treatment with agent at
                                                                  water to control fugitive dust.      least 4 times per year.
Road            Main Plant      Main Plant                        Concrete construction.               Swept every weekday. (1)
                Roads                                             Dry sweeper with Vacuum Filter
                                                                  for maintaining clean paved
                                                                  surfaces.
Road            Main Plant      Main Plant                        Truck Wash Facility                  Operated Apr.- Oct.
                Roads
Road            Secondary       Clinker Storage Hall to water     Gravel construction sealed with a    Treatment with agent at
                Roads           plant.                            road stabilization agent.            least 4 times per year.
                                Contractor Road to Clinker
                                Cooler Baghouse.
Road            Parking lots    Employee and Visitor Parking      Concrete construction.               Swept every 2 weeks. (1)
                                Lots.                             Dry sweeper with Vacuum Filter
                                                                  for maintaining clean paved
                                                                  surfaces.

       *Wet weather may negate these interval requirements.




                                                              Page 118 of 131
                                                                                        Permit Number: MI-ROP-B1743-2004
                                                                                               Expiration Date: April 27, 2009
                                                       ATTACHMENT 2

                   MALFUNCTION ABATEMENT PLAN/PREVENTIVE MAINTENANCE PROGRAM
                                    FOR THE KILN OPERATIONS


1.0      INTRODUCTION

1.1      PLAN REQUIREMENT

This Malfunction Abatement Plan/Preventive Maintenance Program (“Plan”) is developed pursuant to the Administrative Rules
of the Michigan Department of Natural Resources, Part 9, Rules 910, 911, and 912. The Plan describes the method by which
anticipated malfunction situations at the Holcim Inc.’s Dundee Cement Plant (“Dundee”) located in Dundee, Michigan, will be
managed by the owner, or operator, of the facility. This will constitute the standard operating procedures to be implemented at
the Dundee facility for the kiln(s) processes and related controls, not including the scrubber oxidizer systems.

1.2 PLAN PURPOSE

The purpose of this Plan is to describe the standard operating procedures to be used to abate or minimize potential abnormal
conditions that may occur at the facility resulting in an in-stack opacity that exceeds the opacity limitation of 15 percent using a
6-minute average, from the kiln(s) stack. The Plan consists of two parts: 1) The preventive maintenance program, and 2) The
malfunction abatement and equipment monitoring program. The on-duty shift supervisor is responsible for implementing the
Plan.

The preventive maintenance program includes the following elements:

            Items or equipment that are to be inspected
            Frequency of inspection
            Method of inspection
            Personnel responsible for overseeing the inspection
            Scheduled maintenance and repairs of equipment
            Major replacement parts that are to be kept in inventory

The malfunction abatement and equipment monitoring program includes the following elements:

            Equipment operating variables that are to be monitored to detect any malfunction or failure
            Normal operating range of these variables
            Description of the method of monitoring
            Personnel responsible for monitoring
            Frequency of monitoring
            Description of the corrective procedures or operational changes aimed at abating a malfunction or equipment
             failure situation

2.0 FACILITY BACKGROUND

The Dundee Cement Plant began operation in 1959. The plant produces cement clinker in two rotary kilns using a wet process.
The exhaust from each kiln is treated separately by an air pollution control device before it is released vertically upward into the
atmosphere through a common single stack that is 350 feet tall and 15 feet in diameter.

The air pollution control system at the Dundee facility consists of a dry injection venturi scrubber followed by fabric filter
collectors. Activated carbon is injected into the exhaust gas ahead of the fabric filters at a nominal rate of 295 lbs/hr,
consistent with Table F-1.8, V, OPERATIONAL PARAMETERS, Article 9. This control system will maintain particulate
emissions below the emission limitation of 0.10 lb/1000 lb stack gas corrected at 6% oxygen. The control device will also
allow the company to meet a 6 minute opacity limitation of 15 percent opacity in the stack based on the continuous opacity
monitoring system and consistent with the requirement in Table F-1.8, VI, OTHER REQUIREMENTS, Article 11.

3.0 PREVENTIVE MAINTENANCE PROGRAM



                                                        Page 119 of 131
                                                                                        Permit Number: MI-ROP-B1743-2004
                                                                                               Expiration Date: April 27, 2009
This program is designed to minimize equipment malfunctions by establishing an inspection schedule for all equipment and
accessories associated with the air pollution control system. Table 1 lists the items to be inspected, the frequency of inspection,
the person responsible for overseeing the inspection, and the replacement parts kept in inventory. This program will help
identify ahead of time any malfunction that may arise, and by conducting an effective maintenance program, equipment
malfunctions will be kept to a minimum. The method of inspection and maintenance procedures will be conducted per the
vendor’s recommendations. During inspection, the following information will be recorded in a log sheet (see attached
Inspection Log sheet) or equivalent:

             Items inspected
             Equipment identification number
             Date of inspection
             The condition of the equipment
             General comments pertaining to the necessity for repairs or adjustments
             The initials of the person conducting the inspection

4.0 MALFUNCTION ABATEMENT AND EQUIPMENT MONITORING PROGRAM

This program is intended to identify any abnormal conditions or equipment malfunctions. Table 2 lists the equipment that are
anticipated to break down or cause an exceedance of the opacity limitation, the operating variables to be monitored, the normal
operating range, the method of monitoring, the frequency of monitoring, the person monitoring the equipment, and the
corrective procedures or operational changes that achieve compliance during a malfunction or failure of the equipment. This
program helps detecting any malfunctions and initiates the required corrective actions to achieve compliance in a timely
manner. During a malfunction event, the following information will be recorded in a log sheet (see attached Repair Log sheet)
or equivalent:

             Equipment identification number
             The date the malfunction was detected
             A description of the malfunction
             The time the malfunction was detected
             The time the repair was completed
             A description of the required repair
             The initials of the person conducting the repair

Except during startup as defined in V Operational Parameters Article 7, Holcim shall undertake an investigation into the cause
of any occurrence of opacity of three consecutive 6 minute averages in excess of 10% opacity based on the continuous opacity
monitoring system. The results of this investigation shall be recorded in the operating log.

         a) If the cause of excessive opacity is general bag failure requiring rebagging, Holcim shall either take the
            compartment off-line or rebag the faulty compartment in the dust collector within 180 days of the completion of
            the investigation.
         b) If the cause of the excessive opacity is only isolated bag failure, Holcim shall take the compartment off-line until
            repairs are performed.




                                                        Page 120 of 131
                                                                                                             Permit Number: MI-ROP-B1743-2004
                                                                                                                    Expiration Date: April 27, 2009
                                                           ATTACHMENT 2

                                          KILN PREVENTIVE MAINTENANCE PROGRAM
                                                         TABLE 1


                   ITEMS INSPECTED                          FREQUENCY           RESPONSIBILITY        REPLACEMENT PARTS
                                                                                                       KEPT IN INVENTORY
Baghouse Systems       Housing and Duct Conditions         Semi-Annual       Maintenance Engineer
(DV003-2 and                                                                                        bags, kiln exhaust fan
DV003-7)
                       Bag Condition and Tension           Semi-Annual       Maintenance Engineer   motor, programmable
                       Collection Screws                   Semi-Annual       Maintenance Engineer   controller, Computer , air
                       Double Tipping Valves               Semi Annual       Maintenance Engineer   compressor and motor,
                       Hopper Screws                       Semi-Annual       Maintenance Engineer   damper solenoids, dust pod
                       Bypass Dampers                      Semi-Annual       Maintenance Engineer   valves, differential pressure
                       Seal Air Fan                        Semi-Annual       Maintenance Engineer   cells, thermocouples,
                       Dust Pods                           Semi-Annual       Maintenance Engineer   hopper and collect screws,
                       Baghouse Cleaning System            Semi-Annual       Maintenance Engineer   gear reducer and motor, bag
                                    Reverse Air Dampers    Semi-Annual       Maintenance Engineer   bands, tension springs, bag
                                        Reverse Air Fans   Semi-Annual       Maintenance Engineer   caps, filters, drive belts,
                         Shakers (Variable Speed Drives)   Semi-Annual       Electrical Engineer    reverse air fan motor.
                       Sonic Horns                         Semi-Annual       Electrical Engineer
                       Air Compressors LP                  Semi-Annual       Maintenance Engineer
                       Kiln Exhaust Fan                    Semi-Annual       Maintenance Engineer
                       Electric Motors                     Semi-Annual       Electrical Engineer
                       Programmable Controller             Semi-Annual       Electrical Engineer
                       Alarms                              Semi-Annual       Electrical Engineer




                                                           Page 121 of 131
                                                                                                                                                Permit Number: MI-ROP-B1743-2004
                                                                                                                                                       Expiration Date: April 27, 2009
                                                                  KILN PREVENTIVE MAINTENANCE PROGRAM
                                                                             TABLE 1 (continued)



                            ITEMS INSPECTED                                            FREQUENCY                          RESPONSIBILITY                  REPLACEMENT PARTS
                                                                                                                                                           KEPT IN INVENTORY
     Baghouse System (DV003-2 and       Instrumentation                      Semi-Annual                           Electrical Engineer                  see previous page
     DV003-7)
                                        Computer                             Semi-Annual                           Electrical Engineer
                                        Control Logic                        Semi-Annual                           Electrical Engineer
                                        Air Valve Operators                  Semi Annual                           Maintenance Engineer
                                        Air Dryer H.P.                       Monthly                               Electrical Engineer
                                        Filter Regulator Lubricators         Monthly                               Maintenance Engineer
                                        Feed System Calibration              Once/shift (minimum)                  Kiln Burner Operator                 weigh system load cell, weigh
     Dry Venturi Scrubber Systems                                                                                                                       system control package,
     (DV003-5 and DV003-10)                                                                                                                             injection air blower motor, silo
                                                                                                                                                        alleviator bags.
                                        Scrubber System                      Once/shift (minimum)                  Kiln Burner Operator

Notes:

1.        Inspection procedures will be based on vendor’s recommendations
2.        Maintenance is performed as necessary when the inspection reveals problems
3.        Equipment inspection and maintenance date, equipment name, equipment identification number, repairs resulting from inspection will be recorded in a log sheet (see attached
          log sheets).




                                                                                    Page 122 of 131
                                                                                                                           Permit Number: MI-ROP-B1743-2004
                                                                                                                                  Expiration Date: April 27, 2009
                                                                                SHIFT
                                                                       INSPECTION LOGSHEET
            Items Inspected            Equipment ID             Inspection Date       Condition              Comment                      Initials
                                                                                                            (see note 1)
        Dry Venturi               Feed System
        Scrubber Systems          Scrubber System
        (DV003-5 and
         DV003-10)


Note:
1. If repairs are required, fill out the repair log sheet and reference it in the comment column (above).




                                                                            Page 123 of 131
                                                                                                                           Permit Number: MI-ROP-B1743-2004
                                                                                                                                  Expiration Date: April 27, 2009

                                                                                    MONTHLY
                                                                             INSPECTION LOGSHEET
             Items Inspected               Equipment ID               Inspection Date       Condition        Comment                      Initials
                                                                                                            (see note 1)
         Baghouse System (BH1        Air Dryer H.P.
         and BH2)
                                     Filter Regulator
                                     Lubricators


Note:
1. If repairs are required, fill out the repair log sheet and reference it in the comment column (above).




                                                                                   Page 124 of 131
                                                                                                                  Permit Number: MI-ROP-B1743-2004
                                                                                                                         Expiration Date: April 27, 2009

                                                                         SEMI-ANNUAL
                                                      INSPECTION LOGSHEET FOR MISCELLANEOUS EQUIPMENT
            Equipment Name            Items Inspected     Equipment I.D.  Inspection Date Condition          Comment               Initials
                                                                                                            (see note 1)




Note:
1. If repairs are required, fill out the repair log sheet and reference it in the comment column (above).




                                                                                   Page 125 of 131
                                                                                                                         Permit Number: MI-ROP-B1743-2004
                                                                                                                                Expiration Date: April 27, 2009

                                                                                  SEMI-ANNUAL
                                                                           INSPECTION LOGSHEET
                          Items Inspected                          Equipment I.D.      Inspection Date      Condition    Comment            Initials
                                                                                                                        (see note 1)
        Baghouse System         House and Duct Conditions
        (BH1 and BH2)           Bag Condition and Tension
                                Collection Screws
                                Double Tipping Valves
                                Hopper Screws
                                Bypass Dampers
                                Seal Air Fan
                                Dust Pods
                                Baghouse Cleaning System
                                       Reverse Air Dampers
                                          Reverse Air Fans
                                   Shakers (Variable Speed
                                                    Drives)
                                               Sonic Horns
                                Air Compressors LP
                                Kiln Exhaust Fan
                                Electric Motors
                                Programmable Controller
                                Alarms
                                Instrumentation
                                Computer
                                Control Logic
                                Air Valve Operators

Note:
1. If repairs are required, fill out the repair log sheet and reference it in the comment column (above).




                                                                                   Page 126 of 131
                                                                                                                Permit Number: MI-ROP-B1743-2004
                                                                                                                       Expiration Date: April 27, 2009

                                                                          REPAIR LOGSHEET
           Equipment ID           Date            Malfunction           Time Malfunction  Time Repair   Repair Description           Initials
                                                  Description              Detected        Completed      (See Note 1)




Note:
1. If repair time exceeds two hours, see note 3 of the Abatement and Equipment Monitoring Program




                                                                             Page 127 of 131
                                                                                                                                Permit Number: MI-ROP-B1743-2004
                                                                                                                                       Expiration Date: April 27, 2009

                                                                             ATTACHMENT 2

                                            MALFUNCTION ABATEMENT AND EQUIPMENT MONITORING PROGRAM
                                                                    TABLE 2
      Equipment           Operating Variables      Normal Operating        Method of Monitoring        Frequency of     Person Monitoring        Corrective Procedure or
                              Monitored                Range                                            Monitoring                              Operational Change in the
                                                                                                                                                Event of a Malfunction or
                                                                                                                                                    Failure to Achieve
                                                                                                                                                       Compliance
Baghouse systems        Inlet Gas temperature    280F to 475F           Display Screen          Frequently          Kiln Burner Operator   If the malfunction is in one or
(DV003-2 and                                                                                                                                 more compartments, those
 DV003-7)                                                                                                                                    compartments will be taken
                                                                                                                                             out of service until repairs are
                                                                                                                                             performed.
                                                                                                                                             If the malfunction which
                                                                                                                                             results in emissions that
                                                                                                                                             exceed the emission
                                                                                                                                             limitations for more than two
                                                                                                                                             hours, see Note 3.

                        Outlet Gas               275F to 320F           Display Screen          Frequently          Kiln Burner Operator
                        Temperatures
                        Inlet Pressure           -6” W.G. to -8.5” W.G.   Differential Pressure   Continuous          Kiln Burner Operator
                                                                          Trend Display
                        Outlet Pressure          -14” W.G. to -16.5”
                                                 W.G.
                        % Oxygen                 0.5 to 2.0%              Strip Chart Recorder    Continuous          Kiln Burner Operator
                        In Stack Opacity         5 to 10%                 Strip Chart Recorder    Continuous          Kiln Burner Operator   .
Dry Venturi Scrubbers   Inlet Gas Temperature    370 – 425F              Display Screen          Frequently          Kiln Burner Operator   The injection feed system for
(DV003-5 and                                                                                                                                 each source has redundant
DV003-10)                                                                                                                                    sources of injection material
                                                                                                                                             (2 silos) and load cells for
                                                                                                                                             measuring each batch
                                                                                                                                             injection.
                                                                                                                                             In the event of a problem with
                                                                                                                                             the feed system, the operator
                                                                                                                                             selects the alternate
                                                                                                                                             equipment, and repairs will be
                                                                                                                                             made as soon as feasible.
                                                                                                                                             Redundancy is also built into
                                                                                                                                             the computer control of the
                                                                                                                                             system.
                                                                                                                                             The number of batches per
                                                                                                                                             hour and batch weight setpoint
                                                                                                                                             are determined by material
                                                                                                                                             density and desired pounds-
                                                                                                                                             per-hour (PPH).
                        Outlet Gas Temperature   280 – 325               Display Screen          Frequently          Kiln Burner Operator
                        Tempering Air Damper     40 – 100%                Display Screen          Frequently          Kiln Burner Operator
                        Position
                        Batch Weight             10 – 20 pounds           Display Screen          Frequently          Kiln Burner Operator

                                                                              Page 128 of 131
                                                                                                                      Permit Number: MI-ROP-B1743-2004
                                                                                                                             Expiration Date: April 27, 2009

                        Batch Time               Based on Batch Weight   Display Screen        Frequently   Kiln Burner Operator
Dry Venturi Scrubbers   Actual PPH Injection     300 pounds              Display Screen        Frequently   Kiln Burner Operator   see previous page
(DV003-5 and DV003)
                        Total Pounds Injection   Totalizer               Display Screen        Frequently   Kiln Burner Operator




                                                                             Page 129 of 131
                                                                                                                                                             Permit Number: MI-ROP-B1743-2004
                                                                                                                                                                    Expiration Date: April 27, 2009

                                                                                            ATTACHMENT 2

                                                    MALFUNCTION ABATEMENT AND EQUIPMENT MONITORING PROGRAM
                                                                            TABLE 2


Equipment              Operating           Normal Operating             Method of                Frequency of             Person Monitoring                 Corrective Procedure or Operational Change in
                       Variables               Range                    Monitoring                Monitoring                                               the Event of a Malfunction or Failure to Achieve
                       Monitored                                                                                                                                             Compliance
                           ALARMS
                        Batch Weight                               Display Screen            Continuous              Kiln Burner Operator            see previous page
                             UNDER                                 & Panalarm
                             Setpoint
                        Batch Weight                               Display Screen            Continuous              Kiln Burner Operator
                      OVER Setpoint                                & Panalarm
                             Selected                              Display Screen            Continuous              Kiln Burner Operator
                      Equipment OFF                                & Panalarm


Notes:
1.         A repair log sheet will be maintained. The log sheet will include: Equipment ID, Date, Time Malfunction Detected, Time Repair Completed, Repair Procedures (see attached Repair Log
sheet) or equivalent.

2.         The person monitoring the equipment will notify his or her supervisor promptly of any abnormal operating variables that cannot be corrected through normal adjustments and procedures.

Pursuant to the Michigan Air Pollution Control Commission Rules, Part 9, Rule 912, emissions that exceed the applicable emission limitations due to abnormal conditions in, or breakdown of, process
or control equipment which continue for more than two hours will be reported as soon as possible but not later than 9:00 a.m. of the next working day to the District Supervisor. Within ten days of this
occurrence, a detailed report will be submitted to the District Supervisor. The report will include the probably causes, duration of violation, remedial action taken, and the steps that are being undertaken to
prevent a reoccurrence. The preventive steps will become a part of the Malfunction Abatement Plan.




                                                                                             Page 130 of 131
                                                                   Permit Number: MI-ROP-B1743-2004
                                                                          Expiration Date: April 27, 2009
                                          ATTACHMENT 3


                                 Holcim (US), Inc., Dundee Plant
                                     Cement Kiln Baghouse
                         Supplemental Preventive Maintenance Program
                            For the Abatement of Dust Accumulation
                                          April 6, 1999


A.   Slide Gates

     By April 23, 1999 (when Kiln 2 is scheduled to come out of it major outage), slide gates will be
     installed on all four dust transport pod systems. This will enable the individual pods to be isolated
     for maintenance purposes.

B.   Baghouse Inspections/Housekeeping

     The baghouse will be inspected for dust accumulation once per shift. Any visible leaks will be
     corrected promptly. Clean up of accumulated dust will begin not later than the start of the next
     scheduled labor shift. In addition, the sweeper operator will inspect the baghouse and baghouse
     floor at least twice per week of operation and sweep the baghouse floor as necessary.

C.   Baghouse/Cleaning Cycle

     Continue to conduct regular cleaning of the baghouse compartments to maximize the
     performance of the baghouse. Any excessive dust will be cleaned as soon as practicable, not
     later than the start of the next labor shift.

D.   Screw System Alarm

     A hard wire alarm has been installed to notify kiln operators if the screw system has been disabled
     for a long duration.

E.   Gathering Screw Conveyors

     The following activities will be performed every 6 months for each gathering screw conveyor:

         1)      Open and inspect screw hangers, bearings, and shafts. Bar end bearings, inspect
                 drive sheaves and belts.
         2)      Check screw housing thickness and insulation.
         3)      Replace screw seals.
         4)      When above work done, put screws into service.

     Scheduling and recordkeeping of maintenance performed will be tracked using Holcim’s
     electronic maintenance system.




                                           Page 131 of 131

				
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