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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 Facility Name:Lafarge Building Materials, Inc. – Atlanta Plant City: Atlanta County: Fulton AIRS #: 04-13-121-00401 Application #: TV-9548 Date Application Received: November 22, 1996 Date Application Deemed Administratively Complete: December 22, 1996 Date of Draft Permit: Permit No: 3241-121-0401-V-04-0 Program Review Engineers Review Managers SSPP Noel DoHarris James CurrentSSCP Bradley Belflower Larry Webber ISMP Pierre Sanon James Eason Toxics Don Holder Karen Hays Introduction This narrative is being provided to assist the reader in understanding the content of the attached draft Part 70 operating permit. Complex issues and unusual items are explained herein simpler terms and/or greater detail than is sometimes possible in the actual permit. This permit is being issued pursuant to: (1) Georgia Air Quality Act, O.C.G.A § 12-9-1, et seq. and (2) Georgia Rules for Air Quality Control, Chapter 391-3-1, and (3) Title V of the Clean Air Act Amendments of 1990. Section 391-3-1-.03(10) of the Georgia Rules for Air Quality Control incorporates requirements of Part 70 of Chapter I of Title 40 of the Code of Federal Regulations promulgated pursuant to the Federal Clean Air Act. The primary purpose of this permit is to consolidate and identify existing state and federal air requirements applicable to Lafarge Building Materials, Inc. – Atlanta Plant and to provide practical methods for determining compliance with these requirements. The following narrative is designed to accompany the draft permit and is presented in the same general order as the permit. It initially describes the facility receiving the permit, the applicable requirements and their significance, and the methods for determining compliance with those applicable requirements. This narrative is intended as an adjunct for the reviewer and to provide information only. It has no legal standing. Any revisions made to the permit in response to comments received during the public participation and EPA review process will be described in an addendum to this narrative. Printed: December 19, 2003 Page 1 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 I. Facility Description A. Facility Identification 1. Facility Name: Lafarge Building Materials, Inc. – Atlanta Plant 2. Parent/Holding Company: Lafarge North America, Inc. 3. Previous and/or Other Names: 1983 to September 2001: Blue Circle Cement Prior to 1983: Martin Marietta 4. Facility Location 2520 Paul Avenue, NW Atlanta, GA 30318 Fulton County 5. Attainment or Non-attainment Area Location The facility is located within the ozone non-attainment area. 6. Class I Area Impacts The facility is not located within 100 kilometers of any Class I areas. B. Site Determination Lafarge Building Materials, Inc. – Atlanta Plant is the only facility at this part 70 site. No site determination issues exist. C. Existing Permits Table 1: List of Current Permits as Amended Comments Permit Number and/or Purpose of IssuanceDate of Issuance and Date of Amendments (if any)Yes No 3241-121-0401-E-03-0 August 6, 2002 Printed: December 19, 2003 Page 2 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 D. Process Description 1. SIC Code: 3241 (Portland cement manufacturer) The SIC Code(s) identified above were assigned by EPD's Air Protection Branch for purposes pursuant to the Georgia Air Quality Act and related administrative purposes only and are not intended to be used for any other purpose. Assignment of SIC Codes by EPD's Air Protection Branch for these purposes does not prohibit the facility from using these or different SIC Codes for other regulatory and non-regulatory purposes. 2. Description of Product(s) Portland cement manufacturing at the Atlanta Plant involves the following key process steps: raw material handling, raw material grinding, a cement kiln, finish cement grinding and finished product distribution. The Atlanta Plant manufactures Portland cement by the dry process. 3. Overall Facility Process Description Lafarge Building Materials – Atlanta Plant manufactures portland cement using the dry process. Raw materials are received from off site, stored, and then fed to the kiln in which the materials combine chemically to make cement clinker. The cement clinker is then milled to a fine product that is subsequently shipped off site via rail or truck. 4. Overall Process Flow Diagram: Attached to application in hard copy format only. E. Regulatory Status 1. PSD/NSR The facility is major under PSD regulations as its emissions of particulate matter (and PM-10), sulfur dioxide, and nitrogen oxides all exceed the applicable thresholds. The potential emissions of each of these pollutants have been reported to be greater than 250 tons per year in the Title V application. To avoid PSD review in the past, the facility has had the following restrictions/limits placed ineffect in past permit amendments: a. Limit on hours of operation of its blending and bagging facility (Emission Unit ID EU616) to avoid PSD review for emissions of particulate matter. Printed: December 19, 2003 Page 3 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 b. Limits on the following pieces of equipment to avoid PSD review for emissions of particulate matter (see condition No. 3.2.6 in the Title V permit): Emission Unit Source Code Storage Bin/SiloEU622 Storage Bin/SiloEU623 Mixing/Packing SystemEU616 Reclaim SystemEU617 Raw Material Unloading & Belt Conveyor No. 1EU100, EU103Secondary Crusher EU104 Belt Conveyor No. 4 & Transfer Station EU107, EU108Transfer Station ConveyorEU110 Condition 3.2.6 in the Title V permit indicates the limits on PM emissions for the above equipment. The facility has gone through review and permitting for the NOx RACT. 2. Title V Major Source Status by Pollutant Table 3: Title V Major Source Status If emitted, what is the facility’s Title V status for the pollutant? Pollutant Is the Pollutant Emitted? Major Source Status Major Source Requesting SM Status Non-Major Source StatusPMYesPM 10 Yes SO 2 Yes VOCYesNO x Yes COYesTRSYesH 2 SYesIndividual HAP Yes Total HAPs Yes 3. MACT Standards Lafarge's Atlanta Plant is subject only to specific portions of 40 CFR 63 Subpart LLL "National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry" as the facility is considered an area source under 40 CFR 63 due to its emissions of HAPs falling below the applicability thresholds (10 tons per year of a single HAP and/or 25 tons per year of a combination of HAP's) which define a major source under 40 CFR 63. Printed: December 19, 2003 Page 4 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 The facility is subject only to those requirements under 40 CFR 63 Subpart LLL that limit emissions of dioxins and furans (D/F). The applicable requirements for testing, monitoring, record keeping and notification that are related to limiting emissions of D/F from cement kilns apply. Those D/F requirements pertaining to "inline kiln/raw mills" do not apply to the facility. 4. Program Applicability Program Code Applicable (y/n) Program Code 6 - PSD Y Program Code 8 – Part 61 NESHAP N Program Code 9 - NSPS Y Program Code M – Part 63 NESHAP Y Program Code V – Title V Y Regulatory Analysis II. Facility Wide Requirements A. Emission and Operating Caps: The facility has no facility wide emission or operating caps. B. Applicable Rules and Regulations There are no specific rules applicable to the entire facility. C. Compliance Status No compliance issues existed at the time of review. D. Operational Flexibility Lafarge did not make any operational flexibility requests. E. Permit Conditions No specific permit conditions exist in the Title V permit that apply to the entire facility. Printed: December 19, 2003 Page 5 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 III. Regulated Equipment Requirements A. Brief Process Description Raw Material Handling The primary raw material in cement manufacturing is a calcium source, typically limestone. Most Portland cement plants include a nearby or on-site quarry operation for their source of limestone. However, the Atlanta Plant does not include a quarry operation and receives its stone via bulk shipments from various locations. Secondary raw material components used in the preparation of raw kiln feed include materials that are sources of silica (e.g., sand), alumina (e.g., clay, flyash, kaolin), and iron (e.g., buff iron, millscale). Gypsum is another raw material that is not typically added to raw feed, but is normally added into the finish cement grinding process. These secondary raw materials are used to fine-tune the quality of the clinker produced by the kiln. Lafarge searches for alternate sources of these raw materials to provide cost-effective sources of these essential elemental components. These alternate raw material sources include, but are not limited to, calcium hydroxide from acetylene manufacture,waste kaolin (clay), wood ash, spent alumina catalyst, spent lime mud, etc. Limestone is typically shipped to the Atlanta Plant via rail. It is then crushed and conveyed to raw material silos prior to raw milling at the plant. Secondary raw materials usually arrive at the Atlanta Plant by truck and are stored in stockpiles and/or raw material silos until needed in the raw milling process. Air emissions associated with this part of the plant’s operation include dusts generated during crushing, raw material handling, and transfers to/from storage silos. Point source emissions are typically controlled by fabric filters (i.e., baghouses). Raw Material Grinding From these storage locations, raw materials are conveyed to the facility’s raw mills for further processing. The Atlanta Plant’s raw mills are ball type mills that finely grind raw materials into raw kiln feed. The two raw mill systems at the Atlanta Plant generate particulate emissions that arecontrolled by baghouses. Kiln feed is pneumatically conveyed from the raw mills to the kiln feed homogenizing silos prior to being fed to the kiln. Raw materials are fed to the raw mills as received with moisture and the dry process requires a “dry” kiln feed, therefore, the raw mills are heated to drive off the moisture. Heat in the raw mills is produced by the combustion of natural gas, fuel oil, and/or landfill gas. Raw Mill System 1 operates as a swing mill, which means it can also be used as a finish cement mill. During use as a finish mill, no combustion is required. Cement Kiln Dry kiln feed from the raw mills is temporarily stored in silos prior to being fed to the cement kiln. The kiln is fired to temperatures in excess of 3000°F in order to process the kiln feed into clinker. In order to achieve kiln operating temperatures, the cement kiln is primarily fueled by coal and petroleum coke. In addition, the Atlanta Plant uses fuel oil, natural gas, carbon black (toner), used oil, and landfill gas for kiln fuel. Lafarge continues to investigate the use of “alternate fuels” such Printed: December 19, 2003 Page 6 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 as, but not limited to, carpet waste, sawdust, belt trim, used oil, auto fluff, and other carbon fuel sources that have an energy benefit. Lafarge is permitted to burn tires as a supplemental fuel in the cement kiln at the Atlanta Plant. This was permitted after extensive trials. Lafarge does not and has not engaged in the burning of hazardous waste at the Atlanta Plant. The kiln system at the Atlanta Plant is capable of producing clinker at the rate of 44 tons per hour. Clinker produced from the kiln system is cooled in a heat exchanger process unit called a clinker cooler. The clinker cooler transfers heat from the clinker to ambient air that is passed across the clinker to reduce clinker temperature. In order to handle and produce finished cement products, clinker is conveyed from the clinker coolers to a series of storage silos prior to grinding in the plant’s finish mills. Fabric filters (bag houses) control particulate matter emissions from the kiln system and clinker cooler. The Atlanta Plant also employs process control technology (as Reasonably Achievable Control Technology; RACT) to control NOx emissions from the kiln system. Finish Cement Milling The Atlanta Plant uses three ball mills to grind clinker: two finish mills and a raw mill (Raw Mill System 1). In the finish mill, gypsum and other secondary raw materials may be added to the clinker to produce the appropriate finished cement properties. Particulate emissions from these mills are controlled by bag houses. Finished product is transferred pneumatically to cement storage silos prior to final preparation and distribution to customers. Product Distribution At the Atlanta Plant, product is commonly distributed by three key means: bulk trucks, bulk rail cars, and packaged (bagged products). A majority of finished product is shipped out in bulk by truck and rail. Cement is pneumatically transferred from the cement storage silos to bulk load out stations. These load out stations are typically controlled by bag houses to minimize product loss to the atmosphere. The packhouse operation at the Atlanta Plant, constructed in 1989, serves two key roles. First, the pack house includes a bagging operation in which cement is bagged and palletized for off-site transportation. Second, the pack house also includes a cement pigment mixing system to produce custom colored cement products. These custom colored cement products are typically bagged, but can also be shipped in bulk from the pack house operation. Emissions from the pack house area equipment are controlled by bag houses. Printed: December 19, 2003 Page 7 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 B. Equipment List for the Process Emission Units Specific Limitations/Requirements Air Pollution Control Devices ID No. Description Applicable Requirements /Standards Corresponding Permit Conditions ID No. Description Kiln Systems EU303 Kiln No. 1 System 40 CFR 63 Subpart LLL, 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 391-3-1-.02(2)(g) 391-3-1-.02(2)(yy)3.2.2, 3.2.3, 3.2.4, 3.2.5, 3.2.7, 3.2.8, 3.2.11, 3.3.2, 3.3.3, 3.3.4, 3.4.1, 3.4.2, 3.4.3, 4.2.2, 4.2.3, 4.2.4, 5.2.1, 5.2.2, 5.2.3, 5.2.5, 5.2.8, 5.2.9, 5.2.10, 5.3.1, 5.3.2, 5.3.3, 6.2.1, 6.2.8, 6.2.13, 6.2.14 D13BaghouseClinker CoolersEU304 Clinker Cooler System No. 1 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 5.2.3, 3.4.3 D10 Baghouse Raw Mills & Associated Systems EU202 Surge Bin (Raw Mill No.1) 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D02 Baghouse EU208 Raw Mill No. 2 System 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 391-3-1-.02(2)(g) 3.2.9, 3.4.1, 3.4.2, 3.4.3, 5.2.3, 5.2.5 D05BaghouseEU209 Raw Mill No. 2 Separator/Conveyor System 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D06 Baghouse Finish Mills EU203 Finish Mill No. 3 System391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 391-3-1-.02(2)(g) 3.2.9, 3.4.1, 3.4.2, 3.4.3, 5.2.3, 5.2.5 D03BaghouseEU204 Finish Mill No. 3 Separator/Conveyor System 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D02 Baghouse EU505 Finish Mill No. 1 System391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D29 Baghouse EU506 Finish Mill No. 1 Separator System391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D28 Baghouse EU513 Finish Mill No. 2 System391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D20 Baghouse EU514 Finish Mill No. 2 Separator / Conveyor System 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D27 Baghouse Conveyors EU103 Belt Conveyor No. 1 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.2.6, 3.4.1, 3.4.3, 5.2.3 D81BaghouseEU107 Belt Conveyor No. 4 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.2.6, 3.4.1, 3.4.3, 5.2.3 D83BaghouseEU110Transfer Station Conveyor391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.2.6, 3.4.1, 3.4.3, 5.2.3 D84BaghouseEU201Collection Belt Conveyor391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D01 Baghouse EU301 Kiln Feed Bin/Feed Conveyors 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D09 Baghouse EU504 Finish Mill No. 1 Conveyor 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D30, D31 D32, D12 Baghouses Printed: December 19, 2003 Page 8 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 Emission UnitsSpecific Limitations/Requirements Air Pollution Control DevicesID No. Description Applicable Requirements /Standards CorrespondingPermit ConditionsID No. Description EU511 Finish Mill No. 2 Conveyor 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D21, D22 D23, D24 D25, D26 Baghouses EU309 Clinker Drag Conveyor System No. 1 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D12 Baghouse EU313 Clinker Silo Conveyor 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.6 None None EU314 Dust Loadout/Conveyor System 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D07, D08 Baghouses EU500 Clinker Conveyor to Finish Mill No. 1 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D33 Baghouses EU508 Cement Silo Conveyor No. 1 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D29 Baghouse EU516 Cement Silo Conveyor No. 2 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D27 Baghouse Silos & Associated SourcesEU300 Homogenizing Silos 1 & 2 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D07, D08 Baghouses EU317 Dust Silo No. 8 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D34 Baghouse EU501 Clinker Silo 5 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.6 None None EU502 Interstice No. 16391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D67 Baghouse EU503 Clinker Silo No. 9 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D33 Baghouses EU509 Clinker Conveyor w/ Silos 18 & 19 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D19 Baghouse EU510 Clinker Silos 18, 22, 23 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 5.2.6 None None EU518 Clinker Silo No. 7 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D12 Baghouses EU519 Clinker Silos No. 10, 11, 12 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D12 Baghouse EU520 North Flyash Silo 40 CFR 60 Subpart F, 391-3-1-.02(2)(e) 3.3.1, 3.4.1, 3.4.3 D68 Baghouse EU600 Rail Car Loadout (off Cement Silos) 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.6 None None EU601 Finish Silos 1,7,8 and Interstices13, 14391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D35 Baghouse EU602 Finish Silo Interstices 15, 16, 17, 18, 19 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D36 Baghouse EU603 Finish Silos 20 and 21 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D37 Baghouse EU604 Finish Silo 38 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D38 Baghouse EU605 Finish Silos 29, 30, 31 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D39 Baghouse EU606 Finish Silo Interstices 35, 36, 37391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D40 Baghouse EU607 Finish Silo 9 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D41 Baghouse EU608 Finish Silos 2, 3, 4, 5 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D43 Baghouse Printed: December 19, 2003 Page 9 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 Emission Units Specific Limitations/Requirements Air Pollution Control DevicesID No. Description Applicable Requirements /Standards Corresponding Permit Conditions ID No. Description EU609 Finish Silos 9,10,11, 12 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D44 Baghouse EU610 Finish Silo 6 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D45 Baghouse EU611 Finish Silo 22 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D47 Baghouse EU612 Finish Silos 23, 24, 25 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D48 Baghouse EU613 Finish Silo 26, 27, 28 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D49 Baghouse EU627 Finish Silo Interstices 32, 33, 34391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D18 Baghouse Loading & Unloading Operations EU100 Raw Material Unloading/ClinkerUnloading 40 CFR 60 Subpart F, 391-3-1-.02(2)(e) 3.2.6, 3.3.1, 3.4.1, 5.2.3 D81BaghouseEU302Truck Loadout391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.6 None None EU312 Truck Loadout (off Clinker Excess Tank) 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.6 None None EU614 Individual Truck Loadout (offCement Silos) 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.6 None None EU615 Truck and Rail Car Unloading(to Cement/Pigment Mixing System)40 CFR 60 Subpart F, 391-3-1-.02(2)(e) 3.3.1, 3.4.1, 3.4.3, 5.2.6 NoneNoneEU621 South Truck Loading Area/Scale (off Cement Silos) 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D63 Baghouse EU622 South Truck Loading Bin 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.2.6, 3.4.1, 3.4.3, 5.2.3 D64, D77 Baghouse EU623 North Truck Loading Bin 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.2.6, 3.4.1, 3.4.3, 5.2.3 D65, D78 Baghouse EU624 North Truck Loading Area/Scale (off Cement Silos) 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D66 Baghouse Cement Coolers EU507 Cement Cooler No. 1 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.6 None None Other Equipment EU104Secondary Crusher391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.2.6, 3.4.1, 3.4.3, 5.2.3 D82BaghouseEU108Transfer Station391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.2.6, 3.4.1, 3.4.3, 5.2.3 D83BaghouseEU310 Clinker Bucket Elevators (4) 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D12 Baghouses EU311Clinker Excess Tank391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D12 Baghouse EU315Back Dust Tank391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D14 Baghouse EU512 Feed Box (Finish Mill No. 2) 391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3, 5.2.3 D27 Baghouse 3.2.1, 3.3.1, 3.4.1, 5.3.4, 5.2.3, 6.2.2, 6.2.3, 6.2.5, 6.2.6 D53, D54 D55, D56 D57, D58 D59, D70 EU616 Cement/Pigment Mixing System40 CFR 60 Subpart F, 391-3-1-.02(2)(e) 3.2.6, 3.4.1, 5.2.3 D79 Baghouses Printed: December 19, 2003 Page 10 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 Emission UnitsSpecific Limitations/Requirements Air Pollution Control DevicesID No. Description Applicable Requirements /Standards CorrespondingPermit ConditionsID No. Description EU617Packhouse40 CFR 60 Subpart F, 391-3-1-.02(2)(e) 3.3.1, 3.4.1, 5.2.3 D60 Baghouse EU618Color Loading (Packhouse)40 CFR 60 Subpart F, 391-3-1-.02(2)(e) 3.3.1, 3.4.1, 5.2.3 D61, D62 Baghouses EU619 Packing Pumps/Conveyors No. 1391-3-1-.02(2)(b) 391-3-1-.02(2)(e) 3.4.1, 3.4.3 D51 Baghouse EU620 Packing Pumps/Conveyors No. 2391-3-1-.02(2)(e)3.4.1, 3.4.3D52BaghouseEU628 Packhouse – Single Spout Packing System40 CFR 60 Subpart F, 391-3-1-.02(2)(e) 3.3.1, 3.4.1, 5.2.3 D69 Dust Sock EU629 Cement Reclaim System 40 CFR 60 Subpart F, 391-3-1-.02(2)(e) 3.2.6, 3.3.1, 3.4.1, 5.2.3 D80BaghouseEU630 Antique white pipeline 40 CFR 60 Subpart F, 391-3-1-.02(2)(e) 3.3.1, 3.4.1, 5.2.3 D42 Baghouse * Generally applicable requirements contained in this permit may also apply to emission units listed above. C. Equipment & Rule Applicability Emission and Operating Caps Hours of Operation Limit for Blending and Bagging Operation Equipment in the blending and bagging operation (grouped in Emission Unit ID EU616) are limited to operate a maximum of 7,638 hours during any twelve-month period. This limit was put in effect in a permit amendment issued in September 1988 that allowed for the installation and modifications necessary to construct the blending and bagging operation. The limit on hours of operation was put in effect to avoid a PSD. The equipment involved in the blending and bagging operation are subject to 40 CFR 60 Subpart F, New Source Performance Standards for Portland Cement Plants. This equipment is also subject to the general provisions of 40 CFR Part 60, New Source Performance Standards. 40 CFR 60 Subpart F applies to any kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage, clinker storage, finished product storage, conveyor transfer points, bagging and bulk loading and unloading systems that commenced construction or modification after August 17, 1971. For a complete list of equipment subject to 40 CFR 60 Subpart F at the time that the permit is issued, see the table in part III B of this narrative or the table in section 3.1 of the permit. The kiln and clinker cooler at the facility are not subject to 40 CFR 60 Subpart F as they were placed into service in 1962 and have not undergone changes which qualify as modifications under 40 CFR Part 60. 40 CFR 60 Subpart F limits the visible emissions from the subject equipment at the facility to less than 10% opacity. There are no mass emission limits applicable to the subject equipment. Limit on Sulfur Dioxide Emissions Emissions of sulfur dioxide (SO 2 ) from the cement kiln were limited in a previous permit amendment to 9 pounds per ton of clinker produced on an annual calendar year averaging basis. This limit was requested by the facility to reduce the amount of air permit fees due to EPD annually. A review of the condition and the necessity to have a practical monitoring strategy, for verifying compliance periodically, lead to the Division revising the permit condition. The revised permit Printed: December 19, 2003 Page 11 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 condition limits the emissions of sulfur dioxide to 9 pounds per ton of clinker produced on a rolling 12-month averaging basis. The requirement to add a CERMS to obtain emission data has been included in the permit along with the associated monitoring and record keeping requirements. The kiln and two raw mills are subject to Georgia Rule 391-3-1-.02(2)(g) that regulates emissions of sulfur dioxide. The limit taken by the facility to reduce the quantity of air emission fees paid annually is more restrictive than the limits contained in Rule (g). Limits on Nitrogen Oxides (NOx) Emissions The facility's emissions of NOx from the cement kiln are limited as follows: 30-day rolling average limit: 335 lb/hr 24-hour average limit: 460 lb/hr These limits were placed in effect in the permit amendment issued to apply the NOx RACT to the facility in April 1996. Georgia Rule 391-3-1-.02(2)(yy) requires the adoption of the NOx RACT for emissions of NOx from major sources. Limits on NOx Emissions during the "Ozone Season" (May 1 through September 30)The Atlanta ozone attainment SIP for the Lafarge plant requires that emissions of NOx be further reduced during the period May 1 through September 30 every year beginning in the year 2003. The reduced emissions are achieved through the burning of tires as a supplemental fuel in the cement kiln. The tires are injected in the kilns at a rate of approximately one tire per kiln rotation. The quantity is approximate due to the variation of tire sizes. Lafarge received a permit amendment to burn tires in their kiln in October 1999. Permission to burn tires was granted after a number of tests were performed at the facility and results of those tests, similar tests and other data were reviewed. A public hearing was held prior to EPD’s final decision to issue the permit amendment allowing the facility to burn tires as a supplemental fuel. There is a reduction in emissions of NOx from burning tires of between 30% and 50%. The facility's emissions of NOx from the cement kiln during the “ozone season” are limited as follows: 30 -day period during which no clinker is produced for special products.(tires continuously injected into kiln)30-day period during which clinker is produced for special products (no tires injected into kiln) 235 lb/hr rolling 30-day average 268 lb/hr rolling 30-day average The facility is allowed a 10-day period during each 30-day period in the “ozone season” to allow the production of specialty clinker. Burning tires adversely affects the color and quality of the specialty product. During the 30-day period in which no tires are injected into the kiln emissions of NOx are allowed to be higher as shown in the table above. The facility is required to burn tires as a supplemental fuel at all times during the “ozone season” except for periods when producing special clinker. Even though periods of producing specialty clinker is limited to 10 days in any 30-day period, the actual number of days when tires are not burned may be less than 10 days. Printed: December 19, 2003 Page 12 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 Applicable Rules and Regulations - 40 CFR 63 Subpart LLL – National Emission Standard for Hazardous Air Pollutants From the Portland Cement Manufacturing Industry 40 CFR 63 Subpart LLL applies to most equipment at new and existing Portland cement plants. Since the Lafarge plant’s emissions of any single hazardous air pollutant (HAP) is below 10 tons per year and its emissions of a combination of all HAP’s is below 25 tons per year, the facility is considered an area source as defined in 40 CFR 63.2. Area sources subject to 40 CFR 63 Subpart LLL are subject only to those provisions limiting emissions of dioxins and furans (D/F). Additionally, since Lafarge’s kiln and raw mill do not constitute an “inline kiln/raw mill" and does not use carbon injection or an alkali bypass, the facility is not subject to requirements specific to “inline kilns/raw mills” nor is it subject to the requirements on equipment that use carbon injection or an alkali bypass system. 40 CFR 63 Subpart LLL limits emissions of D/F from Lafarge’s kiln to: a. 0.20 ng per dscm (8.7 x 10 -11 gr per dscf) (TEQ) corrected to seven percent oxygen; or b. 0.40 ng per dscm (1.7 x 10 -10 gr per dscf) (TEQ) corrected to seven percent oxygen, when the average of the performance test run average temperatures at the inlet to the particulate matter control device is 204 ºC (400 ºF) or less. The facility is required to perform tests to verify that they can comply with the limits above. The initial compliance tests required by 40 CFR 63 Subpart LLL has shown that the facility can comply with the limits on D/F emissions without the installation of an activated carbon injection system. The D/F emission test average was 0.1218 ng per dscm. The maximum emission rate of D/F during the tests was 0.1284 ng per dscm and the minimum was 0.1187 ng per dscm. All of these test results were below the limit of 0.20 ng per dscm. All test results were (TEQ) corrected to 7% oxygen. The average run temperature at the baghouse inlet was 561.3 °F. Pursuant to the results of the compliance test, the Division is satisfied that Lafarge should be able to meet the limits on D/F emissions as required by 40 CFR 63 Subpart LLL and the Title V permit. 40 CFR 60 Subpart F40 CFR 60 Subpart F applies to kilns, clinker coolers, raw mill systems, finish mill systems, raw mill dryers, raw material storage, clinker storage, finished product storage, conveyor transfer points, as well as bagging and bulk loading/unloading systems at portland cement plants provided that the affected equipment was constructed or modified after August 17, 1971. The kiln, clinker cooler and most of the equipment at the Lafarge facility were constructed prior to 1971 and are therefore not subject to the requirements of 40 CFR 60 Subpart F. The equipment at the plant subject to this NSPS are: Printed: December 19, 2003 Page 13 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 Description Emission Unit ID North Flyash Silo EU520 Raw Material Unloading/Clinker Unloading EU100 Truck and Rail Car Unloading(to Cement/Pigment Mixing System) EU615 Cement/Pigment Mixing SystemEU616 PackhouseEU617Color Loading (Packhouse) EU618 Packhouse – Single Spout packing System EU628 Cement Reclaim System EU629 Antique white pipeline EU630 The equipment listed above appears in section 3.1 of the Title V permit and shows the applicability of the NSPS is indicated. Since the subject equipment does not include a kiln or clinker cooler, only the opacity limit in NSPS F is applicable to the facility at this time. The opacity from the subject equipment is limited to less than 10 percent by NSPS F. Georgia Rule 391-3-1-.02(2)(b) – Visible Emissions The facility is subject to the generally applicable visible emissions rule that limits opacity of emissions from all equipment, except those subject to NSPS subpart F, to 40 percent. Georgia Rule 391-3-1-.02(2)(e) – Particulate Matter Emissions from Manufacturing Processes The facility is subject to Georgia Rule (e) that limits emissions of particulate matter from all process equipment at the facility. For equipment in operation or under construction on or before July 2, 1968, the facility shall determine allowable emission rates using the formula: E = 4.1 P 0.67 For equipment constructed or placed in operation after July 2, 1968 the formulas to be used are: E = 4.1 P 0.67 ; for process input weight rate up to and including 30 tons per hour. E = 55 P 0.11 - 40; for process input weight rate above 30 tons per hour. In the equations, E is the allowable emission rate in pounds per hour, and P is the process input weight rate in tons per hour. Georgia Rule 391-3-1-.02(2)(g) – Sulfur Dioxide The facility is subject to Georgia Rule (g) that limits emissions of SO 2 from subject equipment at the facility. Printed: December 19, 2003 Page 14 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 Georgia Rule 391-3-1-.02(2)(n) – Fugitive Dust The facility is subject to the generally applicable fugitive dust rule that requires that all reasonable steps be taken by the facility to prevent dust from becoming airborne. The rule also lists certain precautions, such as water spray, to use to control fugitive dust. The fugitive dust rule also limits the opacity of fugitive dust emissions to less than 20 percent. D. Compliance Status The facility has no current compliance issues. E. Operational Flexibility Lafarge made no requests for operational flexibility in its Title V application. However, EPD has effected some amount of operational flexibility in the Title V permit allowing Lafarge to add and/or modify equipment without the need to reopen the Title V permit. Such situations would include off-permit changes and changes made under Section 502(b)(10) of the Clean Air Act. Notifying EPD/EPA may or may not be required in some instances, but EPD has requested that facilities making such changes provide notification prior to making those changes so that EPD has the opportunity to evaluate and classify the change prior to the change being made. F. Permit Conditions Permit condition 3.2.1: This permit condition limits the operating hours for equipment in the blending and bagging operation. The limit of 7,638 hours was put in effect in September 1988 to avoid PSD review in processing the permit application for construction and operation of the bagging and blending operation. Permit Condition 3.2.2: The facility previously requested a condition be placed in their permit to limit emissions of sulfur dioxide for the purpose of reducing emission fees. The existing limit on sulfur dioxide emissions from the kiln is a maximum of 9 pounds per ton of clinker produced on an annual calendar year averaging basis. This permit changes the limit to 9 pounds per ton of clinker produced on a rolling twelve-month basis and allows the Permittee to use the calendar year data to for purposes of determining emission fees for SO 2 . Permit Condition 3.2.3: The limits on emissions of nitrogen oxides from the kiln are 460 pounds per hour on a 24-hour averaging basis and, at the same time, 335 pounds per hour on a 30-day rolling average basis. Only those hours during which fuel is being delivered to the kiln are allowed to be used for averaging. These limits were placed on the kiln due to the NOx RACT in April 1996. Permit Condition 3.2.4: This condition places a more restrictive limit on emissions of nitrogen oxides during the “ozone season” – May 1 through September 30 of each year. This condition is required as a result of the Atlanta SIP for NOx emissions and will be first effective in 2003. Permit Condition 3.2.5: This condition specifies that tires must be burned in the kiln at all times that the kiln is in operation, except when producing special product. The exception is necessary to allow the facility to produce special clinkers during which process tires cannot be burned, as doing so would adversely affect product quality (e.g. clinker for white or gray cement). Printed: December 19, 2003 Page 15 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 Permit Condition 3.2.6: This limits in this condition were added to the facility’s operating permit in March 2000 and January 2001 and is carried forward to the Title V permit. The amendments in which these limits were added gave permission to install a packing system and a new rail unloading station. The limits were placed in effect to avoid PSD review. Permit Condition 3.2.7: This condition was placed in the facility’s permit when putting the NOx RACT in effect and later applied to the Atlanta NOx SIP. It specifies that data obtained from the CERMS shall be used to determine compliance with the emission limits in Conditions 3.2.3 and 3.2.4 (NOx limits). Permit Condition 3.2.8 specifies fuels and supplemental fuels which may be used to fire the cement kiln. The fuels primarily used in the kiln are natural gas and coal. The supplemental fuels listed were added at different times between 1993 and 2002. Permit Condition 3.2.9 lists fuels that may be burned in the facility’s two raw mills. Permit Condition 3.2.10 requires the facility to obtain written permission from the Division prior to receiving any coal by-product that will be used as supplemental fuel in the kiln. Permit Condition 3.2.11 specifies that the maximum amount of time that the NOx LINKman control system may be manually overridden be limited to 5% of the kiln’s operating time. The LINKman control system is required to be used for monitoring and controlling NOx emissions from the kiln by the NOx RACT. Permit Condition 3.3.1 applies NSPS subpart F (40 CFR 60 subpart F) to subject equipment at the facility. Table 3.1 in the permit (table also appears above in this document) specifies which pieces of equipment are subject to this standard at the time of permit issuance and indicates that if new equipment is added in the future, in accordance with the operational flexibility conditions in Sections 7.1 and 7.2 of the permit, that the requirements of NSPS subpart F applies to those pieces of equipment added. Permit Condition 3.3.2 applies NESHAP Subpart LLL (40 CFR 63 subpart LLL) to all subject equipment at the facility. Permit Condition 3.3.3 specifies the limits on emissions of dioxins and furans (D/F) from the cement kiln. These limits are required to be complied with by 40 CFR 63 subpart LLL (the cement kiln MACT). It limits the facility’s emissions of D/F to a maximum of 0.20 ng per dscm (8.7 x 10 -11 gr per dscf) (TEQ) corrected to seven percent oxygen. TEQ means the international method of expressing toxicity equivalents for dioxins and furans as defined in U.S. EPA, Interim Procedures for Estimating Risks Associated with Exposures to Mixtures of Chlorinated Dibenzo-p-dioxins and dibenzofurans (CDDs and CDFs) and 1989 Update, March 1989. This definition appears in 40 CFR 63 Subpart LLL. Permit Conditions 3.3.4 specifies the temperature limit for the inlet to the baghouse controlling emissions from the kiln while the kiln is in operation. This limit is required by the cement MACT (40 CFR 63 Subpart LLL). Printed: December 19, 2003 Page 16 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 Permit Conditions 3.3.5 requires that the temperature limit for the inlet to the baghouse controlling emissions from the kiln be determined in accordance with the procedures outlined in Condition 4.2.4. The temperature contained in Condition 3.3.4 was determined using those procedures and Condition 3.3.5 is included in case the limit needs to be modified in the future. Permit Condition 3.4.1 indicates the formulas to be used to determine the facility’s potential to emit particulate matter under Georgia’s rule 391-3-1-.02(2)(e) “particulate Matter Emissions from Manufacturing Processes.” The entire facility is essentially subject to Rule (e). Rule (e) requires that the following equations be used to calculate the allowable rates of emission from new equipment: E = 4.1 P0.67 ; for process input weight rate up to and including 30 tons/hour. E = 55 P 0.11 - 40; for process input weight rate above 30 tons/hour. The following equation shall be used to calculate the allowable rates of emission from existing equipment 9 E = 4.1 P0.67 Equipment in operation, or under construction contract, on or before July 2, 1968, is considered existing equipment and equipment in operation or constructed after July 2, 1968 is considered new equipment for the purposes of Georgia’s Rule (e). In the equations, the variables E and P represent the emission rate in pounds per hour and the process input weight rate in tons per hour, respectively. Permit Condition 3.4.2 requires Lafarge to meet the requirements of Georgia Rule 391-3-1-.02(2)(g) that specifies sulfur content limits for fuel burning equipment. Although the only equipment at the facility subject to the rule at this time are the kiln and two raw mills, the entire rule has been placed in the permit to allow for operational flexibility in the future. The raw mills and kiln, at this time, are subject specifically to 391-3-1-.02(2)(g)2. That part of the rule limits the sulfur content of fuels for the raw mills to no more than 2.5% sulfur, by weight, and to no more than 3% sulfur, by weight for the kiln. The limits are based on the heat inputs of the equipment – the raw mills have a heat input of less than 100 million Btu/hour effecting the 2.5% fuel sulfur content limit and the kiln has a heat input of greater than 100 million Btu/hour making its fuel sulfur content limit 3%. Permit Condition 3.4.3 requires Lafarge to comply with Georgia Rule 391-3-1-.02(2)(b) which restricts the facility’s visible emissions to less than 40 percent opacity. Permit Condition 3.5.1 requires Lafarge to operate baghouses at any time that associated equipment is in operation. Permit Condition 3.5.2 requires Lafarge to maintain an inventory of replacement filter bags and parts for baghouses and monitoring devices. Printed: December 19, 2003 Page 17 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 IV. Testing Requirements (with Associated Record Keeping and Reporting) A. General Testing Requirements Standard general testing requirements have been included in the permit. Other than more specific testing requirements, there are no exceptions to the general testing requirements. B. Specific Testing Requirements Initial performance tests required by 40 CFR 60.8 have been completed for all existing equipment at the facility. The permit allows certain changes to be made to the facility without the necessity of a permit revision. These changes include installing certain new equipment and replacing certain existing equipment. If such changes are made at the facility, a permit condition has been included that requires initial performance tests to be performed in accordance with 40 CFR 60.8 and the applicable subpart. The initial compliance tests required by 40 CFR 63 Subpart LLL and done in accordance with 40 CFR 63.7 have shown that the facility can comply with the limits on emissions of dioxins and furans (D/F) without the installation of an activated carbon injection system. The D/F emission test average was 0.1218 ng/dscm, below the required limit of 0.20 ng/dscm. The maximum emission rate of D/F during the tests was 0.1284 ng/dscm and the minimum was 0.1187 ng/dscm. All tests were performed in accordance with 40 CFR 63. The Division is satisfied that Lafarge should be able to meet the limits on D/F emissions. A permit condition has been included in accordance with 40 CFR 63 LLL to repeat the D/F tests every 30 months and when any significant changes are made to the kiln feed or fuel. The record keeping requirements of 40 CFR 63 LLL have been included in the permit. The Permittee is required to keep at least 5 years of kiln operating records, the most recent two years of records being kept on site. The remaining 3 years of records may be kept off site. The specifics of information to be maintained are contained in condition 6.2.1 b. Printed: December 19, 2003 Page 18 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 V. Monitoring Requirements (with Associated Record Keeping and Reporting) A. General Monitoring Requirements Condition 5.1.1 requires that all required monitors be operated continuously except during breakdowns and repairs. Any repairs or maintenance performed should be completed in an expeditious manner minimizing downtime. All data should also be recorded during any calibration activity to help verify that the calibration was performed and completed properly. B. Specific Monitoring Requirements The majority of the sources at the facility have baghouses for control of particulate matter (PM) emissions and are subject to the PM and Visible Emissions limitations of Condition 3.4.1, Rules 391-3-1-.02(2)(b) and (e), and 40 CFR 60 subpart F. The more significant sources of PM at the facility are controlled by the larger baghouses installed at the facility and are subject to the monitoring requirements of Conditions 5.2.2 and 5.2.3 to reasonably assure compliance with applicable emissions limitations. Sources subject to NSPS subpart F are subject to these conditions. To reasonably assure compliance with applicable PM limitations, a Visible Emissions (VE) check is required each day of operation of the emission units controlled by those baghouses. A Preventive Maintenance Program is required on these baghouses. The program requires weekly monitoring of baghouse pressure drops and the performance of operation and maintenance checks on the baghouses. All VE and Preventative Maintenance Program information is retained by the Permittee and, upon request, submitted to the Division. Excursions, to be reported semiannually, are specified. Baghouses controlling emissions from silos with dedicated bin vents, wet screening operations, bucket elevators, screw conveyors, bagging operations, and pneumatic conveyors are exempt from the detailed monitoring described in the previous paragraph due to little likelihood of significant particulate matter emissions from those sources. All baghouses that receive gases from a combustion source are required to monitor (not record) temperature continuously and to record all occurrences when temperatures exceed the maximum filter design temperatures. The specified excursions are to be reported semiannually. Except for baghouse D13 that controls emissions from the kiln (EU303), surrogate temperature monitoring is allowed. The requirements of 40 CFR 63 LLL do not allow baghouse D13 to be monitored using surrogate temperature measurements. Sources of particulate matter emissions that have no air pollution control equipment are required to be inspected each day of operation for visible emissions and/or malfunctions that might cause increased air emissions. The permit includes a requirement to take corrective action and keep records. If problems are revealed during the daily check, they must be reported in the semiannual report if not corrected within 24 hours. The specified excursions are to be reported semiannually. In accordance with 40 CFR 63 LLL and to provide assurance of compliance with the limits on emissions of D/F, the Permittee is required to continuously monitor the temperature of the exhaust gases from kiln No. 1 at the inlet to or upstream of baghouse D13. The requirements for performing this monitoring are specified in condition 5.2.7 and 5.2.8 in the permit. The Permittee is required to prepare and submit to the Division a written operation and maintenance plan for the Kiln (EU303). The plan is subject to review and approval by the Division and must Printed: December 19, 2003 Page 19 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 contain procedures for operating and maintaining the kiln and its associated air pollution control devices to meet the emission limitations contained in conditions 3.3.2 through 3.3.5. The plan must also contain procedures to be used to inspect the components of the kiln’s combustion system at least once per year. Failure to comply with the approved operation and maintenance plan is considered a violation under 40 CFR 63 LLL. Installation, operation and maintenance of a CERMS are required to monitor emissions of nitrogen oxides to verify compliance with conditions 3.2.3 and 3.2.4. This limit and associated monitoring existed in the facility’s previous air quality permit to place in effect the NOx RACT effective in April 1996. Conditions 5.2.1 and 5.2.13 specify associated requirements for NOx monitoring. The Division has effected changes to the condition limiting emissions of sulfur dioxide to allow for the inclusion of an acceptable periodic monitoring strategy. The condition has been changed so that the averaging basis is on a rolling 12-month averaging basis instead of a calendar year averaging basis. This change should make periodic monitoring more practical and will help to reasonably assure compliance with the limit. The Permittee is allowed to use calendar year data to calculate sulfur dioxide emissions for emission fee purposes. Related record keeping requirements have been included in conditions 5.3.1 and 5.3.2 to keep records of the data acquired and the data used to verify compliance with the SO 2 limit of 9 pounds per ton of clinker produced on a rolling 12-month averaging basis. A continuous emissions rate monitoring system (CERMS) is being required to collect emissions data. The permit includes the requirement to maintain records of hours of operation for the bagging and blending facility to verify compliance with condition 3.2.1, which limits operation of that group of equipment to 7,638 hours during any 12-month period. The Permittee is also required to maintain records of fuel oil supplier certifications for all shipments of fuel oil received. Requirements to maintain records of the quantities of the different types of supplemental fuels used in the kiln and raw mills are included in the permit. Due to the small quantities of supplemental fuels used it was not deemed necessary to require detailed analyses of these fuels. Printed: December 19, 2003 Page 20 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 VI. Other Record Keeping and Reporting Requirements A. General Record Keeping and Reporting Requirements The Permit contains requirements for the maintenance of all records for a period of five years following the date of entry and requires the prompt reporting of all information related to deviations from applicable requirements. Reports of excess emissions, exceedances and/or excursions are required to be reported on a quarterly basis. B. Specific Record Keeping and Reporting Requirements A permit condition has been included to require the Permittee to comply with the reporting and record keeping requirements of Subpart A in 40 CFR Part 60 “Standard of Performance for New Stationary Sources.” The Permittee is required to furnish the Division any required written notifications. All record keeping requirements of 40 CFR 63 Subpart LLL pertaining to the facilities have been included in the permit. Printed: December 19, 2003 Page 21 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 VII. Specific Requirements A. Operational Flexibility The Permittee did not request any operational flexibility to be included in the permit. The Division has, however, included some amount of operational flexibility that allows certain changes to be made without the need for permit revision. In certain instances, new equipment may be added or modifications made without the need for permit revision. For example, certain new pieces of NSPS equipment may be added with only notification from the Permittee to the Division and/or the US EPA. Notifications should be submitted to the Division with a description of the change or new equipment so that the Division has the opportunity to decide if the change may be handled without a permit revision. B. Alternative Requirements • Not applicable C. Insignificant Activities • Refer to Attachment B to the Title V permit and to section 4.10 of the Title V application. D. Temporary Sources • Not applicable E. Short-Term Activities • None indicated in the application. F. Compliance Schedule/Progress Reports • Not applicable G. Emissions Trading • Not applicable H. Acid Rain Requirements • Not applicable I. Prevention of Accidental Releases • Not applicable J. Stratospheric Ozone Protection Requirements • Not applicable Printed: December 19, 2003 Page 22 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 K. Pollution Prevention • Not applicable L. Specific Conditions • Not applicable VIII. General Provisions Generic provisions have been included in this permit to address the requirements in 40 CFR Part 70 that apply to all Title V sources, and the requirements in Chapter 391-3-1 of the Georgia Rules for Air Quality Control that apply to all stationary sources of air pollution Printed: December 19, 2003 Page 23 of 23
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 Addendum to Narrative EPD issued draft Title V Permit 3241-121-0401-V-04-0 for Lafarge Building Materials’ Portland cement manufacturing plant in Atlanta on December 16, 2002. The public notice for this permit was published in the Fulton County Daily Report on August 29, 2003. The public comment period expired on September 28, 2003. Comments on the Title V draft permit were received from the facility (Lafarge) via fax on September 29, 2003 and via mail on October 3, 2003. No comments have been received from EPA. The comments received from the facility are provided below, each followed by a discussion of the comment and any changes made to the permit as a result. Comments & EPD Responses on Title V Draft Permit for Lafarge Building Materials Atlanta Plant Condition 1.3 Lafarge Comment: Lafarge requests that EPD remove references to throughput rates in this section of the permit, as such values should not be construed as permit limits. Specifically, we request EPD remove the following sentence on page 2 of the permit: The kiln system at the Atlanta plant is capable of producing clinker at the rate of 44 tons per hour We also request that the permit list coal byproduct as a fuel used in the kiln. …the Atlanta Plant uses fuel oil, natural gas, carbon black (toner), used oil, coal byproduct,… EPD Response: The sentence for which deletion is being requested was provided, exactly as stated, by Lafarge upon request of EPD in drafting the permit. EPD does not understand how the statement could be construed as a permit limit within the “Process Description.” However, the sentence will be deleted. Coal by-product has been added to the list of fuels. EPD has also added a statement making it clear that prior to obtaining any coal by-product for use as a fuel in the kiln, Lafarge is required to notify EPD and obtain written permission. This is in accordance with Condition 3.2.10 in the permit. Also note that some of the fuels listed in the process description are supplemental fuels as indicated in the permit. Condition 2.2.2 Lafarge Comment: Lafarge’s Atlanta plant is an area source under the portland cement NESHAP. To clarify non-applicability of the major source requirements, we request that EPD include an additional sentence to this effect: “The facility is subject to the area source requirements of 40 CFR 63 Subpart LLL.” EPD Response: The requested change has been made. Table 3.1 Emission Units Lafarge Comment: Lafarge has reviewed the ID Nos. and Descriptions in this table for accuracy and requests the following updates for equipment that have been relocated within the plant, and for sources that have been decommissioned. ♦ Rename EU203 to Finish Mill No. 3 System and move to Finish Mill Section ♦ Rename EU204 to Finish Mill No. 3 Separator/Conveyor System and move to Finish Mill Section ♦ Remove shutdown equipment EU202, EU207, EU625, and EU626 (Surge Bins), EU515 (Cement Cooler No. 2), and EU517 (Finish Mill No. 2 Fringe Tank) Printed: December 19, 2003 Addendum Page 1 of 9
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 In addition, Lafarge has reviewed the regulatory and permit condition citations for accuracy and requests the following changes shown in Table 1. Note that strikethrough text represents text to be deleted and bold text represents text to be added. No changes are requested to emission units within rows, which are not listed in Table 1 except for the decommissioned units above. EPD Response: Georgia Rule 391-3-1-.02(2)(g) is applicable to “fuel burning sources.” Fuel burning sources include any emission unit at a facility that burns a fuel. Therefore, Rule (g) is applicable to the kiln and raw / finish mills. The permit has been modified to remove the shutdown equipment indicated and to prohibit operation of those pieces of equipment (see Condition 7.14.1). Condition 3.2.5 (b) Lafarge Comment: In 2002, a meeting between Lafarge and Jimmy Johnston (EPD), it was agreed upon that a 268 lb/hr limit. “Provided that specialty clinker is produced during any 30-day averaging period, the applicable NO X limit under this conditions is 268 lb/hr.” EPD Response: It appears that the condition number referenced in the comment has been incorrectly quoted. Condition 3.2.5(b) concerns the number of days that tires are burned. Condition 3.2.4 contains the NOx limit at 268 lb/hour. The following addresses condition 3.2.4 and 3.2.5. As has been discussed and agreed upon with Lafarge during the Emission Reduction Credit process, Condition 3.2.4 limits the emissions of NO X in accordance with Appendix XIX of the Atlanta Ozone Non-Attainment SIP. The second column of the table in the condition limits emissions of NO X during the “30-day period during which clinker is produced for special products (no tires injected into kiln)” to 268 pounds per hour on a rolling 30-day average. Condition 3.2.5 limits the number of days on which tires are allowed not to be burned during any 30-day period during which specialty clinker is produced. These conditions incorporate the applicable requirements from the Atlanta Ozone Non-Attainment SIP. Any revision to these conditions would need to be preceded by a rule revision. The permit conditions remain unchanged. Condition 3.2.7 Lafarge Comment: – Lafarge suggests that EPD define the term CERMS (Continuous Emission Rate Monitoring System) in this condition. EPD Response: A reference to 40 CFR 60, Appendix B has been added to the definition of CERMS in Appendix A of the permit for clarification of the definition of “CERMS.” Condition 3.2.11 Lafarge Comment: Appendix XIX of the Georgia State Implementation Plan (SIP) requires the use of LINKman controls at this site. Lafarge may upgrade or change this system in the future to replace obsolete programming as the system ages. However, this terminology is cited in Appendix XIX of the Georgia SIP and in the Title V permit. In Section 7 of the permit (discussed later in this document), Lafarge is suggesting an approach to upgrade this system as an administrative change to the SIP and the permit. EPD Response: This change cannot be handled in the Title V permit, as the use of the LINKman system is specifically included in Appendix XIX of the Atlanta non Attainment SIP. The change must occur first in the Atlanta Non-Attainment SIP using the appropriate process for making changes to the state rules. After such change, the facility may request the change in the permit. Printed: December 19, 2003 Addendum Page 2 of 9
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 Condition 3.3.1: Lafarge Comment: The regulatory citation should be corrected as shown (bolded). …[40 CFR 60 Subpart F; 391-3-1-.02(8)]EPD Response: The citation has been corrected. Condition 3.3.2 Lafarge Comment: Lafarge’s Atlanta plant is an area source under the portland cement NESHAP. To clarify non-applicability of the major source requirements, we request that EPD add the following words. Also the regulatory citation should be corrected as shown (bolded). The Permittee shall comply with the area source requirements of 40 CFR 63 Subpart LLL…. …[40 CFR 63 Subpart LLL; 391-3-1-.02(9)]EPD Response: The requested change has been made. Condition 3.3.3 Lafarge Comment: The portland cement NESHAP allows a source two compliance options for dioxin/furan emissions, based on operating temperatures. Because Lafarge may successfully demonstrate compliance at different baghouse inlet temperatures in future performance tests, we request both dioxin/furan limits be included in the permit (bolded): The Permittee shall not cause to be discharged into the atmosphere from kiln No. 1, gases which contain D/F in excess of 0.20 ng per dscm (TEQ) corrected to seven percent oxygen with a control device inlet temperature more than 204ºC (400ºF), or 0.40 ng per dscm (TEQ) corrected to seven percent oxygen with a control device inlet temperature less than or equal to 204ºC. EPD Response: The condition has been edited to allow the flexibility of using either option under the NESHAP. Condition 3.3.4 Lafarge Comment: Every 30 months, the portland cement NESHAP requires establishing a new temperature limit with each dioxin/furan test. To prevent modifications to the permit with a specific value, we request wording similar to the NESHAP be used (bolded): The Permittee shall operate kiln No. 1 such that the 3-hour rolling average inlet temperature to baghouse D13 does not exceed the temperature established during the most recent dioxin/furan performance test. EPD Response: The permit condition has been revised to allow flexibility in case the temperature limit changes in the future. EPD has revised Condition 5.2.10 to allow 120 days for the installation of the temperature monitoring system required to be installed by Condition 5.2.2. Condition 3.4.2 Lafarge Comment: This condition states that Lafarge’s kiln and raw mills are subject to Georgia Rule (g), which regulates sulfur dioxide from “fuel-burning equipment.” Lafarge recently reviewed this definition, upon which applicability to Rule (g) is based, and does not agree that Rule (g) applies to these units. The term "fuel burning equipment" is defined as (cc) “Fuel-burning Equipment” means equipment the primary purpose of which is the production of thermal energy from the combustion of any fuel. Such equipment is generally that used for, but not limited to, heating water, generating or super heating steam, heating air as in warm air furnaces, furnishing process heat indirectly, through transfer by fluids or transmissions through process vessel walls. Printed: December 19, 2003 Addendum Page 3 of 9
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 While Lafarge is able to meet the Rule (g) limits, the regulated equipment (i.e., kiln and raw mills) are used to manufacture cement and not for the “primary purpose” of producing “thermal energy from the combustion of any fuel.” Also, the process material is in direct contact with the combustion gases, rather than indirectly heated as described for “fuel burning equipment.” For these reasons, Lafarge believes that Rule (g) should not apply to the kiln and raw mills. EPD Response: EPD does not agree with Lafarge’s opinion that Rule (g) applies only to fuel burning equipment. The rule applies to all fuel burning “sources” with no equipment specific restriction as suggested by Lafarge. Hence, condition 3.4.2 remains unchanged. Condition 4.2.1: Lafarge suggests a wording change to clarify the intent of this permit condition In accordance…but no later than 180 days after initial startup, unless stated otherwise in the applicable subpart of 40 CFR Part 60… EPD Response: This condition adds flexibility to allow the addition of certain types of equipment subject to 40 CFR Part 60 without the need for any permitting action. The timing constraints specified in subpart A of 40 CFR Part 60 are not expected to be otherwise specified by the subparts. If EPA chooses to amend any part of the federal register, EPD will amend Part 70 permits as required. Condition 4.2.1 remains unchanged. Condition 4.2.2: Lafarge Comment: Lafarge suggests a wording change to maintain consistency with the portland cement NESHAP Within 30 months of the most recent dioxin/furan performance test, the Permittee shall conduct…EPD Response: Conditions 4.2.2 and 4.2.3 have been revised to clarify the requirements for when performance tests for dioxins/furans (D/F) are to be done. Condition 4.2.4: Lafarge Comment: Correct the permit condition reference from “5.2.2(a)” to “5.2.2.” EPD Response: The reference in the condition has been corrected. Condition 5.2.1 (b): Lafarge Comment: This condition requires Lafarge to install and operate a CERMS for SO 2 emissions from the kiln. SO 2 emissions are determined for comparison against the permit limit of 9 lb SO 2 /ton clinker produced. We request the CERMS requirement be replaced with the current mass balance method of tracking SO 2 emissions each month based on the sulfur contents and throughputs of each material. Please refer to the attached letter, dated November 22, 2002, fromMs. Tia Bohannon (Lafarge) to Mr. Bradley Bellflower (EPD), which shows the formula that Lafarge developed to calculate SO 2 emissions from kiln feed, clinker, waste dust, and fuel throughputs. The SO 2 permit limit was taken to reduce air permit fees, which are based on annual emissions. Requiring a continuous SO 2 measurement using a CERMS, and determining hourly emissions is more frequent than what is needed to show compliance with this requirement. Therefore, a monthly calculation is sufficient to demonstrate compliance with the SO 2 limit applicable to this facility. Lafarge suggests the currently accepted mass balance method be used for future compliance demonstrations in lieu of the proposed CERMS, by removing 5.2.1 (b) and adding a new condition (5.2.13): 5.2.13 The Permittee shall calculate SO 2 emissions for each calendar month, in units of pounds per ton of clinker, from Kiln No. 1 (EU303) using a mass balance approach. EPD Response: EPD further evaluated the mass balance approach and has not been able to establish that a mass balance approach provides accurate SO2 emission data considered reliable as required by Part 70. Consequently, a CERMS has been required, which EPD has determined provides reliable SO2 emission data in accordance with Part 70. Condition Printed: December 19, 2003 Addendum Page 4 of 9
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 5.2.1(b) remains unchanged. EPD does realize that the monitors will require time for installation and Condition 5.2.10 has been revised to allow 120 days for the installation of the CERMS for monitoring SO 2 emissions. Condition 5.2.3: Correct the typographical error in the first sentence of this condition The Permittee shall perform a check of visible emissions from and dust sock D69 and all baghouses …EPD Response: The inclusion of the dust sock D69 is not an error in the condition. The Packhouse (Single Spout Packing System) is subject to Rule (e) and to 40 CFR 60 Subpart F and its venting point is therefore subject to monitoring similar to that performed for baghouses controlling emissions from similarly subject sources. The condition remains unchanged. Condition 5.2.3 (c): Lafarge Comment: This condition, as drafted, requires a daily check for visible emissions on several units at the site. If visible emissions are observed, then corrective action must be initiated. At Lafarge, certain processes may exhibit visible emissions and be considered in compliance with all applicable requirements (e.g., visible emissions may be observed at level corresponding to 5% opacity where an applicable opacity limit for the sources is 10% opacity limit). Also, many of the material handling sources may emit no visible emissions for extended periods of time during the course of a given year. Accordingly, Lafarge requests two items be added to this condition, and both requests are proposed in a manner consistent with the portland cement NESHAP monitoring requirements applicable to major sources. Specifically, Lafarge suggests the option to perform a six-minute Method 9 test in lieu of the presently required steps in this condition for visible emissions. If the tested opacity is in compliance with the applicable standard, then no additional steps are required, and this event is not considered an “excursion”. Secondly, for sources with no visible emissions for extended periods of time, we are proposing less frequent monitoring (i.e., daily, weekly, monthly, semi-annually inspections). This wording would be added to the existing condition: In lieu of these actions, the Permittee may perform a six-minute Method 9 test to determine opacity from a source. If the opacity level is in compliance with the applicable standard, then no additional steps are required, and this event shall not be considered an “excursion”. If no visible emissions are observed for seven consecutive days of daily inspections for an affected source, then the Permittee may decrease the frequency of inspection from daily to once per week for that source. If no visible emissions are observed after four consecutive weekly inspections for a source, then the Permittee may decrease the frequency of inspection from weekly to once per calendar month for that source. If no visible emissions are observed for six consecutive monthly inspections for a source, then the Permittee may decrease the frequency of inspection from monthly to once per six calendar months for that source. If visible emissions are noted at anyinterval, the Permittee must resume daily inspections according to the above schedule. EPD Response: The prescribed monitoring is consistent with EPD’s standard Part 70 monitoring approach for baghouses at major sources in Georgia. The monitoring approach tracks proper operation and maintenance of baghouses. EPD recognizes that facilities in Georgia have existing programs to properly operate and maintain their baghouses. Hence, the additional burden imposed by the Part 70 monitoring is minimal and involves primarily increased record keeping and reporting. EPD has determined that properly operated and maintained baghouses are designed to comply with the particulate matter emission standard and opacity standard. EPD does not have data to support that compliance with the particulate matter standard will be achieved at opacity levels proposed by Lafarge. While a Method 9 may be used to assure direct compliance with the opacity standard, Method 9 would not necessarily assure compliance with the particulate matter standard. For example, a non-NSPS baghouse with visible emissions at 39% opacity would comply with the 40%opacity limit, but would likely fail to meet the particulate matter standard. Printed: December 19, 2003 Addendum Page 5 of 9
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 The daily frequency specified by EPD is the minimum necessary to track proper operation and maintenance of a baghouse. A baghouse check every six months as proposed by Lafarge is not an acceptable part of properly operating and maintaining a baghouse. Lafarge’s proposal would not provide a reasonable assurance of compliance over the relevant time period as required byPart 70. Condition 5.2.3(c) remains unchanged. Condition 5.2.5: Lafarge comment: Lafarge requests this condition be removed as it is in error. The kiln baghouse temperature is monitored as a surrogate for dioxin/furan emissions. However, other baghouses that receive gases from a “source that drys or calcines” at the facility have no applicable regulatory requirements to monitor temperatures. Lafarge operates the baghouses at temperatures well below the filter bag design temperatures and does not experience bag breakage from high temperatures during normal operation, as may be found at clay processing or aggregate facilities. In addition, these ancillary baghouses at the Atlanta Plant receive gases at a much lower temperature (180-190°F) than the kiln baghouse (550-560°F). Lafarge believes this condition is neither warranted nor applicable to the Atlanta Plant and therefore requests its removal. EPD Response: Monitoring baghouse temperature for sources that receive hot exhausts gases from a calciner or dryer assures that the baghouse is properly operated as an integral part of the prescribed Part 70 monitoring for baghouses. EPD recognizes that baghouses receiving hot gases from dryers and calciners throughout Georgia are designed with systems in place to prevent temperatures from exceeding the bag design during “normal” operations. The requirement to monitor temperature will detect instances when bags are overheated under “any” mode of operation, which is reasonable and an integral part of assuring baghouses are properly operated. Condition 5.2.5 remains unchanged. Condition 5.2.6: This condition requires a daily walkthrough and documentation/reporting of visible emissions. Given the time and effort to perform a plant-wide walkthrough and check for visible emissions (in addition to the other monitoring requirements specified in this permit), Lafarge requests the frequency of these checks be changed from daily to once per week. EPD Response: The prescribed monitoring is consistent with EPD’s standard Part 70 monitoring approach for uncontrolled emission units at major sources in Georgia. There are nine uncontrolled emission units identified in Table 3.1 that will need to be checked according to Condition 5.2.6. EPD believes that plant personal will look at these uncontrolled emission units at least once each day of operation as part of normal operating procedures to assure the units are working properly. Hence, this monitoring primarily requires additional record keeping and reporting. Condition 5.2.6 remains unchanged. Condition 5.2.7 (c): We are requesting that EPD remove this condition since Lafarge does not operate an in-line raw mill. The portland cement NESHAP requires off/on records for raw mills that are in-line with kilns. The Atlanta plant does not operate an in-line raw mill; therefore, this record is not necessary. EPD Response: Condition 5.2.7 (c) has been deleted as it pertains only to in-line kilns/raw mills, which do not exist at the facility. Printed: December 19, 2003 Addendum Page 6 of 9
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 Condition 5.2.8: Lafarge Comment: Lafarge requests that the purpose of this condition be more definitively stated, by inserting the following statement at the start of this condition: For purposes of complying with 40 CFR 63 Subpart LLL,… EPD Response: The citation of regulatory authority included with the condition clearly conveys the purpose for the requirement. The condition has not been changed. Condition 5.2.9: Lafarge Comment: Lafarge requests that the purpose of this condition be more definitively stated, by rewording the start of this condition (bolded): For purposes of complying with 40 CFR 63 Subpart LLL,… EPD Response: The citation of regulatory authority included with the condition clearly conveys the purpose for the requirement. The condition has not been changed. Condition 5.2.10: Lafarge Comment: Since the permit issuance date is termed the “effective date” on the final permit, Lafarge asks this terminology be used as indicated: …shall take effect 120 days after the effective date of this permit… EPD Response: The condition has been revised to include the change requested since the permit cover does indicate the “effective date” as the date of issuance. Condition 6.1.4: Lafarge Comment: This condition requires quarterly reports. Lafarge will continue to perform the requirements under NO X RACT on a quarterly basis, such as RATA testing. However, to maintain consistency with the portland cement NESHAP and regulatory objectives to reduce paperwork burdens on both Lafarge and EPD, we are proposing that reporting frequency be changed from quarterly to semi-annually. EPD Response: Increasing the period between reports would be contrary to the existing conditions contained in the permit issued to effect requirements for Lafarge’s RACT plan for NOx. The permit condition remains unchanged. Condition 6.1.7: Lafarge Comment: Correct a typographical error in the regulatory citations as follows: […40 CFR 63.1354(b)(9), & 40 CFR 60 Subpart F]EPD Response: The “&” has been removed from citation for the permit condition. Condition 6.1.7 (b) (viii.):Lafarge Comment: This condition limits the sulfur content of fuels burned in Kiln No. 1 to less than 3.0 percent (by weight) according to condition 3.4.2 [Rule (g)]. As stated previously, Lafarge does not believe that the kiln meets the definition of “fuel-burning equipment” and has requested that condition 3.4.2 be removed. Therefore, Lafarge also requests this condition be removed. EPD Response: EPD does not agree with Lafarge’s opinion that Rule (g) applies only to fuel burning equipment. The rule applies to all fuel burning “sources” with no equipment specific restriction as suggested by Lafarge. Hence, condition 6.1.7(b)(viii.) remains unchanged Printed: December 19, 2003 Addendum Page 7 of 9
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 Condition 6.1.7 (b) (ix): Lafarge Comment: This condition limits the sulfur content of fuel oil burned at the facility to less than 0.5 percent (by weight). The facility is not subject to any New Source Performance Standards (NSPS) or SIP rule, which would limit the sulfur content of fuel to less than 0.5 percent. Therefore, Lafarge requests that this condition be removed. EPD Response: In 1993 Lafarge (then Blue Circle) applied for and received permit amendments allowing No. 2 fuel oil to be used in the cement kilns. Conditions 3.2.8 and 3.2.9 specifically limit fuel oil to No. 2. Therefore, any fuel oil received and used in the kiln or raw mills need to meet distillate oil specification, which must be certified by the supplier according to condition 6.2.10. Note that this is different from the “used oil,” which is authorized for use only as a “supplemental fuel” in the kiln. To clarify the intent of Condition 6.1.7(b)(ix), the condition has been changed to read: “Any period during which fuel oil other than distillate is fired at the facility.” Condition 6.1.7 (b) (x): Lafarge Comment: We are suggesting the following wording change to maintain consistency with portland cement NESHAP x. Any 180-minute average temperature…that exceeds the temperature established during the most recent dioxin/furan performance test. EPD Response: The condition has been revised to include the wording as follows: Any 180-minute average temperature at the inlet to the Kiln No. 1 Baghouse (D13) that exceeds the temperature limit determined by the most recent performance test for dioxins/furans (D/F) and which meets the requirements of 40 CFR 63 Subpart LLL. Condition 6.1.7 (c) (i.): Lafarge Comment: Add wording to match the proposed Method 9 option for compliance Opacity levels in compliance with an applicable standard, as determined using Method 9 according to condition 5.2.3(c), shall not be considered an excursion. EPD Response: EPD does not agree with Lafarge’s request to change Condition 5.2.3(c). Hence, Condition 6.1.7(c)(i) remains unchanged. Condition 6.1.7 (c) (iii): Lafarge Comment: This requirement is to report temperatures of certain non-NESHAP baghouses that exceed their design temperatures. This condition should be removed from the permit since it is associated with condition 5.2.5, which Lafarge is suggesting be removed. EPD Response: EPD does not agree with Lafarge’s request to remove temperature monitoring specified in condition 5.2.5. Hence, Condition 6.1.7(c)(iii) remains unchanged. Printed: December 19, 2003 Addendum Page 8 of 9
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Title V Application Review Lafarge Building Materials, Inc. – Atlanta Plant, TV-9548 Condition 6.2.1 (a) and (b): Lafarge Comment: Lafarge’s Atlanta plant is an area source under the portland cement NESHAP. To clarify non-applicability of the major source requirements, we request that EPD add the following words (bolded). …for equipment subject to the area source requirements of 40 CFR 63 Subpart LLL EPD Response: The requested change has been made. Condition 6.2.14: Lafarge Comment: This condition requires SO 2 emissions be calculated and recorded on a monthly basis. As discussed previously in this letter, the requirement for monitoring emissions on an hourly basis for comparison to an annual limit is overly burdensome for the facility. In addition, this record keeping requirement is only for a monthly frequency. Lafarge suggests changing this wording to be consistent with monthly calculations as follows (bolded): The Permittee shall…Condition 6.2.13 and 5.2.13 and the following procedure…(a) For each calendar month, the total SO 2 emissions shall be determined and recorded in accordance with Condition 5.2.13. EPD Response: EPD does not agree with Lafarge’s request to change monitoring of SO2 emissions as specified in condition 5.2.1(b). Hence, Condition 6.2.14 remains unchanged. 7.1 Operational Flexibility: Lafarge Comment: Lafarge requires flexibility to upgrade the LINKman system if newer technology becomes available during the life of the permit term. While this control system is explicitly noted in both Appendix XIX of the SIP and in the Draft Title V permit, the LINKman system could be replaced with an improved expert controller system in the future that would almost certainly be an improvement to LINKman’s process control technology. Lafarge requests the following condition be added, to consider this change as administrative in nature. Lafarge may replace the existing LINKman system with another expert controller system that offers similar or improved process control technology to LINKman. At least seven days prior to making a change from LINKman to a different expert system, Lafarge will provide EPD with written notice of when this change will occur. This notice shall also constitute an approved changed to Appendix XIX of the SIP. EPD Response: Due to the fact that the Linkman system is specified in the Atlanta Non-Attainment SIP, this change cannot be processed in the Title V permit. Appropriate procedures must be used to make changes in the Atlanta Non-Attainment SIP prior to the changes being made in the permit. Printed: December 19, 2003 Addendum Page 9 of 9