Thomma, Alison (DEQ)

From: Angie Wanger Sent: Wednesday, December 10, 2014 11:31 PM To: DEQ-ROP Cc: Keith C. Miller; Ross P. Olson Subject: N7362 - ROP Renewal Application Attachments: 1. ROP Application Form.pdf; 2. N7362_ROP_MARK-UP.doc; 3. Supplemental Information.pdf; 4. Plans Referenced in ROP (MAP OMM SSMP).pdf; Cover Letter.pdf

To Whom It May Concern,

Please find the attached ROP Renewal Application for Graymont Western Lime – Port Inland Plant (N7362) located in Gulliver, Michigan. This email includes the following attachments which comprise of the full renewal application:

ROP Application Form (“1. ROP Application Form.pdf”) ROP mark‐up (Word version) (“2. N7362_ROP_MARK‐UP.doc”) Supplemental Data (“3. Supplemental Information.pdf”) [this contains GHG PTE calculations‐ROP Application Form includes additional attachments] Plans referenced in ROP (“4. Plans Referenced in ROP (MAP OMM SSMP).pdf”) [note FDP is an Appendix in the ROP]

We are also providing the cover letter less attachments (“Cover Letter.pdf”) which we included with our hard‐copy submittal. It is provided with the electronic submittal to provide context/information about the ROP Renewal Application. A hard copy of the ROP Renewal Application (including original signatures) was sent via UPS and should arrive at the Marquette office on December 11, 2014.

Please do not hesitate to contact me (651‐275‐9900) or Ross Olson at Graymont (920‐437‐4054 x1475) with any questions regarding the ROP Renewal Application. We look forward to a response from MDEQ regarding administrative completeness within 15 days of December 11, 2014.

Thank you and regards, …………………………………………………………………………………………………. Angie Wanger, CM Managing Consultant

Trinity Consultants 12445 55th Street North, Suite A2 | Lake Elmo, MN 55042 Office: 651‐275‐9900 x4 | Fax: 651‐351‐3987 Email: [email protected] | LinkedIn: www.linkedin.com/in/angiewanger

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2 December 5, 2014

Ed Lancaster Michigan Department of Environmental Quality Upper Peninsula ‐ Air Quality Division 1504 West Washington Street Marquette, MI 49855

RE: Renewable Operating Permit Renewal Application for Permit No. MI‐ROP‐N7362‐2010a Graymont Western Lime Inc. – Port Inland Plant SRN Code: N7362

Dear Mr. Lancaster,

Please find the enclosed renewal application for the Graymont Western Lime Inc.’s (Graymont) lime manufacturing plant located in Gulliver, Michigan (herein Port Inland Plant). The Port Inland Plant currently operates under Renewable Operating Permit (ROP) No. MI‐ROP‐N7362‐2010 issued by the Michigan Department of Environment Quality (MDEQ) on July 1, 2010, revised on May 1, 2012 and expires on June 30, 2015. Pursuant to R336.1210(7) (Rule 210(7)) and General Condition 35 of the current ROP, an administratively complete renewal application must be submitted at least six (6) months prior to permit expiration, or not later than December 31, 2014.

A copy of the ROP renewal form is attached to this letter (Attachment 1). Pursuant to the MDEQ guidance, a redline/strikeout version of the current ROP with the proposed changes to the ROP is included in this letter as Attachment 2. Facility‐wide greenhouse gas (GHG) potential to emit (PTE) calculations are included in Attachment 3.

Three facility changes have occurred onsite since the previous application. However, all of these facility changes qualify for Permit to Install (PTI) exemptions. In addition, there are some regulatory updates that are incorporated into the ROP renewal form and permit redline. These facility changes and regulatory updates are further discussed in the following sections.

Graymont recently went through a facility name change from Western Lime Inc. to Graymont Western Lime Inc. While this change appears to have been incorporated into the current ROP, the administrative PTI is conservatively included in the renewal application for completeness.

FACILITY CHANGES As noted above, the following facility changes have occurred at the site since the last permit issuance, described by emissions unit/process:

Coal Pre‐Crusher (EUCOALPRECRUSHER) ‐ The coal pre‐crusher is an attachment to the existing coal chute. The coal chute connects at the top and bottom of the pre‐crusher via a sealed flange. There were no predicted emission increases from the coal pre‐crusher. Graymont conducted a permit applicability analysis for the installation of the coal pre‐crusher and determined that the coal pre‐crusher did not require a PTI pursuant to R336.1290 (Rule 290). Flexible Group “FGR290” is included in the permit markup to incorporate Rule 290 emission limit, recordkeeping and reporting requirements. December 5, 2014‐ Page 2

Kiln Run Silo 231 ‐ The Port Inland Plant added an additional kiln run silo, controlled by Baghouse 231 (described below). The installation of the additional kiln run silo did not require a PTI pursuant to R336.1284(k) (Rule 284(k)).

Baghouse 231 (EUBAGHOUSE 231) ‐ The Port Inland Plant added a fabric filter baghouse that is associated with the feed conveyor and the Kiln Run Silo 231. The installation of the baghouse did not require a PTI pursuant to Rule 284(k). The renewal application also includes the Michigan Air Emission Reporting System (MAERS) stack form associated with the fabric filter baghouse. Graymont proposes to add the new fabric filter baghouse (EUBAGHOUSE231) associated with Kiln Run Silo 231 to the existing Flexible Group “FGBAGHOUSES.”

Loadout bin 144 ‐ An additional product loadout bin was added to the three existing product loadout bins. The new product loadout bin and conveyor are controlled by the existing Baghouse 141 (EUBAGHOUSE141). There have been no operational or design changes to Baghouse 141 to accommodate the additional product loadout bin. Therefore, the addition of the product loadout bin did not require a PTI, pursuant to Rule 284(k).

REGULATORY CHANGES This section includes a summary of potentially applicable rules that either were promulgated during the term of the current ROP or may be applicable upon renewal of the Port Inland Plant’s ROP.

RICE MACT EPA recently finalized amendments to 40 CFR 63, Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants (NESHAP) for stationary reciprocating internal combustion engines (RICE). In order to determine applicable requirements, Graymont reviewed the applicability of this rule for the 68.5 horsepower diesel‐fired Yanmar Engine at the Port Inland Plant.

NESHAP Subpart ZZZZ applies to all existing, new, or reconstructed stationary RICE; therefore, the engine identified above is subject to this regulation. The requirements under NESHAP Subpart ZZZZ depend on unit and source characteristics such as existing versus new, emergency versus non‐emergency and area versus major source of HAP. The Port Inland Plant’s kiln auxiliary drive engine is classified as an existing, non‐emergency engine at a major source of HAP. Accordingly, Graymont expects the applicable RICE MACT provisions to be added to its ROP under a new Flexible Group “FGRICEMACT” and has included them in the ROP markup in Attachment 2. FGRICEMACT will apply to any RICE subject to NESHAP Subpart ZZZZ.

Table 1. RICE unit at Port Inland Plant subject to RICE MACT

Engine Information MACT Applicability Engine Rating Fuel Commenced Subject to MACT Engine Name (HP) Type Construction Date MACT? Classification Classification Non‐ Yanmar 68.5 Diesel Pre 6/12/2006 Yes Existing CI < 100 hp emergency CI

Yanmar Engine – RICE MACT Compliance Requirements Non‐emergency Compression Ignition Engine 1. Comply with the following maintenance limitations (§63.6602, Table 2c): December 5, 2014‐ Page 3

a. Change oil and filter every 1,000 hours of operation or annually, whichever comes first; b. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first, replace as necessary; c. Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and replace as necessary. 2. Operate and maintain engine according to manufacturer’s instructions (§63.6625(e)). 3. Record maintenance conducted on the engine to demonstrate required work practices have been met (§63.6655(e)). 4. No notifications are required (§63.6645(a)(5)).

NSPS Subpart Y 40 CFR 60 Subpart Y (NSPS Subpart Y) applies to coal preparation facilities and processing plants which process more than 181 megagrams (Mg) (200 tons) of coal per day, per 40 CFR 60.250(a).1 The kiln at the facility is designed to consume 8 tons per hour of solid fuel (with 90% of the grind passing a No. 200‐mesh screen). The conveyor system which will feed into the coal pre‐crusher is rated at 100 ton per hour; this capacity rating was included with regard to NSPS Subpart Y applicability pursuant to 40 CFR 60.250(a). Assuming 24 hours of operation per day, and that the coal pre‐crusher will not be physically modified to limit the coal processing capacity (i.e., the production rate of the coal pre‐crusher will be equal to that of the conveyor system), Graymont has a coal processing capacity of 2,400 tons of coal per day. Therefore, the coal pre‐crusher is subject to NSPS Subpart Y because it is capable of processing more than 200 tons per day of coal.

As a result, the following opacity standard requirement applies to the coal pre‐crusher:

The coal pre‐crusher shall not emit any gases which exhibit 10 percent opacity or greater pursuant to §60.254(b)(1).2 An initial performance test for opacity will be conducted pursuant to §60.255(b)(2). Method 9 testing shall follow the procedures outlined in §60.257(a)(1)‐(2). The initial performance test and subsequent Method 9 performance test results will be submitted as required in §60.258(c) and (d), respectively.

In addition to the initial performance test, Graymont is required to monitor visible emissions following the test methods and procedures as outlined in §60.255(f)(1)(i) through (iii) and §60.257(a), respectively.

Monitor visible emissions using daily, 15‐second Method 22 visible emissions tests and Method 9 observations within 45 operating days of when visible emissions are observed (if any) (§60.255(f)(1)(i)); Conduct monthly visible emissions observations, using corrective maintenance if needed (§60.255(f)(1)(ii)); Conduct performance test using Method 9 of appendix A‐4 at least once every five calendar years (§60. 255(f)(1)(iii)); Utilize the test methods and procedures associated with determining compliance with the opacity standard requirement for fugitive coal dust sources (§60.257(a)(2)). Utilize the test methods and procedures associated with visible emissions observations (§60.257(a)(3))

In addition, the Port Inland Plant will maintain the following records in a logbook, pursuant to §60.258(a)(1) through (3):

1 Pursuant to 40 CFR 60.251(f), coal processing and conveying equipment includes any machinery used to reduce the size of coal, or separate it from refuse, and the equipment used to convey or remove coal and refuse from the machinery. This includes, but is not limited to, breakers, crushers, screens, and conveyor belts. 2 The coal pre-crusher does not exhaust emissions through a mechanical vent. As a result, there are no grain loading emission limits associated with the unit. December 5, 2014‐ Page 4

The manufacturer’s recommended maintenance procedures and the date and time of any maintenance and inspection activities (§60.258(a)(1)); The date and time of any visible emissions observations and corrective actions taken to reduce visible emissions (§60.258(a)(2)); The amount and type of coal processed each calendar month (§60.258(a)(3));

The coal pre‐crusher is the only equipment subject to NSPS Subpart Y (i.e., no other coal equipment was physically modified due to the installation of the coal pre‐crusher). Graymont interprets the “coal preparation and processing plant” facility to consist of the coal pre‐crusher only. No chemical stabilizers, water, or dust suppressant is applied to the coal pre‐crusher as this is a sealed unit, nor are these measures recommended by the manufacturer’s specifications for the coal pre‐crusher. Therefore, Graymont has not included records related to §60.258(a)(4) and (5) in its logbook and has excluded these requirements in the ROP markup.

Graymont expects the applicable NSPS Subpart Y provisions to be added to its ROP under a new Flexible Group “FGNSPSY” and has included them in the ROP markup in Attachment 2.

Compliance Assurance Monitoring (CAM) As part of the renewal application development, Graymont reassessed CAM applicability pursuant to 40 CFR Part 64. The applicability criteria outlined in 40 CFR 64.2(a) specifies that CAM applies to any pollutant‐specific emission unit (PSEU) at a major source, ROP facility that:

Is subject to a federally enforceable emission limit or standard for a regulated air pollutant; Uses a control device to comply with that federally enforceable emission limit or standard; and Has a PTE for the applicable regulated pollutant, without taking into account the control device, in an amount (in tons per year) equal to or greater than 100 percent of the ROP major source threshold.

The lime kiln (EUKILN#1) and its associated cooler/baghouse are subject to a federally enforceable emission limit or standard in 40 CFR 63 Subpart AAAAA NESHAP for Lime Manufacturing Plants and are exempt from CAM requirements pursuant to 40 CFR 64.2(b)(1)(i). For the non‐kiln emission units (e.g., dust collectors), Graymont evaluated CAM applicability by assembling pre‐control device emissions of particulate matter for the material handling dust collectors. Specifically, Graymont utilized AP‐42 Sections 11.19 and 13.2, which is consistent with its approach in other states across the United States. The CAM applicability calculations are included in the renewal application. Based on the analysis, all material handling dust collectors at the Port Inland Plant have an uncontrolled PTE below the 100 tons per year threshold and are not subject to CAM requirements.

Tailoring Rule As GHG emissions have become subject to regulation under 40 CFR 70 since the last permit issuance, Graymont is providing GHG PTE calculations with this submittal to ensure that any obligations the company may have under the revised Prevention of Significant Deterioration (PSD) and Title V regulation are satisfied.3 The GHG PTE emission calculations are provided in Attachment 3.

3 The MDEQ expects permittees to submit facility-wide GHG PTE emissions in Title V renewal applications based on telephone conversation with Joel Asher, MDEQ, and Trinity Consultants on October 1, 2014.

Michigan Department of Environmental Quality - Air Quality Division

RENEWABLE OPERATING PERMIT RENEWAL APPLICATION FORM This information is required by Article II, Chapter 1, Part 55 (Air Pollution Control) of P.A. 451 of 1994, as amended, and the Federal Clean Air Act of 1990. Failure to obtain a permit required by Part 55 may result in penalties and/or imprisonment. Refer to instructions for additional information to complete the Renewable Operating Permit Renewal Application Form. GENERAL INSTRUCTIONS This application form should be submitted as part of an administratively complete application package for renewal of a Renewable Operating Permit (ROP). This application form consists of nine parts. Parts A – H must be completed for all applications and must also be completed for each section of a sectioned ROP. Answer all questions in all parts of the form unless directed otherwise. Detailed instructions for this application form can be found at www.michigan.gov/deq. PART A: GENERAL INFORMATION Enter information about the source, owner, contact person and the responsible official.

SOURCE INFORMATION SRN SIC Code NAICS Code Existing ROP Number Section Number (if applicable) N7362 3274 327410 MI-ROP-N7362-2010a Source Name Graymont Western Lime Inc. Street Address 181 W County Road 432 City State ZIP Code County Gulliver MI 49840 Schoolcraft Section/Town/Range (if address not available)

Source Description The plant started operations in May 2007. The plant receives limestone by conveyor belt from Carmeuse Port Inland Limestone plant located adjacent to the facility. The Port Inland Plant calcines the limestone into lime using a single rotary kiln with preheater and Niems style cooler. The kiln is fired on with a mixture of coal and petroleum coke. The preheater/cooler acts as a sulfur dioxide absorption device. Several fabric filters are used at the plant for particulate control and dust control.

The plant has the ability to produce up to 870 tons of lime per day but no more than 292,000 tons per year. The plant operates 24 hours per day, 7 days per week with the ability to operate 365 days per year. Check here if any of the above information is different than what appears in the existing ROP. Identify any changes on the marked-up copy of your existing ROP.

OWNER INFORMATION Owner Name Section Number (if applicable) Graymont Western US Inc. Mailing address ( check if same as source address) 3950 South 700 East, Suite 301

City State ZIP Code County Country Salt Lake City UT 84107 Salt Lake USA

Check here if any information in this ROP renewal application is confidential. Confidential information should be identified on an Additional Information (AI-001) Form.

1 of 17 EQP 6000 (2-2011)

SRN: N7362 Section Number (if applicable):

PART A: GENERAL INFORMATION (continued) At least one contact and responsible official must be identified. Additional contacts and responsible officials may be included if necessary.

CONTACT INFORMATION Contact 1 Name Title Ross Olson HSE Specialist, Graymont Green Bay/Port Inland Mailing address ( check if same as source address)

City State ZIP Code County Country

Phone number E-mail address 920-437-4054 x1475 [email protected]

Contact 2 Name (optional) Title Keith Miller Senior HSE Specialist, Great Lakes Region Mailing address ( check if same as source address) 800 Hill Avenue City State ZIP Code County Country Superior WI 54880 Douglas USA Phone number E-mail address 715-394-1719 [email protected]

RESPONSIBLE OFFICIAL INFORMATION Responsible Official 1 Name Title Paul E. Stoll Jr. Plant Manager Mailing address ( check if same as source address)

City State ZIP Code County Country

Phone number E-mail address 906-283-2900 x1486 [email protected]

Responsible Official 2 Name (optional) Title

Mailing address ( check if same as source address)

City State ZIP Code County Country

Phone number E-mail address

Check here if an AI-001 form is attached to provide more information for Part A. Enter AI-001 form ID:

2 of 17 EQP 6000 (2-2011)

SRN: N7362 Section Number (if applicable):

PART C: SOURCE REQUIREMENT INFORMATION Answer the questions below for specific requirements or programs to which the source may be subject.

C1. Actual emissions and associated data from all emission units with applicable requirements (including those identified in the existing ROP, Permits to Install and other equipment that have not yet been incorporated into the ROP) are required to be reported in MAERS. Are there any emissions and associated data that have not been reported in MAERS for the most recent Yes No emissions reporting year? If Yes, identify the emission unit(s) that was not reported in MAERS in the comments field below or on an AI-001 form. Applicable MAERS form(s) for unreported emission units must be included with this application. C2. Is this source subject to the federal regulations on ozone-depleting substances? Yes No (40 CFR Part 82) C3. Is this source subject to the federal Prevention of Accidental Releases regulations? Yes No (Section 112(r) of the Clean Air Act Amendments, 40 CFR Part 68) If Yes, a Risk Management Plan (RMP) and periodic updates must be submitted to the USEPA. Yes No Has an updated RMP been submitted to the USEPA?

C4. Does this stationary source have the potential to emit 100,000 tons per year or more of CO2e and Yes No 100 tons per year or more of greenhouse gases on a mass basis?

If Yes, provide emissions information on an AI-001 form. See instructions

C5. Are any emission units subject to the Clean Air Interstate Rule (CAIR)? If Yes, identify the specific Yes No emission unit(s) subject to CAIR in the comments area below or on an AI-001 form. Is a CAIR Permit Renewal Application included with this application? Yes No C6. Are any emission units subject to the federal Acid Rain Program? If Yes, identify the specific emission unit(s) subject to the Federal Acid Rain Program in the comments field or on an AI-001 Yes No form. Is an Acid Rain Permit Renewal Application included with this application? Yes No C7. Does the source have any plans such as a malfunction abatement plan, fugitive dust plan, operation/maintenance plan, or any other monitoring plan that is referenced in an existing ROP, Yes No Permit to Install requirement, or any other applicable requirement? If “Yes”, then a copy must be submitted as part of the ROP renewal application. Comments: C1: The new emission unit EUBAGHOUSE231 was not identified or reported in MAERS. C4: The emission units that emit GHG include: EUKILN#1 and the Kiln #1 Auxiliary Engine (currently not identified in the ROP).

Check here if an AI-001 form is attached to provide more information for Part C. Enter AI-001 form ID: There are three additional information forms attached: AI-PARTC1 AI-PARTC4 AI-PARTC7

4 of 17 EQP 6000 (2-2011) Michigan Department Of Environmental Quality - Air Quality Division

RENEWABLE OPERATING PERMIT APPLICATION AI-001: ADDITIONAL INFORMATION

This information is required by Article II, Chapter 1, part 55 (Air Pollution Control) of P.A. 451 of 1994, as amended, and the Federal Clean Air Act of 1990. Failure to obtain a permit required by Part 55 may result in penalties and/or imprisonment. Please type or print clearly. Refer to instructions for additional information to complete this form.

Form Type AI-001 SRN N7362

1. Operator’s Additional Information ID AI PART C1 MAERS

Additional Information 2. Is This Information Confidential? Yes No 3. Narrative Question C1: The MAERS forms attached include the emissions for the existing units. All existing emission units were reported last year. The emission calculations associated with EUBAGHOUSE231 are also attached.

The emissions from EUBAGHOUSE231 are less than 15tpy, and less than 10% of significant level (or 1.5 tpy). As a result, Graymont has not included the MAERS emissions form.

Page of

EQP 5774 (1-2001)

Michigan Air Emissions Reporting System (MAERS) Source Summary Report - AQD Source ID (SRN) N7362 Reporting Year : 2013 S-101 SOURCE INFORMATION Source Name GRAYMONT WESTERN LIME INC NAICS Code 327410 Portable No

Address 181 W COUNTY ROAD 432, GULLIVER LIME PLANT

County SCHOOLCRAFT City GULLIVER Zip Code 49840 District Upper Peninsula

Latitude Longitude +RUL]RQWDO&ROOHFWLRQ Source Map Scale +RUL]RQWDO$FFXUDF\ +RUL]RQWDO5HIHUHQFH 0HWKRG 0HDVXUH 'DWXP

45.97425 -85.87569 001 25 Meter(s) 03

Reference Point Code Principal Product Number of Employees (PSOR\HU)HGHUDO,' 1XPEHU

102 LIME 25 390700260

OWNER INFORMATION Owner Name GRAYMONT WESTERN LIME INC

Mailing Address PO BOX 57 Address Continued 206 N 6TH AVENUE

City WEST BEND State/Province WI Country USA Zip/Postal Code 53095

S-102 CONTACT INFORMATION Emission Inventory Contact Information (Primary) Contact Name Keith Miller Mailing Address 800 Hill Avenue

Contact Title Senior HSE Specialist, Great Lakes Region Address Continued

City Superior

E-Mail Address [email protected] State/Province WI

Telephone Number (715)3941719 Country USA

Fax Number (262)3342874 Zip or Postal Code 54880

Emission Inventory Contact Information (Secondary) Contact Name John Maitland Mailing Address 194 Match Factory Place

Contact Title E. US and Great Lakes EHS Manager Address Continued City Bellefonte

E-Mail Address [email protected] State/Province PA

Telephone Number (814)3532106 Country USA

Fax Number Zip or Postal Code 16823

Fee Invoice Contact Information

Contact Name Keith Miller Mailing Address 800 Hill Avenue

Contact Title Senior HSE Specialist, Great Lakes Region Address Continued

City Superior

E-Mail Address [email protected] State/Province WI

Telephone Number (715)3941719 Country USA

Fax Number (262)3342874 Zip or Postal Code 54880

P-101 PREPARER'S INFORMATION Preparer's First Name Angela Preparer's Last Name Wanger Preparer's Title Senior Consultant

Mailing Address 12445 55th St. N. Address Continued Ste. A2

City Lake Elmo State/Province MN Country USA Zip/Postal Code 55042

Email Address [email protected] Telephone Number (651)2759900 Fax Number

SV-101 STACK INFORMATION Stack ID SV-10 AQD Stack ID SV0005 Dismantle Date

Stack Description Stack for EU-PRODUCT LOADING 2 (Baghouse 162)

Actual Stk Height Above 90 FT Inside Stack Diameter 7.5 IN Stack Orientation Vertical Ground

Exit Gas Temperature 70 F Actual Exit Gas Flow Rate 1000 FT3/MIN Exit Velocity of Gas 54.3249 FT/SEC

Latitude 45.973408 Longitude -85.8753 Horizontal Collection Method 001

Source Map Scale Horizontal Accuracy 25 Meter(s) Horizontal Reference Datum 03

Reference Point Code 106 Bypass Stack Only N If Yes, Main Stack ID

Stack ID SV-11 AQD Stack ID SV0006 Dismantle Date Stack Description Stack for EU-DUST LOADING (baghouse 189)

Actual Stk Height Above 44 FT Inside Stack Diameter 7.5 IN Stack Orientation Vertical Ground

Exit Gas Temperature 70 F Actual Exit Gas Flow Rate 1000 FT3/MIN Exit Velocity of Gas 54.3249 FT/SEC

Latitude 45.97453 Longitude -85.87578 Horizontal Collection Method 001

Source Map Scale Horizontal Accuracy 25 Meter(s) Horizontal Reference Datum 03

Reference Point Code 106 Bypass Stack Only N If Yes, Main Stack ID

Stack ID SV-2 AQD Stack ID SV0007 Dismantle Date

Stack Description Stack for EU-KILN1 (baghouse 185)

Actual Stk Height Above 120 FT Inside Stack Diameter 82 IN Stack Orientation Vertical Ground

Exit Gas Temperature 350 F Actual Exit Gas Flow Rate 120000 FT3/MIN Exit Velocity of Gas 54.5349 FT/SEC

Latitude 45.974422 Longitude -85.8758 Horizontal Collection Method 001

Source Map Scale Horizontal Accuracy 25 Meter(s) Horizontal Reference Datum 03

Reference Point Code 106 Bypass Stack Only N If Yes, Main Stack ID

Stack ID SV-3 AQD Stack ID SV0008 Dismantle Date

Stack Description Stack for EU-DUST HANDLING (baghouse 188)

Actual Stk Height Above 68 FT Inside Stack Diameter 7.5 IN Stack Orientation Vertical Ground

Exit Gas Temperature 70 F Actual Exit Gas Flow Rate 1000 FT3/MIN Exit Velocity of Gas 54.3249 FT/SEC

Latitude 45.974422 Longitude -85.8758 Horizontal Collection Method 001

Source Map Scale Horizontal Accuracy 25 Meter(s) Horizontal Reference Datum 03

Reference Point Code 106 Bypass Stack Only N If Yes, Main Stack ID

Stack ID SV-4 AQD Stack ID SV0009 Dismantle Date

Stack Description Stack for EU-BAGHOUSE 133

Actual Stk Height Above 106 FT Inside Stack Diameter 17 IN Stack Orientation Vertical Ground

Exit Gas Temperature 70 F Actual Exit Gas Flow Rate 4900 FT3/MIN Exit Velocity of Gas 51.8107 FT/SEC

Latitude 45.97333 Longitude -85.87561 Horizontal Collection Method 001 Source Map Scale Horizontal Accuracy 25 Meter(s) Horizontal Reference Datum 03

Reference Point Code 106 Bypass Stack Only N If Yes, Main Stack ID

Stack ID SV-5 AQD Stack ID SV0010 Dismantle Date

Stack Description Stack for EU-BAGHOUSE 132

Actual Stk Height Above 66 FT Inside Stack Diameter 14.5 IN Stack Orientation Vertical Ground

Exit Gas Temperature 70 F Actual Exit Gas Flow Rate 3600 FT3/MIN Exit Velocity of Gas 52.3224 FT/SEC

Latitude 45.97341 Longitude -85.87543 Horizontal Collection Method 001

Source Map Scale Horizontal Accuracy 25 Meter(s) Horizontal Reference Datum 03

Reference Point Code 106 Bypass Stack Only N If Yes, Main Stack ID

Stack ID SV-6 AQD Stack ID SV0011 Dismantle Date

Stack Description Stack for EU-BAGHOUSE 131

Actual Stk Height Above 66 FT Inside Stack Diameter 20 IN Stack Orientation Vertical Ground

Exit Gas Temperature 100 F Actual Exit Gas Flow Rate 7000 FT3/MIN Exit Velocity of Gas 53.4761 FT/SEC

Latitude 45.97341 Longitude -85.87569 Horizontal Collection Method 001

Source Map Scale Horizontal Accuracy 25 Meter(s) Horizontal Reference Datum 03

Reference Point Code 106 Bypass Stack Only N If Yes, Main Stack ID

Stack ID SV-7 AQD Stack ID SV0012 Dismantle Date

Stack Description Stack for EU-BAGHOUSE 141

Actual Stk Height Above 88.5 FT Inside Stack Diameter 24 IN Stack Orientation Vertical Ground

Exit Gas Temperature 70 F Actual Exit Gas Flow Rate 9950 FT3/MIN Exit Velocity of Gas 52.7864 FT/SEC

Latitude 45.973427 Longitude -85.87543 Horizontal Collection Method 001

Source Map Scale Horizontal Accuracy 25 Meter(s) Horizontal Reference Datum 03

Reference Point Code 106 Bypass Stack Only N If Yes, Main Stack ID

Stack ID SV-8 AQD Stack ID SV0013 Dismantle Date Stack Description Stack for EU-BAGHOUSE 163

Actual Stk Height Above 82 FT Inside Stack Diameter 14 IN Stack Orientation Vertical Ground

Exit Gas Temperature 70 F Actual Exit Gas Flow Rate 3750 FT3/MIN Exit Velocity of Gas 58.4651 FT/SEC

Latitude 45.97339 Longitude -85.87518 Horizontal Collection Method 001

Source Map Scale Horizontal Accuracy 25 Meter(s) Horizontal Reference Datum 03

Reference Point Code 106 Bypass Stack Only N If Yes, Main Stack ID

Stack ID SV-9 AQD Stack ID SV0014 Dismantle Date

Stack Description Stack for EU-PRODUCT LOADING (Baghouse 161)

Actual Stk Height Above 90 FT Inside Stack Diameter 7.5 IN Stack Orientation Vertical Ground

Exit Gas Temperature 70 F Actual Exit Gas Flow Rate 1000 FT3/MIN Exit Velocity of Gas 54.3249 FT/SEC

Latitude 45.973354 Longitude -85.8753 Horizontal Collection Method 001

Source Map Scale Horizontal Accuracy 25 Meter(s) Horizontal Reference Datum 03

Reference Point Code 106 Bypass Stack Only N If Yes, Main Stack ID EU-101 EMISSION UNIT INFORMATION AQD Emission Unit ID Emission Unit ID NAICS Code Remove from MAERS Installation Date Dismantle Date

EU0001 EUKILN#1 327410 N 05/14/2007

Preparer's Description EUKILN#1 - Lime Kiln controlled with BAGHOUSE 185; Permit to Install #26-04. Kiln heat input rating 186.3 million BTU per hour, based on 6.9 tons of coal per hour and 13,500 BTU per pound coal. Design Capacity Design Capacity Design Capacity Maximum Namplate Rule 201 Grandfathered? Rule 201 Exempted? Unit Numerator Unit Denominator Capacity

186.3 MMBTU HR N N

If Rule 201 exempt, Rule If Rule 201 exempt, is Permit? If Permitted, Permit Is this Emission Unit required to report emissions to Number throughput below Number MAERS for this reporting year? reporting Thresholds?

Y MI-ROP-N7362-2010 Y

CONTROL DEVICE(S)

Control Device Code BAGHOUSE

EMISSION UNIT STACK(S)

Stack ID SV-2 A-101 ACTIVITY INFORMATION EU/RG ID EUKILN#1 Source Classification Code (SCC) Preparer's SCC Comment 3-05-016-21 Calcining - Coal and Coke fired kiln

SEASONAL MATERIAL USAGE SCHEDULE IF THROUGHPUT IS >0, THEN SEASONAL PERCENTAGES MUST TOTAL 100% OPERATING SCHEDULE Winter (Dec,Jan,Feb) Spring (Mar-May) Summer (Jun-Aug) Fall (Sep-Nov) Hours per Day Days per Week Days per Year Hours/Year 25 25 25 25 24 7 358 8592

MATERIAL INFORMATION

Material Code LIME Material Throughput 209110 Unit Code TON (ENGLISH - 2000 U.S. LBS)

Preparer's material description Reporting in tons of lime produced

VOC Content Density BTUs (fuel) Sulfur Content (fuel) Ash Content (fuel)

E-101 EMISSION INFORMATION EU/RG ID EUKILN#1 SCC Code 3-05-016-21 Pollutant Code Annual Unit code Emission Basis List Emission Exponent Emission Factor Control Comment Emissions Factor Unit Code Efficiency %

CO 481103 CEM

NOX 468391 CEM

PM10,FLTRBLE 25093.2 Stack Test 0.12 0

SO2 40080 CEM

HCL 41612.9 Stack Test 0.199 0

EU-101 EMISSION UNIT INFORMATION AQD Emission Unit ID Emission Unit ID NAICS Code Remove from MAERS Installation Date Dismantle Date

EU0002 EU-Baghouse131 327410 N 05/14/2007

Preparer's Description BAGHOUSE 131 - Lime product from the kiln product cooler is discharged via conveyor to the kiln discharge elevator or to the kiln run silo conveyor. Controlled by fabric filter dust collector BAGHOUSE 131. Design Capacity Design Capacity Design Capacity Maximum Namplate Rule 201 Grandfathered? Rule 201 Exempted? Unit Numerator Unit Denominator Capacity

N N If Rule 201 exempt, Rule If Rule 201 exempt, is Permit? If Permitted, Permit Is this Emission Unit required to report emissions to Number throughput below Number MAERS for this reporting year? reporting Thresholds?

Y MI-ROP-N7362-2010 Y

CONTROL DEVICE(S)

Control Device Code FLTR,FABRIC

EMISSION UNIT STACK(S)

Stack ID SV-6

A-101 ACTIVITY INFORMATION EU/RG ID EU-Baghouse131 Source Classification Code (SCC) Preparer's SCC Comment 3-05-016-15 Lime Transfer - Baghouse 131

MATERIAL INFORMATION

Material Code LIME Material Throughput 209110 Unit Code TON (ENGLISH - 2000 U.S. LBS)

Preparer's material description LIME - Baghouse 131, tons per year

VOC Content Density BTUs (fuel) Sulfur Content (fuel) Ash Content (fuel)

E-101 EMISSION INFORMATION EU/RG ID EU-Baghouse131 SCC Code 3-05-016-15 Pollutant Code Annual Unit code Emission Basis List Emission Exponent Emission Factor Control Comment Emissions Factor Unit Code Efficiency %

PM10,FLTRBLE 460 Other 2.2 0 99.9

EU-101 EMISSION UNIT INFORMATION AQD Emission Unit ID Emission Unit ID NAICS Code Remove from MAERS Installation Date Dismantle Date EU0003 EU-Baghouse132 327410 N 05/14/2007

Preparer's Description BAGHOUSE 132 - Lime product is conveyed to the crusher infeed elevator, crushed to size and discharged from the crusher to the product silo elevator. Controlled by fabric filter dust collector BAGHOUSE 132. Design Capacity Design Capacity Design Capacity Maximum Namplate Rule 201 Grandfathered? Rule 201 Exempted? Unit Numerator Unit Denominator Capacity

N N

Y MI-ROP-N7362-2010 Y

CONTROL DEVICE(S)

Control Device Code FLTR,FABRIC

EMISSION UNIT STACK(S)

Stack ID SV-5 A-101 ACTIVITY INFORMATION EU/RG ID EU-Baghouse132 Source Classification Code (SCC) Preparer's SCC Comment 3-05-016-15 Lime Transfer - Baghouse 132

MATERIAL INFORMATION

Material Code LIME Material Throughput 209110 Unit Code TON (ENGLISH - 2000 U.S. LBS)

Preparer's material description LIME - Baghouse 132, tons per year

VOC Content Density BTUs (fuel) Sulfur Content (fuel) Ash Content (fuel)

E-101 EMISSION INFORMATION EU/RG ID EU-Baghouse132 SCC Code 3-05-016-15 Pollutant Code Annual Unit code Emission Basis List Emission Exponent Emission Factor Control Comment Emissions Factor Unit Code Efficiency %

PM10,FLTRBLE 460 Other 2.2 0 99.9

EU-101 EMISSION UNIT INFORMATION AQD Emission Unit ID Emission Unit ID NAICS Code Remove from MAERS Installation Date Dismantle Date

EU0004 EU-Baghouse133 327410 N 05/14/2007

Preparer's Description BAGHOUSE 133 - Lime product from the kiln discharge elevator and/or the lime product sizing operation are conveyed to the kiln run silo. Controlled by fabric filter dust collector BAGHOUSE 133. Design Capacity Design Capacity Design Capacity Maximum Namplate Rule 201 Grandfathered? Rule 201 Exempted? Unit Numerator Unit Denominator Capacity

N N

Y MI-ROP-N7362-2010 Y CONTROL DEVICE(S)

Control Device Code FLTR,FABRIC

EMISSION UNIT STACK(S)

Stack ID SV-4

A-101 ACTIVITY INFORMATION EU/RG ID EU-Baghouse133 Source Classification Code (SCC) Preparer's SCC Comment 3-05-016-15 Lime Transfer - Baghouse 133

MATERIAL INFORMATION

Material Code LIME Material Throughput 209110 Unit Code TON (ENGLISH - 2000 U.S. LBS)

Preparer's material description LIME - Baghouse 133, tons per year

VOC Content Density BTUs (fuel) Sulfur Content (fuel) Ash Content (fuel)

E-101 EMISSION INFORMATION EU/RG ID EU-Baghouse133 SCC Code 3-05-016-15 Pollutant Code Annual Unit code Emission Basis List Emission Exponent Emission Factor Control Comment Emissions Factor Unit Code Efficiency %

PM10,FLTRBLE 460 Other 2.2 0 99.9

EU-101 EMISSION UNIT INFORMATION AQD Emission Unit ID Emission Unit ID NAICS Code Remove from MAERS Installation Date Dismantle Date

EU0016 EU-Baghouse141 327410 N 05/14/2007

Preparer's Description BAGHOUSE 141 - Lime transfer, screening, and numerous conveyors are controlled by fabric filter dust collector BAGHOUSE 141.

Design Capacity Design Capacity Design Capacity Maximum Namplate Rule 201 Grandfathered? Rule 201 Exempted? Unit Numerator Unit Denominator Capacity N N

Y MI-ROP-N7362-2010 Y

CONTROL DEVICE(S)

Control Device Code FLTR,FABRIC

EMISSION UNIT STACK(S)

Stack ID SV-7

A-101 ACTIVITY INFORMATION EU/RG ID EU-Baghouse141 Source Classification Code (SCC) Preparer's SCC Comment 3-05-016-15 Lime Transfer - Baghouse 141

MATERIAL INFORMATION

Material Code LIME Material Throughput 209110 Unit Code TON (ENGLISH - 2000 U.S. LBS)

Preparer's material description Lime Transfer, Baghouse 141, tons per year

VOC Content Density BTUs (fuel) Sulfur Content (fuel) Ash Content (fuel)

E-101 EMISSION INFORMATION EU/RG ID EU-Baghouse141 SCC Code 3-05-016-15 Pollutant Code Annual Unit code Emission Basis List Emission Exponent Emission Factor Control Comment Emissions Factor Unit Code Efficiency %

PM10,FLTRBLE 460 Other 2.2 0 99.9

EU-101 EMISSION UNIT INFORMATION AQD Emission Unit ID Emission Unit ID NAICS Code Remove from MAERS Installation Date Dismantle Date

EU0017 EU-Baghouse163 327410 N 05/14/2007

Preparer's Description BAGHOUSE 163 - The product silo feeders and the railcar loading spout are controlled by fabric filter dust collector BAGHOUSE 163.

Design Capacity Design Capacity Design Capacity Maximum Namplate Rule 201 Grandfathered? Rule 201 Exempted? Unit Numerator Unit Denominator Capacity

N N

Y MI-ROP-N7362-2010 Y

CONTROL DEVICE(S)

Control Device Code FLTR,FABRIC

EMISSION UNIT STACK(S)

Stack ID SV-8 A-101 ACTIVITY INFORMATION EU/RG ID EU-Baghouse163 Source Classification Code (SCC) Preparer's SCC Comment 3-05-016-26 Product Loading - Enclosed Truck (Railcars are loaded from this spout).

MATERIAL INFORMATION

Material Code LIME Material Throughput 35171 Unit Code TON (ENGLISH - 2000 U.S. LBS)

Preparer's material description LIME, Product Loading, Baghouse 163, tpy

VOC Content Density BTUs (fuel) Sulfur Content (fuel) Ash Content (fuel)

E-101 EMISSION INFORMATION EU/RG ID EU-Baghouse163 SCC Code 3-05-016-26 Pollutant Code Annual Unit code Emission Basis List Emission Exponent Emission Factor Control Comment Emissions Factor Unit Code Efficiency %

PM10,FLTRBLE 21.5 Other 0.61 99.9

EU-101 EMISSION UNIT INFORMATION AQD Emission Unit ID Emission Unit ID NAICS Code Remove from MAERS Installation Date Dismantle Date

EU0018 EU-CoalHandling 327410 N 05/14/2007

Preparer's Description COAL HANDLING - Fugitive emissions from coal unloading, reloading, conveyors, and the storage pile

Design Capacity Design Capacity Design Capacity Maximum Namplate Rule 201 Grandfathered? Rule 201 Exempted? Unit Numerator Unit Denominator Capacity

N N

Y MI-ROP-N7362-2010 Y CONTROL DEVICE(S)

Control Device Code ENCLOSURE

A-101 ACTIVITY INFORMATION EU/RG ID EU-CoalHandling Source Classification Code (SCC) Preparer's SCC Comment 3-05-010-41 Coal Handling

MATERIAL INFORMATION

Material Code COAL Material Throughput 48400 Unit Code TON (ENGLISH - 2000 U.S. LBS)

Preparer's material description COAL, coal handling, tons per year

VOC Content Density BTUs (fuel) Sulfur Content (fuel) Ash Content (fuel)

11346 BRITISH 0.45 weight percent 7.35 weight percent THERMAL UNITS PER POUND

E-101 EMISSION INFORMATION EU/RG ID EU-CoalHandling SCC Code 3-05-010-41 Pollutant Code Annual Unit code Emission Basis List Emission Exponent Emission Factor Control Comment Emissions Factor Unit Code Efficiency %

PM10,FLTRBLE 7.7 POUNDS Other 8 -4 TON (ENGLISH - 80 2000 U.S. LBS)

EU-101 EMISSION UNIT INFORMATION AQD Emission Unit ID Emission Unit ID NAICS Code Remove from MAERS Installation Date Dismantle Date

EU0020 EU-CoalSilo 327410 N 05/14/2007

Preparer's Description COAL AND COKE SILOS - Coal and coke silos which are controlled by a bin vent dust collector and exhausted within a building (#191). Building has zero visible emission limit. Design Capacity Design Capacity Design Capacity Maximum Namplate Rule 201 Grandfathered? Rule 201 Exempted? Unit Numerator Unit Denominator Capacity

Y MI-ROP-N7362-2010 Y

CONTROL DEVICE(S)

Control Device Code Control Device Code FLTR,FABRIC ENCLOSURE

A-101 ACTIVITY INFORMATION EU/RG ID EU-CoalSilo Source Classification Code (SCC) Preparer's SCC Comment 3-05-010-09 Raw Coal Storage, coal silo controlled with bin vent dust collector

MATERIAL INFORMATION

Material Code COAL Material Throughput 48400 Unit Code TON (ENGLISH - 2000 U.S. LBS)

Preparer's material description COAL, storage in coal silo, tons per year

VOC Content Density BTUs (fuel) Sulfur Content (fuel) Ash Content (fuel)

11346 BRITISH 0.45 weight percent 7.35 weight percent THERMAL UNITS PER POUND

E-101 EMISSION INFORMATION EU/RG ID EU-CoalSilo SCC Code 3-05-010-09 Pollutant Code Annual Unit code Emission Basis List Emission Exponent Emission Factor Control Comment Emissions Factor Unit Code Efficiency %

PM10,FLTRBLE 0 Other 0 0 99.9

EU-101 EMISSION UNIT INFORMATION AQD Emission Unit ID Emission Unit ID NAICS Code Remove from MAERS Installation Date Dismantle Date

EU0021 EU-DustHandling 327410 N 05/17/2007 Preparer's Description BAGHOUSE 188 - Lime dust from the kiln baghouse is conveyed to the dust silo. The conveyors and dust silo are controlled by fabric filter dust collector BAGHOUSE 188. Design Capacity Design Capacity Design Capacity Maximum Namplate Rule 201 Grandfathered? Rule 201 Exempted? Unit Numerator Unit Denominator Capacity

N N

Y MI-ROP-N7362-2010 Y

CONTROL DEVICE(S)

Control Device Code FLTR,FABRIC

EMISSION UNIT STACK(S)

Stack ID SV-3 A-101 ACTIVITY INFORMATION EU/RG ID EU-DustHandling Source Classification Code (SCC) Preparer's SCC Comment 3-05-016-15 Lime Transfer (dust handling)

MATERIAL INFORMATION

Material Code LIME Material Throughput 6140 Unit Code TON (ENGLISH - 2000 U.S. LBS)

Preparer's material description Lime Kiln Dust, tons per year

VOC Content Density BTUs (fuel) Sulfur Content (fuel) Ash Content (fuel)

E-101 EMISSION INFORMATION EU/RG ID EU-DustHandling SCC Code 3-05-016-15 Pollutant Code Annual Unit code Emission Basis List Emission Exponent Emission Factor Control Comment Emissions Factor Unit Code Efficiency %

PM10,FLTRBLE 13.5 Other 2.2 0 99.9

EU-101 EMISSION UNIT INFORMATION AQD Emission Unit ID Emission Unit ID NAICS Code Remove from MAERS Installation Date Dismantle Date

EU0022 EU-DustLoading 327410 N 05/14/2007

Preparer's Description BAGHOUSE 189 - Truck loading of lime kiln dust is controlled by fabric filter dust collector BAGHOUSE 189.

Design Capacity Design Capacity Design Capacity Maximum Namplate Rule 201 Grandfathered? Rule 201 Exempted? Unit Numerator Unit Denominator Capacity

N N

Y MI-ROP-N7362-2010 Y CONTROL DEVICE(S)

Control Device Code FLTR,FABRIC

EMISSION UNIT STACK(S)

Stack ID SV-11 A-101 ACTIVITY INFORMATION EU/RG ID EU-DustLoading Source Classification Code (SCC) Preparer's SCC Comment 3-05-016-27 Lime Kiln Dust Loading - Open Truck

MATERIAL INFORMATION

Material Code LIME Material Throughput 3363 Unit Code TON (ENGLISH - 2000 U.S. LBS)

Preparer's material description Lime Kiln Dust Loading - Open Truck, tpy

VOC Content Density BTUs (fuel) Sulfur Content (fuel) Ash Content (fuel)

E-101 EMISSION INFORMATION EU/RG ID EU-DustLoading SCC Code 3-05-016-27 Pollutant Code Annual Unit code Emission Basis List Emission Exponent Emission Factor Control Comment Emissions Factor Unit Code Efficiency %

PM10,FLTRBLE 5 Other 1.5 0 99.9

A-101 ACTIVITY INFORMATION EU/RG ID EU-DustLoading Source Classification Code (SCC) Preparer's SCC Comment 3-05-016-26 Lime Kiln Dust Loading - Enclosed Truck

MATERIAL INFORMATION

Material Code LIME Material Throughput 2777 Unit Code TON (ENGLISH - 2000 U.S. LBS)

Preparer's material description Lime Kiln Dust Loading - Enclosed Truck, tpy

VOC Content Density BTUs (fuel) Sulfur Content (fuel) Ash Content (fuel) E-101 EMISSION INFORMATION EU/RG ID EU-DustLoading SCC Code 3-05-016-26 Pollutant Code Annual Unit code Emission Basis List Emission Exponent Emission Factor Control Comment Emissions Factor Unit Code Efficiency %

PM10,FLTRBLE 1.7 Other 0.61 0 99.9

EU-101 EMISSION UNIT INFORMATION AQD Emission Unit ID Emission Unit ID NAICS Code Remove from MAERS Installation Date Dismantle Date

EU0023 EU-DustLoadWet 327410 N 05/14/2007

Preparer's Description LIME DUST WET LOADOUT - Lime dust is conveyed to a pug mill and fresh water is mixed to produce a wet mixture that is then loaded into trucks. REPORTED ZERO MATERIAL HANDLED DURING 2013. Design Capacity Design Capacity Design Capacity Maximum Namplate Rule 201 Grandfathered? Rule 201 Exempted? Unit Numerator Unit Denominator Capacity

N N

Y MI-ROP-N7362-2010 Y

CONTROL DEVICE(S)

Control Device Code SUPPRESSION,WET A-101 ACTIVITY INFORMATION EU/RG ID EU-DustLoadWet Source Classification Code (SCC) Preparer's SCC Comment 3-05-016-27 LKD Loading (WET) - Open Truck

MATERIAL INFORMATION

Material Code LIME Material Throughput 0 Unit Code TON (ENGLISH - 2000 U.S. LBS)

Preparer's material description LKD Loading (WET) - Open Truck, tons per year

VOC Content Density BTUs (fuel) Sulfur Content (fuel) Ash Content (fuel)

E-101 EMISSION INFORMATION EU/RG ID EU-DustLoadWet SCC Code 3-05-016-27 Pollutant Code Annual Unit code Emission Basis List Emission Exponent Emission Factor Control Comment Emissions Factor Unit Code Efficiency %

PM10,FLTRBLE 0 Other 0 0 95

EU-101 EMISSION UNIT INFORMATION AQD Emission Unit ID Emission Unit ID NAICS Code Remove from MAERS Installation Date Dismantle Date

EU0024 EU-Hauling 327410 N 05/17/2007

Preparer's Description HAULING - Fugitive emissions from the vehicle traffic in the plant area. Wet suppression used to control fugitive dust.

Design Capacity Design Capacity Design Capacity Maximum Namplate Rule 201 Grandfathered? Rule 201 Exempted? Unit Numerator Unit Denominator Capacity

N N

Y MI-ROP-N7362-2010 Y CONTROL DEVICE(S)

Control Device Code SUPPRESSION,WET

A-101 ACTIVITY INFORMATION EU/RG ID EU-Hauling Source Classification Code (SCC) Preparer's SCC Comment 3-05-020-11 Hauling (fugitive emissions from vehicle traffic in plant area)

MATERIAL INFORMATION

Material Code DEVICE Material Throughput 6517 Unit Code MILES

Preparer's material description Vehicle Miles Traveled

VOC Content Density BTUs (fuel) Sulfur Content (fuel) Ash Content (fuel)

E-101 EMISSION INFORMATION EU/RG ID EU-Hauling SCC Code 3-05-020-11 Pollutant Code Annual Unit code Emission Basis List Emission Exponent Emission Factor Control Comment Emissions Factor Unit Code Efficiency %

PM10,FLTRBLE 670.6 POUNDS Other 2.058 0 MILES 95

EU-101 EMISSION UNIT INFORMATION AQD Emission Unit ID Emission Unit ID NAICS Code Remove from MAERS Installation Date Dismantle Date

EU0025 EU-ProductLoad1 327410 N 05/14/2007

Preparer's Description BAGHOUSE 161 - Dry lime is loaded into trucks and is controlled by fabric filter dust collector BAGHOUSE 161.

Design Capacity Design Capacity Design Capacity Maximum Namplate Rule 201 Grandfathered? Rule 201 Exempted? Unit Numerator Unit Denominator Capacity

Y MI-ROP-N7362-2010 Y

CONTROL DEVICE(S)

Control Device Code FLTR,FABRIC

EMISSION UNIT STACK(S)

Stack ID SV-9

EU-101 EMISSION UNIT INFORMATION AQD Emission Unit ID Emission Unit ID NAICS Code Remove from MAERS Installation Date Dismantle Date

EU0026 EU-ProductLoad2 327410 N 05/14/2007

Preparer's Description BAGHOUSE 162 - Dry lime is loaded into trucks and is controlled with fabric filter dust collector BAGHOUSE 162.

Design Capacity Design Capacity Design Capacity Maximum Namplate Rule 201 Grandfathered? Rule 201 Exempted? Unit Numerator Unit Denominator Capacity

N N

Y MI-ROP-N7362-2010 Y

CONTROL DEVICE(S)

Control Device Code FLTR,FABRIC

EMISSION UNIT STACK(S)

Stack ID SV-10

EU-101 EMISSION UNIT INFORMATION AQD Emission Unit ID Emission Unit ID NAICS Code Remove from MAERS Installation Date Dismantle Date

EU0027 EU-StoneHandling 327410 N 05/14/2007 Preparer's Description STONE HANDLING - Raw limestone is stockpiled and conveyed to the kiln preheater. These emissions are fugitive. Wet suppression and enclosure used for fugitive dust control. Design Capacity Design Capacity Design Capacity Maximum Namplate Rule 201 Grandfathered? Rule 201 Exempted? Unit Numerator Unit Denominator Capacity

N N

Y MI-ROP-N7362-2010 Y

CONTROL DEVICE(S)

Control Device Code Control Device Code ENCLOSURE SUPPRESSION,WET

A-101 ACTIVITY INFORMATION EU/RG ID EU-StoneHandling Source Classification Code (SCC) Preparer's SCC Comment 3-05-016-07 Raw material transferring and conveying

MATERIAL INFORMATION

Material Code LIMESTONE Material Throughput 418220 Unit Code TON (ENGLISH - 2000 U.S. LBS)

Preparer's material description Raw material transferring & conveying, tpy

VOC Content Density BTUs (fuel) Sulfur Content (fuel) Ash Content (fuel)

E-101 EMISSION INFORMATION EU/RG ID EU-StoneHandling SCC Code 3-05-016-07 Pollutant Code Annual Unit code Emission Basis List Emission Exponent Emission Factor Control Comment Emissions Factor Unit Code Efficiency %

PM10,FLTRBLE 15055.9 POUNDS MAERS EF 1.8 -1 TON (ENGLISH - 80 2000 U.S. LBS) EU-101 EMISSION UNIT INFORMATION AQD Emission Unit ID Emission Unit ID NAICS Code Remove from MAERS Installation Date Dismantle Date

RG0028 RGProductLoadout N

Preparer's Description RGProductLoadout - Product Loadout BAGHOUSES 161 and 162 - both baghouses have the same permit limits.

Design Capacity Design Capacity Design Capacity Maximum Namplate Rule 201 Grandfathered? Rule 201 Exempted? Unit Numerator Unit Denominator Capacity

N A-101 ACTIVITY INFORMATION EU/RG ID RGProductLoadout Source Classification Code (SCC) Preparer's SCC Comment 3-05-016-26 Product Loading - Enclosed Truck - Baghouses #161 & #162

MATERIAL INFORMATION

Material Code LIME Material Throughput 118083 Unit Code TON (ENGLISH - 2000 U.S. LBS)

Preparer's material description Product Loading, Enclosed Truck, tpy

VOC Content Density BTUs (fuel) Sulfur Content (fuel) Ash Content (fuel)

E-101 EMISSION INFORMATION EU/RG ID RGProductLoadout SCC Code 3-05-016-26 Pollutant Code Annual Unit code Emission Basis List Emission Exponent Emission Factor Control Comment Emissions Factor Unit Code Efficiency %

PM10,FLTRBLE 72 Other 0.61 0 99.9

A-101 ACTIVITY INFORMATION EU/RG ID RGProductLoadout Source Classification Code (SCC) Preparer's SCC Comment 3-05-016-27 Product Loading - Open Truck - Baghouses #161 & #162

MATERIAL INFORMATION

Material Code LIME Material Throughput 54987 Unit Code TON (ENGLISH - 2000 U.S. LBS)

Preparer's material description Product Loading - Open Truck, tpy

VOC Content Density BTUs (fuel) Sulfur Content (fuel) Ash Content (fuel) E-101 EMISSION INFORMATION EU/RG ID RGProductLoadout SCC Code 3-05-016-27 Pollutant Code Annual Unit code Emission Basis List Emission Exponent Emission Factor Control Comment Emissions Factor Unit Code Efficiency %

PM10,FLTRBLE 82.5 Other 1.5 0 99.9 SOURCE EMISSION FACTOR SUBSET REPORT SCC Code Pollutant Code Pollutant Factor Type Factor Exponent Material Code Material Control Device Code Control Device Unit Code Unit Code 1 Code 2

3-05-501-41

PM10,FLTRBLE LB Generic 1 -2 COAL TON

3-05-501-07

PM10,FLTRBLE LB Generic 1.8 -1 LIMESTONE TON

3-05-501-21

CO2 LB Generic 3 3 LIME TON SCRUBR,VENTURI

CO2 LB State Specific 3 3 LIME TON Factors 3-05-502-11

PM10,FLTRBLE LB Generic 6.2 0 DEVICE MILE AI‐PartC1 Graymont Western Lime Inc. ‐ Port Inland Plant ROP Renewal Application ‐ EU BAGHOUSE 231 Emission Summary Graymont Western Lime Inc. – Port Inland Plant December 2014 EUBAGHOUSE231 Emissions Summary

Controlled Controlled 10% of PM10 Grain Loading PM/PM10/PM2.5 PM/PM10/PM2.5 Significance Rate1 Airflow rate1 Emissions2 Emissions3 Threshold4 EU ID Process Description (gr/cf) (cfm) (lb/hr) (tpy) (tpy) Baghouse associated with EUBAGHOUSE231 kiln run silo 231 0.005 1,650 0.07 0.31 1.50 1. The PM grain loading rate and airflow rate was determined from DCL Technical Sales "Emission Statement" document dated March 9, 2011, sent to Angie Wanger, Trinity Consultants on November 19, 2014.

2. The PM emissions is assumed to be equivalent to PM10 and PM2,5. 3. Operating hours were assumed to be 8760 hours/year. 4. Significance thresholds obtained from R 336.1119(e); 10% significance threshold listed in MAERS User Guide & Workbook: http://www.michigan.gov/documents/deq/deq‐oppca‐workbook‐maers_307061_7.pdf Michigan Department Of Environmental Quality - Air Quality Division

RENEWABLE OPERATING PERMIT APPLICATION AI-001: ADDITIONAL INFORMATION

Form Type AI-001 SRN N7362

1. Operator’s Additional Information ID AI PART C4 GHG

Additional Information 2. Is This Information Confidential? Yes No 3. Narrative Question C.4: The greenhouse gas (GHG) potential to emit (PTE) emissions for the facility are attached to this form. The GHG emitting units are 1) EUKILN#1 and 2) Kiln #1 Auxiliary Engine (currently not identified in the permit).

Page of

EQP 5774 (1-2001)

AI‐PartC4 Graymont Western Lime Inc. ‐ Port Inland Plant ROP Renewal Application ‐ GHG Potential Emission Calculations December 2014

Graymont Western Lime Inc. – Port Inland Plant Greenhouse Gas Emissions Summary Greenhouse Gas Potential Emission Calculations Potential To Emit

CO2 CH4 N2O CO2e CO2e Emission Source (metric (metric (metric (metric (short tons/year) tons/year) tons/year) tons/year) tons/year) Fuel Combustion 173,322 18.62 2.71 173,752 191,528 Calcining 192,307 N/A N/A 192,307 211,982 Auxiliary Drive 345 N/A N/A 345 380 Total 366,404 403,891 AI‐PartC4 Graymont Western Lime Inc. ‐ Port Inland Plant ROP Renewal Application ‐ GHG Potential Emission Calculations December 2014

Graymont Western Lime Inc. – Port Inland Plant Greenhouse Gas Emission Calculations Greenhouse Gas Potential Emissions From Fuel Combustion Calculations 1

Worst Case Total6 173,322 18.62 2.708 173,752 191,528 1. The GHG potential emissions from fuel combustion are calculated based on Tier 1 or Tier 3 (depending on whether site specific fuel information was available) as found in the GHG Mandatory Reporting Rule at 40 CFR Part 98 Subpart C. 2. Heat input capacities are based on coal throughput of 14,000 Btu/lb dry‐permit application coal specs (Eastern Coal). 3. Potential annual heat input is calculated based upon the rated heat input capacity and potential hours of operation. 4. Equations per GHG Mandatory Reporting Rule at 40 CFR Part 98 Subpart C.

5. CO2e calculated based on global warming potentials of each pollutant from Table A‐1 to Subpart A of 40 CFR Part 98. 6. Worst case scenario selects the highest emissions of all permitted fuels for Kiln #1. AI‐PartC4 Graymont Western Lime Inc. ‐ Port Inland Plant ROP Renewal Application ‐ GHG Potential Emission Calculations December 2014

Tier 1 CO2 Calculations ‐3 CO2 = 1 x 10 * Fuel * HHV * EF (Eq. C‐1) Fuel = Annual mass or volume of the fuel combusted. HHV= Default high heat value of the fuel from Table C‐1 for Tier 1

EF = Fuel‐specific default CO2 emission factor, from Table C–1 (kg CO 2/MMBtu). 1 x 10‐3 = Conversion factor from kg to metric tons.

Tier 3 CO2 Calculations

CO2 = 44/12 * Fuel * CC *0.91 (Eq. C‐3)

44/12= Ratio of molecular weights, CO2 to carbon Fuel= Annual mass of the solid fuel combusted (short tons) CC= Annual average carbon content of the solid fuel 0.91= Conversion factor from short tons to metric tons

Tier 1 and 3 CH4 and N2O Calculations

‐3 CH4 or N2O = 1 x 10 * Fuel * HHV * EF (Eq. C‐8) Fuel = Annual mass or volume of the fuel combusted. HHV= Default high heat value of the fuel from Table C‐1 for Tier 1, actual HHV data for Tier 3

EF = Fuel‐specific default emission factor for CH 4 or N2O, from Table C–2 (kg CH 4 or N2O per MMBtu). 1 x 10‐3 = Conversion factor from kg to metric tons.

Tier 1 Emission Factors

1 2 2 kg CO2 / MMBtu kg CH4 / MMBtu kg N2O / MMBtu

Propane 62.87 3.0E‐03 6.0E‐04 Petroleum Coke 102.41 3.0E‐03 6.0E‐04 #2 Fuel Oil 73.96 3.0E‐03 6.0E‐04 Coal ‐‐ 1.1E‐02 1.6E‐03 1. Table C‐1 to Subpart C of 40 CFR Part 98 2. Table C‐2 to Subpart C of 40 CFR Part 98

Tier 3 Emission Factors

HHV1 HHV Units Carbon Content1

Coal 25.03 MMBtu/short ton 71.85%

1. Weighted average heating value and carbon content based on 2012 and 2013 fuel information

Global Warming Potentials1

CO2 CH4 N2O 1 25 298 1. Table A‐1 to Subpart A of 40 CFR Part 98 AI‐PartC4 Graymont Western Lime Inc. ‐ Port Inland Plant ROP Renewal Application ‐ GHG Potential Emission Calculations December 2014

Graymont Western Lime Inc. – Port Inland Plant Greenhouse Gas Emission Calculations

Calcining Greenhouse Gas Potential Emissions Calculations1

Potential To Emit Potential Stone Potential Lime Potential Hi‐Cal 2 Hours of Stone Feed Potential LKD Stack/Process Process Feed 3 Product Lime Product Hi‐Cal Lime LKD Production Operation Capacity Production Total CO2 Total CO2e ID Description (tons Production4 Production Product CO2 CO2 (Hours/Year) (tons stone/hr) (tons/year) (metric (short (tons/year) (metric (metric stone/year) (tons/year) tons/year) tons/year) tons/year) tons/year) EU‐KILN#1 Kiln #1 584,000 8,760 66.7 292,000 284,015 7,985 190,994 1,314 192,307 211,982 1. The GHG potential emissions from lime processing are calculated based upon equation S‐1 in Subpart S to 40 CFR 98. 2. Potential annual stone feed based on process constraints and a permit limit in MI‐ROP‐N7362‐2010a. 3. Stone feed hourly capacity is calculated based upon the annual stone throughput limit and number of hours in a year. 4. Limestone throughput is based on the assumed ratio of 2 tons of stone feed being equivalent to 1 ton of lime produced, as noted in the original permit application.

Production Information Data Description Value Unit Data Source tons lime product Common industry convention as noted in Lime Product Production Rate 0.5 /ton stone feed the original permit application. tons Hi‐Cal/tons Average Production Ratio from 2012 & Hi‐Cal Production Ratio 0.97 total lime product 2013 GHG Report tons LKD/ton lime Average Production Ratio from 2012 & LKD Generation Rate 0.03 product 2013 GHG Report Weighted Average from 2012 & 2013 CaO content of Hi‐Cal Lime Product 91.5% percent GHG Report Weighted Average from 2012 & 2013 CaO content of the LKD 19.9% percent GHG Report Weighted Average from 2012 & 2013 MgO content of Hi‐Cal Lime Product 2.1% percent GHG Report Weighted Average from 2012 & 2013 MgO content of the LKD 2.3% percent GHG Report

40 CFR Part 98; Subpart S Calculations

EFLime i,n = [(SRCaO * CaOi,n) + (SRMgO + MgOi,n)] * 2000/2205 (Eq. S‐1)

EFLime i,n Emission factor for lime type i, for month n (metric tons CO2/ton lime) SRCaO Stoichiometric ratio of CO 2 and CaO for calcium carbonate [see Table S‐1 of this subpart] (metric tons CO2/metric tons CaO).

CaOi,n Calcium oxide content for lime type i, for month n, determined according to §98.194(c) (metric tons CaO/metric ton lime). SRMgO Stoichiometric ratio of CO 2 and MgO for magnesium carbonate (See Table S‐1 of this subpart) (metric tons CO2/metric tons MgO). MgOi,n Magnesium oxide content for lime type i, for month n, determined according to §98.194(c) (metric tons MgO/metric ton lime). 2000/2205 Conversion factor for tons to metric tons.

Stoichiometric Ratios 1

SRCaO SRMgO 0.7848 1.0918 1. Table S‐1 to Subpart S of 40 CFR Part 98 AI‐PartC4 Graymont Western Lime Inc. ‐ Port Inland Plant ROP Renewal Application ‐ Kiln Aux Emission Summary December 2014 Graymont Western Lime Inc. – Port Inland Plant Greenhouse Gas Emission Calculations Potential Emissions Process NO CO SO PM PM CO CO Description X 2 TOC 10 2 2 (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (metric tpy) (short tpy) Kiln #1 Auxiliary Engine 9.30 2.00 0.62 0.74 0.66 0.66 345.03 380.34 Current Facility PTE1 532.40 456.00 302.70 1.80 29.20 29.20 366,059 403,511 Updated Facility PTE 541.70 458.00 303.32 2.54 29.86 29.86 366,404 403,891 1. Current facility PTE is found in Table 4.0 of Port Inland Permit Application submitted to the Michigan Department of Environmental Quality dated January 14, 2004. AI‐PartC4 Graymont Western Lime Inc. ‐ Port Inland Plant ROP Renewal Application ‐ Kiln Aux Potential Emissions December 2014

Graymont Western Lime Inc. – Port Inland Plant Auxiliary Engine and HAP Emission Calculations Auxiliary Kiln Drive Internal Combustion Engine Emission Calculations

Form Type AI-001 SRN N7362

1. Operator’s Additional Information ID AI PARTC7

Additional Information 2. Is This Information Confidential? Yes No 3. Narrative Question C7: Current versions of the Malfunction Abatement Plan (MAP), Operations, Maintenance and Monitoring (OM&M) Plan and Startup Shutdown and Malfunction Plan (SSMP) are attached. The Fugitive Dust Control plan is included in Appendix 9 of the current ROP. No updates are needed to the submitted plans.

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EQP 5774 (1-2001)

OM&M and SSMP for the Port Inland Plant This plan was developed to meet the requirements in the Air Quality permit for this facility as well as the requirements listed in the Lime MACT (40CFR63 AAAAA). Because this is a new facility, the information needed to determine whether or not the facility is subject to the Lime MACT will not be available until after facility startup when emissions testing has been performed. Therefore, the requirements of the Lime MACT are included in this plan to ensure compliance pending emission testing results. If emission testing shows that this facility is an area source for HAP’s and therefore not subject to the Lime MACT, the plan may be revised to remove the MACT requirements. This plan is designed to meet the requirements for the Malfunction Abatement Plan (MAP), the Operations, Maintenance and Monitoring Plan (OM&M) and the Startup, Shutdown and Malfunction Plan (SSMP). It covers actions to be taken for the lime kilns, coolers and processed stone handling system as defined below for each kiln. Any revisions to this plan must be submitted to DEQ for approval and/or reported in the semi-annual report.

Kiln 1 Port Inland Port Inland Kiln 1: Processed stone handling subject to MACT starts at the top of the stone bin (N-119) where the stone drops from the conveyor (C-118) into the stone bin (N-119). From the bottom of the bin, the stone drops into the kiln’s preheater (PH-121). The system is designed with minimal drop distances to reduce fugitive dust. The kiln and cooler may also be subject to MACT - both are dust collected by the kiln dust collector. The MACT requirements do not apply to any point after the lime leaves the cooler. What Must Be Included In the Plan WLC Plan R336.1911(2)(a)(MAP Requirements) A complete The overall responsibility for plant operation lies with the Plant Manager. preventative maintenance program, including identification of the supervisory personnel responsible for overseeing the inspection, maintenance, and repair of air-cleaning devices, a description of the items or conditions that shall be inspected, the frequency of the inspections or repairs, and an identification of the major replacement parts that shall be maintained in inventory for quick replacement. Lime MACT § 63.7100 (d)(1) (OM&M Requirements) Kiln Opacity: Kiln opacity will be monitored to ensure compliance. Opacity Process and control device parameters to be monitored to will be maintained at or below 10% opacity as required by the air permit. determine compliance, along with established operating Processed Stone Handling Equipment: Fugitive emissions will be monitored limits or ranges, as applicable, for each emission unit. using opacity readings (Method 9). The emission limit for this source is 10% opacity.

Updated 2013 Page 1 of 6

Lime MACT § 63.7100 (d)(2) (OM&M Requirements) Kiln Opacity: Continuous readings recorded as six minute averages will be A monitoring schedule for each emission unit. used to monitor compliance for Kiln #1 as required by the air permit. R336.1911(2)(b)(MAP Requirements) An identification of Processed Stone Handling Opacity: Monthly 1-minute visible emissions (VE) the source and air-cleaning device operating variables that check for each emission unit will be performed. If visible emissions are shall be monitored to detect a malfunction or failure, the observed during the 1-minute check, a full 6-minute Method 9 test will be normal operating range of these variables, and a description performed. The frequency of the VE checks may be reduced in accordance with of the method of monitoring or surveillance procedures. Item 1 of Table 6 to Subpart AAAAA of Part 63.

Lime MACT § 63.7100 (d)(3) (OM&M Requirements) Kiln Operation and Maintenance: The dust collector for the kiln is required Procedures for the proper operation and maintenance of each by the air permit and is used to remove particulate from the exhaust gases before emission unit and each air pollution control device used to they are released to the atmosphere. Differential pressure across the dust meet the applicable emission limitations and operating limits collector is used to ensure proper operation of the dust collector. The exhaust in Tables 1 and 2 to this subpart, respectively. from the dust collector is also continuously monitored with the opacity monitor. Both the differential pressure readings and the opacity readings are used as indicators as well as diagnostic tools for proper operation and maintenance of the dust collectors. In the event of a potential problem, the diagnostic activities listed in this plan are used to optimize the dust collector performance. Processed Stone Handling Operation and Maintenance: The processed stone handling system is designed to minimize fugitive dust emissions. Portions of the system are fully enclosed, and minimal drop distances are integral to the design. Dust from the stone chute into the kiln preheater is minimized using negative draft from the kiln’s induced draft fan. Lime MACT § 63.7100 (d)(4) (OM&M Requirements) Kiln Opacity Monitor (COMS): The COMS is installed, calibrated, Procedures for the proper installation, operation, and maintained and operated according to PS-1 of 40 CFR Part 60, Appendix B and maintenance of monitoring devices or systems used to in accordance with the manufacturer’s recommendations. The COMS is audited determine compliance, including: on an annual basis in accordance with the existing air permit. Information (i) Calibration and certification of accuracy of each pertaining to this system is contained in the Appendix A of this document monitoring device; (ii) Performance and equipment (Opacity Monitor Calibration & Maintenance). specifications for the sample interface, parametric signal analyzer, and the data collection and reduction systems; (iii) Processed Stone Handling Monitors: There are no monitoring devices or Ongoing operation and maintenance procedures in systems for this fugitive emissions source. accordance with the general requirements of §63.8(c)(1), (3) and (4)(ii): (iv) Ongoing data quality assurance procedures in accordance with the general requirements of §63.8(d).

Lime MACT § 63.7100 (d)(5) (OM&M Requirements) Kiln Opacity: The opacity monitor is installed on the exhaust stack for this

Updated 2013 Page 2 of 6 Procedures for monitoring process and control device process and collects opacity data at least once every 15 seconds in the stack prior parameters. to release. These readings are displayed by the kiln's operating computer in the R336.1911(2)(b)(MAP Requirements) An identification of control room. The data collected is stored as a six minute average in the data the source and air-cleaning device operating variables that acquisition system. The kiln's operating computer program alarms to alert the shall be monitored to detect a malfunction or failure, the kiln operator when the opacity reaches a specified level. normal operating range of these variables, and a description Processed Stone Handling Monitors: There are no monitoring devices or of the method of monitoring or surveillance procedures. systems for this fugitive emissions source. Lime MACT § 63.7100 (d)(6) (OM&M Requirements) When Kiln Opacity Exceeds 10% (Six Minute Average): In the event of a Corrective actions to be taken when process or operating malfunction or failure that results in the exceedance of the applicable limitation, parameters or add-on control device parameters deviate from appropriate actions will be taken to address the problem. These actions may the operating limits specified in Table 2 to this subpart, include but are not limited to: including: a) Ensure that the opacity monitor is working properly. If not contact qualified (i) Procedures to determine and record the cause of a personnel to troubleshoot the problem. deviation or excursion, and the time the deviation or b) Inspect the magnahelics and/or photohelics and the pressure lines and excursion began and ended; and maintain/repair as needed. (ii) Procedures for recording the corrective action taken, the c) Ensure the dampers are working and in the correct position time corrective action was initiated, and the time and date the d) Ensure that the dust removal system is working properly corrective action was completed. e) Inspect and/or replace the bags and cage assembly R336.1911(2)(c)(MAP Requirements) A description of the f) Verify that the bag cleaning system is working properly corrective procedures or operational changes that shall be taken in the event of a malfunction or failure to achieve If repairing a malfunction will jeopardize the safety of an individual or compliance with the applicable emission limits. equipment, seek advice from your supervisor before proceeding.

When Processed Stone Handling Fugitive Emissions Exceed 10% (Six Minute Average): In the event of a malfunction or failure that results in the exceedance of the applicable limitation, appropriate actions will be taken to address the problem. The induced draft fan for the kiln creates negative draft for the stone feed into the kiln preheater. The kiln cannot operate properly without the required negative draft, therefore, when the kiln is operating properly, the negative draft will be in place.

The Port Inland Plant kiln log sheets and/or the Environmental database will be used to document all of the required information.

Updated 2013 Page 3 of 6 Lime MACT § 63.7100 (d)(7) (OM&M Requirements) A Kiln Dust Collector Inspection and Preventative Maintenance Schedule maintenance schedule for each emission unit and control a) An internal inspection of the dust collector and ductwork leading to the dust device that is consistent with the manufacturer's instructions collector will be performed at least once every calendar year or on an as needed and recommendations for routine and long-term basis. The inspection may include such items as: maintenance. i) the condition of the bags R336.1911(2)(a)(MAP Requirements) A complete ii) the internal dust collector structure preventative maintenance program, including identification iii) the bag cleaning system of the supervisory personnel responsible for overseeing the iv) the discharge equipment inspection, maintenance, and repair of air-cleaning devices, a v) the condition of the ductwork leading to the dust collector description of the items or conditions that shall be inspected, vi) the photohelic/magnahelic gauges. the frequency of the inspections or repairs, and an identification of the major replacement parts that shall be b) Preventative maintenance will be performed as needed based upon the maintained in inventory for quick replacement. inspection results.

Processed Stone Handling System Inspection and Preventative Maintenance Schedule a) An inspection of the processed stone handling system will be performed at least once every calendar year or on an as needed basis. The inspection may include such items as the condition of stone handling equipment covers and/or enclosures. Preventative maintenance will be performed as needed based upon the inspection results. Lime MACT § 63.6(e)(3) The owner or operator of an Startup: Ensure that the fabric filter dust collector and COMS are operating affected source must develop a written startup, shutdown and properly. Operate the kiln to safely and steadily increase the temperature and malfunction plan that describes in detail, procedures for pressure inside the kiln. The kiln is started up with exhaust exiting through one operating and maintaining the source during periods of module of the baghouse. Once the kiln's exhaust gas temperature and the startup, shutdown, and malfunction; and a program of differential pressure has been maintained at appropriate levels another baghouse corrective action for malfunctioning process, air pollution module is opened, continuing until all baghouse modules are open and the control and monitoring equipment used to comply with the exhaust gas is passing through the entire dust collector. Bypass capability has relevant standard. been removed.

Shutdown: Before taking the fabric filter dust collector and COMS out of operation, ensure that the kiln is shut down.

Kiln Malfunction: In the event of a malfunction of the kiln process, which causes an exceedance of the applicable permit limit, the process control parameters will be inspected to determine the source of the problem. If the problem can be resolved in a timely fashion, the kiln will remain in operation

Updated 2013 Page 4 of 6 (continued) while the malfunction is being corrected. If an extended amount of time is Lime MACT § 63.6(e)(3) The owner or operator of an needed to correct the malfunction, the kiln will be temporarily shutdown. affected source must develop a written startup, shutdown and malfunction plan that describes in detail, procedures for Dust Collector Malfunction: In the event of a malfunction that results in the operating and maintaining the source during periods of exceedance of the applicable limitation, appropriate actions will be taken to startup, shutdown, and malfunction; and a program of address the problem. These actions may include but are not limited to: corrective action for malfunctioning process, air pollution a) Inspect the magnahelics and/or photohelics and the pressure lines and control and monitoring equipment used to comply with the maintain/repair as needed. relevant standard. b) Inspect and/or replace bags and cage assembly. c) Ensure the dampers are working and in the correct position d) Ensure that the dust removal system is working properly e) Verify that the bag cleaning system is working properly

If repairing a malfunction will jeopardize the safety of an individual or equipment, seek advice from your supervisor before proceeding.

Opacity Monitor Malfunction: If the opacity monitor is malfunctioning the system will be analyzed to determine the source of the problem. If the malfunction can be quickly addressed the work will be performed with the monitor in place on the stack.

Processed Stone Handling System Malfunction: This is a fugitive emissions source. The only dust control for this process is the negative draft in the kiln preheater, supplied by the kiln’s induced draft fan. A malfunction that would affect the negative draft would be addressed as a malfunction of the kiln, which is addressed elsewhere.

The Port Inland Plant kiln log sheets and/or the Environmental database will be used to document all of the required information.

R336.1911(2)(a)(MAP Requirements) A complete The following spare dust collector parts will be maintained at the plant: preventative maintenance program, including identification a) sufficient bags and suspension supplies for routine replacement. of the supervisory personnel responsible for overseeing the b) magnahelic/photohelic gauge. inspection, maintenance, and repair of air-cleaning devices, a description of the items or conditions that shall be inspected, There are no spare parts routinely inventoried for the opacity monitor because of the frequency of the inspections or repairs, and an the ability to get parts within 24 hours. identification of the major replacement parts that shall be

Updated 2013 Page 5 of 6 maintained in inventory for quick replacement.

Updated 2013 Page 6 of 6 SRN: N7362 Section Number (if applicable):

PART D: EXEMPT EMISSION UNIT INFORMATION Review all emission units at the source and answer the question below. D1. Does the source have any emission units that do not appear in the existing ROP but are required to be listed in the ROP application under R 336.1212(4) (Rule 212(4)) of the Michigan Air Pollution Control Rules? If Yes, identify the emission units in the table below. Yes No

If No, go to Part E.

Note: Emission units that are subject to process specific emission limitations or standards, even if identified in Rule 212, must be captured in either Part G or H of this application form. Identical emission units may be grouped (e.g. exempt Storage Tanks).

Emission Unit ID Emission Unit Description Rule 201 Exemption Rule 212(4) Exemption [e.g. Rule 282(b)(i)] [e.g. Rule 212(4)(b)]

The coal pre-crusher is an attachment to 290 (a)(ii)(A) 212(4)(g) EUCOALPRECRUSH the existing coal chute. The chute ER connects at the top and bottom of the pre- crusher via a sealed flange.

EUBAGHOUSE231 Lime product from the kiln discharge 284(k) NA elevator and/or the lime product sizing operation are conveyed to the kiln run silo. The lime kiln feed conveyor and the kiln run silo are controlled by a fabric filter dust collector. Loadout Bin 144 An additional product loadout bin was 284(k) NA added to the three existing product loadout bins. The EUBAGHOUSE141 is connected to the feed conveyor and bin. There are no changes to the operations or the fabric filter dust collector to accommodate the additional product loadout bin. Kiln Run Silo Lime product from the kiln discharge 284(k) N/A elevator and/or the lime product sizing operation are conveyed to the kiln run silo.

5 of 17 EQP 6000 (2-2011) Comments:

Check here if an AI-001 form is attached to provide more information for Part D. Enter AI-001 form ID: AI-PARTD

6 of 17 EQP 6000 (2-2011) Michigan Department Of Environmental Quality - Air Quality Division

RENEWABLE OPERATING PERMIT APPLICATION AI-001: ADDITIONAL INFORMATION

Form Type AI-001 SRN N7362

1. Operator’s Additional Information ID AI PART D1

Additional Information 2. Is This Information Confidential? Yes No 3. Narrative Question D1: Loadout Bin: Graymont added a product loadout bin to the existing series of product storage bins. The loadout bin is a storage container associated with the baghouse EUBAGHOUSE141. The baghouse has not had any operational or design changes as a result of the addition of the loadout bin. Pursuant to R336.1212(4)(c), the loadout bin needs to be only listed in an administratively complete application and is an exempt storage unit identified in R336.1284(k).

Kiln Run Silo: Graymont added an additional kiln run silo, a temporary storage container, associated with the new EUBAGHOUSE231. Pursuant to R336.1214(4)(c), the kiln run silo needs to be only listed in an administratively complete application and is an exempt storage unit identified in R336.1284(k).

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EQP 5774 (1-2001)

SRN: N7362 Section Number (if applicable):

PART E: EXISTING ROP INFORMATION Review all emission units and applicable requirements (including any source wide requirements) in the existing ROP and answer the questions below as they pertain to all emission units and all applicable requirements in the existing ROP. E1. Does the source propose to make any additions, changes or deletions to terms, conditions and underlying applicable requirements as they appear in the existing ROP? Yes No If Yes, identify changes and additions on Part F, Part G and/or Part H. E2. For each emission unit(s) identified in the existing ROP, all stacks with applicable requirements are to be reported in MAERS. Are there any stacks with applicable requirements for emission unit(s) identified in the existing ROP that were not reported in the most recent MAERS reporting Yes No year? If Yes, identity the stack(s) that were not reported on applicable MAERS form(s).

E3. Are any emission units identified in the existing ROP subject to compliance assurance monitoring (CAM)? Yes No If Yes, identify the specific emission unit(s) subject to CAM in the comment area below or on an AI-001 form. If a CAM plan has not been previously submitted to the MDEQ, one must be included with the ROP renewal application on an AI-001 form. Is a CAM plan included with this application? Yes No E4. Do any emission units identified in the existing ROP emit regulated fugitive emissions? If Yes, Yes No identify the specific emission unit(s) in the comment area below or on an AI-001 form. E5. Have any emission units identified in the existing ROP been modified or reconstructed that would have required a PTI? Yes No If Yes, complete Part F with the appropriate information. E6. Have any emission units identified in the existing ROP been dismantled? If Yes, identify the Yes No emission unit(s) and the dismantle date in the comment area below or on an AI-001 form. Comments:

E.2. The emission unit EUBAGHOUSE231 was not reported in MAERS. The stack forms associated with the new emission unit EUBAGHOUSE231 is attached in AI-PARTE2. In addition, the emission calculations associated with the emission unit are attached in AI-PARTC1.

E.3. For more information regarding CAM applicability, please refer to AI-PARTE3 form attached.

E.4. In the existing ROP, the following emission units emit regulated fugitive emissions: 1. EUHAULING 2. EUSTONEHANDLING 3. EUCOALHANDLING

Check here if an AI-001 form is attached to provide more information for Part E. Enter AI-001 form ID: AI-PARTE2 AI-PARTE3

7 of 17 EQP 6000 (2-2011) Michigan Department Of Environmental Quality - Air Quality Division

RENEWABLE OPERATING PERMIT APPLICATION AI-001: ADDITIONAL INFORMATION

Form Type AI-001 SRN N7362

1. Operator’s Additional Information ID AI PARTE2

Additional Information 2. Is This Information Confidential? Yes No 3. Narrative Question E2: The MAERS stack form associated with EUBAGHOUSE231 are conservatively included in this form. Emission calculations associated with the baghouse are attached to AI-PartC1 form.

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EQP 5774 (1-2001)

1. INVENTORY YEAR Michigan Department of Environmental Quality - Air Quality Division Michigan Air Emissions Reporting System (MAERS) SV-101 STACK

Authorized under 1994 P.A. 451, as amended. Completion of information is required. Civil and/or criminal penalties possible for providing false information.

GENERAL INSTRUCTIONS: Refer to last year’s MAERS forms or summary report for information previously submitted, and complete this form with additions or corrections as necessary. For more detailed instructions refer to the MAERS General Instructions Booklet. This MAERS form is used to report stacks for a specific inventory year. Enter the specific inventory year in field 1.

FORM REFERENCE 2. Form Type SV-101 3. AQD Source ID (SRN)

STACK IDENTIFICATION Change Add 4. AQD Stack ID 5. Stack ID 6. Remove from MAERS 7. Dismantle Date (MM/DD/YYYY) SV Yes No

8. Stack Description

9. Actual Stack Height 10. Inside Stack Above Ground feet Diameter inches 11. Exit Gas degrees 12. Actual Exit cubic feet Temperature Fahrenheit Gas Flow Rate per minute 13. Stack Orientation Vertical Vertical with No Loss Sleeve Vertical with Conical Cap Horizontal Goose Neck Downward 14. Latitude 15. Longitude 16. Horizontal Collection Method

_ _ . ______Decimal Degrees _ _ . ______Decimal Degrees

17. Source Map Scale Number 18. Horizontal Accuracy Measure Meters 19. Horizontal Reference Datum Code 20. Reference Point Code

21A. Bypass Stack Only Yes No 21B. If yes, operator ID of main stack

STACK IDENTIFICATION Change Add 4. AQD Stack ID 5. Stack ID 6. Remove from MAERS 7. Dismantle Date (MM/DD/YYYY) SV Yes No

8. Operator’s Stack Description

_ _ . ______Decimal Degrees _ _ . ______Decimal Degrees

17. Source Map Scale Number 18. Horizontal Accuracy Measure Meters 19. Horizontal Reference Datum Code 20. Reference Point Code

21A. Bypass Stack Only Yes No 21B. If yes, operator ID of main stack

EQP 5749 (Rev 11/11) Michigan Department Of Environmental Quality - Air Quality Division

RENEWABLE OPERATING PERMIT APPLICATION AI-001: ADDITIONAL INFORMATION

Form Type AI-001 SRN N7362

1. Operator’s Additional Information ID AI PARTE3

Additional Information 2. Is This Information Confidential? Yes No 3. Narrative Question E3: The Port Inland Plant is not subject to CAM requirements. The CAM applicability calculations are attached.

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EQP 5774 (1-2001)

AI‐PartE3 Graymont Western Lime Inc. ‐ Port Inland Plant Operation Permit Renewal Application ‐ CAM Applicability December 2014

Graymont Western Lime Inc. ‐ Port Inland Plant

CAM Applicability

Calculate uncontrolled PM10 emissions utilizing emission factors/equations from AP‐42.

Number of Maximum Total Process Emissions Operations/ Maximum Mean Wind Moisture Uncontrolled Unit PM10 Exceeds CAM 3 4 5 7,8 9 Activity Controlled Operating Rate Speed Content PM10 Emission PM10 Emission Emission Factor PM10 Emissions Emissions Threshold Emission Unit ID Permit Description1 Description Transfer Points2 (tpy) (U, mph) (M, %) Factor6 Factor Units Reference (tpy) (tpy) (100 tpy)? Lime Cooler for Heat Recovery ‐ Lime product from the kiln product cooler is discharged via conveyor to the kiln discharge elevator to the kiln run silo conveyor. The product cooler discharge to conveyor, the Nemis‐style lime cooler discharge, the lime cooler discharge conveyor, the lime elevator boot and the lime core bin vent are controlled by a AP‐42 Chpt. 13.2.4 ‐ EU‐BAGHOUSE 131 fabric filter dust collector. Material handling 2 292,000 8.11 0.25 2.55E‐02 lb/ton Equation 1 7.44 7.44 No Product transfer from Kiln 1 ‐ Lime product is conveyed to the crusher infeed elevator, crushed to size and discharged AP‐42 Chpt. 13.2.4 ‐ from the crusher to the product silo elevator. The crushed Material handling 2 292,000 8.11 0.25 2.55E‐02 lb/ton Equation 1 7.44 product may be returned to the kiln run silo conveyor. The feed conveyor from the kiln run silos, kiln run silo feeder 1 & AP‐42 Table 2, sizing elevator, and the oversized product crusher are 11.19.2‐2 ‐ EU‐BAGHOUSE 132 controlled by a fabric filter dust collector. Lime crushing 1 292,000 ‐ ‐ 2.40E‐03 lb/ton Tertiary Crushing 0.35 7.79 No Loading of Kiln Preheater Silo ‐ Lime product from the kiln discharge elevator and/or the lime product sizing operation are conveyed to the kiln run silo. The lime kiln discharge elevator head, the feed conveyor from the lime kiln discharge elevator, the feed conveyor from the lime sizing operation, and the kiln run silo are controlled by a fabric filter dust AP‐42 Chpt. 13.2.4 ‐ EU‐BAGHOUSE 133 collector. Material handling 2 292,000 8.11 0.25 2.55E‐02 lb/ton Equation 1 7.44 7.44 No Loading Product Silos & Dust from Product Screen ‐ Lime product from the kiln discharge elevator and/or the lime AP‐42 Table product elevator is sized and sent to product silos prior to 11.19.2‐2 ‐ being loaded into rail cars and/or trucks. The lime screening Lime screening 1 292,000 ‐ ‐ 8.70E‐03 lb/ton Screening 1.27 operation, the lime product elevator head, the lime product silos, the feed conveyor from the kiln discharge elevator, and the feed conveyor from the screening operation are AP‐42 Chpt. 13.2.4 ‐ EU‐BAGHOUSE 141 controlled by a fabric filter dust collector. Material handling 3 292,000 8.11 0.25 2.55E‐02 lb/ton Equation 1 11.16 12.43 No EU‐PRODUCT Loading Product to Truck ‐ Dry lime is loaded into trucks via a LOADING loading spout. The truck loader is controlled by a fabric filter AP‐42 Chpt. 13.2.4 ‐ (BAGHOUSE 161) dust collector. Product loading 1 292,000 8.11 0.25 2.55E‐02 lb/ton Equation 1 3.72 3.72 No EU‐PRODUCT Loading Product to Truck ‐ Dry lime is loaded into trucks via a LOADING 2 loading spout. The truck loader is controlled by a fabric filter AP‐42 Chpt. 13.2.4 ‐ (BAGHOUSE 162) dust collector. Product loading 1 292,000 8.11 0.25 2.55E‐02 lb/ton Equation 1 3.72 3.72 No

Loading Product to Rail ‐ Lime product is discharged from the product silos by feeders to the rail car loading system. The product silo feeders and the railcar loading spout are AP‐42 Chpt. 13.2.4 ‐ EU‐BAGHOUSE 163 controlled by a fabric filter dust collector. Product loading 2 292,000 8.11 0.25 2.55E‐02 lb/ton Equation 1 7.44 7.44 No Vent for Dust Silo ‐ Lime dust collected from the kiln baghouse is conveyed through screw conveyors to the dust EU‐DUST HANDLING silo via the dust silo elevator. The screw conveyor and dust Pneumatic As stated in the July 10, 2002, letter from the EPA to Edward Herbert of the National Ready Mixed Concrete Association, fabric filters on pneumatically loaded silos are considered an (BAGHOUSE 188) silo are controlled by a fabric filter dust collector. conveying 1 inherent part of the process and can be included for purposes of determining PTE. Therefore, the filter is not considered a control device and is not subject to CAM. Waste Dust Truck Loading ‐ Truck loading of lime dust EU‐DUST LOADING (collected from the lime kiln baghouse) which is controlled by AP‐42 Chpt. 13.2.4 ‐ (BAGHOUSE 189) a fabric filter dust collector. Product loading 1 292,000 8.11 0.25 2.55E‐02 lb/ton Equation 1 3.72 3.72 No Loading Kiln Run Silo ‐ Kiln run material conveyed into kiln AP‐42 Chpt. 13.2.4 ‐ EU‐BAGHOUSE 231 run silo which is controlled by bin vent. Material handling 1 292,000 8.11 0.25 2.55E‐02 lb/ton Equation 1 3.72 3.72 No 1. Emission unit descriptions obtained from ROP No. MI‐ROP‐N7362‐2010a dated May 1, 2012. 2. Number of transfer points/operations determined from Ferenco drawing 642‐102 dated March 30, 2012, provided by Ross Olson, Graymont, to Angie Wanger, Trinity Consultants, on December 2, 2014. 3. Maximum operating rates calculated using annual lime production rate limit of 292,000 tons. This is calculated from the permit limit of 584,000 tons of limestone assuming a 2:1 ratio between limestone and lime. 4. The mean wind speed was determined by averaging the wind speed data made available by MDEQ for the nearest city of Manistique (ISQ) for years 2008‐2012. Conservatively assumed all transfers occurred outdoors for the purposes of CAM applicability calculations. 5. Conservatively assumed minimum allowed moisture content (0.25%) for which Equation 1 is valid in AP‐42. 1.3 1.4 6. PM10 Emission Factor [lb/ton] = 0.35 x 0.0032 x (Mean Wind Speed [mph]/5) / (Moisture content [%]/2) (AP‐42 Chpt 13.2.4 ‐ Equation 1). 7. Calculations conservatively apply the maximum operating rate to each operation and transfer point.

8. Maximum uncontrolled PM10 emissions [tpy] = Number of transfer points x Maximum operating rate [tpy] x PM10 emission factor [lb/ton] / 2000 [lb/ton].

9. Total process unit PM10 emissions [tpy] = Ʃ Screening, Handling PM10 emissions.

Page 1 of 1

SRN: N7362 Section Number (if applicable):

PART F: PERMIT TO INSTALL INFORMATION Review all emission units and applicable requirements at the source and answer the following questions as they pertain to all emission units with Permits to Install (PTI). Any PTI(s) identified below must be attached to the application.

F1. Has the source obtained any PTIs where the applicable requirements from the PTI have not been incorporated into the existing ROP? If Yes, complete the following table. Yes No If No, go to Part G. Date of Emission Permit to Install Description (Include Process Equipment and Control Installation/ Units/Flexible Number Devices) Modification/ Group ID(s) Reconstruction

F2. Do/Does the PTI(s) listed above change, add, or delete terms/conditions to established emission units in the existing ROP? If Yes, identify the emission unit(s) or flexible group(s) affected in the comments area below or on an AI-001 form and identify all changes, additions, and deletions in a mark-up of the existing ROP. Yes No If No, then all terms/conditions for new emission units/flexible groups from the PTI(s) above will be incorporated into the ROP. F3. Are there any stacks with applicable requirements for emission unit(s) identified in the PTIs listed above that were not reported in MAERS for the most recent emissions reporting year? If Yes, identity the stack(s) that were not reported on the applicable MAERS form(s). Yes No

F4. Are any emission units in the PTI(s) subject to compliance assurance monitoring (CAM)?

If Yes, identify the specific emission unit(s) subject to CAM in the comments area below or on Yes No an AI-001 form. A CAM plan must be submitted as part of the ROP renewal application on an AI-001 form. F5. Do any of the emission units in the PTI(s) listed above emit regulated fugitive emissions? If Yes No Yes, identify the specific emission unit(s) in the comments area below or on an AI-001 form. F6. Are there any proposed administrative changes to any of the emission unit names, descriptions Yes No or control devices in the PTIs? If Yes, describe the changes on an AI-001 form. Comments:

Graymont Western Lime Inc, - Port Inland Plant (herein Graymont) had an administrative PTI issued for a name change which was incorporated into the ROP but is included in this renewal application for completeness (see attached in AI-PARTF).

Check here if an AI-001 form is attached to provide more information for Part F. Enter AI-001 form ID: AI-PARTF

8 of 17 EQP 6000 (2-2011) Michigan Department Of Environmental Quality - Air Quality Division

RENEWABLE OPERATING PERMIT APPLICATION AI-001: ADDITIONAL INFORMATION

Form Type AI-001 SRN N7362

1. Operator’s Additional Information ID AI PART F

Additional Information 2. Is This Information Confidential? Yes No 3. Narrative Question F1: Graymont has not had any PTIs issued since the current ROP was issued. However, it did have an administrative PTI issued for a facility and corporate name change. This PTI appears to have been incorporated into the ROP but has been conservatively included in this renewal application for completeness.

Page of

EQP 5774 (1-2001)

Michigan Department of Environmental Quality Air Quality Division State Registration Number RENEWABLE OPERATING PERMIT ROP Number N7362 STAFF REPORT MI-ROP-N7362-2010a

GRAYMONT WESTERN LIME INC.

SRN: N7362

Located At:

181 W County Road 432, Gulliver, Michigan 49840

Permit Number: MI-ROP-N7362-2010

Staff Report Date: Nov 23, 2009 and Jan 5, 2010

Amended Date: March 1, 2010; May 1, 2012

This Staff Report is published in accordance with Sections 5506 and 5511 of Part 55, Air Pollution Control, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended (Act 451). Specifically, Rule 214(1) requires that the Michigan Department of Natural Resources and Environment, Air Quality Division, prepare a report that sets forth the factual basis for the terms and conditions of the Renewable Operating Permit.

TABLE OF CONTENTS

November 23, 2009, and January 5, 2010, Staff Report 3

March 1, 2010, Staff Report Addendum 7

May 1, 2012, Staff Report Addendum 8

Michigan Department of Natural Resources and Environment Air Quality Division State Registration Number RENEWABLE OPERATING PERMIT ROP Number

N7362 November 23, 2009, and January 5, 2010 MI-ROP-N7362-2010 Staff Report

Purpose

Major stationary sources of air pollutants, and some non-major sources, are required to obtain and operate in compliance with a Renewable Operating Permit pursuant to Title V of the federal Clean Air Act of 1990 and Michigan’s Administrative Rules for air pollution control pursuant to Section 5506(1) of Act 451. Sources subject to the ROP program are defined by criteria in Rule 211(1). The ROP is intended to simplify and clarify a stationary source’s applicable requirements and compliance with them by consolidating all state and federal air quality requirements into one document.

This report, as required by Rule 214(1), sets forth the applicable requirements and factual basis for the draft permit terms and conditions including citations of the underlying applicable requirements, an explanation of any equivalent requirements included in the draft permit pursuant to Rule 212(5), and any determination made pursuant to Rule 213(6)(a)(ii) regarding requirements that are not applicable to the stationary source.

The Western Lime Corporation application #200800027 for an initial ROP was received on March 5, 2008. This application was received within the time frame specified in Rule 210(5), and was considered timely and administratively complete.

General Information

Stationary Source Mailing Address: 181 W County Road 432 Gulliver, Michigan 49840 Source Registration Number: N7362 North American Industry Classification System (NAICS) Code: 327410 Number of Stationary Source Sections: 1 Application for an Initial or Renewal Permit: Initial Issuance Application Number: 200800027 Responsible Official: Rick Vandermause, President 262-334-3005 AQD Contact: Thomas Maki, Staff Specialist 906-346-8503 Date Permit Application Received: March 5, 2008 Date Application Was Administratively Complete: March 14, 2008 Is Application Shield In Effect? Yes Date Public Comment Begins: * November 23, 2009 Deadline for Public Comment: * December 23, 2009 Date Extended Public Comment Begins: * January 5, 2010 Extended Deadline for Public Comment: * February 4, 2010

* Due to an oversight, Internet access was not provided to the associated documents; therefore, an additional public comment period began on January 5, 2010.

Source Description

Western Lime Corporation has constructed a new lime manufacturing plant at County Road 432, Gulliver, Michigan. The plant was constructed pursuant to Air Quality Permit to Install #26-04, which was issued August 9, 2005. The plant went into operation in May 2007. The plant is located adjacent to the Carmeuse Port Inland limestone plant, from which it receives limestone by conveyor belt. The Western Lime plant calcines limestone into lime using a rotary kiln fired with coal and petroleum coke and is equipped with a preheater, cooler and fabric filter dust collection system. The preheater/cooler serves as an energy conservation device and acts as a sulfur dioxide absorption device, while the fabric filter is for particulate control. Also, fabric filters are used at the plant for dust control from various auxiliary processes.

Source Emissions

The following table lists emission information for the facility as reported to the Michigan Air Emissions Reporting System (MAERS) for calendar year 2008.

Pollutant Quantity Emitted Per Year Carbon Monoxide 245 tons per year Nitrogen Oxides 272 tons per year Particulate Matter (PM10) 23 tons per year Sulfur Oxides 17 tons per year Total Hazardous Air Pollutants ** 0

**As listed pursuant to Section 112(b) of the Clean Air Act.

Regulatory Analysis

The Western Lime facility is located in Schoolcraft County, which is designated as attainment/unclassified for all criteria pollutants. The following is a general description of the regulatory requirements applicable to the Western Lime Corporation Port Inland Plant.

AQD Permit to Install #26-04 was issued August 9, 2005 and covers the installation of the lime manufacturing plant. The facility is subject to the Standards of Performance for Lime Manufacturing Plants, 40 CFR Part 60 Subpart HH, which were issued and published in the Federal Register on April 26, 1984. These standards were incorporated into Permit to Install #26-04. The facility is also subject to the National Emission Standards for Hazardous Air Pollutants for Lime Manufacturing Plants, 40 CFR Part 63 Subpart AAAAA, which were issued and published in the Federal Register on January 5, 2004. These standards were incorporated into the draft Renewable Operating Permit.

Please refer to Parts B and C of the draft Renewable Operating Permit for detailed regulatory citations for the stationary source. Part A contains regulatory citations for the general conditions.

See Part C in the draft ROP for summary tables of all processes at the stationary source that are subject to process-specific emission limits or standards.

Any determinations of regulatory non-applicability for this source are addressed in the non-applicable requirements portion of the Staff Report and Part E of the ROP. At the time of preparation of the draft ROP, no non-applicable requirements have been identified for incorporation into the permit shield provision set forth in the General Conditions in Part A of the draft ROP pursuant to Rule 213(6)(a)(ii).

The monitoring conditions contained in the ROP are necessary to demonstrate compliance with all applicable requirements and are consistent with DNRE’s "Procedure for Evaluating Periodic Monitoring Submittals."

The facility is considered a 40 CFR Part 70 major source because potential emissions of criteria pollutants exceed 100 tons per year.

Source-Wide Permit to Install (PTI)

Rule 214a requires the issuance of a Source-wide Permit To Install (PTI) within the ROP for conditions established pursuant to Rule 201. All terms and conditions that were initially established in a PTI are identified with a footnote designation in the integrated ROP/PTI document. Any PTIs that would be incorporated through this permit action into the Source-Wide PTI are listed in Appendix 6 of the permit.

The following table lists the Permit to Install which have been issued to Western Lime Corporation.

Permit to Install Number Description of Equipment

#26-04 Permit to Install #26-04 authorizes installation of the lime manufacturing plant at the Port Inland site including a coal and petroleum coke fired rotary kiln to calcine limestone into lime, a preheater, cooler and fabric filter dust collection system, related material handling, and associated dust collectors. Permit to Install #26-04 was issued August 9, 2005.

#26-04A Permit to Install #26-04A was issued to the facility on June 29, 2009 for a trial burn to combust up to 100 tons of “Process Engineered Fuel”, co-fired with coal in the rotary kiln. Process Engineered Fuel is alternative fuel derived from municipal solid waste (common residential or commercial garbage), bio-mass (forest products, mill wastes, crop residue, and energy crops such as switchgrass or hybrid willow). The company completed the trial burn period, and so notified the Air Quality on August 20, 2009.

Equivalent Requirements

The draft permit does not include any equivalent requirements or significant changes pursuant to Rule 212(5). Equivalent requirements are enforceable applicable requirements which are equivalent to the applicable requirements contained in the original New Source Review permit, a Consent Order or Consent Judgment, and/or the State Implementation Plan.

Non-applicable Requirements

Part E of the draft Renewable Operating Permit lists requirements that are not applicable to this source as determined by the Air Quality Division. These determinations are incorporated into the permit shield provision set forth in Part A (General Conditions 26 through 29) of the draft ROP pursuant to Rule 213(6)(a)(ii). At the time of issuance of this Renewable Operating Permit, the Air Quality Division has determined that no non-applicable requirements have been identified for incorporation into the permit shield provision set forth in the General Conditions in Part A.

Processes in Application Not Identified in Draft ROP

There were no processes listed in the ROP application as exempt devices under Rule 212(4). Exempt devices are not subject to any process-specific emission limits or standards in any applicable requirement.

Draft Permit Terms or Conditions Not Agreed to by Applicant

This permit does not contain any terms or conditions that the Air Quality Division and the applicant did not agree upon pursuant to Rule 214(2).

Facility Compliance Status

The Air Quality Division finds that the stationary source is expected to be in compliance with all applicable requirements as of the effective date of this Renewable Operating Permit.

Proposed Action

The DNRE Air Quality Division proposes to approve this permit. A final decision on the ROP will not be made until the public and affected states have had an opportunity to comment on the AQD’s proposed action and draft permit. In addition, the USEPA is allowed up to 45 days to review the draft permit and related material. The AQD is not required to accept recommendations that are not based on applicable requirements. The delegated decision maker for the Air Quality Division is Brian D. Brady, Upper Peninsula District Supervisor. The final determination for ROP approval or disapproval will be based on the contents of the permit application, a judgment that the stationary source will be able to comply with applicable emission limits and other terms and conditions, and resolution of any objections by the USEPA.

Michigan Department of Natural Resources and Environment

Air Quality Division State Registration Number RENEWABLE OPERATING PERMIT ROP Number

N7362 March 1, 2010, Staff Report Addendum MI-ROP-N7362-2010

Purpose

A Staff Report dated November 23, 2009, and January 5, 2010, was developed in order to set forth the applicable requirements and factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by R 336.1214(1). The purpose of this Staff Report Addendum is to summarize any significant comments received on the draft ROP during the 30-day public comment period as described in R 336.1214(3). In addition, this addendum describes any changes to the draft ROP resulting from these pertinent comments.

General Information

Responsible Official: Rick Vandermause, President 262-334-3005 AQD Contact: Thomas Maki, Staff Specialist 906-346-8503

Summary of Pertinent Comments

A letter dated January 8, 2010, from a Pennsylvania citizen, was received during the 30-day public comment period. The citizen commented that he believed that 40 CFR 60 Subpart Y – NSPS for Coal Preparation Plants applies to the Western Lime facility. He commented that: “affected facilities include thermal dryers, pneumatic coal-cleaning equipment (air tables), coal processing and conveying equipment (including breakers and crushers), coal storage systems, and coal transfer and loading systems”.

There was no request for a public hearing.

Changes to the January 5, 2010, Draft ROP

The comment received during the 30-day public comment period has been reviewed. The Air Quality Division has determined that the Western Lime facility is not a Coal Preparation Plant as defined in 40 CFR 60.251: “Coal Preparation Plant means any facility (excluding underground mining operations) which prepares coal by one or more of the following processes: breaking, crushing, screening, wet or dry cleaning, and thermal drying.” The Western Lime facility receives coal sized to their specification, transports it via conveyor belt to a storage bin from which it passes to a coal pulverizer immediately prior to being fired to the lime kiln. There is no exhaust or bypass to atmosphere from the coal pulverizer or between the coal pulverizer and the lime kiln. The judgment of the Air Quality Division is that Subpart Y does not apply to the Western Lime facility, and no changes were made to the January 5, 2010 draft ROP.

Proposed Permit

Proposed initial Renewable Operating Permit #MI-ROP-N7362-2010 dated March 1, 2010, has been prepared and will be forwarded to USEPA Region V in Chicago. The EPA will have 45 days to review the proposed permit, as provided under Rule 214(6).

Michigan Department of Environmental Quality Air Quality Division State Registration Number RENEWABLE OPERATING PERMIT ROP Number

N7362 May 1, 2012, STAFF REPORT FOR MI-ROP-N7362-2010 RULE 216(1)(a)(i)-(iv) ADMINISTRATIVE AMENDMENT

Purpose

On May 1, 2012, the Department of Environmental Quality (DEQ), Air Quality Division (AQD), approved and issued Renewable Operating Permit (ROP) No. MI-ROP-N7362-2010a to Graymont Western Lime Inc., pursuant to R 336.1214. Once issued, a company is required to submit an application for changes to the ROP as described in R 336.1216. The purpose of this Staff Report is to describe the changes that were made to the ROP pursuant to R 336.1216(1)(a)(i-iv).

General Information

Responsible Official: Mindy Ochs, Environmental and Regulatory Director 262-334-3005, ext. 101 AQD Contact: Kirsten S. Clemens, P.E., Environmental Engineer 269-567-3548 Application Number: 201200059 Date Application For Administrative April 27, 2012 Amendment Was Submitted:

Regulatory Analysis

The AQD has determined that the change requested by the stationary source meets the qualifications for an Administrative Amendment pursuant to R 336.1216(1)(a)(iv).

Description of Changes to the ROP

Change of legal name to Graymont Western Lime Inc.

Compliance Status

The AQD finds that the stationary source is expected to be in compliance with all applicable requirements associated with the emission unit(s) involved with the change as of the date of approval of the Administrative Amendment to the ROP.

Action Taken by the DEQ

The AQD approved an Administrative Amendment to ROP No. MI-ROP-N7362-2010a, as requested by the stationary source. The delegated decision maker for the AQD is the District Supervisor.

8 SRN: N7362 Section Number (if applicable):

PART G: EMISSION UNITS MEETING THE CRITERIA OF RULES 281(h), 285(r)(iv), 287(c), OR 290 Review all emission units and applicable requirements at the source and answer the following questions. G1. Does the source have any new and/or existing emission units which do not already appear in the existing ROP and which meet the criteria of Rules 281(h), 285(r)(iv), 287(c), or 290. If Yes, identify the emission units in the table below. If No, go to Part H. Yes No Note: If several emission units were installed under the same rule above, provide a description of each and an installation date for each. Origin of Applicable Emission Unit Description – Provide Emission Unit ID and Installation Requirements process equipment/control device descriptions Date(s)

Rule 281(h) or 285(r)(iv) cleaning operation

Rule 287(c) surface coating line

Rule 290 EUCOALPRECRUSHER - The coal pre-crusher is an attachment October, 2014 process with limited to the existing coal chute. The chute connects at the top and emissions bottom of the pre-crusher via a sealed flange.

Comments:

Check here if an AI-001 form is attached to provide more information for Part G. Enter AI-001 form ID:

9 of 17 EQP 6000 (2-2011) SRN: N7362 Section Number (if applicable):

PART H: REQUIREMENTS FOR ADDITION OR CHANGE Complete this part of the application form for all proposed additions, changes or deletions to the existing ROP. This includes state or federal regulations that the source is subject to and that must be incorporated into the ROP or other proposed changes to the existing ROP. Do not include additions or changes that have already been identified in parts F or G of this application form. If additional space is needed copy and complete an additional Part H.

H1. Are there changes that need to be incorporated into the ROP that have not been identified in Parts Yes No F and G? If Yes, answer the questions below.

H2. Are there any proposed administrative changes to any of the existing emission unit names, Yes No descriptions or control devices in the ROP? If Yes, describe the changes in a mark-up of the Emission Unit Summary Table in the existing ROP.

H3. Does the source propose to add a new emission unit or flexible group to the ROP not previously Yes No identified in parts F or G? If Yes, identify and describe the emission unit names, process description, and control device(s) in a mark-up of the Emission Unit Summary Table in the existing ROP.

H4. Does the source propose to make any additions, changes or deletions to terms, conditions and Yes No underlying applicable requirements in the existing ROP? If Yes, identify each emission unit/flexible group subject to the addition, change or deletion and identify the high level citation for each state or federal underlying applicable requirement that the emission unit/flexible group is subject to. Graymont proposes to add the following flexible group :  FGRICEMACT- The 68.5 hp Compression Ignition auxiliary engine (uses diesel fuel) constructed before June 12, 2006 is subject to 40 CFR 63 Subpart ZZZZ. These requirements have been identified in the ROP markup.

H5. Has a Consent Order/Consent Judgment (CO/CJ) been issued where the requirements were not Yes No cited in the existing ROP? If Yes, list the CO/CJ number(s) below and add, change and/or delete the applicable requirements in the mark-up of the existing ROP.

H6. Does the source propose to add, change and/or delete source-wide requirements? If Yes, Yes No identify the addition/change/deletion in a mark-up of the corresponding section of the ROP and provide a justification below.

H8. Does the source propose to add, change and/or delete material limit requirements? If Yes, Yes No identify the addition/change/deletion in a mark-up of the corresponding section of the ROP and provide a justification below.

10 of 17 EQP 6000 (2-2011) SRN: N7362 Section Number (if applicable):

PART H: REQUIREMENTS FOR ADDITION OR CHANGE – (continued) H9. Does the source propose to add, change and/or delete process/operational restriction Yes No requirements? If Yes, identify the addition/change/deletion in a mark-up of the corresponding section of the ROP and provide a justification below.

H10. Does the source propose to add, change and/or delete design/equipment parameter Yes No requirements? If Yes, identify the addition/change/deletion in a mark-up of the corresponding section of the ROP and provide a justification below.

H12. Does the source propose to add, change and/or delete monitoring/recordkeeping Yes No requirements? If Yes, identify the addition/change/deletion in a mark-up of the corresponding section of the ROP and provide a justification below.

Graymont proposes to add recordkeeping requirements pursuant to 40 CFR 63 Subpart ZZZZ.

H13. Does the source propose to add, change and/or delete reporting requirements? If Yes, identify Yes No the addition/change/deletion in a mark-up of the corresponding section of the ROP and provide a justification below. Graymont proposes to add the source-wide reporting requirements in this section as identified in the ROP markup.

H14. Does the source propose to add, change and/or delete stack/vent restrictions? If Yes, identify Yes No the addition/change/deletion in a mark-up of the corresponding section of the ROP and provide a justification below.

H15. Does the source propose to add, change and/or delete any other requirements? If Yes, identify Yes No the addition/change/deletion in a mark-up of the corresponding section of the ROP and provide a justification below. Graymont proposes to add a general reference to 40 CFR 63 Subpart A and ZZZZ.

Check here if an AI-001 form is attached to provide more information for Part H. Enter AI-001 form ID:

11 of 17 EQP 6000 (2-2011) PART H: REQUIREMENTS FOR ADDITION OR CHANGE Complete this part of the application form for all proposed additions, changes or deletions to the existing ROP. This includes state or federal regulations that the source is subject to and that must be incorporated into the ROP or other proposed changes to the existing ROP. Do not include additions or changes that have already been identified in parts F or G of this application form. If additional space is needed copy and complete an additional Part H.

H1. Are there changes that need to be incorporated into the ROP that have not been identified in Parts Yes No F and G? If Yes, answer the questions below.

H4. Does the source propose to make any additions, changes or deletions to terms, conditions and Yes No underlying applicable requirements in the existing ROP? If Yes, identify each emission unit/flexible group subject to the addition, change or deletion and identify the high level citation for each state or federal underlying applicable requirement that the emission unit/flexible group is subject to. Graymont proposes to add the following flexible group:  FGNSPSY- The flexible group includes EUCOALPRECRUSHER. This unit is subject to 40 CFR 60 Subpart Y. The requirements have been identified in the ROP markup.

H7. Does the source propose to add, change and/or delete emission limit requirements? If Yes, Yes No identify the addition/change/deletion in a mark-up of the corresponding section of the ROP and provide a justification below. Pursuant to 40 CFR 60.254(b)(1), the emission unit in this flexible group will be subject to a 10% opacity limit.

SRN: N7362 Section Number (if applicable):

12 of 17 EQP 6000 (2-2011) PART H: REQUIREMENTS FOR ADDITION OR CHANGE – (continued) H9. Does the source propose to add, change and/or delete process/operational restriction Yes No requirements? If Yes, identify the addition/change/deletion in a mark-up of the corresponding section of the ROP and provide a justification below.

H11. Does the source propose to add, change and/or delete testing/sampling requirements? If Yes, Yes No identify the addition/change/deletion in a mark-up of the corresponding section of the ROP and provide a justification below. Graymont proposes to add initial performance testing requirements for opacity pursuant to 40 CFR 60.255(b)(2) as well as the requirements for subsequent visible emissions testing in 40 CFR 60.255(f)(1) following the procedures outlined in 40 CFR 60.257(a) and 40 CFR 258(c)-(d) for the flexible group FGNSPSY.

Graymont proposes to add recordkeeping and monitoring requirements pursuant to 40 CFR 60.258(a)(1)-(3) for the flexible group FGNSPSY.

Check here if an AI-001 form is attached to provide more information for Part H. Enter AI-001 form ID:

13 of 17 EQP 6000 (2-2011) PART H: REQUIREMENTS FOR ADDITION OR CHANGE Complete this part of the application form for all proposed additions, changes or deletions to the existing ROP. This includes state or federal regulations that the source is subject to and that must be incorporated into the ROP or other proposed changes to the existing ROP. Do not include additions or changes that have already been identified in parts F or G of this application form. If additional space is needed copy and complete an additional Part H.

H1. Are there changes that need to be incorporated into the ROP that have not been identified in Parts Yes No F and G? If Yes, answer the questions below.

H4. Does the source propose to make any additions, changes or deletions to terms, conditions and Yes No underlying applicable requirements in the existing ROP? If Yes, identify each emission unit/flexible group subject to the addition, change or deletion and identify the high level citation for each state or federal underlying applicable requirement that the emission unit/flexible group is subject to. Graymont proposes to add the following flexible group:  FGR290- The flexible group includes EUCOALPRECRUSHER. This unit is subject to R336.1290 (Rule 290). The requirements have been identified in the ROP markup.

H7. Does the source propose to add, change and/or delete emission limit requirements? If Yes, Yes No identify the addition/change/deletion in a mark-up of the corresponding section of the ROP and provide a justification below. Graymont proposes to incorporate the Rule 290 applicability emission limit requirements in the ROP markup.

SRN: N7362 Section Number (if applicable):

14 of 17 EQP 6000 (2-2011) PART H: REQUIREMENTS FOR ADDITION OR CHANGE – (continued) H9. Does the source propose to add, change and/or delete process/operational restriction Yes No requirements? If Yes, identify the addition/change/deletion in a mark-up of the corresponding section of the ROP and provide a justification below. Graymont proposes to add a general Rule 290 requirement in the ROP markup.

Graymont proposes to incorporate the Rule 290 monitoring and recordkeeping requirements in the ROP markup.

Check here if an AI-001 form is attached to provide more information for Part H. Enter AI-001 form ID:

15 of 17 EQP 6000 (2-2011) PART H: REQUIREMENTS FOR ADDITION OR CHANGE Complete this part of the application form for all proposed additions, changes or deletions to the existing ROP. This includes state or federal regulations that the source is subject to and that must be incorporated into the ROP or other proposed changes to the existing ROP. Do not include additions or changes that have already been identified in parts F or G of this application form. If additional space is needed copy and complete an additional Part H.

H1. Are there changes that need to be incorporated into the ROP that have not been identified in Parts Yes No F and G? If Yes, answer the questions below.

Graymont proposes to modify the existing flexible group FGBAGHOUSES to include EUBAGHOUSE231.

H7. Does the source propose to add, change and/or delete emission limit requirements? If Yes, Yes No identify the addition/change/deletion in a mark-up of the corresponding section of the ROP and provide a justification below. Graymont proposes to add PM emission limits from R 336.1331 (Rule 331) for EUBAGHOUSE231.

SRN: N7362 Section Number (if applicable):

16 of 17 EQP 6000 (2-2011) PART H: REQUIREMENTS FOR ADDITION OR CHANGE – (continued) H9. Does the source propose to add, change and/or delete process/operational restriction Yes No requirements? If Yes, identify the addition/change/deletion in a mark-up of the corresponding section of the ROP and provide a justification below.

Check here if an AI-001 form is attached to provide more information for Part H. Enter AI-001 form ID:

17 of 17 EQP 6000 (2-2011) Michigan Department of Environmental Quality Air Quality Division

EFFECTIVE DATE: JULY 1, 2010; REVISED MAY 1, 2012

ISSUED TO:

Graymont Western Lime Inc.

State Registration Number (SRN): N7362

LOCATED AT:

181 W County Road 432, Gulliver, Michigan 49840

RENEWABLE OPERATING PERMIT

Permit Number: MI-ROP-N7362-2010a

Expiration Date: JUNE 30, 2015

Administratively Complete ROP Renewal Application Due Between December 31, 2013 and December 31, 2014

This Renewable Operating Permit (ROP) is issued in accordance with and subject to Section 5506(3) of, Part 55, Air Pollution Control, of the Environmental Quality Protection Act, 1994 PA 451, as amended (Act 451). Pursuant to Michigan Air Pollution Control Rule 210(1), this ROP constitutes the permittee’s authority to operate the stationary source identified above in accordance with the general conditions, special conditions and attachments contained herein. Operation of the stationary source and all emission units listed in the permit are subject to all applicable future or amended rules and regulations pursuant to Act 451 and the federal Clean Air Act.

SOURCE-WIDE PERMIT TO INSTALL

Permit Number: MI-PTI-N7362N7362-20102010a Formatted: Font: 12 pt

Formatted: Font: 12 pt This Permit to Install (PTI) is issued in accordance with and subject to Section 5505(5) of Act 451. Pursuant to Michigan Air Pollution Control Rule 214a, the terms and conditions herein, identified by the underlying applicable requirement citation of Rule 201(1)(a), constitute a federally enforceable PTI. The PTl terms and conditions do not expire and remain in effect unless the criteria of Rule 201(6) are met. Operation of all emission units identified in the PTI is subject to all applicable future or amended rules and regulations pursuant to Act 451 and the federal Clean Air Act.

Michigan Department Environmental Quality

______Chris Hare, Acting Upper Peninsula District Supervisor

Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

TABLE OF CONTENTS

AUTHORITY AND ENFORCEABILITY ...... 32

A. GENERAL CONDITIONS ...... 42 Permit Enforceability 42 General Provisions 42 Equipment and Design 52 Emission Limits 52 Testing and Sampling 62 Monitoring and Recordkeeping 62 Certification and Reporting 62 Permit Shield 82 Revisions 82 Reopenings 92 Renewals 92 Stratospheric Ozone Protection 92 Risk Management Plan 102 Emission Trading 102 Permit To Install (PTI) 102 Alternative Operating Scenarios 112 B. SOURCE-WIDE CONDITIONS ...... 122

C. EMISSION UNIT CONDITIONS ...... 162 EMISSION UNIT SUMMARY TABLE 162 Table E-1.1 EU-KILN#1 192 Table E-1.2 EU-HAULING 242 Table E-1.3 EU-STONE HANDLING 262 D. FLEXIBLE GROUP CONDITIONS ...... 282 FLEXIBLE GROUP SUMMARY TABLE 282 Table F-1.1 FG-BAGHOUSES 292 E. NON-APPLICABLE REQUIREMENTS ...... 402

APPENDICES ...... 412 Appendix 1. Abbreviations and Acronyms 412 Appendix 2. Schedule of Compliance 422 Appendix 3. Monitoring Requirements 422 Appendix 4. Recordkeeping 422 Appendix 5. Testing Procedures 422 Appendix 6. Permits to Install 422 Appendix 7. Emission Calculations 432 Appendix 8. Reporting 432 Appendix 9. Fugitive Dust Control Plan 442 Comment [AW1]: Note to MDEQ: The PDF version of the permit has the correct page numbers – this Word version seems to have an error.

Page 2 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Formatted: Don't adjust space between Latin 0B AUTHORITY AND ENFORCEABILITY and Asian text

For the purpose of this permit, the permittee is defined as any person who owns or operates an emission unit at a stationary source for which this permit has been issued. The department is defined in Rule 104(d) as the Director of the Michigan Department of Environmental Quality (MDEQ) or his or her designee.

The permittee shall comply with all specific details in the permit terms and conditions and the cited underlying applicable requirements. All terms and conditions in this ROP are both federally enforceable and state enforceable unless otherwise footnoted. Certain terms and conditions are applicable to most stationary sources for which an ROP has been issued. These general conditions are included in Part A of this ROP. Other terms and conditions may apply to a specific emission unit, several emission units which are represented as a flexible group, or the entire stationary source which is represented as a source-wide group. Special conditions are identified in Parts B, C, D and/or the appendices.

In accordance with Rule 213(2)(a), all underlying applicable requirements will be identified for each ROP term or condition. All terms and conditions that are included in a Permit to Install (PTI), are streamlined or subsumed, or is state only enforceable will be noted as such.

In accordance with Section 5507 of Act 451, the permittee has included in the ROP application a compliance certification, a schedule of compliance, and a compliance plan. For applicable requirements with which the source is in compliance, the source will continue to comply with these requirements. For applicable requirements with which the source is not in compliance, the source will comply with the detailed schedule of compliance requirements that are incorporated as an appendix in this ROP. Furthermore, for any applicable requirements effective after the date of issuance of this ROP, the stationary source will meet the requirements on a timely basis, unless the underlying applicable requirement requires a more detailed schedule of compliance.

Issuance of this permit does not obviate the necessity of obtaining such permits or approvals from other units of government as required by law.

Page 3 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Formatted: Don't adjust space between Latin 1B A. GENERAL CONDITIONS and Asian text Formatted: Don't adjust space between Latin and Asian text Permit7B Enforceability

• All conditions in this permit are both federally enforceable and state enforceable unless otherwise noted. [R336.1213(5)]

• Those conditions that are hereby incorporated in a state-only enforceable Source-wide Permit to Install (PTI) pursuant to Rule 201(2)(d) are designated by footnote one. [R336.1213(5)(a), R336.1214a(5)]

• Those conditions that are hereby incorporated in federally enforceable Source-wide PTI No. MI-PTI-N7362N7362- Formatted: Font: 10 pt 20102010 pursuant to Rule 201(2)(c) are designated by footnote two. [R336.1213(5)(b), R336.1214a(3)] Formatted: Font: 10 pt

Formatted: Don't adjust space between Latin and Asian text General8B Provisions

1. The permittee shall comply with all conditions of this ROP. Any ROP noncompliance constitutes a violation of Act 451, and is grounds for enforcement action, for ROP revocation or revision, or for denial of the renewal of the ROP. All terms and conditions of this ROP that are designated as federally enforceable are enforceable by the Administrator of the United States Environmental Protection Agency (USEPA) and by citizens under the provisions of the federal Clean Air Act (CAA). Any terms and conditions based on applicable requirements which are designated as “state only” are not enforceable by the USEPA or citizens pursuant to the CAA. [R336.1213(1)(a)]

2. 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 ROP. [R336.1213(1)(b)]

3. This ROP 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 ROP term or condition. This does not supersede or affect the ability of the permittee to make changes, at the permittee’s own risk, pursuant to Rules 215 and 216. [R336.1213(1)(c)]

4. 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: [R336.1213(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 ROP. b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of the ROP. c. Inspect, at reasonable times, any of the following: i. Any stationary source. ii. Any emission unit. iii. Any equipment, including monitoring and air pollution control equipment. iv. Any work practices or operations regulated or required under the ROP. d. As authorized by Section 5526 of Act 451, sample or monitor at reasonable times substances or parameters for the purpose of assuring compliance with the ROP or applicable requirements.

Page 4 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

5. 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 ROP or to determine compliance with this ROP. Upon request, the permittee shall also furnish to the department copies of any records that are required to be kept as a term or condition of this ROP. For information which is claimed by the permittee to be confidential, consistent with the requirements of 1976 PA 442, MCL §15.231 et seq., and known as the Freedom of Information Act, the person may also be required to furnish the records directly to the USEPA together with a claim of confidentiality. [R336.1213(1)(e)]

6. A challenge by any person, the Administrator of the USEPA, or the department to a particular condition or a part of this ROP shall not set aside, delay, stay, or in any way affect the applicability or enforceability of any other condition or part of this ROP. [R336.1213(1)(f)]

7. The permittee shall pay fees consistent with the fee schedule and requirements pursuant to Section 5522 of Act 451. [R336.1213(1)(g)]

8. This ROP does not convey any property rights or any exclusive privilege. [R336.1213(1)(h)]

Formatted: Don't adjust space between Latin and Asian text Equipment9B and Design

9. 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 Rule 370(2). [R336.1370]

10. 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. [R336.1910]

Formatted: Don't adjust space between Latin and Asian text Emission10B Limits

11. Except as provided in Subrules 2, 3, and 4 of Rule 301, a person shall not cause or permit to be discharged into the outer air from a process or process equipment a visible emission of a density greater than the most stringent of Rule 301(1)(a) or (b) unless otherwise specified in this ROP. The grading of visible emissions shall be determined in accordance with Rule 303. [R336.1301(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.

12. 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.1 [R336.1901(a)] b. Unreasonable interference with the comfortable enjoyment of life and property.1 [R336.1901(b)]

Page 5 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Formatted: Don't adjust space between Latin and Asian text Testing11B and Sampling

13. 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 Rule 1001 and Rule 1003, under any of the conditions listed in Rule 1001(1). [R336.2001]

14. Any required performance testing shall be conducted in accordance with Rule 1001(2), Rule 1001(3) and Rule 1003. [R336.2001(2), R336.2001(3), R336.2003(1)]

15. Any required test results shall be submitted to the Air Quality Division (AQD) in the format prescribed by the applicable reference test method within 60 days following the last date of the test. [R336.2001(4)]

Formatted: Don't adjust space between Latin and Asian text Monitoring12B and Recordkeeping

16. Records of any periodic emission or parametric monitoring required in this ROP shall include the following information specified in Rule 213(3)(b)(i), where appropriate: [R336.1213(3)(b)] a. The date, location, time, and method of sampling or measurements. b. The dates the 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.

17. 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 ROP. [R336.1213(1)(e), R336.1213(3)(b)(ii)]

Formatted: Don't adjust space between Latin and Asian text Certification13B and Reporting

18. Except for the alternate certification schedule provided in Rule 213(3)(c)(iii)(B), any document required to be submitted to the department as a term or condition of this ROP shall contain an original 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. [R336.1213(3)(c)]

19. A responsible official shall certify to the appropriate AQD District Office and to the USEPA that the stationary source is and has been in compliance with all terms and conditions contained in the ROP except for deviations that have been or are being reported to the appropriate AQD District Office pursuant to Rule 213(3)(c). This certification shall include all the information specified in Rule 213(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 USEPA address is: USEPA, Air Compliance Data - Michigan, Air and Radiation Division, 77 West Jackson Boulevard, Chicago, IL 60604. [R336.1213(4)(c)]

Page 6 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

20. The certification of compliance shall be submitted annually for the term of this ROP as detailed in the special conditions, or more frequently if specified in an applicable requirement or in this ROP. [R336.1213(4)(c)]

21. The permittee shall promptly report any deviations from ROP requirements and certify the reports. The prompt reporting of deviations from ROP requirements is defined in Rule 213(3)(c)(ii) as follows, unless otherwise described in this ROP: [R336.1213(3)(c)] a. For deviations that exceed the emissions allowed under the ROP, prompt reporting means reporting consistent with the requirements of Rule 912 as detailed in Condition 25. All reports submitted pursuant to this paragraph shall be promptly certified as specified in Rule 213(3)(c)(iii). b. For deviations which exceed the emissions allowed under the ROP and which are not reported pursuant to Rule 912 due to the duration of the deviation, prompt reporting means the reporting of all deviations in the semiannual reports required by Rule 213(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 ROP, prompt reporting means the reporting of all deviations in the semiannual reports required by Rule 213(3)(c)(i). The report shall describe the reasons for each deviation and the actions taken to minimize or correct each deviation.

22. For reports required pursuant to Rule 213(3)(c)(ii), prompt certification of the reports is described in Rule 213(3)(c)(iii) as either of the following: [R336.1213(3)(c)] a. 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. b. 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 ROP were submitted to the department pursuant to Rule 213(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 Rule 213(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.

23. Semiannually for the term of the ROP as detailed in the special conditions, or more frequently if specified, the permittee shall submit certified reports of any required monitoring to the appropriate District Office of the AQD. All instances of deviations from ROP requirements during the reporting period shall be clearly identified in the reports. [R336.1213(3)(c)(i)]

24. On an annual basis, the permittee shall report the actual emissions, or the information necessary to determine the actual emissions, of each regulated air pollutant as defined in Rule 212(6) for each emission unit utilizing the emissions inventory forms provided by the department. [R336.1212(6)]

25. 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 Rule 912, 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. Notice shall be by any reasonable means, including electronic, telephonic, or oral communication. Written reports, if required under Rule 912, 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 Rule 912(5) and shall be certified by a responsible official in a manner consistent with the CAA. [R336.1912]

Page 7 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Formatted: Don't adjust space between Latin and Asian text Permit14B Shield

26. Compliance with the conditions of the ROP shall be considered compliance with any applicable requirements as of the date of ROP issuance, if either of the following provisions is satisfied: [R336.1213(6)(a)(i), R336.1213(6)(a)(ii)] a. The applicable requirements are included and are specifically identified in the ROP. 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 E of this ROP have been identified as non-applicable to this ROP and are included in the permit shield.

27. Nothing in this ROP 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 CAA. [R336.1213(6)(b)(i)] b. The liability of the owner or operator of this source for any violation of applicable requirements prior to or at the time of this ROP issuance. [R336.1213(6)(b)(ii)] c. The applicable requirements of the acid rain program, consistent with Section 408(a) of the CAA. [R336.1213(6)(b)(iii)] d. The ability of the EPA to obtain information from a source pursuant to Section 114 of the CAA. [R336.1213(6)(b)(iv)]

28. The permit shield shall not apply to provisions incorporated into this ROP through procedures for any of the following: a. Operational flexibility changes made pursuant to Rule 215. [R336.1215(5)] b. Administrative Amendments made pursuant to Rule 216(1)(a)(i)-(iv). [R336.1216(1)(b)(iii)] c. Administrative Amendments made pursuant to Rule 216(1)(a)(v) until the amendment has been approved by the department. [R336.1216(1)(c)(iii)] d. Minor Permit Modifications made pursuant to Rule 216(2). [R336.1216(2)(f)] e. State-Only Modifications made pursuant to Rule 216(4) until the changes have been approved by the department. [R336.1216(4)(e)]

29. Expiration of this ROP 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 ROP, but the department fails to take final action before the end of the ROP term, the existing ROP does not expire until the renewal is issued or denied, and the permit shield shall extend beyond the original ROP term until the department takes final action. [R336.1217(1)(c), R336.1217(1)(a)]

Formatted: Don't adjust space between Latin and Asian text Revisions15B

30. For changes to any process or process equipment covered by this ROP that do not require a revision of the ROP pursuant to Rule 216, the permittee must comply with Rule 215. [R336.1215, R336.1216]

31. A change in ownership or operational control of a stationary source covered by this ROP shall be made pursuant to Rule 216(1). [R336.1219(2)]

32. For revisions to this ROP, an administratively complete application shall be considered timely if it is received by the department in accordance with the time frames specified in Rule 216. [R336.1210(9)]

Page 8 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

33. Pursuant to Rule 216(1)(b)(iii), Rule 216(2)(d) and Rule 216(4)(d), after a change has been made, and until the department takes final action, the permittee shall comply with both the applicable requirements governing the change and the ROP terms and conditions proposed in the application for the modification. During this time period, the permittee may choose to not comply with the existing ROP terms and conditions that the application seeks to change. However, if the permittee fails to comply with the ROP terms and conditions proposed in the application during this time period, the terms and conditions in the ROP are enforceable. [R336.1216(1)(c)(iii), R336.1216(2)(d), R336.1216(4)(d)]

Formatted: Don't adjust space between Latin and Asian text Reopenings16B

34. A ROP 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 ROP, but not if the effective date of the new applicable requirement is later than the ROP expiration date. [R336.1217(2)(a)(i)] b. If additional requirements pursuant to Title IV of the CAA become applicable to this stationary source. [R336.1217(2)(a)(ii)] c. If the department determines that the ROP contains a material mistake, information required by any applicable requirement was omitted, or inaccurate statements were made in establishing emission limits or the terms or conditions of the ROP. [R336.1217(2)(a)(iii)] d. If the department determines that the ROP must be revised to ensure compliance with the applicable requirements. [R336.1217(2)(a)(iv)]

Formatted: Don't adjust space between Latin and Asian text Renewals17B

35. For renewal of this ROP, 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 ROP. [R336.1210(7)]

Formatted: Don't adjust space between Latin and Asian text Stratospheric18B Ozone Protection

36. If the permittee is subject to Title 40 of the Code of Federal Regulations (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.

37. 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, Subpart 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 Hydrochlorofluorocarbon-22 refrigerant.

Page 9 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Formatted: Don't adjust space between Latin and Asian text Risk19B Management Plan

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

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

40. 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.

41. 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 Rule 213(4)(c). [40 CFR Part 68]

Formatted: Don't adjust space between Latin and Asian text Emission20B Trading

42. Emission averaging and emission reduction credit trading are allowed pursuant to any applicable interstate or regional emission trading program that has been approved by the Administrator of the USEPA as a part of Michigan’s State Implementation Plan. Such activities must comply with Rule 215 and Rule 216. [R336.1213(12)]

Formatted: Don't adjust space between Latin and Asian text Permit21B To Install (PTI)

43. The process or process equipment included in this permit shall not be reconstructed, relocated, or modified unless a PTI authorizing such action is issued by the department, except to the extent such action is exempt from the PTI requirements by any applicable rule.2 [R336.1201(1)]

44. The department may, after notice and opportunity for a hearing, revoke PTI terms or conditions if evidence indicates the process or process equipment is not performing in accordance with the terms and conditions of the PTI or is violating the department’s rules or the CAA.2 [R336.1201(8), Section 5510 of Act 451, PA 1994]

45. The terms and conditions of a PTI shall apply to any person or legal entity that now or hereafter owns or operates the process or process equipment at the location authorized by the PTI. If a new owner or operator submits a written request to the department pursuant to Rule 219 and the department approves the request, this PTI will be amended to reflect the change of ownership or operational control. The request must include all of the information required by Subrules (1)(a), (b) and (c) of Rule 219. The written request shall be sent to the appropriate AQD District Supervisor, MDEQ.2 [R336.1219]

Page 10 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

46. If the installation, reconstruction, relocation, or modification of the equipment for which PTI terms and conditions have been approved has not commenced within 18 months, or has been interrupted for 18 months, the applicable terms and conditions from that PTI shall become void unless otherwise authorized by the department. Furthermore, the person to whom that PTI was issued, or the designated authorized agent, shall notify the department via the Supervisor, Permit Section, MDEQ, AQD, P.O. Box 30260, Lansing, MI 48909, if it is decided not to pursue the installation, reconstruction, relocation, or modification of the equipment allowed by the terms and conditions from that PTI.2 [R336.1201(4)]

Formatted: Don't adjust space between Latin and Asian text 22B Alternative Operating Scenarios

47. The permittee shall maintain contemporaneous records at the facility of any changes from one operating scenario to another. This includes recording in a log the scenario under which it is operating and any additional information associated with the scenario in question, including, but not limited to: batch records, fuel records, operating schedule, or process records. [R336.1213(8)(a)]

Footnotes: 1This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 2This condition is federally enforceable and was established pursuant to Rule 201(1)(a).

Page 11 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Formatted: Don't adjust space between Latin B.2B SOURCE-WIDE CONDITIONS and Asian text

Part B outlines the Source-Wide Terms and Conditions that apply to this stationary source. The permittee is subject to these special conditions for the stationary source in addition to the general conditions in Part A and any other terms and conditions contained in this ROP.

The permittee shall comply with all specific details in the special conditions and the underlying applicable requirements cited. If a specific condition type does not apply to this source, NA (not applicable) has been used in the table. If there are no Source-Wide Conditions, this section will be left blank.

This table also includes REPORTING REQUIREMENTS and LIME MANUFACTURING MACT REQUIREMENTS referenced in other tables in this permit for the purpose of conciseness.

Page 12 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

B. SOURCE-WIDE CONDITIONS

PROCESS AND CONTROL EQUIPMENT

FG-FACILITY - The conditions listed in this table incorporate requirements from Table FG-FACILITY of Permit to Install #26-04, including all process equipment at the facility including equipment covered by other permits, grandfathered equipment, and exempt equipment. This table also includes REPORTING REQUIREMENTS and LIME MANUFACTURING MACT REQUIREMENTS referenced in other tables in this permit for the purpose of conciseness. {Permit to Install #26-04, 40 CFR 52.21, 40 CFR 60 Subpart HH, 40 CFR 63 Subpart AAAAA}

I. EMISSION LIMITS

Pollutant Limit Time Period/ Equipment Monitoring/ Underlying Operating Testing Method Applicable Scenario Requirements

1. Visible 1. Visible emissions from the process Test Protocol FG-FACILITY Method 9 R336.1301 Emissions equipment portions of FG-FACILITY 40 CFR 60.340 (not otherwise covered in this permit) shall not exceed 10 percent opacity.2

2. Visible 2. There shall be no visible emissions Test Protocol FG-FACILITY Method 9 R336.1301 Emissions from buildings that contain process 40 CFR 60.340 stone or coal handling equipment.2

The Standards of Performance for Lime Manufacturing Plants, 40 CFR Part 60 Subpart HH, were issued and published in the Federal Register on April 26, 1984. The National Emission Standards for Hazardous Air Pollutants for Lime Manufacturing Plants, 40 CFR Part 63 Subpart AAAAA, were issued and published in the Federal Register on January 5, 2004.

II. MATERIAL LIMITS

III. PROCESS OR OPERATIONAL RESTRICTIONS

1. The permittee shall not operate FG-FACILITY unless the AQD District Supervisor has approved a plan that describes how emissions will be minimized during startup(s), shutdown(s), and malfunction(s). The plan shall incorporate procedures recommended by the equipment manufacturer as well as incorporating standard industry practices. Unless notified by the District Supervisor within 30 business days after plan submittal, the plan shall be deemed approved.2 [R336.1911, R336.1912, 40 CFR 63.7100(e), 40 CFR 63.6(e)(3), 40 CFR 63.10(d)(5)]

2. The permittee shall not operate FG-FACILITY unless the AQD District Supervisor has approved a written Operations, Maintenance, and Monitoring (OM&M) plan. The plan shall incorporate procedures recommended by the equipment manufacturer as well as incorporating standard industry practices. Unless notified by the District Supervisor within 30 business days after plan submittal, the plan shall be deemed approved.2 [R336.1911, R336.1912, 40 CFR 63.7100(d)]

3. See LIME MANUFACTURING MACT REQUIREMENTS below. [40 CFR 63 Subparts AAAAA and A]

Page 13 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

IV. DESIGN OR EQUIPMENT PARAMETERS

V. TESTING AND SAMPLING

1. See LIME MANUFACTURING MACT REQUIREMENTS below. [40 CFR 63 Subparts AAAAA and A]

VI. MONITORING AND RECORDKEEPING

1. The permittee shall keep a record of calculations determining the total amount of limestone processed for each calendar month and total tons of limestone processed for the most recent 12-month rolling time period as determined at the end of each calendar month. The records shall be kept in a format acceptable to the AQD District Supervisor.2 [R336.1205(3), 40 CFR 52.21(c) & (d)]

2. The permittee shall conduct monthly visible emission checks on all process stone handling operations, buildings and/or any vents. The frequency of these checks may decrease as allowed in 40 CFR 63 Subpart AAAAA.2 [40 CFR 52.21(c) & (d)]

3. See LIME MANUFACTURING MACT REQUIREMENTS below. [40 CFR 63 Subparts AAAAA and A]

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. See Appendix 8. [R336.1213(3)(c)(ii)]

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. See Appendix 8. The report shall be postmarked or received by the appropriate AQD District Office by March 15 for the reporting period July 1 to December 31 and by September 15 for the reporting period January 1 to June 30. [R336.1213(3)(c)(i)]

3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. See Appendix 8. The report shall be postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. [R336.1213(4)(c)]

4. See LIME MANUFACTURING MACT REQUIREMENTS below. [40 CFR 63 Subparts AAAAA and A]

VIII. STACK OR VENT RESTRICTIONS

IX. LIME MANUFACTURING MACT REQUIREMENTS

1. The permittee shall comply with all applicable requirements of the National Emission Standards for Hazardous Air Pollutants for Lime Manufacturing Plants as specified in the Standards. These include General Provisions, Emission Limitations, General Compliance Requirements, Testing and Initial Compliance Requirements, Continuous Compliance Requirements, Notifications, Reports, and Records, and Other Requirements and Information. [40 CFR 63.7140, 40 CFR 63 Subparts AAAAA and A]

Page 14 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

X. NSPS Y REQUIREMENTS Formatted: Underline 1. The permittee shall comply with all the applicable requirements of the New Source Performance Standard for Coal Preparation and Processing Plants (NSPS Subpart Y) as specified in the Standards. These include General Provisions, Emission Limits, Recordkeeping and Reporting Requirements. [40 CFR 60 Subparts Y and A] Formatted: Font: 9 pt, Bold

XI. OTHER REQUIREMENTS

Footnotes: 1This condition is state only enforceable and was established pursuant to Rule 201(1)(b). 2This condition is federally enforceable and was established pursuant to Rule 201(1)(a).

Page 15 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Formatted: Don't adjust space between Latin C.3B EMISSION UNIT CONDITIONS and Asian text Part C outlines terms and conditions that are specific to individual emission units listed in the Emission Unit Summary Table. The permittee is subject to the special conditions for each emission unit in addition to the General Conditions in Part A and any other terms and conditions contained in this ROP.

The permittee shall comply with all specific details in the special conditions and the underlying applicable requirements cited. If a specific condition type does not apply, NA (not applicable) has been used in the table. If there are no conditions specific to individual emission units, this section will be left blank.

Formatted: Don't adjust space between Latin and Asian text EMISSION23B UNIT SUMMARY TABLE The descriptions provided below are for informational purposes and do not constitute enforceable conditions.

Emission Unit ID Emission Unit Description Stack Identification

EU-STONE HANDLING Stone Handling - Raw limestone is unloaded to a stacking conveyor and NA stockpiled. Stone is then reclaimed by vibrating under pile feeders and moved by conveyor belt to a screen. Screened stone is then conveyed to the kiln preheater via conveyor belt. Limestone pile fugitive dust emissions are included. {Permit to Install #26-04, 40 CFR 52.21}

EU-COAL HANDLING Coal Handling – Unloading, reloading, conveyors, coal and petroleum coke NA storage pile fugitive emissions. {Permit to Install #26-04}

EU-COAL SILO Coal Silo (Baghouse 191) – Coal and petroleum coke silos which are controlled SV-1 (BAGHOUSE 191) by a bin vent dust collector and exhausted within a building. {Permit to Install #26-04}

EU-KILN#1 Kiln #1 – Limestone enters a rotary kiln via a ram style preheater. The stone is SV-2 heated as it travels through the kiln. The lime then enters a counterflow Neimis style cooler. Exhaust gas particulate from the preheater, cooler, and kiln is controlled by a fabric filter dust collector using modular baghouse sections. This table includes requirements from 40 CFR Part 63 Subpart AAAAA, National Emission Standards for Hazardous Air Pollutants for Lime Manufacturing Plants. {Permit to Install #26-04, 40 CFR 60 Subpart HH, 40 CFR 63 Subpart AAAAA, 40 CFR 52.21}

EU-DUST HANDLING Dust Handling (Baghouse 188) – Lime dust collected from the kiln baghouse is SV-3 (BAGHOUSE 188) conveyed through screw conveyors to the dust silo via the dust silo elevator. The screw conveyor and dust silo are controlled by a fabric filter dust collector. {Permit to Install #26-04, 40 CFR 52.21}

EU-DUST LOADING Dust Loading (Baghouse 189) – Truck loading of lime dust (collected from the SV-11 (BAGHOUSE 189) lime kiln baghouse) which is controlled by a fabric filter dust collector. {Permit to Install #26-04, 40 CFR 52.21}

Page 16 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Emission Unit ID Emission Unit Description Stack Identification

EU-PRODUCT Product Loading (Baghouse 161) – Dry lime is loaded into trucks via a loading SV-9 LOADING (BAGHOUSE spout. The truck loader is controlled by a fabric filter dust collector. 161) {Permit to Install #26-04, 40 CFR 52.21}

EU-PRODUCT Product Loading 2 (Baghouse 162) – Dry lime is loaded into trucks via a SV-10 LOADING 2 loading spout. The truck loader is controlled by a fabric filter dust collector. (BAGHOUSE 162) {Permit to Install #26-04, 40 CFR 52.21}

EU-DUST LOADING Dust Loading Wet – Lime dust is conveyed into a pug mill and fresh water is WET mixed to produce a wet mixture that is then loaded into trucks. {Permit to Install #26-04}

EU-BAGHOUSE 133 Baghouse 133 – Lime product from the kiln discharge elevator and/or the lime SV-4 product sizing operation are conveyed to the kiln run silo. The lime kiln discharge elevator head, the feed conveyor from the lime kiln discharge elevator, the feed conveyor from the lime sizing operation, and the kiln run silo are controlled by a fabric filter dust collector. {Permit to Install #26-04, 40 CFR 52.21}

EU-BAGHOUSE 132 Baghouse 132 – Lime product is conveyed to the crusher infeed elevator, SV-5 crushed to size and discharged from the crusher to the product silo elevator. The crushed product may be returned to the kiln run silo conveyor. The feed conveyor from the kiln run silos, kiln run silo feeder 1 & 2, sizing elevator, and the oversized product crusher are controlled by a fabric filter dust collector. {Permit to Install #26-04, 40 CFR 52.21}

EU-BAGHOUSE 131 Baghouse 131 – Lime product from the kiln product cooler is discharged via SV-6 conveyor to the kiln discharge elevator or to the kiln run silo conveyor. The product cooler discharge to conveyor, the Nemis-style lime cooler discharge, the lime cooler discharge conveyor, the lime elevator boot and the lime core bin vent are controlled by a fabric filter dust collector. {Permit to Install #26-04, 40 CFR 52.21}

EU-BAGHOUSE 141 Baghouse 141 – Lime product from the kiln discharge elevator and/or the lime SV-7 product elevator is sized and sent to product silos prior to being loaded into rail cars and/or trucks. The lime screening operation, the lime product elevator head, the lime product silos, the feed conveyor from the kiln discharge elevator, and the feed conveyor from the screening operation are controlled by a fabric filter dust collector. {Permit to Install #26-04, 40 CFR 52.21}

EU-BAGHOUSE 163 Baghouse 163 – Lime product is discharged from the product silos by feeders to SV-8 the rail car loading system. The product silo feeders and the railcar loading spout are controlled by a fabric filter dust collector. {Permit to Install #26-04, 40 CFR 52.21}

EU-HAULING Hauling – Fugitive emissions from the vehicle traffic in the plant area. NA Formatted: Font: 9 pt {Permit to Install #26-04, 40 CFR 52.21} Formatted: Font: 9 pt

EU-AUXENGINE Auxiliary Engine – Any reciprocating internal combustion engine (RICE) subject NA Formatted: Font: 9 pt, Not Bold to the RICE NESHAP found in 40 CFR 63 Subpart ZZZZ. This includes the 68.5 Formatted: Font: 9 pt hp non-emergency compression ignition engine. {40 CFR 63.6580} Formatted: Font: 9 pt Formatted: Font: Italic Page 17 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Emission Unit ID Emission Unit Description Stack Identification

EU- Coal Pre-Crusher – The coal pre-crusher is an attachment to the existing coal NA Formatted: Font: 9 pt COALPRECRUSHER chute. The chute connects at the top and bottom of the pre-crusher via a sealed Formatted: Font: 9 pt flange. {R 336.1290(a)(ii)A), 40 CFR 60.250} EU-BAGHOUSE 231 Baghouse 231 – Lime product from the kiln discharge elevator and/or the lime SV-12 Formatted: Font: 8 pt product sized operation are conveyed to the kiln run silo. The lime kiln discharge Font: 9 pt, Italic elevator head, the feed conveyor from the lime kiln discharge elevator, the feed Formatted: conveyor from the lime sizing operation, and the kiln run silo are controlled by a Formatted: Font: (Default) Arial, 9 pt fabric filter dust collector. {R 336.1284(k), R 336.1331} Formatted: Font: (Default) Arial, 9 pt Changes to the equipment described in this table are subject to the requirements of R336.1201, except as allowed by R336.1278 to R336.1290.2 Formatted: Font: 8 pt Formatted: Font: (Default) Arial, 9 pt

Page 18 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Formatted: Don't adjust space between Latin and Asian text Table24B E-1.1 EU-KILN#1 EMISSION UNIT CONDITIONS

PROCESS AND CONTROL EQUIPMENT

EU-KILN#1 – Limestone enters a rotary kiln via a ram style preheater. The stone is heated as it travels through the kiln. The lime then enters a counterflow Neimis style cooler. Exhaust gas particulate from the preheater, cooler, and kiln is controlled by a fabric filter dust collector using modular baghouse sections. This table includes requirements from 40 CFR Part 63 Subpart AAAAA, National Emission Standards for Hazardous Air Pollutants for Lime Manufacturing Plants. {Permit to Install #26-04, 40 CFR 52.21, 40 CFR 60 Subpart HH, 40 CFR 63 Subpart AAAAA}

FLEXIBLE GROUP ID: NA

I. EMISSION LIMITS

Pollutant Limit Time Period / Operating Equipment Monitoring / Underlying Scenario Testing Method Applicable Requirements

1. PM10 1. 7.5 pounds per hour.2 Test Protocol EU-KILN#1 GC 13, 14, 15 40 CFR 52.21(j), R336.1205, R336.1331

2. PM10 2. 0.1 pounds per ton of Test Protocol EU-KILN#1 GC 13, 14, 15 40 CFR 52.21(j), stone feed.2 R336.1205, R336.1331

3. PM10 3. 29.2 tons.2 12-month rolling time period EU-KILN#1 GC 13, 14, 15 40 CFR 52.21(j), R336.1205, R336.1331

4. PM 4. PM emissions must not Test Protocol EU-KILN#1 40 CFR 63.7112, 40 CFR exceed 0.10 pounds per ton 40 CFR 63.7(e)(1) 63.7090(a) of stone feed.

5. NOx 5. 132.6 pounds per hour Test Protocol / EU-KILN#1 GC 13, 14, 15 40 CFR 52.21(j), (this limit was based upon 24-hour rolling average as R336.1205 1.83 pounds per ton of stone determined each hour by feed).2 CEMS

6. NOx 6. 532 tons.2 12-month rolling time period EU-KILN#1 GC 13, 14, 15 40 CFR 52.21(j), R336.1205

7. SO2 7. 60.2 pounds per hour Test Protocol / EU-KILN#1 GC 13, 14, 15 40 CFR 52.21(j), (this limit was based upon monthly basis R336.1205 0.83 pounds per ton of stone feed).2

Page 19 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Pollutant Limit Time Period / Operating Equipment Monitoring / Underlying Scenario Testing Method Applicable Requirements

8. SO2 8. 242 tons.2 12-month rolling time period EU-KILN#1 GC 13, 14, 15 40 CFR 52.21(j), R336.1205

9. CO 9. 113.2 pounds per hour Test Protocol / EU-KILN#1 GC 13, 14, 15 40 CFR 52.21(j), (this limit was based upon 24-hour rolling average as R336.1205 1.56 pounds per ton of stone determined each hour by feed.2 CEMS

10. CO 10. 456 tons.2 12-month rolling time period EU-KILN#1 GC 13, 14, 15 40 CFR 52.21(j), R336.1205

11. Visible 11. Visible emissions from 6-minute average EU-KILN#1 Continuous 40 CFR 52.21(j), Emissions EU-KILN#1 shall not exceed Opacity R336.1301, 10 percent opacity as Monitoring System measured by the Continuous 40 CFR 60 Opacity Monitoring System Subpart HH (COMS). This opacity limit shall not include periods of startup when using No. 2 Fuel Oil and/or propane and no stone feed.2

II. MATERIAL LIMITS

1. The permittee shall not process more than 584,000 tons of limestone feed in EU-KILN#1 per year based upon a 12-month rolling time period as determined at the end of each calendar month.2 [40 CFR 52.21(c) & (d)]

2. The permittee shall only burn No. 2 Fuel Oil, propane, coal, or coal combined with petroleum coke in EU- KILN#1.2 [40 CFR 52.21(j)]

3. The combined coal and petroleum coke sulfur content of the fuel shall not exceed 2.5% by weight based upon a monthly average.2 [R336.1205, 40 CFR 52.21(j)]

Page 20 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

III. PROCESS OR OPERATIONAL RESTRICTIONS

1. The permittee shall comply with all provisions of the federal Standards for Performance for New Stationary 2 Sources as specified in 40 CFR Part 60 Subparts HH and A, as they apply to EU-KILN#1. [40 CFR 60 Subpart HH]

2. The permittee shall not operate EU-KILN#1 during periods of startup, while bypassing the baghouse unless the kiln is burning only No. 2 fuel oil or propane and there is no stone feed to EU-KILN#1.2 [R336.1205, R336.1224, R336.1225]

3. The permittee shall not operate EU-KILN#1 unless an acceptable plan that describes how emissions will be minimized during all startups, shutdowns, and malfunctions has been submitted to the AQD District Supervisor. The plan shall incorporate procedures recommended by the equipment manufacturer as well as incorporating standard industry practices.2 [R336.1911, R336.1912, 40 CFR 52.21(j)]

4. The permittee shall operate EU-KILN#1 with a fabric filter collection system which is installed, maintained, and operated in a satisfactory manner. Bypassing of the collection system will only be allowed during startup on No. 2 fuel oil with no stone feed to the kiln.2 [R336.1224, R336.1225, R336.1205, R336.1910]

5. The permittee shall not operate EU-KILN#1 unless the preheater is installed, maintained, and operated in a satisfactory manner.2 [40 CFR 52.21(j)]

6. See TABLE B. SOURCE WIDE CONDITIONS, IX. LIME MANUFACTURING MACT REQUIREMENTS. [40 CFR 63 Subparts AAAAA and A]

IV. DESIGN OR EQUIPMENT PARAMETERS

V. TESTING AND SAMPLING

1. Within three years of the effective date of this permit, the permittee shall conduct emissions tests for PM and PM10 to determine compliance with the EMISSION LIMITS above. The testing shall include concurrent measurement of stone feed rate to EU-KILN#1. Performance tests shall be conducted according to procedures and methods specified or approved by the AQD. Not less than 30 days prior to testing, a complete testing plan shall be submitted to the AQD. The testing plan must be approved by the AQD prior to testing. Verification of the emission rates includes the submittal of a complete report of the test results to the AQD within 60 days following the last date of testing. [R336.1201(3)]

2. See TABLE B. SOURCE WIDE CONDITIONS, IX., LIME MANUFACTURING MACT REQUIREMENTS. [40 CFR 63 Subparts AAAAA and A]

Page 21 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

VI. MONITORING AND RECORDKEEPING

1. The permittee shall monitor and record visible emissions from EU-KILN#1 on a continuous basis. The continuous opacity monitoring system (COMS) shall be installed, calibrated, maintained, and operated in accordance with the procedures set forth in 40 CFR Subpart AAAAA, 40 CFR 60.13, and Performance Specification 1 of 40 CFR Part 60 Appendix B.2 [R336.1205, 40 CFR 52.21(j), 40 CFR 60.13, 40 CFR 63 Subparts AAAAA and A]

2. The permittee shall perform an annual audit of the COMS using the procedures set forth in USEPA publication 450/4-92-010, “Performance Audits Procedures for Opacity Monitors”, or a procedure acceptable to AQD. Within 30 days after the completion of the audit, the results of the annual audit shall be submitted to the Air Quality Division. [R336.1201(3)]

3. The permittee shall monitor and record NOx and CO emissions from EU-KILN#1 on a continuous basis. The continuous emissions monitoring systems (CEMS) shall be installed, calibrated, maintained, and operated in accordance with the procedures set forth in appropriate Performance Specifications of 40 CFR Part 60 Appendix B and 40 CFR 60.13.2 [R336.1205, 40 CFR 52.21(j)]

4. Each calendar quarter, the permittee shall perform the Quality Assurance Procedures of the CEMS set forth in Appendix F of 40 CFR Part 60. Within 30 days following the end of each calendar quarter, the permittee shall submit the results to the Air Quality Division in the format of the Data Assessment Report (Figure 1, Appendix F). [R336.1202(3)]

5. The permittee shall keep, in a satisfactory manner, 24-hour rolling average pound per hour NOx and CO emission records and 12-month rolling time period NOx and CO emission records for EU-KILN#1.2 [R336.1205, 40 CFR 52.21(j)]

6. The permittee shall install and maintain a device to determine the daily amount of fuel consumed by EU- KILN#1.2 [R336.1205, 40 CFR 52.21(j)]

7. The permittee shall keep a written record of the following information for EU-KILN#1 in a format acceptable to the AQD District Supervisor for the purpose of compliance demonstration:2 [R336.1205, R336.1224, R336.1225, R336.1901, R336.1910]

a. Daily recording of the pressure drop across the fabric filter using the pressure transmitter monitoring system on any days that the Kiln is in operation.

b. Monthly calculations, determining the pounds per hour emission rate based upon a monthly average for SO2.

c. Calculations determining the mass emission rate in tons per year for SO2 based upon a 12-month rolling time period as determined at the end of each calendar month using the SO2 removal efficiency as determined by testing.

d. Daily records of the coal/petroleum coke samples (date, time, weight) and the amount of No. 2 Fuel Oil, propane, and/or coal/petroleum coke used.

e. Records determining the combined average monthly sulfur content of the coal and petroleum coke, as determined in accordance with ASTM methods or alternative methods approved by the District Supervisor.

f. The hours of operation for the lime kiln per month and 12 month rolling time period as determined at the end of each month.

g. The hours of operation per month and 12-month rolling time period which the kiln was operated during startup, shutdown, and upset conditions.

Page 22 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

8. See TABLE B. SOURCE WIDE CONDITIONS, IX., LIME MANUFACTURING MACT REQUIREMENTS. [40 CFR 63 Subparts AAAAA and A]

VII. REPORTING

1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. See Appendix 8. [R336.1213(3)(c)(ii)]

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A and 40 CFR 63.7131. See Appendix 8. The report shall be postmarked or received by the appropriate AQD District Office by March 15 for the reporting period July 1 to December 31 and by September 15 for the reporting period January 1 to June 30. [R336.1213(3)(c)(i), 40 CFR 63.7131]

4. In accordance with 40 CFR 60.7(c) and (d), the permittee shall submit two copies of an Excess Emission Report (EER) and/or the Summary Report in an acceptable format to the Air Quality Division within 30 days following the end of each calendar quarter for NOx, CO, and Opacity. The Summary Report shall follow the format of Figure 1 in 40 CFR 60.7(d). [R336.1201(3)]

5. See TABLE B. SOURCE-WIDE CONDITIONS, IX., LIME MANUFACTURING MACT REQUIREMENTS. [40 CFR 63 Subparts AAAAA and A]

VIII. STACK OR VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted.

Stack or Vent ID Minimum Height Above Maximum Diameter Applicable Requirement Ground Level

1 1 40 CFR 52.21 (c) & (d), R336.1225, SV-2 120 feet 82 inches R336.1901

IX. LIME MANUFACTURING MACT REQUIREMENTS

1. See TABLE B. SOURCE WIDE CONDITIONS, IX., LIME MANUFACTURING MACT REQUIREMENTS. [40 CFR 63 Subparts AAAAA and A]

X. OTHER REQUIREMENTS

Footnotes:

Page 23 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

1This condition is state-only enforceable and was established pursuant to Rule 201(1)(b). 2This condition is federally enforceable and was established pursuant to Rule 201(1)(a).

Page 24 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Formatted: Don't adjust space between Latin and Asian text Table25B E-1.2 EU-HAULING EMISSION UNIT CONDITIONS

PROCESS AND CONTROL EQUIPMENT

EU-HAULING – Fugitive emissions from the vehicle traffic in the plant area. {Permit to Install #26-04, 40 CFR 52.21}

FLEXIBLE GROUP ID: NA

I. EMISSION LIMITS

1. Visible emissions from all wheel loaders and all truck traffic, operated in conjunction with EU-HAULING, shall not exceed 5 percent opacity.2 [R336.1301, 40 CFR 52.21(c) & (d)]

II. MATERIAL LIMITS

III. PROCESS OR OPERATIONAL RESTRICTIONS

1. The permittee shall not operate EU-HAULING unless the program for continuous fugitive emissions control for all plant roadways, the plant yard, all material storage piles, and all material handling operations specified in Appendix 9 has been implemented and is maintained.2 [R336.1371, R336.1901]

IV. DESIGN OR EQUIPMENT PARAMETERS

V. TESTING AND SAMPLING

VI. MONITORING AND RECORDKEEPING

VII. REPORTING

1. See TABLE B. SOURCE-WIDE CONDITIONS, VII. REPORTING. [R336.1213(3)(c)(ii), R336.1213(3)(c)(i), R336.1213(4)(c)]

Page 25 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

VIII. STACK OR VENT RESTRICTIONS

IX. OTHER REQUIREMENTS

Footnotes: 1This condition is state-only enforceable and was established pursuant to Rule 201(1)(b). 2This condition is federally enforceable and was established pursuant to Rule 201(1)(a).

Page 26 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Formatted: Don't adjust space between Latin and Asian text Table26B E-1.3 EU-STONE HANDLING EMISSION UNIT CONDITIONS

PROCESS AND CONTROL EQUIPMENT

EU-STONE HANDLING – Raw limestone is unloaded to a stacking conveyor and stockpiled. Stone is then reclaimed by vibrating underpile feeders and moved by conveyor belt to a screen. Screened stone is then conveyed to the kiln preheater via conveyor belt. Limestone pile fugitive dust emissions are included. {Permit to Install #26-04, 40 CFR 52.21}

FLEXIBLE GROUP ID: NA

I. EMISSION LIMITS

1. Visible emissions from each of the material storage piles maintained under EU-STONE HANDLING shall not exceed 5 percent opacity.2 [R336.1301, 40 CFR 52.21(c) & (d)]

II. MATERIAL LIMITS

III. PROCESS OR OPERATIONAL RESTRICTIONS

1. The permittee shall not operate EU-STONE HANDLING unless the program for continuous fugitive emissions control for all plant roadways, the plant yard, all material storage piles, and all material handling operations specified in Appendix 9 has been implemented and is maintained.2 [R336.1371, R336.1901]

IV. DESIGN OR EQUIPMENT PARAMETERS

V. TESTING AND SAMPLING

VI. MONITORING AND RECORDKEEPING

VII. REPORTING

1. See TABLE B. SOURCE-WIDE CONDITIONS, VII. REPORTING. [R336.1213(3)(c)(ii), R336.1213(3)(c)(i), R336.1213(4)(c)]

Page 27 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

VIII. STACK OR VENT RESTRICTIONS

IX. OTHER REQUIREMENTS

Footnotes: 1This condition is state-only enforceable and was established pursuant to Rule 201(1)(b). 2This condition is federally enforceable and was established pursuant to Rule 201(1)(a).

Page 28 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Formatted: Don't adjust space between Latin D.4B FLEXIBLE GROUP CONDITIONS and Asian text Part D outlines the terms and conditions that apply to more than one emission unit. The permittee is subject to the special conditions for each flexible group in addition to the General Conditions in Part A and any other terms and conditions contained in this ROP.

The permittee shall comply with all specific details in the special conditions and the underlying applicable requirements cited. If a specific condition type does not apply, NA (not applicable) has been used in the table. If there are no special conditions that apply to more than one emission unit, this section will be left blank.

Formatted: Don't adjust space between Latin and Asian text FLEXIBLE27B GROUP SUMMARY TABLE The descriptions provided below are for informational purposes and do not constitute enforceable conditions.

Flexible Group ID Flexible Group Description Stack Identification

Formatted Table FG-BAGHOUSES EU-DUST HANDLING, EU-BAGHOUSE 131, SV-1, SV-3, SV-4, SV-5, EU-BAGHOUSE 132, EU-BAGHOUSE 133, SV-6, SV-7, SV-8, SV-9, EU-BAGHOUSE 141, EU-BAGHOUSE 163, SV-10, SV-11, SV-12 EU-PRODUCT LOADING, EU-PRODUCT LOADING 2, EU-DUST LOADING, EU-BAGHOUSE 231

FG-NSPSY EU-COALPRECRUSHER NA Formatted: Font: 10 pt Formatted: Font: 10 pt Formatted: Font: 10 pt

FG-RICEMACT EU-AUXENGINE NA Formatted: Font: 10 pt Formatted: Font: 10 pt Formatted: Font: 10 pt

FG-R290 EU-COALPRECRUSHER NA

Page 29 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Formatted: Don't adjust space between Latin and Asian text Table28B F-1.1 FG-BAGHOUSES FLEXIBLE GROUP CONDITIONS

DESCRIPTION

Emission Unit IDs:

EU-DUST HANDLING (Baghouse 188), EU-BAGHOUSE 131, EU-BAGHOUSE 132, EU-BAGHOUSE 133, EU- BAGHOUSE 141, EU-BAGHOUSE 163, EU-PRODUCT LOADING (Baghouse 161), EU-PRODUCT LOADING 2 (Baghouse 162), EU-DUST LOADING (Baghouse 189). {Permit to Install #26-04, 40 CFR 52.21}

EU-BAGHOUSE 231 (Baghouse 231) {R 336.1284(k)} Formatted: Font: 8 pt

Pollution Control Equipment: Formatted: Font: 10 pt

Baghouses

I. EMISSION LIMITS

Pollutant Limit Time Period/ Equipment Monitoring/ Underlying Applicable Operating Testing Requirements Scenario Method

1. PM10 1. 0.014 lb/1000 lb.2 Test Protocol Baghouse 131 GC 13, 14, 15 40 CFR 52.21(j), 40 CFR 52.21(c) & (d), R336.1331

2. PM10 2. 0.44 lb/hr.2 Test Protocol Baghouse 131 GC 13, 14, 15 40 CFR 52.21(j), 40 CFR 52.21(c) & (d), R336.1331

3. PM10 3. 0.015 lb/1000 lb.2 Test Protocol Baghouse 132 GC 13, 14, 15 40 CFR 52.21(j), 40 CFR 52.21(c) & (d), R336.1331

4. PM10 4. 0.25 lb/hr.2 Test Protocol Baghouse 132 GC 13, 14, 15 40 CFR 52.21(j), 40 CFR 52.21(c) & (d), R336.1331

5. PM10 5. 0.006 lb/1000 lb.2 Test Protocol Baghouse 133 GC 13, 14, 15 40 CFR 52.21(j), 40 CFR 52.21(c) & (d), R336.1331

6. PM10 6. 0.13 lb/hr.2 Test Protocol Baghouse 133 GC 13, 14, 15 40 CFR 52.21(j), 40 CFR 52.21(c) & (d), R336.1331

Page 30 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Pollutant Limit Time Period/ Equipment Monitoring/ Underlying Applicable Operating Testing Requirements Scenario Method

7. PM10 7. 0.019 lb/1000 lb.2 Test Protocol Baghouse 141 GC 13, 14, 15 40 CFR 52.21(j), 40 CFR 52.21(c) & (d), R336.1331

8. PM10 8. 0.85 lb/hr.2 Test Protocol Baghouse 141 GC 13, 14, 15 40 CFR 52.21(j), 40 CFR 52.21(c) & (d), R336.1331

9. PM10 9. 0.009 lb/1000 lb.2 Test Protocol Baghouse 161 GC 13, 14, 15 40 CFR 52.21(j), 40 CFR 52.21(c) & (d), R336.1331

10. PM10 10. 0.04 lb/hr.2 Test Protocol Baghouse 161 GC 13, 14, 15 40 CFR 52.21(j), 40 CFR 52.21(c) & (d), R336.1331

11. PM10 11. 0.009 lb/1000 lb.2 Instantaneous Baghouse 162 GC 13, 14, 15 40 CFR 52.21(j), 40 CFR 52.21(c) & (d), R336.1331

12. PM10 12. 0.04 lb/hr.2 Test Protocol Baghouse 162 GC 13, 14, 15 40 CFR 52.21(j), 40 CFR 52.21(c) & (d), R336.1331

13. PM10 13. 0.011 lb/1000 lb.2 Instantaneous Baghouse 163 GC 13, 14, 15 40 CFR 52.21(j), 40 CFR 52.21(c) & (d), R336.1331

14. PM10 14. 0.19 lb/hr.2 Test Protocol Baghouse 163 GC 13, 14, 15 40 CFR 52.21(j), 40 CFR 52.21(c) & (d), R336.1331

15. PM10 15. 0.019 lb/1000 lb.2 Instantaneous Baghouse 188 GC 13, 14, 15 40 CFR 52.21(j), 40 CFR 52.21(c) & (d), R336.1331

16. PM10 16. 0.09 lb/hr.2 Test Protocol Baghouse 188 GC 13, 14, 15 40 CFR 52.21(j), 40 CFR 52.21(c) & (d), R336.1331

17. PM10 17. 0.019 lb/1000 lb.2 Instantaneous Baghouse 189 GC 13, 14, 15 40 CFR 52.21(j), 40 CFR 52.21(c) & (d), R336.1331

18. PM10 18. 0.09 lb/hr.2 Test Protocol Baghouse 189 GC 13, 14, 15 40 CFR 52.21(j), 40 CFR 52.21(c) & (d), R336.1331

Page 31 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Pollutant Limit Time Period/ Equipment Monitoring/ Underlying Applicable Operating Testing Requirements Scenario Method

2 19. PM 19. 0.10 lb/1000 lb. Test Protocol Baghouse 231 GC 13, 14, 15 R 336.1331 Formatted: Font: 9 pt, Bold

1920. 1920. Visible emissions from Test Protocol Baghouse 161 & Method 9 40 CFR 60.340, Formatted: Superscript Visible Baghouse 161 and Baghouse Baghouse 162 R336.1301 Formatted: Font: 9 pt Emissions 162 portions of FG- portions of FG- BAGHOUSES shall not exceed BAGHOUSES Formatted: Font: 9 pt 2 5 percent opacity. Formatted: Font: 9 pt

Formatted: Font: 9 pt, Not Bold

2021. 2021. Visible emissions from Test Protocol Each baghouse Method 9 40 CFR 60.340, Formatted: Font: 9 pt Visible each baghouse portion of FG- portion of FG- R336.1301 Emissions BAGHOUSES (except BAGHOUSES Baghouse 161 and Baghouse (except Baghouse 162) shall not exceed 10 161 and Baghouse percent.2 162)

The Standards of Performance for Lime Manufacturing Plants, 40 CFR Part 60 Subpart HH, were issued and published in the Federal Register on April 26, 1984.

II. MATERIAL LIMITS

III. PROCESS OR OPERATIONAL RESTRICTIONS

IV. DESIGN OR EQUIPMENT PARAMETERS

V. TESTING AND SAMPLING

VI. MONITORING AND RECORDKEEPING

1. The permittee shall monitor in a satisfactory manner the condition of dry filter particulate control system through visual inspection [or other program proposed by the permittee] on a weekly basis during operation. The permittee shall keep in a satisfactory manner records of visual inspections of the dry filter particulate control system which includes the dates and results of the inspections and the date and reasons for repairs.2 [R336.1331, 40 CFR 52.21 (c) & (d)]

VII. REPORTING

1. See TABLE B. SOURCE-WIDE CONDITIONS, VII., REPORTING. [R336.1213(3)(c)(ii), R336.1213(3)(c)(i), R336.1213(4)(c)]

Page 32 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

VIII. STACK OR VENT RESTRICTIONS

The exhaust gases from the stacks listed in the table below shall be discharged unobstructed vertically upwards to the ambient air unless otherwise noted.

Stack or Vent ID Minimum Height Above Maximum Diameter Applicable Requirement Ground Level

1 1 40 CFR 52.21 (c) & (d), R336.1225, SV-3 68 feet 7.5 inches R336.1901

1 1 40 CFR 52.21 (c) & (d), R336.1225, SV-4 106 feet 17 inches R336.1901

1 1 40 CFR 52.21 (c) & (d), R336.1225, SV-5 66 feet 14.5 inches R336.1901

1 1 40 CFR 52.21 (c) & (d), R336.1225, SV-6 66 feet 20 inches R336.1901

1 1 40 CFR 52.21 (c) & (d), R336.1225, SV-7 88.5 feet 24 inches R336.1901

1 1 40 CFR 52.21 (c) & (d), R336.1225, SV-8 82.0 feet 14 inches R336.1901

1 1 40 CFR 52.21 (c) & (d), R336.1225, SV-9 90.0 feet 7.5 inches R336.1901

1 1 40 CFR 52.21 (c) & (d), R336.1225, SV-10 90.0 feet 7.5 inches R336.1901

1 1 40 CFR 52.21 (c) & (d), R336.1225, SV-11 44.0 feet 7.5 inches R336.1901 Formatted Table

1 1 SV-12 115.5 feet 16.8 inches R 336.1901 Formatted: Superscript Formatted: Superscript

X. OTHER REQUIREMENTS Formatted: Font: 9 pt

Footnotes: 1This condition is state-only enforceable and was established pursuant to Rule 201(1)(b). Page 33 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

2This condition is federally enforceable and was established pursuant to Rule 201(1)(a). Formatted: Don't adjust space between Latin and Asian text

Page 34 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Table29B F-1.2 FG-NSPSY FLEXIBLE GROUP CONDITIONS

DESCRIPTION

Emission Unit IDs:

EU-COALPRECRUSHER (Coal Pre-Crusher). {40 CFR 60 Subpart Y} Formatted: Font: 8 pt, Italic

Pollution Control Equipment:

I. EMISSION LIMITS

Formatted Table Pollutant Limit Time Equipment Monitoring/ Underlying Applicable Period/Operating Testing Requirements Scenario Method Formatted: Font: 9 pt

1. PM 1. 0.023 gr/dscm (0.010 NA Coal Pre-Crusher NA 40 CFR 60.254 (b) Comment [AW2]: Note to MDEQ: Deleted 2 gr/dscf). this emission limitation because there is no mechanical vent associated with the coal pre- crusher (and therefore no PM emission 2. Visible 2. Visible emissions from Coal Test Protocol Coal Pre-Crusher NAMethod 9 40 CFR 60.254 (b)(1) limitation applies). Emissions Pre-Crusher shall not exceed 10 Formatted: Font: 9 pt percent opacity.2 Formatted: Font: 9 pt The Standards of Performance for Coal Preparation and Processing Plant, 40 CFR Part 60 Subpart Y, were issued and published in the Federal Formatted: Font: 9 pt Register on September 19, 1995 January 15, 1976 and most recently revised October 8, 2009. Formatted: Font: 9 pt, Not Bold, Font color: Black II. MATERIAL LIMITS

III. PROCESS OR OPERATIONAL RESTRICTIONS

IV. DESIGN OR EQUIPMENT PARAMETERS

V. TESTING AND SAMPLING

NA 1. Conduct initial performance test. Follow Method 9 procedures outlined in 40 CFR 60.257(a)(1)-(2). Initial performance test and subsequent Method 9 performance test results shall be submitted as required in 40 CFR 60.258(c) and (d).

2. Monitor visible emissions using daily, 15-second Method 22 visible emissions test and Method 9 observations within 45 operating days of when visible emissions are observed (if any). [40 CFR 60.255(f)(1)(i)]. Formatted: Font: 9 pt, Bold

Page 35 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

3. Conduct monthly visible emissions observations, using corrective maintenance if needed. [40 CFR Formatted: Font: 9 pt, Bold 60.255(f)(1)(ii)]. Font: Bold Formatted: 4. Conduct performance test using Method 9 of appendix A-4 at least once every five calendar years. [40 CFR Formatted: Numbered + Level: 1 + 60.255(f)(1)(iii)]. Numbering Style: 1, 2, 3, … + Start at: 1 + Alignment: Left + Aligned at: 0" + Tab after: 5. Utilize the test methods and procedures associated with determining compliance with the opacity standard 0.25" + Indent at: 0.25" requirement for fugitive coal dust sources. [40 CFR 60.257(a)(2)]. Formatted: Font: 9 pt, Bold

Formatted: Font: Bold 6. Utilize the test methods and procedures associated with visible emissions observations. [40 CFR 60.257(a)(3)]. Formatted: Numbered + Level: 1 + Numbering Style: 1, 2, 3, … + Start at: 1 + Alignment: Left + Aligned at: 0" + Tab after: VI. MONITORING AND RECORDKEEPING 0.25" + Indent at: 0.25"

1. The permittee shall maintain a logbook with the manufacturer’s recommended maintenance procedures and Formatted: Font: 9 pt, Bold the date and time of any maintenance and inspection activities. The permittee shall maintain records of the date Formatted: Font: 9 pt and time any visible emissions were observed. The permittee will also maintain records of the amount and type Formatted: List Paragraph, No bullets or of coal processed each calendar month, monthly certification that the dust suppressant systems were numbering operational when coal was processed and that manufacture recommendations were followed for all control 2 Formatted: Numbered + Level: 1 + systems. [40 CFR 60.2568(a)(1)-(3)] Numbering Style: 1, 2, 3, … + Start at: 1 + Alignment: Left + Aligned at: 0" + Tab after: 0.25" + Indent at: 0.25" VII. REPORTING Formatted: Font: 9 pt, Bold

1. The permittee will report periods where the 6-minute average opacity exceeded the applicable standard. [40 Formatted: Font: 9 pt CFR 60.258(b)(3)] Comment [AW3]: Note to MDEQ: Deleted 1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. [R 336.1213(3)(c)(ii)] these requirements because Graymont interprets the “coal preparation and processing plant” facility to consist of the coal pre-crusher 2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall only. No chemical stabilizers, water, or dust be postmarked or received by the appropriate AQD District Office by March 15 for reporting period July 1 to suppressant is applied to the coal pre-crusher December 31 and September 15 for reporting period January 1 to June 30. [R 336.1213(3)(c)(i)] as this is a sealed unit, nor are the measures recommended by the manufacturer’s specifications for the coal pre-crusher. 3. Annual certification of compliance pursuant to General Conditions 19 and 20 of Part A. The report shall be Therefore, Graymont has not included records postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. [R related to §60.258(a)(4) and (5) in its logbook. 336.1213(4)(c)] Comment [AW4]: Note to MDEQ: Citation should be 40 CFR 60.258(a)(1)-(3) VIII. STACK OR VENT RESTRICTIONS Formatted: Font: 9 pt, Bold NA Formatted: Font: 9 pt, Bold Formatted: Font: 9 pt, Bold IX. OTHER REQUIREMENTS Formatted: Font: 9 pt NA 1. The permittee shall comply with all applicable requirements of 40 CFR 60 Subpart A and Y.

Footnotes: 1This condition is state-only enforceable and was established pursuant to Rule 201(1)(b). 2This condition is federally enforceable and was established pursuant to Rule 201(1)(a). Formatted: Don't adjust space between Latin and Asian text

Page 36 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Table30B F-1.3 FG-RICEMACT FLEXIBLE GROUP CONDITIONS

DESCRIPTION

Emission Unit IDs:

EU-AUXENGINE (Auxiliary Engine). {40 CFR 63 Subpart ZZZZ} Formatted: Font: 8 pt, Bold, Italic

Pollution Control Equipment:

I. EMISSION LIMITS

II. MATERIAL LIMITS

III. PROCESS OR OPERATIONAL RESTRICTIONS

IV. DESIGN OR EQUIPMENT PARAMETERS

V. MAINTENANCE REQUIREMENTS

1. Permittee shall comply with maintenance limitations as listed in the standards. The permittee shall operate and maintain engine according the manufacturer’s instructions, minimize idle time and engine startup time, not to exceed 30 minutes. [40 CFR 63.6602 Table 2c, 40 CFR 63.6625(e), 40 CFR 63.6625(h)] Formatted: Font: 9 pt

VI. TESTING AND SAMPLING

VII. MONITORING AND RECORDKEEPING

1. The permittee shall maintain records of the maintenance conducted on the engine. [40 CFR 63.6655(e)] Formatted: Font: 9 pt

VIII. REPORTING

NA 1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. [R 336.1213(3)(c)(ii)]

Page 37 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

2. Semiannual reporting of monitoring and deviations pursuant to General Condition 23 of Part A. The report shall be postmarked or received by the appropriate AQD District Office by 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 General Conditions 19 and 20 of Part A. The report shall be postmarked or received by the appropriate AQD District Office by March 15 for the previous calendar year. [R 336.1213(4)(c)]

IX. STACK OR VENT RESTRICTIONS

X. OTHER REQUIREMENTS

NA 1. The permittee shall comply with all applicable provisions of 40 CFR 63 Subpart A and ZZZZ, i.e., the RICE MACT.

Page 38 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Table31B F-1.4 FG-R290 FLEXIBLE GROUP CONDITIONS

DESCRIPTION

Any emission unit that emits air contaminants and is exempt from the requirements of Rule 201 pursuant to Rules 278 and 290. Formatted: Font: Not Bold

Emission Unit IDs:

EU-COALPRECRUSHER (Coal Pre-Crusher), . {R 336.1290} Formatted: Font: 8 pt, Italic

Pollution Control Equipment:

I. EMISSION LIMITS

NA 1. Each emission unit that emits only noncarcinogenic volatile organic compounds or noncarcinogenic materials which are listed in Rule 122(f) as not contributing appreciably to the formation of ozone if the total uncontrolled or controlled emissions of air contaminants are not more than 1,000 or 500 pounds per month, respectively [R Formatted: Font: 9 pt 336.1290(a)(i)]

2. Each emissions unit that the total uncontrolled or controlled emissions of air contaminants are not more than 1,000 or 500 pounds per month, respectively, and all the following criteria listed below are met: [R 336.1290(a)(ii)] Formatted: Font: 9 pt

a. For noncarcinogenic air contaminants, excluding noncarcinogenic volatile organic compounds and noncarcinogenic materials which are listed in Rule 122(f) as not contributing appreciably to the formation of ozone, with initial threshold screening levels greater than or equal to 2.0 micrograms per cubic meter, the uncontrolled or controlled emissions shall not exceed 1,000 or 500 pounds per month, respectively. [R 336.1290(a)(ii)(A)] Formatted: Font: 9 pt b. For noncarcinogenic air contaminants, excluding noncarcinogenic volatile organic compounds and noncarcinogenic materials which are listed in Rule 122(f) as not contributing appreciably to the formation of ozone, with initial threshold screening levels greater than or equal to 0.04 microgram per cubic meter and less than 2.0 micrograms per cubic meter, the uncontrolled or controlled emissions shall not exceed 20 or 10 pounds per month, respectively. [R 336.1290(a)(ii)(B)] Formatted: Font: 9 pt c. For carcinogenic air contaminants with initial risk screening levels greater than or equal to 0.04 microgram per cubic meter, the uncontrolled or controlled emissions shall not exceed 20 or 10 pounds per month, respectively. [R 336.1290(a)(ii)(C)] Formatted: Font: 9 pt d. The emission unit shall not emit any air contaminants, excluding non-carcinogenic volatile organic compounds and noncarcinogenic materials which are listed in Rule 122(f) as not contributing appreciably to the formation of ozone, with an initial threshold screening level or initial risk screening level less than 0.04 microgram per cubic meter. [R 336.1290(a)(ii)(D)] Formatted: Font: 9 pt

3. Each emission unit that emits only noncarcinogenic particulate air contaminants and other air contaminants that are exempted under Rule 290(a)(i) and/or Rule 290(a)(ii), if all the following provisions are met: [R 336.1290(a)(iii)] Formatted: Font: 9 pt

a. The particulate emissions are controlled by an appropriately designed and operated fabric filter collector or an equivalent control system which is designed to control particulate matter to a concentration of less than or equal to 0.01 pound of particulate per 1,000 pounds of exhaust gases and which does not have an exhaust gas flow rate more than 30,000 actual cubic feet per minute. [R 336.1290(a)(iii)(A)] Formatted: Font: 9 pt b. The visible emissions from the emission unit are not more than 5 percent opacity in accordance with the methods contained in Rule 303. [R 336.1290(a)(iii)(B)] Formatted: Font: 9 pt

Page 39 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

c. The initial threshold screening level for each particulate air contaminant, excluding nuisance particulate, is more than 2.0 micrograms per cubic meter. [R 336.1290(a)(iii)(C)] Formatted: Font: 9 pt

Formatted: Font: Bold II. MATERIAL LIMITS

III. PROCESS OR OPERATIONAL RESTRICTIONS

NA 1. The provisions of Rule 290 apply to each emission unit that is operating pursuant to Rule 290. [R 336.1290] Formatted: Font: 9 pt

Formatted: Font: Bold

IV. DESIGN OR EQUIPMENT PARAMETERS

V. TESTING AND SAMPLING

VI. MONITORING AND RECORDKEEPING

1. The permittee shall maintain a description of the exempt process or process equipment, including the date of Formatted: Indent: Left: 0", First line: 0" installation, the specific exemption used by the process or process equipment, an analysis demonstrating that the R 336.1278 does not apply to the process or process equipment, and monthly emission and material processing records for the previous two years of operation. [R 336.1278a, R 336.1290(b), R 336.1278a(1)(a), R 336.1278a(1)(b), R Formatted: Font: 9 pt 336.1278a(1)(c), R 336.1290(c), R 336.1290 (d)]. Formatted: No bullets or numbering 2. The permittee shall maintain records of the following information for each emission unit for each calendar month using the methods outlined in the DEQ, AQD Rule 290, Permit to Install Exemption Record form (EQP 3558) or an alternative format that is approved by the AQD District Supervisor. [R 336.1213(3)] Formatted: Font: 9 pt a. Records identifying each air contaminant that is emitted. [R 336.1213(3)] Formatted: Font: 9 pt b. Records identifying if each air contaminant is controlled or uncontrolled. [R 336.1213(3)] c. Records identifying if each air contaminant is either carcinogenic or noncarcinogenic. [R 336.1213(3)] Formatted: Font: 9 pt d. Records identifying the ITSL and IRSL, if established, of each air contaminant that is being emitted Formatted: Font: 9 pt under the provisions of Rules 290(a)(ii) and (iii). [R 336.1213(3)] Formatted: Font: 9 pt e. Material use and calculations identifying the quality, nature, and quantity of the air contaminant emissions in sufficient detail to demonstrate that the actual emissions of the emission unit meet the emission limits outlined in this table and Rule 290. [R 336.1213(3), R 336.1290(c)] Formatted: Font: 9 pt

3. The permittee shall maintain an inventory of each emission unit that is exempt pursuant to Rule 290. The inventory shall include the following information. [R 336.1213(3)] Formatted: Font: 9 pt a. The permittee shall maintain a written description of each emission unit as it is maintained and operated throughout the life of the emission unit. [R 336.1290(b), R 336.1213(3)] Formatted: Font: 9 pt b. For each emission unit that emits noncarcinogenic particulate air contaminants pursuant to Rule 290(a)(iii), the permittee shall maintain a written description of the control device, including the designed control efficiency and the designed exhaust gas flow rate. [R 336.1213(3)] Formatted: Font: 9 pt Comment [AW5]: Note to MDEQ: The # for 7. For each emission unit that emits noncarcinogenic particulate air contaminants pursuant to Rule 290(a)(iii), the this section should be 4 instead of 7. permittee shall perform a monthly visible emission observation of each stack or vent during routine operating Formatted: Numbered + Level: 1 + conditions. This observation need not be performed using Method 9. The permittee shall keep a written record Numbering Style: 1, 2, 3, … + Start at: 1 + of the results of each observation. [R 336.1213(3)] Alignment: Left + Aligned at: 0" + Tab after: 0.25" + Indent at: 0.25" VII. REPORTING Formatted: Font: 9 pt Page 40 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

NA 1. Prompt reporting of deviations pursuant to General Conditions 21 and 22 of Part A. [R 336.1213(3)(c)(ii)] Formatted: Font: 9 pt

IX. STACK OR VENT RESTRICTIONS

X. OTHER REQUIREMENTS

Footnotes: 1This condition is state-only enforceable and was established pursuant to Rule 201(1)(b). 2This condition is federally enforceable and was established pursuant to Rule 201(1)(a).

Page 41 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Formatted: Don't adjust space between Latin E.5B NON-APPLICABLE REQUIREMENTS and Asian text At the time of issuance of this Renewal Operating Permit, the Air Quality Division has determined that no non- applicable requirements have been identified for incorporation into the permit shield provision set forth in the General Conditions in Part A pursuant to Rule 213(6)(a)(ii).

Page 42 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Formatted: Don't adjust space between Latin 6B APPENDICES and Asian text Formatted: Don't adjust space between Latin 32B Appendix 1. Abbreviations and Acronyms and Asian text

AQD Air Quality Division MM Million Acfm Actual cubic feet per minute MSDS Material Safety Data Sheet BACT Best Available Control Technology MW Megawatts BTU British Thermal Unit NA Not Applicable °C Degrees Celsius NAAQS National Ambient Air Quality Standards CAA Federal Clean Air Act NESHAP National Emission Standard for Hazardous Air Pollutants CAM Compliance Assurance Monitoring NMOC Non-methane Organic Compounds CEM Continuous Emission Monitoring NOx Oxides of Nitrogen CFR Code of Federal Regulations NSPS New Source Performance Standards CO Carbon Monoxide NSR New Source Review COM Continuous Opacity Monitoring PM Particulate Matter department Michigan Department of Environmental Quality PM-10 Particulate Matter less than 10 microns in diameter dscf Dry standard cubic foot pph Pound per hour dscm Dry standard cubic meter ppm Parts per million EPA United States Environmental Protection Agency ppmv Parts per million by volume EU Emission Unit ppmw Parts per million by weight °F Degrees Fahrenheit PS Performance Specification FG Flexible Group PSD Prevention of Significant Deterioration GACS Gallon of Applied Coating Solids psia Pounds per square inch absolute gr Grains psig Pounds per square inch gauge HAP Hazardous Air Pollutant PeTE Permanent Total Enclosure Hg Mercury PTI Permit to Install Hr Hour RACT Reasonable Available Control Technology HP Horsepower ROP Renewable Operating Permit

H2S Hydrogen Sulfide SC Special Condition HVLP High Volume Low Pressure scf Standard cubic feet ID Identification (Number) sec Seconds IRSL Initial Risk Screening Level SCR Selective Catalytic Reduction

ITSL Initial Threshold Screening Level SO2 Sulfur Dioxide LAER Lowest Achievable Emission Rate SRN State Registration Number lb Pound TAC Toxic Air Contaminant m Meter Temp Temperature MACT Maximum Achievable Control Technology THC Total Hydrocarbons MAERS Michigan Air Emissions Reporting System tpy Tons per year MAP Malfunction Abatement Plan µg Microgram MDEQ Michigan Department of Environmental Quality VE Visible Emissions mg Milligram VOC Volatile Organic Compounds mm Millimeter yr Year

Page 43 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Formatted: Don't adjust space between Latin and Asian text 33B Appendix 2. Schedule of Compliance

The permittee certified in the ROP application that this stationary source is in compliance with all applicable requirements and the permittee shall continue to comply with all terms and conditions of this ROP. A Schedule of Compliance is not required. [R336.1213(4)(a), R336.1119(a)(ii)]

Formatted: Don't adjust space between Latin and Asian text 34B Appendix 3. Monitoring Requirements

Specific monitoring requirement procedures, methods or specifications are detailed in Part A or the appropriate source-wide, emission unit and/or flexible group special conditions. Therefore, this appendix is not applicable.

Formatted: Don't adjust space between Latin and Asian text 35B Appendix 4. Recordkeeping

Specific recordkeeping requirement formats and procedures are detailed in Part A or the appropriate source-wide, emission unit and/or flexible group special conditions. Therefore, this appendix is not applicable.

Formatted: Don't adjust space between Latin and Asian text 36B Appendix 5. Testing Procedures

Specific testing requirement plans, procedures, and averaging times are detailed in the appropriate source-wide, emission unit and/or flexible group special conditions. Therefore, this appendix is not applicable.

Formatted: Don't adjust space between Latin and Asian text 37B Appendix 6. Permits to Install

This original ROP #MI-ROP-N7362-2010 incorporates the requirements of the following Permit to Install:

Permit to Install Number Description of Equipment

#26-04 Installation of a new lime manufacturing plant at Gulliver, Michigan. The plant uses a rotary kiln fired with coal and petroleum coke to calcine limestone to lime. The rotary kiln is equipped with a preheater, cooler, and baghouse dust collector.

The following table lists any limited term or limited process quantity Permits to Install issued to the company for the purpose of testing.

Permit to Install Number Description of Equipment

#26-04A Permit to Install #26-04A was issued June 29, 2009 to the permittee for a trial burn to combust “Process Engineered Fuel” in the existing lime kiln.

Page 44 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Formatted: Don't adjust space between Latin and Asian text 38B Appendix 7. Emission Calculations There are no specific emission calculations to be used for this Renewable Operating Permit. Therefore, this appendix is not applicable.

Formatted: Don't adjust space between Latin and Asian text 39B Appendix 8. Reporting

A. Annual, Semiannual, and Deviation Certification Reporting

The permittee shall use the MDEQ Report Certification form (EQP 5736) and MDEQ Deviation Report form (EQP 5737) for the annual, semiannual and deviation certification reporting referenced in the Reporting section of the source-wide, emission unit and/or flexible group special conditions. Alternative formats must meet the provisions of Rule 213(4)(c) and Rule 213(3)(c)(i), respectively, and be approved by the AQD District Supervisor.

B. Other Reporting

Specific reporting requirement formats and procedures are detailed in Part A or the appropriate source-wide, emission unit and/or flexible group special conditions. Therefore, Part B of this appendix is not applicable.

Page 45 of 46 Graymont Western Lime Inc. ROP No. MI-ROP-N7362N7362- Formatted: Font: 9 pt 20102010a Gulliver Lime Plant Effective Date: MAY 1, 2012 Formatted: Font: 9 pt PTI No. MI-PTI-N7362-2010a Expiration Date: JUNE 30, 2015

Formatted: Don't adjust space between Latin and Asian text 40B Appendix 9. Fugitive Dust Control Plan

I. Site Roadways / Plant Yard

A. The dust on the site roadways/plant yard shall be controlled by applications of water, calcium chloride or other acceptable and approved fugitive dust control compounds. Applications of dust suppressants shall be done as often as necessary to meet the 5% opacity limits.

B. All paved roadways/plant yards shall be swept as needed between applications.

C. Any material spillage on roads shall be cleaned up promptly.

II. Plant

A. The drop distance at each transfer point shall be reduced to the minimum the equipment can achieve. The transfer point from the recirculating belt to the feed belt shall be equipped with an enclosed chute.

B. All stone transfer conveyors and transfer points (except conveyors 113 and 114) will be kept covered.

III. Storage Piles

A. Stockpiling of all nonmetallic minerals shall be performed to minimize drop distance and control potential dust problems.

B. Stockpiles shall be watered on an as needed basis in order to meet the opacity limit of 5 percent. Also, equipment to apply water or dust suppressant shall be available at the site, or on call for use at the site, within a given operating day. A record of all watering shall be kept on file and be made available to the AQD upon request.

IV. Truck Traffic

A. On-site: Finished lime transport vehicles shall be loaded with telescopic chutes into railcars or trucks.

V. AQD / MDEQ Inspection

A. The provisions and procedures of this plan are subject to adjustment if following an inspection and written notification the AQD finds the fugitive dust requirements and/or permitted emission limits are not being met.

Page 46 of 46 AI-PartC4 Graymont Western Lime Inc. - Port Inland Plant ROP Renewal Application - GHG Potential Emission Calculations December 2014

Graymont Western Lime Inc. – Port Inland Plant Greenhouse Gas Emissions Summary Greenhouse Gas Potential Emission Calculations Potential To Emit

CO2 CH4 N2O CO2e CO2e Emission Source (metric (metric (metric (metric (short tons/year) tons/year) tons/year) tons/year) tons/year) Fuel Combustion 173,322 18.62 2.71 173,752 191,528 Calcining 192,307 N/A N/A 192,307 211,982 Auxiliary Drive 345 N/A N/A 345 380 Total 366,404 403,891 AI-PartC4 Graymont Western Lime Inc. - Port Inland Plant ROP Renewal Application - GHG Potential Emission Calculations December 2014

Graymont Western Lime Inc. – Port Inland Plant Greenhouse Gas Emission Calculations Greenhouse Gas Potential Emissions From Fuel Combustion Calculations1

Potential To Emit Rated Heat Input Hours of Potential Annual Stack/Process Process 2 3 Calculation 5 Fuel Capacity Operation Heat Input CO2 CH4 N2O CO2e CO2e ID Description Methodology4 (MMBtu/hr) (Hours/Year) (MMBtu/Year) (metric (metric (metric (metric (short tons/year) tons/year) tons/year) tons/year) tons/year) Subpart C Propane 193.2 8,760 1,692,432 106,403 5.08 1.015 106,833 117,763 (C-1, C-8) Subpart C Coal 193.2 8,760 1,692,432 162,092 18.62 2.708 163,364 180,078 (C-3, C-8) EU-KILN#1 Kiln #1 Subpart C #2 Fuel Oil 193.2 8,760 1,692,432 125,172 5.08 1.015 125,602 138,452 (C-1, C-8) Subpart C Petroleum Coke 193.2 8,760 1,692,432 173,322 5.08 1.015 173,752 191,528 (C-1, C-8) Worst Case Total6 173,322 18.62 2.708 173,752 191,528 1. The GHG potential emissions from fuel combustion are calculated based on Tier 1 or Tier 3 (depending on whether site specific fuel information was available) as found in the GHG Mandatory Reporting Rule at 40 CFR Part 98 Subpart C. 2. Heat input capacities are based on coal throughput of 14,000 Btu/lb dry-permit application coal specs (Eastern Coal). 3. Potential annual heat input is calculated based upon the rated heat input capacity and potential hours of operation. 4. Equations per GHG Mandatory Reporting Rule at 40 CFR Part 98 Subpart C.

5. CO2e calculated based on global warming potentials of each pollutant from Table A-1 to Subpart A of 40 CFR Part 98. 6. Worst case scenario selects the highest emissions of all permitted fuels for Kiln #1. AI-PartC4 Graymont Western Lime Inc. - Port Inland Plant ROP Renewal Application - GHG Potential Emission Calculations December 2014

Tier 1 CO2 Calculations -3 CO2 = 1 x 10 * Fuel * HHV * EF (Eq. C-1) Fuel = Annual mass or volume of the fuel combusted. HHV= Default high heat value of the fuel from Table C-1 for Tier 1

EF = Fuel-specific default CO2 emission factor, from Table C–1 (kg CO2/MMBtu). 1 x 10-3 = Conversion factor from kg to metric tons.

Tier 3 CO2 Calculations

CO2 = 44/12 * Fuel * CC *0.91 (Eq. C-3)

Tier 1 and 3 CH4 and N2O Calculations

-3 CH4 or N2O = 1 x 10 * Fuel * HHV * EF (Eq. C-8) Fuel = Annual mass or volume of the fuel combusted. HHV= Default high heat value of the fuel from Table C-1 for Tier 1, actual HHV data for Tier 3

EF = Fuel-specific default emission factor for CH4 or N2O, from Table C–2 (kg CH4 or N2O per MMBtu). 1 x 10-3 = Conversion factor from kg to metric tons.

Tier 1 Emission Factors

1 2 2 kg CO2 / MMBtu kg CH4 / MMBtu kg N2O / MMBtu

Propane 62.87 3.0E-03 6.0E-04 Petroleum Coke 102.41 3.0E-03 6.0E-04 #2 Fuel Oil 73.96 3.0E-03 6.0E-04 Coal -- 1.1E-02 1.6E-03 1. Table C-1 to Subpart C of 40 CFR Part 98 2. Table C-2 to Subpart C of 40 CFR Part 98

Tier 3 Emission Factors

HHV1 HHV Units Carbon Content1

Coal 25.03 MMBtu/short ton 71.85% 1. Weighted average heating value and carbon content based on 2012 and 2013 fuel information

Global Warming Potentials1

CO2 CH4 N2O 1 25 298 1. Table A-1 to Subpart A of 40 CFR Part 98 AI-PartC4 Graymont Western Lime Inc. - Port Inland Plant ROP Renewal Application - GHG Potential Emission Calculations December 2014

Graymont Western Lime Inc. – Port Inland Plant Greenhouse Gas Emission Calculations

Calcining Greenhouse Gas Potential Emissions Calculations1

Potential Stone Potential Lime Potential Hi-Cal Potential To Emit 2 Hours of Stone Feed Potential LKD Stack/Process Process Feed 3 Product Lime Product Hi-Cal Lime LKD Production Operation Capacity Production Total CO2 Total CO2e ID Description (tons Production4 Production Product CO2 CO2 (Hours/Year) (tons stone/hr) (tons/year) (metric (short (tons/year) (metric (metric stone/year) (tons/year) tons/year) tons/year) tons/year) tons/year) EU-KILN#1 Kiln #1 584,000 8,760 66.7 292,000 284,015 7,985 190,994 1,314 192,307 211,982 1. The GHG potential emissions from lime processing are calculated based upon equation S-1 in Subpart S to 40 CFR 98. 2. Potential annual stone feed based on process constraints and a permit limit in MI-ROP-N7362-2010a. 3. Stone feed hourly capacity is calculated based upon the annual stone throughput limit and number of hours in a year. 4. Limestone throughput is based on the assumed ratio of 2 tons of stone feed being equivalent to 1 ton of lime produced, as noted in the original permit application.

Production Information Data Description Value Unit Data Source tons lime product Common industry convention as noted in Lime Product Production Rate 0.5 /ton stone feed the original permit application. tons Hi-Cal/tons Average Production Ratio from 2012 & Hi-Cal Production Ratio 0.97 total lime product 2013 GHG Report tons LKD/ton lime Average Production Ratio from 2012 & LKD Generation Rate 0.03 product 2013 GHG Report Weighted Average from 2012 & 2013 CaO content of Hi-Cal Lime Product 91.5% percent GHG Report Weighted Average from 2012 & 2013 CaO content of the LKD 19.9% percent GHG Report Weighted Average from 2012 & 2013 MgO content of Hi-Cal Lime Product 2.1% percent GHG Report Weighted Average from 2012 & 2013 MgO content of the LKD 2.3% percent GHG Report

40 CFR Part 98; Subpart S Calculations

EFLime i,n = [(SRCaO * CaOi,n) + (SRMgO + MgOi,n)] * 2000/2205 (Eq. S-1) EFLime i,n Emission factor for lime type i, for month n (metric tons CO2/ton lime)

SRCaO Stoichiometric ratio of CO2 and CaO for calcium carbonate [see Table S-1 of this subpart] (metric tons CO2/metric tons CaO). CaOi,n Calcium oxide content for lime type i, for month n, determined according to §98.194(c) (metric tons CaO/metric ton lime). SRMgO Stoichiometric ratio of CO2 and MgO for magnesium carbonate (See Table S-1 of this subpart) (metric tons CO2/metric tons MgO).

MgOi,n Magnesium oxide content for lime type i, for month n, determined according to §98.194(c) (metric tons MgO/metric ton lime). 2000/2205 Conversion factor for tons to metric tons.

Stoichiometric Ratios1

SRCaO SRMgO 0.7848 1.0918 1. Table S-1 to Subpart S of 40 CFR Part 98 AI-PartC4 Graymont Western Lime Inc. - Port Inland Plant ROP Renewal Application - Kiln Aux Emission Summary December 2014 Graymont Western Lime Inc. – Port Inland Plant Greenhouse Gas Emission Calculations Potential Emissions Process NO CO SO PM PM CO CO Description X 2 TOC 10 2 2 (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (metric tpy) (short tpy) Kiln #1 Auxiliary Engine 9.30 2.00 0.62 0.74 0.66 0.66 345.03 380.34 Current Facility PTE1 532.40 456.00 302.70 1.80 29.20 29.20 366,059 403,511 Updated Facility PTE 541.70 458.00 303.32 2.54 29.86 29.86 366,404 403,891 1. Current facility PTE is found in Table 4.0 of Port Inland Permit Application submitted to the Michigan Department of Environmental Quality dated January 14, 2004. AI-PartC4 Graymont Western Lime Inc. - Port Inland Plant ROP Renewal Application - Kiln Aux Potential Emissions December 2014

Graymont Western Lime Inc. – Port Inland Plant Auxiliary Engine and HAP Emission Calculations Auxiliary Kiln Drive Internal Combustion Engine Emission Calculations

Emission Factors1 Potential Emissions Hours of Process Engine Power Engine Type Fuel Operation 2 Description (HP) NOX CO SO2 TOC PM CO2 NOX CO SO2 TOC PM PM10 CO2 CO2 (Hours/Year) (lb/hp-hr) (lb/hp-hr) (lb/hp-hr) (lb/hp-hr) (lb/hp-hr) (lb/hp-hr) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (metric tpy) (short tpy) Kiln #1 Auxiliary Non-Emergency Diesel 68.5 8,760 0.031 6.68E-03 2.05E-03 2.47E-03 2.20E-03 1.15 9.30 2.00 0.62 0.74 0.66 0.66 345 380 Engine Current Facility PTE3 532.40 456.00 302.70 1.80 29.20 29.20 366,059 403,511 Updated Facility PTE 541.70 458.00 303.32 2.54 29.86 29.86 366,404 403,891 1. Emission factors taken from AP-42 (10/96), Chapter 3 Section 3; Table 3.3-1. 2. Per footnote b to AP-42 Chapter 3 Section 3; table 3.3-1, all PM is assumed to be < 1 micrometer in size. 3. Current facility PTE is found in Table 4.0 of Port Inland Permit Application dated January 14, 2004. OM&M and SSMP for the Port Inland Plant This plan was developed to meet the requirements in the Air Quality permit for this facility as well as the requirements listed in the Lime MACT (40CFR63 AAAAA). Because this is a new facility, the information needed to determine whether or not the facility is subject to the Lime MACT will not be available until after facility startup when emissions testing has been performed. Therefore, the requirements of the Lime MACT are included in this plan to ensure compliance pending emission testing results. If emission testing shows that this facility is an area source for HAP’s and therefore not subject to the Lime MACT, the plan may be revised to remove the MACT requirements. This plan is designed to meet the requirements for the Malfunction Abatement Plan (MAP), the Operations, Maintenance and Monitoring Plan (OM&M) and the Startup, Shutdown and Malfunction Plan (SSMP). It covers actions to be taken for the lime kilns, coolers and processed stone handling system as defined below for each kiln. Any revisions to this plan must be submitted to DEQ for approval and/or reported in the semi-annual report.

Updated 2013 Page 1 of 6

Lime MACT § 63.7100 (d)(5) (OM&M Requirements) Kiln Opacity: The opacity monitor is installed on the exhaust stack for this

The Port Inland Plant kiln log sheets and/or the Environmental database will be used to document all of the required information.

Shutdown: Before taking the fabric filter dust collector and COMS out of operation, ensure that the kiln is shut down.

If repairing a malfunction will jeopardize the safety of an individual or equipment, seek advice from your supervisor before proceeding.

The Port Inland Plant kiln log sheets and/or the Environmental database will be used to document all of the required information.

Updated 2013 Page 5 of 6 maintained in inventory for quick replacement.

Updated 2013 Page 6 of 6