K A N S A S

RODERICK L. BREMBY, SECRETARY	KATHLEEN SEBELIUS, GOVERNOR

DEPARTMENT OF HEALTH AND ENVIRONMENT

AIR EMISSION SOURCE

CLASS I OPERATING PERMIT

Source ID No.:	1330001

Effective Date:	DRAFT

Expiration Date:	June 21, 2009

Source Name:	Ash Grove Cement Company

SIC Code:	3241, 4953 Portland Cement Manufacturing Industries

NAICS Code:	327310, Cement Manufacturing

Source Location:	1801 North Santa Fe Chanute, Kansas 66720

Mailing Address:	P.O. Box 519

	Chanute, Kansas 66720 

DIVISION OF ENVIRONMENT

Bureau of Air & Radiation

Air Construction/Operating Permits & Compliance Section

CURTIS STATE OFFICE BUILDING, 1000 SW JACKSON ST., STE 310, TOPEKA, KS
66612-1366

Voice 785-296-1570	Fax 785-291-3953	  HYPERLINK
http://www.kdhe.state.ks.us  http://www.kdhe.state.ks.us 

Printed on Recycled Paper

Authority

This permit, developed in accordance with the provisions of K.A.R.
28-19-500 et seq., Operating Permit, meets the requirements of K.A.R.
28-19-510 et seq., Class I Operating Permits and Title V of the federal
Clean Air Act.

Permit Intent

The purpose of this Class I Air Operating Permit is to identify the
emission sources, types of regulated air pollutants emitted from the
facility, the emission limitations, standards and requirements
applicable to each emission source, and the monitoring, record keeping
and reporting requirements applicable to each source as of the effective
date of this permit. At the time of permit issuance, a Class I Air
Emission Source Operating Permit was required because the facility’s
potential-to-emit PM10, NOx, SO2, CO, and VOC is above 100 tons per
year, the potential to emit a single Hazardous Air Pollutant (HAP) is
above 10 tons per year, and combined HAPs is above 25 tons per
year.TABLE OF CONTENTS

Section											     Page

Facility Description 	4

Summary of Applicable Requirements 	6

Emission Source Information 	6

Applicable Requirements 	6

Facility Wide Applicable Requirements 	62

Opacity Monitoring Section 	64

Requirements Which Will Become Applicable During the Permit Term 	66

Permit Shield 	66

Testing, Monitoring, Recordkeeping, and Reporting 	67

Reporting of Deviations from Permit Terms 	67

General Provisions 	68

K.A.R. 28-19-11: Exceptions Due to Breakdowns or Scheduled Maintenance 
68

K.A.R. 28-19-752a: Hazardous Air Pollutants; Limitations Applicable to

Construction of New Major Sources or Reconstruction of Existing Major
Sources 	68

K.A.R. 28-19-753: Hazardous Air Pollutants; Limitations Applicable to
Sources

for Which the U.S. EPA Fails to Meet Certain Deadlines 	68

Permit Term and Renewal 	69

Severability 	69

Property Rights 	69

Compliance 	69

Compliance Certification 	69

Emergency 	70

Inspection and Entry 	70

Permit Amendment, Modification, Reopening, and Changes Not Requiring a

 Permit Action 	71

Duty to Provide Information 	71

Duty to Supplement 	71

Other Permits and Approvals; Applicability 	72

Submissions 	72

Attachment A. Site Diagram

Attachment B. Acronyms and Symbols

Attachment C. Emission Sources Listed with Their Applicable Requirements
(Regulatory Classifications)

Attachment D. Emission Points with Very Low or Nonexistent Visible
Emissions 

Attachment E. 40 CFR 60 Subpart A

Attachment F. 40 CFR 61 Subpart A 

Attachment G. 40 CFR 63 Subpart A

Facility Description

Introduction

Ash Grove Cement Company (Ash Grove) of Overland Park, Kansas, is a
major manufacturer of Portland cement in the United States. Ash Grove
owns and operates numerous cement manufacturing facilities located
across the country. One such facility is the Ash Grove Cement Plant
(Plant) located at the corner of North Santa Fe Street and Ash Grove
Road adjacent to the northern limits of the city of Chanute, Kansas. The
plant is located within the city limits of Chanute in Neosho County.

Cement production has been conducted at this site since 1908. The latest
wet-process cement operation was constructed in 1964 and continued
operation until 2001. Numerous technical advances have occurred over the
last three decades to make the Portland cement manufacturing process
more energy efficient. Ash Grove intends to take advantage of these
advances to maintain its competitive position in the market and to
provide its customers with increased quantities of quality cement
products. The new plant is significantly larger than the existing
operation and employs the latest technology in all phases of cement
production. The two pre-existing wet-process kilns and the associated
raw mill have been replaced with a single preheater/precalciner kiln
design and an in-line raw mill for dry raw material preparation. With
these kiln design changes came modifications in the various material
conveyance and storage operations at the facility. These modifications
were designed to minimize air emissions. Even with the increase in
production, certain pollutant emissions have decreased over previous
operations.

Ash Grove received authorization to modify and modernize the existing
Plant on August 27, 1999 from the Kansas Department of Health &
Environment (KDHE) and on October 28, 1999 from Region VII of the United
States Environmental Protection Agency (USEPA). Authorizations for
additional systems were received from the agency after these dates for
other supporting systems. A Modification of Permit Conditions June 22,
2004 has modified previously established permit conditions.

Ash Grove received authorization from KDHE on December 30, 2004 to
modify the kiln to utilize alternative non-hazardous waste fuels.  Ash
Grove also received authorization from KDHE to utilize petroleum coke
during all modes of operation on March 30, 2006.  The operating permit
was updated on May 29, 2007 to incorporate these two PSD permits, as
well as a number of construction approvals that were issued since the
last update. 

General Description

Ash Grove’s Plant manufactures various Portland cement products for
shipment throughout a large geographical area in the Midwest region of
the United States. The cement manufacturing process involves the
following steps:

	1)	Quarrying and crushing limestone and acquisition of other raw
materials.

	2)	Proportioning and grinding of the raw materials.

	3)	Pyroprocessing the raw material mix in the cement kiln system to
form Portland 			cement clinker.

	4)	Grinding the clinker with gypsum and other additives to form
Portland cement 			products.

	Ash Grove acquires much of the raw materials for the cement production
operation from 	adjacent quarries. Materials such as limestone are mined
from these quarries and transported 	to the primary crusher. Once
initial sizing has occurred, the limestone material is then 	transported
through a secondary crusher unit and conveyed into a storage dome.
Additional 	raw materials such as clay, sand, and iron ore are received
from on-site and off-site sources, 	unloaded into receiving bins, and
conveyed into a covered storage building. From these two 	storage
operations, raw materials are transported into holding bins for proper
proportioning 	into the raw mill grinding systems. Predetermined ratios
of the various materials are 	determined by the cement laboratory and
depend on the cement chemical composition of the 	individual components
within each raw material.

	The ground raw materials, known as the raw material mix or kiln feed,
are stored in a 	blending silo system prior to introduction into the top
portion of the preheater/precalciner 	tower. Features of the
pyroprocessing system include a relatively short rotary kiln, five 
stages of cyclone-type preheater vessels located in a tall tower
adjacent to the kiln, and a 	precalciner vessel at the base of the tower
in which burning fuel is intimately mixed with 	raw materials. Coal,
petroleum coke, natural gas, used oil, hazardous waste-derived fuels 
(WDF), and alternative non-hazardous waste-derived fuels are used to
provide thermal 	energy to the pyroprocess in both the
preheater/precalciner tower and the rotary kiln. The 	Plant has been
permitted for, and continues to use liquid (pumpable) and solid
(containerized 	and bulk) WDF for beneficial energy recovery in the new
pyroprocessing system. Flame 	temperatures of approximately 3400oF must
be reached within the rotary kiln to produce 	material temperatures in
the range of 2700oF to bring about the final chemical reactions that 
turn the raw materials into clinker. The hot exhaust gases from the
tower are used to dry the 	raw materials in the vertical roller raw
mill.

	In conjunction with the kiln and raw mill replacement, Ash Grove has
expanded the finished 	cement grinding capacity of the plant through the
conversion of the existing raw mill into a 	finish mill system and the
addition of a new finish mill. The two existing finish mills will 
remain in production. All finish mill operations are typical ball mill
systems that include the 	rotary ball mill, a high efficiency separator,
dust collectors, material bins and feeders, and 	material
handling/conveyance equipment. The finished cement products are stored
in 	existing silos systems for bulk transport loading.

	Aside from the described major processes, there are numerous minor
operations such as 	cement bagging operations, coal unloading/storage,
and diesel/gasoline storage tanks.

III. 	40 CFR Part 63, Subpart LLL and EEE Transition

	Various operations at the facility were previously subject to 40 CFR
Part 60, Subpart F, 	Cement Manufacturing. As of June 14, 2002 all such
operations, other than the kiln system, 	are now subject to the
provisions of 40 CFR Part 63, Subpart LLL, National Emission 	Standard
for Hazardous Air Pollutants from the Portland Cement Manufacturing
Industry. 	Therefore the Subpart F requirements do not apply. The kiln
system is subject to 40 CFR Part 	63, Subpart EEE, National Emission
Standard for Hazardous Air Pollutants from Hazardous 	Waste Combustors.

Summary of Applicable Requirements

K.A.R. 28-19-xx 	7

40 CFR 60 Subpart A 	8

40 CFR 60 Subpart Kb 	8

40 CFR 60 Subpart Y 	9

40 CFR 60 Subpart OOO 	11

40 CFR 61 Subpart A 	13

40 CFR 61 Subpart V 	13

40 CFR 61 Subpart FF 	21

40 CFR 63 Subpart A 	29

40 CFR 63 Subpart DD 	29

40 CFR 63 Subpart PP 	32

40 CFR 63 Subpart EEE 	35

40 CFR 63 Subpart LLL 	42

State Construction Permit Conditions 	50

Emission Source Information

A list of emission sources including emission source IDs, emission
source descriptions, Stack/Vent ID’s, and Control Equipment ID Numbers
is included as Attachment C.

Applicable Requirements

The following provides a listing of the regulatory and permit
requirements that are applicable to the facility and the method(s) the
facility will use to comply with the requirements. A listing of the
sources

subject to each of the specific regulatory classifications, if any, is
provided as Attachment C.

A.	Kansas Administrative Regulations

A.1	K.A.R. 28-19-20, Particulate matter emission limitations -
Processing Equipment

Limitation/ Standard:		PM emissions are limited according to the
following equations: for Process weight # 30 tons/hr, E = 4.1(P0.67),
for Process weight > 30 tons/hr, E = 55(P0.11) - 40. Where: E = the rate
of emissions in lb/hr, P = the process weight rate in tons/hr





	Monitoring	Due to potentially very low or nonexistent emissions, no
monitoring is

required at time of permit issuance. If, however, any factors change
that

would affect the potential particulate matter emission rate (process
changes, emission factor increases, fuel changes, etc.), the potential
particulate matter emission rate must be recalculated and evaluated
against the rule limitation.	Permit

Condition

Reporting and

Recordkeeping	Records shall be maintained to ensure that this
particulate matter emission

source is in compliance with the particulate matter emission rate
limitation. If, however, any factors change that would affect the
potential particulate matter emission rate, records shall be maintained
of any recalculations and evaluations. These records shall include the
design rate capacity of the unit, emission factors used in calculations
and potential/allowable emission rates.	Permit

Condition



A.2	K.A.R 28-19-650(a)(2), Opacity Limitations, Stationary Sources,
Existing as of 1971

Limitation/ Standard:	Opacity of visible emissions from any emission
unit shall not exceed 40% opacity for any emission unit, other than a
portable source, existing on or before January 1, 1971 and that has not
been relocated after January 1, 1971.







Monitoring	Conduct 1-min visible emissions (VE) test using Method 22. If
visible

emissions are observed conduct an additional 1-minute Method 22

within twenty-four hours with a result of “No visible emissions,” or

conduct a 6-minute Method 9. The Method 9 test must begin within

twenty-four hours of the original, or follow-up (if conducted),

Method 22 during which visible emissions were observed, unless a

follow-up Method 22 demonstrated no visible emission. See Non-

MACT Visible Emissions Monitoring Plan for more details.	Permit

Condition

Reporting	The owner or operator shall promptly report deviations from
permit

requirements, the probable cause of such deviations, and any

corrective actions or preventive measures taken. To be considered

prompt, deviations shall be reported as part of the routine semi-

annual reporting requirements under K.A.R. 28-19-512(11)(A), and, if

applicable, in accordance with the malfunction reporting requirements

under K.A.R. 28-19-11, unless otherwise specified in an applicable

requirement.	K.A.R. 28-19-

512(11)(A),

28-19-11

Recordkeeping	Maintain records of the monthly VE tests for a period of
five years.	Permit

Condition



A.3	K.A.R 28-19-650(a)(3), Opacity Limitations, New Sources

Limitation/ Standard:	Opacity of visible emissions from any emission
unit shall not exceed 20% opacity for any emission

unit that existed or was relocated after January 1, 1971.





	Monitoring	Conduct 1-min visible emissions (VE) test using Method 22.
If

visible emissions are observed conduct an additional 1-minute

Method 22 within twenty-four hours with a result of “No visible

emissions,” or conduct a 6-minute Method 9. The Method 9 test

must begin within twenty-four hours of the original, or follow-up (if
conducted), Method 22 during which visible emissions were

observed, unless a follow-up Method 22 demonstrated no visible

emission. See Non-MACT Visible Emissions Monitoring Plan for

more details.

	Permit Condition

Reporting	The Permittee shall promptly report deviations from permit

requirements, the probable cause of such deviations, and any

corrective actions or preventive measures taken. To be considered

prompt, deviations shall be reported as part of the routine semi-

annual reporting requirements under K.A.R. 28-19-512(11)(A), and, if
applicable, in accordance with the malfunction reporting

requirements under K.A.R. 28-19-11, unless otherwise specified in an
applicable requirement.	K.A.R. 28-19-

512(11)(A),

K.A.R. 28-19-11

Recordkeeping	Maintain records of the monthly VE tests for a period of
five years.

	

40 CFR 60 Subpart A

Applicable citations for 40 CFR 60 Subpart A are provided in Attachment
E.

C.	40 CFR 60 Subpart Kb



Equipment subject to 40 CFR 60 Subpart Kb must comply with the
requirements of 40 CFR 60 Subpart A - General Provisions except where
Subpart Kb provides for explicit exemptions to Subpart A. The 40 CFR 60
Subpart A - General Provisions are found in Attachment E of this permit.

Except as provided in §60.1 10b(b), (c), and (d), the affected facility
to which this subpart applies is each storage vessel with a capacity
greater than or equal to 40 cubic meters (m3) that is used to store
volatile organic liquids (VOLs) for which construction, reconstruction,
or modification is commenced after July 23, 1984.	60.1 10b(a)



C.1	40 CFR 60 NSPS - Kb, Tank

a.	Limitation/Standard:	60.1 12b(a)(3)(i)

	Must have a closed vent system designed to collect all VOC vapors and
operate with no detectable emission as indicated by an instrument
reading of less than 500 ppm above background and visual inspection as
determined in §60.485(b).



	Monitoring	Compliance with LDAR program of 40 CFR 61 Subpart FF
demonstrates

compliance with this requirement.	N/A

Testing	Method 21 and visual inspection	60.485(b)



b.	Limitation/Standard:	60.1 12b(a)(3)(ii) Must have a control device
designed to reduce VOC emissions by 95%



Monitoring	Closed vent system and control device must be monitored
according to the operating plan	60.1 13b(c)(2)

	One or more devices which vent directly to the atmosphere may be used
on the closed-vent system provided each device remains in a closed,
sealed position during normal operations	61.349(a)(1)(iv)

Reporting	An operating plan must be submitted with the startup
notification that documents that the combustion device will have a
minimum residence time of 0.75 seconds and a minimum temp. of 816(C	60.1
13b(c)(1)

Recordkeeping	Keep records of 1) Operating plan and 2) Measured values
of

monitored parameters for life of control equipment	60.115b(c)

	Records must be kept for the life of the source	60.1 16b(a)

	Keep records of the dimension and capacity of the storage vessel for
the life of the control device	60.1 16b(b)

Testing	The source of each vessel storing a waste mixture of 
indeterminate or variable composition shall be subject to these
requirements: Prior to initial filling of the vessel, the highest
maximum true vapor pressure for the range of anticipated liquid
compositions to be stored will be determined using the methods described
in paragraph (e). For vessels in which the vapor pressure of the
anticipated liquid composition is above the cutoff for monitoring but
below the cutoff for controls as defined in §60.1 12b(a), an initial
physical test of the vapor pressure is required; and a physical test at
least once every 6 months thereafter is required as determined by the
following methods: ASTM Method D2879-83 (incorporated by reference-see
§60.17); ASTM Method D323-82 (incorporated by reference-see §0.17); or
as measured by an appropriate approved method.	60.1 16b(f)

	The owner or operator of each vessel equipped with a closed vent

system and control device meeting the specifications of § 60.1 12b is
exempt from the requirements of §60.1 16b(c) and (d).	60.1 16b(g)



D. 	40 CFR 60 Subpart Y Standards of Performance for Coal Preparation
Plants

Applicable Requirement (Summary)

Equipment subject to 40 CFR 60 Subpart Y must comply with the
requirements of 40 CFR 60 Subpart A – General Provisions except where
Subpart Y provides for explicit exemptions to Subpart A. The 40 CFR 60
Subpart A - General Provisions are found in Attachment E of this permit.

The provisions of this subpart are applicable to any of the following
affected facilities in coal

preparation plants which process more than 200 tons per day: Thermal
dryers, pneumatic coal-

cleaning equipment (air tables), coal processing and conveying equipment
(including breakers and crushers), coal storage systems, and coal
transfer and loading systems.	60.250(a)

Any facility under §60.250(a) that commences construction or
modification after October 24, 1974,

is subject to the requirements of this subpart.	60.250(b)



D.1	40 CFR 60 Subpart Y, 60.252(c) Opacity Limitations for coal
processing, conveying, storage, transfer, or loading equipment

Limitation/	Emissions from coal processing and conveying equipment, coal
storage systems, and coal transfer

Standard	and loading systems shall not exhibit 20% opacity or greater
except during startups, shutdowns, & malfunctions



Monitoring	Conduct 1-min visible emissions (VE) test using Method 22. If
visible emissions are observed conduct an additional 1-minute Method 22
within twenty-four hours with a result of “No visible emissions,” or
conduct a 6-minute Method 9. The Method 9 test must begin within
twenty-four hours of the original, or follow-up (if conducted), Method
22 during which visible emissions were observed, unless a follow-up
Method 22 demonstrated no visible emission. See Non-MACT Visible
Emissions Monitoring Plan for more details.	Permit

Condition

Reporting	The Permittee shall promptly report deviations from permit
requirements, the probable cause of such deviations, and any corrective
actions or preventive measures taken. To be considered prompt,
deviations shall be reported as part of the routine semi-annual
reporting requirements under K.A.R. 28-19-512(11)(A), and, if
applicable, in accordance with the malfunction reporting requirements
under K.A.R. 28-19-11, unless otherwise specified in an applicable
requirement.	K.A.R. 28-

19-512(ii)(A)

K.A.R. 28-

19-11

Recordkeeping	Maintain records of the monthly VE tests for a period of
five years.	Permit Condition



D.2	40 CFR 60 Subpart, 60.252(a)(1) Thermal dryer particulate standard

a. Limitation/Standard	Thermal Dryers. Shall not emit particulate matter
in excess of 0.031 gr/scf. 8/26/99



Monitoring	Due to potentially very low or nonexistent emissions, no
monitoring is

required at time of permit issuance. If, however, any factors change
that

would affect the potential particulate matter emission rate (process
changes,

emission factor increases, fuel changes, etc.), the potential
particulate matter

emission rate must be recalculated and evaluated against the rule
limitation.	Permit

Condition

8/26/99

Recordkeeping	No recordkeeping is required at time of permit issuance.
If, however, any

factors change that would affect the potential particulate matter
emission

rate, records shall be maintained of any recalculations and evaluations.

These records shall include the design rate capacity of the unit,
emission

factors used in calculations and potential/allowable emission rates.
Permit

Condition

Testing	Test methods. Method 5 sampling time and volume shall be at
least 60

minutes and 30 dscf.	60.254(b)(1)

b.  Limitation/Standard	60.252(a)(2): Thermal dryers. Shall not
exhibit greater than 20% opacity except during startups, 	shutdowns, &
malfunctions



	Monitoring

	Reporting	See Section L, 40 CFR 63 Subpart EEE, for details on
compliance with this limit

Recordkeeping

	Testing

	

c  Limitation/Standard	60.253(a)(1): Thermal dryers shall be monitored
using a CMS for the measurement of the 	temperature of the gas stream at
the exit of the dryer. CMS shall be calibrated and certified by 	the
manufacturer to be accurate within ±3(F annually.



	Monitoring	All monitoring devices under (a) of this section are to be
recalibrated

annually in accordance with procedures under §60.13 (b).	60.253(b)

Recordkeeping	Records of requirements requested in CEMS conditions are
included in the

facility wide requirements	N/A



E. 	40 CFR 60 Subpart OOO Standards of performance for nonmetallic
mineral processing 	plants

Equipment subject to 40 CFR 60 Subpart OOO must comply with the
requirements of 40 CFR 60 Subpart A -General Provisions except where
Subpart OOO provides for explicit exemptions to Subpart A. The 40 CFR 60
Subpart A - General Provisions are found in Attachment E of this permit.

Except as provided in §60.670(a)(2), (b), (c), and (d), the provisions
of this subpart are

applicable to the following affected facilities in fixed or portable
nonmetallic mineral

processing plants: each crusher, grinding mill, screening operation,
bucket elevator, belt

conveyor, bagging operation, storage bin, enclosed truck or railcar
loading station.	60.670(a)(1)

An affected facility under § 60.670(a) that commences construction,
reconstruction, or

modification after August 31, 1983 is subject to the requirements of
this part.	60.670(e)



One-Time Initial Performance Testing Related Requirements



	Reporting	Submit written reports of the results of all performance
tests conducted to

demonstrate compliance with the standards set forth in § 60.672 of this

subpart.	60.676(f)

Testing	Method 9 and the procedures in §60.11 shall be used to
determine opacity.	60.675(b)(2)

	In determining compliance with the particulate matter standards
[opacity] in

§ 60.672 (b) and (c), the owner or operator shall use Method 9 and the

procedures in § 60.11, with additions as given in §
60.675(c)(1)(i)-(iii).	60.675(c)(1)



	

Testing	If emissions from two or more facilities continuously interfere
so that the

opacity of fugitive emissions from an individual affected facility
cannot be

read, either of the following procedures may be used:

(i) Use for the combined emission stream the highest fugitive opacity
standard applicable to any of the individual affected facilities
contributing to the emissions stream. 

(ii) Separate the emissions so that the opacity of emissions from each  
affected facility can be read.	60.675(e)

	Non-crushers - When determining compliance with the opacity standard,
the

duration of the initial performance test, Method 9 observations, may be

reduced from 3 hours (thirty 6-minute averages) to 1 hour (ten 6-minute

averages) if there are no individual readings greater than 10 percent
opacity;

and there are no more than 3 readings of 10 percent for the 1-hour
period.	60.675(c)(3)

	Crushers - When determining compliance with the fugitive emissions
standard for any crusher at which a capture system is not used as
described under § 60.672(c) of this subpart, the duration of the Method
9 observations may be reduced from 3 hours (thirty 6-minute averages) to
1 hour (ten 6-minute averages) only if the following conditions apply:

(i) There are no individual readings greater than 15 percent opacity;
and

(ii) There are no more than 3 readings of 15 percent for the 1-hour
period.	60.675(c)(4)

	Storage Bins Controlled by a Baghouse - The duration of the initial
Method 9

observations shall be 1 hour (ten 6-minute averages).	60.675(c)(2)

	Structures.	Shall use Method 22 to determine fugitive emissions. The

performance test shall be conducted while all affected facilities inside
the

building are operating. The performance test for each building shall be
at least 75 minutes in duration, with each side of the building and the
roof being observed for at least 15 minutes.	60.675(d)



E.1	40 CFR 60 NSPS OOO, Belt Conveyor Transfer Point, Grinding Mill,
Screen, Bagging 	Operation, Storage Bin – Fugitive Source

Limitation/	60.672(b): Shall not cause to be discharged into the
atmosphere from any transfer point on belt

Standard	conveyors or from any other affected facility any fugitive
emissions which exhibit greater than 10% opacity except during startups,
shutdowns, & malfunctions.



	Monitoring	Conduct 1-min visible emissions (VE) test using Method 22.
If visible

emissions are observed conduct an additional 1-minute Method 22 within

twenty-four hours with a result of “No visible emissions,” or
conduct a 6-

minute Method 9. The Method 9 test must begin within twenty-four hours

of the original, or follow-up (if conducted), Method 22 during which
visible emissions were observed, unless a follow-up Method 22
demonstrated no visible emission. See Non-MACT Visible Emissions
Monitoring Plan for more details.	Permit

Condition

	If emissions from two or more facilities continuously interfere so that
the

opacity of fugitive emissions from an individual affected facility
cannot be read, either of the following procedures may be used:

(i) Use for the combined emission stream the highest fugitive opacity

standard applicable to any of the individual affected facilities
contributing

to the emissions stream.

(ii) Separate the emissions so that the opacity of emissions from each

affected facility can be read.	60.675(e)

Reporting	The Permittee shall promptly report deviations from permit
requirements,

the probable cause of such deviations, and any corrective actions or

preventive measures taken. To be considered prompt, deviations shall be

reported as part of the routine semi-annual reporting requirements under

K.A.R. 28-19-512(11)(A), and, if applicable, in accordance with the

malfunction reporting requirements under K.A.R. 28-19-11, unless
otherwise specified in an applicable requirement..	Permit

Condition

Recordkeeping	Maintain records of the monthly VE tests for a period of
five years.	Permit

Condition



E.2	40 CFR 60 NSPS OOO, Belt Conveyor Transfer Point, Crusher, Grinding
Mill, Screen, Bagging Operation, Storage Bin –Affected Sources in
Buildings

Limitation/	60.672(e): No owner or operator shall cause to be discharged
into the atmosphere from any Standard	building enclosing any transfer
point on a conveyor belt or any other affected facility any visible 
fugitive emissions except during startups, shutdowns, & malfunction.

Monitoring	Conduct 1-min visible emissions (VE) test using Method 22.
If visible

emissions are observed conduct an additional 1-minute Method 22 within

twenty-four hours with a result of “No visible emissions,” or
conduct a 6- minute Method 9. The Method 9 test must begin within
twenty-four

hours of the original, or follow-up (if conducted), Method 22 during
which visible emissions were observed, unless a follow-up Method 22

demonstrated no visible emission. See Non-MACT Visible Emissions

Monitoring Plan for more details.	Permit Condition

Reporting	The Permittee shall promptly report deviations from permit
requirements,

the probable cause of such deviations, and any corrective actions or

preventive measures taken. To be considered prompt, deviations shall be

reported as part of the routine semi-annual reporting requirements under

K.A.R. 28-19-512(11)(A), and, if applicable, in accordance with the

malfunction reporting requirements under K.A.R. 28-19-11, unless

otherwise specified in an applicable requirement.	K.A.R. 28-19-

512(11)(A)

K.A.R. 28-19-11

Recordkeeping	Maintain records of the monthly VE tests for a period of
five years.	Permit Condition



40 CFR 61 Subpart A

Applicable citations for 40 CFR 61 Subpart A are provided in Attachment
F.

40 CFR 61 Subpart V National Emission Standard for Equipment Leaks

General Requirements

Applicable Requirement (Summary)	Citation

Equipment subject to 40 CFR 61 Subpart V must comply with the
requirements of 40 CFR 61 Subpart A - General

Provisions except where Subpart V provides for explicit exemptions to
Subpart A. The 40 CFR 61 Subpart A – General Provisions are found in
Attachment F of this permit.

The provisions of this subpart apply to each of the following sources
that are intended to operate in

volatile hazardous air pollutant (VHAP) service: pumps, compressors,
pressure relief devices,

sampling connection systems, open-ended valves or lines, valves, flanges
and other connectors,

product accumulator vessels, and control devices or systems required by
this subpart.	 61.240(a)

The provisions of this subpart shall demonstrate compliance with the
requirements of §§61.242 -1 to 61.242-11 for each new and existing
source as required in 40 CFR 61.05, except as provided in §§61.243 and
61.244.	 61.242-1(a)

Compliance with this subpart will be determined by review of records,
review of performance test

results, and inspection using the methods and procedures specified in
§61.245.	 61.242-1(b)

If an instrument reading of 10,000 ppm or greater is measured, a leak is
detected.	 61.242-7(b)

G.1	40 CFR 61 Subpart V, General Requirements

Limitation/Standard	61.242-1(d) Standards: General. Each piece of
equipment to which this subpart applies shall be marked in such a manner
that it can be distinguished readily from other pieces of equipment.

Limitation/Standard	61.242-1(e) Standards: Equipment that is in vacuum
service is excluded from the requirements of §61.242-2, to §61.242-11
if it is identified as required in §61.246(e)(5).

Reporting	 A statement must be submitted to the Administrator notifying
them that the

 requirements of §§61.242, 61.245, 61.246, and 61.247 are being
implemented.	61.247(a)(1)

	Statement is to be submitted within 90 days of the effective date
61.247(a)(2)

	In the case of new sources which did not have an initial startup date
preceding

the effective date, the statement shall be submitted with the
application for

approval of construction, as described in § 61.07.	61.247(a)(3)

	The statement shall contain the listed information for each source.
61.247(a)(4)

	A report shall be submitted to the Administrator semiannually starting
6 months after the initial report that includes the information detailed
in §61.247(b)(1-5)	61.247(b)

	In the first report submitted as required in paragraph (a) of this
section, the

report shall include a reporting schedule stating the months that
semiannual

reports shall be submitted. Subsequent reports shall be submitted
according to

that schedule, unless a revised schedule has been submitted in a
previous

semiannual report.	61.247(c)

Recordkeeping	Record in a log a list of identification numbers for
equipment (except welded

fittings) subject to the requirements of this subpart.	61.246(e)(1)

	Record in a log a list of identification numbers for equipment that the
owner or operator elects to designate for no detectable emissions as
indicated by an

instrument reading of less than 500 ppm above background, the
designation of

this equipment for no detectable emissions shall be signed by the owner
or

operator.	61 .246(e)(2)

	Record in a log a list of equipment identification numbers for pressure
relief

devices required to comply with §61.242-4(a).	61.246(e)(3)

	Record in a log the dates of each compliance test required in
§61.242-2(e),

§61.242-3(l), §61.242-4, §61.242-7(f), and §61.135(g) as well as the
background level measure during each test and the maximum instrument
reading measured at the equipment during each test.	61.246(e)(4)

	Record in a log a list of identification numbers for equipment in
vacuum service.	61 .246(e)(5)

	Record in a log an analysis demonstrating the design capacity of the
process

unit and an analysis demonstrating that the equipment is not in VHAP
service

for use in determining exemptions as provided in 40 CFR 61, Subpart V.
61.246(i)

	Record in a log information and data used to demonstrate that a piece
of

equipment is not in VHAP service.	61.246(j)



G.2	40 CFR 61 NESHAP - Subpart V, Pumps

Limitation/Standard	61.242-2(a)(1) Standards: Each pump shall be
monitored monthly to detect leaks, except as provided in §61.242-1(c)
and §61.242-2(d), (e), (f) and (g).

Limitation/Standard	61.242-2(a)(2) Standards: Each pump shall be checked
by visual inspection each calendar week for indications of liquids
dripping from the pump seal.



	Monitoring	Test methods and procedures. Monitoring, as required in §§
61.242, 61.243,

61.244, and 61.135, shall comply with the following requirements: (1)
Monitoring shall comply with Method 21 of appendix A of 40 CFR part 60.
61.245(b)(1)

	Test methods and procedures. Monitoring, as required in §§ 61.242,
61.243,

61.244, and 61.135, shall comply with the following requirements: (2)
The

detection instrument shall meet the performance criteria of Reference
Method 21.	61.245(b)(2)

	Monitoring, as required in §§ 61.242, 61.243, 61.244, and 61.135,
shall comply with the following requirements: (3) The instrument shall
be calibrated before use on each day of its use by the procedures
specified in Reference Method 21.	61.245(b)(3)

	Calibration gases shall be: (i) Zero air (less than 10 ppm of
hydrocarbon in air); and (ii) A mixture of methane or n-hexane and air
at a concentration of

approximately, but less than, 10,000 ppm methane or n-hexane.
61.245(b)(4)

	If an instrument reading of 10,000 ppm or greater is measured, a leak
is detected.	61.242-2(b)(1)

	If there are indications of liquids dripping from the pump seal, a leak
is detected.	61.242-2(b)(2)

	Delay of repair of equipment for which leaks have been detected will be
allowed if the repair is technically infeasible without a process unit
shutdown. Repair of this equipment shall occur before the end of the
next process unit shutdown.	61.242-10(a)

	Delay of repair for equipment for which leaks have been detected will
be allowed for equipment that is isolated from the process and that does
not remain in VHAP service.	61.242-10(b)

	Delay of repair for pumps will be allowed if: (1) Repair requires the
use of a dual mechanical seal system that includes a barrier fluid
system, and (2) Repair is completed as soon as practicable, but not
later than 6 months after the leak was detected.	61.242-10(d)

	Delay of repair beyond a process unit shutdown will be allowed if
supplies

depleted and had previously been stocked.	61.242-10(e)

	When a leak is detected, it shall be repaired as soon as practicable,
but not later than 15 calendar days after it is detected, except as
provided in §61.242–10.	61.242-2(c)(1)

	A first attempt at repair shall be made no later than 5 calendar days
after each

leak is detected.	61 .242-2(c)(2)

Recordkeeping	When each leak is detected, a weatherproof and readily
visible identification,

marked with the equipment identification number shall be attached to the
leaking equipment.	61.246(b)(1)

	When each leak is detected as specified in §§ 61.242–2, 61.242–3,
61.242–7,

61.242–8, and 61.135, the following requirements apply: (3) The
identification on equipment, except on a valve, may be removed after it
has been repaired.	61.246(b)(3)

	When each leak is detected, record the instrument and operator
identification

numbers and the equipment identification number.	61.246(c)(1)

	When each leak is detected, record the date the leak was detected and
the dates

of each attempt to repair the leak.

	61 .246(c)(2)



	Recordkeeping	When each leak is detected record ‘‘Above
10,000’’ if the maximum instrument reading measured by the methods
specified in § 61.245(a) after each repair attempt is equal to or
greater than 10,000 ppm	61.246(c)(4)

	When leak is detected record ‘‘Repair delayed’’ and the reason
for the delay if a leak is not repaired within 15 calendar days after
discovery of the leak.	61.246(c)(5)

	When each leak is detected, record the signature of the owner or
operator (or designate) whose decision it was that repair could not be
effected without a

process shutdown.	61 .246(c)(6)

	When each leak is detected the following information shall be recorded
in a log and shall be kept for 2 years in a readily accessible location:
(7) The expected date of successful repair of the leak if a leak is not
repaired within 15 calendar days.	61 .246(c)(7)

	When each leak is detected, the following information shall be recorded
in a log and shall be kept for 2 years in a readily accessible location:
(8) Dates of process unit shutdowns that occur while the equipment is
unrepaired.	61 .246(c)(8)

	When each leak is detected, the following information shall be recorded
in a log and shall be kept for 2 years in a readily accessible location:
(9) The date of successful repair of the leak.	61 .246(c)(9)



G.2a	40 CFR 61 Subpart V, Pumps Equipped with Dual Mechanical Seal
System

Limitation/	61.242-2(d) Each pump equipped with a dual mechanical seal
system that includes a barrier fluid

Standard	   system is exempt from the requirements of §61.242-2(a) and
(b), provided that the requirements 	listed in  §61.242-2(d) are met.

G.2b	40 CFR 61 Subpart V, Pumps Designated as “no detectable
emissions”

Limitation/      61.242-2(e)  Any pump designated, as described in
§61.246(e)(2), for no detectable emissions, as

Standard         indicated by an instrument reading of less than 500 ppm
above background, is exempt from the     

                     	 requirements of §61.242-2(a), (c), and (d) as
long as the pump meets the requirements 	listed in §61.242-2(e).

G.2c	40 CFR 61 Subpart V, Pumps with a Closed-vent System

Limitation/	61.242-2(f) If any pump is equipped with a closed-vent
system capable of capturing and

Standard	  transporting any leakage from the seal or seals to a process
or fuel gas system or to a 	control  device that complies with the
requirements of §61.242-11, it is exempt from the 	requirements of 
§61.242-2(a-e).

G.2d	40 CFR 61 Subpart V, Pumps that are Unsafe to Monitor

Limitation/	61.242-2(g) Any pump that is designated, as described in
§61.246(f)(1), as an unsafe-to-monitor

Standard	   pump is exempt from the monitoring and inspection
requirements of §61.242-2(a) and (d)(4-6) as   

                         long as the requirements of §61.242-2(g) are
met.

G.2e	40 CFR 61 Subpart V, Unmanned Plant Site

Limitation/	61.242-2(h) Any pump that is located within the boundary of
an unmanned plant site is exempt

 Standard         from the weekly visual inspection requirement of
§61.242-2(a)(2) and (d)(4) of this 	section, and the  daily
requirements of paragraph §61.242-2(d)(5), provided that each pump 	is
visually inspected as often as practicable and at least monthly.

G.3	40 CFR 61 Subpart V, Compressors

Limitation/	61.242-3(a) Each compressor shall be equipped with a seal
system that includes a barrier fluid

Standard	 system and that prevents leakage of process fluid to
atmosphere, except as provided in §61.242- 1(c)

	and §61.242-3(h) and (i).



	Monitoring	 Each compressor seal system required shall follow the
requirements of §61.242-3(b)(1-3).	61.242-3(b)

	The barrier fluid shall not be in VHAP service and, if the compressor
is covered

by standards under 40 CFR part 60, shall not be in VOC service.
61.242-3(c)

	Each barrier fluid system shall be equipped with a sensor that will
detect failure of the seal system, barrier fluid system, or both.
61.242-3(d)

	Each sensor shall be checked daily or shall be checked daily or shall
be equipped with an audible alarm unless the compressor is located
within the boundary of an unmanned plant site.	61.242-3(e)(1)

	The owner or operator shall determine, based on design considerations
and operating experience, a criterion that indicates failure of the seal
system, the barrier fluid system, or both.	61.242-3(e)(2)

	If the sensor indicates failure of the seal system, the barrier fluid
system, or both based on the criterion determined under
§61.242-3(e)(2), a leak is detected.	61.242-3(f)

	When a leak is detected, it shall be repaired as soon as practicable,
but not later than 15 calendar days after it is detected, except as
provided in §61.242-10.	61.242-3(g)(1)

	A first attempt at repair shall be made no later than 5 calendar days
after each leak is detected.	61.242-3(g)(2)

	A compressor is exempt from the requirements of §61.242-3(a) and (b)
if it is equipped with a closed-vent system to capture and transport
leakage from the compressor drive shaft back to a process or fuel gas
system or to a control device that complies with the requirements of
§61.242-11, except as provided in §61.242-3(h)(i).	61.242-3(h)



G.4	40 CFR 61 Subpart V, Pressure Relief Devices in gas/vapor service

Limitation/	61.242-4(a) Except during pressure releases, each pressure
relief device in gas/vapor service shall be

Standard	operated with no detectable emissions, as indicated by an
instrument reading of less than 500ppm                         	above
background, as measured by the method specified in §61.245(c).	



	Monitoring	After each pressure release, the pressure relief device
shall be returned

to a condition of no detectable emissions, as indicated by the
instrument reading of less than 500 ppm above background, as soon as
practicable, but no later than 5 calendar days after each pressure
release, except as provided in §61.242-10.	61.242-4(b)(1)

	No later than 5 calendar days after the pressure release, the pressure
relief device shall be monitored to confirm the condition of no
detectable emissions, as indicated by an instrument reading of less than
500 ppm above background, as measured by the method specified in
§61.245(c).	61.242-4(b)(2)

	Any pressure relief device that is routed to a process or fuel gas
system or equipped with a closed-vent system capable of capturing and
transporting leakage from the pressure relief device as described in
§61.242-11 is exempt from the requirements of §61.242-4(a) and (b).
61.242-4(c)

	Any pressure relief device that is equipped with a rupture disk
upstream of the pressure relief device is exempt from the requirements
of §61.242-4(a) and (b), provided the owner or operator complies with
§61.242-4(d)(2).	61.242-4(d)(1)

	After each pressure release, a new rupture disk shall be installed
upstream of the pressure relief device as soon as practicable, but no
later than 5 calendar days after each pressure release, except as
provided in §61.242-10.	61.242-4(d)(2)



G.5	Subpart V, Sampling connecting systems

Limitation/	61.242-5(a) Each sampling connection system shall be
equipped with a closed-purge system or

Standard	closed vent system, except as provided in § 61.242–1(c).
Gases displaced during filling of the sample container are not required
to be collected or captured.



	Monitoring	Each closed-purge system or closed-vent system as required
in paragraph (a) shall: (1) Return the purged process fluid directly to
the process line (2) Collect and recycle the purged process fluid; or
(3) Be designed and operated to capture and transport all the purged
process fluid to a control device that complies with the requirements of
§61.242-11; or (4) Collect, store and transport the purged process
fluid to any of the systems or facilities listed in
§61.242-5(b)(4)(i-iii).	61.242-5(b)(1-4)

	In-situ sampling systems and sampling systems without purges are exempt
from the requirements of §61.242-5(a) and (b).	61.242-5(c)



G.6	40 CFR 61 Subpart V, Open-ended valves or lines

Limitation/	61.242-6(a)(1) Each open-ended valve or line shall be
equipped with a cap, blind flange, plug, or a

Standard	second valve, except as provided in § 6 1.242–1(c).



	Monitoring	 Open-ended valves or lines. The cap, blind flange, plug, or
second valve shall seal the open end at all times except during
operations requiring process fluid flow through the open-ended valve or
line.	61.242-6(a)(2)

	Open-ended valves or lines. Each open-ended valve or line equipped with
a second valve shall be operated in a manner such that the valve on the
process fluid end is closed before the second valve is closed.
61.242-6(b)

	When a double block and bleed system is being used, the bleed valve or
line may remain open during operations that require venting the line
between the block valves but shall comply with paragraph (a) at all
other times.	61.242-6(c)

	Open-ended valves or lines in an emergency shutdown system which are
designed to open automatically in the event of a process upset are
exempt from the requirements of §61.242-6(a-c).	61.242-6(d)

	Open-ended valves or lines containing materials which would
autocatalytically polymerize or would present an explosion, serious
overpressure, or other safety hazard if capped or equipped with a double
block and bleed system as specified in §61.242-6(a-c) are exempt from
the requirements of §61.242-6(a-c).	61.242-6(e)



G.7	40 CFR 61 Subpart V, Valves

Limitation/	6 1.242-7(a) Each valve shall be monitored monthly to detect
leaks by the method specified in 

Standard	§61.245(b) and shall comply with paragraphs (b)–(e), except
as provided in paragraphs (f), (g), and (h) of 	this section, §
61.243–1 or § 61.243–2, and § 61.242– 1(c).



	Monitoring	Test methods and procedures. Monitoring, as required in §§
61.242, 61.243, 61.244, and 61.135, shall comply with the following
requirements: (1) Monitoring shall comply with Method 21 of appendix A
of 40 CFR part 60.	61.245(b)(1)

	Test methods and procedures. Monitoring, as required in §§ 61.242,
61.243,

61.244, and 61.135, shall comply with the following requirements: (2)
The detection instrument shall meet the performance criteria of
Reference Method 21.	61.245(b)(2)

	Monitoring, as required in §§ 61.242, 61.243, 61.244, and 61.135,
shall comply with the following requirements: (3) The instrument shall
be calibrated before use on each day of its use by the procedures
specified in Reference Method 21.	61.245(b)(3)

	Calibration gases shall be: (i) Zero air (less than 10 ppm of
hydrocarbon in air); and (ii) A mixture of methane or n-hexane and air
at a concentration of approximately, but less than, 10,000 ppm methane
or n-hexane.	61.245(b)(4)

	Monitoring shall comply with the following requirements: (5) The
instrument

probe shall be traversed around all potential leak interfaces as close
to the interface as possible as described in Reference Method 21.
61.245(b)(5)

	Any valve for which a leak is not detected for 2 successive months may
be monitored the first month of every quarter, beginning with the next
quarter, until a leak is detected.	61.242-7(c)(1)

	If a leak is detected, the valve shall be monitored monthly until a
leak is not detected for 2 successive months.	61.242-7(c)(2)



	Monitoring	When a leak is detected, it shall be repaired as soon as
practicable, but no later than 15 calendar days after the leak is
detected, except a provided in §61.242–10.	61.242-7(d)(1)

	A first attempt at repair shall be made no later than 5 calendar days
after each leak is detected.	61.242-7(d)(2)

	Any valve that is designated for no detectable emissions, as indicated
by an instrument reading of less than 500 ppm above background as
described in §61.246(e)(2), is exempt from the requirements of
§61.242-7(a) if the valve meets the requirements in §61.242-7(f)(1-3).
61.242-7(f)

	Unsafe to monitor valves are exempt is personnel would be in danger and
there is a written plan to monitor during safe times.	61.242-7(g)

	Difficult to monitor valves are exempt if monitoring personnel must be
elevated 2 meters, in existing process unit, follows yearly written
monitor plan.	61.242-7(h)



G.8	40 CFR 61 Subpart V, Pressure Relief Services in liquid service and
connectors

Limitation/	61.242-8(a) Pressure relief devices in liquid service and
flanges and other connectors shall be

Standard	monitored within 5 days by the method specified in § 61.245(b)
if evidence of a potential leak is found by visual, audible, olfactory,
or any other detection method.



	Monitoring	Test methods and procedures. Monitoring, as required in §§
61.242, 61.243, 61.244, and 61.135, shall comply with the following
requirements: (1) Monitoring shall comply with Method 21 of appendix A
of 40 CFR part 60.	61.245(b)(1)

	Test methods and procedures. Monitoring, as required in §§ 61.242,
61.243, 61.244, and 61.135, shall comply with the following
requirements: (2) The detection instrument shall meet the performance
criteria of Reference Method 21.	61.245(b)(2)

	Monitoring, as required in §§ 61.242, 61.243, 61.244, and 61.135,
shall comply with the following requirements: (3) The instrument shall
be calibrated before use on each day of its use by the procedures
specified in Reference Method 21.	61.245(b)(3)

	Calibration gases shall be: (i) Zero air (less than 10 ppm of
hydrocarbon in air); and (ii) A mixture of methane or n-hexane and air
at a concentration of approximately, but less than, 10,000 ppm methane
or n-hexane.	61.245(b)(4)

	Monitoring shall comply with the following requirements: (5) The
instrument probe shall be traversed around all potential leak interfaces
as close to the interface as possible as described in Reference Method
21.	61.245(b)(5)

	Pressure relief devices in liquid service and flanges and other
connectors. When a leak is detected, it shall be repaired as soon as
practicable, but not later than 15 calendar days after it is detected,
except as provided in §61.242–10.	61.242-8(c)(1)

	Pressure relief devices in liquid service and flanges and other
connectors. The first attempt at repair shall be made no later than 5
calendar days after each leak is detected.	61.242-8(c)(2)



G.9	40 CFR 61 Subpart V, Surge Control Vessels and bottoms receivers

Limitation/	6 1.242-9(a) ach surge control vessel or bottoms receiver
that is not routed back to the process and

Standard:	that meets the conditions specified in table 1 or table 2 of
40 CFR 61 Subpart V shall be equipped with a closed-vent system capable
of capturing and transporting any leakage from the vessel back to the
process or to a control device as described in §61.242-11, except as
provided in §61.242-1(c).

G.10	40 CFR 61 Subpart V, Closed-vent systems and control devices

Limitation/	61.242-11(a) Owners or operators of close-vent systems and
control devices used to comply with

Standard	provisions of this subpart shall comply with the provisions of
this section, except as provided in §61.242-1(c).



	Monitoring	Vapor recovery systems shall be designed and operated to
recover organic vapors vented to them with an efficiency of 95 percent
or greater or to an exit concentration of 20 ppmv, whichever is less
stringent.	61.242-11(b)

	Enclosed combustion devices shall be designed and operated to reduce
the VHAP emissions vented to them with an efficiency of 95 percent or
greater, or to an exit concentration of 20 ppmvd, corrected to 3 percent
oxygen, whichever is less stringent, or to provide a minimum residence
time of 0.50 seconds at a minimum temperature of 760ºC.	61.242-11(c)

	Flares that are used for compliance with 40 CFR 61 Subpart V shall
comply with the requirements of §60.18.	61.242-11(d)

	Owners or operators of control devices that are used to comply with the
provisions of 40 CFR 61 Subpart V shall monitor these control devices to
ensure that they are operated and maintained in conformance with their
design.	61.242-11(e)

	Except as provided in §61.242-1 1(i-k), each closed vent system shall
be inspected according to the procedures and schedule specified in
§61.242- 11(f)(1) or (2).	61.242-1 1(f)

	Leaks, as indicated by an instrument reading greater than 500 ppmv
above background or by visual inspections, shall be repaired as soon as
practicable except as provided in §61.242-11(h).	61.242-11(g)

	Delay of repair of a closed vent system for which leaks have been
detected is allowed if the repair is technically infeasible without a
process unit shutdown, or if the owner or operator determines that
emissions resulting from immediate repair would be greater than the
fugitive emissions likely to result from the delay of the repair. Repair
of such equipment shall be complete by the end of the next process unit
shutdown.	61.242-11(h)

	If a vapor collection system or closed vent system is operated under a
vacuum,

it is exempt from the inspection requirements of §61.242-1 1(f)(1)(i)
and (2).	61.242-11(i)

	Any parts of the closed vent system that are designated, as described
in paragraph as described in §61.242-1 1(l)(1) as unsafe-to-inspect are
exempt from the inspection requirements of §61.242-1 1(f)(1)(i) and (2)
if they comply with the requirements listed in §61.242-1 1(j)(1-2).
61.242-11(j)

	Any parts of the closed vent system that are designated, as described
in §61.242-1 1(l)(2) as difficult-to-inspect are exempt from the
inspection requirements of §61.242-1 1(f)(1)(i) and (2) if they comply
with the requirements listed in §61.242-11(k)(1-2).	61.242-11(k)

	Closed vent systems and control devices used to comply with provisions
of 40 CFR 61 Subpart V shall be operated at all times when emissions may
be vented to them.	61.242-11(m)

Recordkeeping	The owner or operator shall record the information listed
in §61.242-1 1(l)(1-5)	61.242-11(l)



H.	40 CFR 61 Subpart FF National Emission Standard for Benzene Waste
Operations

Equipment subject to 40 CFR 61 Subpart FF must comply with the
requirements of 40 CFR 61 Subpart A - General

Provisions except where Subpart FF provides for explicit exemptions to
Subpart A. The 40 CFR 61 Subpart A -

General Provisions are found in Attachment F of this permit.

The provisions of this subpart apply to owners and operators of
hazardous waste treatment, storage, and disposal facilities that treat,
store, or dispose of hazardous waste generated by any facility listed in
§61.340(a). The waste streams at hazardous waste treatment, storage,
and disposal facilities subject to the provisions of this subpart are
the benzene-containing hazardous waste from any facility listed in
§61.340(a).	61.340

An owner or operator of a facility at which the total annual benzene
quantity from facility waste is

less than 10 megagrams per year (Mg/yr) shall be exempt from the
requirements of §61.342(b) and (c). The total annual benzene quantity
from facility waste is the sum of the annual benzene quantity for each
waste stream at the facility that has a flow-weighted annual average
water

content greater than 10 percent or that is mixed with water, or other
wastes, at any time and the

mixture has an annual average water content greater than 10 percent.
61.342(a)

Each owner or operator of a facility at which the total annual benzene
quantity from facility waste

is =10 Mg/yr as determined in §61.342 (a) shall manage and treat the
facility waste as follows:

(1) For each waste stream that contains benzene, including (but not
limited to) organic waste streams that contain < 10 % water and aqueous
waste streams, even if the wastes are not discharged to an individual
drain system, the owner or operator shall be subject to the provisions
of §61.342(c)(1)(i – iii).	61.342(c)(1)

A waste stream is exempt from §61.342 (c)(1) provided that the owner or
operator demonstrates

initially and, thereafter, at least once per year that the flow-weighted
annual average benzene

concentration for the waste stream is less than 10 ppmw as determined by
the procedures specified in §61.355(c)(2) or §61.355(c)(3).
61.342(c)(2)

Rather than treating the waste onsite, an owner or operator may elect to
comply with §61.342(c)(1)(i) by transferring the waste offsite to
another facility where the waste is treated in accordance with the
requirements of §61.342(c)(1)(i). The owner or operator transferring
the waste shall abide by the listed provisions.	61.342(f)

Compliance with this subpart will be determined by review of facility
records and results from tests and inspections using methods and
procedures per §61.355.	61.342(g)

The owner or operator shall meet the standards for each container in
which waste is placed in

accordance with §61.342(c)(1)(ii).	61.345(a)

Each cover and all openings shall be visually inspected initially and
quarterly thereafter to ensure

that they are closed and gasketed properly.	61.345(b)

Except as provided in §61.350, when a broken seal or gasket or other
problem is identified, first

efforts at repair shall be made as soon as practicable, but not later
than 15 calendar days after

identification.	61.345(c)

Except as provided in§61.348(a)(5), the owner or operator shall treat
the waste stream in

accordance with 61.348(a)(1-5).	61.348(a)

The owner and operator shall demonstrate that each treatment process or
wastewater treatment

system unit, except per §61.348(d), achieves the appropriate conditions
specified in §61.348(a) or

(b) in accordance with 61.348(c)(1-2).	61.348(c)

A treatment process or waste stream is in compliance with the
requirements of this subpart and

exempt from the requirements of §61.348(c) provided that the owner or
operator documents that

the treatment process or waste stream is in compliance with other
regulatory requirements per

61.348(d)(1-5)	61.348(d)

Except as specified in §61.348(e)(3), if the treatment process or
wastewater treatment system unit has any openings (e.g., access doors,
hatches, etc.), all such openings shall be sealed (e.g., gasketed,
latched, etc.) and kept closed at all times when waste is being treated,
except during inspection and maintenance as listed in this section.
61.348(e)

Except for treatment processes complying with §61.348(d), the
Administrator may request at any time an owner or operator demonstrate
that a treatment process or wastewater treatment system unit meets the
applicable requirements specified in §61.348(a) or (b) by conducting a
performance test using the test methods and procedures as required in
§61.355.	61.348(f)

The owner or operator of a treatment process or wastewater treatment
system unit that is used to

comply with the provisions of this section shall monitor the unit in
accordance with the applicable

requirements in §61.354.	61.348(g)

Except as provided in §61.350, if visible defects are observed during
an inspection, or if other

problems are identified, or if detectable emissions are measured, a
first effort to repair the closed-vent system and control device shall
be made as soon as practicable but no later than 5 calendar days after
detection. Repair shall be completed no later than 15 calendar days
after the emissions are detected or the visible defect is observed.
61.349(g)

Specifications for monitoring non-regenerative carbon adsorption
systems.	61.354(d)

An owner or operator shall determine the total annual benzene quantity
from facility waste by the

procedures in accordance with 61.355(a)(1-6).	61.355(a)

For purposes of the calculation required by §61.355(a), an owner or
operator shall determine the

annual waste quantity at the point of waste generation, unless otherwise
provided in §61.355(b) (1),

(2), (3), and (4), by one of the methods given in §61.355 (b) (5)
through (7).	61.355(b)

For the purposes of the calculation required by §61.355(a), an owner or
operator shall determine the flow-weighted annual average benzene
concentration in a manner that meets the requirements given in §61.355
(c)(1) using either of the methods given in §61.355 (c)(2) and (c)(3).
61.355(c)

Each owner or operator shall maintain records that identify each waste
stream at the facility subject

to this subpart, and indicate whether or not the waste stream is
controlled for benzene emissions in

accordance with this subpart. In addition the owner or operator shall
maintain the records as required under sections 1-6 of 61.356(b)(1-6).
61.356(b)

An owner or operator transferring waste off-site to another facility for
treatment in accordance with

§61.342(f) shall maintain documentation for each offsite waste shipment
that includes the listed

information.	61.356(c)

An owner or operator using a treatment process or wastewater treatment
system unit in

accordance with §61.348 shall maintain the records in accordance with
§61.356(e)(1-4). The

documentation shall be retained for the life of the unit.	61.356(e)

For each treatment process and wastewater treatment system unit operated
to comply with

§61.348, the owner or operator shall maintain documentation that
includes the listed information.	61.356(i)



H.1	40 CFR 61 Subpart FF, Control device, thermal oxidizer

a. Limitation/	61.349(a)(2)(i) Enclosed combustion device shall be
designed and operated with a minimum

Standard	residence time of 0.5 seconds and a minimum temperature of 760
C



	Monitoring	Quarterly visual inspections for each closed-vent system and
control

device including ductwork, piping, connections to cover and control

devices.	61.349(f)(ii)

	The owner or operator of a control device that is used to comply with
the provisions of this section shall monitor the control device in
accordance with §61.354(c).	61.349(h)

	Except for a treatment process or waste stream complying with

§61.348(d), the owner or operator shall monitor each treatment process
or wastewater treatment system unit to ensure the unit is properly
operated and maintained by the monitoring procedures in accordance with
sections 1-2 of 61.354(a)	61.354(a)

	Inspect control device monitoring equipment daily.	61.354(c)

	Install a temperature sensor with a continuous recorder in thermal
vapor incinerator	61.354(c)(1)

	Owners or operators using a closed-vent system that contains any bypass
line that could divert a vent stream from a control device used to
comply with the provisions of this subpart shall do the listed items.
61.354(f)

Reporting	Submit quarterly certifications that all of the required
inspections have

been carried out	61.357(d)(6)

	Submit quarterly reports recording each three hour period when average
temperature of gas stream in combustion zone of thermal vapor
incinerator is greater than 28 deg Celsius below the design combustion
zone temperature.	61.357(d)(7)(iv)(A)

	Submit annual report that summarizes all inspections required by

61.342 - 61.345 during which detectable emissions are measured or a
problem that could result in benzene emissions is identified, including
repair or corrective taken.	61.357(d)(8)

Recordkeeping	Maintain records onsite for at least two years.	61.356(a)

	Maintain engineering design documentation for all control equipment
installed on the waste management unit for the life of the equipment.
Also maintain control device records require by paragraph (f)	61.356(d)

	Retain a signed statement certifying design of the closed-vent system
and control device for the life of the device	61.356(f)(1)

	Maintain visual inspection records required by 61.343 through 61.347
that identify a problem which could result in benzene emissions
61.356(g)

	For each control device, the owner or operator shall maintain

documentation that includes the following information regarding the

control device operation: (1) Dates of startup and shutdown of the

closed-vent system and control device.	61.356(j)(1)





	Recordkeeping	Record description and explanation of parameters to be
monitored to ensure compliance, keep for life of source.	61.356(j)(2)

	Record periods when the closed vent system and control device are

not operated as designed, including any valve car-seal or closure

mechanism that is broken or when vapors are not routed to control

device.	61.356(j)(3)

	If a thermal vapor incinerator is used, then the owner or operator
shall maintain continuous records of the temperature of the gas stream
in the combustion zone of the incinerator	61.356(j)(4)

	An owner or operator shall demonstrate compliance of each flare in

accordance with (a)(2)(iii) of this section.	61.349(d)

Testing	Demonstrate control device achieves required control efficiency
by

using engineering calculations as specified in 61.356(f) or performance
test as specified in 61.355.	61.349(c)

	Initial visual inspections for each closed-vent system and control

device including ductwork, piping, connections to cover and control
devices.	61.349(f)(i)



Limitation/	61.349(b) Must operate all closed-vent systems and control
devices when waste is in the system.

      Standard	



	Monitoring	None required.	N/A

Reporting	None required.	N/A

Recordkeeping	For each control device, the owner or operator shall
maintain documentation that includes the following information regarding
the control device operation: (1) Dates of startup and shutdown of the
closed-vent system and control device.	61.356(j)(1)



Limitation/	6 1.350(a) Delay of repair will be allowed if the repair is
technically impossible without a 		  Standard	complete or partial
facility or unit shutdown.

Monitoring	Must make delayed repairs before end of the next facility or
unit shutdown.	61.350(b)



H.2	40 CFR 61 Subpart FF, Closed-vent system

Limitation/	61.349(a)(1)(i) Must have closed-vent system and control
device with no detectable emissions           	Standard 	(No readings
>500 ppmv above background). (Per 61.349(a)(1)(iii) gauging and sampling
devices 		must be gas-tight)



	Monitoring	One or more devices which vent directly to the atmosphere
may be

used on the closed-vent system provided each device remains in a

closed, sealed position during normal operations	61.349(a)(1)(iv)

	Quarterly visual inspections for each closed-vent system and

control device including ductwork, piping, connections to cover and
control devices.	61.349(f)(ii)

Reporting	None required.	N/A

Recordkeeping	Maintain records onsite for at least two years.	61.356(a)

	Maintain visual inspection records required by 61.343 through

61.347 that identify a problem which could result in benzene

emissions 	61.356(g)

Testing	Initial visual inspections for each closed-vent system and
control

device including ductwork, piping, connections to cover and control
devices.	61.349(f)(i)

	Monitor emissions for compliance with no detectable emissions.

Use Method 21 from Appendix A of 40 CFR 60.	61.355(h)



Limitation/	61.349(a)(1)(i) Must have closed-vent system and control
device with no detectable emissions 	Standard	(No  readings >500 ppmv
above background). (Per 61.349(a)(1)(iii) gauging and sampling 		
devices must be gas-tight)



	Reporting	Submit quarterly certifications that all of the required
inspections

have been carried out.	61.357(d)(6)

	Submit annual report that summarizes all inspections required by

61.342 - 61.345 during which detectable emissions are measured or a
problem that could result in benzene emissions is identified,

including repair or corrective taken.	61.357(d)(8)

Recordkeeping	Maintain records for each test of no detectable emissions
61.356(h)



Limitation/	61.349(b) Must operate all closed-vent systems and control
devices when waste is in the    	Standard:	system.   



	Recordkeeping	For each control device, the owner or operator shall
maintain

documentation that includes the following information regarding the
control device operation: (1) Dates of startup and shutdown of the
closed-vent system and control device.	61.356(j)(1)



H.3	40 CFR 61 Subpart FF, Tank

Limitation/	61.342(b) Must be in compliance with requirements of
paragraphs c through h of this section 		Standard	within 90 days of
effective date.



	Reporting	Submit a report to the Administrator summarizing regulatory
status of each waste stream. This report must be submitted within 90
days after January 7, 1993 or by initial startup for a new source that
starts after January 7,1993	61.357(a)

	If the total annual benzene quantity from facility waste is less than 1
Mg/yr, then the owner or operator shall submit to the Administrator a
report that updates the information listed in paragraphs (a)(1)-(a)(3)
of this section whenever there is a change in the process generating the
waste stream that could cause the total annual benzene quantity from
facility waste to increase to 1 Mg/yr or more.	61.357(b)

	If the total annual benzene quantity from facility waste < 10 Mg/yr but
is equal to or greater than 1 Mg/yr, then the owner or operator shall
submit to the Administrator a report that updates the information listed
in (a)(1)-(a)(3) of this section. The report shall be submitted annually
and whenever there is a change in the process generating the waste
stream that could cause the total annual benzene quantity from facility
waste to increase to 10 Mg/yr or more.	61.357(c)

	Unless a waiver of compliance is granted, submit a cert that the equip

necessary to comply with these stds has been installed and that the
required initial inspections or tests have been carried out. Submit by
date of initial startup for new source.	61.357(d)(1)

	Submit annual report updating information in paragraphs (a)(1) through
(a)(3).	61.357(d)(2)



Limitation/	61.343(a)(1)(i)(A) No detectable emissions (>500 ppm above
background) from tank cover or

     Standard	openings. (Per 61.349(a)(1)(iii) gauging and sampling
devices must be gas tight except when 	gauging or sampling is taking
place.)



	Monitoring	No detectable emissions (>500 ppm above background) from
tank

cover or openings. (Per 61.349(a)(1)(iii) gauging and sampling

devices must be gas-tight)	61.343(a)(1)(i)(A)

	Monitor once per year in accordance with Method 21	61.343(a)(1)(i)(A)

Reporting	Submit quarterly certifications that all of the required
inspections

have been carried out	61.357(d)(6)

	Submit annual report that summarizes all inspections required by

61.342 - 61.345 during which detectable emissions are measured or a
problem that could result in benzene emissions is identified, including
repair or corrective taken.	61.357(d)(8)

Recordkeeping	Maintain records onsite for at least two years.	61.356(a)

	Maintain records for each test of no detectable emissions	61.356(h)

Testing	Monitor emissions for compliance with no detectable emissions.

Use Method 21 from Appendix A of 40 CFR 60.	61.355(h)



c. Limitation/	61.343(a)(1)(i)(B) Close and seal tank openings. (Per
61.349(a)(1)(iv), pressure relief valves can    	Standard	 be used when
necessary to prevent physical damage or permanent deformation of tank)

Testing	Complete quarterly visual inspections of openings for closure
and

tightness	61.343(c)(ii)

	One or more devices which vent directly to the atmosphere may be

used on the closed-vent system provided each device remains in a

closed, sealed position during normal operations	61.349(a)(1)(iv)



Limitation/	61.343(a)(1)(i)(B) Close and seal tank openings. (Per
61.349(a)(1)(iv), pressure relief valves can 	Standard	be used when
necessary to prevent physical damage or permanent deformation of tank)



	Monitoring	Complete initial visual inspections of openings for closure
and tightness.	61.343(c)(i)

	Repair broken seals or gaskets and fix emission leaks on tanks within
45 calendar days of problem identification.	61.343(d)

Reporting	Submit quarterly certifications that all of the required
inspections have

been carried out 	61.357(d)(6)

	Submit annual report that summarizes all inspections required by 61.342
-61.345 during which detectable emissions are measured or a problem that
could result in benzene emissions is identified, including repair or
corrective taken.	61.357(d)(8)

Recordkeeping	Maintain records onsite for at least two years.	61.356(a)

	Maintain visual inspection records required by 61.343 through 61.347

that identify a problem which could result in benzene emissions.
61.356(g)



Limitation/	6 1.350(a) Delay of repair will be allowed if the repair is
technically impossible without a 		Standard	complete or partial facility
or unit shutdown.

		

Monitoring	Must make delayed repairs before end of the next facility or
unit shutdown.	61.350(b)

H.4	40 CFR 61 Subpart FF, Control device, carbon absorption system that
does not regenerate the carbon bed directly

a. Limitation/	61.349(a)(2)(ii) The vapor recovery system must have > or
= 95 weight % control of organics or >  	Standard	or = 98 weight %
control of benzene.



	Monitoring	Quarterly visual inspections for each closed-vent system and
control device.

including ductwork, piping, connections to cover and control devices.
61.349(f)(ii)

	Inspect control device monitoring equipment daily.	61.354(c)

	Monitor control device daily and replace carbon when breakthrough is

indicated, or replace the carbon at a regular predetermined time
interval.	61.354(d)

Recordkeeping	Maintain records onsite for at least two years.	61.356(a)





Maintain engineering design documentation for all control equipment
installed on the waste management unit for the life of the equipment.
Also maintain control device records require by paragraph (f)	61.356(d)

	Retain a signed statement certifying design of the closed-vent system
and

control device for the life of the device.	61.356(f)(1)

	Retain documentation of engineering calculations used to determine
control device (carbon absorption system that does not regenerate the
carbon bed directly) perf for the life of the control device. Maintain a
design analysis for the control device.	61.356(f)(2)(i)(G)

	Maintain visual inspection records required by 61.343 through 61.347
that

identify a problem which could result in benzene emissions.	61.356(g)

	For each control device, the owner or operator shall maintain
documentation that includes the following information regarding the
control device operation: (1) Dates of startup and shutdown of the
closed-vent system and control device.	61.356(j)(1)

	Record description and explanation of parameters to be monitored to
ensure compliance, keep for life of source.	61.356(j)(2)

Testing	Demonstrate control device achieves required control efficiency
by using

engineering calculations as specified in 61.356(f) or performance test
as

specified in 61.355.	61.349(c)

	Initial visual inspections for each closed-vent system and control
device

including ductwork, piping, connections to cover and control devices.
61.349(f)(i)



Limitation/	61.349(a)(2)(ii) The vapor recovery system must have 95
weight % control of organics or 98 		Standard	weight % control of
benzene.



	Reporting	Submit quarterly certifications that all of the required
inspections have been carried out.	61.357(d)(6)

	Submit annual report that summarizes all inspections required by 61.342
- 61.345 during which detectable emissions are measured or a problem
that could result in benzene emissions is identified, including repair
or corrective taken.	61.357(d)(8)

Recordkeeping	Record periods when the closed vent system and control
device

are not operated as designed, including any valve car-seal or

closure mechanism that is broken or when vapors are not routed

to control device.	61.356(j)(3)

	If a carbon adsorber is not regenerated directly on site, owner

shall record times of monitoring, breakthrough, and replacement.
61.356(j)(10)



Limitation/	61.349(b) Must operate all closed-vent systems and control
devices when waste is in the 	Standard:	system.

Recordkeeping	For each control device, the owner or operator shall
maintain documentation that includes the following information regarding
the control device operation: (1) Dates of startup and shutdown of the
closed-vent system and control device.	61.356(j)(1)



d. Limitation/    61.350(a) Delay of repair will be allowed if the
repair is technically impossible without a 	  	Standard:	complete or
partial facility or unit shutdown.

Monitoring	Must make delayed repairs before end of the next facility or
unit shutdown.	  61.350(b)



H.5	40 CFR 61 Subpart FF, Treatment process

Limitation/	61.348(a)(1)(iii) Must have waste treatment process
(combustion unit) that destroys 99% of 	

	Standard:	benzene.    	

Monitoring	Install, calibrate, operate, maintain, and inspect the data
each day from a CEM for a process parameter that indicates proper system
operation.	61.354(a)

Recordkeeping	Maintain records onsite for at least two years.	61.356(a)

	Retain a signed statement certifying design of the waste treatment

process unit for the life of the unit.	61.356(e)(1)

	Maintain documentation of the dates of start up and shut down of the

treatment process. 	61.356(i)(1)

	The owner or operator shall maintain documentation that includes the

following information regarding the unit operation: (5) Periods when

the unit is not operated as designed.	61.356(i)(5)

Testing	The treatment process is exempt from performance testing since
Ash

Grove has been issued a final permit under 40 CFR 266 subpart D.
61.348(d)(2)



Limitation/	61.348(e) Openings shall be sealed and kept closed at all
times except during inspection and

      Standard:	maintenance

Monitoring	Complete initial and quarterly visual inspections of openings
for

closure and tightness.	61.348(e)(1)

	Install, calibrate, maintain, and operate continuous pressure monitor.
61.354(g)

Recordkeeping	Maintain records onsite for at least two years.	61.356(a)

	Maintain records of monitoring device and records of all periods when
pressure is greater than atmospheric.	61.356(m)



Limitation/	6 1.350(a) Delay of repair will be allowed if the repair is
technically impossible without a 		Standard:	complete or partial
facility or unit shutdown.



	Monitoring	Must make delayed repairs before end of the next facility or
unit. shutdown.	61.350(b)

Recordkeeping	Maintain documentation of the dates of start up and shut
down of the

treatment process. 	61.356(i)(1)

	The owner or operator shall maintain documentation that includes the

following information regarding the unit operation: (5) Periods when the

unit is not operated as designed.	61.356(i)(5)



I.	40 CFR Part 63 Subpart A General Provisions

Applicable citations for 40 CFR 63 Subpart A are provided in Attachment
G.



J.	40 CFR 63 Subpart DD

General Requirements

Applicable Requirement (Summary)

Equipment subject to 40 CFR 63 Subpart DD must comply with the
requirements of 40 CFR 63 Subpart A – General Provisions except where
Subpart DD provides for explicit exemptions to Subpart A. The 40 CFR 63
Subpart A - General Provisions are found in Attachment G of this permit.

The provisions of this subpart apply to the owner and operator of a
plant site for which both of the conditions specified in §63.680(a)(1)
and (a)(2) are applicable according to the definitions and exemptions
presented in §63.680(b)-(d), (f), and §63.681 and the dates in
§63.680(e).	63.680

Definitions	63.681

This section applies to owners and operators of affected sources as
defined in §63.680(c) of this subpart.	63.683(a)

Air emissions from each affected source must be controlled per one of
the requirements in

§63.683(b)(1) (i)-(iii).	63.683(b)(1)

Exempted off-site material management units. An off-site material
management unit is exempted from the requirements specified in
§63.683(b) when the unit meets any one of the exemptions provided in
§63.683(c)(1-5).	63.683(b)(2)

The provisions of this section apply to the control of air emissions
from tanks for which §63.683(b)(1)(i) references the use of this
section for such air emission control.	63.685(a)

The owner or operator shall control air emissions from each tank subject
to this section in accordance with the applicable requirements listed in
§63.685(1)-(4).	63.685(b)

Owners and operators controlling air emissions from a tank using Tank
Level 2 controls shall use one of the requirements listed as
§63.685(1)-(5).	63.685(d)

The owner or operator who controls tank air emissions by venting to a
control device shall meet the requirements in §63.685(g)(1-3).
63.685(g)

The provisions of this section apply to the control of air emissions
from containers for which §63.683 (b)(1)(i) references the use of this
section for such air emission control.	63.688(a)

The owner or operator shall control air emissions from each container
subject to this section in accordance with the requirements, as
applicable to the container, of §63.688(1)-(3).	63.688(b)

The provisions of this section apply to the control of air emissions
from transfer systems for which §63.683 (b)(1)(i) references the use of
this section for such air emission control.	63.689(a)

For each transfer system that is subject to this section, but is not an
individual drain system, the owner or operator shall control air
emissions by using one of the listed systems in §63.689(c)(1)

through (c)(3).	63.689(c)

The provisions of this section apply to the control of air emissions
from equipment leaks for which §63.683 (b) references the use of this
section for such air emission control.	63.691

The provisions of this section apply to closed-vent systems and control
devices used to control air emissions for which another standard
references its use.	63.693(a)

For each closed-vent system and control device used to comply with this
section, the owner or operator shall meet the requirements of §63.693
(1)-(8).	63.693(b)

Closed-vent system requirements. The vent stream required to be
controlled shall be conveyed to the control device by either of the
closed-vent systems detailed in § 63.693 (1) and (2).	63.693(c)

Carbon adsorption control device requirements	63.693(d)

The carbon adsorption system shall be designed and operated to achieve
one of the performance

specifications detailed in §63.693(d)(1) (i) or (ii).	63.693(d)(1)

Applicable Requirement (Summary)

The owner or operator shall demonstrate that the carbon adsorption
system achieves the

performance requirements of §63.693(d)(1) by one of the methods
detailed in §63.693 (d)(2)(i) or (ii).	63.693(d)(2)

The owner or operator must monitor the operation of the carbon
adsorption system in accordance

with the requirements of § 63.695(e) using one of the continuous
monitoring systems specified in

§63.693(d)(3) (i)-(iii). Monitoring of non-regenerative carbon
adsorption systems using continuous monitoring systems is not required
when the carbon is replaced on a regular basis per

§63.693(d)(4)(iii).	63.693(d)(3)

The owner or operator shall manage the carbon used for the carbon
adsorption system, as described in §63.693(i) - (iii).	63.693(d)(4)

Flare control device requirements.	63.693(h)

The flare must be designed and operated in accordance with 40 CFR
63.11(b)	63.693(h)(1)

The owner or operator must demonstrate that the flare achieves the
requirements in §63.693 (h)(1) by the procedures in §63.693 (h)(2)(i)
or (ii).	63.693(h)(2)

The owner or operator must monitor the operation of the flare using a
heat sensing monitoring device that continuously detects the presence of
a pilot flame in accordance with the listed parameters.	63.693(h)(3)

This section specifies the testing methods and procedures required for
this subpart to determine

HAP and VOHAP concentrations, rates, and limits for the items listed in
§63.694(1)-(12).	63.694

This section specifies the inspection and monitoring procedures required
to perform the items listed in §63.695 (1)-(4).	63.695(a)

Tank Level 2 fixed roof and floating roof inspection requirements.
63.695(b)

Fixed roof provisions	63.695(b)(3)

The owner or operator will repair each defect detected during an
inspection in the listed manner.	63.695(b)(4)

Owners and operators that use a closed vent system in accordance with
the provisions of §63.693

shall meet the inspection and monitoring requirements of this section.
63.695(c)

The owner or operator subject to this subpart shall comply with the
record keeping requirements in §63.10 under 40 CFR 63 subpart A-General
Provisions that are applicable to this subpart as specified in Table 2.
63.696(a)

The owner or operator of a control device subject to this subpart shall
maintain the records in

accordance with 40 CFR 63.10.	63.696(b)

Each owner or operator using a fixed roof to comply with the tank
control requirements specified in §63.685(g) shall prepare and maintain
the records specified in this section.	63.696(e)

An owner or operator shall record, on a semiannual basis, the
information specified in §63.696(g)(1-2) for those planned routine
maintenance operations that would require the control device not to meet
the requirements of §63.693 (d-h), as applicable.	63.696(g)

An owner or operator shall record the information specified in
§63.696(h)(1-3) for those unexpected control device system malfunctions
that would require the control device not to meet the requirements of
§63.693 (d-h), as applicable.	63.696(h)

The owner or operator of a control device used to meet the requirements
of §63.693 shall submit the reports specified in this section to the
Administrator.	63.697(b)

Delegation of authority	63.698



J.1   40 CFR 63 NESHAP - DD, Equipment leak



	Monitoring	Monitoring and Recordkeeping in accordance with 40 CFR 61
Subpart V	40 CFR 61

	Sections 61.242 - 61.247	Subpart V

 a. Limitation/ Standard    63.683(d) Must control equipment leaks from
each equipment component of a transfer 		system by implementing leak
detection and control measures per 63.69 1 (40 CFR 61 		Subpart V)

b. Limitation/	63.691(b)(1) Must control equipment leaks from each
equipment component of a transfer system

   Standard:	by implementing leak detection and control measures per
63.69 1 (40 CFR 61 Subpart V)



	Monitoring	Monitoring and Recordkeeping in accordance with 40 CFR 61
Subpart V Sections 61.242 - 61.247	40 CFR 61

Subpart V



J.2	40 CFR 63 NESHAP - DD, Transfer system

a. Limitation/	63.689(c)(2) Transfer system must consist of continuous
hard piping, joints to be welded or

   Standard:	flanged with gasket and bolts.

Monitoring	an annual walkthrough



b. Limitation/	63.697(a)(1) Must submit notifications in 63.9(b)(2)
before October 9, 1999

    Standard:

Monitoring	Compliance with other sections of this rule demonstrates
compliance  with this rule.	No Regulatory

Requirements



c. Limitation/	63.697(a)(2) Must submit notifications in 63.10

   Standard:

Monitoring	Compliance with other sections of this rule demonstrates
compliance  with this rule.	No Regulatory

Requirements



K.	40 CFR Part 63 Subpart PP

General Requirements

Applicable Requirement (Summary)

Equipment subject to 40 CFR 63 Subpart PP must comply with the
requirements of 40 CFR 63 Subpart A – General Provisions except where
Subpart PP provides for explicit exemptions to Subpart A. The 40 CFR 63
Subpart A - General Provisions are found in Attachment G of this permit.

The provisions of this subpart apply to the control of air emissions
from containers for which

another subpart of 40 CFR parts 60, 61, or 63 references its use in
accordance with the definitions in §63.921.	63.920

The owner or operator shall inspect containers using Container Level 1
controls in accordance with the procedures specified in §63.926 (a) of
this subpart.	63.922(e)

For the purpose of compliance with §63.922(b)(1), containers shall be
used that meet the applicable U.S. DOT regulations on packaging
hazardous materials for transportation as detailed in
§63.922(f)(1)-(3).	63.922(f)

Applicable Requirement (Summary)

This section applies to owners and operators subject to this subpart and
required to control air emissions from containers using Container Level
2 controls.	63.923(a)

The owner or operator shall inspect containers using Container Level 2
controls in accordance with the procedures specified in §63.926(a).
63.923(e)

For the purpose of compliance with §63.923(b)(1), containers shall be
used that meet the applicable U.S. DOT regulations on packaging
hazardous materials for transportation as detailed in
§63.923(f)(1)-(3).	63.923(f)



40 CFR 63 MACT – PP, Containers – Level 1 Controls (Emissions from
containers for which another subpart of 40 CFR 60, 61 or 63 references
this subpart)

a. Limitation/ Standard:  63.922(b) Containers required to use Level 1
controls shall meet the U.S. Department of Transportation regulations,
be equipped with a cover and closure device that form a continuous
barrier over the container, or be equipped with an open-top container in
which an organic vapor-suppressing barrier is placed on or over the
regulated-material in the container such that no regulated-material is
exposed to the atmosphere.



	Monitoring	None required at this time

Reporting	None required at this time

Recordkeeping	None required at this time

Testing	None required at this time



Limitation/	  63 .922(d) All covers and closure devices shall be
maintained in the closed position except as

    Standard:	  provided in 63.922(d)(1)-(5).



	Monitoring	If regulated material is in the container at the time the
owner/operator

first accepts possession and not emptied within 24 hours, the

owner/operator shall visually inspect the container and its cover and

closure device. This inspection shall occur on or before the container
is

accepted at the facility. If a defect is detected the repair shall be

conducted as specified in 63.926(a)(3);	63.926(a)(1)

	If a container containing regulated material remains unopened at the

facility site for one year or more, the container shall be inspected
initially and at least once every calendar year. If a defect is detected
the repair shall be conducted as specified in 63.926(a)(3).	63.922(a)(2)



40 CFR 63 MACT – PP, Containers – Level 2 Controls (Emissions from
containers for which another subpart of 40 CFR 60, 61 or 63 references
this subpart)

Limitation/	63.923(b)(1) & (2) Containers required to use Level 2
controls shall meet the U.S. Department of

     Standard:	Transportation (DOT) regulations, operate with no
detectable emissions as defined in 40 CFR 63.921, or have demonstrated
within the previous twelve months that the container is vapor-tight



	Monitoring	None required at this time

Reporting	None required at this time

Recordkeeping	None required at this time

Testing	Demonstrate no detectable organic emissions at each potential
leak interface on the cover and associated closure device using the
procedures specified in Method 21 of 40 CFR part 60, appendix A.
63.925(a)

	Demonstrate vapor-tightness in accordance with Method 27 of 40 CFR part
60, Appendix A.	63.925(b)



Limitation/	63.923(c) Transfer of regulated-material into or out of
Level 2 Container shall be conducted so as

     Standard:	to minimize exposure of the regulated material to the
atmosphere.



	Monitoring	None required at this time

Reporting	None required at this time

Recordkeeping	None required at this time

Testing	None required at this time



Limitation/	63.923(d) All covers and closure devices shall be maintained
in the closed position except as

     Standard:	provided in 63.923(d)(1)-(5).



	Monitoring	If regulated material is in the container at the time the
owner/operator first accepts possession and not emptied within 24 hours,
the owner/operator shall visually inspect the container and its cover
and closure device. This inspection shall occur on or before the
container is accepted at the facility. If a defect is detected the
repair shall be conducted as specified in 63.926(a)(3);	63.926(a)(1)

	If a container containing regulated material remains unopened at the
facility site for one year or more, the container shall be inspected
initially and at least once every calendar year. If a defect is detected
the repair shall be conducted as specified in 63.926(a)(3).	63.922(a)(2)



K.3	40 CFR 63 MACT – PP, Containers – Level 3 Controls (Emissions
from containers for which another subpart of 40 CFR 60, 61 or 63
references this subpart)

Limitation/ 	63.924(b) Containers required to use Level 3 controls shall
be vented directly through a

Standard: 	closed-vent system to a control device or vented inside an
enclosure which is exhausted through a 		closed-vent  system to a
control device.



	Monitoring	The closed-vent system shall be inspected and monitored in
accordance with § 63.693 in 40 CFR part 63, subpart DD – National
Emission Standards for Hazardous Air Pollutants from Off-Site Waste and
Recovery Operations.	63.926(b)

Reporting	Prepare and submit reports required for closed-vent systems
and control

devices in accordance with § 63.693 in 40 CFR part 63, subpart DD –

National Emission Standards for Hazardous Air Pollutants form Off-Site

Waste and Recovery Operations.	63.928(a)

Recordkeeping	Maintain records of the most recent set of calculations
performed to verify that the enclosure meets the criteria of a permanent
total enclosure as specified in “Procedure T – Criteria for and
Verification of a Permanent or Temporary Total Enclosure” under 40 CFR
52.741, Appendix B.	63.927(a)(1)

Recordkeeping	Maintain records required for the closed-vent system and
control device in accordance with the requirements of § 63.693 in 40
CFR part 63, subpart DD – National Emission Standards for Hazardous
Air Pollutants form Off-Site Waste and Recovery Operations.	63.927(a)(2)



Section L

Subpart EEE - National Emission Standards for Hazardous Air Pollutants

from Hazardous Waste Combustors

Note: All regulatory references pertain to 40 CFR Part 63, unless
otherwise noted.

	1.0	Modes of Operation

The hazardous waste combustion system has four Subpart EEE compliance
modes of operation:

Mode 1: raw mill on with no hazardous waste in the chamber; 

Mode 2: raw mill off with no hazardous waste in the chamber; 

Mode 3: raw mill on with hazardous waste in the chamber; and

Mode 4: raw mill off with hazardous waste in the chamber.

In accordance with 40 CFR 63.1 209(q)( 1), Ash Grove may elect to
operate in modes 1 and 2 when not burning hazardous waste and the
hazardous waste residence time has expired. Both modes contain the
otherwise applicable requirements of 40 CFR Part 63, Subpart LLL. These
requirements become applicable requirements under Subpart EEE and are
presented in this section.

While operating under different modes of operation:

The facility must document in the operating record a change in a mode of
operation and compliance with the operating limits for an alternative
mode of operation (63.1204(d)(1 )(ii)).

The facility shall calculate averages under the different modes of
operation per alternate monitoring approved by the EPA on July 9, 2001
(63.1209(g) and 63.8(f)).

Comparable fuels, used oils and other non-hazardous wastes that are
blended with hazardous are considered hazardous wastes and shall be
burned under the definition and requirements of hazardous wastes.

	2.0	Emission Standards and Operating Limits

The owner or operator shall comply with the applicable section of 40 CFR
Part 63, Subpart A (Attachment G) as identified in Table 1 to 40 CFR
Part 63, Subpart EEE, 40 CFR Part 63, Subpart EEE and when operating in
modes 1 and 2, the otherwise applicable standards of 40 CFR Part 63,
Subpart LLL in lieu of the substantive requirements of 40 CFR Part 63,
Subpart EEE. The facility shall comply with the EPA-approved alternative
monitoring methods and procedures dated February 6, 2001 and July 9,
2001.

	Operating parameter limits were established through performance testing
and/or equipment 	manufacturer specifications and ensure compliance with
the emission standards. The operating 	parameter limits are included in
the most recent Notification of Compliance (NOC). These 	operating
parameters may change if performance testing is conducted per Subsection
3.0.  In the 	event of subsequent changes to the NOC, the permittee
shall:

operate in accordance with the most recent NOC (based on postmark date
of the submittal), and

together with the revised NOC, submit a permit modification application
to incorporate any necessary revisions into the Title V permit (K.A.R.
28-19-513, 40 CFR 63.1206, 40 CFR 63.1210, and 40 CFR 70.7(e)(2)(v)).

The EPA finalized Phase I replacement standards for Subpart EEE on
October 12, 2005.  The facility will comply with the replacement
standards per the timeframe specified in the regulation.

	2.1	Destruction and Removal Efficiency Emissions Limitation

The owner or operator shall achieve a destruction and removal efficiency
(DRE) of 99.99% (63. 1204(c)(1 )).

Monitoring

The facility shall demonstrate continuous compliance with the DRE
standards by complying with the operating parameter limits specified in
the most recent Notification of Compliance.

Modes 3 and 4

Minimum combustion chamber temperature profile on a three-hour rolling
time block (63.1209(j)(1));

Maximum gas flowrate on an hourly rolling average (63.1209(j)(2));

Maximum MCBP LWDF feedrate on an hourly rolling average (63.1209(j)(3));

Maximum DDC LWDF feedrate (including BWF)on an hourly rolling average
(63.1209(j)(3)); and

Maximum SEI SWDF feedrate on an hourly rolling average (63.1209(j)(3)).

	2.2	Dioxins/Furans

	Emissions Limitation

The owner or operator shall not cause combustion gases to be emitted
into the atmosphere that contain dioxins/furans:

i	Emissions in excess of 0.20 ng TEQ/dscm corrected to 7 percent oxygen
(63. 	1204(b)(1)(i)); or

ii 	Emissions in excess of 0.40 ng TEQ/dscm corrected to 7 percent
oxygen provided that the combustion gas temperature at the inlet to the
initial dry particulate matter control device is 400 (F or lower based
on the average of the test run average temperatures (63.
1204(b)(1)(ii)).

Monitoring

The facility shall demonstrate continuous compliance with the
dioxin/furans emission standards by complying with the operating
parameter limits specified in the most recent Notification of
Compliance.

Modes 1 and 2

Maximum inlet gas temperature to the kiln/raw mill baghouse on a
three-hour rolling average (63.1350(f)(2));

Maximum inlet gas temperature to the bypass baghouse on a three-hour
rolling average (63.1350(f)(2)); and

Maximum inlet gas temperature to the coal mill baghouse on a three-hour
rolling average (63.8(g) alternative to 63.1350(f)(2)).

Modes 3 and 4

Maximum inlet gas temperature to the kiln/raw mill baghouse on an hourly
rolling average (63.1209(k)(1 )(i));

Maximum inlet gas temperature to the bypass baghouse on an hourly
rolling average (63.1209(k)(1 )(i));

Maximum inlet gas temperature to the coal mill baghouse on an hourly
rolling average (63.1209(g) alternative to 63.1209(k)(1 )(i));

Minimum combustion chamber temperature profile on a three-hour rolling
time block (63.1209(g) alternative to 63.1209(k)(2));

Maximum stack gas flowrate on an hourly rolling average
(63.1209(k)(3)(i) & (ii));

Maximum MCBP LWDF feedrate on an hourly rolling average (63.1
209(k)(4)(i) &  	(ii));

Maximum DDC LWDF feedrate (including BWF) on an hourly rolling average
(63. 1209(k)(4)(i) &  ii)); 	and

Maximum SEI SWDF feedrate on an hourly rolling average (63.
1209(k)(4)(i) & (ii)).

Mercury

      	Emissions Limitation

The owner or operator shall not cause combustion gases to be emitted
into the atmosphere that contain mercury in excess of 120 (g/dscm
corrected to 7 percent oxygen.

The facility shall demonstrate compliance with the mercury emission
standards by complying with the following equation (63. 1204(d)(2)) on
an annual basis based on a one-year block average performed June 12 of
every year:

Where:	CHG,Total

CHG,millon

CHG,milloff

Tmillon

Tmilloff	=	Time-weighted average concentration of mercury

=	Extrapolated emission concentration of mercury with the raw mill on
line (operating mode 3)

=	Extrapolated emission concentration of mercury with the raw mill off
line (operating mode 4)

=	Time when kiln gases are routed through the raw mill (operating mode
3)

=	Time when kiln gases are not routed through the raw mill (operating
mode 4)



Monitoring

The facility shall demonstrate compliance with the mercury emission
standards by complying with the operating parameter limits specified in
the most recent Notification of Compliance.

Modes 3 and 4

Maximum total mercury feedrate on a 12-hour rolling average
(63.1209(l)).

 	

2.4 	Particulate Matter

Emissions Limitation

The owner or operator shall not cause combustion gases to be emitted
into the atmosphere that contain particulate matter in excess of 0.15
kg/Mg dry feed and opacity greater than 20 percent (63.1 204(b) (7)).

Monitoring

The facility  shall demonstrate continuous compliance with the
particulate matter emission standards by complying with the operating
parameter limits specified in the most recent Notification of
Compliance.

Modes 1 and 2

	1.	Continuously monitor the average opacity for each six-minute block
period with a 	Continuous Opacity Monitor System (COMS) (63.1350(c)(3)).

Modes 3 and 4

Continuously monitor the average opacity for each six-minute block
period with a COMS (63.1209(a)(1 )(ii)(B));

Maximum stack gas flowrate on an hourly rolling average
(63.1209(m)(2)(i) & (ii)).

Continuously monitor the particulate matter emission rate with a
Continuous Emission Monitor System (CEMS). The compliance date and
performance specification for the PM CEMS has not been established.

2.5	Semivolatile Metals and Low-Volatile Metals

	Emissions Limitation

The owner or operator shall not cause combustion gases to be emitted
into the atmosphere that contain:

Lead and cadmium in excess of 180 (g/dscm, combined emissions, corrected
to 7 percent oxygen (63.1204(b)(3)); or

Arsenic, beryllium, and chromium in excess of 54 (g/dscm, combined
emissions, corrected to 7 percent oxygen (63.1204(b)(4)).

Monitoring

The facility shall demonstrate continuous compliance with the
semivolatile metals and low-volatile metals emission standards by
complying with the operating parameter limits specified in the most
recent Notification of Compliance.

Modes 3 and 4

Maximum inlet gas temperature to the kiln/raw mill baghouse on an hourly
rolling average (63.1209(n)(1));

Maximum inlet gas temperature to the bypass baghouse on an hourly
rolling average (63.1209(n)(1));

Maximum inlet gas temperature to the coal mill baghouse on an hourly
rolling average 63.1209(g) alternative to (63.1209(n)( 1));

Maximum feedrate of semivolatile metals on a 12-hour rolling average
limit (63. 	1209(n)(2));

Maximum feedrate of low volatile metals on a 12-hour rolling average
limit (63.1209(n)(2));

Maximum pumpable low volatile metal feedrate on a 12-hour rolling
average (63. 1209(n)(2));

Maximum total chlorine and chloride feedrate on a 12-hour rolling
average (63. 1209(n)(4)); and

Maximum stack gas flowrate on an hourly rolling average (63.1209(n)(5)).

2.6	Hydrocarbons

		Emissions Limitation

The owner or operator shall not cause combustion gases to be emitted
into the atmosphere that contain total hydrocarbons in excess of 10 ppm,
dry basis, corrected to 7 percent oxygen, and reported as propane
(63.1204(b)(5)(A)(2)).

Monitoring

The facility shall demonstrate continuous compliance with the total
hydrocarbon emission standards by complying with the operating parameter
limits specified in the most recent Notification of Compliance.

Modes 3 and 4

Continuously monitor the maximum total hydrocarbon emission rate at the
preheater tower on an hourly rolling average with a CEMS
(63.1204(b)(5)(A)(2)).

Continuously monitor the maximum total hydrocarbon emission rate at the
alkali bypass baghouse outlet on an hourly rolling average with a CEMS
(63.1204(b)(5)(A)(2)).

	2.7	Hydrochloric Acid and Chlorine Gas Emissions Limitation

The owner or operator shall not cause combustion gases to be emitted
into the atmosphere that contain hydrochloric acid and chlorine gas in
excess of 86 ppm, combined emissions, expressed as hydrochloric acid
equivalents, dry basis and corrected to 7 percent oxygen
(63.1204(b)(6)).

Monitoring

The facility shall demonstrate continuous compliance with the
hydrochloric acid and chlorine emission standards by complying with the
operating parameter limits specified in the most recent Notification of
Compliance.

Modes 3 and 4

Maximum chlorine/chloride feedrate on a 12-hour rolling average
(63.1209(o)(1)); and

Maximum stack gas flowrate on an hourly rolling average (63.1209(o)(2)).

	2.8	Combustion System Leaks

Emissions Limitation

The owner or operator shall control the combustion system leaks of
hazardous air pollutants by maintaining the maximum combustion chamber
pressure lower than ambient pressure (63. 1206(c)(5)).

Monitoring

The facility shall demonstrate continuous compliance with the limitation
by complying with the operating parameter limits specified in the most
recent Notification of Compliance.

Modes 3 and 4

Maximum combustion chamber kiln differential pressure; and

Maximum combustion chamber tower differential pressure.

3.0	Performance Testing

An initial performance test was conducted from December 11 through 15,
2001 and March 11 through 14, 2002.

Modes 1 and 2

In accordance with the provisions of 63.1209(q)(1)(ii), the facility has
identified the otherwise applicable requirements of Subpart LLL emission
standards,  monitoring and compliance, notification, reporting, and
recordkeeping for modes 1 and 2.  Specific provisions for each of these
otherwise applicable requirements are listed in the following sections
of this permit:

Otherwise Applicable Requirements for Modes 1 and 2

Emission Standards	Section 2.2 (D/F) and Section 2.4 (PM)

Monitoring and Compliance	Section 2.2 (D/F), Section 2.4 (PM), Section
4.0, and the most recent Notification of Compliance

Performance Testing	Section 3.0

Operating Requirements	Section 5.4

Reporting and Recordkeeping Requirements	Section 6.0



The facility must comply with 63.1206(b)(ii) and 1209(q) to meet the
otherwise applicable requirements of Subpart LLL for performance
testing, as listed below. Ash Grove submitted a waiver request on May
28, 2004 for the dioxin/furan testing due on June 11, 2004; the EPA
issued a waiver on June 16, 2004.

Per EPA’s July 9, 2001 compliance determination, when Ash Grove is
required to test for modes 3 and 4 (burning hazardous waste), the
results may be used to demonstrate compliance in modes 1 and 2. 
Pursuant to the provisions of 63.1206(b)(ii),  63.1209(q) and this
waiver, all future testing for modes 1 and 2 is waived in lieu of
testing performed in modes 3 and 4 according to all the specific
provisions of Subpart EEE, so long as the source remains subject to
Subpart EEE.  The APCD inlet temperature limits established for modes 3
and 4 will be used to establish the respective temperature limits for
modes 1 and 2.  The temperature limits shall be established as the
average of the test run averages, in accordance with 63.1209(k)(1) and
63.1349(b)(3)(iv). 

Modes 3 and 4

Periodic comprehensive performance tests and confirmatory performance
tests are not required until the EPA promulgates permanent replacement
standards. If the facility conducts testing for other reasons (such as a
change in operation that adversely effects emissions), a test plan shall
be submitted in accordance with 40 CFR 63.1207 and submitted at least
one year before the performance test and performance evaluation are
scheduled to begin in accordance with 40 CFR 63.1207(e)(1)(i). The
facility must also submit a notification of intention to conduct the
comprehensive performance test at least 60 calendar days before the test
is scheduled to begin. Current operating parameter limits are waived
during testing if approved in the test plan according to 40 CFR
63.1207(h). The facility must submit a Notification of Compliance within
90 days of the completion of testing documenting compliance or
noncompliance with the emission standards and continuous monitoring
requirements and identifying operating parameter limits.

The coal mill baghouse inlet temperature OPL is not to be established by
testing and is set at 200 (F per the alternate monitoring approved by
the EPA on July 9, 2001 (63.1209(g) and 63.8(f)(2)).

	4.0	Continuous Monitoring Requirements

In accordance with 63.1209(a) and (b) and approved alternatives, the
facility is required to use the following to monitor the stack gas:

two total hydrocarbon (THC) Continuous Emissions Monitoring Systems
(CEMS) to demonstrate and monitor compliance with the plant specific
alternative THC standard approved on February 6, 2001;

Continuous Opacity Monitoring System (COMS) to demonstrate and monitor
compliance with the opacity standard. The COMS shall be maintained and
operated in accordance with the requirements of 63.8(c);

when applicable, PM CEMS to demonstrate and monitor compliance with the
PM standard (the compliance date and performance specification for the
PM CEMS has not been established); and

the facility must operate two oxygen CEMS.

The inlet temperatures for the kiln/raw mill baghouse, bypass baghouse
and the coal mill baghouse are each measured with a thermocouple system
located in the inlet duct to the respective baghouses. The recorder
response range must include zero and 1.5 times the average temperature
of the exhaust gas (63.1 350(f)(1)(i)). These thermocouples shall meet
the requirements of 63.1209(b)(1) and 63.1350(f).

The minimum combustion chamber temperature profile which is an
alternative to the combustion chamber exit temperature is also measured
with a thermocouple, which is located in the outlet duct from the
in-line calciner. This thermocouple shall meet the requirements of
63.1209(c)(1).

The maximum combustion chamber pressure is monitored to control the
combustion system fugitive emissions by maintaining the differential
pressure lower than ambient pressure using an instantaneous monitor in
accordance with 63.1206(c)(5)(i)(B). The pressure is monitored with
pressure transmitters located at rotary kiln raw material feed hood,
rotary kiln fuel firing hood and in the tower gas exit ducts.

	5.0	Operating Requirements

	5.1	Startup, Shutdown and Malfunction Plan

The owner or operator shall develop and implement a written startup,
shutdown and malfunction plan (SSM) in accordance with 40 CFR
63.6(e)(3). During the periods of startup, shutdown and malfunction, the
owner or operator shall comply with the SSM plan in accordance with
procedures specified in 40 CFR 63.1206(c)(2).

The SSM plan dated June 5, 2001, is incorporated into the permit by
reference. The facility shall describe any revisions to the plan in the
semiannual report. Revisions to the SSM plan are automatically
incorporated by reference and do not require a permit modification.
Revisions to the SSM plan must be recorded in the operating record and
detailed in the periodic SSM reports.

	5.2	Automatic Waste Feed Cutoff System Operability

The owner or operator shall operate the hazardous waste combustor with a
functioning Automatic Waste Feed Cutoff System per 40 CFR63.1206(c)(3).
The purpose of the AWFCO system is to instantaneously and automatically
stop the flow of hazardous waste-derived fuel to the kiln in the event
that any of the OPLs in the most recent Notification of Compliance are
exceeded. During an AWFCO period, hazardous waste fuel will not be used;
other fuels will be used to replace the thermal energy supplied from the
waste-derived fuel (WDF) to maintain the system operation along with the
system’s capacity to destroy constituents of WDF remaining in the
system. In accordance with the Operation and Maintenance Plan, the AWFCO
system and associated alarms operability must be verified weekly. The
facility shall take corrective measures to minimize future AWFCOs and
record the findings and corrective measures in the operating record.
AWFCOs also apply when burning hazardous waste during startup and
shutdown.

	5.3	Operator Training and Certification

The facility must establish and implement training and, as appropriate,
certification programs for all categories of personnel whose activities
may be expected to directly affect emissions of hazardous air pollutants
from the source in accordance with 40 CFR 63.1 206(c)(6). The operator
training and certification program must be recorded in the facility
operating record.

	5.4	Operation and Maintenance Plan

The facility shall operate according to an operation and maintenance
(O&M) plan as required under 40 CFR 63.1206(c)(7). The O&M plan
describes in detail procedures for operation, inspection, maintenance,
and corrective action measures for all components of the system,
including the combustion system of the kiln and associated pollution
control equipment that could affect emissions of regulated HAPs. The
inspections must be conducted at least once per year. The O&M plan shall
ensure compliance with the operation and maintenance requirements of 40
CFR 63.6(e), 63.1206(c)(7) and 63.1350(a). The plan must be recorded in
the operating record.

The O&M plan dated May 22, 2001, is incorporated in the permit by
reference. Revisions to the O&M plan are automatically incorporated by
reference and do not require a permit modification. Revisions must be
recorded in the operating record.

	5.5	Feedstream Analysis Plan

The facility must develop and implement a feedstream analysis plan (FAP)
and record it in the operating record in accordance with 63.1209(c)(2).
The plan must specify at a minimum:

the parameters for which each feedstream is analyzed to ensure
compliance with applicable operating parameter limits;

whether the analysis will be obtained by performing sampling and
analysis or by other methods;

how the analysis will be used to document compliance with applicable
feedrate limits; 

the test methods used to obtain the analyses;

the sampling methods used to obtain a representative sample of each
feedstream to be analyzed; and

the frequency with which initial analysis of the feedstream will be
reviewed or repeated to ensure that the analysis is accurate and up to
date.

The feedstream analysis plan dated October 17, 2001, is incorporated in
the permit by reference. The facility shall notify KDHE within 7
calendar days after the revision is put into effect. Revisions to the
FAP are automatically incorporated by reference and do not require a
permit modification.

6.0	Reporting and Recordkeeping Requirements

The owner or operator shall meet all applicable reporting and
recordkeeping requirements as specified in 40 CFR 63.1211, 63.1354,
63.1355 and Subpart A. These records shall be maintained in accordance
with the requirements of 63.10(b)(1) and made available for inspection
upon request.

The facility shall submit, at minimum, the reports of the following to
KDHE:

Periodic startup, shutdown and malfunction reports postmarked by the
30th day following the end of each calendar half or as established
otherwise by KDHE (63.10(d)(5)(i));

Only if the source exceeds a relevant emission standard, an immediate
startup, shutdown and malfunction reports consisting of a telephone call
(or facsimile transmission) to KDHE within 2 working days after
commencing actions inconsistent with the plan, followed by a letter,
postmarked within 7 working days after the end of the event
(63.10(d)(5)(ii));

Excess emissions and continuous monitoring system performance report and
summary report semiannually (63.1 0(e)(3));

Excessive exceedances reports within 5 calendar days of the 1 0th
exceedance during a 60-day block period (63.1206(c)(3)(vi)); and

Any changes in design, operation and maintenance practices of the source
in a manner that may adversely affect compliance with any emission
standard that is not monitored with a CEMS at least 60 days prior to the
change (63.1206(b)(5)).

Send copies of submissions required by this section to Hazardous Waste
Section in Bureau of Waste Management in addition to submissions to
Bureau of Air and Radiation.



	The facility shall keep, at minimum, the records of the following:

Documentation of mode of operation changes (63.1 204(d)( 1 )(ii));

Documentation of compliance demonstration with the emission averaging
requirements

		(63.1 204(d)(2)(ii));

Corrective measures for any AWFCO that results in an exceedance of an
emission standard or operating parameter limit (63.1 206(c)(3)(v));

Documentation and results of the AWFCO operability test procedures and
results (63.1 206(c)(3)(vii);

Differential pressure readings used for control of combustion system
leaks (63.1 206(c)(5)(ii));

Operator training and certification program (63.1206(c)(6));

Operation and maintenance plan (63.1206(c)(7)(i)(D));

Feedstream analysis plan (63.1209(c)(2));

The value of the parameter for each feedstream by sampling and analysis
or other method (63.1209(c)(4)(i));

The mass or volume flowrate of each feedstream, except process air and
natural gas, by a CMS (63.1209(c)(4)(ii));

11.	The mass feedrate of the parameter per unit time (63.
1209(c)(4)(iii)). 

The following table details the fuels and feed locations approved for
the in-line kiln/raw mill system:

Permitted Fuel Types and Feed Locations

✓	✓	✓	✓	✓



	In Line Calciner	✓	✓







Down Draft Calciner	✓	✓	✓	✓	✓

✓

	Solid Entry Interlock

✓



✓



Tire Entry Interlock







✓

1. LWDF = Liquid Waste Derived Fuel.  This feedstream may be composed of
any RCRA approved hazardous waste  and may also contain non-hazardous
liquid wastes mixed with hazardous waste liquids, including solids and
sludges that can be blended and fed through the liquid fuel storage
tanks and feed nozzles.

2. Used Oil = non-hazardous used oil handled under the provisions of 40
CFR 279 through the LWDF system.

3. SWDF = Solid Waste Derived Fuel.  This feedstream is containerized in
pails and may be composed of any RCRA approved hazardous waste codes. 
This feedstream may also include containerized non-hazardous waste
solids.

4. BWF = Bulk Waste Fuel.  This may be composed of any non-containerized
solid material that contains no free liquids.  This feedstream may
include RCRA approved hazardous waste and non-hazardous waste solids. 

5. TDF = Tire Derived Fuel.  This feedstream is composed of whole
passenger and truck tires.

M. 40 CFR Part 63 Subpart LLL

Equipment subject to 40 CFR 63 Subpart LLL must comply with the
requirements of 40 CFR 63 Subpart A - General Provisions except where
Subpart LLL provides for explicit exemptions to Subpart A. The 40 CFR 63
Subpart A - General Provisions are found in Attachment G of this permit.

M.1	All equipment subject to 40 CFR 63, Subpart LLL

a. Limitation/	Part 63 Subpart LLL Standard.

Standard:



	Monitoring



Reporting	Submit results of all PM performance tests within 60 days of
the test, Opacity tests within 30 days of the test	63.1354(b)(1),(2)

	Submit progress reports by the dates specified in written extension of
compliance.	63.1354(b)(3)

	State that actions taken during startups, shutdowns, or malfunctions
were consistent with the SSMP in semi-annual report and K.A.R. 28-19-11.
63.1354(b)(4)

K.A.R. 28-19-11

	Report actions taken during startup, shutdown, or malfunction that were
inconsistent with the SSMP, if an exceedance of the standard occurs
(63.6(e)(1)(iv)), within 2 working days (telephone or fax) and follow up
with letter within 7 days	63.1354(b)(5)

Recordkeeping	Maintain files required by this section for at least 5
years.	63.1355(a)

Testing	Repeat performance tests every 5 years.	63.1349(c)



b. Limitation/	63.1350(b) Failure to comply with O and M plan is a
violation of the standard

Standard:

	





Monitoring	Monitor according to O and M plan.	63.1350(j)



M.2	Source Specific- all CMS systems required by 40 CFR 63, Subpart LLL

Limitation/	Part 63 Subpart LLL - CMS Requirements

Standard:



	Monitoring



Reporting	Report results of CMS performance evaluation.	63.1354(b)(6)

	Report results of COMS performance evaluation.	63.1354(b)(7)

	Submit excess emissions and CMS performance report whenever source is
not in compliance with applicable limits.	63.1354(b)(8)

	Submit excess emissions and CMS performance report with summary report
if CMS downtime is > 10% of total operating time.	63.1354(b)(10)



M.3	40 CFR 63 NESHAP - LLL, Clinker Cooler (major source; new or
existing), Effective June 14, 2002)

Limitation/	63.1345(a)(1) PM < or = 0.10 lb per ton of feed to kiln:

	Standard



	Testing	Demonstrate initial compliance by performance testing
63.1349(a)

	Conduct performance tests in accordance with 63.1349(b)(1)-(4)
63.1349(b)



Limitation/	63.1345(a)(2) Opacity < or = 10% except during startups,
shutdowns, & malfunctions 

    Standard:



	Monitoring	Submit operations and maintenance plan as part of a Title V
application	63. 1350(a)(1-3)

	Monitor opacity at each point where emissions are vented.	63.1350(d)

	Opacity < or = 10% for each 6-minute average except during startups,
shutdowns, & Malfunctions	63.1350(d)(3)

	Operate a COM at the outlet of the clinker cooler PM control device.
63.1350(d)(1)

Testing	Demonstrate initial compliance by performance testing	63.1349(a)

	Demonstrate opacity using COM during Method 5 performance tests.
63.1349(b)(1)(v)

M.4	40 CFR 63 NESHAP - LLL, Raw or Finish Mill, Existing, Effective June
14, 2002

Limitation/	63.1347 Opacity < or = 10% except during startups,
shutdowns, & malfunctions

Standard:



	Monitoring	Conduct daily 6-minute visible emissions test (Method 22) of
mill sweep and air separator PMCDs, unless a BLDS is installed. If
visible

emissions are observed, initiate corrective action within 1 hr, conduct

follow-up Method 22 test within 24-hours and then 30-minute Method 9 if
further emissions.	63.1350(e)

	If a BLDS is installed, the BLDS must be certified by the manufacturer
to detect PM emissions at concentrations of 10 mg per actual cubic meter
or less.	63.1350(m)(1)

	If a BLDS is installed, the sensor must provide output of relative PM

emissions.	63.1350(m)(2)

	If a BLDS is installed, the BLDS must have an alarm that activates

automatically when it detects a significant increase in PM emissions.
63.1350(m)(3)

	If a BLDS is installed, the presence of an alarm condition should be

apparent to facility.	63.1350(m)(4)

	If a BLDS is installed, For a positive pressure fabric filter, each

compartment should have a bag leak detector. For a negative-pressure

or induced-air fabric filter, the bag leak detector must be installed

downstream of the fabric filter.	63.1350(m)(5)

	If a BLDS is installed, it must be operated, adjusted, and maintained

based on manufacturer's written specifications and recommendations.
63.1350(m)(6)

	If a BLDS is installed, the baseline output of the system must be

established by adjusting the range and averaging period of the device,

and establishing the alarm set points and delay time.	63.1350(m)(7)

	If a BLDS is installed, after the initial adjustment, the range,
averaging

period, alarm set points, or alarm delay time may not be adjusted except
as specified in the operations and maintenance plan.	63.1350(m)(8)

	If a BLDS is installed, the fabric filter must be maintained and
operated such that the bag leak detector alarm condition does not exist
more than 5 percent of the total operating time for a 6-month block
period.	63.1350(m)(9)

	If a COMS is used in Lieu of M22/M9s, it must be installed at the
outlet of the APCD and in accordance with PS-1. Compliance is
demonstrated when the 6 minute block average is less than 10%.
63.1350(m)

Testing	Conduct an initial 3-hour (30 6-minute averages) Method 9 test.
63.1349(b)(2)(ii)



M.5	40 CFR 63 NESHAP - LLL, Open or Partially Enclosed - Conveying
System Transfer Points, Storage Bins, Unloading Systems, Raw Material
Dryers, Bagging Systems, or the associated APCDs – With the potential
to emit particulate matter

Limitation/	63.1348 Opacity < or = 10% except during startups,
shutdowns, & malfunctions 

Standard:



	Monitoring	Conduct 1-min visible emissions (VE) test using Method 22.
If

visible emissions are observed during any Method 22 test,

conduct a 6-minute Method 9 within one hour. See Opacity

Monitoring Section for more details. 	63.13 50(a)(4)(i-vii)

Testing	Conduct an initial 3-hour (30 6-minute averages) Method 9 test.

The test time may be reduced to 1-hour if there are no readings

greater than 10% opacity and there are no more than three

readings of 10% opacity are observed in the first hour.
63.1349(b)(2)(i)(ii)



M.6	40 CFR 63 NESHAP - LLL, NON EMITTING - Conveying System Transfer
Points, Storage Bins, Unloading Systems, Raw Material Dryers, Bagging

Limitation/	63.1348 Opacity < or = 10% except during startups,
shutdowns, malfunctions 

Standard:



	Monitoring	Quarterly visual inspections for leaks will be conducted. If

visible emissions are observed during these inspections, the

requirements of 63.1350(a)(4)(i)-(iv) will apply to that source.
Alternative Monitoring

Request – 12/04/2001

Testing	None Required at this time since one was conducted on

12/04/2001	Initial Performance Testing

Waiver – 12/04/2001



M.7	40 CFR 63 NESHAP - LLL, Conveying System Transfer Points with
Limited Operation

Limitation/	63.1348 Opacity < or = 10% except during startups,
shutdowns, & malfunctions 

Standard:



	Monitoring	Conduct a monthly Method 22 test when the emission

source is operating.	Alternative Monitoring Requests –

04/25/2002 and 08/21/2002

Testing	Waiver of initial Method 9 Performance test.	Initial Performance
Testing Waiver

– 04/25/2002 and 08/21/2002



M.8	40 CFR 63 NESHAP - LLL, Inaccessible Conveying System Transfer
Points (601 .CH3)

Limitation/	63.1348 Opacity < or = 10% except during startups,
shutdowns, & malfunctions 

Standard:



	Monitoring	Conduct monthly visual inspections for leaks or evidence of
leaks

when the emission source is operating. The frequency of these

visual inspections can be reduced to semi-annually if no leaks are

observed in six consecutive monthly tests and further reduced to

annually if no leaks are observed in the semi-annual inspection.
Alternative Monitoring

Request – 04/17/2001

Testing	Waiver of initial Method 9 Performance test and Method 22 test.
Initial Performance Testing

Waiver – 04/17/2001



M.9	40 CFR 63 NESHAP - LLL, Inaccessible Conveying System Transfer
Points (601 .CH4)

Limitation/	63.1348 Opacity < or = 10% except during startups,
shutdowns, & malfunctions

Standard:



	Testing	In lieu of performing an initial Method 9 Performance Test,
Initial Performance Testing

	conduct an initial visual inspection for leaks or evidence of leaks
followed by a 6-minute Method 9 test.	Waiver – 04/17/2001



N.	State Construction Permit Conditions

N.1	KDHE Construction Permit 8-26-99 (superseded by 3-30-06 permit) Air
Emission Unit Technical Specifications

Limitation/Standard:	Construction Permit 8-26-99 (superseded by 3-30-06
permit) Preheater/precalciner and kiln to be fired with coal and/or
petroleum coke, natural gas, used oil, solid and liquid hazardous
waste-derived fuel, and alternative non-hazardous waste-derived fuels.

Monitoring	Monitor fuel used for the preheater/ precalciner.

Recordkeeping	Record fuel used for the preheater/ precalciner.



N.2	KDHE Construction Permit 8-26-99 (superseded by 3-30-06 permit) Air
Emission Unit 	Technical Specifications

Limitation/

Standard:	Construction Permit 8-26-99 (superseded by 3-30-06 permit)
Maximum kiln annual feed of 2,899,560 tons/year.



Monitoring	Monitor kiln feed on a rolling 12-month basis in units of
(tons/year).

Recordkeeping	Record kiln feed on a rolling 12-month basis (tons/year).



N.3	KDHE Construction Permit 8-26-99 (superseded by 3-30-06 permit) Air
Emission Unit Technical Specifications

Limitation/

Standard:	Construction Permit 8-26-99 (superseded by 3-30-06 permit)
Maximum raw mill annual throughput 3,285,000 tons/year



Monitoring	Monitor raw mill throughput on a rolling 12-month basis in
units of (tons/year).

Recordkeeping	Record raw mill throughput on a rolling 12-month basis
(tons/year).



N.4	KDHE Construction Permit 8-26-99 (superseded by 3-30-06 permit) Air
Emission Unit Technical Specifications

Limitation/

Standard:	Construction Permit 8-26-99 (superseded by 3-30-06 permit)
Maximum clinker cooler annual throughput of 1,699,440 tons/year



Monitoring	Monitor clinker cooler throughput on a rolling 12-month basis
(tons/year).

Recordkeeping	Record clinker cooler throughput on a rolling 12-month
basis (tons/year).



N.5	KDHE Construction Permit 8-26-99 (superseded by 3-30-06 permit) Air
Emission Unit Technical Specifications

Limitation/

Standard:	Construction Permit 8-26-99 (superseded by 3-30-06 permit)
Maximum coal mill annual throughput of 245,280 tons/year



Monitoring	Monitor coal mill throughput on a rolling 12-month basis
(tons/year).

Recordkeeping	Record coal mill throughput on a rolling 12-month basis
(tons/year).



N.6	KDHE Construction Permit 8-26-99 (superseded by 3-30-06 permit) Air
Emission Unit Technical Specifications

Limitation/

Standard:	Construction Permit 8-26-99 (superseded by 3-30-06 permit)
Maximum finish mills #1 and #3 throughput of 876,000 tons/year



Monitoring	Monitor finish mills #1 and #3 throughput on a rolling
12-month basis (tons/year).

Recordkeeping	Record finish mills #1 and #3 throughput on a rolling
12-month basis (tons/year).



N.7	KDHE Construction Permit 8-26-99 (superseded by 3-30-06 permit) Air
Emission Unit Technical Specifications

Limitation/

Standard:	Construction Permit 8-26-99 (superseded by 3-30-06 permit)
Maximum finish mill #4 throughput of 1,314,000 tons/year



Monitoring	Monitor finish mill #4 throughput on a rolling 12-month basis
(tons/year).

Recordkeeping	Record finish mill #4 throughput on a rolling 12-month
basis (tons/year).



N.8	KDHE Construction Permit 8-26-99 (superseded by 3-30-06 permit) Air
Emission Unit Technical Specifications

Limitation/ Standard:	Construction Permit 8-26-99 (superseded by 3-30-06
permit) Fabric filters shall be installed, operated and maintained to
control particulate matter from conveyor transfer points (Belt
conveyors, screw conveyors, drag chain conveyors, pneumatic conveyors,
metal pan conveyors and bucket elevators for moving raw material,
clinker, additives and finished cement).

	

Monitoring	All APCDs must be operating when the emission source it is
designated to control is operating.

	Each mandated APCD designed to capture particulate matter emitted from
in-plant material conveyance system transfer points shall be operated
and maintained such that particulate matter is diverted to and captured
by the control device at all times that a conveyance system is
operating.

Recordkeeping	Record that all APCDs are operated and maintained
according to manufacturer’s specifications or recommendations.



N.9	KDHE Construction Permit 8-26-99 (superseded by 3-30-06 permit)  Air
Emission Unit Technical Specifications

Limitation/ Standard:	Construction Permit 8-26-99 (superseded by 3-30-06
permit) Fabric filters shall be installed, operated and maintained to
control particulate matter from new storage bins and silos for raw and
in-process materials.

	

Monitoring	All APCDs must be operating when the emission source it is
designated to control is operating.

Recordkeeping	Record that all APCDs are operated and maintained
according to manufacturer’s specifications or recommendations



N.10	KDHE Construction Permit 8-26-99 (superseded by 3-30-06 permit)
BACT Air 	Emission Limitations

Limitation/ Standard:	Construction Permit 8-26-99, Modification of
Permit/Approval Conditions June 22, 2004  (superseded by 3-30-06 permit)
Maximum plant wide emission of carbon monoxide limited to 5,000 lb/hr,
measured as an 8-hour block average.



Monitoring	CEMS required for CO 

	Ash Grove shall operate all CEMS in accordance with the applicable
procedures under

Performance Specifications 1,2, and 4 in 40 CFR 60, Appendix B.

	Ash Grove shall perform quarterly accuracy determinations and daily
calibration drift tests in accordance with Procedure 1 in 40 CFR 60,
Appendix F.

	For the CO monitors, the span values of  each CEMS shall be 800 ppm.

	When there are gaps in emissions data recorded by CO CEMS, use the
average of the one-minute values of data previously recorded during the
last 30 days.

Recordkeeping	Record each 8-hour block average CO emission rate 3 times
each day.





Maintain records of CEMS data for the previous 2 years.



N.11	KDHE Construction Permit 8-26-99 (superseded by 3-30-06 permit) 
BACT Air 	Emission Limitations

Limitation/ Standard:	Construction Permit 8-26-99, Modification of
Permit/Approval Conditions June 22, 2004 (superseded by 3-30-06 permit)
Maximum annual plant-wide emissions of carbon monoxide limited to 1,169
tons, measured as a 12-month rolling average.



Monitoring	CEMS required for CO 

	Ash Grove shall operate all CEMS in accordance with the applicable
procedures under

Performance Specifications 1,2, and 4 in 40 CFR 60, Appendix B.

	Ash Grove shall perform quarterly accuracy determinations and daily
calibration drift tests in accordance with Procedure 1 in 40 CFR 60,
Appendix F.

	For the CO monitors, the span values of each CEMS shall be 800 ppm.

	When there are gaps in emissions data recorded by CO CEMS, use the
average of the one-minute values of data previously recorded during the
last 30 days.

Recordkeeping	Maintain monthly emission rates based on hourly averages
of CEMS data and compute and record the 12-month rolling total emission
rate. Maintain records of CEMS data for the previous 2 years.



N.12	KDHE Construction Permit 8-26-99 (superseded by 3-30-06 permit) Air
Emission 	Limitations

Limitation/

Standard:	Construction Permit 8-26-99, Modification of Permit/Approval
Conditions June 22, 2004 (superseded by 3-30-06 permit) Maximum annual
plant-wide emissions of sulfur-oxides limited to 1,037 tons, measured as
a 12-month rolling average.

	

Monitoring	CEMS required for SOx

	Ash Grove shall operate all CEMS in accordance with the applicable
procedures under Performance Specifications 1,2, and 4 in 40 CFR 60,
Appendix B.

	Ash Grove shall perform quarterly accuracy determinations and daily
calibration drift tests in accordance with Procedure 1 in 40 CFR 60,
Appendix F.

	For the SOx monitors, the span values of each CEMS shall be 600ppm.

	When there are gaps in emissions data recorded by SOx CEMS, use the
average of the one-minute values of data previously recorded during the
last 30 days.

Recordkeeping	Maintain monthly emission rates based on hourly averages
of CEMS data and compute and record the 12-month rolling total emission
rate.

	Maintain records of CEMS data for the previous 2 years.



N.13	KDHE Construction Permit 8-26-99 (superseded by 3-30-06 permit) Air
Emission 	Limitations

Limitation/

Standard:	Construction Permit 8-26-99Modification of Permit/Approval
Conditions June 22, 2004 (superseded by 3-30-06 permit), Maximum annual
plant-wide emissions of nitrogen oxides limited to 2,623 tons, measured
as a 12-month rolling average.



Monitoring	CEMS required for NOx.

	Ash Grove shall operate all CEMS in accordance with the applicable
procedures under

Performance Specifications 1,2, and 4 in 40 CFR 60, Appendix B.

	Ash Grove shall perform quarterly accuracy determinations and daily
calibration drift tests in accordance with Procedure 1 in 40 CFR 60,
Appendix F.

	For the NOx monitors, the span values of each CEMS shall be 1000 ppm.

	When there are gaps in emissions data recorded by NOx CEMS, use the
average of the

one-minute values of data previously recorded during the last 30 days.

Recordkeeping	Maintain monthly emission rates based on hourly averages
of CEMS data and compute and record the 12-month rolling total emission
rate.

	Maintain records of CEMS data for the previous 2 years.



N.14	KDHE Construction Permit 8-26-99 (superseded by 3-30-06 permit)
Permit 	Conditions

Limitation/ Standard:	Construction Permit 8-26-99 (superseded by 3-30-06
permit) A dust-abating surfactant shall be applied to all unpaved haul
roads leading from the quarry to the cement plant and to all unpaved
roadways that are located on or within the cement plant perimeter that
are traveled by haul trucks, regardless of whether the haul truck(s) are
owned by Ash Grove. At a minimum, dust-abating surfactant shall be
applied in a manner and at a frequency consistent with the
manufacturer’s specifications as necessary to achieve a 90% control
efficiency of PM10

 emissions.



Recordkeeping	Record when surfactant is applied to unpaved haul roads.



N.15	KDHE Construction Permit 8-26-99 (superseded by 3-30-06 permit)
Permit Conditions

Limitation/

Standard:	Construction Permit 8-26-99 (superseded by 3-30-06 permit) To
implement BACT for the preheater/precalciner kiln system, Ash Grove
shall install, operate and maintain a “Good Combustion Practices” or
GCP emission control system, as described in the permit application, to
minimize emission of carbon monoxide.  The GCP emission control system
shall be implemented to minimize emissions of all criteria air
pollutants at all times.



Monitoring Reporting

Recordkeeping	Each person working at the Ash Grove Chanute, Kansas
facility in the capacity of a

production manager, production supervisor, process engineer, shift
supervisor or control room operator shall successfully complete the GCP
Training Program, or an equivalent program, prior to assuming duties
related to, or involving implementation of, the GCP BACT technology.

	Provide a course of training consisting of classroom and hands-on
training in GCP to

cover topics as outlined in the Construction Permit

	The GCP Training Program shall be administered by a qualified
instructor(s)

	Employees shall be tested on their understanding of the contents of the
GCP program.

Written records shall be maintained, as necessary, to document
successful completion of the GCP training program by each person working
in the capacities listed above.

	Maintain employee-training records relating to GCP training program.



N.16	KDHE Construction Permit  8-26-99 (superseded by 3-30-06 permit)
Monitoring 	Requirements and Compliance

Limitation/

Standard:	Construction Permit 8-26-99 (superseded by 3-30-06 permit) Ash
Grove shall install, calibrate, maintain and operate a system to
continuously measure and record the volumetric flow rate and temperature
of gas discharged to the atmosphere from the main stack.



Monitoring	Continuously monitor the stack gas flow rate and temperature.

Recordkeeping	Continuously record the stack gas flow rate and
temperature.



N.17	KDHE Construction Permit 8-26-99 (superseded by 3-30-06 permit)
Monitoring 	Requirements

Limitation/

Standard:	Construction Permit 8-26-99 (superseded by 3-30-06 permit) Ash
Grove shall install, calibrate, maintain and operate a system to
continuously measure and record the stack gas oxygen concentration in
the alkali bypass system and between the second and third preheater
stages.

	

Monitoring	Continuously monitor the stack gas oxygen concentration in
the alkali bypass system and

between the second and third preheater stages.

Recordkeeping	Continuously record the stack gas oxygen concentration in
the alkali bypass system and

between the second and third preheater stages.



N.18	KDHE Construction Permit 8-26-99 (superseded by 3-30-06 permit)
Monitoring 	Requirements

Limitation/

Standard:	Construction Permit 8-26-99 (superseded by 3-30-06 permit) Ash
Grove shall operate all of the CEMS and stack gas flow rate monitor when
the kiln system is operated, except for CEMS breakdowns, repairs,
calibration checks and zero span adjustments.



Monitoring	Continuously monitor the stack gas flow rate when the kiln
system is operating.



N.19	KDHE Construction Permit 8-26-99 (superseded by 3-30-06 permit)
Notification

Limitation/

Standard:	Construction Permit 8-26-99 (superseded by 3-30-06 permit) Ash
Grove shall submit a written excess emissions and monitoring systems
performance report to the Department each calendar quarter. The reports
shall include the information required in § 60.7(c) and (d) and shall
be postmarked by the 30th day following the end of the calendar quarter.
 



Reporting	Submit the excess emissions and monitoring systems performance
report quarterly.



N.20	KDHE Construction Permit 10-03-00 Cement Unloading

Limitation/

Standard:	Construction Permit 10-03-00 The railcar unloading connectors
(“boot-lift”) must be properly

engaged and operating when the railcar unloading station is in
operation.



Recordkeeping	Compliance with this limit is demonstrated by complying
with the opacity limitations of M.5 40 CFR 63 NESHAP - LLL, Conveying
System Transfer Points, Storage Bins, Unloading Systems, Raw Material
Dryers, Bagging Systems, or the associated APCDs – With the potential
to emit particulate matter.



N.21	KDHE Construction Permit 1-16-01 Modified CKD Handling and Storage

Limitation/

Standard:	Construction Permit 1-16-0 1 Exhaust gases from the processing
equipment shall be vented through the air emission control equipment.



Recordkeeping	Compliance with this limit is demonstrated by complying
with the opacity limitations of M.5 40 CFR 63 NESHAP - LLL, Conveying
System Transfer Points, Storage Bins, Unloading Systems, Raw Material
Dryers, Bagging Systems, or the associated APCDs  With the potential to
emit particulate matter.



N.22	KDHE Construction Permit 1-16-01 Modified CKD Handling and Storage

Limitation/

shall be in place and tightly secure when material is being moved
through this equipment so that a capture efficiency of 100% is
maintained.



Recordkeeping	Compliance with this limit is demonstrated by complying
with the opacity limitations of M.5 40 CFR 63 NESHAP - LLL, Conveying
System Transfer Points, Storage Bins, unloading Systems, Raw Material
Dryers, Bagging Systems, or the associated APCDs – With the potential
to emit particulate matter.



N.23	KDHE Construction Permit 1-16-01 Modified CKD Handling and Storage

Limitation/

Standard:	Construction Permit 1-16-0 1 The control equipment with at
least 99% control efficiency shall be in place and continuously operate
to control emission of PM and PM10 from the raw material handling
equipment when in operation.

	

Recordkeeping	Compliance with this limit is demonstrated by complying
with the opacity limitations of M.5 40 CFR 63 NESHAP - LLL, Conveying
System Transfer Points, Storage Bins, Unloading Systems, Raw Material
Dryers, Bagging Systems, or the associated APCDs – With the potential
to emit particulate matter.



	

N.24	KDHE Construction Permit 5-01-01 Clinker Loadout

Limitation/

Standard:	Construction Permit 5-01-01 The APCD (baghouse) shall be
operated at all times and emissions

routed to the baghouse whenever the load-out chute is being operated.



Recordkeeping	Compliance with this limit is demonstrated by complying
with the opacity limitations of M.5 40 CFR 63 NESHAP - LLL, Conveying
System Transfer Points, Storage Bins, Unloading Systems, Raw Material
Dryers, Bagging Systems, or the associated APCDs – With the potential
to emit particulate matter.



N.25	KDHE Construction Permit 8-08-02 Fly Ash Permit

Limitation/

Standard:	Construction Permit 8-08-02 Baghouse 535.BF2 shall be
operating at all times and emissions from the cement load-out system
shall be routed to baghouse 535.BF2, whenever the load-out chute is
being operated to transfer fly ash to cement storage silo #38.  (Not
applicable, refer to construction permit 1-20-05, Condition N.30)



Recordkeeping	Compliance with this limit is demonstrated by complying
with the opacity limitations of M.5 40 CFR 63 NESHAP - LLL, Conveying
System Transfer Points, Storage Bins, Unloading Systems, Raw Material
Dryers, Bagging Systems, or the associated APCDs – With the potential
to emit particulate matter.



Limitation/

Standard:	Construction Permit 8-08-02 A magnahelic or similar type
device shall be installed on the baghouse to enable accurate monitoring
of the pressure drop across the baghouse.



Recordkeeping	Compliance with this limit is demonstrated by complying
with the opacity limitations of M.5 40 CFR 63 NESHAP - LLL, Conveying
System Transfer Points, Storage Bins, Unloading Systems, Raw Material
Dryers, Bagging Systems, or the associated APCDs – With the potential
to emit particulate matter.



The Construction Permit 8-26-99 has been modified by a Modification of
Permit/Approval Conditions June 22, 2004.

N.26	KDHE Construction Permit 2-25-04 Meat and Bone Meal Feasibility
Test

Limitation/

Standard:	Construction Permit 2-25-04   The feed rate of meat and bone
meat to the calciner shall not exceed ten (10) tons per hour.  The total
amount of meat and bone meal burned to the calciner during the testing
shall not exceed 50 tons.  (This test has been completed and the system
has been removed.)



Recordkeeping	Record the feed rate of meat and bone meal fed to the
calciner.

	Maintain records on-site at the facility for at least two (2) years
from the date of the record.



N.27	KDHE Construction Permit 6-01-04 Selective Non-Catalytic Reduction
Feasibility Test

Limitation/

Standard:	Construction Permit 6-1-04   The testing associated with the
injection of ammonium hydroxide shall be limited to no more than 168
hours of kiln operating time.  (This test has been completed and the
system has been removed.)



Recordkeeping	Record the feed rate(s) and duration (in hours) of
injection of the ammonium hydroxide fed to the kiln.

	Maintain records on-site at the facility for at least two (2) years
from the date of the record.



N.28	KDHE Modification of Permit/Approval Conditions, June 22, 2004

Limitation/

Standard:	The overall maximum combined production rate for all finish
mill systems shall not exceed 2,100,000 tons in any consecutive 12 month
period.



Monitoring Recordkeeping	The owner or operator is required to monitor
and record the production rate of each finish mill system and the
combined production total of all finish mill systems. Each record shall
be updated monthly, no later than the last day of the month following
the month to which the

record relates. Each record shall be kept on-site for a minimum of five
(5) years from the date of the record.



N.29	KDHE Construction Permit 12-16-05 Selective Non-Catalytic Reduction
System

Limitation/

Standard:	Construction Permit 12-16-05  Selective Non-Catalytic
Reduction System is subject to all conditions, operating limits, and
monitoring requirements specified for the kiln system as stated in
Condition N.2 according to the 3-30-06 Construction Permit



Recordkeeping

	Maintain written records of the feed rate(s) and duration (in hours) of
injection of the ammonium hydroxide fed to the kiln 

	  Keep all records on-site for at least two (2) years from the date of
the record.





N.30	KDHE Construction Permit 3-30-06 PM Emission Limits

Limitation/

Standard:	Construction Permit 3-30-06   PM emissions are limited to 0.02
grains/dscf for the following facilities: in-line raw mill/kiln, coal
mill, and clinker cooler.

	

Monitoring	Compliance with this limit is demonstrated by following the
procedures under 40 CFR 60.13 for installation, evaluation, and
operation of the COMS, including operation of the COM system at all
times, except during period of COM system breakdown, repair, calibration
checks and zero and span adjustments.  Ash Grove shall operate all COMS
in accordance with the applicable procedures under Performance
Specification 1 in 40 CFR 60, Appendix B.

N.31	KDHE Construction Permit 3-30-06 Monitoring Requirements

Limitation/

Standard:	Construction Permit 3-30-06  The primary (211.CR1) and
secondary crushers (211.CR2) are subject to:

	A.	K.A.R. 28-19-20 Particulate matter emission limitation which limits
the quantity of particulate 	emissions from processing equipment in
proportion to the rate at which 			materials are processed.

B.	K.A.R. 28-19-650(a)  Opacity of visible emissions from the crushers
shall not exceed 40 		percent. 



Monitoring, Reporting, and Recordkeeping	Compliance with this limit is
demonstrated by complying with monitoring, reporting, and recordkeeping
requirements as specified for K.A.R. 28-19-20 and K.A.R. 28-19-650(a)
above.





N.32	KDHE Construction Permit 3-30-06 Monitoring Requirements

Limitation/

Standard:	Construction Permit 3-30-06  Alternative fuels and pails of
non-hazardous waste fuel may be fed to the preheater/precalciner kiln
system using the existing feed systems and those included in this
permit, so long as the total feed stream characteristics or emissions
from the kiln system do not result in an exceedance of the operating
parameter limits specified in the most recent Notification of
Compliance.  Alternative waste fuels may only be fed in Modes 3 and 4,
except upon approval by KDHE to burn in Modes 1 and 2.  After successful
demonstration of compliance while burning TDF, BWF, and/or non-hazardous
waste fuel pails in Modes 3 and 4, Ash Grove may, upon approval from
KDHE, begin feeding TDF, BWF, and non-hazardous waste fuel pails in
Modes 1 and 2.



Monitoring	If an exceedance of operating parameter limits occurs while
feeding TDF, BWF, or non-hazardous pail in Modes 3 or 4, take immediate
steps to ramp down the alternate waste fuel feedrate.  Completely stop
burning of all non-hazardous alternative waste fuels within 10 minutes
or the first recorded exceedance of any operating parameter limit. 
Feeding of alternate waste fuel shall not be resumed unless/until all
operating parameters are within acceptable limits, as defined in the
most recent Notification of Compliance.

Burning of non-hazardous alternative waste fuels shall not impact the
AWFCO requirements for hazardous waste-derived fuel.  Hazardous
waste-derived fuels shall be controlled by an AWFCO system and shall be
used to instantaneously and automatically stop the flow of hazardous
waste-derived fuel to the kiln in the event that any of the operating
parameter limits in the most recent Notification of Compliance are
exceeded.

Reporting and Recordkeeping	Only exceedances that occur while hazardous
waste remains in the combustion chamber shall be counted towards the
excessive exceedance reporting requirements of 40 CFR 63.1206(c)(3)(vi).

Since qualitative assessments and/or Method 9 evaluations or any other
reporting requirements are required in the Applicable Requirements
Section of this permit, the facility is required to submit a semi-annual
report every six months. Refer to the Testing, Monitoring, Record
Keeping and Reporting Section of this permit for the submittal dates of
these reports.

Facility-Wide Applicable Requirements

The permittee shall comply with the following when required by the
relevant regulations:

K.A.R. 28-19-20 Particulate Matter Emission Limitations

The permittee shall comply with the requirements of K.A.R. 28-19-20.
This regulation applies to handling and processing equipment for dry
bulk materials, excluding indirect heating equipment and incinerators

K.A.R. 28-19-30 through K.A.R. 28-19-32. Emission Limitations (Indirect
Heating Equipment):

The permittee shall comply with the requirements of K.A.R. 28-19-30
through 28-19-32. These regulations apply to installations in which fuel
is burned for the primary purpose of producing steam, hot water, or hot
air, or other indirect heating of liquids, gases, or solids and, in the
course of doing so, the products of combustion do not come into contact
with process materials.

K.A.R. 28-19-55 through K.A.R. 28-19-58. Emergency Episode Plans

The permittee shall comply with the requirements of K.A.R. 28-19-55
through 28-19-58, Emergency Episode Plans, and shall maintain on site an
emergency episode plan if KDHE requires an emergency episode plan be
developed pursuant to K.A.R. 28-19-58.

K.A.R. 28-19-202. Annual Fee Payment

The owner or operator of a permitted emissions unit or stationary source
is required to pay fees to the permitting authority consistent with the
fee schedule set out in the regulations pursuant to K.A.R. 28-19-202.

K.A.R. 28-19-210, Calculation of Actual Emissions

The following applies to emission control equipment not otherwise
addressed in this permit:

If the owner or operator uses air emission control equipment, not
otherwise addressed in this permit, to calculate actual emissions, the
air emission control equipment shall be maintained in accordance with
the manufacturer’s recommendation. The owner or operator shall keep a
written log recording the date and type of action taken when performing
preventive or other maintenance on the air emission control equipment.

K.A.R. 28-19-517. Annual Emission Inventory

The owner or operator shall submit all operating or relevant information
to estimate emissions for the preceding year to the KDHE.  This
information shall be submitted before the date specified at K.A.R.
28-19-517 or amendments thereto and shall be submitted on forms provided
or approved by the KDHE.  At the time of permit issuance, the due date
for submittal of this information is June 1.

K.A.R. 28-19-645. Open Burning

The permittee is prohibited from conducting open burning, except as
allowed by K.A.R. 28-19-647 and K.A.R. 28-19-648.

K.A.R. 28-19-735 which adopted by reference 40 CFR Part 61, Subpart A
and 40 CFR 61, Subpart M

The permittee shall comply with the National Emission Standard for
Hazardous Air Pollutants (NESHAP) 40 CFR Part 61, Subpart A, General
Provisions and Subpart M, National Emission Standard for Asbestos,
adopted by K.A.R. 28-19-735, and K.A.R. 28-50-1 et seq. when conducting
any renovation or demolition activities at the facility.

40 CFR Part 68. Chemical Accident Prevention Provisions

Chemical Accident Prevention Provisions, 40 CFR Part 68, is applicable
to an owner or operator of a stationary source that has more than a
threshold quantity of a regulated substance in a process, as determined
in 40 CFR 68.115.

If the stationary source is subject to 40 CFR Part 68, but is not
required to comply with those requirements as of the effective date of
this operating permit, the stationary source shall be in

compliance with the requirements of 40 CFR Part 68 no later than the
latest of the following dates:

Three years after the date on which a regulated substance is first
listed in 40 CFR 68.130; or

The date on which a regulated substance is first present above a
threshold quantity in a process.

On the effective date of this permit, Ash Grove Cement Company, as
reviewed, does not have more than the threshold quantity of any
regulated substance.

40 CFR Part 82, Protection of Stratospheric Ozone

The permittee shall comply with 40 CFR Part 82, Protection of
Stratospheric Ozone. Affected controlled substances include, but are not
limited to, chlorofluorocarbons, hydrochlorofluorocarbon refrigerants,
halons, carbon tetrachloride, and methyl chloroform (specific affected
controlled substances are listed in 40 CFR Part 82, Subpart A,
appendices A {Class I} and B {Class II}).

The following subparts and sections of 40 CFR Part 82 are conditions of
this permit:

Subpart A - Production and Consumption Controls

Subpart B - Servicing of Motor Vehicle Air Conditioners

Subpart E - Labeling of Products Using Ozone-Depleting Substances:
Section; 82.106 	 Warning statement requirements, 82.108 Placement of
warning statement, 82.110 Form of label bearing warning statement, and
82.112 Removal of label bearing warning statement

Subpart F - Recycling and Emissions Reduction: Sections; 82.156 Required
practices,

82.158 Standards for recycling and recovery equipment, 82.161 Technician

certification, and 82.166 Reporting and recordkeeping requirements
Subpart G - Significant New Alternatives Policy Program

Opacity Monitoring

Facilities are required to perform qualitative (Method 22) and
potentially quantitative (Method 9) visible emissions assessments to
ensure compliance with opacity standards identified in the applicable
requirements section of this permit.

The person responsible for making qualitative (Method 22) opacity
assessments must be knowledgeable about the effects on visibility of
emissions caused by background contrast, ambient lighting, observer
position relative to lighting, wind, and the presence of uncombined
water. The person responsible for making quantitative opacity
assessments must be certified to conduct Method 9 observations.

The records kept of visible emissions assessments shall include the
specific requirements of Method 22 and/or Method 9 as required as well
as any steps taken to correct any opacity standard exceedances, plus
information required under the Testing, Monitoring, Record keeping, and
Reporting section of this permit.

The detection of visible emissions is not considered to be a deviation
subject to reporting in accordance with the Reporting of Deviations from
Permit Terms portion of this permit.

Portland Cement MACT Visible Emissions Monitoring Plan
(63.1350(a)(4)(i-vii))

The facility must conduct a monthly 1 -minute visible emissions test of
each affected (or listed) source in accordance with Method 22 of
Appendix A to part 60. The test must be conducted while the affected (or
listed) source is in operation.

If no visible emissions are observed in six consecutive monthly tests
for any affected (or listed) source, the owner or operator may decrease
the frequency of testing from monthly to semi-annually for that affected
(or listed) source. If visible emissions are observed during any
semi-annual test, the owner or operator must resume testing of that
affected (or listed) source on a monthly basis and maintain that
schedule until no visible emissions are observed in six consecutive
monthly tests.

If no visible emissions are observed during the semi-annual test for any
affected (or listed) source, the owner or operator may decrease the
frequency of testing from semi-annually to annually for that affected
(or listed) source. If visible emissions are observed during any annual
test, the owner or operator must resume testing of that affected (or
listed) source on a monthly basis and maintain that schedule until no
visible emissions are observed in six consecutive monthly tests.

If visible emissions are observed during any Method 22 test, the owner
or operator must conduct a 6-minute test of opacity in accordance with
Method 9 of appendix A to part 60 of this chapter. The Method 9 test
must begin within one hour of the original Method 22 during which
visible emissions were observed.

The requirement to conduct Method 22 visible emissions monitoring under
this paragraph shall not apply to any totally enclosed conveying system
transfer point, regardless of the location of the transfer point.
“Totally enclosed conveying system transfer point” shall mean a
conveying system transfer point that is enclosed on all sides, top and
bottom.

If any partially enclosed or unenclosed conveying system transfer point
is located in a building, the owner or operator of the portland cement
plant shall have the option to conduct a Method 22 visible emissions
monitoring test according to the requirements of paragraphs (a)(4)(i)
through (iv) of this section for each such conveying system transfer
point located within the building, or for the building itself (according
to paragraph (a)(4)(vii) of this section.

If visible emissions from a building are monitored, the requirements of
paragraphs (a)(4)(i) through (iv) of this section apply to the
monitoring of the building, and you must also do the following: Test
visible emissions from each side, roof, and vent of the building for at
least 1 minute. The test must be conducted under normal operating
conditions.

Non-MACT Sources - Visible Emissions Monitoring Plan
(63.1350(a)(4)(i-vii))

The facility must conduct a monthly 1-minute visible emissions test of
each affected (or listed) source in accordance with Method 22 of
Appendix A to part 60. The test must be conducted while the affected (or
listed) source is in operation.

If no visible emissions are observed in six consecutive monthly tests
for any affected (or listed) source, the owner or operator may decrease
the frequency of testing from monthly to semi-annually for that affected
(or listed) source. If visible emissions are observed during any
semi-annual test, the owner or operator must resume testing of that
affected (or listed)

source on a monthly basis and maintain that schedule until no visible
emissions are observed in six consecutive monthly tests.

If no visible emissions are observed during the semi-annual test for any
affected (or listed) source, the owner or operator may decrease the
frequency of testing from semi-annually to annually for that affected
(or listed) source. If visible emissions are observed during any annual
test, the owner or operator must resume testing of that affected (or
listed) source on a monthly basis and maintain that schedule until no
visible emissions are observed in six consecutive monthly tests.

If visible emissions are observed during any Method 22 test, the owner
or operator must either conduct an additional 1-minute Method 22 within
twenty-four hours with a result of “No visible emissions,” or
conduct a 6-minute test of opacity in accordance with Method 9 of
appendix A to part 60 of this chapter. The Method 9 test must begin
within twenty-four hours of the original, or follow-up (if conducted),
Method 22 during which visible emissions were observed, unless a
follow-up Method 22 demonstrated no visible emission.

The requirement to conduct Method 22 visible emissions monitoring under
this paragraph shall not apply to any totally enclosed conveying system
transfer point, regardless of the location of the transfer point.
“Totally enclosed conveying system transfer point” shall mean a
conveying system transfer point that is enclosed on all sides, top and
bottom.

If any partially enclosed or unenclosed conveying system transfer point
is located in a building, the owner or operator of the portland cement
plant shall have the option to conduct a Method 22 visible emissions
monitoring test according to the requirements of paragraphs (a)(4)(i)
through (iv) of this section for each such conveying system transfer
point located within the building, or for the building itself (according
to paragraph (a)(4)(vii) of this section.

If visible emissions from a building are monitored, the requirements of
paragraphs (a)(4)(i) through (iv) of this section apply to the
monitoring of the building, and you must also do the following: Test
visible emissions from each side, roof, and vent of the building for at
least 1 minute. The test must be conducted under normal operating
conditions.

Emission Points with Very Low or Nonexistent Visible Emissions

Some emission points subject to opacity requirements may be identified
as not requiring compliance demonstration due to potentially very low or
nonexistent visible emissions. These may include:

Degreasing operations, painting operations which filter particulate
emissions, non-heat set printing operations, other non-heat set
evaporative VOC sources, petroleum product storage tanks, glycol
dehydrators and sources which are vented inside a building which is
usually occupied may be presumed to be in compliance with any opacity
limit of 20% or greater. Burners in indirect heating applications, space
heaters, turbines, internal combustion engines or boilers may be
presumed to be in compliance with any opacity limit of 20% or greater
when burning natural gas or propane/LPG. Opacity increases as
particulate content of emissions increase. The particulate content of
emissions from burning natural gas or propane/LPG is small and the
particulate content of emissions from the evaporation of volatile
organic compounds is zero. Particulate emissions inside an occupied
building must be small to protect the health of the occupants. The
possibility of emissions from these types of sources exceeding an
opacity of 20% is therefore potentially very low or nonexistent.

If an operation in one of the above categories changes such that visible
emissions are no longer, very low or nonexistent, the owner or operator
shall apply for the appropriate permit or approval in accordance with
K.A.R. 28-19-300 and commence appropriate qualitative opacity
assessments pursuant to the above schedule. If a permit or approval is
not required by K.A.R. 28-19-300 the owner or operator shall notify KDHE
within thirty days of the change in operations and commence appropriate
qualitative opacity assessments pursuant to the above schedule.

Sources specifically identified as being in this category are listed in
Attachment D.

Requirements Which Will Become Applicable During the Permit Term

The owner or operator, in accordance with the provisions of K.A.R.
28-19-511(b)(16)(C)(ii) and K.A.R. 28-19-512(a)(23) shall comply in a
timely manner with those applicable requirements that become effective
during the permit term, unless a detailed schedule is expressly required
by applicable requirements.

Permit Shield

Compliance with the conditions of this permit shall be deemed in
compliance with the applicable requirements of the Kansas air quality
program as of the date of permit issuance. This shield applies only to:

applicable requirements included, and specifically identified in the
permit;

applicable requirements that KDHE has specifically identified in writing
as not being applicable to the emissions unit or stationary sources and
the determination or a concise summary thereof is included in the
permit.

Nothing in this permit shall alter or affect:

the liability of a permittee for any violation of an applicable
requirement occurring prior to or at the time of issuance of this
permit;

U.S. EPA’s ability to obtain information under Section 114 of the
Clean Air Act; or

the provisions of Section 303, Emergency orders, of the Clean Air Act,
including the authority of

the administrator of the U.S. EPA under that section of the air
pollution emergency provisions of

the Kansas air quality program regulations, K.A.R. 28-19-55 through
28-19-58.

the applicable requirements of the acid rain program, consistent with
section 408(a) of the Act.

Testing, Monitoring, Recordkeeping, & Reporting

Testing, monitoring, recordkeeping, and reporting requirements
sufficient to assure compliance with the terms and conditions of the
permit are required.

In addition to any testing, monitoring, recordkeeping, or reporting
requirement contained in the Applicable Requirements section of this
permit, monitoring and reporting may be required under the provisions of
K.A.R. 28-19-12, Measurement of Emissions, or as required by any other
provision of the federal Clean Air Act.

Records to support all monitoring and copies of all reports required by
the permit must be maintained for a period of at least five years from
the date of the activity. Summary reports of any routine, continuous or
periodic monitoring must be submitted at six-month intervals on a
calendar year basis. The first report being due 30 days after each
subsequent six month period for the duration of the permit (i.e. January
30th and July 30th). All instances of deviations from permit
requirements, including perceived opacity exceedances, shall be clearly
identified in the report.

Submission of quarterly or semi-annual reports required by any
applicable requirement which duplicate the reporting required in the
previous paragraph will satisfy the reporting requirements of the
previous paragraph if noted on the submitted report.

Records of required monitoring shall include:

The date, place, and time of sampling or measurement;

The date or dates analyses were performed;

The company or entity which performed the analyses;

The analytical techniques or methods used;

The result of the analyses; and

The operating conditions that existed at the time of sampling or
measurement. 

Reporting of Deviations from Permit Terms

Unless a different time period is specified in this permit, deviations
from the requirements of this permit shall be reported to KDHE as
follows:

Deviations which result in emissions exceeding those allowed in this
permit shall be reported the next business day following the discovery
of the release, with follow-up written notice within five business days
following discovery of the release. The report shall include the
probable cause of such deviations and any corrective actions or
preventive measures taken.

Deviations which do not result in emissions exceeding those allowed in
this permit shall be reported in writing within 10 business days
following discovery of the deviation.

Oral notifications may be made to the air program field staff at the
Southeast District Office in Chanute or to the KDHE central office in
Topeka. Written notifications shall be made to the KDHE central office
with a copy to the Southeast District Office.

General Provisions

1. K.A.R. 28-19-11: Exceptions Due to Breakdowns or Scheduled
Maintenance

	a.	Abnormal operating conditions resulting from malfunction breakdown,
or necessary repairs 		to control or processing equipment and
appurtenances which cause emissions in excess of the 		limitations
specified in K.A.R. 28-19-20, K.A.R. 28-19-30 through K.A.R. 28-19-32
and 			K.A.R. 28-19-650 shall not be deemed violations provided that:

The person responsible for the operation of the emission source notifies
the department of the occurrence and nature of such malfunctions,
breakdown, or repairs, in writing, within ten days of noted occurrence.

The number of occurrences of such breakdowns is not deemed excessive by
the department and appropriate reasonable action is taken to initiate
and complete any necessary repairs and place the equipment back in
operation as quickly as possible.

b.	Emissions in excess of the limitations specified in K.A.R. 28-19-20,
K.A.R. 28-19-30 through K.A.R. 28-19-32 and K.A.R. 28-19-650 resulting
from scheduled maintenance of control equipment and appurtenances will
be permitted only on the basis of prior approval by the department and
upon demonstration that such maintenance cannot be accomplished by
maximum reasonable effort, including off-shift labor where required,
during periods of shutdown of any related equipment.

K.A.R. 28-19-752a: Hazardous Air Pollutants; Limitations Applicable to
Construction of New Major Sources or Reconstruction of Existing Major
Sources

This regulation shall continue in effect for an emissions unit or
stationary source until a standard has been promulgated which is
applicable to such source pursuant to Section 112(d) of the federal
Clean Air Act.

This regulation shall apply whenever construction of a new major source
or reconstruction of an existing major source of hazardous air
pollutants is proposed.

K.A.R. 28-19-753: Hazardous Air Pollutants; Limitations Applicable to
Sources for Which the U.S. EPA Fails to Meet Certain Deadlines

This regulation shall be applicable to a source only if the U.S. EPA
fails to promulgate an emission standard for the subcategory applicable
to the source within the time frame scheduled by the U.S. EPA at the
most recent revision of 58 Federal Register 63941.

The Federal 112(j) rule (promulgated on May 20, 1994) has been amended.
A direct final rule, published in Federal Register on April 16, 1999,
delays the permit application deadline for 7-year source categories
listed in the regulatory schedule until December 15, 1999. The previous
deadline was May 15, 1999 which was 18 months after the original
November 15, 1997 promulgation date for 7-year MACTs.

The deadline for the 10-year MACTs was May 15, 2002, which was 18 months
after the original November 15, 2000 promulgation date for the 10-year
MACTs.

Permit Term and Renewal 

	This permit has a term of five years unless otherwise stated in this
permit. A complete 	application, as defined in K.A.R. 28-19-518, and any
applicable fee, must be submitted to 	KDHE not less than six months and
not more than 18 months prior to the expiration date. This 	operating
permit shall not expire on the expiration date if a complete and timely
application has 	been filed with the KDHE.

Severability

The provisions of this permit are severable, and if any portion of this
permit, or the application of any provision of this permit to any
circumstance, is held invalid, the application of such provision to
other circumstance, and the remainder of this permit, shall not be
affected thereby.

Property Rights

This permit does not convey any property rights of any sort or any
exclusive privilege.

Compliance

The owner or operator shall comply with all conditions of the permit and
shall continue to comply with applicable requirements with which the
owner or operator is in compliance. Any permit noncompliance shall
constitute a violation of the Kansas Air Quality Act and shall be
grounds for enforcement action, for permit revocation or amendment, or
for denial of a permit renewal application. Any credible evidence may be
used for the purpose of establishing noncompliance with an emission
limit or standard. All permit terms and conditions are federally
enforceable.

It shall not be a defense for a permittee in an enforcement action to
contend that it would have been necessary to halt or reduce the
permitted activity in order to maintain compliance with the conditions
of the permit.

Compliance Certification

The permittee shall annually submit to the Air and Asbestos Compliance
Section of the KDHE, and a copy to the Air Permitting and Compliance
Branch of the U.S. EPA, Region 7, a certification of compliance (Form
CR-02, Annual Certification.). The due date of the certification is July
22 of each year, beginning July 22, 2005 for the period June 22, 2004
through June 21, 2005.

The certification shall include the permit term or condition that is the
basis of the certification; the current compliance status; whether
compliance was continuous or intermittent; the method or methods used
for determining the compliance, currently and over the reporting period;
and a statement that the emission unit or stationary source shall
continue to comply with all applicable requirements. Any document
required to be submitted in accordance with this permit shall be
certified by a responsible official. The certification shall state that,
based on information and belief formed after reasonable inquiry, the
statements and information in the certification are true, accurate, and
complete.

Emergency

	a.	An emergency means any situation arising from sudden and reasonably
unforeseeable events 			beyond the control of the source, including acts
of God, which situation requires immediate

corrective action to restore normal operation, and that causes the
source to exceed a technology-based emission limitation under this
permit, due to unavoidable increases in emissions attributable to the
emergency. An emergency shall not include noncompliance to the extent
caused by improperly designed equipment, lack of preventative
maintenance, careless or improper operation, or operator error.

b.	An emergency shall constitute an affirmative defense to an action
brought for noncompliance with such technology-based emission limitation
if the conditions of paragraph (c) below are met.

c.	The affirmative defense of emergency shall be demonstrated through
properly signed, contemporaneous operating logs or relevant evidence
that:

an emergency occurred and that the permittee can identify the cause or
causes of the emergency;

the permitted facility was at the time being properly operated;

during the period of the emergency the permittee took all reasonable
steps to minimize levels of emissions that exceeded the emission
standards or other requirements in the permit; and

the permittee submitted notice of the emergency, containing a
description of the emergency, any steps taken to mitigate emissions, and
corrective actions taken, to KDHE within two working days of the time
when emission limitations were exceeded due to the emergency.

d.	In any enforcement proceeding, the permittee seeking to establish the
occurrence of an emergency shall have the burden of proof.

e.	These emergency provisions are in addition to any emergency or upset
provisions contained in any applicable requirement. Whenever these
emergency provisions conflict with the provisions of K.A.R. 28-19-11,
these emergency provisions shall control.

10. Inspection and Entry

Upon presentation of credentials and other documents as may be required
by law, representatives of KDHE, including authorized contractors of
KDHE, shall be allowed by the permittee to:

enter upon the premises where a regulated facility or activity is
located or conducted and where records are kept under conditions of this
document;

have access to and copies of, at reasonable times, any records that must
be kept under conditions of this document;

inspect at reasonable times, any facilities, equipment (including
monitoring and control equipment), practices, or operations regulated or
required under this document; and

d. 	as authorized by the Kansas Air Quality Act, sample or monitor at
reasonable times substances or parameters for the purpose of assuring
compliance with the permit or applicable requirements.

11. Permit Amendment, Modification, Reopening, and Changes Not Requiring
a Permit Action

a.	The permit may be modified, revoked, reopened, reissued, or
terminated for cause. The filing of a request by the permittee for a
permit modification, revocation, reissuance, or termination, or of a
notification of planned changes or anticipated noncompliance does not
stay any permit condition.

b.	The permitting authority will reopen and revise or revoke this permit
as necessary to remedy deficiencies in the following circumstances:

Additional requirements under the Clean Air Act become applicable to the
source three or more years prior to the expiration date of this permit.
Such a reopening shall be completed no later than 18 months after
promulgation of the applicable requirement. No such reopening is
required if the effective date of the requirement is later than the
expiration date of this permit.

KDHE determines that this permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards
or other terms or conditions of this permit.

KDHE determines that it is necessary to revise or revoke this permit in
order to assure compliance with applicable requirements.

c.	This document is subject to periodic review and amending as deemed
necessary to fulfill the intent and purpose of the Kansas Air Quality
Statutes and the Kansas Air Quality Regulations.

d.	No permit revision shall be required under any approved economic
incentives, pollution prevention incentives, marketable permits,
emissions trading, and other similar programs or processes for changes
that are provided for in the permit.

12. Duty to Provide Information

Unless a different time frame is specified in this permit, the permittee
shall furnish to the KDHE any information that the KDHE may request in
writing within 60 days of the request, unless the KDHE specifies another
time period. Submittal of confidential business information must be in
accordance with KDHE procedures.

13. Duty to Supplement

The permittee, upon becoming aware that any relevant facts were omitted
or incorrect information was submitted in any submittal, shall promptly
submit such supplementary facts or corrected information.

14. Other Permits and Approvals; Applicability

A construction permit or approval must be obtained from KDHE prior to
commencing any construction or modification of equipment or processes
that results in potential emission increases equal to or greater than
the thresholds specified at K.A.R. 28-19-300.

This document does not relieve the permittee of the obligation to obtain
other approvals, permits, licenses, or documents of sanction that may be
required by other federal, state, or local government agencies.

15. Submissions

All reports, notifications, information, and other correspondence
concerning compliance issues (including the submission of the Annual
Certification Form CR-02) shall be submitted to:

Air Construction/Operating Permits & Compliance Section

Bureau of Air and Radiation

Kansas Department of Health and Environment

1000 SW Jackson, Suite 310

Topeka, KS 66612-1366 

(785) 296-1550

A copy of each Annual Certification Form CR-02 shall be submitted to:

Kansas Compliance Officer

Air Permitting and Compliance Branch

U.S. EPA, Region 7

901 North 5th Street

Kansas City, KS 66101

Any documents required to be submitted in accordance with this permit
shall be certified by a responsible official. This certification shall
state that, based on the information and belief formed after reasonable
inquiry, the statements and information in the certification are true,
accurate, and complete. This certification shall be submitted with
original signatures.

When specified in the permit, contact the district office at:

Southeast District Office 1500 West 7th

Chanute, Kansas 66720

(620) 431-2390

All other correspondence concerning the permit itself shall be submitted
to:

Air Construction/Operating Permits & Compliance Section Kansas
Department of Health and Environment 

Bureau of Air and Radiation

1000 SW Jackson, Suite 310 

Topeka, KS 66612-1366 

(785) 296-1570

Permit Engineer

________________________________________________		_______________

Herbert Buckland								Date Signed

Engineering Associate							

Air Permitting Section

HB:saw

C: SEDO

O-6855 & O-6905Attachment A

Site Diagram

Attachment B

List of Acronyms and Symbols

LIST OF ACRONYMS AND SYMBOLS



ACRONYM or SYMBOL	

DESCRIPTION

<	less than

>	greater than

acfm	actual cubic feet per minute

AP-42	U.S. EPA publication of emission factors

BACT	Best Available Control Technology

APCD	Air Pollution Control Device

BAR	Bureau of Air and Radiation

BTU	British thermal unit

CAA	Federal Clean Air Act

CAAA	Clean Air Act Amendments of 1990

CAS	Chemical Abstract Service

CDE	Control Device Efficiency

CEM	Continuous Emission Monitor

CFC	Chlorofluorocarbon

cfm	cubic feet per minute

CFR	Code of Federal Regulations

CMS	Continuous Monitoring System

CO	Carbon Monoxide

COM	Continuous Opacity Monitor

CTG	Control Techniques Guideline

dscf	dry standard cubic feet

dscm	dry standard cubic meters

EG	Emission Guideline

EPA	Environmental Protection Agency

EU	Emission Unit

FGR	Flue Gas Recirculation

g	gram

GOP	General Operating Permit

gph	gallons per hour

gpm	gallons per minute

gr	grains

HAP	Hazardous Air Pollutant

HC	Hydrocarbon

hp	horsepower

KDHE	Kansas Department of Health and Environment

HON	Hazardous Organic NESHAP

IA	Insignificant Activity

JCED	Johnson County Environmental Department

K.A.R.	Kansas Administrative Regulation

K.S.A	Kansas Statutes Annotated

LAER	Lowest Achievable Emission Rate

MACT	Maximum Achievable Control Technology

MBTU	Thousand Btu

Mg	Mega grams

MMBTU	Million Btu

MON	Miscellaneous Organic NESHAP

MSDS	Material Safety Data Sheet

MWC	Municipal Waste Combustor

MWI	Medical Waste Incinerator

NAAQS	National Ambient Air Quality Standards

NCDO	North Central District Office

NEDO	Northeast District Office

NESHAP	National Emission Standards for Hazardous Air Pollutants

NMOC	Non-Methane Organic Compound

NOX	Nitrogen Oxides

NOC	Notification of Compliance

NSPS	New Source Performance Standard

NSR	New Source Review

NWDO	Northwest District Office

OAQPS	Office of Air Quality Planning and Standards

P2	Pollution Prevention

PAL	Plant wide Applicability Limitation

PM	Particulate Matter

PM10	PM with an aerodynamic diameter of less than or equal to 10 microns

PM2.5	PM with an aerodynamic diameter of less than or equal to 2.5
microns

PCD	Pollution Control Device

ppmv	parts per million, volumetric basis

ppmw	parts per million, weight basis

PSD	Prevention of Significant Deterioration

psia	pounds per square inch, absolute

psig	pounds per square inch, gage

PTE	Potential to Emit

QA/QC plan	Quality Assurance/Quality Control plan

RACT	Reasonable Available Control Technology

RMP	Risk Management Plan

SCDO	South Central District Office

SCHA	Shawnee County Health Agency

SEDO	Southeast District Office

SIC	Standard Industrial Classification

SIP	State Implementation Plan

SOX	Oxides of Sulfur

SOCMI	Synthetic Organic Chemical Manufacturing Industry

SWDO	Southwest District Office

TOC	Total Organic Carbon

tph	tons per hour

tpy	tons per year

TRS	Total Reduced Sulfur

TSDF	Hazardous waste treatment, storage and disposal facilities

TSP	Total Suspended Particulate

VOC	Volatile Organic Compound

VOL	Volatile Organic Liquid

WCHD	Wyandotte County Health Department

WDF	Waste Derived Fuel

W-SCDCH	Wichita-Sedgwick County Department of Community Health



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G.9	40 CFR 61 Subpart V, Surge Control Vessels and bottoms receivers

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c. Limitation/	61.343(a)(1)(i)(B) Close and seal tank openings. (Per
61.349(a)(1)(iv), pressure relief valves can be

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