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Michigan Department of Environmental Quality

Air Quality Division

State Registration Number RENEWABLE OPERATING PERMIT ROP Number

B1477 STAFF REPORT MI-ROP-B1477-2012c

LAFARGE MIDWEST, INC. - ALPENA PLANT

SRN: B1477

Located at:

1435 Ford Avenue, Alpena, Alpena County, Michigan 49707

Permit Number: MI-ROP-B1477-2012c Staff Report Date: November 7, 2011 Amended Date: November 6, 2015 September 19, 2016 May 26, 2017

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

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TABLE OF CONTENTS

NOVEMBER 7, 2011, STAFF REPORT 3

APRIL 6, 2012, STAFF REPORT ADDENDUM 10

MAY 22, 2012, STAFF REPORT ADDENDUM 20

JUNE 4, 2012, STAFF REPORT ADDENDUM 23

JULY 12, 2012, STAFF REPORT ADDENDUM 24

JULY 25, 2012 STAFF REPORT ADDENDUM 28

NOVEMBER 6, 2015 STAFF REPORT FOR RULE 216(2) MINOR MODIFICATION 29

NOVEMBER 6, 2015 STAFF REPORT FOR RULE 216(1)(a)(v) ADMINISTRATIVE AMENDMENT 30

DECEMBER 22, 2015 STAFF REPORT ADDENDUM FOR RULE 216(1)(a)(v) ADMINISTRATIVE AMENDMENT 32

SEPTEMBER 19, 2016 - STAFF REPORT FOR RULE 216(2) MINOR MODIFICATION 33

NOVEMBER 4, 2016 - STAFF REPORT ADDENDUM FOR RULE 216(2) MINOR MODIFICATION 35

MAY 26, 2017 - STAFF REPORT FOR RULE 216(1)(a)(v) ADMINISTRATIVE AMENDMENT 36

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Michigan Department of Natural Resources & Environment



B1477 NOVEMBER 7, 2011, STAFF REPORT MI-ROP-B1477-2012

Purpose Major stationary sources of air pollutants, and some non-major sources, are required to obtain and operate in compliance with a ROP pursuant to Title V of the federal Clean Air Act of 1990 and Michigan’s Administrative Rules for air pollution control pursuant to Section 5506(1) of Act 451. Sources subject to the ROP program are defined by criteria in Rule 211(1). The ROP is intended to simplify and clarify a stationary source’s applicable requirements and compliance with them by consolidating all state and federal air quality requirements into one document. This report, as required by Rule 214(1), sets forth the applicable requirements and factual basis for the draft permit terms and conditions including citations of the underlying applicable requirements, an explanation of any equivalent requirements included in the draft permit pursuant to Rule 212(5), and any determination made pursuant to Rule 213(6)(a)(ii) regarding requirements that are not applicable to the stationary source. General Information

Stationary Source Mailing Address: Lafarge Midwest, Inc. - Alpena Plant 1435 Ford Avenue Alpena, Michigan 49707

Source Registration Number (SRN): B1477 North American Industry Classification System (NAICS) Code:

327310

Number of Stationary Source Sections: One Is Application for a Renewal or Initial Issuance? Renewal Application Number: 200800075

Responsible Official: Mr. David Dziubinski, Plant Manager 989-354-4171

AQD Contact: Ms. Gloria Torello, Environmental Quality Analyst 989-705-3410

Date Permit Application Received: June 3, 2008 Date Application Was Administratively Complete: June 3, 2008 Is Application Shield In Effect? Yes Date Public Comment Begins: November 7, 2011 Deadline for Public Comment: December 7, 2011

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Source Description The Lafarge Midwest, Inc. - Alpena Plant is a cement manufacturing facility located at 1435 Ford Avenue in Alpena, Michigan, on the shores of Lake Huron. Cement manufacturing has been occurring at this site since 1909. In 1986, the Lafarge Corporation purchased the operations from the National Gypsum Corporation. The total area of the facility, including the quarry is approximately 300 acres. The actual production and shipping facilities occupy 135 acres. The plant operates three (3) rotary kilns in Kiln Group 5 and two (2) rotary kilns in Kiln Group 6. The kilns in Kiln Group 5 are smaller than the kilns in Kiln Group 6, but are of a similar overall design. All five kilns operate with waste-heat boilers for energy recovery. All five kilns operate with fabric filter baghouses for control of particulate matter emissions. The kilns have the potential to operate 24 hours per day, seven days a week. In 2010, the kilns hours of operation were as follows: Kiln 19 operated 7017 hours, Kiln 20 operated 6892 hours, Kiln 21 operated 6859 hours, Kiln 22 operated 5331 hours, Kiln 23 operated 6029 hours. Raw materials include limestone, sand, bauxite, shale, gypsum. Alternate raw materials include slag, iron ore, fly ash, and Cement Kiln Dust. Both the raw and alternate raw materials are combined, ground and sent to the kilns. A general mix includes limestone (86-91%), fly ash (5-8%), and iron ore tailings and/or sand (4-6%). The limestone is obtained on site from Lafarge’s quarrying operations; the fly ash utilized is primarily from Canada and Michigan; the iron ore tailings are primarily from the steel industry located in the Chicago, Illinois area. All of the kilns use as fuel sources natual gas, coal, a blend of coal and coke, wood, and non-chlorinated, non-halogenated polyethylene/polypropylene plastics. The site includes: the quarry operations, conveying and storage systems for raw materials, the kilns, clinker coolers, clinker conveying and storage systems, the finish mill, storage and shipping facilities, and landfill for cement kiln dust. Particulate from all kilns are controlled by high efficiency baghouses. Dust suppression systems are operated at conveyor drop points and conveyor transfer points are controlled by dust collectors. Dust collectors are also used on various other process equipment throughout the plant. In the ROP, the smaller fabric filter particulate control devices are referred to as dust collectors. Lafarge mines and uses approximately 3.9 million tons of limestone per year; 235,000 tons of fly ash per year and 165,000 tons of iron ore tailings/sand per year. These raw materials are utilized to produce approximately 2.5 million tons of cement annually. The following table lists stationary source emission information as reported to the Michigan Air Emissions Reporting System in the 2010 submittal.

TOTAL STATIONARY SOURCE EMISSIONS

Pollutant Tons per Year Carbon Monoxide (CO) 593 Lead (Pb) 0.03 Nitrogen Oxides (NOx) 6894 Particulate Matter (PM) 468 Sulfur Dioxide (SO2) 8465 Volatile Organic Compounds (VOCs) 0

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Pollutant Tons per Year Individual Hazardous Air Pollutants (HAPs) ** Mercury

0.14

Individual Hazardous Air Pollutants (HAPs) ** HCL

373

Total Hazardous Air Pollutants (HAPs) 373 **As listed pursuant to Section 112(b) of the federal Clean Air Act. In addition to the pollutants listed above that have been reported in MAERS, the potential to emit of Greenhouse Gases in tons per year of carbon dioxide equivalents (CO2e) is greater than 100,000. CO2e is a calculation of the combined global warming potentials of six Greenhouse Gases (carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride). See Parts C and D in the draft ROP for summary tables of all processes at the stationary source that are subject to process-specific emission limits or standards. Regulatory Analysis The following is a general description and history of the source. Any determinations of regulatory non-applicability for this source are explained below in the Non-Applicable Requirement part of the Staff Report and identified in Part E of the ROP. The stationary source is located in Alpena County, which is currently designated by the U.S. Environmental Protection Agency (USEPA) as attainment/unclassified for all criteria pollutants. The stationary source is subject to Title 40 of the Code of Federal Regulations (CFR), Part 70, because the potential to emit carbon monoxide, nitrogen oxides, particulate matter, sulfur dioxide, and volatile organic compounds exceeds 100 tons per year. The potential to emit of Greenhouse Gases is 100,000 tons per year or more calculated as CO2e and 100 tons per year or more on a mass basis. The stationary source is considered a major source of Hazardous Air Pollutant (HAP) emissions because the potential to emit of any single HAP regulated by the federal Clean Air Act, Section 112, is more than 10 tons per year and/or the potential to emit of all HAPs combined is more than 25 tons per year. The stationary source is subject to the New Source Performance Standards (NSPS) for mining operations promulgated in 40 CFR, Part 60, Subpart OOO. The stationary source is subject to the NSPS for cement manufacturing promulgated in 40 CFR, Part 60, Subpart F for emission units that commenced construction or modification after August 17, 1971 (EU KILN 22, EU KILN 23, EU CLINK STR BLD). The stationary source is subject to the Maximum Achievable Control Technology (MACT) Standards for Portland Cement manufacturing promulgated in 40 CFR, Part 63, Subpart LLL. At the stationary source, FG KG-5 and FG-KG-6 are subject to the Best Available Retrofit Technology (BART) program contained in 40 CFR, Part 51, Appendix Y and pursuant to Rules 970 and 971.

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No major emitting Emissions Unit at the stationary source are currently subject to the Prevention of Significant Deterioration (PSD) regulations of Part 18, Prevention of Significant Deterioration of Air Quality of Act 451 or 40 CFR, Part 52.21 because the Emission Unit was constructed/installed prior to June 19, 1978, the promulgation date of the PSD regulations. The monitoring conditions contained in the ROP are necessary to demonstrate compliance with all applicable requirements and are consistent with the "Procedure for Evaluating Periodic Monitoring Submittals." EU BALL MILL 20 Mill Vent and Separator, EU BALL MILL 21 Mill Vent and Separator, and EU CLINK COOL 19, EU CLINK COOL 20, EU CLINK COOL 21 are subject to the federal Compliance Assurance Monitoring (CAM) rule under 40 CFR, Part 64. These emissions units have a control device and potential pre-control emissions of particulate matter greater than the major source threshold level. The emission limitations or standards for particulate matter from each of the kilns at the stationary source are exempt from the federal CAM regulation under 40 CFR, Part 64 because particulate emission limits are addressed by 40 CFR, Part 63, Subpart LLL. Therefore, each of the kilns is exempt from CAM requirements for particulate matter. Please refer to Parts B, C and D in the draft ROP for detailed regulatory citations for the stationary source. Part A contains regulatory citations for general conditions. At this time, there are no GHG applicable requirements to include in the ROP. The mandatory Greenhouse Gas Reporting Rule under 40 CFR 98 is not an ROP applicable requirement and is not included in the ROP. Source-wide Permit to Install (PTI) Rule 214a requires the issuance of a Source-wide PTI within the ROP for conditions established pursuant to Rule 201. All terms and conditions that were initially established in a PTI are identified with a footnote designation in the integrated ROP/PTI document. The following table lists all individual PTIs that were incorporated into previous ROPs. PTIs issued after the effective date of ROP No. MI-ROP-B1477-2003b are identified in Appendix 6 of the ROP.

PTI Number 1-68 376-78 356-88C 152-92 8-72 960-78 356-88E 936-92 118-74 796-79 886-93 426-74 797-79 622-89C 203-94 353-75 798-79 166-93 380-94 442-75 857-79 83-89 611-95 443-75 956-79 786-89A 268-97 221-76 42-83 158-90 837-90 131-76 126-86D 837-90 624-77 163-88

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Streamlined/Subsumed Requirements The following table lists explanations of any streamlined/subsumed requirements included in the ROP pursuant to Rules 213(2) and 213(6). All subsumed requirements are enforceable under the streamlined requirement that subsumes them. Emission Unit/Flexible Group ID

Condition Number

Streamlined Limit/ Requirement

Subsumed Limit/ Requirement

Stringency Analysis

FG QUARRY I.3. R336.1301(1)(c), 5% opacity

40 CFR 60.672(b), 15% opacity

The streamlined requirement allows for 5% opacity, while the subsumed requirement allowed for 15% opacity.

FG QUARRY I.6. R333.1301(1)(c), Zero opacity

40 CFR 60.672(e), 7% opacity

The streamlined requirement allows for zero % opacity, while the subsumed requirement allowed for 7% opacity.

Non-applicable Requirements Part E of the draft ROP lists requirements that are not applicable to this source as determined by the AQD, if any were proposed in the application. These determinations are incorporated into the permit shield provision set forth in Part A (General Conditions 26 through 29) of the draft ROP pursuant to Rule 213(6)(a)(ii). Processes in Application Not Identified in Draft ROP The following table lists processes that were included in the ROP application as exempt devices under Rule 212(4). These processes are not subject to any process-specific emission limits or standards in any applicable requirement.

Exempt Emission Unit ID

Description of Exempt Emission Unit

ROP Exemption

PTI Permit Exemption

EU HVAC

Space heating – ALPAU0001, ALPAU0003 ALPAU0004, ALPAU0005 ALPAU0007, ALPAU0008 ALPAU0018, ALPAU0019 ALPAU0026, ALPAU0027 ALPAU0030, ALPAU0031 ALPAU0032, ALPAU0034 ALPAU0035, ALPAU0036 ALPAU0037, ALPAU0038 ALPAU0039, ALPAU0040 ALPAU0041, ALPAU0042 ALPAU0043, ALPAU0044 ALPAU0045, ALPAU0046 ALPAU0047, ALPAU0048 ALPAU0049, ALPAU0050 ALPAU0051, ALPAU0052 ALPAU0053, ALPAU0054

R 336.1212(4)(b) R 336.1282(b)(i)

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Exempt Emission Unit ID

Description of Exempt Emission Unit

ROP Exemption

PTI Permit Exemption

ALPAU0055, ALPAU0056 ALPAU0057, ALPAU0058 ALPAU0059, ALPAU0061 ALPAU0062, ALPAU0063 ALPAU0064, ALPAU0065 ALPAU0066, ALPAU0067

EU HotWaterHeater Hot water Heaters units 1 through 12 R 336.1212(4)(b) R 336.1282(b)(i) EU Propane tanks Propane storage tanks 1 through 17 R 336.1212(4)(c) R 336.1284(b) EU Gasoline Tank Vehicles refueling gasoline tank R 336.1212(4)(c) R 336.1284(g)(i)

EU Maint Shop Eqp All maintenance equipment in maintenance shop building

R 336.1212(4)(d) R 336.1285(l)(vi)

EU InComb Engines

Kilns 19 through 23 Auxilary Drives, Indirect Firing Generator Drive, Fire Suppression Pump Drive, Fire Suppression Generator Drive

R 336.1212(4)(d) R 336.1285(g)

Draft ROP Terms/Conditions Not Agreed to by Applicant The following table lists terms and/or conditions of the draft ROP that the AQD and the applicant did not agree upon and outlines the applicant’s objections pursuant to Rule 214(2). The terms and conditions that the AQD believes are necessary to comply with the requirements of Rule 213 shall be incorporated into the ROP.

Emission Unit/ Flexible Group ID

Permit Term(s) and/or Condition(s)

in Dispute Applicant’s Objection

FG FINISH MILLS V.2

This condition should be source wide condition. It should state that the permittee shall calculate and keep records of the annual emissions (MAERS) of PM-10 emissions described in Appendix 4, Table C in tons per calendar year. Calculations and record keeping shall continue until January 31, 2018 in the same language as the original Permit #15-05 (1.13). This condition applies to the whole plant’s emissions not just the specific emission units listed.

FG FUEL HAND V.2

This condition should be source wide condition. It should state that the permittee shall calculate and keep records of the annual emissions (MAERS) of PM-10 emissions described in Appendix 4, Table C in tons per calendar year. Calculations and record keeping shall continue until January 31, 2018.in the same language as the original Permit #15-05 (1.13). This condition applies to the whole plant’s emissions not just the specific emission units listed.

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Compliance Status The AQD finds that the stationary source is expected to be in compliance with all applicable requirements as of the effective date of this ROP. Action taken by the DEQ The AQD proposes to approve this permit. A final decision on the ROP will not be made until the public and affected states have had an opportunity to comment on the AQD’s proposed action and draft permit. In addition, the USEPA is allowed up to 45 days to review the draft permit and related material. The AQD is not required to accept recommendations that are not based on applicable requirements. The delegated decision maker for the AQD is Ms. Janis Denman, Cadillac District Supervisor. The final determination for ROP approval/disapproval will be based on the contents of the permit application, a judgment that the stationary source will be able to comply with applicable emission limits and other terms and conditions, and resolution of any objections by the USEPA.

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B1477 APRIL 6, 2012, STAFF REPORT ADDENDUM MI-ROP-B1477-2012

Purpose A Staff Report dated November 7, 2011, was developed in order to set forth the applicable requirements and factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by R 336.1214(1). The purpose of this Staff Report Addendum is to summarize any significant comments received on the draft ROP during the 30-day public comment period as described in R 336.1214(3). In addition, this addendum describes any changes to the draft ROP resulting from these pertinent comments. General Information


AQD Contact: Ms. Gloria Torello, Environmental Quality Analyst, 989-705-3410

Summary of Pertinent Comments Several changes were made to the ROP due to regulatory changes. The emission limitations or standards for particulate matter from each of the kilns at the stationary source are not exempt from the federal CAM regulation under 40 CFR, Part 64 because the kilns are no longer subject to particulate emission limits addressed by 40 CFR, Part 63, Subpart LLL (PC MACT). Instead the kilns are subject to 40 CFR, Part 60, Subpart DDDD Emissions Guidelines and Compliance Times for Commercial and Industrial Solid Waste Incineration Units that Commenced Construction on or before November 30, 1999 (CISWI). Therefore, each kiln is subject to CAM requirements for particulate matter. CAM conditions were added to FG KG5 and FG KG6. All conditions associated with the PC MACT were removed from FG KG5 and FG KG6. CISWI compliance is referenced in FG KG5 and FG KG6. Upon the effective date of CISWI regulations, FG KG5 and FG KG6 will be subject to mercury and dioxins/furans emission limitations as specified in Table 2 of CISWI, or Tables 6 through 9 of CISWI, by the final compliance date under the approved state plan, federal plan, or delegation, as applicable. During the public comment period, comments were received from the USEPA and Lafarge Midwest, Inc.-Alpena Plant. These and other pertinent comments resulted in changes to the November 7, 2011 Draft ROP and are described below. The referenced page numbers below relate to the November 7, 2011 Draft ROP. Changes to the November 7, 2011 Draft ROP

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SOURCE-WIDE CONDITIONS *Page 13, Process/Operational Restriction III.3 – no changes to this condition. The Operations and Maintenance plan referenced in this condition (“PC MACT Startup, Shutdown, and Malfunction Plan Kiln Groups 5 and 6 and Clinker Cooler Systems”) will be updated to include the baghouse pressure drops established as the normal range from the most recent particulate emission stack test on KG5, KG6, and Clinker Coolers associated with K22 and K23; and omit reference to the PC MACT as related to the kilns. Page 14, Monitoring/Recordkeeping Condition V1.1 was changed to: The permittee shall calculate and keep records of the annual emissions of SO2, NOx, CO, VOC, PM total, PM-10 filterable, and Lead from FG QUARRY, FG RAW MAT, FG RAW MILL SYS, FG KG5, FG KG6, FG KG5&6, FG CLINK COOL, FG CLINKER SYS, FG FINISH MILLS, FG CMNT STR LOAD, FG CKD HAND SYS, FG FUEL HAND and FG COLDCLEANERS. Calculations and record keeping shall continue until January 31, 2018.2 (40 CFR 52.21(r)(6)(c)(iii)) Page 14, Reporting Condition VII.4 was changed to: In the event that annual emissions (tons/year) of each regulated pollutant (as indicated below) exceed baseline actual emissions by a significant amount, the permittee shall submit a report to the Department. The report shall contain the following information: the name, address, and telephone number of the stationary source, the annual emissions calculated, an explanation as to why annual emissions exceeded the pre-construction projected actual

emissions. This information shall be submitted to the Department within 60 days after the end of each calendar year. (40 CFR 52.21(r)(6)(c)(iii))

Following are the projected actual emission:

NSR Pollutant Baseline

Emissions (tons/year)

Projected Actual

Emissions (tons/year)

PSD Significance Level (tons/year)

Baseline + Significance

Level (tons/year)

SO2 21,081 21,084 40 21,121 NOx 12,333 12,337 40 12,373 CO 1,524 1,530 100 1,624

VOC 54 58 40 94 PM, total 994 1,185 25 1019

PM10, filterable 836 995 15 851 Lead 0.13 0.16 0.6 0.73

The values listed in the table above are not emission limits but are only for purposes of indicating when the reporting requirements of this special condition are applicable. Page 15, Other Requirement IX.1 was deleted. FG RAW MAT *Page 33, Monitoring/Recordkeeping Condition VI.3, removed UAR: R 336.1301. Page 35, Removed footnotes 3 & 4.

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FG RAW MILL SYS *Page 36, Emission Limit I.2 Pollutant changed to PM. (PM and PM-10 conditions were grouped together.) Testing Condition V.5 was added: The permittee shall conduct a performance emission test for mercury every five years.2 (R 336.1229(1)(c), R 336.1901, R 336.2003, R 336.2001) Page 41, Removed footnote 3. Footnote 4 was re-numbered to 3 on page 41 and throughout FG RAW MILL SYS. Other Requirement IX.2 was added: The permittee shall be in compliance with all conditions of 40 CFR, Part 63, Subpart LLL National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry. (40 CFR, Part 63, Subpart LLL) FG KG5 (KILN GROUP 5) Page 43, Emission Limits I.3 and I.4 were deleted. Page 44, Emission Limits I.16 through I.22 were deleted. Page 45, Emission Limit I.23 was deleted. Page 45, Footnotes a, b, c & d were deleted. Footnote e was changed to a on page 45 and throughout

the Emission Limits table. Page 46, Material Limit II.6 was deleted. Page 46, Process/Operational Restriction III.3 was deleted. Page 47, Process/Operational Restrictions III. 5 through III.10 were deleted. Page 48, Design/Equipment Parameters IV. 2 and IV.3 were deleted. Page 48, Testing Conditions V. 3, 5, 7, 8 and 9 were deleted. **Testing Condition V.3 was added: Every five years, the permittee shall conduct stack testing to

correlate PM emission rate in pounds per 1,000 pounds of exhaust gases with percent opacity measured during testing. (40 CFR 64.4(e), 64.6(d))

Testing Condition V.8 was added: The permittee shall conduct a performance emission test for mercury every five years.2 (R 336.1229(1)(c), R 336.1901, R 336.2003, R 336.2001) Page 49, Monitoring/Recordkeeping Condition VI.1 removed UAR: 40 CFR 63.1355. Page 49, Monitoring/Recordkeeping Conditions VI. 4, 5, 7, 8, and 9 were deleted. **Page 49, Monitoring/Recordkeeping Condition VI.6, these UARs were added: 40 CFR 64.6(c)(1)(iii),

40 CFR 64.6(c)(3), 40 CFR 64.7.

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**Monitoring/Recordkeeping Conditions VI were added: VI.5 The permittee shall utilize COMS recorded opacity as an indicator of the proper functioning of the

baghouses. The appropriate range of opacity defining proper function of the baghouses is 0-20 percent opacity. (40 CFR 64.6(c)(1)(i) & (ii))

VI.6 The permittee shall use the COMS to assure compliance with the PM limit. An excursion for PM

shall be two consecutive 1-hour block average opacity values greater than 20 percent opacity. This condition does not affect compliance with R 336.1301. (40 CFR 64.6 (c)(2))

VI.7 The permittee shall properly maintain the COMS including keeping necessary parts for routine repair

of the monitoring equipment. (40 CFR 64.7(b))

VI.8 Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), the permittee shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant-specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of this part, including data averages and calculations or fulfilling a minimum data availability requirement, if applicable. The permittee shall use all the data collected during all other periods in assessing the operation of the control device and associated control system. A monitoring malfunction is any sudden, in frequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. The permittee shall operate the COMS during all required periods when the kilns are operating. Data recorded during monitoring malfunctions, repair activities and QA/QC operations shall not be used for 40 CFR, Part 64 compliance. (40 CFR 64.6(c)(3), 40 CFR 64.7(c))

VI.9 Upon detecting an excursion or exceedance, the permittee shall restore operation of the kiln(s)

(including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion or exceedance (other than those caused by excused startup or shutdown conditions). (40 CFR 64.7(d))

* Page 49, Monitoring/Recordkeeping Condition VI.11 was changed to: From EU KILN 19, EU KILN 20, and EU KILN 21, the permittee shall keep records of, the SO2, NOx and CO exhaust concentrations in ppmv corrected to seven percent oxygen on a dry gas basis and based on a one (1) minute average and 12-month rolling time period as determined at the end of each calendar month. These monitors and the resulting data shall be used in Excess Emission Reports for SO2, NOx and CO in special condition VII. Page 50, Monitoring/Recordkeeping Conditions VI.11 and VI.12 – removed UAR: 40 CFR 63.1355 Page 50, Monitoring/Recordkeeping Conditions VI. 13 through 19 were deleted. **Page 51, Reporting Condition VII.2, added UARS: 40 CFR 64.9(a)(2)(i) & (iii) Page 51, Reporting Conditions VII.4 and VII.6, removed UAR: 40 CFR 63.1354 Page 52, Reporting Conditions VII.7, VII.8 and VII.10, removed UAR: 40 CFR 63.1354 Page 52, Reporting Conditions VII.9 and VII. 11 were deleted. *Page 52, Reporting Condition VII.10 was changed to include in part:

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The EER shall also include the magnitudes of the excess emissions above the numbers in the table below. All concentrations shall be corrected to 7 percent oxygen on a dry gas basis and based on a one (1) minute average and a 12-month rolling time period as determined at the end of each calendar month. Page 53, Other Requirements IX.4 and IX.5 were deleted. Other Requirement IX.5 was added: The permittee shall be in compliance with all conditions of 40 CFR, Part 60, Subpart DDDD emission guidelines and compliance times for Commercial and Industrial Solid Waste Incineration units that commenced construction on or before November 30, 1999. (40 CFR, Part 60, Subpart DDDD) **Other Requirements IX were added: IX.2 The permittee shall promptly notify AQD for the need to modify the CAM Plan if the existing plan is found to be inadequate and shall submit a proposed modification to the ROP if necessary. (40 CFR 64.7(e)) IX.3 The permittee shall comply with all applicable requirements of 40 CFR, Part 64. (40 CFR, Part 64) Page 53, Removed footnotes 3 and 4. FG KG6 (KILN GROUP 6) Page 54, Emission Limit I.4 was deleted. Page 55, Emission Limit I.5 was deleted. Page 56, Emission Limits I.16 through I.23 were deleted. Page 56, Footnotes a, b, c, d were deleted. Footnote e was changed to a on page 56 and throughout the Emission Limits table. Page 57, Material Limit II.6 was deleted. Page 57, Process/Operational Restriction III.3 was deleted. Page 58, Process/Operational Restrictions III.5 through III.10 were deleted. Page 58, Design/Equipment Parameters IV.2 and IV.3 were deleted. **Testing Condition V.3 was added: Every five years, the permittee shall conduct stack testing to

correlate PM emission rate in pounds per 1,000 pounds of exhaust gases with percent opacity measured during testing. (40 CFR 64.4(e), 40 CFR 64.6(d))

Testing Condition V.8 was added: The permittee shall conduct a performance emission test for mercury every five years.2 (R 336.1229(1)(c), R 336.1901, R 336.2003, R 336.2001) Page 59, Testing Conditions V.3, V.5, V.7, V.8, and V.9 were deleted. Page 59, Monitoring/Recordkeeping Condition VI.1, removed UAR: 40 CFR 63.1355

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**Monitoring/Recordkeeping Conditions VI were added: VI.5 The permittee shall utilize COMS recorded opacity as an indicator of the proper functioning of the baghouses. The appropriate range of opacity defining proper function of the baghouses is 0-20 percent opacity. (40 CFR 64.6(c)(1)(i & ii))

VI.6 The permittee shall use the COMS to assure compliance with the PM limit. An excursion for PM

shall be two consecutive 1-hour block average opacity values greater than 20 percent opacity. This condition does not affect compliance with R 336.1301. (40 CFR 64.6 (c)(2))

VI.7 The permittee shall properly maintain the COMS including keeping necessary parts for routine repair

of the monitoring equipment. (40 CFR 64.7(b))

VI.8 Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), the permittee shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant-specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of this part, including data averages and calculations or fulfilling a minimum data availability requirement, if applicable. The permittee shall use all the data collected during all other periods in assessing the operation of the control device and associated control system. A monitoring malfunction is any sudden, in frequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. The permittee shall operate the COMS during all required periods when the kilns are operating. Data recorded during monitoring malfunctions, repair activities and QA/QC operations shall not be used for 40 CFR, Part 64 compliance. (40 CFR 64.6(c)(3), 40 CFR 64.7(c))

VI.9 Upon detecting an excursion or exceedance, the permittee shall restore operation of the kiln(s)

(including the control device and associated capture system) to its normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion or exceedance (other than those caused by excused startup or shutdown conditions). (40 CFR 64.7(d))

Page 60, Monitoring/Recordkeeping Conditions VI.3, VI.13 and VI.14, removed UAR: 40 CFR 63.1355 Page 60, Monitoring/Recordkeeping Conditions VI.4, VI.6, VI.8, VI.9 and VI.11 were deleted. **Page 60, Monitoring/Recordkeeping Condition VI.7, UARs were added: 40 CFR 64.6(c)(1)(iii), 40 CFR 64.6(c)(3), 40 CFR 64.7 *Page 60, Monitoring/Recordkeeping Condition VI.13 was changed to: From EU KILN 22 and EU KILN 23, the permittee shall keep records of the SO2, NOx and CO exhaust concentrations in ppmv corrected to seven percent oxygen on a dry gas basis and based on a one (1) minute average and a 12-month rolling time period as determined at the end of each calendar month. Concentrations shall be recorded consistent with the approved Monitoring Plan. These monitors and the resulting data shall be used in Excess Emission Reports for determining compliance with SO2, NOx and CO in special condition VII. Page 60, Monitoring/Recordkeeping Condition VI.5 was changed to: The permittee shall determine the hourly clinker production rate. (R 336.1213(3)) Page 61, Monitoring/Recordkeeping Conditions VI.16 through VI.22 were deleted.

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**Page 62, Reporting Condition VII.2, added UARS: 40 CFR 64.9(a)(2)(i) & (iii) Page 62, Reporting Conditions VII.4, VII.6 and VII.7, deleted UAR: 40 CFR 63.1354 Page 63, Reporting Conditions VII.8 and VII.10, deleted UAR: 40 CFR 63.1354 Page 63, Reporting Conditions VII.9 and VII.12 were deleted. Page 63, Reporting Condition VII.10 was changed to include in part: The EER shall also include the magnitudes of the excess emissions above the numbers in the table below. All concentrations shall be corrected to 7 percent oxygen on a dry gas basis and based on a one (1) minute average and a 12-month rolling time period as determined at the end of each calendar month. Page 64, Other Requirements IX.3 and IX.4 were deleted. **Other Requirements IX were added: IX.2 The permittee shall promptly notify AQD for the need to modify the CAM Plan if the existing plan is

found to be inadequate and shall submit a proposed modification to the ROP if necessary. (40 CFR 64.7(e))

IX.3 The permittee shall comply with all applicable requirements of 40 CFR Part 64.

(40 CFR, Part 64) Other Requirement IX.5 was added: The permittee shall be in compliance with all conditions of 40 CFR, Part 60, Subpart DDDD emission guidelines and compliance times for Commercial and Industrial Solid Waste Incineration units that commenced construction on or before November 30, 1999. (40 CFR, Part 60, Subpart DDDD) Page 64, Removed footnotes 3 & 4. FG CLINK COOL Page 70, Pollution Control Equipment, Stack and Vent Identification: added SV 25-507A to EU CLINK COOL 19, EU CLINK COOL 20 & EU CLINK COOL 21 **Testing Condition V.4 was added: Every five years, the permittee shall conduct stack testing to correlate PM emission rate in pounds per 1,000 pounds of exhaust gases with percent opacity measured during testing. (40 CFR 64.4(e), 40 CFR 64.6(d)) **Monitoring/Recordkeeping Condition VI.7 was added: Except for, as applicable, monitoring malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), the permittee shall conduct all monitoring in continuous operation (or shall collect data at all required intervals) at all times that the pollutant-specific emissions unit is operating. Data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities shall not be used for purposes of this part, including data averages and calculations or fulfilling a minimum data availability requirement, if applicable. The permittee shall use all the data collected during all other periods in assessing the operation of the control device and associated control system. A monitoring malfunction is any sudden, in frequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. The permittee shall operate the COMS during all required periods when the kilns are operating. Data recorded during monitoring malfunctions, repair activities and QA/QC operations shall not be used for 40 CFR, Part 64, compliance. (40 CFR 64.6(c)(3), 40 CFR 64.7(c))

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Monitoring/Recordkeeping Condition VI.11 was changed to: The permittee shall determine the hourly clinker production rate in accordance with 40 CFR, Part 63, Subpart LLL.4 (40 CFR 63.1350(d)) **Page 73, Reporting Condition VII. 2, UARS were added: 40 CFR 64.9(a)(2)(i) & (iii) Page 74, Stack/Vent Restrictions VIII.1 and VIII.2, added SV 25-507A. Other Requirement IX.2 was added: The permittee shall be in compliance with all conditions of 40 CFR, Part 63, Subpart LLL National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry. (40 CFR, Part 63, Subpart LLL) Page 75, Footnote 3, deleted reference to mercury, THC, and HCl. FG CLINKER SYS *Page 78, Monitoring/Recordkeeping Condition VI.3 was changed to: The permittee shall calculate monthly and calendar year PM emissions for FG CLINKER SYS using US EPA AP-42 emission factors, or emission factors acceptable to the AQD. All records shall be made available to the AQD upon request. (R 336.1213(3)) Other Requirement IX.1 was added: The permittee shall be in compliance with all conditions of 40 CFR, Part 63, Subpart LLL National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry. (40 CFR, Part 63, Subpart LLL) Page 79, Removed footnotes 3 & 4. FG FINISH MILLS **Testing Conditions V were added: V.3 The permittee shall utilize visible emission readings as an indicator of the proper functioning of the

dust collectors on EU BALL MILL 20 and EU BALL MILL 21, including mill vents and separators. The appropriate range of opacity is 0-10 percent. (40 CFR 64.4(c)(1)(i) & (ii))

V.4 Upon detecting an excursion or exceedance, the permittee shall restore operation of the EU BALL

MILL 20 and EU BALL MILL 21, including mill vents and separators, and including the control device and associated capture system, to their normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion or exceedance (other than those caused by excused startup or shutdown conditions). (40 CFR 64.7(d))

*Page 83, Monitoring/Recordkeeping Condition VI.8 was changed to: The permittee shall calculate monthly and 12-month rolling time period PM-10 emissions for EU BALL MILL 20 mill vent and EU BALL MILL 21 mill vent using stack test results, or other emission factors acceptable to the AQD. All records shall be made available to the AQD upon request.2 (R 336.1213(3), R 336.1205(1)(a) & (3)) Monitoring/Recordkeeping Conditions VI were added: VI.9 The permittee shall utilize visible emission readings as an indicator of the proper functioning of the dust collectors on EU BALL MILL 20 and EU BALL MILL 21, including mill vents and separators. The appropriate range of opacity is 0-10 percent. (40 CFR 64.4(c)(1)(i) & (ii))

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VI.10 Upon detecting an excursion or exceedance, the permittee shall restore operation of the EU BALL

MILL 20 and EU BALL MILL 21, including mill vents and separators, and including the control device and associated capture system, to their normal or usual manner of operation as expeditiously as practicable in accordance with good air pollution practices for minimizing emissions. The response shall include minimizing the period of any startup, shutdown or malfunction and taking any necessary corrective actions to restore normal operation and prevent the likely recurrence of the cause of an excursion or exceedance (other than those caused by excused startup or shutdown conditions). (40 CFR 64.7(d))

**Page 83, Reporting Condition VII.2, UARS were added: 40 CFR 64.9(a)(2)(i) & (iii) Other Requirement IX.4 was added: The permittee shall be in compliance with all conditions of 40 CFR, Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry. (40 CFR, Part 63, Subpart LLL) Page 84, Removed footnotes 3 and 4. FG CMNT STR LOAD *Page 88, Monitoring/Recordkeeping Condition VI.3 was changed to: The permittee shall calculate and keep monthly and 12-month rolling time period PM-10 emissions for EU STORE UNIT 4 and EU BULK LD TRUCK using EPA AP-42 emission factors, or other emission factors acceptable to the AQD. All records shall be made available to the AQD upon request 2 (R 336.1213(3), R 336.1205(1)(a) & (3)) *Page 88, Monitoring/Recordkeeping Condition VI.4 was changed to: The permittee shall keep, in a satisfactory manner, the annual PM emissions for FG CMNT STR LOAD using EPA AP-42 emission factors or other emission factors approved by the AQDB1477. All records shall be made available to the AQD upon request. (R 336.1213(3) Other Requirement IX.1 was added: The permittee shall be in compliance with all conditions of 40 CFR, Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry. (40 CFR, Part 63, Subpart LLL) Page 89, Removed footnotes 3 and 4. FG CKD HAND SYS Other Requirement IX.1 was added: The permittee shall be in compliance with all conditions of 40 CFR, Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry. (40 CFR, Part 63, Subpart LLL) Page 93, Removed footnotes 3 and 4. FG FUEL HAND Other Requirement IX.1 was added: The permittee shall be in compliance with all conditions of 40 CFR, Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry. (40 CFR, Part 63, Subpart LLL) Page 98, Removed footnotes 3 and 4.

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APPENDICES Page 103, Changed Appendix 4 to the standard boilerplate language: Specific recordkeeping requirement formats and procedures are detailed in Part A or the appropriate Source-Wide, Emission Unit and/or Flexible Group Special Conditions. Therefore, this appendix is not applicable. Page 108, Updated the language in Appendix 6 and moved the source-wide permit to install from within the table to the new language preceding the table. ___________ *This is a result of a comment from USEPA. **This was added to the ROP to address CAM.

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B1477 MAY 22, 2012, STAFF REPORT ADDENDUM MI-ROP-B1477-2012

Purpose A Staff Report dated November 7, 2011, was developed in order to set forth the applicable requirements and factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by R 336.1214(1). The purpose of this Staff Report Addendum is to summarize any significant comments received on the Draft Number 2 ROP from the company. In addition, this addendum describes any changes to the Draft Number 2 ROP resulting from these pertinent comments. General Information



Summary of Pertinent Comments The company requested the changes below.

Change texts to more accurately cite 40 CFR, Part 60, Subpart DDDD, and 40 CFR, Part 63, Subpart LLL.

Include an Alternate Monitoring Plan. The referenced page numbers below relate to the April 4, 2012 Draft Number 2 ROP. Changes to the April 4, 2012 Draft Number 2 ROP. FG RAW MILL SYS Page 39, Other Requirements, IX.2 was changed to: The permittee shall be in compliance with all applicable requirements of 40 CFR, Part 63, Subpart LLL National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry. (40 CFR, Part 63, Subpart LLL) FG KG5 (KILN GROUP 5) Page 47, Other Requirements, IX. 5 was changed to: The permittee shall comply with all applicable requirements of a state or federal plan implementing the provision of 40 CFR, Part 60, Subpart DDDD, Commercial and Industrial Solid Waste Incineration units that commenced construction on or before November 30, 1999. (40 CFR, Part 60, Subpart DDDD)

FG KG6 (KILN GROUP 6) Page 56, Other Requirements, IX. 5 was changed to: The permittee shall comply with all applicable requirements of a state or federal plan implementing the provision of 40 CFR, Part 60, Subpart DDDD, Commercial and Industrial Solid Waste Incineration units that commenced construction on or before November 30, 1999. (40 CFR, Part 60, Subpart DDDD) FG CLINK COOL

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Page 65, Monitoring/Recordkeeping, VI. 13 was added and includes: The permittee shall use the Alternate Monitoring Plan, as approved by EPA and found in Appendix 3, to determine the hourly clinker production rate, and the PM emission rate in pounds of PM per ton of clinker based on a 30 day rolling average.. (40 CFR 63.1350) Page 67, Other Requirements, IX.2 was changed to: The permittee shall be in compliance with all applicable requirements of 40 CFR, Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry. (40 CFR, Part 63, Subpart LLL) FG CLINKER SYS

Page 71, Other Requirements, IX.1 was changed to: The permittee shall be in compliance with all applicable requirements of 40 CFR, Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry. (40 CFR, Part 63, Subpart LLL) FG FINISH MILLS Page 77, Other Requirements, IX.4 was changed to: The permittee shall be in compliance with all applicable requirements of 40 CFR, Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry. (40 CFR, Part 63, Subpart LLL) FG CMNT STR LOAD Page 82, Other Requirements, IX.2 was changed to: The permittee shall be in compliance with all applicable requirements of 40 CFR, Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry. (40 CFR, Part 63, Subpart LLL) FG CKD HAND SYS Page 86, Other Requirements, IX.1 was changed to: The permittee shall be in compliance with all applicable requirements of 40 CFR, Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry. (40 CFR, Part 63, Subpart LLL) FG FUEL HAND Page 90, Other Requirements, IX.1 was changed to: The permittee shall be in compliance with all applicable requirements of 40 CFR, Part 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry. (40 CFR, Part 63, Subpart LLL)

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Appendix 3 Monitoring Requirement Page 95 Alternate Monitoring Plan to Determine the Hourly Clinker Production Rate, and a PM emission rate in pounds of PM per ton of clinker based on a 30 day rolling average, from FG KG 5 and FG KG6

FG KG 5

The permittee shall continuously monitor kiln rotations of each individual kiln in FG KG 5. Kiln rotations are monitored by the tachometers in the kiln drive which records the rotation of motor and multiplies with the reduction ratio of gear box and girth gear to get the kiln actual Rotation Per Hour (RPH). This number is recorded and stored in IP21 (group database for process parameters). The kiln rotations are used to determine weight rates in tons-mass per hour of the amount of clinker produced from each kiln in KG5. This shall be known as the Kiln Rotation Method (KRM). In the KRM, clinker produced is apportioned to each kiln according to the kiln’s hourly revolution counts by using the following formula “(total Clinker produced in 24 hours as recorded by clinker scale * Number of rotation completed by the specific kiln) / (total number of completed rotations by all three kilns) + Total Lime Stone Injected (LSI) in the kiln (recorded by scale) for the kiln *(LSI Proprietary Factor (LPF)).

Based on the KRM and the quarterly “weighted trucks” verification tests a PM emission rate in pounds of PM per ton of clinker based on a 30 day rolling average will be calculated for each clinker cooler.

Quarterly, for each kiln in KG 5, the permittee shall perform checks of the KRM by monitoring kiln revolutions, using weighted trucks* with weights of clinker produced by the kilns, and then comparing it with the scale data. One kiln check requires a minimum of 12 hours to complete.

During each quarter that FG CLINK COOL operates, the permittee shall determine, record, and maintain a record of the ongoing accuracy of the existing clinker weigh scale, including tons-mass per hour of clinker production. These records shall be maintained on file for five years and made available to the AQD upon request.

FG KG 6

The permittee shall continuously determine weight rates in tons-mass per hour of the amount of clinker produced from each kiln in FG KG 6 using the following weight averaging formula (total Clinker produced in 24 hours* Number of rotation completed by the specific kiln) / (total number of completed rotations by both kilns)

Based on the KRM and the quarterly “weighted trucks” verification tests a PM emission rate in pounds of PM per ton of clinker based on a 30 day rolling average will be calculated for each clinker cooler stack.

During each quarter that FG CLINK COOL operates, the permittee shall determine, record, and maintain a record of the ongoing accuracy of the existing clinker weigh scale, including tons-mass per hour of clinker production. These records shall be maintained on file for five years and made available to the AQD upon request.

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B1477 JUNE 4, 2012, STAFF REPORT ADDENDUM MI-ROP-B1477-2012

Purpose A Staff Report dated November 7, 2011, was developed in order to set forth the applicable requirements and factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by R 336.1214(1). The purpose of this Staff Report Addendum is to provide notice of a second public comment period for the Draft ROP. General Information Responsible Official: Mr. David Dziubinski, Plant Manager

989-354-4171 AQD Contact: Ms. Gloria Torello, Environmental Quality Analyst

989-705-3410 Date Public Comment Begins: June 4, 2012 Deadline for Public Comment: July 10, 2012

Second Public Comment Period The ROP is being public noticed for a second time as a result of changes in the applicability of federal regulations to emission units at the source. Specifically, the cement kilns included in FG KG5, FG KG6, and FG KG5&6 are no longer subject to the requirements of the National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry (40 CFR Part 63, Subpart LLL), and are now subject to the requirements in the Emission Guidelines for Existing Sources: Commercial and Industrial Solid Waste Incineration Units (40 CFR Part 60, Subpart DDDD). The Draft ROP reflects these changes.

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B1477 JULY 12, 2012, STAFF REPORT ADDENDUM MI-ROP-B1477-2012

Purpose A Staff Report dated November 7, 2011 was developed in order to set forth the applicable requirements and factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by R 336.1214(1). The purpose of this Staff Report Addendum is to summarize any significant comments received on the Draft Number 3 ROP during the 30-day public comment period as described in R 336.1214(3). In addition, this addendum describes any changes to the Draft Number 3 ROP resulting from these pertinent comments. General Information



Summary of Pertinent comments The USEPA provided comments during the public comment period of the Draft Number 3 ROP. The pertinent comments are summarized here. FG RAW MAT 1. Please ensure that there is a condition in the permit that requires the facility to operate the

baghouses for the emission units in FG RAW MAT to ensure that the terms from PTI 166-93A are incorporated completely.

2. Please explain and include in the permit record how the limit established on the baghouses in PTI 166-93A are sufficiently incorporated into the draft permit.

3. The draft permit, as written, does not explicitly require additional testing to verify the PM10 emission rate from each emission unit. Instead, condition III. 1 of FG RAW MAT requires the facility to maintain an approved MAP as a monitoring/testing method. Please explain and include in the permit record how maintaining an approved MAP ensures that the facility is meeting the PM10 emission rate limits or add monitoring, testing, and recordkeeping to the draft ROP sufficient to ensure that these rate limits are enforceable.

4. Draft permit conditions I.1, VI.3, and VIII. 1-6 of FG RAW MAT are denoted as federally enforceable requirements. However, PTI 166-93A conditions EU ARM I.8, VI.3, and VIII.1-6 are denoted as state-only enforceable conditions. Please clarify and include in the permit record justification as to why these conditions are now federally enforceable.

FG RAW MILL SYS 5. Please explain and include in the permit record how implementing and maintaining a MAP will ensure

compliance with this emission rate or add sufficient monitoring, testing, recordkeeping, and reporting sufficient to ensure that the facility complies with the PM10 emission rate limit.

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FG RAW MILL SYS/FG KG5/FG KG6 6. Mercury testing is included in these FGs, but a mercury emission rate limit is not established within

the ROP. Please clarify whether the facility must comply with a mercury limit. If so, please add this limit to the permit along with any other monitoring, testing, recordkeeping, and reporting to ensure compliance with such a limit. Otherwise, please explain and include in the permit record why a performance test for mercury is required and how this performance test is federally enforceable.

FG CLINK COOL 7. Condition III.2 of FG CLINK COOL requires the facility to install and operate a PM CEMS. Condition

VI.6 of FG CLINK COOL requires the facility to install and operate a COMS to assure compliance with the PM limit. Please clarify in the permit record that the COMS is being used to assure compliance with the PM limits since the facility is not required to operate a PM CEMS until September 9, 2013, per 40 CFR 63.1351(c). EPA recommends the draft permit include a condition that the facility use the PM CEMS to show compliance with the PM limit on and after the date it is required to operate a PM CEMS.

FG CLINKER SYS/FG CMNT STR LOAD 8. FG CLINKER SYS condition VI.3 and FG CMNT STR LOAD condition VI.4 require the facility to

calculate and record the annual PM emissions using EPA AP-42 emission factors or other approved emission factors. Please specify which AP-42 emission factors should be used to determine the annual PM emissions.

CAM PLAN 9. The CAM Plan employs COMS and pressure drop readings for compliance assurance with PM limits

but does not establish a mathematical correlation between the opacity and pressure drop indicator ranges and the PM limits. Such correlation must be established for the justification to be adequate.

The referenced page numbers below relate to the June 4, 2012 Draft Number 3 ROP. The “EPA Comment #” referenced below relate USEPA comments above. Changes to the June 4, 2012 Draft Number 3 ROP: FG RAW MAT Page 30. I. EMISSION LIMITS I.1. under Monitoring/Testing Method, VI.2 was removed. EPA Comment #1: Page 31, III. PROCESS/OPERATIONAL RESTRICTION(S) condition III.1. was changed to: The permittee shall not operate any equipment in FG RAW MAT unless the associated dust collector is installed and maintained and operated properly. The permittee is not required to operate dust collector 18-205 on EU ARM STOR BLDG. However, if the permittee does operate dust collector 18-205, its discharge shall not be discharged directly to the outside ambient air.2 EPA Comment #3: Page 31. I. EMISSION LIMIT(S) condition I.3 was changed. Under Monitoring/Testing Method “GC 13” was added. EPA Comment #4: Page 32, VI. MONITORING/RECORDKEEPING condition VI.3 the footnote was changed to 1.

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FG CLINKER SYS EPA Comment #8: Page 70 VI. MONITORING/RECORDKEEPING condition VI.3 was changed to: The permittee shall calculate monthly and calendar year PM emissions for FG CLINKER SYS using emission factors acceptable to the AQD. All records shall be made available to the AQD upon request. FG CMNT STR LOAD EPA Comment #8: Page 80 VI. MONITORING/RECORDKEEPING condition VI.4 was changed to: The permittee shall keep, in a satisfactory manner, the annual PM emissions for FG CMNT STR LOAD using emission factors approved by the AQD. All records shall be made available to the AQD upon request. Additional Responses to EPA Comments FG RAW MAT EPA Comment #2: Page 31. I. EMISSION LIMIT(S) condition I.3. The PM-10 limit applies to specific equipment within the emission unit. The limit was established in Permit to Install (PTI) 166-93A. In PTI 166-93A the emission limit referenced the stack vent. Below is a cross reference of the emission unit in the ROP to the stack vent from PTI 166-93A. ROP EU ARM FLY ASH PTI 166-93A Stack Vent ID Fly ash rail car unloading 17-018 SV 17-005 Fly ash receiver bin 17-040, SV 17-045 Fly ash dome 17-100 SV 17-105 Fly ash day bin 17-200 SV 17-205 Fly ash gravity conveyors 17-315 and 17-415 SV 17-325, SV 17-425

EPA Comment #3: Page 31. PROCESS/OPERATIONAL RESTRICTION condition III.2. A malfunction abatement plan (MAP) serves to prevent, detect, and correct malfunctions or equipment failures resulting in emissions exceeding any applicable emission limitation. A MAP is developed per the requirements of Rule 911 and specifies all of the following:

(a) identification of the supervisory personnel responsible for overseeing the inspection, maintenance, and repair of air-cleaning devices, a description of the items or conditions that shall be inspected, the frequency of the inspections or repairs, and an identification of the major replacement parts that shall be maintained in inventory for quick replacement.

(b) identification of the source and air-cleaning device operating variables that shall be monitored to detect a malfunction or failure, the normal operating range of these variables, and a description of the method of monitoring or surveillance procedures.

(c) a description of the corrective procedures or operational changes that shall be taken in the event of a malfunction or failure to achieve compliance with the applicable emission limits.

By preventing, detecting, and correcting malfunctions or equipment failures, the facility ensures that the permitted emission limit is met. EPA Comment #4: Pages 30, 33. FG RAW MAT. The following conditions have footnote 2 and are federally enforceable as follows. Page 30, EMISSION LIMIT(S) condition I.1 includes UAR R 336.1301 which sets opacity limits and is part of the state implementation plan (SIP). Page 33 STACK/VENT RESTRICTION(S) conditions VIII.1-6 include UARs R 336.1331 and R 336.1205 which restrict emissions of particulate matter, and assure the permit contains conditions that are enforceable and have been subjected to public participation. These UARS are part of the SIP. UAR 40 CFR 52.21 is included and is also federally enforceable.

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FG RAW MILL SYS EPA Comment #5: Page 34 I. EMISSION LIMIT(S) condition I.2. A MAP serves to prevent, detect, and correct malfunctions or equipment failures resulting in emissions exceeding any applicable emission limitation. See above EPA Comment #3 for the merits of a MAP used to meet a permitted emission limit. EPA Comment #6: Page 36 V. TESTING/SAMPLING condition V.5 requires mercury testing because this is a condition of permit to install 15-05. The ROP renewal is not the process to remove a condition from a permit to install. FG KG5 EPA Comment #6: Page 41 V. TESTING/SAMPLING condition V.8 requires mercury testing because this is a condition of Permit to Install 15-05. The ROP renewal is not the process to remove a condition from a Permit to Install. FG KG6 EPA Comment #6: Page 51 V. TESTING/SAMPLING condition V.8 requires mercury testing because this is a condition of Permit to Install 15-05. The ROP renewal is not the process to remove a condition from a Permit to Install. FG CLINK COOL EPA Comment #7: Page 63 III. PROCESS/OPERATIONAL RESTRICTION(S) condition III.2 requires a PM CEMS as a direct measure of PM emissions and has a UAR of 40 CFR 63.1350 and has a footnote 4 indicating the compliance date for this condition is established in 40 CFR 63.1351. The draft permit includes conditions that the facility use the PM CEMS to show compliance with the PM limits as seen in I.EMISSION LIMIT(S) conditions 2, 3, 4, 6 and 7 under Monitoring/Testing which includes “VI.8.” Condition VI.8 states in part, “…continuously monitor and continuously demonstrate compliance with the PM emissions standard…” Page 64 MONITORING/RECORDKEEPING condition VI.6. requires a COM to assure compliance with PM as the compliance relates to CAM and has a UAR of 40 CFR 64.6(c) (2). Condition VI.6 will be in use when the ROP is issued and beyond September 9, 2013 to show compliance with CAM. CAM Plans that employ COMS and pressure drop readings for compliance assurance with PM limits EPA Comment #9: The CAM Plan incorporate COMS and pressure drop to confirm proper operation of the Dust Collectors on the Clinker Coolers. In addition, the particulate emission rate is verified through periodic stack testing to ensure compliance with PM limits. The stack testing is conducted under normal operating conditions with the COMS in place and operating and the dust collector under negative pressure. For the stack testing periods, per the required methods the COMS must be functioning and reading within a normal range with a negative pressure drop maintained across the collectors. As a consequence, there is a clear correlation that as long as the COMS are reading within the normal range and a negative pressure drop is maintained across the collector, then the Clinker Cooler stack vents are meeting the PM limits.

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B1477 JULY 25, 2012 STAFF REPORT ADDENDUM MI-ROP-B1477-2012

Purpose A Staff Report dated November 7, 2011, was developed in order to set forth the applicable requirements and factual basis for the draft Renewable Operating Permit (ROP) terms and conditions as required by R 336.1214(1). The purpose of this Staff Report Addendum is to summarize any significant comments received from the company on the preliminary Proposed ROP following changes made as a result of comments received during the 30-day public comment period as described in R 336.1214(3). In addition, this addendum describes any changes to the draft ROP resulting from these pertinent comments. General Information



Summary of Pertinent Comments No pertinent comments were received from the company following their review of the preliminary Proposed ROP. Changes to the preliminary Proposed ROP No changes were made to the preliminary Proposed ROP.

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B1477 NOVEMBER 6, 2015 STAFF REPORT FOR RULE 216(2) MINOR MODIFICATION

MI-ROP-B1477-2012a

Purpose On September 13, 2012, the Department of Environmental Quality, Air Quality Division (AQD), approved and issued Renewable Operating Permit (ROP) No. MI-ROP-B1477-2012 to Lafarge Midwest Inc. pursuant to R 336.1214. Once issued, a company is required to submit an application for changes to the ROP as described in R 336.1216. The purpose of this Staff Report is to describe the changes that were made to the ROP pursuant to R 336.1216(2). General Information Responsible Official: Mr. Paul Rogers, Plant Manager

AQD Contact: Ms. Caryn Owens, Environmental Quality Analyst 231-775-4414

Application Number: 201500067 Date Application For Minor Modification Was Submitted:

May 6, 2015

Regulatory Analysis The AQD has determined that the change requested by the stationary source meets the qualifications for a Minor Modification pursuant to R 336.1216(2). Description of Changes to the ROP Incorporate Permit to Install (PTI) No. 89-13. PTI No. 89-13 incorporated limits into (FG KG5 and FG KG6) that were required by the EPA Global Consent Decree number 3:10-cv-44-JPG. Compliance Status The AQD finds that the stationary source is expected to be in compliance with all applicable requirements associated with the emission unit(s) involved with the change as of the date of approval of the Minor Modification to the ROP. Action Taken by the DEQ The AQD proposes to approve a Minor Modification to ROP No. MI-ROP-B1477-2012, as requested by the stationary source. A final decision on the Minor Modification to the ROP will not be made until any affected states and the U.S. Environmental Protection Agency (USEPA) has been allowed 45 days to review the proposed changes to the ROP. The delegated decision maker for the AQD is the District Supervisor. The final determination for approval of the Minor Modification will be based on the contents of the permit application, a judgment that the stationary source will be able to comply with applicable emission limits and other requirements, and resolution of any objections by any affected states or the USEPA.

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B1477 NOVEMBER 6, 2015 STAFF REPORT FOR RULE 216(1)(a)(v) ADMINISTRATIVE AMENDMENT

MI-ROP-B1477-2012a

Purpose On September 13, 2012, the Department of Environmental Quality (DEQ), Air Quality Division (AQD), approved and issued Renewable Operating Permit (ROP) No. MI-ROP-B1477-2012 to Lafarge Midwest Inc. pursuant to R 336.1214. Once issued, a company is required to submit an application for changes to the ROP as described in R 336.1216. The purpose of this Staff Report is to describe the changes that were made to the ROP pursuant to R 336.1216(1)(a)(v). General Information Responsible Official: Mr. Paul Rogers, Plant Manager


Application Numbers: 201500093; 201500094 Date Applications For Administrative Amendment Were Submitted:

June 24, 2015

Regulatory Analysis The stationary source has requested that Permit to Install (PTI) Nos. 195-10b (issued May 17, 2013) and 106-08A (issued October 23, 2014) be incorporated into their ROP. The AQD has determined that the change requested meets the following criteria for an Administrative Amendment pursuant to Rule 216(1)(a)(v): the PTI includes terms and conditions that comply with the permit content requirements contained in Rule 213; the procedure used to issue the PTI was substantially equivalent to the requirements of Rule 214 regarding public participation and review by affected states; and the process or process equipment is in compliance with, and no changes are required to, the terms and conditions of the PTI that are to be incorporated into the ROP. Also, the permittee notified the AQD in writing within 30 days of commencing operation of the processes covered by the PTI and has submitted certified results of all required testing, monitoring and recordkeeping performed to demonstrate compliance with the PTI. Description of Changes to the ROP Incorporate PTI No. 195-10A: Under PTI No. 195-10A, Lafarge is installing a new Wet flue gas desulfurization (FGD) on Kiln Group 6 (KG-6; also called kilns 22+23). Lafarge is installing a bleed stream from the dewatering portion of the wet FGD system to remove chlorides and inert minerals in the exhaust gas stream before recirculating to the kilns. The materials must be removed prior to entering the kiln system, as excessive levels of chlorides and inert minerals could make the gypsum unsuitable for use in cement.

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Lafarge has determined that the optimal location to introduce the bleed stream is at the clinker coolers. By introducing the bleed stream to the clinker coolers, Lafarge will reclaim clinker from the solids in the water. The increase in clinker production was used as the basis to calculate the increases in particulate matter (PM), particulate matter that has an aerodynamic diameter less than or equal to a nominal 10 microns (PM10), and particulate matter that has an aerodynamic diameter less than or equal to a nominal 2.5 microns (PM2.5). The proposed installation will also result in a new emission source of mercury (Hg). This will not increase Hg emissions; only re-direct a portion of the Hg emissions from kilns 22 and 23. Incorporate PTI No. 106-08A: Lafarge is expanding the types of plastics to burn in all 5 kilns and utilize shingles on all 5 kilns on a continuous basis. No physical modifications of the kilns are needed to allow for the use of additional plastics or shingles. The plastics will be pneumatically conveyed to the kiln burner pipe as shredded, dry pieces. Shingles can be introduced to the kilns through existing systems as well. Lafarge anticipates that the use of plastics and shingles as proposed has the potential to reduce mercury emissions and will assist in achieving the mercury emission limit applicable to the facility as the alternative fuels contain less mercury compared to the coal and coke, which will be offset on a one for one heat content basis. No change in NOx or SO2 will result as all kilns are controlled to emission limitations established or being established pursuant to Lafarge’s federal consent decree. No changes in CO or VOC emissions are anticipated. As indicated, increased utilization of these alternate fuels will assist in maintaining compliance with applicable mercury limits. As the co-benefit of the SO2 controls is control of acid gases, no meaningful change is anticipated and the facility’s ability to maintain compliance with existing chlorine/HCL emission limitations. The Lafarge facility is an existing major stationary source of air pollution. However, the proposed fuel additions of plastic and shingles will not result in significant emission increases or trigger Prevention of Significant Deterioration (PSD) permitting requirements. Additionally, the fuel additions are expected to decrease emissions of sulfur dioxide (SO2) and mercury (Hg). Compliance Status The AQD finds that the stationary source is expected to be in compliance with all applicable requirements associated with the change as of the date of approval of the Administrative Amendment to the ROP. Action Taken by the DEQ The AQD proposes to approve an Administrative Amendment to ROP No. MI-ROP-B1477-2012 as requested by the stationary source. A final decision on the Administrative Amendment to the ROP will not be made until the U.S. Environmental Protection Agency (USEPA) has been allowed 45 days to review the proposed changes to the ROP. The delegated decision maker for the AQD is the District Supervisor. The final determination for approval of the Administrative Amendment will be based on the contents of the permit application, a judgment that the stationary source will be able to comply with applicable emission limits and other requirements, and resolution of any objections by the USEPA.

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B1477

DECEMBER 22, 2015 STAFF REPORT ADDENDUM FOR RULE 216(1)(a)(v)

ADMINISTRATIVE AMENDMENT MI-ROP-B1477-2012a

Purpose A Staff Report dated November 6, 2015, was developed in order to set forth the applicable requirements and factual basis for the proposed Administrative Amendment to Renewable Operating Permit’s (ROP) terms and conditions as required by R 336.1216(1)(c). The purpose of this Staff Report Addendum is to summarize any significant comments received on the proposed ROP Administrative Amendment during the U.S. Environmental Protection Agency’s (USEPA), 45-day comment period as described in R 336.1216(1)(c). In addition, this addendum describes any changes to the proposed ROP Administrative Amendment resulting from these pertinent comments. General Information Responsible Official: Mr. Paul Rogers, Plant Manager


Summary of Pertinent Comments No pertinent comments were received during the USEPA’s 45-day comment period. Changes to the November 6, 2015 Proposed ROP Administrative Amendment No changes were made to the proposed ROP Administrative Amendment.

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B1477 SEPTEMBER 19, 2016 - STAFF REPORT FOR

RULE 216(2) MINOR MODIFICATION

MI-ROP-B1477-2012b

Purpose On September 13, 2012, the DEQ, AQD, approved and issued ROP No. MI-ROP-B1477-2012 to Lafarge Midwest, Inc. - Alpena Plant pursuant to R 336.1214. Once issued, a company is required to submit an application for changes to the ROP as described in R 336.1216. The purpose of this Staff Report is to describe the changes that were made to the ROP pursuant to R 336.1216(2). General Information Responsible Official: Mr. Paul Rogers, Plant Manager


Application Number: 201500128 Date Application For Minor Modification Was Submitted:

July 15, 2015

Regulatory Analysis The AQD has determined that the change requested by the stationary source meets the qualifications for a Minor Modification pursuant to R 336.1216(2). Description of Changes to the ROP The particulate matter (PM) monitoring device referred to in FG CLINK COOL was incorrectly identified as the PM CEMS (Particulate Matter Continuous Emission Monitoring System) in the ROP. The monitoring device is actually a PM continuous parametric monitoring system (CPMS), and the monitoring conditions were for a PM CPMS. The AQD has changed all references of PM CEMS to PM CPMS in FG CLINK COOL. Lafarge Midwest, Inc. - Alpena Plant also requested to remove the CAM requirements from FG CLINK COOL, FG KG5, FG KG6, and FG FINISH MILLS, and add the requirements as an Appendix in the ROP. Removal of requirements referencing the opacity limit and Continuous Opacity Monitor System (COMS) was also requested. The AQD denied the request to add the CAM requirements in an Appendix, and to remove opacity and COM Conditions from FG CLINK COOL, since opacity limits and monitoring were originally required in a Permit to Install and an opacity monitor is still in place and being used at the facility. The emission limitation for PM from FG CLINK COOL at the stationary source is subject to the federal CAM rule, but monitoring included in 40 CFR Part 63, Subpart LLL (PC MACT) is considered to be presumptively acceptable monitoring for PM and is included in the ROP in FG CLINK COOL. There are some existing Conditions related to CAM that could not be removed, because the PC MACT does not include references to these specific CAM requirements. For the most part, the AQD added the CAM UARs along with the PC MACT UARs to show compliance with both. Additionally, The AQD updated the CAM requirements for FG KG6 and removed the COM requirements since this emission unit uses a baghouse and wet scrubber for PM control and the COMS has been removed.

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Compliance Status The AQD finds that the stationary source is expected to be in compliance with all applicable requirements associated with the emission unit(s) involved with the change as of the date of approval of the Minor Modification to the ROP. Action Taken by the MDEQ The AQD proposes to approve a Minor Modification to ROP No. MI-ROP-B1477-2012a, as requested by the stationary source. A final decision on the Minor Modification to the ROP will not be made until any affected states and the USEPA has been allowed 45 days to review the proposed changes to the ROP. The delegated decision maker for the AQD is the District Supervisor. The final determination for approval of the Minor Modification will be based on the contents of the permit application, a judgment that the stationary source will be able to comply with applicable emission limits and other requirements, and resolution of any objections by any affected states or the USEPA.

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B1477 NOVEMBER 4, 2016 - STAFF REPORT ADDENDUM

FOR RULE 216(2) MINOR MODIFICATION

MI-ROP-B1477-

2012b Purpose A Staff Report dated September 19, 2016, was developed in order to set forth the applicable requirements and factual basis for the proposed Minor Modification to the Renewable Operating Permit’s (ROP) terms and conditions as required by R 336.1216(2)(c). The purpose of this Staff Report Addendum is to summarize any significant comments received on the proposed ROP modification during the U.S. Environmental Protection Agency’s (USEPA) 45-day comment period as described in R 336.1216(2)(c). In addition, this addendum describes any changes to the proposed ROP Minor Modification resulting from these pertinent comments. General Information Responsible Official: Mr. Paul Rogers, Plant Manager AQD Contact: Ms. Caryn Owens, Environmental Quality Analyst

231-876-4414 Summary of Pertinent Comments No pertinent comments were received during the USEPA’s 45-day comment period. Changes to the September 19, 2016 Proposed ROP Minor Modification No changes were made to the proposed ROP Minor Modification.

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B1477 MAY 26, 2017 - STAFF REPORT FOR RULE

216(1)(a)(v) ADMINISTRATIVE AMENDMENT

MI-ROP-B1477-2012c

Purpose On November 4, 2016, the Department of Environmental Quality (DEQ), Air Quality Division (AQD), approved and issued Renewable Operating Permit (ROP) No. MI-ROP-B1477-2012b to Lafarge Midwest, Inc. - Alpena Plant pursuant to R 336.1214. Once issued, a company is required to submit an application for changes to the ROP as described in R 336.1216. The purpose of this Staff Report is to describe the changes that were made to the ROP pursuant to R 336.1216(1)(a)(v). General Information

Responsible Official: Mr. Paul Rogers, Plant Manager 989-354-4171


Application Number: 2016000164 Date Application For Administrative Amendment Was Submitted:

October 14, 2016

Regulatory Analysis The stationary source has requested that the Permit to Install (PTI) No. 171-15, issued on September 13, 2016, be incorporated into their ROP. The AQD has determined that the change requested meets the following criteria for an Administrative Amendment pursuant to Rule 216(1)(a)(v): the PTI includes terms and conditions that comply with the permit content requirements contained in Rule 213; the procedure used to issue the PTI was substantially equivalent to the requirements of Rule 214 regarding public participation and review by affected states; and the process or process equipment is in compliance with, and no changes are required to, the terms and conditions of the PTI that are to be incorporated into the ROP. Also, the permittee notified the AQD in writing within 30 days of commencing operation of the processes covered by the PTI and has submitted certified results of all required testing, monitoring and recordkeeping performed to demonstrate compliance with the PTI. Description of Changes to the ROP Incorporate PTI 171-15, which was issued to eliminate the outdated requirements and streamline the permit to allow modification of the existing ROP to include only the most relevant applicable requirements. Additionally, this PTI established a lower sulfur dioxide SO2 emissions in pounds per ton of clinker based on a 30-day rolling average for FG KG6 (Special Conditions (SC) I.6 and SC VI.4). Lafarge monitors the SO2 using a continuous emission monitoring system (CEMS) to show compliance with this limit. Additionally, changes to the Federal PSD Regulation 40 CFR 52.21 versus Michigan Part 18 Rules were clarified. The Federal Regulation (40 CFR 52.21) is a very broad regulation and before the Michigan Part 18 SIP was approved the AQD would cite 40 CFR 52.21 for a number of different requirements. During review for PTI 171-15 all the 40 CFR 52.21 citations had to be researched to determine if they were cited for Increment Modeling (R 336.2803), NAAQS Modeling (R 336.2804), PSD BACT

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(R 336.2810), Netting (R 336.2802(4)) or Actual to Actual (A2A) emissions (R 336.2818). Once the reason for citing the federal regulation was determined the Michigan Part 18 Rule replaced it. Compliance Status The AQD finds that the stationary source is expected to be in compliance with all applicable requirements associated with the change as of the date of approval of the Administrative Amendment to the ROP. Action Taken by the MDEQ The AQD proposes to approve an Administrative Amendment to ROP No. MI-ROP-B1477-2012b, as requested by the stationary source. A final decision on the Administrative Amendment to the ROP will not be made until the USEPA has been allowed 45 days to review the proposed changes to the ROP. The delegated decision maker for the AQD is the District Supervisor. The final determination for approval of the Administrative Amendment will be based on the contents of the permit application, a judgment that the stationary source will be able to comply with applicable emission limits and other requirements, and resolution of any objections by the USEPA.

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