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QuarryNo10570 Blandor Way

Los Altos Hills, CA 94024

www.quarryno.com

May 18, 2011

Ms. Deborah Jordan

Director, Air Division

Environmental Protection Agency

75 Hawthorne Street

San Francisco, CA 94105

Dear Ms. Jordan,

We are writing you in regard to BAAQMD Application 22954 for Facility #A0017 submitted by

the Air District to you for approval last week. This Application while key to the new Title V

Permit (Application 17947) was deliberately left out of the Title V Permit as circulated for Publiccomment even though it was received prior to the circulation.

The apparent intent was to circumvent Public comment by processing it as a minor revision to the

current Title V Permit and reinserting it later into the new Title V Permit as stated on page 4 of

this application (22954). It was anything but minor being the key element in reducing Mercury

emissions.

The BAAQMD had withdrawn an earlier version of the Title V Permit on January 5, 2010 for the

express purpose of incorporating significantly more stringent standards for mercury air

contaminants under Amendments to 40 CFR 63, Subpart LLL, National Emission Standards for

Hazardous Air Pollutants (NESHAP). That has not happened and the Public wound up

reviewing an incomplete document missing key elements such as the Carbon Injection system

here and the critical Mercury Continuous Emission Monitoring (CEM) system.

Hopefully the Carbon Air Injection system contemplated will be a great success but today it has

not been demonstrated in the Cement Industry, it is very temperature sensitive and there is the

challenge of source monitoring of a 32 bag venting system notorious for leaks and fugitive dust.

This application should not be processed separately but should be incorporated into the new Title

V Permit along with its Mercury CEM and made available for Public comment. Please consider

the Public in your actions. We have had silence on Mercury emissions that exceeded

notifications levels for the last 3 years and now we have this manipulation of the Title V process.

This is not the role the Public was to play per the Clean Air Act. Thanks for your consideration.

Sincerely,

Bill Almon

QuarryNo

http://www.quarryno.com/http://www.quarryno.com/http://www.quarryno.com/

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S%UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX4 75 Hawthorne Street%PRO San Francisco, CA 94105

June 20 , 2011Mr. William J. AlmonQUARRYNO10570 Blando r WayLos Altos Hills, California 94024Dear Mr. Almon:Thank you for your letter da ted May 18, 2011 to Debo rah Jordan regarding the Bay Area Air QualityManagement Districts (BAAQMD or D istrict) minor revision to the Clean Air Act title V permitfor facility #A0017 , which is the Lehigh Southwes t Cement Company (Lehigh). Your letter ment ion syour concern s about the omission of the minor revision from the recent draft title V renew al permit forLehigh that BAAQMD issued for the public commen t that began on Janua ry 21, 2011 and concluded onMarch 25, 2011. According to the Districts Statemen t of Basis for the minor permit rev ision, theminor revision incorporates requirements for the installation and ope ration of an ac tivated carboninjection (ACT) system and a mercury continuous em ission mon itoring system (CEMS) at Lehighscemen t ki ln into Leh ighs title V perm it.We contacted the BAAQMD regarding your concerns. The District info rmed us tha t Lehigh submittedan application for a New Source Review (NSR) construction permit for the ACT system and mercuryCEMS on January 10, 2011. The District also informed us it issued a final NSR permit onMay 5. 2011. BAAQMDs minor permit revision to Lehighs title V permit will incorporate the NSRpe rm it into the title V perm it using the Districts minor revision ru le, Rule 2-6-215.The Districts Statement of Basis for the minor permit revision to the title V permit states tha t theoperation of the ACT system and mercu ry CEMS is a voluntary in terim action tha t is in tended to reducemercury emissions under the California Air Toxics Hot Spots Program, which is a State-onlyrequirem ent . Because it appears that, at th is tim e, th is revision does not address federal applicablerequirements, we be lieve the District may proceed with processing the revision under Rule 2-6-215 ,which requires a 45 -day rev iew period for the Environmental Pro tection Agency (EPA), bu t does notrequire publ ic participation.Please note, however , that we are providing a comment to the District on the minor perm it revisionstating that it is our understanding that the ACT system and the mercury CEMS will be used todemonstrate compliance with requirements in the National Emission Standa rds for Hazardous AirPollutants (NE5HAP) for Por tland Cem ent Plants. (The emission stand ard in the NESHAP has acompliance deadline in 2013.) We sugge st that the District clarify in the future revision to the title Vpermit that the ACT system and mercury CEMS will be used to comply with the NESHAP. A copy ofth is letter is enclosed for you r conven ience.Please no te as well that the renewal of Lehighs title V permit will be subject to a 45 -day EPA reviewperiod later this year. BAAQMD Rule 2-6-411 allows the public allowed to petition EPA to fo rmally

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object to the permit based on commen ts made to BAAQMD or revisions made to the ren ewal pe rmit thatwas public no ticed. The public may subm it a petition 60 days after EPAs 45-day review period ends.If you have further que stions, please feel free to con tact me at rios.gerardoepa.gov, or Shaheerah Kellyof my staff for permitting issues at kel1y.shaheerahepa.gov, or Kara Christenson for legal issues atchristenson.karaepa.gov.We hope the above intbrmation is useful to you, and thank you for sharing your concerns with EPA.

Sincerely,1 /

Gerardo C. RiosChief, Permits OfficeAir Division

Enclosure

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S7qUNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION IXC 75 Hawthorne StreetSan Francisco, CA 94105

June 20, 2011Mr. Dennis JangSenior Air Quality EngineerBay Area Air Quality Management District939 Ellis StreetSan Francisco, California 94109Dear Mr. Jang:Thank you for the opportunity to review the minor revision to the Clean Air Act title V permit for theLehigh Southwest Cement Company (Lehigh). This permit action was submitted to the EnvironmentalProtection Agency (EPA) on May 10, 2011. According to the Districts Statement of Basis, thepurpose of this minor revision is to incorporate requirements for the installation and operation of anactivated carbon injection (ACT) system for mercury control and a mercury continuous emissionmonitoring system (CEMS) at Lehighs cement kiln in to the t itle V permit.The Districts permit evaluation for this minor revision states that these requirements are voluntary and areintended to reduce mercury emissions under the California Air Toxics Hot Spots Program, which is aState-only requirement. It also states that the ACT system is part of Lehighs overall efforts to controlmercury emissions from the fac ili ty , and that the facility will be making additional modifications,including adding a single stack, to further reduce mercury and other hazardous air pollutants.It is also ou r understanding that these controls will be used to demonstrate compliance with some or all ofthe requirements in the National Emission Standards for Hazardous Air Pollutants (NESHAP) forPortland Cement Plants that apply to Lehigh, which has a future compliance date in 2013. We suggestthat the future revision to the title V permit clarify that the ACT system and mercury CEMS will be used tocomply with the NESHAP.If you have any questions, feel f ree to contact Shaheerah Kelly of my staff at (415) 947-4156 orkel1y.shaheerahepa.gov.

Sincerely,

Gerardo C. RiosChief, Permits OfficeAir Division