Iowa State Implementation Plan, Revision for PM10 in ...

Iowa State Implementation Plan

Revision for PM10 in

Buffalo, Iowa

Iowa Department of Natural Resources Environmental Services Division

Air Quality Bureau 502 E 9th St

Des Moines, IA 50319

Draft December 2020

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Executive Summary The Iowa Department of Natural Resources (DNR) is revising the State Implementation Plan (SIP) to replace Administrative Consent Order (ACO) number 98-AQ-07, issued to Linwood Mining & Minerals Corporation in 1998, with 35 air construction permits. The air construction permits contain updated emissions limits, operating conditions, and other control measures necessary to provide for continued attainment of the PM10 national ambient air quality standards (NAAQS) in the Buffalo, Iowa area.

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Table of Contents Executive Summary ................................................................................................................................................................. 2 1. Introduction ...................................................................................................................................................................... 4

1.1. PM10 NAAQS ............................................................................................................................................................... 4 1.2. Buffalo Area Overview ............................................................................................................................................... 4 1.3. PM10 24-Hour Ambient Air Data Summary ................................................................................................................ 6 1.4. SIP Revision ................................................................................................................................................................ 7

2. Linwood’s Revised Control Measures .............................................................................................................................. 8 3. Modeling Demonstration ............................................................................................................................................... 10

3.1. Air Quality Model Selection ..................................................................................................................................... 10 3.2. Receptor Grid/Spacing/Terrain Elevations .............................................................................................................. 10 3.3. Meteorological Data ................................................................................................................................................ 11 3.4. Downwash................................................................................................................................................................ 12 3.5. Source Inventory ...................................................................................................................................................... 12 3.6. Background Concentration ...................................................................................................................................... 14 3.7. Results ...................................................................................................................................................................... 15

4. Administrative Materials ................................................................................................................................................ 16 4.1. Legal Authority ......................................................................................................................................................... 16

5. Public Participation ......................................................................................................................................................... 17 Appendix A. Linwood’s Air Construction Permits ................................................................................................................. 18

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1. Introduction On October 1, 1998, the state submitted a revision of the State Implementation Plan (SIP) to reduce ambient concentrations of particulate matter with an aerodynamic diameter less than or equal to 10 microns (PM10) in the Buffalo, Iowa area. That SIP revision included two Administrative Consent Orders (ACO), one each for the two major PM10 sources in the area, Linwood Mining & Minerals Corporation (Linwood) and Lafarge Corporation (now Continental Cement). The Iowa Department of Natural Resources (DNR) designed the emission limits and other control measures in Linwood’s ACO, 98-AQ-07, and in Lafarge’s ACO, 98-AQ-08, to meet the PM10 national ambient air quality standards (NAAQS). The U.S. Environmental Protection Agency (EPA) fully approved the SIP revision and the ACOs on March 18, 1999 (64 FR 13343).

1.1. PM10 NAAQS Solid and liquid particles within the PM10 size fraction can harm lung tissue by causing scarring and decreased lung function. These particles can also cause eye and throat irritation and premature death. To protect public health, EPA establishes standards, called primary NAAQS, which quantify the maximum amount of pollution allowed in ambient air. To protect public welfare from any known or anticipated adverse effects of a pollutant, such as visibility degradation, EPA establishes secondary NAAQS. The state of Iowa ambient air quality standards are the national primary and secondary ambient air quality standards as published in 40 Code of Federal Regulations (CFR) Part 50, as adopted by reference into 567 Iowa Administrative Code (IAC) Chapter 28 (as amended on February 15, 2017, and effective March 22, 2017). The level of the current primary PM10 NAAQS is 150 micrograms per cubic meter (µg/m3), based on a 24-hour average concentration. The standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 µg/m3, as determined in accordance with Appendix K to 40 CFR 50, is equal to or less than one. The PM10 secondary NAAQS is equal to the primary standard in all respects.

1.2. Buffalo Area Overview Buffalo, Iowa, is a town in southern Scott County with a 2018 annual population estimate of 1,279 people (State Data Center, accessed October 2020). Buffalo is located southwest of the city of Davenport along Highway 22, near the western shore of the Mississippi River, as indicated in Figure 1-1. A series of quarries lie east of Buffalo. The Buffalo PM10 monitoring site (site ID 19-163-0017) is located at 11100 110th Avenue (Davenport). It was established in April of 1992 and remains a part of the State/Local Ambient Monitoring System (SLAMS). Figure 1-2 depicts the monitor’s location, as well as the location of the two major PM10 sources in the area, Linwood Mining & Minerals Corporation and Continental Cement. Linwood Mining & Minerals Corporation (facility ID 82-01-015) is located at 401 East Front Street, Davenport. Linwood operates underground mining operations and quarrying processes and produces calcium carbonate (CaCO3), lime products, and aggregates. Stone is extracted from the mine and then transported to a primary crusher. Following the initial crushing process, the material is then sized and screened. The materials are then either stockpiled or transported to other parts of the plant for further processing. Lime and related products are produced using four rotary kilns located in the portion of the plant south of Highway 22. The underground mining operation and related quarrying activities are situated north of Highway 22. Continental Cement (facility ID 82-04-005), formerly Lafarge Corporation, is located at 301 East Front Street, Buffalo. Continental Cement is a Portland cement manufacturing facility. Its limestone quarrying operations are located north of Highway 22 in an open-pit mine. The kiln and associated Portland cement production operations are located in the portion of the plant south of Highway 22.

https://www.federalregister.gov/d/99-6498

https://www.legis.iowa.gov/law/administrativeRules/agencies

https://www.iowadatacenter.org/city-quick

https://www.iowadatacenter.org/city-quick

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Figure 1-1. Geographical overview of Iowa highlighting Buffalo’s location in Scott County in eastern Iowa.

Figure 1-2. Locations of the monitor, Linwood Mining & Minerals, and Continental Cement (formerly Lafarge).

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1.3. PM10 24-Hour Ambient Air Data Summary Table 1-1 shows the three highest 24-hour average PM10 concentrations from each year between 1993 and 2019 from the Buffalo monitoring site (AQS ID 19-163-0017).1 The site has recorded eleven PM10 exceedances since it began operation, with the most recent exceedance occurring in 2006. An exceedance of the PM10 NAAQS occurs when a site records a 24-hour average concentration of 155 µg/m3 or more.2

Table 1-1. Buffalo (site ID 19-163-0017) 24-hour average PM10 ambient monitoring data overview. Exceedance values (concentrations greater than or equal to 155 µg/m3) are shaded.

Year 1st 24-Hour

Maximum (µg/m3) 2nd 24-Hour

Maximum (µg/m3) 3rd 24-Hour

Maximum (µg/m3)

1993 119 106 92

1994 229 146 124

1995 162 156 140

1996 202 152 149

1997 144 143 139

1998 129 120 118

1999 182 176 143

2000 192 120 109

2001 146 145 114

2002 169 142 134

2003 144 137 134

2004 170 133 131

2005 164 151 150

2006 161 122 119

2007 113 107 106

2008 116 101 99

2009 119 116 107

2010 132 129 126

2011 149 134 124

2012 141 137 129

2013 141 130 124

2014 145 132 117

2015 153 114 111

2016 120 110 107

2017 110 105 104

2018 123 117 117

2019 127 113 105

A PM10 NAAQS violation at a site occurs when the three-year average of the annual number of expected exceedances at the site is greater than 1.0. To compute the number of expected exceedances in a calendar quarter, one divides the number of exceedances in the quarter by the data capture rate for the quarter (the data capture rate is the number of days with monitoring data divided by the number of days in the quarter). The annual number of expected exceedances is the sum of the quarterly exceedances for the calendar year. The three-year average of the annual number of expected exceedances is then calculated to establish NAAQS compliance for the site for that three-year period.

1 Note that the data record summarized in Table 1-1 does not include PM10 BAM data gathered at the site, which is used for air quality index (AQI) reporting only. 2 See 40 CFR 50 Appendix K.

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At the Buffalo site, the expected exceedances in 1993, 1994, and 1995 were 0.0, 6.1, and 8.5, respectively, resulting in a three-year average of 4.8, a violation of the PM10 NAAQS. Although the site recorded a NAAQS violation, EPA chose to allow the state to work with the sources in the area to establish NAAQS compliance, rather than designating the area to be in nonattainment with the PM10 NAAQS. As part of that process, the state submitted a SIP revision to EPA that required emission reductions and other control measures at Linwood and Lafarge (Continental Cement).

1.4. SIP Revision Although the area is currently attaining the PM10 NAAQS, the provisions of the Buffalo SIP, as approved by EPA on March 18, 1999, (64 FR 13343) remain federally enforceable. Those enforceable provisions include the control measures and related conditions contained in the ACOs for both Linwood and Lafarge. This SIP revision updates Linwood’s control measures to account for changes in facility operations and places those enforceable requirements in 35 air construction permits, eliminating the need for ACO 98-AQ-07. The air construction permits are legally enforceable and contain source-specific emission limits, operating conditions, monitoring and record keeping requirements, and other provisions necessary to continue attaining the PM10 NAAQS in the Buffalo area. No revisions are requested for Lafarge (Continental Cement) because modification of their ACO (98-AQ-08) is not necessary at this time.

https://www.federalregister.gov/d/99-6498

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2. Linwood’s Revised Control Measures In 1998, the DNR and Linwood entered into ACO 98-AQ-07 for purposes of resolving the PM10 NAAQS violations monitored in Buffalo. The ACO was signed by the DNR on February 13, 1998, and was included in Appendix D of the Buffalo SIP submitted to EPA on October 1, 1998. Examples of the control measures specified in the ACO include, but are not limited to, a fugitive dust control program for Linwood’s haul roads, redesigned traffic patterns, paving a plant exit road, restricting storage pile sizes and locations, modifying dust collectors to meet new emission limits, increasing stack heights, and converting horizontal discharges to unobstructed vertical releases. On March 4, 2002, the DNR and Linwood entered into a new ACO, 2002-AQ-10, which superseded and replaced ACO 98-AQ-07. However, ACO 2002-AQ-10 was not submitted to EPA for inclusion in the SIP. Therefore, ACO 98-AQ-07 remains federally enforceable, as approved under 40 CFR 52 Subpart Q. The more recent ACO, 2002-AQ-10, is no longer needed because Linwood’s control measures were updated to account for facility changes and those changes were made enforceable in air construction permits. The DNR rescinded ACO 2002-AQ-10 on April 19, 2019. Through this revision, the state will request that EPA remove Linwood’s ACO, 98-AQ-07, from the SIP and include the 35 air construction permits listed in Table 2-1. This action will help ensure that Linwood’s SIP-approved control measures align with current requirements as permitted by the state. Linwood’s control measures remain similar in type to those originally established in their previous ACOs and include revised emission limits for point sources, updated source-specific fugitive dust plans (SSFDP) for the haul roads (paved and unpaved) and the storage piles, use of windscreens and water suppression, modified operating conditions, and other restrictions necessary to continue attaining the PM10 NAAQS in the Buffalo area. The air construction permits, which are provided in Appendix A, also include ongoing compliance testing, monitoring, recordkeeping, and reporting procedures.

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Table 2-1. Equipment and control measure summary listing the associated air construction permits that replace Linwood’s previous ACOs.

Emission Unit Description Emission Point Control Measure Summary* Permit Number Date Issued

Dolo Processing System LP-16 Baghouse 11-A-335-S3 3/14/2019

Dolo – Storage and Truck Loadout LP-17 Baghouse 11-A-336-S3 3/14/2019

Haul Roads - Paved HR-P Sweeping and Water Flushing 18-A-109-S1 3/14/2019

Haul Roads - Unpaved HR-U Dust Suppressant 18-A-108-S1 3/14/2019

Ingredients Bin LP-12 Baghouse 97-A-1084-S4 3/14/2019

Kiln #1, 2 Rockbox & Conveyor LP-38 n/a 17-A-492-S1 7/2/2019

Kiln #3 Rockbox & Conveyor LP-36 n/a 17-A-491 3/13/2018

Kilns - Four (4) Rotary Lime Kilns LP-4 Cyclones and Limestone Mining Tunnel 73-A-219-S8 2/26/2020

Kilns - Four (4) Rotary Lime Kilns LP-9 Multiclones and Baghouse 91-A-324-S6 3/14/2019

Kilns Solid Fuel Tank & Conveyor LP-24 n/a 17-A-494-S1 3/14/2019

Lime Kiln Dust Tank and Loadout LP-7 Baghouse 88-A-220-S5 3/13/2018

Loadout - #4 Lime Truck Loadout System LP-8 Baghouse 88-A-221-S10 7/2/2019

Loadout - Barge Loadout East BL01 Windscreen and Water Suppression 02-A-168-S2 3/14/2019

Loadout - Barge Loadout West BL02 Windscreen and Water Suppression 02-A-169-S2 3/14/2019

Loadout - Calcium Truck & Rail Loadout CC-3 Baghouse 88-A-218-S6 3/13/2018

Loadout - Lime Rail Loadout System LP-13 Baghouse 02-A-028-S5 3/13/2018

Loadout #6 Bins CC-16 n/a 17-A-488-S1 5/7/2020

New Mill CC-2 Baghouse 86-A-049-S9 3/14/2019

New Mill Dryer CC-5 Baghouse 98-A-846-S2 7/14/2006

Old Mill CC-1 Baghouse 71-A-084-S13 8/27/2020

Piles 1 and 11 Pile 1 and 11 Source-Specific Fugitive Dust Plan (SSFDP) 18-A-114 9/6/2018

Piles 2, 3, 5, 10, 12, 13, 15, 16, 17, and 18 Storage Piles SSFDP 18-A-110 9/6/2018

Pile 8 Pile 8 SSFDP 18-A-115 9/6/2018

Pile 14 Pile 14 SSFDP 18-A-116 9/6/2018

Pile A (Includes Piles B, Barge, E, H) Pile A SSFDP; Windscreens and Water Suppression 18-A-117-S1 3/14/2019

Quarry 1 Equipment and Pile 6 Q-1 SSFDP; Water Suppression 11-A-337-S1 9/6/2018

Q-11C Equipment and Pile I Q11C SSFDP; Building Enclosure & Windscreen 18-A-111-S1 3/14/2019

Q-12 Equipment (Aggregate Processing) Q-12 n/a 20-A-156 9/3/2020

Q-2LP Equipment and Pile 7 Q-2LP SSFDP 18-A-112-S1 3/14/2019

Q-2TP Equipment and Pile 4 Q-2TP SSFDP; Water Suppression 18-A-113 9/6/2018

Q-3P Equipment and Pile 9 Q-3P SSFDP; Building Enclosure 02-A-017-S3 3/14/2019

Scale 3 Ingredient Bins CC-17 Baghouse 19-A-178-S2 8/27/2020

Solid Fuel Crusher & Burner LP-39 Baghouse 17-A-505-S2 7/2/2019

Solid Fuel Hopper LP-20 n/a 17-A-495-S1 3/14/2019

Solid Fuel Pile Solid Fuel-01 Building Enclosure 17-A-504-S1 3/14/2019 *An “n/a” generally means no physical control device or SSFDP was necessary. Material throughput restrictions, process constraints, or other limits still apply.

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3. Modeling Demonstration Before finalizing Linwood’s revised control measures, the DNR conducted a dispersion modeling analysis to demonstrate that the maximum allowable emission rates from all the sources at both Linwood and Continental Cement, in combination with the background concentration, would not produce a predicted PM10 NAAQS violation at any location in ambient air in the Buffalo area. That analysis is described below.

3.1. Air Quality Model Selection The EPA recommended American Meteorological Society (AMS)/EPA Regulatory Model (AERMOD) was used to perform the analysis. The most current version (19191) of AERMOD available at the time of the analysis was used with regulatory default options, as recommended in the EPA Guideline on Air Quality Models. The following supporting pre‐processing programs for AERMOD were also used:

• BPIP‐Prime (version 04274)

• AERMET (version 18081)

• AERMAP (version 18081) AERMOD is a steady‐state plume model that simulates air dispersion based on planetary boundary layer turbulence structure and scaling concepts, including treatment of both surface and elevated sources, and both simple and complex terrain. This model is recommended for short‐range (<50 kilometers [km]) dispersion from the source. The model incorporates the Plume Rise Model Enhancement (PRIME) algorithm for modeling building downwash. AERMOD is designed to accept input data prepared by two specific pre‐processor programs, AERMET and AERMAP. AERMOD was run with the following options:

• Regulatory default options

• Direction‐specific building downwash characterized by BPIP‐PRIME

• Actual receptor elevations and hill height scales obtained from AERMAP

• PM10 pollutant keyword

3.2. Receptor Grid/Spacing/Terrain Elevations Receptors were sited along and outside of the fence line boundaries of Linwood and Continental Cement. Figure 3-1 shows the receptor grid for the modeling analysis. Receptors were spaced at 50 meters both along the facility fence lines and throughout the grid. Two additional grids (not shown) were also created. In one grid, receptors were added on Linwood’s property. In the other grid, receptors were added on Continental Cement’s property. These grids were then used to evaluate the impacts of the emissions from one facility on the other facility’s property. Interpolated terrain elevations were input to the model using United States Geological Survey (USGS) National Elevation Dataset (NED) data for Scott County in North American Datum 1983 (NAD83). All receptors were assigned a terrain height and hill height using the terrain preprocessor AERMAP.

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Figure 3-1. Dispersion modeling receptor grid surrounding Linwood and Continental Cement.

3.3. Meteorological Data Hourly meteorological data for the dispersion modeling analysis was preprocessed with the AERMET program by the Iowa DNR. The surface data was collected from the Moline, IL (KMLI) station with upper air data from the Davenport NWS station (KDVN) for calendar years 2010 through 2014. Based on the results from a representivity study conducted by the DNR,3 these meteorological data are considered representative of the conditions near Buffalo. Figure 3-2 shows the 2010-2014 five‐year wind rose for the KMLI station.

3 The representivity analysis is documented in the DNR’s “2010 – 2014 AERMOD Meteorological Data Technical Support Document,” dated October 15, 2015.

http://www.iowadnr.gov/portals/idnr/uploads/air/dispmodel/tsd_2010_2014_aermod_met_data.pdf

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Figure 3-2. Moline, IL (KMLI) five-year wind rose (2010-2014).

3.4. Downwash All building downwash analyses were conducted using version 04274 of EPA’s Building Profile Input Program with Plume Rise Enhancements (BPIP-Prime).

3.5. Source Inventory Linwood and Continental Cement are the only major PM10 sources in the Buffalo area. Each PM10 source at each facility was modeled at its current maximum permitted allowable emission rate. For point sources, actual stack parameters were used. All actual stack heights were below the applicable Good Engineering Practice (GEP) height. Emissions not vented through a stack, such as from quarrying activities, haul roads, storage piles, and some loadout activities, were modeled as either an area or a volume source. Table 3-1 lists Linwood’s SIP-affected PM10 emission units and provides the associated modeled source ID, emissions source type, and the air construction permit(s) associated with each source. Multiple permits are listed for the RIVER_[A1-A3] and BLUFF_PILE sources because they represent the combined emissions from various quarrying, haul road, and storage pile activities.

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Table 3-1. Modeled source characterizations and associated permits for Linwood’s PM10 SIP sources.

Emission Unit Description Model Source ID Source Type Associated Permit(s)

Dolo - Storage and Truck Loadout LP17 Point 11-A-336-S3

Dolo Processing System LP16 Point 11-A-335-S3

Ingredients Bin LP12 Point 97-A-1084-S4

Kiln #1, 2 Rockbox & Conveyor LP38 Point 17-A-492-S1

Kiln #3 Rockbox & Conveyor LP36 Point 17-A-491

Kilns - Four (4) Rotary Lime Kilns LP4 Point 73-A-219-S8

Kilns - Four (4) Rotary Lime Kilns LP9 Point 91-A-324-S6

Kilns Solid Fuel Tank & Conveyor LP24 Point 17-A-494-S1

Lime Kiln Dust Tank and Loadout LP7 Point 88-A-220-S5

Loadout - #4 Lime Truck Loadout System LP8 Point 88-A-221-S10

Loadout - Barge Loadout East BL01 Volume 02-A-168-S2

Loadout - Barge Loadout West BL02 Volume 02-A-169-S2

Loadout - Calcium Truck & Rail Loadout CC3 Point 88-A-218-S6

Loadout - Lime Rail Loadout System LP13 Point 02-A-028-S5

Loadout #6 Bins CC16 Point 17-A-488-S1

New Mill CC2 Point 86-A-049-S9

New Mill Dryer CC5 Point 98-A-846-S2

Old Mill CC1 Point 71-A-084-S13

Q11C Equipment Q11C Volume 18-A-111-S1

Scale 3 Ingredient Bins CC17 Point 19-A-178-S2

Solid Fuel Crusher & Burner LP39 Point 17-A-505-S2

Solid Fuel Hopper LP20 Volume 17-A-495-S1

Solid Fuel Pile FUEL01 Volume 17-A-504-S1

Q-12 Equipment (Aggregate Processing) CC_Bluff_R1 Area 20-A-156

Haul Roads and Piles RIVER_[A1-A3]* Area (polygon)

18-A-108-S1 18-A-109-S1 18-A-111-S1 18-A-117-S1

Quarry, Haul Roads, and Piles BLUFF_PILE** Area (polygon)

02-A-017-S3 11-A-337-S1 18-A-108-S1 18-A-109-S1 18-A-110 18-A-112-S1 18-A-113 18-A-114 18-A-115 18-A-116

*The river side source “RIVER_[A1-A3]” includes haul road segments4 1-25, Piles B, E, H, I, and the Barge Pile. **The bluff side source “BLUFF_PILE” includes the quarry emissions,5 haul road segments 41-50, 59-61, 65-75 and 82-86, and Piles 1, 2, 3, 4, 5, 8, 10, 11, 12, 13, 14, 15, 16, 17, & 18.

4 The location and type (unpaved or paved) of the various haul road segments are indicated in the associated construction permits (18-A-108-S1 and 18-A-109-S1). 5 The quarry emissions include Piles 6, 7, and 9, the Q2LP, Q3P, and Q1P equipment, all of haul road segment 51, all of haul road segment 52, a portion of haul road segment 53, all of haul road segment 54, all of haul road segment 55, all of haul road segment 56, all of haul road segment 57, and all of haul road segment 58.

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3.6. Background Concentration To account for 24-hour average PM10 contributions from sources not explicitly modeled,6 the DNR used a 2012-2014 PM10 background concentration of 44 μg/m3. This value was calculated by averaging the three-year averages of the annual second maximum 24-hour averaged PM10 concentrations for the Davenport PM10 monitoring sites, as provided in Table 3-2. Available monitoring sites included the Jefferson School site (ID 19-163-0015) and the Adams School site (ID 19-163-0018). Additionally, the Blackhawk Foundry7 site (ID 19-163-0019) was reestablished at the nearby Hayes School site (ID 19-163-0020) beginning in 2014, providing a third dataset encompassing the 2012-2014 time frame. These sites are located approximately 7 to 12 km northeast of Linwood, as indicated in Figure 3-3, and are the appropriate choice for developing a representative background concentration due to their proximity. No other PM10 monitoring sites provides a more suitable selection.

Table 3-2. The 2012-2014 annual second maximum 24-hour averaged PM10 ambient concentrations (µg/m3).

Site Name Site ID 2012 2013 2014 3-Year Average

Jefferson School 19-163-0015 47 44 41 44

Adams School 19-163-0018 49 38 39 42

Blackhawk Foundry 19-163-0019 52 43 47.33333

Hayes School 19-163-0020 47

Average (rounded) 44

Figure 3-3. Depiction of the monitoring sites in Davenport used to construct the background concentration.

6 Other types of sources that may emit PM10 in the area but are not explicitly modeled include minor point sources, nonpoint (area) sources, and mobile sources (both on-road and off-road). 7 At that time the Blackhawk Foundry monitoring site was no longer source-oriented because the Blackhawk Foundry facility had closed in 2010. Most of the facility’s structures were later dismantled.

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3.7. Results The modeling analysis incorporated four operating scenarios for Linwood and two operating scenarios for Continental Cement, requiring that eight scenarios be modeled to ensure that each provided for continued attainment of the PM10 NAAQS. The scenarios vary depending upon which combination of stacks, loadout options, and fuels are in use. The emissions from Linwood’s kilns, subject to specific restrictions, may exit through either stack LP-4 or stack LP-9,8 and Linwood’s loadout options include either using or not using the East and West Barge loadout equipment. Continental Cement may burn either conventional fuel or alternative fuel in its kiln. The AERMOD model results for the eight scenarios are summarized in Table 3-3. The PM10 24-hour modeled design value is the highest sixth highest predicted value from across the five-year period modeled. The PM10 background concentration of 44 µg/m3 was then added to the model design value for comparison to the NAAQS. Among all

scenarios, the “LP-9, Barge Loading, Conventional Fuel” scenario produced the largest total concentration of 147 g/m3. This modeling analysis demonstrates that all eight scenarios meet the 24-hour PM10 NAAQS. Additionally, the DNR modeled the emissions from just Linwood with receptors added to Continental Cement’s property, and vice versa. The total predicted concentrations from those analyses were below the results listed in Table 3-3. This analysis demonstrates that the revised control measures developed for Linwood are protective of the current PM10 NAAQS and supports the requested SIP revision to replace Linwood’s ACO, 98-AQ-07, with the 35 air construction permits listed in Table 2-1.

Table 3-3. Cumulative modeled ambient air impact analysis for PM10 in the Buffalo area.

Scenario Model

Design Value

(g/m3)

Background Concentration

(g/m3)

Total Concentration

(g/m3)

Meets 150

g/m3 PM10 NAAQS

LP-4, Barge Loading, Conventional Fuel 102.09

44

146.09 Yes

LP-4, No Barge Loading, Conventional Fuel 84.50 128.50 Yes

LP-4, Barge Loading, Alternative Fuel 101.93 145.93 Yes

LP-4, No Barge Loading, Alternative Fuel 84.50 128.50 Yes

LP-9, Barge Loading, Conventional Fuel 103.00 147.00 Yes

LP-9, No Barge Loading, Conventional Fuel 84.58 128.58 Yes

LP-9, Barge Loading, Alternative Fuel 102.96 146.96 Yes

LP-9, No Barge Loading, Alternative Fuel 83.72 127.72 Yes

8 The LP-9 kiln baghouse system is a backup system to the LP-4 mine vent system. When LP-4 is in operation, LP-9 emissions equal zero, and vice versa.

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4. Administrative Materials The submittal of this SIP revision complies with the procedural elements of Subpart F of 40 CFR 51 and the applicable criteria in Appendix V of 40 CFR 51, as discussed below and in Chapter 5.

4.1. Legal Authority The DNR is the regulatory agency with primary responsibility for outdoor air quality permitting and compliance activities in the State of Iowa. The DNR’s authority is set forth in chapter 455B of the Iowa Code and implemented through 567 IAC Chapters 10 and 20-35, and 561 IAC Chapters 2 and 7. The DNR’s permitting and compliance programs and associated rules have previously been approved by EPA as part of Iowa’s SIP. The DNR has the necessary legal authority under state statute to adopt and implement this plan. Iowa Code section 455B.133(3) provides that the Iowa Environmental Protection Commission shall “[a]dopt, amend, or repeal ambient air quality standards for the atmosphere of this state on the basis of providing air quality necessary to protect the public health and welfare.” The federal NAAQS for PM10 are adopted by reference at 567 IAC 28. Iowa Code section 455B.133(4) provides that the commission shall “[a]dopt, amend, or repeal emission limitations or standards relating to the maximum quantities of air contaminants that may be emitted from any air contaminant source.” Iowa Code section 455B.134(9) states that the duties of the director include issuing “orders consistent with rules to cause the abatement or control of air pollution, or to secure compliance with permit conditions.” In combination with the DNR’s existing legal authority and associated administrative regulations, this SIP revision is adequate to provide for continued attainment of the PM10 NAAQS in the Buffalo area.

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5. Public Participation Proof of publication, public hearing certification, and response to comments will be addressed after the close of the public comment period.

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Appendix A. Linwood’s Air Construction Permits

Air Quality Construction Permit

Permit Number: 11-A-335-S3

Plant Number: 82-01-015

Company: Linwood Mining & Minerals Corporation

Contact Person: Responsible Party: Darin Osland Environmental Manager

563-324-1931 [email protected]

40 I E Front Street Davenport, IA 52761

Same

Permitted Equipment

Emission Point ID: LP-16

Emission Unit(s) and Control Eqnipment:

EUID Description Maximnm Rated Canacitv

Multiple* Dolo Processing System 90,000 lbs per hour of

*See Emission Unit list in Condition 3

Equipment Location: 401 E Front Street Davenpmt, IA 52761

dolomite

Control Equipment Description and ID

Baghouse (CE LP-16)

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, and federal law.

Project Project Description Number

18-366 Increase PMI0 permit limit

[PSP]

Stack Issuance Testine Date

No 03/14/19

,

Under the Direction of the Director of the Depaitment of Natural Resources

ICPFPl82010151103142019il8366111A335S31

Linwood Mining & Minerals Corp. Dolo Processing System (EP LP-16) Page 2 of 7 Davenport, Iowa 11-A-335-S3

PERMIT CONDITIONS

1. Emission Limits The owner or operator is required to report all emissions as required by law, regardless of whether a specific emission limit has been established in this permit. The following emission limits shall not be exceeded:

Pollutant lb/hr1 tons/yr2 Other Limits Reference/Basis Particulate Matter (PM) – State 0.82 5 NA 0.1 gr/dscf 567 IAC 23.3(2)”a” PM10 0.82 6 NA NA NAAQS PM2.5 NA NA NA NA Opacity NA NA 40%3, 4 567 IAC 23.3(2)“d”

1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 The emission limit is based on a six (6) minute average. 4 An exceedance of the indicator opacity of 10% will require the owner or operator to promptly investigate the emission unit and make

corrections to operations or equipment associated with the exceedance. If exceedances continue after the corrections, the Department may require additional proof to demonstrate compliance (e.g., stack testing).

5 PM emissions limit was added to restrict PTE. 6 The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved

into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343).

2. Compliance Demonstration(s)

Compliance Demonstration Table

Pollutant Compliance Methodology Frequency Test Run

Time Test Method

PM – State None NA 1 hour 40 CFR 60, Appendix A, Method 5 40 CFR 51 Appendix M Method 202

PM10 None NA 1 hour 40 CFR 51, Appendix M, 201A with 202 PM2.5 None NA 1 hour 40 CFR 51, Appendix M, 201A with 202 Opacity None NA 1 hour 40 CFR 60, Appendix A, Method 9

If an initial stack test is specified in the “Compliance Demonstration Table,” the owner or the owner’s authorized agent shall demonstrate compliance with the emission limitations contained in Condition 1 within the applicable time period specified below:

• Within sixty (60) days after achieving the maximum production rate and no later than one hundred eighty (180) days after the initial startup date of the proposed equipment for the addition of new equipment or the physical modification of existing equipment or control equipment.

• Within ninety (90) days of the issuance of this permit if there is no physical modification to any emission units or control equipment.

If any additional stack testing beyond an initial test (i.e. quarterly, semi-annual, annual, etc.) is required in “Compliance Demonstration Table,” the owner or the owner’s authorized agent shall demonstrate compliance with the emission limitations contained in Condition 1 as specified in the “Compliance Demonstration Table.” See Conditions 12.A.(4) and 12.B.(5) for notification and reporting requirements. If stack testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the “Compliance Demonstration Table” unless another testing methodology is approved by the Department prior to testing. Each emissions compliance test must be approved by the Department. Unless otherwise specified by the Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs shall apply for compliance, unless otherwise indicated by the Department.

Linwood Mining & Minerals Corp. Dolo Processing System (EP LP-16) Page 3 of 7 Davenport, Iowa 11-A-335-S3 2. Compliance Demonstration(s) (Continued) Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.

3. Emission Point Characteristics This emission point shall conform to the specifications listed below:

Parameter Value Stack Height (feet from the ground) 60 Discharge Style Vertical Unobstructed Stack Outlet Dimensions (inches) 24 Exhaust Temperature (oF) 90 Exhaust Flowrate (scfm) 9,000

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process and ambient conditions. If it is determined that any of the emission point characteristics above are different than the values stated, the owner or operator shall submit a request either by electronic mail or written correspondence to the Department within thirty (30) days of the discovery to determine if a permit amendment is required, or submit a permit application requesting to amend the permit. The following emission units exhaust through this emission point:

Emission Unit Maximum Capacity Control Equipment

Dolo Process Loading Spout (LP-6) 40 Tons per hour of lime

Baghouse (CE LP-16)

Dolo Process Bins (LP-16B) (5 bins combined) 400 Tons of lime Dolo Process Conveying (LP-16C) (15

conveyors/screws/elevators) 45 Tons per hour of lime

Dolo Process Screener and Crusher (LP-16S) (screener, Briquetter and crusher) 45 Tons per hour of lime

Linwood Mining & Minerals Corp. Dolo Processing System (EP LP-16) Page 4 of 7 Davenport, Iowa 11-A-335-S3 4. Federal Standards

A. New Source Performance Standards (NSPS): This emission unit is not subject to any NSPS subparts at this time as there are no applicable subparts for its source category.

NOTE: The absence of the inclusion of any NSPS requirements as part of this permit does not relieve the owner or operator from any obligation to comply with all applicable NSPS conditions.

B. National Emission Standards for Hazardous Air Pollutants (NESHAP): At this time, the plant is an area source for hazardous air pollutants, and so is not currently subject to the requirements of Subpart AAAAA, National Emission Standards for Hazardous Air Pollutants for Lime Manufacturing Plants.

NOTE: The absence of the inclusion of any NESHAP requirements as part of this permit does not relieve the owner or operator from any obligation to comply with all applicable NESHAP conditions.

5. Operating Requirements with Associated Monitoring and Recordkeeping Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an orderly manner. The operating requirements and associated recordkeeping for this permit shall be:

A. The maximum production rate of dolo processing system shall not exceed 90,000 pounds per hour averaged over 6-hr period.

i. For each hour, the owner or operator shall maintain records of the amount of product loaded, using the belt scale, in pounds.

ii. The owner or operator shall maintain records of the 6-hour average of product loaded, using the belt scale, in pounds.

B. The owner or operator shall begin monitoring the differential pressure drop across the baghouse, as specified in condition 5.C. by May 1, 2018.

i. The owner or operator shall maintain a record of the commencement date of the differential pressure drop monitoring of the control equipment.

C. The differential pressure drop across Baghouse (CE LP-16) shall be maintained between 2 and 10 inches of water column, based on 1-hr block average.

i. The owner or operator shall properly operate and maintain equipment to monitor differential pressure drop across Baghouse (CE LP-16). The monitoring devices and any recorders shall be installed, calibrated, operated and maintained in accordance with the manufacturer’s recommendations, instructions and operating manuals or per written facility specific operation and maintenance plan.

ii. The owner or operator shall collect and record the pressure drop across Baghouse (CE LP-16), in inches of water, at a minimum of once every 2 minutes. Calculate and record the hourly average for all readings for each 1-hour block. If the average hourly pressure drop across Baghouse (CE LP-16) falls outside the range specified in Condition 5.C., the owner or operator shall investigate Baghouse (CE LP-16) and make corrections to the baghouse. The owner or operator shall maintain a record of all corrective actions taken. This requirement shall not apply on the days that Baghouse (CE LP-16) are not in operation.

D. The owner or operator shall develop an operating and maintenance plan for the Baghouse (CE LP-16), including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance.

i. The owner or operator shall maintain a record of all inspections and maintenance and any action resulting from the inspection and maintenance of the Baghouse (CE LP-16).

E. The owner or operator shall rescind permit #88-A-219-S4 (LP 6) within 30 days of issuance of this permit.

Linwood Mining & Minerals Corp. Dolo Processing System (EP LP-16) Page 5 of 7 Davenport, Iowa 11-A-335-S3 6. Continuous Emission Monitoring Systems (CEMS) Continuous emission monitoring is not required by this permit at this time.

7. Department Review This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply. This permit is issued based on information submitted by the applicant. Any misinformation, false statements or misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. No review has been undertaken on the engineering aspects of the equipment or control equipment other than the potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, installation, maintenance or operation of the proposed equipment.

8. Owner and Operator Responsibility This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point as described in this permit and in the application for this permit. The permit holder, owner, and operator of the facility shall assure that the installation of the equipment listed in this permit conforms to the design in the application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this emission unit(s), control equipment, or emission point without the required amended permit. Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the provisions of this permit and all other applicable requirements and that adequate operation and maintenance is provided to ensure that no condition of air pollution is created.

9. Transferability Unless the equipment is portable, this permit is not transferable from one location to another or from one piece of equipment to another. See Condition 12.A.(2) for notification requirements for relocating portable equipment (567 IAC 22.3(3)“f”).

10. Construction

A. General Requirements: It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as submitted. In permit amendments, all provisions of the original permit remain in full force and effect unless they are specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or operator shall seek a permit amendment in order to revert back to the most recent previous version of the permit. The previous, unchanged permit provisions are included in the amendment for your convenience only and are unappealable. This permit or amendment shall become void if any one of the following conditions occurs: (1) The construction or implementation of the proposed project, as it affects the emission point permitted herein, is

not initiated within eighteen (18) months after the permit issuance date; or (2) The construction or implementation of the proposed project, as it affects the emission point permitted herein, is

not completed within thirty-six (36) months after the permit issuance date; or (3) The construction or implementation of the proposed project, as it affects the emission point permitted herein, is

not completed within a time period specified elsewhere in this permit.

B. Changes to Plans and Specifications: The owner or operator shall amend this permit or amendment prior to startup of the equipment if:


(1) Any changes are made to the final plans and specifications submitted for the proposed project; or (2) This permit becomes void. Changes to the final plans and specification shall include changes to plans and specifications for permitted equipment and control equipment and the specified operation thereof.

C. Amended Permits: The owner or operator may continue to act under the provisions of the previous permit for the affected emission unit(s) and emission point, together with any previous amendment to the permit, until one of the following conditions occurs: (1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and emission

point permitted herein; or (2) This current amendment becomes void.

11. Excess Emissions Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good practice for minimizing emissions except when another regulation applicable to the unit or process provides otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be limited to one (1) six-minute period per one (1) hour period. An incident of excess emissions other than the above is a violation and may be subject to criminal penalties according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within a reasonable period of time, as specified in 567 IAC 24.1. An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident [See Permit Condition 12.B.(1)]. A written report of an incident of excess emissions shall be submitted as a follow-up to all required initial reports within seven (7) days of the onset of the upset condition [See Permit Condition 12.B.(2)].

12. Notification, Reporting, and Recordkeeping

A. The owner or operator shall furnish the Department the following written notifications: (1) Per 567 IAC 22.3(3)“b”:

(a) The date construction, installation, or alteration is initiated postmarked within thirty (30) days following initiation of construction, installation, or alteration.

(b) The actual date of startup, postmarked within fifteen (15) days following the start of operation. (2) Per 567 IAC 22.3(3)“f,” when portable equipment for which a permit has been issued is to be transferred from

one location to another, the Department shall be notified: (a) At least fourteen (14) days before equipment relocation if the equipment will be located in a nonattainment

area for the National Ambient Air Quality Standards (NAAQS) or a maintenance area for the NAAQS. (b) At least seven (7) days before equipment relocation.

(3) Per 567 IAC 22.3(8), a new owner shall notify the Department of the transfer of equipment ownership within thirty (30) days of the occurrence. The notification shall include the following information: • The date of ownership change; the name, address, and telephone number of the responsible official, the

contact person, and the owner of the equipment both before and after the ownership change; and the construction permit number(s) of the equipment changing ownership.

(4) Unless specified per a federal regulation, the owner or the owner’s authorized agent shall notify the Department in writing not less than thirty (30) days before a required test or performance evaluation of a continuous emission monitor [567 IAC 25.1(7)]. The notification shall include: • The time; the place; the name of the person who will conduct the tests; and other information as required by

the Department. If the owner or operator does not provide timely notice to the Department, the Department shall not consider the test results or performance evaluation results to be a valid demonstration of compliance with the applicable rules or permit conditions. Upon written request, the Department may allow a notification period of less than thirty (30) days.


B. The owner or operator shall furnish the Department with the following reports:

(1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported within eight (8) hours or at the start of the first working day following the onset of the incident. The report may be made by electronic mail, in person or by telephone.

(2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2 shall be submitted as a follow-up to all required initial reports to the Department within seven (7) days of the onset of the upset condition.

(3) Operation of this emission unit(s) or control equipment outside of those operating parameters specified in Permit Condition 5 in accordance to the schedule set forth in 567 IAC 24.1.

(4) Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring system or systems shall provide quarterly reports to the Director, no later than thirty (30) calendar days following the end of the calendar quarter, on forms provided by the Director.

(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, whether successful or not, postmarked not later than six (6) weeks after the completion of the test period unless other regulations provide for other notification requirements. In that case, the more stringent reporting requirement shall be met.

C. All data, records, reports, documentation, construction plans, and calculations required under this permit shall be

available at the plant during normal business hours for inspection and copying by federal, state, or local air pollution regulatory agencies and their authorized representatives, for a minimum of two (2) years from the date of recording unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)

D. Information regarding this permit should be sent to the attention of the following individuals based on the type of

information being submitted: change in ownership (Air Quality Bureau Records Center), permit correspondence (Construction Permit Supervisor), stack testing correspondence (Stack Test Coordinator), and reports and notifications (Compliance Unit Supervisor and DNR Field Office). The addresses are:

Air Quality Bureau Iowa Department of Natural Resources 502 E. 9th St. Des Moines, IA 50319 Telephone: (515) 725-8200 Fax: (515) 725-9501

Field Office 6 1023 West Madison Washington, IA 52353 Telephone: (319) 653-2135

Fax: (319) 653-2856

13. Appeal Rights All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in the amendment for your convenience only and are unappealable.

14. Permit History

Permit No. Project No. Description Date Stack

Testing 11-A-335 10-602 Permit existing units from 78-A-321-S4 and new units 06/16/11 Yes

11-A-335-S1 12-226 Decrease permitted flow rate; decrease production rate 07/30/14 No 11-A-335-S2 17-118 Amend capacity, add emission units, reduce PM10 emission rate 03/13/18 Yes

END OF PERMIT





Contact Person: Darin Osland Environmental Manager


401 E Front Street Davenpmi, IA 52761

Responsible Party: Same

Permitted Equipment


Emission Unit(s) and Control Equipment:

EUID Description

Multiple* Dolo - storage and truck loadout


Equipment Location: 401 E Front Street Davenpmi, IA 52761

Maximum Rated Capacity

100 tons of dolomite per hour

Control Equipment Descrintion and ID

Baghouse (CE LP-17)


Project Number

18-366

[PSP]

Project Description Stack Issuance Testine: Date

Remove PM test requirement from the permit; PM 10 already done No 03/14/19 in 2018

Under the Direction of the Director of the Department of Natural Resources

:crFr:s20101s1:03142019: 1s366:11A336S3:

Linwood Mining & Minerals Corp. Dolo Storage and Truck Loadout (EP LP-17) Page 2 of 7 Davenport, Iowa 11-A-336-S3

PERMIT CONDITIONS


Pollutant lb/hr1 tons/yr2 Other Limits Reference/Basis Particulate Matter (PM) – State 1.0 5 NA 0.1 gr/dscf 567 IAC 23.3(2)”a” PM10 0.94 6 NA NA NA PM2.5 NA NA NA NA Opacity NA NA 40%3, 4 567 IAC 23.3(2)“d”








Time Test Method



If an initial stack test is specified in the “Compliance Demonstration Table,” the owner or the owner’s authorized agent shall demonstrate compliance with the emission limitations contained in Condition 1 within the applicable time period specified below:.



If any additional stack testing beyond an initial test (i.e. quarterly, semi-annual, annual, etc.) is required in “Compliance Demonstration Table,” the owner or the owner’s authorized agent shall demonstrate compliance with the emission limitations contained in Condition 1 as specified in the “Compliance Demonstration Table.” See Conditions 12.A.(4) and 12.B.(5) for notification and reporting requirements. If stack testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the “Compliance Demonstration Table” unless another testing methodology is approved by the Department prior to testing. Each emissions compliance test must be approved by the Department. Unless otherwise specified by the Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs shall apply for compliance, unless otherwise indicated by the Department. Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the

Linwood Mining & Minerals Corp. Dolo Storage and Truck Loadout (EP LP-17) Page 3 of 7 Davenport, Iowa 11-A-336-S3 owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.





Dolo Truck Loading Spout (LP-17) 100 tons per hour of dolomite

Baghouse (CE-17)

Dolo Loadout Conveyor #1 (LP-17-1) (Rail & Truck) 100 tons per hour of dolomite Dolo Loadout Conveyor #2 (LP-17-2) 100 tons per hour of dolomite

Bathtub Bins (5 total) (LP-17-4) 80 tons each bin C352 Dolo Belt to Loadout (EU LP-1Q) 50 tons per hour of dolomite C353 Dolo Drag Conveyor (EU LP-1R) 50 tons per hour of dolomite

I I

Linwood Mining & Minerals Corp. Dolo Storage and Truck Loadout (EP LP-17) Page 4 of 7 Davenport, Iowa 11-A-336-S3 4. Federal Standards


NOTE: The absence of the inclusion of any NSPS requirements as part of this permit does not relieve the owner or operator

from any obligation to comply with all applicable NSPS conditions.




A. The maximum amount of dolo loaded out using the dolo loadout system shall not exceed 100 tons per hour averaged over 6-hr period.

i. For each hour, the owner or operator shall maintain records of the amount of product loaded out in tons. ii. The owner or operator shall maintain records of the 6-hour average of product loaded out in tons.



C. The differential pressure drop across Baghouse (CE LP-17) shall be maintained between 2 and 10 inches of water column, based on 1-hr block average.





E. The owner or operator shall decommission loadout EP LP-17B (Bathtub) by May 1, 2018. i. The owner or operator shall maintain a record of the date when EP LP-17B was decommissioned from use.

6. Continuous Emission Monitoring Systems (CEMS) Continuous emission monitoring is not required by this permit at this time.

Linwood Mining & Minerals Corp. Dolo Storage and Truck Loadout (EP LP-17) Page 5 of 7 Davenport, Iowa 11-A-336-S3 7. Department Review This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply. This permit is issued based on information submitted by the applicant. Any misinformation, false statements or misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. No review has been undertaken on the engineering aspects of the equipment or control equipment other than the potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, installation, maintenance or operation of the proposed equipment.



10. Construction





B. Changes to Plans and Specifications: The owner or operator shall amend this permit or amendment prior to startup of the equipment if: (1) Any changes are made to the final plans and specifications submitted for the proposed project; or (2) This permit becomes void. Changes to the final plans and specification shall include changes to plans and specifications for permitted equipment and control equipment and the specified operation thereof.

















(2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2 shall be


submitted as a follow-up to all required initial reports to the Department within seven (7) days of the onset of the upset condition.










Fax: (319) 653-2856


14. Permit History


Testing 11-A-336 10-602 Permit existing units from 78-A-321-S4 and new units 06/16/11 Yes

11-A-336-S1 12-226 Increase permitted flow rate; decrease production rate 07/30/14 No 11-A-336-S2 17-118 Amend equipment list to add as-built units 03/13/18 Yes

END OF PERMIT







401 E Front Street Davenpmt, IA 52761


Permitted Equipment

Emission Point ID: HR-P


EUID Description Maximum Rated

Canacitv HR-P Paved Haul Roads* NA

*See Figure I - Haul Roads Map

Equipment Location: 40 I E Front Street Davenport, IA 52761

Control Measnre

Sweeping and Vv~ter flushing (CE Paved Haul Roads)

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with applicable provisions of the State Implementation Plan (SIP), and any other requirements oflocal, state, and federal law.

Project Project Description Stack Issuance

Number Testing Date 18-366 Modify PM10 permit limits due to change in silt loading No 03/14/19

/ Under the Direction of the Director of the Department of Natural Resources

[PSP] :crrr:s201o1s1:03142019: 1 sJ66: 1SA109s 1:

Linwood Mining & Minerals Corp. Paved Haul Roads (EP HR-P) Page 2 of 9 Davenport, Iowa 18-A-109-S1

PERMIT CONDITIONS


Pollutant lb/hr1 tons/yr2 Other Limits Reference/Basis Particulate Matter (PM) – State NA NA NA NA PM10 NA NA 4 NA PM2.5 NA NA NA NA Opacity NA NA 3 567 IAC 23.3(2)“c”

1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 The owner or operator shall take reasonable precautions to prevent the discharge of visible emissions of fugitive dusts beyond lot line

of the property. 4 Emission limit for PM10 established at 58.32 pounds of PM10 per day, which correlates to surface silt loading as specified in

Condition 5. A., and maximum worst case truck traffic (material/product is shipped or received by truck). The parameters used in calculation are specified in Condition 5.A. The PM10 pound per hour emission rate was established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343).



Pollutant Compliance Methodology Frequency

Test Run Time

Test Method

PM – State NA NA NA AP-42, Appendix C.1 Procedures for

Sampling Surface/Bulk Dust Loading, Appendix C.2 Procedures for Laboratory Analysis of Surface/Bulk Dust Loading

Samples PM10 Silt Sampling

Quarterly (segments 1, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22,

23, 85 and 86) NA

Opacity NA NA NA 40 CFR 60, Appendix A, Method 9 If an initial stack test is specified in the “Compliance Demonstration Table,” the owner or the owner’s authorized agent shall demonstrate compliance with the emission limitations contained in Condition 1 within the applicable time period specified below:



If any additional stack testing beyond an initial test (i.e. quarterly, semi-annual, annual, etc.) is required in “Compliance Demonstration Table,” the owner or the owner’s authorized agent shall demonstrate compliance with the emission limitations contained in Condition 1 as specified in the “Compliance Demonstration Table.” See Conditions 12.A.(4) and 12.B.(5) for notification and reporting requirements.

Linwood Mining & Minerals Corp. Paved Haul Roads (EP HR-P) Page 3 of 9 Davenport, Iowa 18-A-109-S1 2. Compliance Demonstration(s) (Continued) If stack testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the “Compliance Demonstration Table” unless another testing methodology is approved by the Department prior to testing. Each emissions compliance test must be approved by the Department. Unless otherwise specified by the Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs shall apply for compliance, unless otherwise indicated by the Department.

Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.


Parameter Value Stack Height (feet from the ground) See Note Discharge Style See Note Stack Outlet Dimensions (inches) See Note Exhaust Temperature (oF) See Note Exhaust Flowrate (scfm) See Note

Note: Emissions from this unit are fugitive emissions generated by vehicle traffic on roadways inside the facility. The temperature and flowrate are intended to be representative and characteristic of the design of the permitted emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process and ambient conditions. If it is determined that any of the emission point characteristics above are different than the values stated, the owner or operator shall submit a request either by electronic mail or written correspondence to the Department within thirty (30) days of the discovery to determine if a permit amendment is required, or submit a permit application requesting to amend the permit.

4. Federal Standards

A. New Source Performance Standards (NSPS):

There are no New Source Performance Standards (NSPS) for this source type at this time, as there are no applicable subparts.


B. National Emission Standards for Hazardous Air Pollutants (NESHAP):

There are no National Emission Standard for Hazardous Air Pollutants (NESHAP) for this source type at this time.


NOTE: The absence of the inclusion of any NESHAP requirements as part of this permit does not relieve the owner or

operator from any obligation to comply with all applicable NESHAP conditions.

5. Operating Requirements with Associated Monitoring and Recordkeeping Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an orderly manner. The operating requirements and associated recordkeeping for this permit shall be: A. The total surface material silt loading shall not exceed 8.2 g/m2 on paved road segments 1, 13, 14, 15, 16, 17, 18, 19, 20,

21, 22, 23, 85 and 86.

i. Beginning October 1, 2018, performance testing on the haul road surface silt loading shall be determined on a quarterly basis. Performance testing shall be completed prior to any sweeping or water flushing. The silt loading sampling shall be conducted according to the procedures outlined in AP-42, Appendix C.1 Procedures for Sampling Surface/Bulk Dust Loading and Appendix C.2 Procedures for Laboratory Analysis of Surface/Bulk Dust Loading Samples.

ii. Surface silt loading sampling shall be conducted on paved road segments, as listed in 1, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 85 and 86. The owner or operator shall sample a minimum of three paved road segments and rotate the segments sampled each calendar quarter. The owner or operator shall determine the average of all samples taken for each calendar quarter, expressed as silt loading for the paved roads.

iii. The owner or operator shall maintain a log of each silt load sampling event that contains the following:

a. Records of the road segments sampled each quarter.

b. The measured silt loading as grams.

c. The date of silt sampling event.

d. The location of the sample taken.

e. Sample area used for silt sampling in feet.

f. The operator’s initials.

iv. The owner or operator shall maintain record of the average silt loading results in g/m2 for each quarter.

B. Truck traffic emissions on the paved road shall be controlled by weekly sweeping, at a minimum, except as specified in B. i, ii and iii. At a minimum the sweeper shall be an enclosed vacuum sweeper or functional equivalent as approved by the department.

i. If sweeping cannot be accomplished because the ambient air temperature (as measured at the facility during daylight operating hours) will be less than 35o F (1.7o C) or conditions due to weather could create hazardous driving conditions, then the sweeping shall be postponed and accomplished as soon after the scheduled date as the conditions preventing the sweeping have abated.

ii. Paved road sweeping need not occur when a rain gauge located at the site indicates that at least 0.2 inches of precipitation (water equivalent) has occurred within the preceding 24-hour time period. However, paved road sweeping shall resume within 24-hours after the precipitation event has ended.

iii. Paved road sweeping need not occur when the facility experiences no haul road traffic on that calendar day. iv. The facility shall record the frequency of cleaning/sweeping performed on the haul roads. If the roads are not

cleaned due to weather, a written record must be kept on site outlining the conditions. C. Truck traffic emissions on the paved road shall be controlled by water flushing at a rate of 0.12 gallons per square feet,

three times a day at a minimum, except as specified in B. i, ii and iii. i. If water flushing cannot be accomplished because the ambient air temperature (as measured at the facility during

daylight operating hours) will be less than 35o F (1.7o C) or conditions due to weather could create hazardous driving conditions, then the water flushing shall be postponed and accomplished as soon after the scheduled date as the conditions preventing the water flushing have abated.

ii. Paved road water flushing need not occur when a rain gauge located at the site indicates that at least 0.2 inches of precipitation (water equivalent) has occurred within the preceding 24-hour time period. However, paved road water flushing shall resume within 24-hours after the precipitation event has ended.

iii. Paved road water flushing need not occur when the facility experiences no haul road traffic on that calendar day.


iv. The facility shall record the frequency of water flushing performed on the haul roads. If the roads are not water flushed due to weather, a written record must be kept on site outlining the conditions.

D. Maximum number of trucks shall not exceed:

i. 2,208 trucks per calendar month on segment 13.

ii. 4772 trucks per calendar month on segment 85.

iii. The owner or operator shall record the total number of trucks on segment 13 for each calendar month.

iv. The owner or operator shall record the total number of trucks on segment 85 for each calendar month.

v. Based on throughput and storage capacity limitations, the plant truck traffic on paved and unpaved surfaces is directly proportional to the quantity of trucks measured on segments 13 and 85 (customer output). If plant operations change, the owner or operator shall request amendment of the paved or unpaved haul roads permit requirements.

E. Best Management Practices (BMP) – The owner or operator shall implement “good housekeeping” or best management practices to minimize fugitive emissions from plant haul roads. Such practices include but are not limited to:

i. Clean up spills of raw materials and product on the haul road surface as expeditiously as possible and in a manner consistent with good practice for minimizing dust emissions.

ii. Clean around truck scale areas and process buildings in a manner consistent with good practice for minimizing fugitive emissions.

iii. Clean up spills of raw materials and product on Iowa Highway 22 as expeditiously as possible and in a manner consistent with good practice for minimizing dust emissions.

iv. Post and maintain speed limit (10 mph) signs.

F. The owner or operator shall develop a written plan to implement, at a minimum, the Best Management Practices as specified in condition 5.E. The written plan and any documentation as required by the plan shall be maintained onsite and available for inspection.



8. Owner and Operator Responsibility This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point as described in this permit and in the application for this permit. The permit holder, owner, and operator of the facility shall assure that the installation of the equipment listed in this permit conforms to the design in the application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this emission unit(s), control equipment, or emission point without the required amended permit. Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person who

Linwood Mining & Minerals Corp. Paved Haul Roads (EP HR-P) Page 6 of 9 Davenport, Iowa 18-A-109-S1 becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the provisions of this permit and all other applicable requirements and that adequate operation and maintenance is provided to ensure that no condition of air pollution is created.


10. Construction








11. Excess Emissions Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good practice for minimizing emissions except when another regulation applicable to the unit or process provides otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be limited to one (1) six-minute period per one (1) hour period. An incident of excess emissions other than the above is a violation and may be subject to criminal penalties according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within a reasonable period of time, as specified in 567 IAC 24.1. An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate field

Linwood Mining & Minerals Corp. Paved Haul Roads (EP HR-P) Page 7 of 9 Davenport, Iowa 18-A-109-S1 office within eight (8) hours of, or at the start of, the first working day following the onset of the incident [See Permit Condition 12.B.(1)]. A written report of an incident of excess emissions shall be submitted as a follow-up to all required initial reports within seven (7) days of the onset of the upset condition [See Permit Condition 12.B.(2)].




















D. Information regarding this permit should be sent to the attention of the following individuals based on the type of information being submitted: change in ownership (Air Quality Bureau Records Center), permit correspondence (Construction Permit Supervisor), stack testing correspondence (Stack Test Coordinator), and reports and notifications (Compliance Unit Supervisor and DNR Field Office). The addresses are:



Fax: (319) 653-2856


14. Permit History


Testing 18-A-109 18-017 Original permit to establish PM10 permit limits 09/06/18 No

END OF PERMIT

I I

Linwood Mining & Minerals Corp. Paved Haul Roads (EP HR-P) Page 9 of 9 Davenport, Iowa 18-A-109-S1 Figure 1 - Haul Roads Map

Table 1 - Haul Road Segments

Unpaved Road Segment #

2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 24, 25, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 65,

66, 67, 68, 69, 70, 71, 72, 73, 74, 75, 82, 83, 84.

Paved Road Segment #

1, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 85, 86.

7 9

7 78







40 I E Front Street Davenpo1t, IA 52761

Emission Point ID: HR-U

Same

Permitted Equipment


EUID Description Maximum Rated Capacitv

Control Measure

HR-U i Unpaved Haul Roads* NA Dust Suppressant (CE Unpaved Haul Roads)

*See Figure 1 - Haul Roads Map

Equipment Location: 401 E Front Street Davenport, IA 52761


Project Project Description Number 18-366 Update emission limits; silt content

[PSP]

Stack Issuance Testin2 Date

No 03/14/19

Under the Direction of the Director of the Depa1tment of Natural Resources

lCPFPl8201015ll03142019l 18366l 18Al 08S I l

Linwood Mining & Minerals Corp. Unpaved Haul Roads (EP HR-U) Page 2 of 9 Davenport, Iowa 18-A-108-S1

PERMIT CONDITIONS



1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 The owner or operator shall take reasonable precautions to prevent the discharge of visible emissions of fugitive dusts beyond lot line

of the property. 4 Emission limit for PM10 established at 409 pounds of PM10 per day, which correlates to surface silt loading as specified in

Condition 5. A and 5. B., and maximum worst case truck traffic (material/product is shipped or received by truck). The parameters used in calculation are specified in Condition 5.A. and 5.B. The emission rate also includes emissions of haul roads located within the storage Piles A, Pile 4, and Pile 8. The PM10 pound per hour emission rate was established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343).




Time Test Method

PM – State NA NA NA

AP-42, Appendix C.1 Procedures for Sampling Surface/Bulk Dust Loading,

Appendix C.2 Procedures for Laboratory Analysis of Surface/Bulk Dust Loading

Samples

PM10 Silt Sampling Quarterly NA

PM10 Silt Sampling Once every other calendar

month (segments 2,3,4,5,6,7,8,9,10,11,12 and

24)*

NA

Opacity NA NA NA 40 CFR 60, Appendix A, Method 9 *The facility could request the department to lower silt sampling frequency after successfully collecting at least 4 data points. If an initial stack test is specified in the “Compliance Demonstration Table,” the owner or the owner’s authorized agent shall demonstrate compliance with the emission limitations contained in Condition 1 within the applicable time period specified below:




Linwood Mining & Minerals Corp. Unpaved Haul Roads (EP HR-U) Page 3 of 9 Davenport, Iowa 18-A-108-S1 If stack testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the “Compliance Demonstration Table” unless another testing methodology is approved by the Department prior to testing. Each emissions compliance test must be approved by the Department. Unless otherwise specified by the Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs shall apply for compliance, unless otherwise indicated by the Department. Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.


Parameter Value Stack Height (feet from the ground) See Note Discharge Style See Note Stack Outlet Dimensions (inches) See Note Exhaust Temperature (oF) See Note Exhaust Flowrate (scfm) See Note

Note: Emissions from this unit are fugitive emissions generated by vehicle traffic on roadways inside the facility. The temperature and flowrate are intended to be representative and characteristic of the design of the permitted emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process and ambient conditions. If it is determined that any of the emission point characteristics above are different than the values stated, the owner or operator shall submit a request either by electronic mail or written correspondence to the Department within thirty (30) days of the discovery to determine if a permit amendment is required, or submit a permit application requesting to amend the permit.



There are no New Source Performance Standards (NSPS) for this source type at this time.



There are no National Emission Standard for Hazardous Air Pollutants (NESHAP) for this source type at this time.



5. Operating Requirements with Associated Monitoring and Recordkeeping Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an orderly manner. The operating requirements and associated recordkeeping for this permit shall be: A. The total surface material silt content shall not exceed 2.1 percent on unpaved road segments 2, 3, 4, 5, 6, 7, 8, 9, 10, 11,

12 and 24.

i. Beginning October 1, 2018, performance testing on the unpaved haul road surface silt content shall be determined once every other calendar month. Performance testing shall be completed prior to any suppressant application. The silt content sampling shall be conducted according to the procedures outlined in AP-42, Appendix C.1 Procedures for Sampling Surface/Bulk Dust Loading and Appendix C.2 Procedures for Laboratory Analysis of Surface/Bulk Dust Loading Samples. If suppressant application cannot be accomplished for the entire month due to ambient temperatures or hazardous weather, silt content sampling is not required for that month.

ii. Silt content sampling shall be conducted on unpaved road segments 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, and 24. The owner or operator shall sample a minimum of three unpaved road segments and rotate the segments sampled each time. The owner or operator shall determine the average of all samples taken each time, expressed as silt content for the unpaved roads.

iii. The owner or operator shall maintain a log of each silt content sampling event that contains the following:

i. Records of the road segments sampled every other calendar month.

ii. The measured silt content as percent.

iii. The date of silt sampling event.

iv. The location of the sample taken.

v. Sample area used for silt sampling in feet.

vi. The operator’s initials.

iv. The owner or operator shall maintain record of the average silt content results expressed as percent every other calendar month.

B. The total surface material silt content shall not exceed 6.2 percent on unpaved road segments 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 65, 66, 67, 68, 69, 70, 71, 72, 73, 74, 75, 82, 83, and 84.

i. Beginning October 1, 2018, performance testing on the unpaved haul road surface silt content shall be determined on a quarterly basis. Performance testing shall be completed prior to any suppressant application. The silt content sampling shall be conducted according to the procedures outlined in AP-42, Appendix C.1 Procedures for Sampling Surface/Bulk Dust Loading and Appendix C.2 Procedures for Laboratory Analysis of Surface/Bulk Dust Loading Samples.

ii. Silt content sampling shall be conducted on unpaved road segments 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 65, 66, 67, 68, 69, 70, 71, 72, 73, 74, 75, 82, 83, and 84. The owner or operator shall sample a minimum of three unpaved road segments and rotate the segments sampled for each calendar quarter. The owner or operator shall determine the average of all samples taken for each calendar quarter, expressed as silt content for the unpaved roads.

iii. The owner or operator shall maintain a log of each silt content sampling event that contains the following:

i. Records of the road segments sampled each quarter.

ii. The measured silt content as percent.

iii. The date of silt sampling event.

iv. The location of the sample taken.

v. Sample area used for silt sampling in feet.


vi. The operator’s initials.

iv. The owner or operator shall maintain record of the average silt content results expressed as percent for each quarter.

C. The owner or operator shall utilize control measures to reduce particulate emissions generated on unpaved road segments, while in use except as noted in Conditions 5.C.ii and 5.C.iii. These measures include any of the following

i. Chemical dust suppressant application. The owner or operator shall apply chemical dust suppressant to the road surface at minimum frequency of twice per month.

ii. If the suppressant cannot be applied because the ambient air temperature (as measured at the facility during daylight operating hours) will be less than 35° F (1.7° C) or conditions due to weather could create hazardous driving conditions, then the suppressant application shall be postponed and applied immediately after the scheduled date as the conditions preventing the application have abated.

iii. Suppressant application need not occur when a rain gauge located at the site indicates that at least 0.2 inches of precipitation (water equivalent) has occurred within the preceding 24-hour time period. However, suppressant application shall resume within 24-hours after the precipitation event has ended

D. If visible emissions are observed from the Unpaved Road Segments, during use, the owner or operator shall immediately apply water or chemical dust suppressant to haul road segment.

E. The owner or operator shall maintain as record of the suppressant application on unpaved road segments. The record shall include suppressant application frequency, quantity applied and suppressant utilized. If suppressant is not applied due to weather as specified in conditions 5.C.ii and 5.C.iii, a written record must be kept on site outlining the conditions and when suppressant application resumed.

F. Best Management Practices (BMP) – The owner or operator shall implement “good housekeeping” or best management practices to minimize fugitive emissions from unpaved road segments. Such practices may include but are not limited to:

i. Clean up spills of materials on the road surface as expeditiously as possible and in a manner consistent with good practice for minimizing dust emissions,

ii. Post and maintain speed limit (10 mph) signs,

iii. Apply additional suppressant to material unloading/loading areas as necessary to prevent track out of material on the traveled road surface.

G. The owner or operator shall develop a written plan to implement, at a minimum, the Best Management Practices as

specified in condition 5.F. The written plan and any documentation as required by the plan shall be maintained onsite and available for inspection.

H. Maximum number of trucks shall not exceed:

i. 2,208 trucks per calendar month on segment 13.

ii. 4772 trucks per calendar month on segment 85.

iii. The owner or operator shall record the total number of trucks on segment 13 for each calendar month.

iv. The owner or operator shall record the total number of trucks on segment 85 for each calendar month.

v. Based on throughput and storage capacity limitations, the plant truck traffic on paved and unpaved surfaces is

directly proportional to the quantity of trucks measured on segments 13 and 85 (customer output). If plant

operations change, the owner or operator shall request amendment of the paved or unpaved haul roads permit

requirements.


Linwood Mining & Minerals Corp. Unpaved Haul Roads (EP HR-U) Page 6 of 9 Davenport, Iowa 18-A-108-S1 7. Department Review This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply. This permit is issued based on information submitted by the applicant. Any misinformation, false statements or misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. No review has been undertaken on the engineering aspects of the equipment or control equipment other than the potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, installation, maintenance or operation of the proposed equipment.



10. Construction







C. Amended Permits:

The owner or operator may continue to act under the provisions of the previous permit for the affected emission unit(s) and emission point, together with any previous amendment to the permit, until one of the following conditions occurs: (1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and emission














(1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported within eight (8) hours or at the start of the first working day following the onset of the incident. The report may be made by


electronic mail, in person or by telephone. (2) Per 567 IAC 24.1(3), a written report of an incident of excess emissions as defined in 567 IAC 20.2 shall be

submitted as a follow-up to all required initial reports to the Department within seven (7) days of the onset of the upset condition.










Fax: (319) 653-2856


14. Permit History


Testing 18-A-108 18-017 Original permit to establish PM10 permit limits 09/06/18 No

END OF PERMIT

I I

Linwood Mining & Minerals Corp. Unpaved Haul Roads (EP HR-U) Page 9 of 9 Davenport, Iowa 18-A-108-S1 Figure 1 - Haul Roads Map

Table 1 - Haul Road Segments

Unpaved Road Segment #

2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 24, 25, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 65,

66, 67, 68, 69, 70, 71, 72, 73, 74, 75, 82, 83, 84.

Paved Road Segment #

1, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 85, 86.







401 E Front Street Davenpmt, IA 5276 l


Same

Permitted Equipment


EUID Description Maximnm Rated Capacity Control Eqnipment Descriotion and ID

LP-12 Ingredients Bin* 100 Tons of ingredients per hour Baghouse (CE LP-12) *See Emission Unit list in Condition 3

Eqnipment Location: 401 E Front Street Davenport, IA 52761


Project Number

l 8-366

[PSP]

Project Description Stack Testin"

Issuance Date

Add emission units from LP-3; modify stack characteristics No 03/14/19

Under the Direction of the Director of the Depattment of Natural Resources

:crFr:s20 l 0 1 s1:03 l 420 l 9: 18366:97 Al 084S4:

Linwood Mining & Minerals Corp. Ingredients Bin (EP LP-12) Page 2 of 7 Davenport, Iowa 97-A-1084-S4

PERMIT CONDITIONS



1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 The emission limit is based on a six (6) minute average. 4 An exceedance of the indicator opacity of No Visible Emissions will require the owner or operator to promptly investigate the

emission unit and make corrections to operations or equipment associated with the exceedance. If exceedances continue after the corrections, the Department may require additional proof to demonstrate compliance (e.g., stack testing).






Time Test Method







Linwood Mining & Minerals Corp. Ingredients Bin (EP LP-12) Page 3 of 7 Davenport, Iowa 97-A-1084-S4 2. Compliance Demonstration(s) (Continued) Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.


Parameter Value Stack Height (feet from the ground) 65 Discharge Style Vertical Unobstructed Stack Outlet Dimensions (inches) 12 Exhaust Temperature (oF) Ambient Exhaust Flowrate (scfm) 3,600


Emission Unit Maximum Capacity Control Equipment Hi-Cal Storage Bin (LP-12a) 165 tons of ingredient

Baghouse (CE LP-12)

Pneumatic Blowers (LP-12b) 75 tons of ingredient per hour Hi-Cal Storage Bin (LP-12c) 50 tons of ingredient

Flourspar Storage Bin (LP-12e) 50 tons of ingredient Cal-Aluminate Storage Bin (LP-12f) 75 tons of ingredient

Hi-Cal Storage Bin (LP-12g) 75 tons of ingredient Bagging Tank Conveyor (LP-3a) 75 tons of ingredient per hour

2-ton Bagger (LP-3b) 20 tons of ingredient per hour






B. National Emission Standards for Hazardous Air Pollutants (NESHAP): This emission unit is not subject to any NESHAP subparts at this time as there are no applicable subparts for its source category.



A. The maximum amount of product conveyed to bagging shall not exceed 100 tons per hour averaged over 3-hr period. i. For each hour, the owner or operator shall maintain records of the amount of product loaded out in tons.

ii. The owner or operator shall maintain records of the 3-hour average the amount of product loaded out in tons.

B. The owner or operator shall decommission loadout LP-3 and rescind permit #71-A-085-S2 by June 30, 2019. i. The owner or operator shall maintain a record of the date when EP LP-3 was decommissioned from use.

C. The differential pressure drop across Baghouse (CE LP-12) shall be maintained between 2 and 10 inches of water

column, based on 1-hr block average. i. The owner or operator shall properly operate and maintain equipment to monitor differential pressure drop

across Baghouse (CE LP-12). The monitoring devices and any recorders shall be installed, calibrated, operated and maintained in accordance with the manufacturer’s recommendations, instructions and operating manuals or per written facility specific operation and maintenance plan.






Linwood Mining & Minerals Corp. Ingredients Bin (EP LP-12) Page 5 of 7 Davenport, Iowa 97-A-1084-S4 8. Owner and Operator Responsibility This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point as described in this permit and in the application for this permit. The permit holder, owner, and operator of the facility shall assure that the installation of the equipment listed in this permit conforms to the design in the application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this emission unit(s), control equipment, or emission point without the required amended permit. Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the provisions of this permit and all other applicable requirements and that adequate operation and maintenance is provided to ensure that no condition of air pollution is created.


10. Construction








11. Excess Emissions Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good practice for minimizing emissions except when another regulation applicable to the unit or process provides otherwise. Cleaning of control equipment,

Linwood Mining & Minerals Corp. Ingredients Bin (EP LP-12) Page 6 of 7 Davenport, Iowa 97-A-1084-S4 which does not require the shutdown of process equipment, shall be limited to one (1) six-minute period per one (1) hour period. An incident of excess emissions other than the above is a violation and may be subject to criminal penalties according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within a reasonable period of time, as specified in 567 IAC 24.1. An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident [See Permit Condition 12.B.(1)]. A written report of an incident of excess emissions shall be submitted as a follow-up to all required initial reports within seven (7) days of the onset of the upset condition [See Permit Condition 12.B.(2)].
























Fax: (319) 653-2856


14. Permit History


Testing 97-A-1084 97-686 Original permit. 2/16/98 Yes

97-A-1084-S1 03-139 Vented additional EUs through stack. 9/24/03 Yes 97-A-1084-S2 04-045 Modify exhaust flow rate 1/29/04 No 97-A-1084-S3 15-457 Amend permit to allow baghouse replacement 03/13/18 Yes

END OF PERMIT







401 E Front Street Davenport, IA 52761


Permitted Equipment



EUID Description

LP-38 Kiln # 1, 2 Rockbox Conveyor LP-52 Kiln # 1 Rockbox LP-40 Kiln #2 Rockbox



55 Tons of Limestone per hour




None

None

None


Project Project Description

Number 19-130 Correct EU ID for Kiln # 1 Rockbox

[PSP]

Stack Issuance Testing Date

No 07/02/19


:cPFP:s20 IOI SI:01022019: 19130: 11 A492S I:

Linwood Mining & Minerals Corp. Kiln #1, 2 Rockbox and Conveyor (EP LP-38) Page 2 of 7 Davenport, Iowa 17-A-492-S1

PERMIT CONDITIONS










Time Test Method







Linwood Mining & Minerals Corp. Kiln #1, 2 Rockbox and Conveyor (EP LP-38) Page 3 of 7 Davenport, Iowa 17-A-492-S1 2. Compliance Demonstration(s) (Continued) Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.


Parameter Value Stack Height (feet from the ground) 76 Discharge Style Vertical Unobstructed Stack Outlet Dimensions (inches) 32 x 32 Exhaust Temperature (oF) Ambient Exhaust Flowrate (scfm) 80

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process and ambient conditions. If it is determined that any of the emission point characteristics above are different than the values stated, the owner or operator shall submit a request either by electronic mail or written correspondence to the Department within thirty (30) days of the discovery to determine if a permit amendment is required, or submit a permit application requesting to amend the permit.







Linwood Mining & Minerals Corp. Kiln #1, 2 Rockbox and Conveyor (EP LP-38) Page 4 of 7 Davenport, Iowa 17-A-492-S1 5. Operating Requirements with Associated Monitoring and Recordkeeping Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an orderly manner. The operating requirements and associated recordkeeping for this permit shall be:

A. The maximum amount of product conveyed using kiln#1, 2 rockbox conveyor shall not exceed 55 tons per hour averaged over 3-hr period.

i. For each hour, the owner or operator shall maintain records of the amount of product conveyed in tons. ii. The owner or operator shall maintain records of the 3-hour average the amount of product conveyed in tons.

B. The owner or operator shall check for visible emissions from Kiln #1 & #2 Rockbox and Conveyor (EP LP-38) once

per week at a time while Kiln #1 & #2 Rockbox and Conveyor (EP LP-38) is in operation. The owner or operator shall record the date and time of the observation and the presence or absence of visible emissions. If the owner or operator observes visible emissions from Kiln #1 & #2 Rockbox and Conveyor (EP LP-38), the owner or operator shall investigate the emission unit or operations associated with the emission unit and make corrections to the associated operations or equipment. The owner or operator shall maintain a record of all corrective actions taken. This requirement shall not apply on the days that Kiln #1 & #2 Rockbox and Conveyor (EP LP-38) is not in operation.





Linwood Mining & Minerals Corp. Kiln #1, 2 Rockbox and Conveyor (EP LP-38) Page 5 of 7 Davenport, Iowa 17-A-492-S1 10. Construction












(b) The actual date of startup, postmarked within fifteen (15) days following the start of operation.

Linwood Mining & Minerals Corp. Kiln #1, 2 Rockbox and Conveyor (EP LP-38) Page 6 of 7 Davenport, Iowa 17-A-492-S1

(2) Per 567 IAC 22.3(3)“f,” when portable equipment for which a permit has been issued is to be transferred from one location to another, the Department shall be notified: (a) At least fourteen (14) days before equipment relocation if the equipment will be located in a nonattainment


















Fax: (319) 653-2856

Linwood Mining & Minerals Corp. Kiln #1, 2 Rockbox and Conveyor (EP LP-38) Page 7 of 7 Davenport, Iowa 17-A-492-S1 13. Appeal Rights All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in the amendment for your convenience only and are unappealable.

14. Permit History


Testing 17-A-492 15-457 Issue permit for the as-built units & Establish PM10 Limits 03/13/18 No

END OF PERMIT


Permit Number: 17-A-491







Permitted Equipment



EUID ! Description Maxim nm Rated Capacity

LP-36 LP-37

. Kiln# 3 Rockbox Conveyor L_. 70 Tons of Limestone per hour Kiln# 3 Rockbox 70 Tons of Limestone per hour



None None


Project Number 15-457

[PSP]

Project Description Stack Issuance

Testin!!. Date Issue permit for the as-built units & Establish PM IO Limits No 03/13/18


:cPFP:s20 IO 151:031320 Is: 15457: I 7 A491:

Linwood Mining & Minerals Corp. Kiln # 3 Rockbox and Conveyor (EP LP-36) Page 2 of 7 Davenport, Iowa 17-A-491

PERMIT CONDITIONS










Time Test Method







Linwood Mining & Minerals Corp. Kiln # 3 Rockbox and Conveyor (EP LP-36) Page 3 of 7 Davenport, Iowa 17-A-491 2. Compliance Demonstration(s) (Continued) Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.


Parameter Value Stack Height (feet from the ground) 76 Discharge Style Vertical Unobstructed Stack Outlet Dimensions (inches) 32 x 32 Exhaust Temperature (oF) Ambient Exhaust Flowrate (scfm) 290








Linwood Mining & Minerals Corp. Kiln # 3 Rockbox and Conveyor (EP LP-36) Page 4 of 7 Davenport, Iowa 17-A-491 5. Operating Requirements with Associated Monitoring and Recordkeeping Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an orderly manner. The operating requirements and associated recordkeeping for this permit shall be:

A. The maximum amount of product conveyed using kiln#3 conveyor shall not exceed 70 tons per hour averaged over 3-hr period.

i. For each hour, the owner or operator shall maintain records of the amount of product conveyed in tons. ii. The owner or operator shall maintain records of the 3-hour average the amount of product conveyed in tons.

B. The owner or operator shall check for visible emissions from Kiln #3 Rockbox and Conveyor (EP LP-36) once per week at a time while Kiln #3 Rockbox and Conveyor (EP LP-36) is in operation. The owner or operator shall record the date and time of the observation and the presence or absence of visible emissions. If the owner or operator observes visible emissions from Kiln #3 Rockbox and Conveyor (EP LP-36), the owner or operator shall investigate the emission unit or operations associated with the emission unit and make corrections to the associated operations or equipment. The owner or operator shall maintain a record of all corrective actions taken. This requirement shall not apply on the days that Kiln #3 Rockbox and Conveyor (EP LP-36) is not in operation.





Linwood Mining & Minerals Corp. Kiln # 3 Rockbox and Conveyor (EP LP-36) Page 5 of 7 Davenport, Iowa 17-A-491 10. Construction













Linwood Mining & Minerals Corp. Kiln # 3 Rockbox and Conveyor (EP LP-36) Page 6 of 7 Davenport, Iowa 17-A-491

(2) Per 567 IAC 22.3(3)“f,” when portable equipment for which a permit has been issued is to be transferred from one location to another, the Department shall be notified: (a) At least fourteen (14) days before equipment relocation if the equipment will be located in a nonattainment
















Air Quality Bureau Iowa Department of Natural Resources 7900 Hickman Road, Suite 1 Windsor Heights, IA 50324 Telephone: (515) 725-9549 Fax: (515) 725-9502


Fax: (319) 653-2856

13. Appeal Rights All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. Amended

Linwood Mining & Minerals Corp. Kiln # 3 Rockbox and Conveyor (EP LP-36) Page 7 of 7 Davenport, Iowa 17-A-491 conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in the amendment for your convenience only and are unappealable.

14. Permit History


Testing

END OF PERMIT









Permitted Equipment



EUID Description

Multiple* Four (4) Rotary Lime Kilns



Maximum Rated Control Equipment Description and Capacity ID

* Cyclones & Limestone Mining Tunnel

(CE LP-4)



[PSP]


Testin~ Date Replace damaged stack; modify stack height and diameter Yes 02/26/20

.

/4 Under the Direction of the Director of the Depa1tment of Natural Resources

:cPFP:s20 IO I s :02262020: 19406:73A2 I 9S8:

Linwood Mining & Minerals Corporation 4 Lime Kilns (EP LP-4) Page 2 of 9 Davenport, Iowa 73-A-219-S8

PERMIT CONDITIONS

1. Emission Limits The owner or operator is required to report all emissions as required by law, regardless of whether a specific emission limit has been established in this permit. The following emission limits shall not be exceeded: 1. a. Emission Limits with Kiln 4 Operating

Pollutant lb/hr1 tons/yr2 Additional Limits Reference (567 IAC) Particulate Matter (PM) – Federal NA NA 0.30 kg/megagram3 567 IAC 23.1(2)”y”4 Particulate Matter (PM) – State NA NA 0.51 lb/ton lime5 PSD SM PM10 45.596 NA 0.51 lb/ton lime5 NAAQS PM2.5 NA NA NA NA Opacity NA NA 15% 567 IAC 23.1(2)”y”4 Sulfur Dioxide (SO2) 9.457 41.47 See Footnote 8 567 IAC 23.3(3) Nitrogen Oxides (NOx) 58.97 272.29 NA PSD SM Volatile Organic Compounds (VOC) NA NA NA NA Carbon Monoxide (CO) 46.87 205.27 NA PSD SM Lead (Pb) NA NA NA NA Hydrochloric Acid (HCl) 0.3510 NA NA Area Source (Single HAP) NA NA NA NA (Total HAP) NA NA NA NA

1 Standard is expressed as the average of three (3) runs. 2 Standard is a 12-month rolling total. 3 0.30 kg/megagram of stone feed = 0.60 lb/ton of stone feed. 4 IAC reference to New Source Performance Standard (NSPS) Subpart HH (Standards of Performance for Lime Manufacturing

Plants; 40 CFR §60.340 – 40 CFR §344). 5 Emission limit for Kiln 4. This emission rate was used in Prevention of Significant Deterioration (PSD) netting calculations to keep

the addition of kiln 4 a “synthetic minor” (SM). 6 The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved

into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343). 7 The limit was set based on the netting calculations to keep the addition of kiln 4 a PSD SM. 8 The sulfur dioxide limits are: • 6 lb/MMBTU when combusting only on solid fuels (i.e. coal & pet coke) • 500 ppm when combusting only gaseous fuels (i.e. natural gas & landfill gas) • The stricter of the above standards when using a combination of fuels

9 Adjusted permit limit based on netting calculations to keep the addition of kiln 4 a PSD SM. The limit is 272.2 tons/yr (plant total). The limit was based on the following calculations:

NOx baseline emissions (TPY) = EF1 lb/ton x 141,112 TPY lime ÷ 2,000 lb/ton NOx permit limit (TPY) = Baseline emissions + 39.4 TPY

Where: EF1 (lb NOx/ton of lime produced) was to be verified by testing the combined exhaust from kilns #1 and #2. The

combined exhaust shall be used to purge the tunnel at least twelve (12) hours before conducting the stack test and the lime produced during the test period shall be recorded.

10 Emission limit to ensure the facility is an area source for the National Emission Standards for Hazardous Air Pollutants (NESHAP). This limit was based on the upper bound 95% confidence interval of the May 23, 2006 stack test.

Linwood Mining & Minerals Corporation 4 Lime Kilns (EP LP-4) Page 3 of 9 Davenport, Iowa 73-A-219-S8 1. b. Emission Limits when Kiln 4 is not Operating

Pollutant lb/hr1 Tons/Yr2 Additional Limits Reference (567 IAC) Federal Particulate Matter (PM) NA NA NA NA State Particulate Matter (PM) NA NA 1.58 lb/ton of lime3 PSD SM4 PM10 45.595 NA 1.58 lb/ton lime3 NAAQS Opacity NA NA 40%6,8 567 IAC 23.3(2)”d” Sulfur Dioxide (SO2) NA NA See Footnote 7 567 IAC 23.3(3) Nitrogen Oxides (NOX) NA NA NA NA Volatile Organic Compounds NA NA NA NA Carbon Monoxide (CO) NA NA NA NA Lead (Pb) NA NA NA NA (Single HAP) NA NA NA NA (Total HAP) NA NA NA NA

1 Standard is expressed as the average of 3 runs 2 Standard is a 12-month rolling total. 3 This emission rate was used in netting calculations to keep the addition of Kiln 4 a “synthetic minor (SM)” for Prevention of Significant Deterioration (PSD) purposes. The facility claimed a reduction in emissions for Kilns 1 – 3 by the addition of kiln seals. 4 The stack is also subject to a standard of 0.1 gr/scf [See 567 IAC 23.4(8)]. 5 The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343). 6 An exceedance of the indicator opacity of 10% will require the owner/operator to promptly investigate the emission unit and make corrections to operations or equipment associated with the exceedance. If exceedances continue after the corrections, the DNR may require additional proof to demonstrate compliance (e.g., stack testing). 7 The sulfur dioxide limits are: • 6 lb/MMBTU when combusting only on solid fuels (i.e. coal & pet coke) • 500 ppm when combusting only gaseous fuels (i.e. natural gas & landfill gas) • The stricter of the above two standards when using a combination of fuels. 8 The emission limit is a six (6) minute average.




Time Test Method

PM – Federal None NA 1 hour 40 CFR 60, Appendix A, Method 5

PM – State Stack Test3 One-Time 1 hour 40 CFR 60, Appendix A, Method 5 40 CFR 51 Appendix M Method 202

PM10 Stack Test4 One-Time 1 hour 40 CFR 51, Appendix M, 201A with 202 PM2.5 None NA 1 hour 40 CFR 51, Appendix M, 201A with 202 Opacity1,2 Opacity monitor Continuous 1 hour 40 CFR 60, Appendix A, Method 9 SO2 None NA 1 hour 40 CFR 60, Appendix A, Method 6C NOx None NA 1 hour 40 CFR 60, Appendix A, Method 7E

VOC None NA 1 hour 40 CFR 63, Appendix A, Method 320 or 40 CFR 60, Appendix A, Method 18

CO None NA 1 hour 40 CFR 60, Appendix A, Method 10 Pb None NA 1 hour 40 CFR 60, Appendix A, Method 12 CO2 None NA 1 hour 40 CFR 60, Appendix A, Method 3

HAP (HCl) None NA 1 hour 40 CFR 63, Appendix A, Method 320 or 40 CFR 60, Appendix A, Method 18

1 Combined exhaust from Kilns 1 – 4. 2 Compliance with opacity shall be measured through the use of a Continuous Opacity Monitoring System (COMS). See permit

Condition 6 for more details. 3 Compliance demonstration is required for PM with the state limit of 0.51 lb/ton of lime in Condition 1.a. 4 Compliance demonstration is required for PM10 lb/hr limit as specified in Condition 1.a.

Linwood Mining & Minerals Corporation 4 Lime Kilns (EP LP-4) Page 4 of 9 Davenport, Iowa 73-A-219-S8 2. Compliance Demonstration(s) (Continued) If an initial stack test is specified in the “Compliance Demonstration Table,” the owner or the owner’s authorized agent shall demonstrate compliance with the emission limitations contained in Condition 1 within the applicable time period specified below:


• Test shall be completed by October 1, 2020 if there is no physical modification to any emission units or control equipment.

If any additional stack testing beyond an initial test (i.e. quarterly, semi-annual, annual, etc.) is required in “Compliance Demonstration Table,” the owner or the owner’s authorized agent shall demonstrate compliance with the emission limitations contained in Condition 1 as specified in the “Compliance Demonstration Table.” See Conditions 12.A.(4) and 12.B.(5) for notification and reporting requirements. If stack testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the “Compliance Demonstration Table” unless another testing methodology is approved by the Department prior to testing. Each emissions compliance test must be approved by the Department. Unless otherwise specified by the Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs shall apply for compliance, unless otherwise indicated by the Department. Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.




Linwood Mining & Minerals Corporation 4 Lime Kilns (EP LP-4) Page 5 of 9 Davenport, Iowa 73-A-219-S8 The following emission units exhaust through this emission point:

Emission Unit Maximum Capacity 1st set of Control Equipment 2nd Set of Control

Equipment Dry Rotating Kiln (Kiln #1) 5 tons of lime/hr Production cyclones C1, C2, C3, C4

Limestone Mining

Tunnel (CE TL1)

Dry Rotating Kiln (Kiln #2) 5 tons of lime/hr Production cyclones C1, C2, C3, C4 Preheater Lime Kiln (Kiln #3) 8.75 tons of lime/hr Production cyclones C1, C2, C3, C4 Preheater Lime Kiln (Kiln #4) 21.875 tons of lime/hr C4-East, C4-West

Elevator 431 (LP-41) 50 ton/hr C3, C4 Conveyor 446 (LP-42) 50 ton/hr C3, C4

West Kiln Run Tank 442 (LP-50) 900 Tons C3, C4 East kiln Run Tank 443 (LP-51) 900 Tons C3, C4


A. New Source Performance Standards (NSPS): Kiln #4 is subject to Subpart A (General Provisions, 40 CFR §60.1 – 40 CFR §60.19) and Subpart HH (Standards of Performance for Lime Manufacturing Plants, 40 CFR §60.340 – 40 CFR §60.344) of the New Source Performance Standards (NSPS).

The other emission units (Kilns #1 – #3) are of the source category for Subpart HH, but are not subject as they commenced construction prior to May 3, 1977 and have not been modified or reconstructed.




This facility is of the source category for Subpart AAAAA (National Emission Standards for Hazardous Air Pollutants for Lime Manufacturing Plants; 40 CFR §63.7080 – 40 CFR §63.7143) of the National Emission Standards for Hazardous Air Pollutants (NESHAP). However, it is not subject as the facility has conducted testing per 40 CFR §63.7142 and it has been determined the facility is an area source.



5. Operating Requirements with Associated Monitoring and Recordkeeping Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an orderly manner. The operating requirements and associated recordkeeping for this permit shall be: A. Total lime production for the plant shall be limited according to the plant annual total NOx emission limitation set forth in

Condition 1.a. and as listed in the equation in Condition 5.A.i: i. Compliance with the annual NOx limit shall be demonstrated as follows:

Calculate the monthly NOx emissions from Kilns #1 – #4: Tons of NOx emissions/month = [(tons of lime production from Kilns #1 & #2) x (EF1) + (tons of lime production from Kilns #3 & #4) x (EF2)] ÷ 2000 lb/ton Where:

EF1 = lb NOx/ton of lime produced for the combined exhaust from kilns #1 and #2. The combined exhaust shall be used to purge the tunnel at least 12 hours before conducting the stack test, and the lime produced during the test period shall be recorded. EF2 = lb NOx/ton of lime produced for the combined exhaust from kilns #3 and #4. The combined exhaust


shall be used to purge the tunnel at least 12 hours before conducting the stack test, and the lime produced during the test period shall be recorded.

ii. Calculate the twelve (12) month rolling total NOx emissions for each month of operation. B. The owner or operator of Kiln #4 shall install, calibrate, maintain, and operate a device for measuring the mass rate of

stone feed to Kiln #4. The measuring device used must be accurate to within + 5% of the mass rate over its operating range pursuant to NSPS Subpart HH [40 CFR §60.343(d)].

C. The owner or operator of the facility (plant number 82-01-015) shall either 1. Install, calibrate, maintain, and operate a device for measuring the mass rate of lime products from Kilns #1, #2, #3,

and #4. The measuring device used must be accurate to within + 5% of the mass rate over its operating range or 2. In lieu of installing a belt scale on all four (4) kilns, record the total production for Kilns 1 – 3 and the total

production for Kiln 4 and use the following formula to demonstrate compliance with the NOx limit: Tons of NOx emissions/month = [(tons of lime production from Kilns #1, #2, & #3) x (EF3) + (tons of lime

production from Kiln #4)x(EF2)] ÷ 2000 lb/ton Where:

EF3 = lb NOx/ton of lime produced for the combined exhaust from kilns #1, #2, and #3. The combined exhaust shall be used to purge the tunnel at least 12 hours before conducting the stack test, and the lime produced during the test period shall be recorded.

D. If the facility (plant number 82-01-015) intends on changing the method of demonstrating compliance with either the NOx emission limit or the opacity monitoring requirements of Condition 6, the facility shall inform (in writing) the Compliance Supervisor of the Air Quality Bureau and the Field Office of its intentions thirty (30) days prior to making the change.

E. The emission units listed in this permit are limited to coal, petroleum coke, natural gas, and landfill gas as fuels. F. The owner or operator shall complete stack design and installation by April 1, 2020.

i. The owner or operator shall maintain a record of the date when the stack (EP LP-4) was installed.

6. Continuous Emission Monitoring Systems (CEMS) The facility (plant number 82-01-015) shall either:

• Install, calibrate, maintain, and operate a continuous emission monitoring system (CEMS) for measuring the opacity of the emissions discharged to the atmosphere and record the output of the system for all periods when Kiln #4 is in operation in accordance with the New Source Performance Standards (NSPS) Subpart HH (Standards of Performance for Lime Manufacturing Plants). The system shall be designed to meet the 40 CFR 60, Appendix B, Performance Specification 1 (PS1) or

• Conduct opacity monitoring for those periods when Kiln #4 is in operation per an EPA approved alternative opacity monitoring program.


8. Owner and Operator Responsibility This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point as described

Linwood Mining & Minerals Corporation 4 Lime Kilns (EP LP-4) Page 7 of 9 Davenport, Iowa 73-A-219-S8 in this permit and in the application for this permit. The permit holder, owner, and operator of the facility shall assure that the installation of the equipment listed in this permit conforms to the design in the application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this emission unit(s), control equipment, or emission point without the required amended permit. Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the provisions of this permit and all other applicable requirements and that adequate operation and maintenance is provided to ensure that no condition of air pollution is created.


10. Construction








11. Excess Emissions Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good practice for minimizing emissions except when another regulation applicable to the unit or process provides otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be limited to one (1) six-minute period per one (1) hour period. An incident of excess emissions other than the above is a violation and may be subject to criminal penalties according to Iowa

Linwood Mining & Minerals Corporation 4 Lime Kilns (EP LP-4) Page 8 of 9 Davenport, Iowa 73-A-219-S8 Code 455B.146A. If excess emissions are occurring, either the control equipment causing the excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shut down within a reasonable period of time, as specified in 567 IAC 24.1. An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident [See Permit Condition 12.B.(1)]. A written report of an incident of excess emissions shall be submitted as a follow-up to all required initial reports within seven (7) days of the onset of the upset condition [See Permit Condition 12.B.(2)].
















(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, whether successful or not, postmarked no later than six (6) weeks after the completion of the test period unless other regulations provide for other notification requirements. In that case, the more stringent reporting requirement shall be met.







Fax: (319) 653-2856


14. Permit History


Testing 73-A-219 Original permit. 12/20/73 No

73-A-219-S1 95-432 Added Kiln 4. 09/16/96 Yes 73-A-219-S2 01-220 Amended emission limits and flowrate. 12/09/03 Yes 73-A-219-S3 04-041 Amended operating condition language. 02/03/04 Yes 73-A-219-S4 04-082 Amended typo in permit. 02/11/04 Yes 73-A-219-S5 10-258 Replaced multiclones on kilns 1 – 3. 08/04/10 No 73-A-219-S6 14-174 Install a new fan on EP-4 for Kilns 1, 2, 3 and 4 08/29/14 Yes

73-A-219-S7 17-118 Amend equipment list to add as-built units, Modify stack diameter, Update control equipment description 03/13/18 No

END OF PERMIT







40 I E Front Street Davenport, IA 5276 I


Same

Permitted Equipment


EUID Description Maximum Rated Capacity Control Equipment Description and ID

Multiple* Four ( 4) Rotary Lime Kilns 31.875 tons of lime per hour Multiclones & Baghouse

(CE LP-9)

*See Em1ss10n Umt hst m Condition 3




[PSP]

Project Description

Correct typo in Condition 5.D.

Stack Testin~

No

Issuance Date

03/14/19


:crFr:s2010151:03142019:1 s366:91A324s6:

Linwood Mining & Minerals Corp. 4 Lime Kilns (EP LP-9) Page 2 of 8 Davenport, Iowa 91-A-324-S6

PERMIT CONDITIONS


Pollutant lb/hr1 tons/yr2 Other Limits Reference/Basis Particulate Matter (PM) – Federal NA NA 0.30 kg/megagram3 567 IAC 23.1(2)”y”4 Particulate Matter (PM) – State NA NA NA 567 IAC 23.3(2)”a” PM10 29.95 14.06 NA NA PM2.5 NA NA NA NA Opacity NA NA 15%1, 7 567 IAC 23.1(2)”y”4 Sulfur Dioxide (SO2) NA 39.06 See Footnote 8 567 IAC 23.3(3) Nitrogen Oxides (NOX) NA 39.06 NA PSD SM Volatile Organic Compounds NA NA NA NA Carbon Monoxide (CO) NA 95.06 NA PSD SM Single HAP NA NA NA NA Total HAP NA NA NA NA

1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 0.30 kg/megagram of stone feed = 0.60 lb/ton of stone feed. 4 IAC reference to New Source Performance Standard (NSPS) Subpart HH (Standards of Performance for Lime Manufacturing Plants;

40 CFR §60.340 – 40 CFR §344). 5 The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved

into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343). 6 Emission limit for Kiln 4. This emission rate was used in Prevention of Significant Deterioration (PSD) netting calculations to keep

the addition of kiln 4 a “synthetic minor” (SM). 7 The 15% opacity standard shall apply to this emission point during all periods of Kiln 4 operation. A 0% opacity standard shall

apply to this emission point when Kiln 4 is not in operation. The facility (plant number 82-01-015) may establish a source specific opacity standard other than the 0% during the initial compliance test.

8 The sulfur dioxide limits are: • 6 lb/MMBTU when combusting only on solid fuels (i.e. coal & pet coke) • 500 ppm when combusting only gaseous fuels (i.e. natural gas & landfill gas) • The stricter of the above standards when using a combination of fuels




Time Test Method





• Within ninety (90) days of the issuance of this permit if there is no physical modification to any emission units or


control equipment. If any additional stack testing beyond an initial test (i.e. quarterly, semi-annual, annual, etc.) is required in “Compliance Demonstration Table,” the owner or the owner’s authorized agent shall demonstrate compliance with the emission limitations contained in Condition 1 as specified in the “Compliance Demonstration Table.” See Conditions 12.A.(4) and 12.B.(5) for notification and reporting requirements. If stack testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the “Compliance Demonstration Table” unless another testing methodology is approved by the Department prior to testing. Each emissions compliance test must be approved by the Department. Unless otherwise specified by the Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs shall apply for compliance, unless otherwise indicated by the Department. Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.




Emission Unit Maximum Capacity 1st set of Control Equipment

2nd Set of Control Equipment

Dry Rotating Kiln (Kiln #1) 5 tons of lime/hr Multiclone (CE MC1) Baghouse (CE LP-9)

Dry Rotating Kiln (Kiln #2) 5 tons of lime/hr Multiclone (CE MC2) Preheater Lime Kiln (Kiln #3) 8.75 tons of lime/hr Multiclone (CE MC3) Preheater Lime Kiln (Kiln #4) 21.875 tons of lime/hr Multiclone (CE MC4)

Linwood Mining & Minerals Corp. 4 Lime Kilns (EP LP-9) Page 4 of 8 Davenport, Iowa 91-A-324-S6 4. Federal Standards

A. New Source Performance Standards (NSPS): Kiln #4 is subject to Subpart A (General Provisions, 40 CFR §60.1 – 40 CFR §60.19) and Subpart HH (Standards of Performance for Lime Manufacturing Plants, 40 CFR §60.340 – 40 CFR §60.344) of the New Source Performance Standards (NSPS).

The other emission units (Kilns #1 – #3) are of the source category for Subpart HH, but are not subject as they commenced construction prior to May 3, 1977 and have not been modified or reconstructed.



B. National Emission Standards for Hazardous Air Pollutants (NESHAP): This facility is of the source category for Subpart AAAAA (National Emission Standards for Hazardous Air Pollutants for Lime Manufacturing Plants; 40 CFR §63.7080 – 40 CFR §63.7143) of the National Emission Standards for Hazardous Air Pollutants (NESHAP). However, it is not subject as the facility has conducted testing per 40 CFR §63.7142 and it has been determined the facility is an area source.



A. Operation through this emission point shall not exceed 876 hours per year on a rolling twelve-month total. i. Operator personnel shall maintain a log of baghouse usage on-site. This tabulation shall include hours of

usage per day, per month, and per year. Annual hours of operation shall be determined on a rolling-12-month total.

B. The operation of kilns 1, 2, 3, and 4 shall be operated in accordance with all conditions set forth in permit number 73-A-219-S1.

C. This emission point is limited to the following operating scenarios: i. Any of the four (4) kilns operating individually.

ii. Kilns 3 & 4. iii. Kilns 1, 2, and 3. iv. Kilns 1, 2, and 4. v. Kilns 1 & 4.

vi. Kilns 2 & 4. vii. Kilns 1 & 3.

viii. Kilns 2 & 3. ix. Kilns 1 & 2.

D. The following operating limits are set forth in lieu of the continuous opacity monitoring requirements established by NSPS Subpart HH. Should the owner or operator elect to install a COM in accordance with 60 CFR §60.343, these operating limits shall be disregarded.

i. Should the emissions from kiln #4 be routed to the LP-9 baghouse for more than 876 hours in any consecutive twelve (12) month period, a COM shall be installed and certified on the baghouse within ninety (90) days of exceeding this time limit.

ii. A log shall be maintained indicating the beginning and ending dates and times that emissions from kiln #4 are routed to the LP-9 baghouse. Baghouse operating parameters, such as pressure drop, shall be recorded daily as an indicator of baghouse operation.

iii. Visible emission observations in accordance with Method 9 shall be taken by a certified observer for at least three six (6) minute periods each day that emissions from kiln #4 are routed to the LP-9 baghouse.

iv. The date, time,and results of the visible emission observations described in item D.iii. above shall be recorded.


v. The visible emission observations described above (bulleted item 3 in Condition 5.D.iii) above shall be initiated at random times during each day that emissions from kiln #4 are routed to the LP-9 baghouse.

vi. In the event that the average opacity during a six (6) minute period is greater than 15%, visible emission observations in accordance with Method 9 shall continue to be taken and recorded until such time that the average opacity of a six (6) minute period is below 15%.

vii. Reports of excess emissions, including the information specified in 40 CFR 60.7(c), shall be submitted semiannually. For purposes of this report, periods of excess emissions that shall be reported are defined as all six (6) minute periods during which the average opacity is greater than 15%.

E. The following operating condition monitoring is set forth in lieu of the continuous opacity monitoring requirements established by NSPS Subpart HH. Should the owner or operator elect to install a COM in accordance with 60 CFR §60.343, these recordkeeping requirements shall be disregarded.

i. A log shall be maintained indicating the beginning and ending dates and times that emissions from kiln #4 are routed to the LP-9 baghouse. Baghouse operating parameters, such as pressure drop, shall be recorded daily as an indicator of baghouse operation.

ii. Visible emission observation in accordance with Method 9 shall be taken by a certified observer for at least three six (6) minute periods each day that emissions from kiln #4 are routed to the LP-9 baghouse.

iii. The date, time, and results of the visible emission observations required above (bulleted item 3 in Condition 5.D.iii), shall be recorded.

iv. Reports of excess emissions, including the information specified in 40 CFR 60.7(c), shall be submitted semiannually.

6. Continuous Emission Monitoring Systems (CEMS) Continuous emission monitoring shall not be required at this time. In lieu of operating a COMS, owner or operator shall comply with permit conditions 5D and 5E. The Department reserves the right to require the installation, calibration, maintenance, and operation of a CEMS in the future as needed (i.e. in the event the applicant requests an increase in hours of operation).



Linwood Mining & Minerals Corp. 4 Lime Kilns (EP LP-9) Page 6 of 8 Davenport, Iowa 91-A-324-S6 9. Transferability Unless the equipment is portable, this permit is not transferable from one location to another or from one piece of equipment to another. See Condition 12.A.(2) for notification requirements for relocating portable equipment (567 IAC 22.3(3)“f”).

10. Construction









Linwood Mining & Minerals Corp. 4 Lime Kilns (EP LP-9) Page 7 of 8 Davenport, Iowa 91-A-324-S6 12. Notification, Reporting, and Recordkeeping






















Fax: (319) 653-2856


14. Permit History


Testing 91-A-324 91-229 Original permit. 12/26/91 No

91-A-324-S1 96-711 Added Kiln 4. 07/17/97 Yes 91-A-324-S2 98-059 Amended PM10 allowable. 03/25/98 Yes 91-A-324-S3 03-341 Amended operating conditions. 09/24/03 No 91-A-324-S4 01-220 Amended SO2 limit. 12/09/03 No 91-A-324-S5 10-258 Replaced multiclones on kilns 1 – 3. 08/04/10 No

END OF PERMIT



Plaut Number: 82-01-015






Permitted Equipment



EUID Description

LP-21 Kilns Solid Fuel Conveyor 1

LP-25 Kilns Solid Fuel Tank



70 TPH; 300 Tons Per day of Solid Fuel

300 Tons Per day of Solid Fuel


None

None



18-366 Increase bin throughput

[PSP]

Stack Issuance Testin!! Date

No 03/14/19


:crFr:s20101 s1:031420 I 9:t 8366: t 7 A494St:

Linwood Mining & Minerals Corp. Kilns Solid Fuel Conveyor and Tank (EP LP-24) Page 2 of 7 Davenport, Iowa 17-A-494-S1

PERMIT CONDITIONS





5 PM emissions limit was requested by the permittee to restrict PTE. 6 The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved





Time Test Method







Linwood Mining & Minerals Corp. Kilns Solid Fuel Conveyor and Tank (EP LP-24) Page 3 of 7 Davenport, Iowa 17-A-494-S1 2. Compliance Demonstration(s) (Continued) Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.


Parameter Value Stack Height (feet from the ground) 70 Discharge Style Vertical Unobstructed Stack Outlet Dimensions (inches) 32 by 32 Exhaust Temperature (oF) Ambient Exhaust Flowrate (scfm) 11.7



A. New Source Performance Standards (NSPS): The facility is of the source type subject to the New Source Performance Standard (NSPS), Subpart Y, Standards of Performance for Coal Preparation and Processing Plants. These units are not subject to the subpart as the facility does not process more than 200 tons of coal per day.





Linwood Mining & Minerals Corp. Kilns Solid Fuel Conveyor and Tank (EP LP-24) Page 4 of 7 Davenport, Iowa 17-A-494-S1 5. Operating Requirements with Associated Monitoring and Recordkeeping Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an orderly manner. The operating requirements and associated recordkeeping for this permit shall be:

A. The maximum amount of solid fuel conveyed through the conveyor shall not exceed 70 tons per hour. i. For each hour, the owner or operator shall maintain records of the amount of solid fuel conveyed through the

conveyor in tons. ii. The owner or operator shall maintain hourly records of the solid fuel conveyed in tons.

B. The maximum amount of solid fuel conveyed through the conveyor shall not exceed 300 tons per day. The maximum amount of solid fuel stored in the tank shall not exceed 300 tons per day.

i. For each day, the owner or operator shall maintain records of the amount of solid fuel conveyed through the conveyor in tons and stored in the tank in tons.

ii. The owner or operator shall maintain daily records of the solid fuel conveyed and stored in tons. C. The owner or operator shall check for visible emissions from Solid Fuel Conveyor (EP LP-24) once per day at a time

while Solid Fuel Conveyor (EP LP-24) is in operation. The owner or operator shall record the date and time of the observation and the presence or absence of visible emissions. If the owner or operator observes visible emissions from Solid Fuel Conveyor (EP LP-24), the owner or operator shall investigate the emission unit or operations associated with the emission unit and make corrections to the associated operations or equipment. The owner or operator shall maintain a record of all corrective actions taken. This requirement shall not apply on the days that Solid Fuel Conveyor (EP LP-24) is not in operation.




Linwood Mining & Minerals Corp. Kilns Solid Fuel Conveyor and Tank (EP LP-24) Page 5 of 7 Davenport, Iowa 17-A-494-S1 9. Transferability Unless the equipment is portable, this permit is not transferable from one location to another or from one piece of equipment to another. See Condition 12.A.(2) for notification requirements for relocating portable equipment (567 IAC 22.3(3)“f”).

10. Construction









Linwood Mining & Minerals Corp. Kilns Solid Fuel Conveyor and Tank (EP LP-24) Page 6 of 7 Davenport, Iowa 17-A-494-S1 12. Notification, Reporting, and Recordkeeping


















Linwood Mining & Minerals Corp. Kilns Solid Fuel Conveyor and Tank (EP LP-24) Page 7 of 7 Davenport, Iowa 17-A-494-S1




Fax: (319) 653-2856


14. Permit History


Testing 17-A-494 17-118 Permit as-built equipment & Establish PM10 Limits 03/13/18 No

END OF PERMIT


Permit Number: 88-A-220-SS







Permitted Equipment



!

EUID Description ' i

LP-7 Lime Kiln Dust Tank and

Loadont* -*See Emission Unit list in Condition 3



1050 tons of lime, limestone and flyash; Loadout capacity: 240 tons per 3-hours


Baghonse (CE LP-7)



Number 15-457 Route LP-7L to LP-7 baghouse

[PSP]

Stack Issuance Testine: Date

No 03/13/18

Under the Direction of the Director of the Department ofNatural Resources

ICPFP1820 I 0151103132018115457188A220S5I

Linwood Mining & Minerals Corp. Lime Kiln Dust Tank and Loadout (EP LP-7) Page 2 of 7 Davenport, Iowa 88-A-220-S5

PERMIT CONDITIONS










Time Test Method







Linwood Mining & Minerals Corp. Lime Kiln Dust Tank and Loadout (EP LP-7) Page 3 of 7 Davenport, Iowa 88-A-220-S5 2. Compliance Demonstration(s) (Continued) Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.










Linwood Mining & Minerals Corp. Lime Kiln Dust Tank and Loadout (EP LP-7) Page 4 of 7 Davenport, Iowa 88-A-220-S5 5. Operating Requirements with Associated Monitoring and Recordkeeping Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an orderly manner. The operating requirements and associated recordkeeping for this permit shall be:

A. The maximum amount of product loaded out using lime kiln dust loadout shall not exceed 240 tons per 3-hr period. i. The owner or operator shall maintain records of the amount of product loaded out every 3-hours, in tons.



C. The differential pressure drop across Baghouse (CE LP-7) shall be maintained between 2 and 10 inches of

water column, based on 1-hr block average. i. The owner or operator shall properly operate and maintain equipment to monitor differential pressure drop







8. Owner and Operator Responsibility This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point as described in this permit and in the application for this permit. The permit holder, owner, and operator of the facility shall assure that the installation of the equipment listed in this permit conforms to the design in the application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this emission unit(s), control equipment, or emission point without the required amended permit.

Linwood Mining & Minerals Corp. Lime Kiln Dust Tank and Loadout (EP LP-7) Page 5 of 7 Davenport, Iowa 88-A-220-S5 Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the provisions of this permit and all other applicable requirements and that adequate operation and maintenance is provided to ensure that no condition of air pollution is created.


10. Construction








11. Excess Emissions Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good practice for minimizing emissions except when another regulation applicable to the unit or process provides otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be limited to one (1) six-minute period per one (1) hour period. An incident of excess emissions other than the above is a violation and may be subject to criminal penalties according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within a reasonable period of time, as specified in 567 IAC 24.1.

Linwood Mining & Minerals Corp. Lime Kiln Dust Tank and Loadout (EP LP-7) Page 6 of 7 Davenport, Iowa 88-A-220-S5 An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident [See Permit Condition 12.B.(1)]. A written report of an incident of excess emissions shall be submitted as a follow-up to all required initial reports within seven (7) days of the onset of the upset condition [See Permit Condition 12.B.(2)].





















Linwood Mining & Minerals Corp. Lime Kiln Dust Tank and Loadout (EP LP-7) Page 7 of 7 Davenport, Iowa 88-A-220-S5



Fax: (319) 653-2856


14. Permit History


Testing 88-A-220 87-151 Original Permit. 12/29/88 No

88-A-220-S1 97-191 Revised PM10 Emission Limit for SIP. 6/6/97 Yes 88-A-220-S2 97-478 Changed the Fan Flowrate on Baghouse. 2/16/98 Yes

88-A-220-S3 06-132 Decrease Stack Height due to Partial Tank Collapse and Remove NSPS Subpart OOO Requirements. 7/14/06 No

88-A-220-S4 15-175 Replace baghouse; replace kiln dust tank lid. 06/18/15 Yes

END OF PERMIT





Contact Pe1·son: Darin Osland Environmental Manager




Permitted Equipment



EUID Description

Multiple* #4 Lime Truck Loadout System




90 tons per hour

Control Equipment Description and ID Baghouse (CE LP-8)


Project Number

19-130

[PSP]

Project Description Stack Issuance Testing Date

Correct exhaust flowrate based on recent stack test No 07/02/19


:cPFP:s20 IO I s1:01022019:19 I3o:ssA22 IS Io:

Linwood Mining & Minerals Corp. #4 Lime Truck Loadout System (EP LP-8) Page 2 of 8 Davenport, Iowa 88-A-221-S10

PERMIT CONDITIONS










Time Test Method





If any additional stack testing beyond an initial test (i.e. quarterly, semi-annual, annual, etc.) is required in “Compliance Demonstration Table,” the owner or the owner’s authorized agent shall demonstrate compliance with the emission limitations contained in Condition 1 as specified in the “Compliance Demonstration Table.” See Conditions 12.A.(4) and 12.B.(5) for notification and reporting requirements. If stack testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the “Compliance Demonstration Table” unless another testing methodology is approved by the Department prior to testing. Each emissions compliance test must be approved by the Department. Unless otherwise specified by the Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs shall apply for compliance, unless otherwise indicated by the Department. Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later

Linwood Mining & Minerals Corp. #4 Lime Truck Loadout System (EP LP-8) Page 3 of 8 Davenport, Iowa 88-A-221-S10 2. Compliance Demonstration(s) (Continued)

than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.




Emission Unit Maximum Capacity Tank 445 (LP-8a) 500 tons of Lime Tank 446 (LP-8b) 500 tons of Lime Tank 447 (LP-8c) 500 tons of Lime Crusher (LP-8d) 50 tons of Lime /hour Screen (LP-8e) 50 tons of Lime /hour

Briquetter (LP-8f) 5 tons of Lime /hour Pneumatic Blower System (LP-8g) 25 tons of Lime /hour

Tank 441 (LP-8h) 500 tons of Lime Scale #1 Loadout System (LP-8i) 90 tons of Lime per hour

Tank 446B (LP-8j) 200 tons of Lime

Linwood Mining & Minerals Corp. #4 Lime Truck Loadout System (EP LP-8) Page 4 of 8 Davenport, Iowa 88-A-221-S10 4. Federal Standards







A. The maximum amount of lime loaded out using the truck loadout system shall not exceed 90 tons per hour averaged over 3-hr period.


B. The stack shall be raised to 105 feet from the ground within 90 days of permit issuance.

i. The owner or operator shall maintain a record of the completion date that stack EP LP-8 was increased to 105 feet from the ground.

C. The owner or operator shall begin monitoring the differential pressure drop across the baghouse, as specified in

condition 5.D. by May 1, 2018. i. The owner or operator shall maintain a record of the commencement date of the differential pressure drop

monitoring of the control equipment.

D. The differential pressure drop across Baghouse (CE LP-8) shall be maintained between 2 and 10 inches of water column, based on 1-hr block average.


ii. The owner or operator shall collect and record the pressure drop across Baghouse (CE LP-8), in inches of water, at a minimum of once every 2 minutes. Calculate and record the hourly average for all readings for each 1-hour block. If the average hourly pressure drop across Baghouse (CE LP-8) falls outside the range specified in Condition 5.D., the owner or operator shall investigate Baghouse (CE LP-8) and make corrections to the baghouse. The owner or operator shall maintain a record of all corrective actions taken. This requirement shall not apply on the days that Baghouse (CE LP-8) are not in operation.

E. The owner or operator shall develop an operating and maintenance plan for the Baghouse (CE LP-8), including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance.


Linwood Mining & Minerals Corp. #4 Lime Truck Loadout System (EP LP-8) Page 5 of 8 Davenport, Iowa 88-A-221-S10 6. Continuous Emission Monitoring Systems (CEMS) Continuous emission monitoring is not required by this permit at this time.




10. Construction





B. Changes to Plans and Specifications: The owner or operator shall amend this permit or amendment prior to startup of the equipment if:


(1) Any changes are made to the final plans and specifications submitted for the proposed project; or (2) This permit becomes void. Changes to the final plans and specification shall include changes to plans and specifications for permitted equipment and control equipment and the specified operation thereof.




















(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, whether successful or not, postmarked no later than six (6) weeks after the completion of the test period unless other regulations provide for other notification requirements. In that case, the more stringent reporting requirement shall be met.







Fax: (319) 653-2856


Linwood Mining & Minerals Corp. #4 Lime Truck Loadout System (EP LP-8) Page 8 of 8 Davenport, Iowa 88-A-221-S10 14. Permit History


Testing 88-A-221 87-151 Original Permit 12/29/88 No

88-A-221-S1 97-191 Revised PM10 Allowable for SIP 06/06/97 Yes 88-A-221-S2 97-478 Amended Fan Flowrate 02/16/98 Yes 88-A-221-S3 00-622 Listed All Emission Units in System 06/20/02 Yes 88-A-221-S4 02-231 Amended Stack Characteristics 09/24/03 No 88-A-221-S5 01-220 Amend NSPS Conversion in Condition 10 12/09/03 No 88-A-221-S6 06-204 Removed Reference to NSPS Subpart OOO 05/01/06 No 88-A-221-S7 10-063 Update Stack Characteristics 04/15/10 No 88-A-221-S8 10-401 Add Emission Unit 10/26/10 No 88-A-221-S9 17-118 Amend equipment list and increase stack height for modeling 03/13/18 Yes

END OF PERMIT







40 I E Front Street Davenpmt, IA 5276 I

Same

Permitted Equipment

Emission Point ID: BL0I


EUID Description Maximum Rated Caoacitv

BL0l East Barge Loadout 400 Tons Per Hour

Equipment Location: 401 E Front Street Davenpo1t, IA 52761


Windscreen and Water Suppression (CE BL0!)



[PSP]

Project Description Stack Issuance Testin!! Date

Change operating hours and increase throughput No 03/14/19


:crFr:s20101s1:03142019:1s366:02A168s2:

Linwood Mining & Minerals Corp. East Barge Loadout (EP BL01) Page 2 of 7 Davenport, Iowa 02-A-168-S2

PERMIT CONDITIONS


Pollutant lb/hr1 tons/yr2 Other Limits Reference/Basis Particulate Matter (PM) – State 0.2 4 NA 0.1 gr/dscf 567 IAC 23.3(2)”a” PM10 0.105 5 NA NA NA PM2.5 NA NA NA NA Opacity-Conveyor Stacker NA NA 10% 6 567 IAC 23.1(2)”bbb”3

1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 IAC reference to NSPS Subpart OOO (Standards of Performance for Nonmetallic Mineral Processing Plants; 40 CFR §60.670 – 40

CFR §60.676). 4 PM emissions limit was added to restrict PTE. 5 The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved

into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343). 6 Limit established per Table 3 of Subpart OOO Part 60.




Time Test Method







Linwood Mining & Minerals Corp. East Barge Loadout (EP BL01) Page 3 of 7 Davenport, Iowa 02-A-168-S2 2. Compliance Demonstration(s) (Continued) Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.


Parameter Value Stack Height (feet from the ground) NA Discharge Style NA Stack Outlet Dimensions (inches) NA Exhaust Temperature (oF) NA Exhaust Flowrate (scfm) NA



A. New Source Performance Standards (NSPS): The facility is of the source type subject to the New Source Performance Standard (NSPS), Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants and the conveyor stacker is subject to Subpart OOO per 40 CFR §60.670 – 40 CFR §60.676.




Linwood Mining & Minerals Corp. East Barge Loadout (EP BL01) Page 4 of 7 Davenport, Iowa 02-A-168-S2 5. Operating Requirements with Associated Monitoring and Recordkeeping Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an orderly manner. The operating requirements and associated recordkeeping for this permit shall be:

A. The maximum combined throughput of emission units BL01 and BL02 shall not exceed 8,500 tons per calendar day. i. The owner or operator shall maintain records of the total throughput of BL01 and BL02 for each calendar

day in tons. B. Emission units BL01 and BL02 shall operate only between March 1 and December 31. C. Emission units BL01 and BL02 shall not operate more than 6 days per calendar week and between hours of 6 am and

9 pm for each calendar day. i. The owner or operator shall maintain records detailing the date and operation times (start and stop) for BL01

and BL02. D. The owner or operator shall operate water suppression system when visible emissions from processing units

associated with East barge Loadout are observed.

E. The owner or operator shall check for visible emissions each time the East barge loadout is used. This requirement shall not apply on the days that processing units associated with East barge Loadout are not in operation.

i. The owner or operator shall record the date and time of the observation and the presence or absence of visible emissions.

ii. If the owner or operator observes visible emissions during barge loading, the owner or operator shall investigate the emission unit, or the operations associated with the emission unit and make corrections to the associated operations or equipment. The owner or operator shall maintain a record of all corrective actions taken.

F. The owner or operator shall develop an operating and maintenance plan for the water suppression system, including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance.

i. The owner or operator shall maintain a record of all inspections and maintenance and any action resulting from the inspection and maintenance of the water suppression system.

G. The owner or operator shall install the water suppression system on East barge loadout and West barge loadout by October 1, 2018.

i. The owner or operator shall maintain a record of the completion date that the water suppression was installed on site.



8. Owner and Operator Responsibility This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point as described in this permit and in the application for this permit. The permit holder, owner, and operator of the facility shall assure that the installation of the equipment listed in this permit conforms to the design in the application (i.e. type, maximum rated capacity,

Linwood Mining & Minerals Corp. East Barge Loadout (EP BL01) Page 5 of 7 Davenport, Iowa 02-A-168-S2 etc.). No person shall construct, install, reconstruct or alter this emission unit(s), control equipment, or emission point without the required amended permit. Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the provisions of this permit and all other applicable requirements and that adequate operation and maintenance is provided to ensure that no condition of air pollution is created.


10. Construction








11. Excess Emissions Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good practice for minimizing emissions except when another regulation applicable to the unit or process provides otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be limited to one (1) six-minute period per one (1) hour period. An incident of excess emissions other than the above is a violation and may be subject to criminal penalties according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within a reasonable period of time, as specified

Linwood Mining & Minerals Corp. East Barge Loadout (EP BL01) Page 6 of 7 Davenport, Iowa 02-A-168-S2 in 567 IAC 24.1. An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident [See Permit Condition 12.B.(1)]. A written report of an incident of excess emissions shall be submitted as a follow-up to all required initial reports within seven (7) days of the onset of the upset condition [See Permit Condition 12.B.(2)].




















information being submitted: change in ownership (Air Quality Bureau Records Center), permit correspondence

Linwood Mining & Minerals Corp. East Barge Loadout (EP BL01) Page 7 of 7 Davenport, Iowa 02-A-168-S2

(Construction Permit Supervisor), stack testing correspondence (Stack Test Coordinator), and reports and notifications (Compliance Unit Supervisor and DNR Field Office). The addresses are:



Fax: (319) 653-2856


14. Permit History


Testing 02-A-168 02-016 “As-built” permit. 6/20/02 Yes

02-A-168-S1 18-017 Correct maximum capacity; add water suppression; add operating restrictions 09/06/18 No

END OF PERMIT








Emission Point ID: BL02

Same

Permitted Equipment


EUID Description Maximum Rated Capacity Control Equipment Description and ID

EUBL02 West Barge Loadout 650 Tons Per Hour


Windscreen and Water Suppression (CEBL02)


Project i ' Number i

Project Description

18-366 i Change operating hours and increase throughput

[PSP]

Stack Testing

No

Issuance Date

03/14/19

Under the Direction of the Director of the Depattment of Natural Resources

:cPFP:szo Io I s1:03142019: 1 s366:02A t 69sz:

Linwood Mining & Minerals Corp. West Barge Loadout (EP BL02) Page 2 of 7 Davenport, Iowa 02-A-169-S2

PERMIT CONDITIONS


Pollutant lb/hr1 tons/yr2 Other Limits Reference/Basis Particulate Matter (PM) – State 0.325 4 NA 0.1 gr/dscf 567 IAC 23.3(2)”a” PM10 0.17 5 NA NA NA PM2.5 NA NA NA NA Opacity-Conveyor Stacker NA NA 10% 6 567 IAC 23.1(2)”bbb”3

1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 IAC reference to NSPS Subpart OOO (Standards of Performance for Nonmetallic Mineral Processing Plants; 40 CFR §60.670 – 40

CFR §60.676). 4 PM emissions limit was added to restrict PTE. 5 The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved

into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343). 6 Limit established per Table 3 of Subpart OOO Part 60.




Time Test Method







Linwood Mining & Minerals Corp. West Barge Loadout (EP BL02) Page 3 of 7 Davenport, Iowa 02-A-169-S2 2. Compliance Demonstration(s) (Continued) Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.





A. New Source Performance Standards (NSPS): The facility is of the source type subject to the New Source Performance Standard (NSPS), Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants. The conveyor stacker is subject to Subpart OOO per 40 CFR §60.670 – 40 CFR §60.676.




Linwood Mining & Minerals Corp. West Barge Loadout (EP BL02) Page 4 of 7 Davenport, Iowa 02-A-169-S2 5. Operating Requirements with Associated Monitoring and Recordkeeping Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an orderly manner. The operating requirements and associated recordkeeping for this permit shall be:

A. The maximum combined throughput of emission units BL01 and BL02 shall not exceed 8,500 tons per calendar day. i. The owner or operator shall maintain records of the total throughput of BL01 and BL02 for each calendar

day in tons. B. Emission units BL01 and BL02 shall operate only between March 1 and December 31. C. Emission units BL01 and BL02 shall not operate more than 6 days per calendar week and between hours of 6 am and

9 pm for each calendar day. i. The owner or operator shall maintain records detailing the date and operation times (start and stop) for BL01

and BL02. D. The owner or operator shall operate water suppression system when visible emissions from processing units

associated with West barge Loadout are observed.

E. The owner or operator shall check for visible emissions each time the West barge loadout is used. This requirement shall not apply on the days that processing units associated with West barge Loadout are not in operation.


ii. If the owner or operator observes visible emissions during barge loading, the owner or operator shall investigate the emission unit, or the operations associated with the emission unit and make corrections to the associated operations or equipment. The owner or operator shall maintain a record of all corrective actions taken.

F. The owner or operator shall develop an operating and maintenance plan for the water suppression system, including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance.


G. The owner or operator shall install the water suppression system on East barge loadout and West barge loadout by October 1, 2018.

i. The owner or operator shall maintain a record of the completion date that the water suppression was installed on site.



8. Owner and Operator Responsibility This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point as described in this permit and in the application for this permit. The permit holder, owner, and operator of the facility shall assure that the installation of the equipment listed in this permit conforms to the design in the application (i.e. type, maximum rated capacity,

Linwood Mining & Minerals Corp. West Barge Loadout (EP BL02) Page 5 of 7 Davenport, Iowa 02-A-169-S2 etc.). No person shall construct, install, reconstruct or alter this emission unit(s), control equipment, or emission point without the required amended permit. Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the provisions of this permit and all other applicable requirements and that adequate operation and maintenance is provided to ensure that no condition of air pollution is created.


10. Construction








11. Excess Emissions Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good practice for minimizing emissions except when another regulation applicable to the unit or process provides otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be limited to one (1) six-minute period per one (1) hour period. An incident of excess emissions other than the above is a violation and may be subject to criminal penalties according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within a reasonable period of time, as specified

Linwood Mining & Minerals Corp. West Barge Loadout (EP BL02) Page 6 of 7 Davenport, Iowa 02-A-169-S2 in 567 IAC 24.1. An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident [See Permit Condition 12.B.(1)]. A written report of an incident of excess emissions shall be submitted as a follow-up to all required initial reports within seven (7) days of the onset of the upset condition [See Permit Condition 12.B.(2)].





















Linwood Mining & Minerals Corp. West Barge Loadout (EP BL02) Page 7 of 7 Davenport, Iowa 02-A-169-S2

(Construction Permit Supervisor), stack testing correspondence (Stack Test Coordinator), and reports and notifications (Compliance Unit Supervisor and DNR Field Office). The addresses are:



Fax: (319) 653-2856


14. Permit History


Testing 02-A-169 02-016 “As-built” permit. 6/20/02 Yes

02-A-169-S1 18-017 Correct maximum capacity; add water suppression; add operating restrictions 09/06/18 No

END OF PERMIT






563-324-193 l [email protected]


Emission Point ID: CC-3

Same

Permitted Equipment


EUID Description Maximum Rated Capacity Control Equipment

Descrintion and ID

CC-3 Calcium Loadout * 160 tons of limestone Baghouse (CE CC-3)

! *See Em1ss1on Umt hst m Condition 3


products


Project Project Description Number 16-026 Permit baghouse replacement

[PSP]


No 03/13/18

'


:cPFP:s2010151:0J 13201 s: 16026:ssA2 l 8S6:

Linwood Mining & Minerals Corp. Calcium Loadout (EP CC-3) Page 2 of 7 Davenport, Iowa 88-A-218-S6

PERMIT CONDITIONS


Pollutant lb/hr1 tons/yr2 Other Limits Reference/Basis Particulate Matter (PM) – State NA NA 0.02 gr/dscf 567 IAC 23.1(2)”bbb” PM10 0.36 3 NA NA NA PM2.5 NA NA NA NA Opacity NA NA 7%4 567 IAC 23.1(2)“bbb”5

1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved

into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343). 4 Limit established per Table 3 of Subpart OOO Part 60. 5 Iowa adoption of 40 CFR Part 60 Subpart OOO.




Time Test Method







Linwood Mining & Minerals Corp. Calcium Loadout (EP CC-3) Page 3 of 7 Davenport, Iowa 88-A-218-S6 2. Compliance Demonstration(s) (Continued) Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.


Parameter Value Stack Height (feet from the ground) 37 Discharge Style Vertical Unobstructed Stack Outlet Dimensions (inches) 17 Exhaust Temperature (oF) Ambient Exhaust Flowrate (scfm) 1,500


Emission Unit Maximum Capacity Control Equipment Calcium Railcar Loadout (CC-3) 160 tons of limestone per hour

Baghouse (CE CC-3) North/South Belt (CC-3A) 160 tons of limestone per hour East/West Belt (CC-3B) 160 tons of limestone per hour

Calcium Truck Loadout (CC-3C) 85 tons of limestone per hour


A. New Source Performance Standards (NSPS): These emission units are subject to NSPS Subparts A (General Provisions; 40 CFR §60.1 – 40 CFR §60.19) and OOO (Standards of Performance for Nonmetallic Mineral Processing Plants; 40 CFR §60.670 – 40 CFR §60.676).







A. The maximum amount of product loaded out using the Calcium Railcar loadout shall not exceed 160 tons per hour averaged over 3-hr period.

i. For each hour, the owner or operator shall maintain records of the amount of product loaded out in tons. ii. The owner or operator shall maintain records of the 3-hour average the amount of product loaded out in tons.

B. The maximum amount of product loaded out using the Calcium Truck loadout shall not exceed 85 tons per hour

averaged over 3-hr period. i. For each hour, the owner or operator shall maintain records of the amount of product loaded out in tons.

ii. The owner or operator shall maintain records of the 3-hour average the amount of product loaded out in tons. C. The owner or operator shall begin monitoring the differential pressure drop across the baghouse, as specified in


monitoring of the control equipment.

D. The differential pressure drop across Baghouse (CE CC-3) shall be maintained between 2 and 10 inches of water column, based on 1-hr block average.

i. The owner or operator shall properly operate and maintain equipment to monitor differential pressure drop across Baghouse (CE CC-3). The monitoring devices and any recorders shall be installed, calibrated, operated and maintained in accordance with the manufacturer’s recommendations, instructions and operating manuals or per written facility specific operation and maintenance plan.

ii. The owner or operator shall collect and record the pressure drop across Baghouse (CE CC-3), in inches of water, at a minimum of once every 2 minutes. Calculate and record the hourly average for all readings for each 1-hour block. If the average hourly pressure drop across Baghouse (CE CC-3) falls outside the range specified in Condition 5.D., the owner or operator shall investigate Baghouse (CE CC-3) and make corrections to the baghouse. The owner or operator shall maintain a record of all corrective actions taken. This requirement shall not apply on the days that Baghouse (CE CC-3) are not in operation.

E. The owner or operator shall develop an operating and maintenance plan for the Baghouse (CE CC-3), including a

preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance.

i. The owner or operator shall maintain a record of all inspections and maintenance and any action resulting from the inspection and maintenance of the Baghouse (CE CC-3).


7. Department Review This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply. This permit is issued based on information submitted by the applicant. Any misinformation, false statements or misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. No review has been undertaken on the engineering aspects of the equipment or control equipment other than the potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, installation, maintenance or

Linwood Mining & Minerals Corp. Calcium Loadout (EP CC-3) Page 5 of 7 Davenport, Iowa 88-A-218-S6 operation of the proposed equipment.



10. Construction








11. Excess Emissions Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are not a violation

Linwood Mining & Minerals Corp. Calcium Loadout (EP CC-3) Page 6 of 7 Davenport, Iowa 88-A-218-S6 of the emission standard if it is accomplished expeditiously and in a manner consistent with good practice for minimizing emissions except when another regulation applicable to the unit or process provides otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be limited to one (1) six-minute period per one (1) hour period. An incident of excess emissions other than the above is a violation and may be subject to criminal penalties according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within a reasonable period of time, as specified in 567 IAC 24.1. An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident [See Permit Condition 12.B.(1)]. A written report of an incident of excess emissions shall be submitted as a follow-up to all required initial reports within seven (7) days of the onset of the upset condition [See Permit Condition 12.B.(2)].
























Fax: (319) 653-2856


14. Permit History


Testing 88-A-218 Original Permit 12/29/1988 Yes

88-A-218-S1 97-191 Revised PM10 emission limit to comply with the SIP 6/6/1997 Yes 88-A-218-S2 98-059 Revised PM10 emission limit to comply with the SIP 3/25/1998 Yes 88-A-218-S3 98-208 Changed Operating Conditions 5/8/1998 Yes 88-A-218-S4 06-071 Modify flow rate based on stack test 2/28/2006 No 88-A-218-S5 14-363 Add as-built emission units CC-3A, CC-3B, CC-3C to the

equipment list 01/20/15 No

END OF PERMIT








Same

Permitted Equipment



EUID Description Maximum Rated Capacity

Multiple* Lime Rail Loadout System


Equipment Location: 401 E Front Street Davenp011, IA 52761

100 TPH


Baghouse (CE LP-13)



Number 17-118 Add dolo loadout equipments to the loadout

[PSP]

Stack Issuance Testing Date

No 03/13/ 18

Under the Direction of the Director of the Depat1ment of Natural Resources

:cPFPi820 IO I 5li03 I3201s: I 7 I I 8i02A028S5:

Linwood Mining & Minerals Corp. Lime Rail Loadout System (EP LP-13) Page 2 of 7 Davenport, Iowa 02-A-028-S5

PERMIT CONDITIONS










Time Test Method







Linwood Mining & Minerals Corp. Lime Rail Loadout System (EP LP-13) Page 3 of 7 Davenport, Iowa 02-A-028-S5 2. Compliance Demonstration(s) (Continued) Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.




Emission Unit Maximum Capacity Control Equipment Lime Rail Loadout System (LP-13) (Spout and belt#1) 100 Tons of Lime Per Hour

Baghouse (LP-13)

Lime Rail Loading Conveyor (LP-13A) 100 Tons of Lime Per Hour Tank 445 Rail Conveyor (LP-13B) 100 Tons of Lime Per Hour Tank 446 Rail Conveyor (LP-13C) 100 Tons of Lime Per Hour Tank 446 Rail Conveyor (LP-13D) 100 Tons of Lime Per Hour

Dolo to Rail Loadout Conveyor (LP-13E) 100 Tons of Lime Per Hour

Linwood Mining & Minerals Corp. Lime Rail Loadout System (EP LP-13) Page 4 of 7 Davenport, Iowa 02-A-028-S5 4. Federal Standards







A. The maximum amount of lime loaded out using the rail loadout system shall not exceed 100 tons per hour averaged over 3-hr period.


B. The stack shall be raised to 50 feet from the ground within 90 days after permit issuance. i. The owner or operator shall maintain a record of the completion date that stack EP LP-13 was raised to 50

feet from the ground. C. The owner or operator shall begin monitoring the differential pressure drop across the baghouse, as specified in


monitoring of the control equipment. D. The differential pressure drop across Baghouse (CE LP-13) shall be maintained between 2 and 10 inches of



ii. The owner or operator shall collect and record the pressure drop across Baghouse (CE LP-13), in inches of water, at a minimum of once every 2 minutes. Calculate and record the hourly average for all readings for each 1-hour block. If the average hourly pressure drop across Baghouse (CE LP-13) falls outside the range specified in Condition 5.D., the owner or operator shall investigate Baghouse (CE LP-13) and make corrections to the baghouse. The owner or operator shall maintain a record of all corrective actions taken. This requirement shall not apply on the days that Baghouse (CE LP-13) are not in operation.

E. The owner or operator shall develop an operating and maintenance plan for the Baghouse (CE LP-13), including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance.


F. The owner or operator shall complete the modification of EP LP-13 to add the Dolo to Rail Loadout Conveyor (LP-13E) by May 31, 2018.

i. The owner or operator shall maintain a record of the completion date that the Dolo to Rail Loadout Conveyor (LP-13E) was added to EP LP-13.

Linwood Mining & Minerals Corp. Lime Rail Loadout System (EP LP-13) Page 5 of 7 Davenport, Iowa 02-A-028-S5 6. Continuous Emission Monitoring Systems (CEMS) Continuous emission monitoring is not required by this permit at this time.




10. Construction





B. Changes to Plans and Specifications: The owner or operator shall amend this permit or amendment prior to startup of the equipment if: (1) Any changes are made to the final plans and specifications submitted for the proposed project; or


(2) This permit becomes void. Changes to the final plans and specification shall include changes to plans and specifications for permitted equipment and control equipment and the specified operation thereof.















B. The owner or operator shall furnish the Department with the following reports: (1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported within eight

(8) hours or at the start of the first working day following the onset of the incident. The report may be made by electronic mail, in person or by telephone.











Fax: (319) 653-2856


14. Permit History


Testing 02-A-028 01-147 Original Permit 01/11/02 Yes

02-A-028-S1 02-080 Amended Stack Characteristics 06/20/02 Yes 02-A-028-S2 03-183 Added Emission Unit 09/24/03 Yes 02-A-028-S3 06-204 Removed Reference to NSPS Subpart OOO 05/01/06 Yes 02-A-028-S4 10-401 Add Emission Unit 10/26/10 Yes

END OF PERMIT

[PSP] ¦CPFP¦8201015¦05072020¦20038¦17A488S1¦




Company: Linwood Mining & Minerals Corp Contact Person: Responsible Party:

Darin Osland Darin Osland Environmental Manager Environmental Manager 563-324-1931 563-324-1931 [email protected] [email protected] 401 E Front Street 401 E Front Street Davenport, IA 52804 Davenport, IA 52804

Permitted Equipment Emission Point ID: CC-16 Emission Unit(s) and Control Equipment:

EU ID Description Maximum Rated

Capacity

Control Equipment

Description and ID

CC-16 Loadout #6 Bins* 70 tons of limestone per hr None

*See Emission Unit list in Condition 3 Equipment Location: 401 E Front Street Davenport, IA 52804


Project

Number Project Description

Stack

Testing

Issuance

Date

20-038 Amend permit to add EU CC-19 Yes 05/07/20


Linwood Mining & Minerals Corp. Loadout #6 Bins (EP CC-16) Page 2 of 7 Davenport, Iowa 17-A-488-S1

PERMIT CONDITIONS

1. Emission Limits

The owner or operator is required to report all emissions as required by law, regardless of whether a specific emission limit has

been established in this permit. The following emission limits shall not be exceeded:

Pollutant lb/hr1 tons/yr2 Other Limits Reference/Basis

Particulate Matter (PM) – State 0.21 5 NA 0.1 gr/dscf 567 IAC 23.3(2)”a”

PM10 0.08 6 NA NA NA

PM2.5 NA NA NA NA

Opacity (CC-16; CC-17; CC-18) NA NA 10%4 567 IAC 23.1(2)” bbb”3

Opacity (CC-19) NA NA 7%4 567 IAC 23.1(2)” bbb” 3 1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 IAC reference to NSPS Subpart OOO (Standards of Performance for Nonmetallic Mineral Processing Plants; 40 CFR §60.670 – 40

CFR §60.676). 4 Limit established per Table 3 of Subpart OOO Part 60. 5 PM emissions limit was added to restrict PTE. 6 The PM 10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved




Pollutant Compliance

Methodology Frequency Test Run

Time Test Method

PM – State None NA 1 hour 40 CFR 60, Appendix A, Method 5

40 CFR 51 Appendix M Method 202

PM10 None NA 1 hour 40 CFR 51, Appendix M, 201A with 202

PM2.5 None NA 1 hour 40 CFR 51, Appendix M, 201A with 202

Opacity 1 Initial 1 hour 40 CFR 60, Appendix A, Method 9

1 Opacity test/monitoring shall be conducted per NSPS Subpart OOO (40 CFR §60.670 – 40 CFR §60.676) on CC-19 and CC-

16, CC-17, CC-18.

If an initial stack test is specified in the “Compliance Demonstration Table,” the owner or the owner’s authorized agent

shall demonstrate compliance with the emission limitations contained in Condition 1 within the applicable time period specified

below:

• Within sixty (60) days after achieving the maximum production rate and no later than one hundred eighty (180) days

after the initial startup date of the proposed equipment for the addition of new equipment or the physical modification

of existing equipment or control equipment.


control equipment.

If any additional stack testing beyond an initial test (i.e. quarterly, semi-annual, annual, etc.) is required in “Compliance

Demonstration Table,” the owner or the owner’s authorized agent shall demonstrate compliance with the emission limitations

contained in Condition 1 as specified in the “Compliance Demonstration Table.” See Conditions 12.A.(4) and 12.B.(5) for

notification and reporting requirements.

If stack testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the

“Compliance Demonstration Table” unless another testing methodology is approved by t he Department prior to testing.

Each emissions compliance test must be approved by the Department. Unless otherwise specified by the Department, each test

Linwood Mining & Minerals Corp. Loadout #6 Bins (EP CC-16) Page 3 of 7 Davenport, Iowa 17-A-488-S1 shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs s hall apply for compliance, unless

otherwise indicated by the Department.

Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the

owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later

than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the

Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the

owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the

test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements.

The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operat ed

in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the

owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated

at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to

that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity

cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or

any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.

3. Emission Point Characteristics

This emission point shall conform to the specifications listed below:

Parameter Value

Stack Height (feet from the ground) 62

Discharge Style Vertical Unobstructed

Stack Outlet Dimensions (inches) 32 x 32

Exhaust Temperature (oF) Ambient

Exhaust Flowrate (scfm) 2,178

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted emission point.

The Department recognizes that the temperature and flow rate may vary with changes in the process and ambient conditions.

If it is determined that any of the emission point characteristics above are different than the values stated, the owner or operator

shall submit a request either by electronic mail or written correspondence to the Department within thirty (30) days of the

discovery to determine if a permit amendment is required, or submit a permit application requesting to amend the permit.

The following emission units are associated with this permit:


Long Conveyor (CC-16) 70 tons of limestone per hour

None Granular Bin #1 (CC-17) 70 tons of limestone per hour

Granular Bin #2 (CC-18) 70 tons of limestone per hour

Transfer Belt to Long Conveyor (CC-19) 25 tons of limestone per hour



The facility is of the source type subject to the New Source Performance Standard (NSPS), Subpart OOO, Standards

of Performance for Nonmetallic Mineral Processing Plants and the units are subject to Subpart OOO per 40 CFR

§60.670 – 40 CFR §60.676. EU CC-19 is an affected unit that commenced construction on or after April 22, 2008.

EU CC-16, CC-17 and CC-18 are affected units that commenced construction after August 31, 1983 but before April

22, 2008.





This emission unit is not subject to any NESHAP subparts at this time as there are no applicable subparts for its source

category.



5. Operating Requirements with Associated Monitoring and Recordkeeping

Unless specified by a federal regulation, all records as required by this permit shall be kept on -site for a minimum of two (2)

years and shall be available for inspection by the Department. Records shall be legible and maintained in an orderly manner.

The operating requirements and associated recordkeeping for this permit shall be:

A. The owner or operator shall not operate the New Mill (EP CC-2) when the Transfer Belt to Long Conveyor (CC-19)

is in operation.

B. The owner or operator shall maintain the following daily records:

i. Date, operation start, and end time when Transfer Belt to Long Conveyor (CC-19) is in operation.

ii. Date, operation start, and end time for the New Mill (EP CC-2), on days when Transfer Belt to the Long

Conveyor (CC-19) is in operation.

C. The maximum amount of product transferred using loadout #6 bins shall not exceed 70 tons per hour averaged over

3-hr period.

i. For each hour, the owner or operator shall maintain records of the amount of product transferred in tons.

ii. The owner or operator shall maintain records of the 3-hour average the amount of product transferred in tons.

D. Opacity test/monitoring shall be conducted per NSPS Subpart OOO (40 CFR §60.670 – 40 CFR §60.676).

E. The owner or operator shall check for visible emissions from Loadout #6 bins (EP CC-16) once per week at a time

while Loadout #6 bins (EP CC-16) is in operation. The owner or operator shall record the date and time of the

observation and the presence or absence of visible emissions. If the owner or operator observes visible emissions from

Loadout #6 bins (EP CC-16), the owner or operator shall investigate the emission unit or operations associated with

the emission unit and make corrections to the associated operations or equipment. The owner or operator shall maintain

a record of all corrective actions taken. This requirement shall not apply on the days that Loadout #6 bins (EP CC-16)

is not in operation.

6. Continuous Emission Monitoring Systems (CEMS)

Continuous emission monitoring is not required by this permit at this time.

7. Department Review

This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has been

evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal Regulations

(CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply. This permit is issued based on information submitted by

the applicant. Any misinformation, false statements or misrepresentations by the applicant or by the applicant’s

representative(s) shall cause this permit to be void.

No review has been undertaken on the engineering aspects of the equipment or control equipment other than the potential of

that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or indirectly, for any

loss due to damage to persons or property caused by, resulting from, or arising out of the design, installation, maintenance or

operation of the proposed equipment.

8. Owner and Operator Responsibility

This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point as desc ribed

in this permit and in the application for this permit. The permit holder, owner, and operator of the facility shall assure t hat the

installation of the equipment listed in this permit conforms to the design in the application (i.e. type, maximum rated capac ity,

Linwood Mining & Minerals Corp. Loadout #6 Bins (EP CC-16) Page 5 of 7 Davenport, Iowa 17-A-488-S1 etc.). No person shall construct, install, reconstruct or alter this emission unit(s), control equipment, or emission point without

the required amended permit.

Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person who

becomes an owner or operator subsequent to the date on which this permit is issued, is resp onsible for assuring that the

installation, operation, and maintenance of the equipment listed in this permit is in compliance with the provisions of this permit

and all other applicable requirements and that adequate operation and maintenance is provided to ensure that no condition of

air pollution is created.

9. Transferability

Unless the equipment is portable, this permit is not transferable from one location to another or from one piece of equipment

to another. See Condition 12.A.(2) for notification requirements for relocating portable equipment (567 IAC 22.3(3)“f”).

10. Construction

A. General Requirements:

It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as submitted.

In permit amendments, all provisions of the original permit remain in full force and effect unless they are specifically

changed by the permit amendment. If a proposed project is not timely completed, the owner or operator shall seek a

permit amendment in order to revert back to the most recent previous version of the permit. The previous, unchanged

permit provisions are included in the amendment for your convenience only and are unappealable.

This permit or amendment shall become void if any one of the following conditions occurs:

(1) The construction or implementation of the proposed project, as it affects the emission point permitted herein, is

not initiated within eighteen (18) months after the permit issuance date; or


not completed within thirty-six (36) months after the permit issuance date; or

(3) The construction or implementation of the proposed project, as it affects the emission point permitte d herein, is


B. Changes to Plans and Specifications:

The owner or operator shall amend this permit or amendment prior to startup of the equipment if:

(1) Any changes are made to the final plans and specifications submitted for the proposed project; or

(2) This permit becomes void.

Changes to the final plans and specification shall include changes to plans and specifications for permitted equipment

and control equipment and the specified operation thereof.

C. Amended Permits:

The owner or operator may continue to act under the provisions of the previous permit for the affected emission unit(s)

and emission point, together with any previous amendment to the permit, until one of the following condition s occurs:

(1) The proposed project authorized by this amendment is completed as it affects the emission unit(s) and emission

point permitted herein; or

(2) This current amendment becomes void.

11. Excess Emissions

Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are not a violation

of the emission standard if it is accomplished expeditiously and in a manner consistent with good practice for minimizing

emissions except when another regulation applicable to the unit or process provides otherwise. Cleaning of control equipment,

which does not require the shutdown of process equipment, shall be limited to one (1) six-minute period per one (1) hour

period.

An incident of excess emissions other than the above is a violation and may be subject to criminal penalties according to Iowa

Code 455B.146A. If excess emissions are occurring, either the control equipment causing the excess shall be repaired in an

expeditious manner, or the process generating the emissions shall be shut down within a reasonable period of time, as specified

Linwood Mining & Minerals Corp. Loadout #6 Bins (EP CC-16) Page 6 of 7 Davenport, Iowa 17-A-488-S1 in 567 IAC 24.1.

An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate field office

within eight (8) hours of, or at the start of, the first working day following the onset of the incident [See Permit Condition

12.B.(1)]. A written report of an incident of excess emissions shall be submitted as a follow-up to all required initial reports

within seven (7) days of the onset of the upset condition [See Permit Condition 12.B.(2)].


A. The owner or operator shall furnish the Department the following written notifications:

(1) Per 567 IAC 22.3(3)“b”:

(a) The date construction, installation, or alteration is initiated postmarked within thirty (30) days following

initiation of construction, installation, or alteration.


(2) Per 567 IAC 22.3(3)“f,” when portable equipment for which a permit has been issued is to be transferred from

one location to another, the Department shall be notified:

(a) At least fourteen (14) days before equipment relocation if the equipment will be located in a nonattainment

area for the National Ambient Air Quality Standards (NAAQS) or a maintenance area for the NAAQS.

(b) At least seven (7) days before equipment relocation.

(3) Per 567 IAC 22.3(8), a new owner shall notify the Department of the transfer of equipment ownership within

thirty (30) days of the occurrence. The notification shall include the following information:

• The date of ownership change; the name, address, and telephone number of the responsible official, the

contact person, and the owner of the equipment both before and after the ownership change; and the

construction permit number(s) of the equipment changing ownership.

(4) Unless specified per a federal regulation, the owner or the owner’s authorized agent shall notify the Department

in writing not less than thirty (30) days before a required test or performance evaluation of a continuous emission

monitor [567 IAC 25.1(7)]. The notification shall include:

• The time; the place; the name of the person who will conduct the tests; and other information as required by

the Department.

If the owner or operator does not provide timely notice to the Department, the Department shall not consider the

test results or performance evaluation results to be a valid demonstration of compliance with the applicable rules

or permit conditions. Upon written request, the Department may allow a notification period of less than thirty

(30) days.


(1) Per 567 IAC 24.1(2), an incident of excess emissions as defined in 567 IAC 20.2 shall be reported within eight

(8) hours or at the start of the first working day following the onset of the incident. The report may be made by

electronic mail, in person or by telephone.


submitted as a follow-up to all required initial reports to the Department within seven (7) days of the onset of the

upset condition.

(3) Operation of this emission unit(s) or control equipment outside of those operating parameters specified in Permit

Condition 5 in accordance to the schedule set forth in 567 IAC 24.1.

(4) Per 567 IAC 25.1(6), the owner or operator of any facility required to install a continuous monitoring system or

systems shall provide quarterly reports to the Director, no later than thirty (30) calendar days following the end

of the calendar quarter, on forms provided by the Director.

(5) Per 567 IAC 25.1(7), a written compliance demonstration report for each compliance testing event, whether

successful or not, postmarked no later than six (6) weeks after the completion of the test period unless other

regulations provide for other notification requirements. In that case, the more stringent reporting requirement

shall be met.


available at the plant during normal business hours for inspection and copying by federal, state, or local air pollution

regulatory agencies and their authorized representatives, for a minimum of two (2) years from the date of recording

unless otherwise required by another applicable law (i.e. NSPS, NESHAP, etc.)




(Construction Permit Supervisor), stack testing correspondence (Stack Test Coordinator), and reports and notifications

(Compliance Unit Supervisor and DNR Field Office). The addresses are:

Air Quality Bureau

Iowa Department of Natural Resources

502 E. 9th St.


Telephone: (515) 725-8200

Fax: (515) 725-9501

Field Office 6

1023 West Madison

Washington, IA 52353

Telephone: (319) 653-2135

Fax: (319) 653-2856

13. Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. Amend ed

conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. In permit

amendments, all provisions of the original permit remain in full force and effect unless they are specifically changed by the

permit amendment. The previous, unchanged permit provisions are included in the amendment for your convenience only and

are unappealable.

14. Permit History


Testing

17-A-488 15-457 Issue new permit for as-built units & Establish PM10 Limits 03/13/18 No

END OF PERMIT









Permitted Equipment



EUID Description

* New Mill*



Maximum Rated Canacitv Control Equipment Description and ID

* Baghouse (CE CC-2)

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with applicable provisions of the State Implementation Plan (SIP), and any other requirements oflocal, state, and federal law,


[PSP]

Project Description Stack Issuance Testine: Date

Correct permit to remove EU CC-2j from the EU list No 03/14/19


ICPFP182010151103142019118366186A049S9I

Linwood Mining & Minerals Corp. New Mill (EP CC-2) Page 2 of 8 Davenport, Iowa 86-A-049-S9

PERMIT CONDITIONS


Pollutant lb/hr1 tons/yr2 Other Limits Reference/Basis Particulate Matter (PM) – Federal NA NA 0.032 g/dscm 3 567 IAC 23.1(2)”bbb” 4 Particulate Matter (PM) – State 1.61 5 NA 0.01 gr/scf 6 567 IAC 31.20(1)”d”, LAER PM10 1.61 5, 7 NA NA NAAQS PM2.5 NA NA NA NA Opacity NA NA 4 567 IAC 23.3(2)“c”

1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 0.032 grams per dry standard cubic meter (g/dscm) = 0.014 grains per dry standard cubic foot (gr/dscf). Limit established per 40

CFR §60.672(a). 4 IAC reference to NSPS Subpart OOO (Standards of Performance for Nonmetallic Mineral Processing Plants; 40 CFR §60.670 – 40

CFR §60.676). 5 Limit set in order to keep Project Number 06-105 minor for Prevention of Significant Deterioration (PSD) purposes. 6 Limit established when the Buffalo, IA area was designated nonattainment for Total Suspended Particulates (TSP). Any relaxation

of the Lowest Achievable Emission Rate (LAER) after the Buffalo area is redesignated attainment for TSP is subject to review under the Prevention of Significant Deterioration (PSD) regulations in effect at the time the relaxation occurs.

7 The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343).




Time Test Method




Opacity Yes 1 Stack Test 1 30 minutes 40 CFR 60, Appendix A, Method 22

1 Per 40 CFR §60.674(c), the owner or operator shall conduct quarterly thirty (30) minute visible emissions inspections using EPA Method 22 (40 CFR Part 60, Appendix A-7). The Method 22 test shall be conducted while the baghouse is operating. The test is successful if no visible emissions are observed. If any visible emissions are observed, the owner or operator of the affected facility must initiate corrective action within twenty-four (24) hours to return the baghouse to normal operation. The owner or operator of the affected facility may establish a different baghouse specific success level for the visible emissions test (other than no visible emissions) by conducting a PM performance test according to 40 CFR §60.675(b) simultaneously with Method 22 to determine what constitutes normal visible emissions from the affected facility’s baghouse when it is in compliance with the applicable PM concentration limit. The revised visible emissions success level must be incorporated into the permit for the affected facility.








The temperature and flowrate are intended to be representative and characteristic of the design of the permitted emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process and ambient conditions. If it is determined that any of the emission point characteristics above are different than the values stated, the owner or operator shall submit a request either by electronic mail or written correspondence to the Department within thirty (30) days of the discovery to determine if a permit amendment is required, or submit a permit application requesting to amend the permit. The following emission units are associated with this permit:

Emission Unit Maximum Capacity New Mill Hammermill 1 (CC-2b) 50 tons/hr New Mill Hammermill 2 (CC-2c) 50 tons/hr

New Mill Separator Φ 18’ (CC-2d) 100 tons/hr New Mill Screen (CC-2e) 25 tons/hr New Mill Screen (CC-2f) 25 tons/hr New Mill Screen (CC-2g) 25 tons/hr New Mill Screen (CC-2h) 25 tons/hr

New Mill Raymond Mill (CC-2i) 35 tons/hr

I


New Mill Conveyors/Screw/Elevators (CC-2k) 100 tons/hr


A. New Source Performance Standards (NSPS): The facility (plant number 82-01-015) is of the source type subject to Subpart HH (Standards of Performance for Lime Manufacturing Plants; 40 CFR §60.340 – 40 CFR §60.344) of the New Source Performance Standards (NSPS). However, the subpart only applies to rotary lime kilns so none of these emission units are subject. These emission units are subject to NSPS Subparts A (General Provisions; 40 CFR §60.1 – 40 CFR §60.19) and OOO (Standards of Performance for Nonmetallic Mineral Processing Plants; 40 CFR §60.670 – 40 CFR §60.676).



B. National Emission Standards for Hazardous Air Pollutants (NESHAP): This facility (plant number 82-01-015) is considered an “area source” of hazardous air pollutant (HAP) emissions and is therefore not subject to any National Emission Standards for Hazardous Air Pollutant (NESHAP) subparts as Subpart AAAAA (National Emission Standards for Hazardous Air Pollutants for Lime Manufacturing Plants; 40 CFR §63.7080 – 40 CFR §63.7143) is for major sources of HAP emissions and there are currently no subparts for lime manufacturing area sources.



A. The owner or operator shall maintain record per 40 CFR §60.676(b), the results of each Method 22 test, including the date and any corrective actions taken.

B. The owner or operator shall begin monitoring the differential pressure drop across the baghouse, as specified in condition 5.C. by June 30, 2019.


C. The differential pressure drop across Baghouse (CE CC-2) shall be maintained between 2 and 10 inches of


across Baghouse (CE CC-2). The monitoring devices and any recorders shall be installed, calibrated, operated and maintained in accordance with the manufacturer’s recommendations, instructions and operating manuals or per written facility specific operation and maintenance plan.

ii. The owner or operator shall collect and record the pressure drop across Baghouse (CE CC-2), in inches of water, at a minimum of once every 2 minutes. Calculate and record the hourly average for all readings for each 1-hour block. If the average hourly pressure drop across Baghouse (CE CC-2) falls outside the range specified in Condition 5.C., the owner or operator shall investigate Baghouse (CE CC-2) and make corrections to the baghouse. The owner or operator shall maintain a record of all corrective actions taken. This requirement shall not apply on the days that Baghouse (CE CC-2) are not in operation.

D. The owner or operator shall develop an operating and maintenance plan for the Baghouse (CE CC-2), including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance.

i. The owner or operator shall maintain a record of all inspections and maintenance and any action resulting from the inspection and maintenance of the Baghouse (CE CC-2).






10. Construction







The owner or operator shall amend this permit or amendment prior to startup of the equipment if: (1) Any changes are made to the final plans and specifications submitted for the proposed project; or (2) This permit becomes void. Changes to the final plans and specification shall include changes to plans and specifications for permitted equipment and control equipment and the specified operation thereof.



























Fax: (319) 653-2856

Linwood Mining & Minerals Corp. New Mill (EP CC-2) Page 8 of 8 Davenport, Iowa 86-A-049-S9 13. Appeal Rights All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in the amendment for your convenience only and are unappealable. 14. Permit History


Testing 86-A-049 86-039 Original permit. 07/08/86 Yes

86-A-049-S1 --- Replaced baghouse. 12/26/91 No 86-A-049-S2 98-059 Revised PM10 allowable for SIP. 03/25/98 Yes 86-A-049-S3 98-161 Revised PM10 allowable for SIP. 09/30/98 Yes 86-A-049-S4 00-220 Amended flowrate. 05/23/00 Yes 86-A-049-S5 01-555 Revised PM10 allowable for SIP. 06/20/02 No 86-A-049-S6 06-105 Replaced baghouse. 07/14/06 Yes 86-A-049-S7 12-495 Added pickup point. 02/25/13 Yes 86-A-049-S8 14-186 Remove emission unit EU CC-2j and waive testing required by

permit#86-A-049-S7 09/02/14 No

END OF PERMIT

•Iowa Department of Natural Resources


Permit Holder

Firm: Linwood Mining & Minerals Corporation

Contact:

Jaci Moore

Environmental Engineer

563.324.1931

401 East Front Street

Davenport, Iowa 52804

Emission Unit(s): ._

Control Equipment:

Emission Point:

Equipment Location:


Responsible Party:

Jeff Dahl

Vice President Chemical Operations

Permitted E<J.!!!Pmen~' ,: -<

. NE;lWMill Dtij3r (EU' ..QC-2a),::,~ i~.~..;,;.-~\iM~ximum Firing Rate of 28,7 MMBtu per hour' - ,

Maximum Capacity of 70 tons per hour' of limestone

New Mill Outside Conveyors/Screws/Elevators (EU CC-2k)

Maximum Capacity of 100 tons per hour of limestone

Baghouse (CE CC-5)

CC-5 .

401 East Front Street

Davenport, Iowa 52804

•

Permit No. Project No. Description I Date I Testing

98-A-846 98-161 Original Permit. 9/30/98 Yes~---

98-A-846-S1, 01-555 .j Allowed Use of Landfill Gas in Dryer. 6/20/02 No.....- .._._ ...~-..---"._--98-A-846-S2 j 06-105 Relocate Equipment. 7/14/06 No~._"'_.'_w ____ '. _. ____.

I. . ._._.- -- ._" ....- .__ ._----_._------_ .

. ._. _....._ .... ..(... _._-_._--- _._----I

Under the Direction of the Director of

the Department of Natural Resources

•

• -

Iowa Department of Natural Resources Air Quality Construction Permit

Permit Holder

Firm: Linwood Mining & Minerals Corporation

Contact: Responsible Party:

Jaci Moore Environmental Engineer

563.324.1931

401 East Front Street Davenport, Iowa 52804

. . Emission. Unit(s): _.

Control Equipment:

Emission Point:

Equipment Location:


Jeff Dahl Vice President Chemical Operations

Permitted Eguipnien~'··•:·.-< ' :.. . t

NE:W° M!H Dri¥.r (ELJ...QC-2a)~ ;\ ~ .{. . ,;;· i1 M~xjmum Fin.rm Rate of 28_: 7 MM Btu per hour : !.

Maximum Capacity of 70 tons per hour of limestone New Mill Outside Conveyors/Screws/Elevators {EU CC-2k) Maximum Capacity of 100 tons per hour of limestone

Bag_housE:! (CE CC-~)

CC-5 ·

401 East Front Street Davenport, Iowa 52804

Permit No. Project No. Description I Date I Testing 98-A~846 98-161" Original Permit. 9/30/98 Yes

98-A-846-S1 i 01-555 Allowed Use of Landfill Gas in Dryer. 6/20/02 No ..... _. ·-·-··~---t---~~_:A-846-S2 1 __ --~~-105 Relocate Equipment. 7/14/06 No

. . ... i- . ·--- -- - --·--·· ....... -.... --... ---.......---. - . ............. __ ---i--- -•----• --·- 1-------

I


Linwood Mining & Minerals New Mill Dryer and Outside Conveying Equip. (CC-5) page 2 of 7 Davenport, Iowa 98-A-846-S2

PERMIT CONDITIONS The permit holder, owner and operator of the facility shall assure that the installation, operation, and maintenance of this equipment is in compliance with all of the conditions of this permit.

1. Departmental Review This permit is issued based on information submitted by the applicant. Any misinformation, false statements or misrepresentations by the applicant shall cause this permit to be void. In addition, the applicant may be subject to criminal penalties according to Iowa Code Section 455B.146A. This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20-31; and 40 CFR Parts 51, 52, 60, 61 and 63 and has the potential to comply. No review has been undertaken on the engineering aspects of the equipment or control equipment other than the potential of that equipment for reducing air contaminant emissions. The DNR assumes no liability, directly or indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, installation, maintenance or operation of the proposed equipment.

2. Transferability As limited by 567 IAC 22.3(3)"f", this permit is not transferable from one location to another or from one piece of equipment to another, unless the equipment is portable. When portable equipment for which a permit has been issued is to be transferred from one location to another, the DNR shall be notified in writing at least thirty (30) days prior to transferring to the new location (See 8.A.6). The owner will be notified at least ten (10) days prior to the scheduled relocation if the relocation will cause a violation of the National Ambient Air Quality Standards. In such case, a supplemental permit shall be required prior to the initiation of construction of additional control equipment or equipment modifications needed to meet the standards. This permit is for the construction and operation of the specific emission unit(s), control equipment and emission point as described in this permit and in the application for this permit. Any owner or operator of the specified emission unit(s), control equipment or emission point, including any person who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for compliance with the provisions of this permit. No person shall construct, install, reconstruct or alter this emission unit, control equipment or emission point without the required revisions to this permit.

3. Construction This permit shall become void if construction on the proposed project has not been initiated within eighteen (18) months after the date of the issuance of this permit and completed within thirty-six (36) months after the date of the issuance of this permit.

It shall be the responsibility of the owner to ensure that construction conforms to the final plans and specifications as submitted and that adequate operation and maintenance is provided to ensure that no condition of air pollution is created. A supplement to this permit shall be obtained if the owner proposes changes to the final submitted plans and specifications.


4. Credible Evidence As stated in 567 IAC 21.5 and also in 40 CFR Part 60.11(g), where applicable, any credible evidence may be used for the purpose of establishing whether a person has violated or is in violation of any provisions specified in this permit or any provisions of 567 IAC Chapters 20 through 31.

5. Owner Responsibility Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, and federal law. The owner or operator of any emission unit or control equipment shall maintain and operate the equipment and control equipment at all times in a manner consistent with good practice for minimizing emissions, as required by paragraph 567 IAC 24.2(1) "Maintenance and Repair".

6. Disposal of Contaminants The disposal of materials collected by the control equipment shall meet all applicable rules.

7. Excess Emissions Excess emissions during a period of startup, shutdown, or cleaning of control equipment are not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good practice for minimizing emissions except when another regulation applicable to the unit or process provides otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be limited to one six-minute period per one-hour period. An incident of excess emissions other than the above is a violation and may be subject to criminal penalties according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within a reasonable period of time, as specified in 567 IAC 24.1. An incident of excess emissions shall be orally reported to the appropriate DNR field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident (See section 8.B.1). A written report of an incident of excess emissions shall be submitted as a follow-up to all required oral reports within seven (7) days of the onset of the upset condition.

8. Notification, Reporting and Recordkeeping

A. The owner shall furnish the DNR the following written notifications: 1. The date construction, installation, or alteration is initiated postmarked within thirty (30) days

following initiation of construction, installation, or alteration; 2. The actual date of startup, postmarked within fifteen (15) days following the start of operation; 3. The date of each compliance test required by Permit Condition 12, at least thirty (30) days

before the anticipated compliance test date; 4. The date of each pretest meeting, at least fifteen (15) days before the proposed meeting date.

The owner shall request a proposed test plan protocol questionnaire at least sixty (60) days prior to each compliance test date. The completed questionnaire shall be received by the DNR at least fifteen (15) days before the pretest meeting date;

5. Transfer of equipment ownership, within 30 days of the occurrence; 6. Portable equipment relocation, at least thirty (30) days before equipment relocation.


8. Notification, Reporting and Recordkeeping (Continued)

B. The owner shall furnish DNR with the following reports:

1. Oral excess emissions reports, in accordance with 567 IAC 24.1; 2. A written compliance demonstration report for each compliance testing event, whether

successful or not, postmarked not later than forty-five (45) days after the completion of the test period unless other regulations provide for other notification requirements. In that case, the more stringent reporting requirement shall be met;

3. Operation of this emission unit(s) or control equipment outside of those limits specified in Permit Conditions 10 and 14 and according to the schedule set forth in 567 IAC 24.1.

C. The owner shall send correspondence regarding this permit to the following addresses:

Construction Permit Supervisor Air Quality Bureau Iowa Department of Natural Resources 7900 Hickman Road, Suite 1 Urbandale, IA 50322 Telephone: 515.281.8189 Fax: 515.242.5094

D. The owner shall send correspondence concerning stack testing to:

Stack Testing Coordinator Air Quality Bureau Iowa Department of Natural Resources 7900 Hickman Road, Suite 1 Urbandale, IA 50322 Telephone: 515.242.6001 Fax: 515.242.5127

E. The owner shall send reports and notifications to:

Compliance Unit Supervisor Air Quality Bureau Iowa Department of Natural Resources 7900 Hickman Road, Suite 1 Urbandale, IA 50322 Telephone: 515.281.8448 Fax: 515.242.5127

DNR Field Office 6 1023 West Madison Washington, IA 52353 Telephone: 319.653.2135 Fax: 319.653.2856

F. All data, records, reports, documentation, construction plans, and calculations required under this

permit shall be available at the plant during normal business hours for inspection and copying by federal, state, or local air pollution regulatory agencies and their authorized representatives, for a minimum of two (2) years from the date of recording.

9. Permit Violations Knowingly committing a violation of this permit may carry a criminal penalty of up to $10,000 per day fine and 2 years in jail according to Iowa Code Section 455B.146A.


10. Emission Limits

Pollutant lb/hr(1) Tons/Yr(2) Additional

Limits

Reference

(567 IAC)

Particulate Matter (PM) NA NA 0.1 gr/dscf 23.3(2)”a”

Particulate Matter (PM) NA NA 0.05 gr/dscm(4) 23.1(2)”bbb”

Particulate Matter (PM) NA NA 0.01 gr/dscf(5) LAER (SIP)

PM10 0.93(3) NA NA NAAQS

Opacity NA NA 7%(4) 23.1(2)”bbb”

Sulfur Dioxide (SO2) NA NA NA NA

Nitrogen Oxides (NOX) NA NA NA NA

Volatile Organic Compounds NA NA NA NA

Carbon Monoxide (CO) NA NA NA NA

Lead (Pb) NA NA NA NA

(Single HAP) NA NA NA NA

(Total HAP) NA NA NA NA

(1) Standard is expressed as the average of 3 runs (2) Standard is a 12-month rolling total. (3) The limit for PM10 emissions is also established to limit emissions below levels that predict

exceedances of the annual and 24-hour NAAQS for PM10. (4) Reference to Subpart OOO of the New Source Performance Standards (NSPS). See also 40 CFR

§60.670 to 40 CFR §60.676. Note: 0.05 grams/dscm = 0.022 grains/dscf. (5) Limit established when the Buffalo Area was designated non-attainment for TSP (PM). Any

relaxation in the Lowest Achievable Emission Rates (LAER) after the Buffalo Area is redesignated attainment for TSP (PM) is subject to review under the PSD regulations in effect at the time the relaxation occurs.


This emission point shall conform to the specifications listed below.

Parameter Value

Stack Height, (ft, from the ground) 97 ft

Discharge Style Vertical, Unobstructed

Stack Opening, (inches, dia.) 30 inches

Exhaust Temperature (°F) 100°F

Exhaust Flowrate (scfm) 20,600 scfm

The temperature and flowrate are intended to be representative and characteristic of the design of the permitted emission point. The Department recognizes that the temperature and flowrate may vary with changes in the process and ambient conditions. If it is determined that any of the emission point design characteristics are different than the values stated above, the owner/operator must notify the Department and obtain a permit amendment, if required.


12. Initial Performance Testing Requirements

Pollutant Testing Required Test Run Time Test Method

PM (state) No 3 hours Iowa Compliance Sampling Manual Method 5

PM (federal) Yes(1) 3 hours 40 CFR 60, Appendix A, Method 5

PM10 Yes(1) 5 hours 40 CFR 51, Appendix M, 201A with 202

Opacity Yes(1) 1 hour 40 CFR 60, Appendix A, Method 9

SO2 No 1 hour 40 CFR 60, Appendix A, Method 6C

NOX No 1 hour 40 CFR 60, Appendix A, Method 7E

VOC No 1 hour 40 CFR 60, Appendix A, Method 25A

CO No 1 hour 40 CFR 60, Appendix A, Method 10

Pb No NA 40 CFR 60, Appendix A, Method 12

Other No NA

(1) Testing on this emission point was successfully completed on May 22, 2000. No further testing is required as a part of this project.

If specified above, the owner shall verify compliance with the emission limitations contained in Permit

Condition 10 within 60 days after achieving maximum production rate and no later than one hundred eighty (180) days after the initial startup date of the proposed new control equipment. The unit(s) being sampled should be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the department to determine whether this unit(s) is in compliance. Each emissions compliance test must be approved by the DNR. Unless otherwise specified by the DNR, each test shall consist of three separate runs. The arithmetic mean of three acceptable test runs shall apply for compliance, unless otherwise indicated by the DNR. The test methods and run times to be used are those stated above unless otherwise approved by the DNR.

A pretest meeting shall be held at a mutually agreeable site no less than fifteen (15) days prior to the date of each test. Representatives from the DNR shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. The owner shall be responsible for the installation and maintenance of test ports. The DNR shall reserve the right to impose additional, different, or more detailed testing requirements.

13. NSPS and NESHAP Applicability

This emission unit is subject to Subpart A – General Provisions (40 CFR ♣60.1 through 40 CFR ♣60.19) of the New Source Performance Standards (NSPS) and Subpart OOO – Standards of Performance for

Nonmetallic Mineral Processing Plants (40 CFR ♣60.670 through 40 CFR ♣60.676) and is also subject to the requirements of 567 IAC 23.1(2)”bbb”. Currently, these emission units are not subject to any National Emission Standards for Hazardous Air Pollutants (NESHAP). There are no applicable subparts.


14. Operating Limits

A. The fuel for the New Mill Dryer (EU CC-2a) is limited to either natural gas or landfill gas.

B. The owner or operator shall maintain the control equipment according to manufacturer’s specifications and maintenance schedule.

15. Operating Condition Monitoring

All records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the DNR. Records shall be legible and maintained in an orderly manner.

A. The owner or operator shall maintain a record of all inspections/maintenance and any action resulting from the inspection/maintenance of the control equipment.

16. Continuous Emission Monitoring


17. Descriptions of Terms and Acronyms

acfm Actual cubic feet per minute Applicant The owner, company official or authorized agent CFR Code of Federal Regulations Department Iowa Department of Natural Resources DNR Iowa Department of Natural Resources gr/dscf Grains per dry standard cubic foot HAP Hazardous Air Pollutant(s) IAC Iowa Administrative Code LAER Lowest Achievable Emission Rate MMBtu One million British thermal units NA Not Applicable NAAQS National Ambient Air Quality Standards NOX Nitrogen Oxides Owner The owner or authorized representative Permit This document including permit conditions and all submitted application materials PM10 Particulate Matter equal to or less than 10 microns in aerodynamic diameter scfm Standard cubic feet per minute SIP State Implementation Plan SO2 Sulfur Dioxide TSP Total Suspended Particulate VOC Volatile Organic Compound

END OF PERMIT CONDITIONS

[PSP] ¦CPFP¦8201015¦08272020¦20143¦71A084S13¦





Contact Person: Responsible Party:

Darin Osland Same

Environmental Manager

563-324-1931

[email protected]

401 E Front Street

Davenport, IA 52804

Permitted Equipment




Capacity

Control Equipment

Description and ID

* Old Mill * Baghouse (CE CC-1)


Equipment Location: 401 E Front Street

Davenport, IA 52804

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with applicable

provisions of the State Implementation Plan (SIP), and any other requirements of local, state, and federal law.

Project


Stack

Testing

Issuance

Date

20-143 Increase Dryer capacity to 57 Tons per hour No 08/27/20

Under the Direction of the Director of the

Department of Natural Resources

Linwood Mining & Minerals Corp. Old Mill (EP CC-1) Page 2 of 9

Davenport, Iowa 71-A-084-S13

PERMIT CONDITIONS

1. Emission Limits




Particulate Matter (PM) – Federal NA NA 0.032 g/dscm3,4 567 IAC 23.1(2)”bbb”3,4


PM10 2.48 5,6 NA NA NA

PM2.5 NA NA NA NA

Opacity NA NA 40%7, 8 4 ; 567 IAC 23.3(2)“d”

Sulfur Dioxide (SO2) NA NA 500 ppmv 567 IAC 23.3(3)”e”



CFR §60.676). Opacity monitoring requirements in Condition 5. 5 Limit set in order to keep Project Number 06-105 minor for Prevention of Significant Deterioration (PSD) purposes. 6 The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved

into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343). 7 The emission limit is based on a six (6) minute average. 8 An exceedance of the indicator opacity of No Visible Emissions will require the owner or operator to promptly investigate the

emission unit and make corrections to operations or equipment associated with the exceedance. If exceedances continue after the

corrections, the Department may require additional proof to demonstrate compliance (e.g., stack testing).





Time Test Method






Opacity 1 NA 1 hour 40 CFR 60, Appendix A, Method 9 1 Opacity test/monitoring shall be conducted per NSPS Subpart OOO (40 CFR §60.670 – 40 CFR §60.676)



below:





control equipment.








“Compliance Demonstration Table” unless another testing methodology is approved by the Department prior to testing.


shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs shall apply for compliance, unless








The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated









Parameter Value



Stack Outlet Dimensions (inches) 42

Exhaust Temperature (oF) 150









The following emission units exhaust through this emission point:

Emission Unit Maximum Capacity Control

Equipment

Storage Tank CL2 (CC-01K) 138 tons of ingredient

(limestone or ash)

Baghouse

(CE CC-1)

Storage Tank CL3 (CC-01L) 138 tons of ingredient

(limestone or ash)

Old Mill Dryer (EU CC-1a) feeds to EU CC-1g* 57 tons/hr

Old Mill Cage Mill (EU CC-1b) 40 tons/hr

Old Mill Screen (EU CC-1c) 60 tons/hr

Old Mill Screen (EU CC-1d) 60 tons/hr

Old Mill Separator 1 (EU CC-1e) 40 tons/hr

Old Mill Separator 2 (EU CC-1f) 30 tons/hr

Old Mill Conveyors/Screws/Elevators (EU CC-1g) Includes Transfer

Point CL-1 From Tank and Transfer Point CL-1 to Elevator 57 tons/hr

Old Mill Finished Storage Tank (EU CC-1h) 1200 tons

Old Mill Finished Storage Tank (EU CC-1i) 1200 tons

Storage Bin (EU CC-1j) 138 tons

Storage Bin (EU CC-1k) 138 tons

Storage Bin (EU CC-1l) 138 tons

Storage Bin (EU CC-1m) 138 tons

South Tank (CC-13) 175 tons

North Tank (CC-12) 400 tons

#3 Loadout System (EU CC-1r) Includes a pneumatic conveyor (60

TPH), an enclosed belt conveyor (60 TPH), two load out spouts and a

scale.

Total = 120 tons/hr

Max allowed = 60 tons/hr

*Old Mill Dryer (EU CC-1a) capacity is limited by Old Mill Conveyors/Screws/Elevators (EU CC-1g) capacity.



The following subparts apply to the emission unit(s) in this permit:

These emission units are subject to NSPS Subparts A (General Provisions; 40 CFR §60.1 – 40 CFR §60.19) and OOO

(Standards of Performance for Nonmetallic Mineral Processing Plants; 40 CFR §60.670 – 40 CFR §60.676).




These emission units are not subject to any NESHAP subparts at this time as there are no applicable subparts for its

source category.






Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2)



A. The fuel combusted in the Old Mill Dryer (EU CC-1a) is limited to either natural gas or landfill gas.

B. The facility shall operate only one of the following conveying systems, which are associated with #3 Loadout System

(EU CC-1r), at a time:

i. Pneumatic conveyor

ii. Fully enclosed belt conveyor

C. The owner or operator shall implement written procedures onsite to ensure only one conveyor system is operated.

These procedures shall be retained onsite and made available for inspection.

D. The owner or operator shall conduct visible emissions observation (Method 22) on emission units associated with #3

Loadout System (EU CC-1r) once per calendar week.

E. If the owner or operator observes visible emissions from emission units associated with #3 Loadout System (EU

CC-1r), the owner or operator shall investigate the emission units, control equipment or operations associated with

EU CC-1r and make corrections to the associated operations or equipment. The owner or operator shall maintain a

record of all corrective actions taken. This requirement shall not apply on the days that emission units, control

equipment or operations associated with EU CC-1r are not in operation. F. Per 40 CFR §60.674(c), the owner or operator of any affected facility for which construction, modification, or

reconstruction commenced on or after April 22, 2008, that uses a baghouse to control emissions must conduct quarterly

30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60, appendix A-7). The Method 22 (40

CFR part 60, appendix A-7) test shall be conducted while the baghouse is operating. The test is successful if no visible

emissions are observed. If any visible emissions are observed, the owner or operator of the affected facility must

initiate corrective action within 24 hours to return the baghouse to normal operation. The owner or operator must

record each Method 22 (40 CFR part 60, appendix A-7) test, including the date and any corrective actions taken, in

the logbook required under §60.676(b).

G. Per 40 CFR §60.676(b), the results of each Method 22 test, including the date and any corrective actions taken. H. The differential pressure drop across Baghouse (CE CC-1) shall be maintained between 2 and 10 inches of water

column, based on 1-hr block average.

a. The owner or operator shall properly operate and maintain equipment to monitor differential pressure drop

across Baghouse (CE CC-1). The monitoring devices and any recorders shall be installed, calibrated, operated

and maintained in accordance with the manufacturer’s recommendations, instructions and operating manuals

or per written facility specific operation and maintenance plan.

b. The owner or operator shall collect and record the pressure drop across Baghouse (CE CC-1), in inches of

water, at a minimum of once every 2 minutes. Calculate and record the hourly average for all readings for

each 1-hour block. If the average hourly pressure drop across Baghouse (CE CC-1) falls outside the range

specified in Condition 5.H., the owner or operator shall investigate Baghouse (CE CC-1) and make

corrections to the baghouse. The owner or operator shall maintain a record of all corrective actions taken.

This requirement shall not apply on the days that Baghouse (CE CC-1) is not in operation.

I. The owner or operator shall develop an operating and maintenance plan for the Baghouse (CE CC-1), including a

preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term

maintenance.

J. The owner or operator shall maintain a record of all inspections and maintenance and any action resulting from the

inspection and maintenance of the Baghouse (CE CC-1).
















This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point as described

in this permit and in the application for this permit. The permit holder, owner, and operator of the facility shall assure that the

installation of the equipment listed in this permit conforms to the design in the application (i.e. type, maximum rated capacity,

etc.). No person shall construct, install, reconstruct or alter this emission unit(s), control equipment, or emission point without



becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring that the




9. Transferability



10. Construction




















C. Amended Permits:


and emission point, together with any previous amendment to the permit, until one of the following conditions occurs:











period.




in 567 IAC 24.1.







(1) Per 567 IAC 22.3(3)“b”:


















the Department.




(30) days.







upset condition.











shall be met.









Air Quality Bureau


502 E. 9th St.


Telephone: (515) 725-8200

Fax: (515) 725-9501

Field Office 6

1023 West Madison


Telephone: (319) 653-2135

Fax: (319) 653-2856

13. Appeal Rights

All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. Amended




are unappealable.



14. Permit History

Permit No. Project No. Description Date Stack Testing

71-A-084 -- Original permit. 11/29/71 No

71-A-084-S1 97-191 Revised PM10 allowable for SIP. 06/06/97 Yes



71-A-084-S4 01-555 Allowed use of landfill gas. 06/20/02 No

71-A-084-S5 02-296 Amended maximum capacity of EU CC-1a. 09/24/03 No

71-A-084-S6 01-220 Corrected NESHAP applicability. 12/09/03 No

71-A-084-S7 06-105 Increased PM10 allowable. 07/14/06 Yes

71-A-084-S8 12-495 Added emission units. 02/25/13 Yes

71-A-084-S9 14-186 Remove emission unit EU CC-1n 09/02/14 Yes

71-A-084-S10 15-165 Add as-built and new emission units. Modify Section

14 requirements. 09/29/15 No

71-A-084-S11 19-130 Add EU CC-17A and EU CC-17B to the equipment

list 07/02/19 No

71-A-084-S12 19-356 Remove EU CC-17A and EU CC-17B from the

equipment list 02/26/20 No

END OF PERMIT








Same

Permitted Equipment

Emission Point ID: Pile I and 11


EUID Description Maximum Rated

Control Equipment Description and ID Caoacitv

* Piles I and 11 *



* *



[PSPJ


Testing Date Issue new permit for material storage piles & Establish PMl O Limits No 09/06/18


ICPFPl82010151109062018118011:18AI 14:

Linwood Mining & Minerals Corp. Piles 1 and 11 (EP Pile 1, 11) Page 2 of 7 Davenport, Iowa 18-A-114

PERMIT CONDITIONS

1. Emission Limits (Piles 1 and 11) The owner or operator is required to report all emissions as required by law, regardless of whether a specific emission limit has been established in this permit. The following emission limits shall not be exceeded:

EP Pollutant lb/hr1 tons/yr2 Other Limits Reference/Basis

Pile 1 and 11

Particulate Matter (PM) – State NA NA NA NA PM10 NA NA 3 NA PM2.5 NA NA NA NA Opacity NA NA 4 567 IAC 23.3(2)“c”

1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 The limit for PM10 emissions for the Piles 1 and 11 is 8.65 pounds per day. The PM10 limit established for attainment and

maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343).

4 The owner or operator shall take reasonable precautions to prevent the discharge of visible emissions of fugitive dusts beyond lot line of the property.



Pollutant Compliance Methodology Frequency Test Run Time Test Method

PM – State None NA 1 hour AP-42, Appendix C.1 Procedures for Sampling Surface/Bulk Dust Loading, Appendix C.2 Procedures for Laboratory Analysis of Surface/Bulk Dust Loading Samples

PM10 Active Surface Silt & Moisture

Sampling Quarterly 1 hour

PM2.5 None NA 1 hour 40 CFR 51, Appendix M, 201A with 202 Opacity None NA 1 hour 40 CFR 60, Appendix A, Method 9





Linwood Mining & Minerals Corp. Piles 1 and 11 (EP Pile 1, 11) Page 3 of 7 Davenport, Iowa 18-A-114 Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.




Pile 1 Maximum Pile Area: 80,318 ft2



A. New Source Performance Standards (NSPS): The facility is of the source type subject to the New Source Performance Standard (NSPS), Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants. The units permitted under this permit are not subject to the NSPS Subpart OOO, as they were built prior to the rule applicability date.






5. Operating Requirements with Associated Monitoring and Recordkeeping Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an orderly manner. The operating requirements and associated recordkeeping for this permit shall be: A. The owner or operator shall maintain the total area of Pile 1 to less than or equal to 80,318 square feet.

i. The owner or operator shall maintain annual records of Pile 1 area in square feet. B. The average active surface moisture content for the material storage pile 1 shall be greater than or equal to 1.2% by weight.

i. The owner or operator shall sample the active surface of storage pile 1 to determine moisture content as percent by weight once per calendar quarter.

ii. The owner or operator shall take a minimum of two active surface samples per calendar quarter. iii. The owner or operator shall determine the average moisture content as percent by weight for all samples

taken per calendar quarter. iv. On quarterly basis, the owner or operator shall maintain the following records for each sampling event a) The

date of the sample; b) The sample location; c) The measured moisture content as percent weight d); The average moisture content as percent by weight and e) The operator’s initials

C. The average active surface silt from the material storage pile 1 shall be less than or equal to 0.23% by weight. i. The owner or operator shall sample the active surface of storage pile 1 to determine silt content as percent by

weight once per calendar quarter. ii. The owner or operator shall take a minimum of two active surface samples per calendar quarter.

iii. The owner or operator shall determine the average silt content as percent by weight for all samples taken per calendar quarter.

iv. On quarterly basis, the owner or operator shall maintain the following records for each sampling event a) The date of the sample; b) The sample location; c) The measured silt content as percent weight d); The average silt content as percent by weight and e) The operator’s initials.

D. The owner or operator shall maintain the total area of Pile 11 to less than or equal to 33,485 square feet. i. The owner or operator shall maintain annual records of Pile 11 area in square feet.

E. The average active surface moisture content for the material storage pile 11 shall be greater than or equal to 2.1% by weight.

i. The owner or operator shall sample the active surface of storage pile 11 to determine moisture content as percent by weight once per calendar quarter.

ii. The owner or operator shall take a minimum of two active surface samples per calendar quarter. iii. The owner or operator shall determine the average moisture content as percent by weight for all samples

taken per calendar quarter. iv. On quarterly basis, the owner or operator shall maintain the following records for each sampling event a) The


F. The average active surface silt from the material storage pile 11 shall be less than or equal to 3.9% by weight. i. The owner or operator shall sample the active surface of storage pile 11 to determine silt content as percent

by weight once per calendar quarter. ii. The owner or operator shall take a minimum of two active surface samples per calendar quarter.



G. During high wind episodes (greater than 12 miles per hour) if visible emissions are observed from the working face of Piles 1 or 11, the owner or operator shall employ measures to eliminate or minimize emissions. Such measures may include applying dust suppressant to working face of the pile or coverings the working face of the pile.

i. The owner or operator shall develop a written plan to implement, at a minimum, measures to minimize emissions during high wind episodes as specified in condition 5.G. The written plan and any documentation as required by the plan shall be maintained onsite and available for inspection.

Linwood Mining & Minerals Corp. Piles 1 and 11 (EP Pile 1, 11) Page 5 of 7 Davenport, Iowa 18-A-114 6. Continuous Emission Monitoring Systems (CEMS) Continuous emission monitoring is not required by this permit at this time.




10. Construction


















Fax: (319) 653-2856

13. Appeal Rights All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in the amendment for your convenience only and are unappealable. 14. Permit History


Testing

END OF PERMIT








Same

Permitted Equipment

Emission Point ID: Storage Piles (Pile 2, Pile 3, Pile 5, Pile 10, Pile 12, Pile 13, Pile 15, Pile 16, Pile 17, Pile 18)


EUID Description

* Material Storage Piles*

*See Emission Unit list in Condition 1 and 5


Maximum Rated Control Equipment Description and ID Capacity

* *



[PSP]


Testine: Date Issue new permit for material storage piles & Establish PMI O Limits No 09/06/18


ICPFPl82010l511090620181180 l 7i l 8Al IOI

Linwood Mining & Minerals Corp. Material Storage Piles (EP Piles) Page 2 of 8 Davenport, Iowa 18-A-110

PERMIT CONDITIONS


EP Pollutant lbs/day1 tons/yr2 Other Limits Reference/Basis

Pile 2 Undisturbed pile

Particulate Matter (PM) – State NA NA NA NA PM10 0.184 NA NA NA PM2.5 NA NA NA NA Opacity NA NA 3 567 IAC 23.3(2)“c”

Pile 3


Pile 5










Pile 16


Pile 17



Particulate Matter (PM) – State NA NA NA NA PM10 0.71 4 NA NA NA PM2.5 NA NA NA NA Opacity NA NA 3 567 IAC 23.3(2)“c”

1 The emission limit is expressed in pounds per day. 2 The emission limit is based on a twelve (12) month rolling total. 3 The owner or operator shall take reasonable precautions to prevent the discharge of visible emissions of fugitive dusts beyond lot line of the property. 4 The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343).

Linwood Mining & Minerals Corp. Material Storage Piles (EP Piles) Page 3 of 8 Davenport, Iowa 18-A-110 2. Compliance Demonstration(s)



Time Test Method







Linwood Mining & Minerals Corp. Material Storage Piles (EP Piles) Page 4 of 8 Davenport, Iowa 18-A-110 3. Emission Point Characteristics This emission point shall conform to the specifications listed below:




A. New Source Performance Standards (NSPS): The facility is of the source type subject to the New Source Performance Standard (NSPS), Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants. The units included in this permit are not subject to the NSPS Subpart OOO.






A. The owner or operator shall maintain the area of Piles, in square feet, less than or equal to the area listed in the table below.

i. Maintain records of area of each pile as listed in table below in square feet, on an annual basis.

EP ID Maximum Area (square feet) Pile 2 12,628 Pile 3 28,825 Pile 5 40,166

Pile 10 19,814 Pile 12 55,683 Pile 13 442,704 Pile 15 535,773 Pile 16 87,425


Pile 17 203,244 Pile 18 1,170,056

B. The owner or operator shall notify the department within 30-days if the following storage piles are disturbed more

frequently than once per calendar month. i. Pile 2, Pile 10, Pile 12, Pile 13, and Pile 15.

ii. The owner or operator shall maintain records of the Pile 2, Pile 10, Pile 12, Pile 13, and Pile 15 disturbance frequency.

C. During high wind episodes (greater than 12 miles per hour) if visible emissions are observed from the working face of active Piles listed in Condition 1. a., the owner or operator shall employ measures to eliminate or minimize emissions. Such measures may include applying dust suppressant to working face of the pile or coverings the working face of the pile.

i. The owner or operator shall develop a written plan to implement at a minimum measures to minimize emissions during high wind episodes as specified in condition 5.C. The written plan and any documentation as required by the plan shall be maintained onsite and available for inspection.





Linwood Mining & Minerals Corp. Material Storage Piles (EP Piles) Page 6 of 8 Davenport, Iowa 18-A-110 10. Construction
































Fax: (319) 653-2856

Linwood Mining & Minerals Corp. Material Storage Piles (EP Piles) Page 8 of 8 Davenport, Iowa 18-A-110 13. Appeal Rights All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in the amendment for your convenience only and are unappealable. 14. Permit History


Testing

END OF PERMIT








Same

Permitted Equipment

Emission Point ID: Pile 8


Material Storage Pile 8




[PSP]


Testin!! Date Issue new pe11nit for material storage piles & Establish PM! 0 Limits No 09/06/18


:crFr:s2010151:0906201 s: 1 so 1111 sA1 151

Linwood Mining & Minerals Corp. Material Storage Pile 8 (EP Pile 8) Page 2 of 6 Davenport, Iowa 18-A-115

PERMIT CONDITIONS



Pile 8


1 The emission limit is expressed in pounds per day. 2 The emission limit is based on a twelve (12) month rolling total. 3 The limit for PM10 controlled emissions for Pile 8 is established at 3.82 pounds of PM10 per day. The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343). 4 The owner or operator shall take reasonable precautions to prevent the discharge of visible emissions of fugitive dusts beyond lot line of the property.




Time Test Method






If any additional stack testing beyond an initial test (i.e. quarterly, semi-annual, annual, etc.) is required in “Compliance Demonstration Table,” the owner or the owner’s authorized agent shall demonstrate compliance with the emission limitations contained in Condition 1 as specified in the “Compliance Demonstration Table.” See Conditions 12.A.(4) and 12.B.(5) for notification and reporting requirements. If stack testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the “Compliance Demonstration Table” unless another testing methodology is approved by the Department prior to testing. Each emissions compliance test must be approved by the Department. Unless otherwise specified by the Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs shall apply for compliance, unless otherwise indicated by the Department. Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the

Linwood Mining & Minerals Corp. Material Storage Pile 8 (EP Pile 8) Page 3 of 6 Davenport, Iowa 18-A-115 Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.





A. New Source Performance Standards (NSPS): This emission unit is not subject to any New Source Performance Standard (NSPS). There are no applicable subparts for this source category.






A. The owner or operator shall maintain the total area of Pile 8 to less than or equal to 183,860 square feet. i. The owner or operator shall maintain annual records of Pile 8 area in square feet.

B. The owner or operator shall store washed rocks only in Pile 8.


i. The owner or operator shall maintain records of type of rock stored in Pile 8. C. During high wind episodes (greater than 12 miles per hour) if visible emissions are observed from the working face

of Pile 8, the owner or operator shall employ measures to eliminate or minimize emissions. Such measures may include applying dust suppressant to working face of the pile or coverings the working face of the pile.

i. The owner or operator shall develop a written plan to implement at a minimum measures to minimize emissions during high wind episodes as specified in condition 5.C. The written plan and any documentation as required by the plan shall be maintained onsite and available for inspection.





10. Construction

A. General Requirements: It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as submitted. In permit amendments, all provisions of the original permit remain in full force and effect unless they are specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or operator shall seek a permit amendment in order to revert back to the most recent previous version of the permit. The previous, unchanged permit provisions are included in the amendment for your convenience only and are unappealable. This permit or amendment shall become void if any one of the following conditions occurs:


(1) The construction or implementation of the proposed project, as it affects the emission point permitted herein, is not initiated within eighteen (18) months after the permit issuance date; or

(2) The construction or implementation of the proposed project, as it affects the emission point permitted herein, is not completed within thirty-six (36) months after the permit issuance date; or

(3) The construction or implementation of the proposed project, as it affects the emission point permitted herein, is not completed within a time period specified elsewhere in this permit.


The owner or operator shall amend this permit or amendment prior to startup of the equipment if: (1) Any changes are made to the final plans and specifications submitted for the proposed project; or (2) This permit becomes void. Changes to the final plans and specification shall include changes to plans and specifications for permitted equipment and control equipment and the specified operation thereof.












(4) Unless specified per a federal regulation, the owner or the owner’s authorized agent shall notify the Department in writing not less than thirty (30) days before a required test or performance evaluation of a continuous emission


monitor [567 IAC 25.1(7)]. The notification shall include: • The time; the place; the name of the person who will conduct the tests; and other information as required by














Fax: (319) 653-2856



END OF PERMIT








Same

Permitted Equipment

Emission Point ID: Pile 14


Material Storage Pile 14




· [PSP]


Testin!! Date Issue new permit for material storage piles & Establish PM! 0 Limits No 09/06/18


:cPFP:s20 IO I SI:0906201 s: 18011: l 8Al I 6:


PERMIT CONDITIONS

1. a. Emission Limits The owner or operator is required to report all emissions as required by law, regardless of whether a specific emission limit has been established in this permit. The following emission limits shall not be exceeded:


Pile 14


1 The emission limit is expressed in pounds per day. 2 The emission limit is based on a twelve (12) month rolling total. 3 The limit for PM10 controlled emissions for Pile 14 is established at 6.02 pounds of PM10 per day. The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343). 4 The owner or operator shall take reasonable precautions to prevent the discharge of visible emissions of fugitive dusts beyond lot line of the property.




Time Test Method


PM10 Active Surface Silt & Moisture Sampling Quarterly 1 hour





If any additional stack testing beyond an initial test (i.e. quarterly, semi-annual, annual, etc.) is required in “Compliance Demonstration Table,” the owner or the owner’s authorized agent shall demonstrate compliance with the emission limitations contained in Condition 1 as specified in the “Compliance Demonstration Table.” See Conditions 12.A.(4) and 12.B.(5) for notification and reporting requirements. If stack testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the “Compliance Demonstration Table” unless another testing methodology is approved by the Department prior to testing. Each emissions compliance test must be approved by the Department. Unless otherwise specified by the Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs shall apply for compliance, unless otherwise indicated by the Department. Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the

Linwood Mining & Minerals Corp. Material Storage Pile 14 (EP Pile 14) Page 3 of 7 Davenport, Iowa 18-A-116 owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.











A. The owner or operator shall maintain the total area of Pile 14 to less than or equal to 347,974 square feet.


i. The owner or operator shall maintain annual records of Pile 14 area in square feet. B. The average active surface moisture content for the material storage pile 14 shall be greater than or equal to 1.4% by

weight. i. The owner or operator shall sample the active surface of storage pile 14 to determine moisture content as

percent by weight once per calendar quarter. ii. The owner or operator shall take a minimum of two active surface samples per calendar quarter.

iii. The owner or operator shall determine the average moisture content as percent by weight for all samples taken per calendar quarter.

iv. On quarterly basis, the owner or operator shall maintain the following records for each sampling event a) The date of the sample; b) The sample location; c) The measured moisture content as percent weight d); The average moisture content as percent by weight and e) The operator’s initials

C. The average active surface silt from the material storage pile 14 shall be less than or equal to 1.04% by weight. i. The owner or operator shall sample the active surface of storage pile 14 to determine silt content as percent




D. During high wind episodes (greater than 12 miles per hour) if visible emissions are observed from the working face

of Pile 14, the owner or operator shall employ measures to eliminate or minimize emissions. Such measures may include applying dust suppressant to working face of the pile or coverings the working face of the pile.

i. The owner or operator shall develop a written plan to implement at a minimum measures to minimize emissions during high wind episodes as specified in condition 5.D. The written plan and any documentation as required by the plan shall be maintained onsite and available for inspection.



8. Owner and Operator Responsibility This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point as described in this permit and in the application for this permit. The permit holder, owner, and operator of the facility shall assure that the installation of the equipment listed in this permit conforms to the design in the application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this emission unit(s), control equipment, or emission point without the required amended permit. Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring that the

Linwood Mining & Minerals Corp. Material Storage Pile 14 (EP Pile 14) Page 5 of 7 Davenport, Iowa 18-A-116 installation, operation, and maintenance of the equipment listed in this permit is in compliance with the provisions of this permit and all other applicable requirements and that adequate operation and maintenance is provided to ensure that no condition of air pollution is created.


10. Construction








11. Excess Emissions Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good practice for minimizing emissions except when another regulation applicable to the unit or process provides otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be limited to one (1) six-minute period per one (1) hour period. An incident of excess emissions other than the above is a violation and may be subject to criminal penalties according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within a reasonable period of time, as specified in 567 IAC 24.1. An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident [See Permit Condition 12.B.(1)]. A written report of an incident of excess emissions shall be submitted as a follow-up to all required initial reports

Linwood Mining & Minerals Corp. Material Storage Pile 14 (EP Pile 14) Page 6 of 7 Davenport, Iowa 18-A-116 within seven (7) days of the onset of the upset condition [See Permit Condition 12.B.(2)].





















Air Quality Bureau Field Office 6


Iowa Department of Natural Resources 7900 Hickman Road, Suite 1 Windsor Heights, IA 50324 Telephone: (515) 725-9549 Fax: (515) 725-9502

1023 West Madison Washington, IA 52353 Telephone: (319) 653-2135

Fax: (319) 653-2856



END OF PERMIT






563-324-l 93 l [email protected]

401 E Front Street Davenpo11, IA 52761

Same

Permitted Equipment

Emission Point ID: Pile A


Material Storage Pile A (Includes Material Storage Piles Barge, B, E, H)


Issuance of this pennit shall not relieve the owner or operator of the responsibility to comply fully with applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, and federal law.


[PSP]


Modify pe1mit to update pile throughput; enclose units No 03/!4/!9


:cPFP:s20101s1:031420t9:t8366:t8Al 17s i:

Linwood Mining & Minerals Corp. Material Storage Pile A (EP Pile A) Page 2 of 9 Davenport, Iowa 18-A-117-S1

PERMIT CONDITIONS



Pile A (Piles Barge, B, E, H)


1 The emission limit is expressed in pounds per day. 2 The emission limit is based on a twelve (12) month rolling total. 3 The limit for PM10 controlled emissions for Pile A is established at 180 pounds of PM10 per day. The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343). 4 The owner or operator shall take reasonable precautions to prevent the discharge of visible emissions of fugitive dusts beyond lot line of the property.




Time Test Method

PM – State None NA 1 hour

AP-42, Appendix C.1 Procedures for Sampling Surface/Bulk Dust Loading, Appendix C.2 Procedures for Laboratory Analysis of Surface/Bulk Dust Loading Samples

PM10 Active Surface Silt & Moisture Sampling Quarterly 1 hour


PM2.5 None NA 1 hour


Opacity None NA 1 hour 40 CFR 60, Appendix A, Method 9 If an initial stack test is specified in the “Compliance Demonstration Table,” the owner or the owner’s authorized agent shall demonstrate compliance with the emission limitations contained in Condition 1 within the applicable time period specified below:



If any additional stack testing beyond an initial test (i.e. quarterly, semi-annual, annual, etc.) is required in “Compliance Demonstration Table,” the owner or the owner’s authorized agent shall demonstrate compliance with the emission limitations contained in Condition 1 as specified in the “Compliance Demonstration Table.” See Conditions 12.A.(4) and 12.B.(5) for notification and reporting requirements. If stack testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the “Compliance Demonstration Table” unless another testing methodology is approved by the Department prior to testing.

Linwood Mining & Minerals Corp. Material Storage Pile A (EP Pile A) Page 3 of 9 Davenport, Iowa 18-A-117-S1 Each emissions compliance test must be approved by the Department. Unless otherwise specified by the Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs shall apply for compliance, unless otherwise indicated by the Department. Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.

3. a. Emission Point Characteristics This emission point shall conform to the specifications listed below:


The temperature and flowrate are intended to be representative and characteristic of the design of the permitted emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process and ambient conditions. If it is determined that any of the emission point characteristics above are different than the values stated, the owner or operator shall submit a request either by electronic mail or written correspondence to the Department within thirty (30) days of the discovery to determine if a permit amendment is required, or submit a permit application requesting to amend the permit. Description of units covered by this permit:

EP ID

Area (square

feet)

Throughput (tpy)

Load In/Load out (Moisture

%)

Wind Erosion

(Silt Loading %)

Control (Load out)

(% reduction)

Control (load in) (% reduction)

Notes

Pile A

(Piles Barge, B,

E, H)

Pile Barge 244,618 750,000 2.1 3.9

Windscreens on Pile B, E

(50%)

5% of area of each pile

is active working

face

Pile B 131,097 650,000 0.4 0.56

Water Suppression

on Pile B (75%

reduction) Pile E 240,554 500,000 1.6 3.95 Pile H 116,627 20,000 2.1 3.9 No load in

Pile B includes the following units: Kiln 4 Screener (LP-29) (Rated 50.31 tons per hour)[95% enclosed]

Kiln 1, 2, 3 Screener (LP-35) (Rated 43.13 tons per hour) [95% enclosed] Stackers under (LP-30) (Rated 50.31 tons per hour)

Conveyor (LP-34) (Rated 43.13 tons per hour)

Linwood Mining & Minerals Corp. Material Storage Pile A (EP Pile A) Page 4 of 9 Davenport, Iowa 18-A-117-S1 4. Federal Standards






5. Operating Requirements with Associated Monitoring and Recordkeeping Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an orderly manner. The operating requirements and associated recordkeeping for this permit shall be: A. The owner or operator shall maintain the area of merged Pile A (includes Barge, B, E, and H Piles), in square feet to less

than or equal to 1,729,849. i. The owner or operator shall maintain annual records of pile area in square feet.

B. The owner or operator shall maintain the throughput of Pile B in tons, on a daily basis, to less than or equal to 2238. i. The owner or operator shall maintain daily records of pile throughput in tons.

C. The owner or operator shall maintain the throughput of Pile E in tons, on a daily basis, to less than or equal to 2640. i. The owner or operator shall maintain daily records of pile throughput in tons.

D. The owner or operator shall install a wind screen on 5 loadout hoppers within Pile B and Pile E by October 1, 2018. i. The owner or operator shall maintain a record of the date when installation of wind screen is completed.

E. The owner or operator shall maintain the wind screen in a manner to minimize emissions and achieve 50 percent reduction in emissions due to loadout of material from Pile B and Pile E loadout hopper. The wind screen shall at minimum be enclosed on three sides, at a height of 5 feet above the hopper and maintained in good working order.

i. The owner or operator shall develop an operating and maintenance plan for the Pile B and Pile E loadout hopper wind screen, including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance.

ii. The owner or operator shall maintain a record of all inspections and maintenance and any action resulting from the inspection and maintenance of the Pile B and Pile E loadout hopper windscreen.

F. The owner or operator shall operate water suppression system when visible emissions from processing units located in Pile B are observed except when the ambient air temperature (as measured at the facility during daylight operating hours) will be less than 35o F (1.7o C) or conditions due to weather could create hazardous conditions.

G. The owner or operator shall check for visible emissions each time the processing units located in Pile B are in operation. This requirement shall not apply on the days that processing units located in Pile B are not in operation.


ii. If the owner or operator observes visible emissions, the owner or operator shall investigate the emission unit, or the operations associated with the emission unit and make corrections to the associated operations or equipment. The owner or operator shall maintain a record of all corrective actions taken.

H. The owner or operator shall develop an operating and maintenance plan for the water suppression system, including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance.


I. The owner or operator shall check for visible emissions from the equipment operating within Pile Barge and Pile E once


per day at a time while the equipment is in use. i. The owner or operator shall record the date and time of the observation and the presence or absence of visible

emissions. If the owner or operator observes visible emissions from the equipment with the piles, the owner or operator shall investigate the emission unit or operations associated with the emission unit and make corrections to the associated operations or equipment. The owner or operator shall maintain a record of all corrective actions taken. This requirement shall not apply on the days that processing units located within the pile are not in operation.

J. During high wind episodes (greater than 12 miles per hour) if visible emissions are observed from the working face of Pile Barge, Pile B, Pile E, or Pile H, the owner or operator shall employ measures to eliminate or minimize emissions. Such measures shall include applying dust suppressant to working face of the pile or coverings the working face of the pile.

i. The owner or operator shall develop a written plan to implement, at a minimum, measures to minimize emissions during high wind episodes as specified in condition 5.J. The written plan and any documentation as required by the plan shall be maintained onsite and available for inspection.

K. The average active surface moisture content for the material storage pile Barge shall be greater than or equal to 2.1% by weight.

i. The owner or operator shall sample the active surface of storage pile Barge to determine moisture content as percent by weight once per calendar quarter.

ii. The owner or operator shall take a minimum of two active surface samples per calendar quarter. iii. The owner or operator shall determine the average moisture content as percent by weight for all samples taken

per calendar quarter. iv. On quarterly basis, the owner or operator shall maintain the following records for each sampling event a) The


L. The average active surface silt from the material storage pile Barge shall be less than or equal to 3.9% by weight. i. The owner or operator shall sample the active surface of storage pile Barge to determine silt content as percent




M. The average active surface moisture content for the material storage pile B shall be greater than or equal to 0.4% by weight. i. The owner or operator shall sample the active surface of storage pile B to determine moisture content as percent




N. The average active surface silt from the material storage pile B shall be less than or equal to 0.56% by weight. i. The owner or operator shall sample the active surface of storage pile B to determine silt content as percent by




O. The average active surface moisture content for the material storage pile E shall be greater than or equal to 1.6% by weight. i. The owner or operator shall sample the active surface of storage pile E to determine moisture content as percent



iv. On quarterly basis, the owner or operator shall maintain the following records for each sampling event a) The date of the sample; b) The sample location; c) The measured moisture content as percent weight d); The average


moisture content as percent by weight and e) The operator’s initials P. The average active surface silt from the material storage pile E shall be less than or equal to 3.95% by weight.

i. The owner or operator shall sample the active surface of storage pile E to determine silt content as percent by weight once per calendar quarter.

ii. The owner or operator shall take a minimum of two active surface samples per calendar quarter. iii. The owner or operator shall determine the average silt content as percent by weight for all samples taken per

calendar quarter. iv. On quarterly basis, the owner or operator shall maintain the following records for each sampling event a) The

date of the sample; b) The sample location; c) The measured silt content as percent weight d); The average silt content as percent by weight and e) The operator’s initials.

Q. Beginning June 30, 2019, the owner or operator shall maintain Pile Barge, Pile B, and Pile E a minimum distance of 80 feet from the fence line along highway 22.

i. The owner or operator shall maintain records of the date when Pile Barge, Pile B and Pile E were setback 80 feet from the fence line along highway 22.

ii. The owner or operator shall maintain annual records of the distance from the fence line along highway 22 for Pile Barge, Pile B and Pile E.

R. The owner or operator shall install an enclosed building structure to utilize 95 percent reduction of particulate emissions generated, by June 30, 2019, at:

i. Kiln 4 Screener (LP-29) ii. Kiln 1, 2, 3 Screener (LP-35)

iii. The owner or operator shall maintain records of the completion date for the building enclosure on Kiln 4 Screener (LP-29) and Kiln 4 Screener (LP-29).

S. The owner or operator shall develop an operating and maintenance plan for the building structure, including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance.

i. The owner or operator shall maintain a record of all inspections and maintenance and any action resulting from the inspection and maintenance of the building structure.

T. The owner or operator shall maintain equipment to ensure 24-hour surveillance of all gaps in the property berm along the river boundaries. “No Trespassing” signs shall be posted at both ends of the gap in the property berm coverage to further restrict public access.

U. The owner or operator shall maintain a fence along all property lines except as specified in condition 5T to restrict public access to the facility’s property.

V. The owner or operator shall install and maintain signage to restrict public access from the landfill to Linwood property by June 30, 2019.



8. Owner and Operator Responsibility This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point as described in this permit and in the application for this permit. The permit holder, owner, and operator of the facility shall assure that the installation of the equipment listed in this permit conforms to the design in the application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this emission unit(s), control equipment, or emission point without

Linwood Mining & Minerals Corp. Material Storage Pile A (EP Pile A) Page 7 of 9 Davenport, Iowa 18-A-117-S1 the required amended permit. Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person who becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the provisions of this permit and all other applicable requirements and that adequate operation and maintenance is provided to ensure that no condition of air pollution is created.


10. Construction








11. Excess Emissions Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good practice for minimizing emissions except when another regulation applicable to the unit or process provides otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be limited to one (1) six-minute period per one (1) hour period. An incident of excess emissions other than the above is a violation and may be subject to criminal penalties according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within a reasonable period of time, as specified in 567 IAC 24.1.

Linwood Mining & Minerals Corp. Material Storage Pile A (EP Pile A) Page 8 of 9 Davenport, Iowa 18-A-117-S1 An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident [See Permit Condition 12.B.(1)]. A written report of an incident of excess emissions shall be submitted as a follow-up to all required initial reports within seven (7) days of the onset of the upset condition [See Permit Condition 12.B.(2)].




















information being submitted: change in ownership (Air Quality Bureau Records Center), permit correspondence (Construction Permit Supervisor), stack testing correspondence (Stack Test Coordinator), and reports and notifications





Fax: (319) 653-2856


14. Permit History


Testing 18-A-117 18-017 Issue new permit for material storage piles & Establish PM10 Limits 09/06/18 No

END OF PERMIT








Emission Point ID: Q-1

Same

Permitted Equipment


EUID Description Maximum Rated Control Equipment Description and ID Capacity

* Quarry 1 Equipment and

Pile 6 * *See Emission Unit list in Condition 3


700 Tons Per Hour Water Suppression


Project Project Description Number 18-017 Amend permit limit and add water suppression

[PSP]

Stack Issuance Testinf!: Date

No 09/06/18

\


:cPFP:82010151:0906201 &: 180 l 7: 11A337S 1:

Linwood Mining & Minerals Corp. Quarry 1 Equipment and Pile 6 (EP Q-1) Page 2 of 8 Davenport, Iowa 11-A-337-S1

PERMIT CONDITIONS

1. a. Emission Limits (Q1 Crusher and Q1 Conveyor#1) The owner or operator is required to report all emissions as required by law, regardless of whether a specific emission limit has been established in this permit. The following emission limits shall not be exceeded:


1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 The limit for PM10 emissions for Q-1 Crusher and Q-1 Belt #1 is established at 9.84 pounds of PM10 per day. The PM10 limit

established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343).


1. b. Emission Limits (Quarry 1 Stacker and Pile 6) The following emission limits shall not be exceeded:


1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 The limit for PM10 emissions for Q-1 Stacker is established at 10.64 pounds per day The PM10 limit established for attainment and



1. c. Emission Limits (NSPS OOO Q-1 Stacker)

Pollutant lb/hr tons/yr Other Limits Reference/Basis Opacity (Q-1 Stacker) NA NA 7% 2 567 IAC 23.1(2)“bbb” 1

1 NSPS Subpart OOO reference. 2 Limit established per Table 3 of Subpart OOO Part 60.

Linwood Mining & Minerals Corp. Quarry 1 Equipment and Pile 6 (EP Q-1) Page 3 of 8 Davenport, Iowa 11-A-337-S1 2. Compliance Demonstration(s)



Time Test Method









Linwood Mining & Minerals Corp. Quarry 1 Equipment and Pile 6 (EP Q-1) Page 4 of 8 Davenport, Iowa 11-A-337-S1 The temperature and flowrate are intended to be representative and characteristic of the design of the permitted emission point. The Department recognizes that the temperature and flow rate may vary with changes in the process and ambient conditions. If it is determined that any of the emission point characteristics above are different than the values stated, the owner or operator shall submit a request either by electronic mail or written correspondence to the Department within thirty (30) days of the discovery to determine if a permit amendment is required, or submit a permit application requesting to amend the permit. The following emission units are associated with this permit:

Emission Unit Maximum Capacity Control Primary Crusher (Q-1) 700 tons per hour Water Suppression Conveyor #1 (Q1C1) 700 tons per hour Water Suppression

Stacker (Q1C2) 700 tons per hour Water Suppression Pile 6 (In pit)

Maximum Pile Area: 26,685 ft2


A. New Source Performance Standards (NSPS): The facility is of the source type subject to the New Source Performance Standard (NSPS), Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants. The crusher and conveyor #1 are not subject to the NSPS Subpart OOO, as they were built prior to the rule applicability date. The stacker is subject to the NSPS Subpart OOO.






A. The owner or operator shall operate water suppression system when visible emissions from processing units Q-1 Crusher, Q-1 Conveyor#1 or Q-1 Stacker are observed.

B. The owner or operator shall check for visible emissions each time the processing units Q-1 Crusher, Q-1 Conveyor#1 and Q-1 Stacker are in operation. This requirement shall not apply on the days that processing units Q-1 Crusher, Q-1 Conveyor#1 and Q-1 Stacker are not in operation.


ii. If the owner or operator observes visible emissions during operation of processing units Q-1 Crusher, Q-1 Conveyor#1 and Q-1 Stacker, the owner or operator shall investigate the emission unit, or the operations associated with the emission unit and make corrections to the associated operations or equipment. The owner or operator shall maintain a record of all corrective actions taken.

C. The owner or operator shall develop an operating and maintenance plan for the water suppression system, including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance.


I

Linwood Mining & Minerals Corp. Quarry 1 Equipment and Pile 6 (EP Q-1) Page 5 of 8 Davenport, Iowa 11-A-337-S1 D. The owner or operator shall maintain the total area of Pile 6 to less than or equal to 26,685 square feet.

i. The owner or operator shall maintain annual record of Pile 6 area in square feet.

E. During high wind episodes (greater than 16 miles per hour) if visible emissions are observed from the working face of Pile 6, the owner or operator shall employ measures to eliminate or minimize emissions. Such measures may include applying dust suppressant to working face of the pile or coverings the working face of the pile.

ii. The owner or operator shall develop a written plan to implement, at a minimum, measures to minimize emissions during high wind episodes as specified in condition 5E. The written plan and any documentation as required by the plan shall be maintained onsite and available for inspection.

F. The owner or operator shall comply with the requirements per 40 CFR §60.670 through §60.676 for Q-1 Stacker.





10. Construction

A. General Requirements: It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as submitted. In permit amendments, all provisions of the original permit remain in full force and effect unless they are specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or operator shall seek a


permit amendment in order to revert back to the most recent previous version of the permit. The previous, unchanged permit provisions are included in the amendment for your convenience only and are unappealable. This permit or amendment shall become void if any one of the following conditions occurs: (1) The construction or implementation of the proposed project, as it affects the emission point permitted herein, is































Fax: (319) 653-2856


Linwood Mining & Minerals Corp. Quarry 1 Equipment and Pile 6 (EP Q-1) Page 8 of 8 Davenport, Iowa 11-A-337-S1 14. Permit History


Testing 11-A-337 10-603 Permit new conveyor system layout for grandfathered primary crusher 06/16/2011 No

END OF PERMIT







40 I E Front Street Davenpmt, IA 52761

Same

Permitted Equipment

Emission Point ID: Q 11 C


EUID Description

* Q 11 C Equipment & Pile I * *See Emission Unit list in Condition 3


Maximum Rated Capacitv

*

Control Equipment Descrintion and ID

*



[PSP]

Project Description Stack Issuance Testing Date

Increase equipment capacity; move pile I back 85 feet No 03/14/19


ICPFP1820l0l5l:o3 l420l9i18366118Al 11s1:

Linwood Mining & Minerals Corp. Q11C Equipment and Pile I (EP Q11C) Page 2 of 8 Davenport, Iowa 18-A-111-S1

PERMIT CONDITIONS

1. a. Emission Limits (Q11C Sugarbeet Plant and Screener) The owner or operator is required to report all emissions as required by law, regardless of whether a specific emission limit has been established in this permit. The following emission limits shall not be exceeded:


1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 The limit for PM10 emissions is established at 1.44 pounds of PM10 per day. The PM10 limit established for attainment and



1. b. Emission Limits (Pile I) The following emission limits shall not be exceeded:


1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 The limit for PM10 emissions for Pile I is established at 3.96 pounds per day. The PM10 limit established for attainment and






Time Test Method




• Within sixty (60) days after achieving the maximum production rate and no later than one hundred eighty (180) days after the initial startup date of the proposed equipment for the addition of new equipment or the physical modification


of existing equipment or control equipment. • Within ninety (90) days of the issuance of this permit if there is no physical modification to any emission units or





Linwood Mining & Minerals Corp. Q11C Equipment and Pile I (EP Q11C) Page 4 of 8 Davenport, Iowa 18-A-111-S1 The following emission are associated with this emission point:

Emission Unit Maximum Capacity Control Feed Conveyor (Q11C-1) 105 tons per hour Building Enclosure

Screener (Q11C-2) 105 tons per hour Building Enclosure Overs Conveyor (Q11C-3) 10 tons per hour Building Enclosure

Unders Conveyor (Q11C-4) 10 tons per hour Building Enclosure Weigh Conveyor (Q11C-5) 85 tons per hour Building Enclosure

Stacker (Q11C-6) 85 tons per hour None Pile I

Load In: 2.1% moisture Load Out: windscreen (50% control efficiency), 2.1% moisture

Wind erosion: 3.9% Silt Loading Area: 28,179 ft2


A. New Source Performance Standards (NSPS): The facility is of the source type subject to the New Source Performance Standard (NSPS), Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants. The units permitted in this permit are not subject to the NSPS Subpart OOO, as they were built prior to the rule applicability date.






A. The owner or operator shall maintain the building as an enclosed structure to utilize 95 percent reduction of particulate emissions generated at:

i. Q-11C-1 Feed Conveyor ii. Q-11C-2 Screener

iii. Q-11C-3 Overs Conveyor iv. Q-11C-4 Unders Conveyor v. Q-11C-5 Weight Conveyor

B. The owner or operator shall develop an operating and maintenance plan for the building structure, including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance.

i. The owner or operator shall maintain a record of all inspections and maintenance and any action resulting from the inspection and maintenance of the building structure.

C. The owner or operator shall install a wind screen on Pile I hopper by October 1, 2018. i. The owner or operator shall maintain a record of the date when installation of wind screen is completed.

D. The owner or operator shall maintain the wind screen in a manner to minimize emissions and achieve 50 percent


reduction in emissions due to loadout of material from pile I hopper. The wind screen shall be at minimum enclosed on three sides, at a height of 5 feet above the hopper and maintained in good working order.

i. The owner or operator shall develop an operating and maintenance plan for the pile I hopper wind screen, including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance.

ii. The owner or operator shall maintain a record of all inspections and maintenance and any action resulting from the inspection and maintenance of the pile I hopper windscreen.

E. The owner or operator shall check for visible emissions from building enclosing all units associated with EP Q-11C once per calendar day at a time while units associated with EP Q-11C is in operation.

i. The owner or operator shall record the date and time of the observation and the presence or absence of visible emissions. If the owner or operator observes visible emissions from building enclosing units associated with EP Q-11C, the owner or operator shall investigate the emission unit or operations associated with the emission unit and make corrections to the associated operations or equipment. The owner or operator shall maintain a record of all corrective actions taken. This requirement shall not apply on the days that units associated with EP Q-11C are not in operation.

F. The owner or operator shall maintain the total area of Pile I to less than or equal to 28,179 square feet. i. The owner or operator shall maintain annual records of Pile I area in square feet.

G. During high wind episodes (greater than 12 miles per hour) if visible emissions are observed from the working face of Pile I, the owner or operator shall employ measures to eliminate or minimize emissions. Such measures may include applying dust suppressant to working face of the pile or coverings the working face of the pile.

i. The owner or operator shall develop a written plan to implement at a minimum measures to minimize emissions during high wind episodes as specified in condition 5.G. The written plan and any documentation as required by the plan shall be maintained onsite and available for inspection.

H. Beginning June 30, 2019, the owner or operator shall maintain Pile I a minimum distance of 85 feet from the fence line along highway 22.

i. The owner or operator shall maintain records of the date when Pile I was moved 85 feet from the fence line along highway 22.

ii. The owner or operator shall maintain annual records of the distance from the fence line along highway 22 for Pile I.



8. Owner and Operator Responsibility This permit is for the construction and operation of specific emission unit(s), control equipment, and emission point as described in this permit and in the application for this permit. The permit holder, owner, and operator of the facility shall assure that the installation of the equipment listed in this permit conforms to the design in the application (i.e. type, maximum rated capacity, etc.). No person shall construct, install, reconstruct or alter this emission unit(s), control equipment, or emission point without the required amended permit. Any owner or operator of the specified emission unit(s), control equipment, or emission point, including any person who

Linwood Mining & Minerals Corp. Q11C Equipment and Pile I (EP Q11C) Page 6 of 8 Davenport, Iowa 18-A-111-S1 becomes an owner or operator subsequent to the date on which this permit is issued, is responsible for assuring that the installation, operation, and maintenance of the equipment listed in this permit is in compliance with the provisions of this permit and all other applicable requirements and that adequate operation and maintenance is provided to ensure that no condition of air pollution is created.


10. Construction








11. Excess Emissions Per 567 IAC 24.1(1), excess emissions during a period of startup, shutdown, or cleaning of control equipment are not a violation of the emission standard if it is accomplished expeditiously and in a manner consistent with good practice for minimizing emissions except when another regulation applicable to the unit or process provides otherwise. Cleaning of control equipment, which does not require the shutdown of process equipment, shall be limited to one (1) six-minute period per one (1) hour period. An incident of excess emissions other than the above is a violation and may be subject to criminal penalties according to Iowa Code 455B.146A. If excess emissions are occurring, either the control equipment causing the excess shall be repaired in an expeditious manner, or the process generating the emissions shall be shutdown within a reasonable period of time, as specified in 567 IAC 24.1. An incident of excess emissions shall be orally reported by telephone, electronic mail or in person to the appropriate field office within eight (8) hours of, or at the start of, the first working day following the onset of the incident [See Permit Condition

Linwood Mining & Minerals Corp. Q11C Equipment and Pile I (EP Q11C) Page 7 of 8 Davenport, Iowa 18-A-111-S1 12.B.(1)]. A written report of an incident of excess emissions shall be submitted as a follow-up to all required initial reports within seven (7) days of the onset of the upset condition [See Permit Condition 12.B.(2)].
























Fax: (319) 653-2856


14. Permit History


Testing 18-A-111 18-017 Permit as-built screening plant & Establish PM10 Limits 09/06/18 No

END OF PERMIT

[PSP] ¦CPFP¦8201015¦09032020¦20169¦20A156¦






Darin Osland Same


563-324-1931

[email protected]

401 E Front Street

Davenport, IA 52804

Permitted Equipment

Emission Point ID: Q-12



Capacity

Control Equipment

Description and ID

* Q-12 Equipment * 400 Tons per hour None



Davenport, IA 52761



Project


Stack

Testing

Issuance

Date

20-169 Original Permit - Aggregate Processing Plant Yes 09/03/20



Linwood Mining & Minerals Corp. Q-12 Equipment (EP Q-12) Page 2 of 7

Davenport, Iowa 20-A-156

PERMIT CONDITIONS

1. a. Emission Limits




Particulate Matter (PM) – State NA NA NA NA

PM10 NA NA 3 NA

PM2.5 NA NA NA NA

Opacity (Screeners, Conveyors) NA NA 10% 4 567 IAC 23.1(2)“bbb” 5

Opacity (Crusher) NA NA 15% 4 567 IAC 23.1(2)“bbb” 5

1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 The limit for PM10 emissions for Q-12 equipment is established at 131 pounds of PM10 per day. The PM10 limit established for

attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved into the state implementation

plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343). 4 Limit established per Table 3 of Subpart OOO Part 60. 5 NSPS Subpart OOO reference.





Time Test Method





Opacity Initial Stack Test1 One-time 1 hour 40 CFR 60, Appendix A, Method 9 1 Opacity test/monitoring shall be conducted per NSPS Subpart OOO (40 CFR §60.670 – 40 CFR §60.676)



below:





control equipment.

























3. a. Emission Point Characteristics


Parameter Value

Stack Height (feet from the ground) NA

Discharge Style NA

Stack Outlet Dimensions (inches) NA

Exhaust Temperature (oF) NA

Exhaust Flowrate (scfm) NA






3. b. The following emission units are associated with this permit:

Emission Unit ID Emission Unit Name Maximum Capacity Control

Q-12-01 Crusher 400 tons per hour None

Q-12-02 Screener 400 tons per hour None

Q-12-03 Conveyor Overs 100 tons per hour None

Q-12-04 Conveyor Cut 300 tons per hour None

Q-12-05 Conveyor Unders 100 tons per hour None

Q-12-06 Conveyor Screen 400 tons per hour None



The units associated with EP Q-12 are of the source type subject to the New Source Performance Standard (NSPS),

Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants. Q-12 equipment are subject to

the NSPS Subpart OOO from §60.670 to §60.676.







source category.







A. The maximum amount of product processed in the Crusher (EU Q-12-01) shall not exceed 400 tons per hour averaged

over 24-hr period.

i. The owner or operator shall maintain records of the 24-hour average of the amount of product processed in

the Crusher (EU Q-12-01) in tons.

ii. The owner or operator shall maintain records of the number of hours the Crusher (EU Q-12-01) is operated

on a daily basis.

iii. The owner or operator shall calculate and maintain records of the 24-hr average rate of the material processed

in tons per hour on a daily basis.

B. The Q-12 Equipment listed in 3. b. of this permit shall not operate more than 3,250 hours in any rolling 12-month

period.

i. The owner or operator shall maintain records of the number of hours the Q-12 Equipment is operated on a

daily basis.

ii. The owner or operator shall calculate and record the monthly total hours of operation of the Q-12 Equipment.

iii. The owner or operator shall calculate and record the rolling 12-month total of the hours of operation of the

Q-12 equipment.

C. The owner or operator can use engine run-time hours for the engine used to power the Q-12 Equipment; or,

D. The owner or operator can use paper records showing daily operation in hours of the Q-12 Equipment.

E. The owner or operator shall follow requirements per 40 CFR §60.670 through §60.676.


























9. Transferability



10. Construction




















C. Amended Permits:













period.




in 567 IAC 24.1.







(1) Per 567 IAC 22.3(3)“b”:


















the Department.




(30) days.







upset condition.









shall be met.











Air Quality Bureau


502 E. 9th St.


Telephone: (515) 725-8200

Fax: (515) 725-9501

Field Office 6

1023 West Madison


Telephone: (319) 653-2135

Fax: (319) 653-2856

13. Appeal Rights





are unappealable.

14. Permit History

Permit No. Project

No. Description Date

Stack

Testing

END OF PERMIT








Same

Permitted Equipment

Emission Point ID: Q-2LP


EU ID I Description I Maximum Rated Capacity

• • I 300 TPH; Recycle rate I 00 TPH




None

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, and federal law,


[PSP]


Amend emission rate due to change in emission factor No 03/14/19


ICPFPl820 I Ol 51i03142019i 18366il8Al 12S Ii

Linwood Mining & Minerals Corp. Quarry 2LP Equipment and Pile 7 (EP Q-2LP) Page 2 of 8 Davenport, Iowa 18-A-112-S1

PERMIT CONDITIONS

1. a. Emission Limits (Q-2LP Crusher and other equipment) The owner or operator is required to report all emissions as required by law, regardless of whether a specific emission limit has been established in this permit. The following emission limits shall not be exceeded:


1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 The limit for PM10 emissions for Q-2LP equipment is established at 127.92 pounds of PM10 per day. The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343). 4 The owner or operator shall take reasonable precautions to prevent the discharge of visible emissions of fugitive dusts beyond lot line of the property.

1. b. Emission Limits (Stackers and Pile 7) The following emission limits shall not be exceeded:


1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 The limit for PM10 emissions for Q-2LP Stackers is established at 9.36 pounds per day. The PM10 limit established for attainment and






Time Test Method



Linwood Mining & Minerals Corp. Quarry 2LP Equipment and Pile 7 (EP Q-2LP) Page 3 of 8 Davenport, Iowa 18-A-112-S1 If an initial stack test is specified in the “Compliance Demonstration Table,” the owner or the owner’s authorized agent shall demonstrate compliance with the emission limitations contained in Condition 1 within the applicable time period specified below:







Linwood Mining & Minerals Corp. Quarry 2LP Equipment and Pile 7 (EP Q-2LP) Page 4 of 8 Davenport, Iowa 18-A-112-S1 The following emission units are associated with this permit:

Emission Unit Maximum Capacity Control LP1 Belt 400 tons per hour None

LP1 Screen 400 tons per hour None LP1 Crusher 100 tons per hour None

LP6 Belt 100 tons per hour None LP9 Belt 100 tons per hour None

LP4A Belt 75 tons per hour None LP2 screen 100 tons per hour None LP4 Stacker 75 tons per hour None LP3 Stacker 125 tons per hour None LP5 Stacker 40 tons per hour None LP8 Stacker 60 tons per hour None

Pile 7 (In pit) Maximum Pile Area: 19,461 ft2








A. The owner or operator shall check for visible emissions each time the processing units listed in Condition 3 are in operation. This requirement shall not apply on the days that processing units listed in Condition 3 are not in operation.


ii. If the owner or operator observes visible emissions during operation of processing units listed in Condition 3, the owner or operator shall investigate the emission unit, or the operations associated with the emission unit and make corrections to the associated operations or equipment. The owner or operator shall maintain a record of all corrective actions taken.

B. The owner or operator shall maintain the total area of Pile 7 to less than or equal to 19,461 square feet. i. The owner or operator shall maintain annual records of Pile 7 area in square feet.

C. The owner or operator shall check for visible emissions from the equipment operating within Pile 7 once per day at a time while the equipment is in use.

i. The owner or operator shall record the date and time of the observation and the presence or absence of visible emissions. If the owner or operator observes visible emissions from the equipment with the piles, the owner

I


or operator shall investigate the emission unit or operations associated with the emission unit and make corrections to the associated operations or equipment. The owner or operator shall maintain a record of all corrective actions taken. This requirement shall not apply on the days that processing units located within the pile are not in operation.

D. During high wind episodes (greater than 16 miles per hour) if visible emissions are observed from the working face of Pile 7, the owner or operator shall employ measures to eliminate or minimize emissions. Such measures may include applying dust suppressant to working face of the pile or coverings the working face of the pile.

i. The owner or operator shall develop a written plan to implement, at a minimum, measures to minimize emissions during high wind episodes as specified in condition 5.D. The written plan and any documentation as required by the plan shall be maintained onsite and available for inspection.





10. Construction

A. General Requirements: It is the owner's responsibility to ensure that construction conforms to the final plans and specifications as submitted. In permit amendments, all provisions of the original permit remain in full force and effect unless they are specifically changed by the permit amendment. If a proposed project is not timely completed, the owner or operator shall seek a


permit amendment in order to revert back to the most recent previous version of the permit. The previous, unchanged permit provisions are included in the amendment for your convenience only and are unappealable. This permit or amendment shall become void if any one of the following conditions occurs: (1) The construction or implementation of the proposed project, as it affects the emission point permitted herein, is































Fax: (319) 653-2856

Linwood Mining & Minerals Corp. Quarry 2LP Equipment and Pile 7 (EP Q-2LP) Page 8 of 8 Davenport, Iowa 18-A-112-S1 13. Appeal Rights All conditions within an original permit may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. Amended conditions within a permit amendment may be appealed, subject to the appeal rights set forth in 561 IAC Chapter 7. In permit amendments, all provisions of the original permit remain in full force and effect unless they are specifically changed by the permit amendment. The previous, unchanged permit provisions are included in the amendment for your convenience only and are unappealable. 14. Permit History


Testing 18-A-112 18-017 Permit as-built plant & Establish PM10 Limits 09/06/18 No

END OF PERMIT






Same



Permitted Equipment

Emission Point ID: Q-2TP


EUID Description

* Quarry 2TP Equipment and Pile 4 *



Maximum Rated Capacity Control Equipment Descriotion and ID

400 TPH; Recycle rate 25 Water Suppression TPH (CEQ-2TP)

Issuance of this permit shall not relieve the owner or operator of the responsibility to comply fully with applicable provisions of the State Implementation Plan (SIP), and any other requirements of local, state, and federal Jaw.


I 8-017 Permit as-built plant & Establish PMI0 Limits

[PSP]

Stack Issuance . Testin11: Date

No 09/06/18

Under the Direction of the Director of the Department ofNatural Resources

:cPFP:s20101s1:09062018i18017il8Al n:

Linwood Mining & Minerals Corp. Quarry 2TP Equipment and Pile 4 (EP Q-2TP) Page 2 of 8 Davenport, Iowa 18-A-113

PERMIT CONDITIONS

1. a. Emission Limits (Q2TP equipment) The owner or operator is required to report all emissions as required by law, regardless of whether a specific emission limit has been established in this permit. The following emission limits shall not be exceeded:


1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 The limit for PM10 emissions for Q-2TP equipment is established at 18.96 pounds of PM10 per day. The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343). 4 The owner or operator shall take reasonable precautions to prevent the discharge of visible emissions of fugitive dusts beyond lot line of the property.


EP Pollutant lb/hr1 tons/yr2 Other Limits Reference/Basis

Pile 4


1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 The limit for PM10 emissions for the Q-2TP stackers and Pile 4 is established at 13.44 pounds per day. The PM10 limit established for

attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343).






PM10 Active Surface Silt & Moisture

Sampling Quarterly 1 hour



• Within sixty (60) days after achieving the maximum production rate and no later than one hundred eighty (180) days after the initial startup date of the proposed equipment for the addition of new equipment or the physical modification


of existing equipment or control equipment. • Within ninety (90) days of the issuance of this permit if there is no physical modification to any emission units or





Linwood Mining & Minerals Corp. Quarry 2TP Equipment and Pile 4 (EP Q-2TP) Page 4 of 8 Davenport, Iowa 18-A-113 The following emission units are associated with this permit:

Emission Unit Maximum Capacity Control TP1a Belt 400 tons/hr Water Suppression TP1b Belt 400 tons/hr Water Suppression TP2 Belt 425 tons/hr Water Suppression

TP1 N Screen 212 tons/hr Water Suppression TP1 S Screen 213 tons/hr Water Suppression

TP3 Crusher Belt 25 tons/hr Water Suppression TP1 Crusher 25 tons/hr Water Suppression

TP4 Crusher Return Belt 25 tons/hr Water Suppression TP6 Cross Belt 325 tons/hr Water Suppression

TP8 Belt 325 tons/hr Water Suppression TP3 West Screen 150 tons/hr Water Suppression TP4 East Screem 175 tons/hr Water Suppression

TP9 Belt 125 tons/hr Water Suppression TP11 Belt 125 tons/hr Water Suppression

TP14 Belt Washer 100 tons/hr Water Suppression TP12 Belt 50 tons/hr Water Suppression TP17 Belt 50 tons/hr Water Suppression

TP6 PEP Screen 50 tons/hr Water Suppression TP5 Sugarbeet Stacker 100 tons/hr None

TP16 Belt Stacker (wet material processed) 100 tons/hr None TP18 Stacker (wet material processed) 25 tons/hr None TP19 Stacker (wet material processed) 25 tons/hr None








Linwood Mining & Minerals Corp. Quarry 2TP Equipment and Pile 4 (EP Q-2TP) Page 5 of 8 Davenport, Iowa 18-A-113 5. Operating Requirements with Associated Monitoring and Recordkeeping Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an orderly manner. The operating requirements and associated recordkeeping for this permit shall be:

A. The owner or operator shall operate water suppression system when visible emissions from processing units listed in Condition 3 are observed.

B. The owner or operator shall check for visible emissions each time the processing units listed in Condition 3 are in operation. This requirement shall not apply on the days that processing units listed in Condition 3 are not in operation.


ii. If the owner or operator observes visible emissions during operation of processing units listed in Condition 3, the owner or operator shall investigate the emission unit, or the operations associated with the emission unit and make corrections to the associated operations or equipment. The owner or operator shall maintain a record of all corrective actions taken.

C. The owner or operator shall develop an operating and maintenance plan for the water suppression system, including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance.


D. The owner or operator shall maintain the total area of Pile 4 to less than or equal to 47,468 square feet. i. The owner or operator shall maintain annual records of Pile 4 area in square feet.

E. The average active surface moisture content for the material storage pile 4 shall be greater than or equal to 2.1% by weight. i. The owner or operator shall sample the active surface of storage pile 4 to determine moisture content as

percent by weight once per calendar quarter. ii. The owner or operator shall take a minimum of two active surface samples per calendar quarter.



F. The average active surface silt from the material storage pile 4 shall be less than or equal to 3.9% by weight. i. The owner or operator shall sample the active surface of storage pile 4 to determine silt content as percent by




G. During high wind episodes (greater than 12 miles per hour) if visible emissions are observed from the working face of Pile 4 the owner or operator shall employ measures to eliminate or minimize emissions. Such measures may include applying dust suppressant to working face of the pile or coverings the working face of the pile.

i. The owner or operator shall develop a written plan to implement, at a minimum, measures to minimize emissions during high wind episodes as specified in condition 5.G. The written plan and any documentation as required by the plan shall be maintained onsite and available for inspection.

H. The owner or operator shall only process wet material in TP16 Belt Stacker, TP18 Stacker, and TP19 Stacker. i. The owner or operator shall maintain a record if non-wet material is processed in TP16 Belt Stacker, TP18

Stacker, and TP19 Stacker.

Linwood Mining & Minerals Corp. Quarry 2TP Equipment and Pile 4 (EP Q-2TP) Page 6 of 8 Davenport, Iowa 18-A-113 6. Continuous Emission Monitoring Systems (CEMS) Continuous emission monitoring is not required by this permit at this time.




10. Construction


















Fax: (319) 653-2856



Testing

END OF PERMIT







40 I E Front Street Davenpo1i, IA 52761

Same

Permitted Equipment

Emission Point ID: Q-3P


EUID Description Maximum Rated Control Equipment Description and ID Capacity

* Q-3P Equipment and Pile 9*

*See Emiss10n Unit list in Condition 3

Equipment Location: 40 I E Front Street Davenpo1i, IA 52761

150 Tons Per Hour Enclosure



[PSP]

Project Description Stack Issuance Testin2 Date

Amend permit limit due to use of correct emission factors No 03/14/19


:cPFP:s2010 l SI:m 142019: 1 s366:02A0 17S3:

Linwood Mining & Minerals Corp. Q-3P Equipment and Pile 9 (EP Q-3P) Page 2 of 8 Davenport, Iowa 02-A-017-S3

PERMIT CONDITIONS

1. a. Emission Limits (Q-3P Equipment) The owner or operator is required to report all emissions as required by law, regardless of whether a specific emission limit has been established in this permit. The following emission limits shall not be exceeded:


1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 The limit for PM10 controlled emissions for Q-3P equipment is established at 21.60 pounds of PM10 per day. The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343). 4 The owner or operator shall take reasonable precautions to prevent the discharge of visible emissions of fugitive dusts beyond lot line of the property.



1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 The limit for PM10 emissions for stackers and pile 9 is established at 1.38 pounds per day. The PM10 limit established for attainment

and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343).


1. c. Emission Limits (NSPS OOO) The following emission limits shall not be exceeded for Q-3P equipment:

Pollutant lb/hr tons/yr Other Limits Reference/Basis

Opacity (Screeners) NA NA 10% 2 567 IAC 23.1(2)“bbb” 1 Opacity (Crusher) NA NA 15% 2 567 IAC 23.1(2)“bbb” 1

1 NSPS Subpart OOO reference. 2 Limit established per Table 3 of Subpart OOO Part 60.





Time Test Method











Emission Unit Maximum Capacity Control Q-03E Crusher 75 tons per hour None

Q-03F Belt 75 tons per hour None Q-03G Stacker 50 tons per hour None

Q-03H Belt 120 tons per hour None Q-03I Screen WET 120 tons per hour None

Q-03J Stacker 120 tons per hour None Q-03B Belt 150 tons per hour None Q-03C Belt 225 tons per hour None

Q-03D Screen 225 tons per hour Four sided building or structure equivalent to 95% enclosure Pile 9 (In pit)

Maximum Pile Area: 123,623 ft2


A. New Source Performance Standards (NSPS): The facility (Q-3P equipment) is of the source type subject to the New Source Performance Standard (NSPS), Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants. Q-3P equipment are subject to the NSPS Subpart OOO from §60.670 to §60.676.






A. The owner or operator shall install a four sided building or structure to enclose Q-03D Screen by October 1, 2018. The three sided building or structure shall be equivalent to 95% enclosure of quarry equipment specified in condition 3.

i. The owner or operator shall maintain a record of the date when construction of 4-side building or structure is completed.

B. The owner or operator shall develop an operating and maintenance plan for the 4-sided building or structure, including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance.

i. The owner or operator shall maintain a record of all inspections and maintenance and any action resulting

I


from the inspection and maintenance of the 4-side building or structure.

C. The owner or operator shall check for visible emissions from the enclosure on Q-03D Screen once per calendar day

at a time while Q-03D Screen is in operation. i. The owner or operator shall record the date and time of the observation and the presence or absence of visible

emissions. If the owner or operator observes visible emissions from the enclosure containing Q-03D Screen, the owner or operator shall investigate the emission unit or operations associated with the emission unit and make corrections to the associated operations or equipment. The owner or operator shall maintain a record of all corrective actions taken. This requirement shall not apply on the days that Q-03D Screen is not in operation.

D. The owner or operator shall maintain the total area of Pile 9 to less than or equal to 123,623 square feet.

i. The owner or operator shall maintain annual records of Pile 9 area in square feet.

E. During high wind episodes (greater than 16 miles per hour) if visible emissions are observed from the working face of Pile 9, the owner or operator shall employ measures to eliminate or minimize emissions. Such measures may include applying dust suppressant to working face of the pile or coverings the working face of the pile.

i. The owner or operator shall develop a written plan to implement, at a minimum, measures to minimize emissions during high wind episodes as specified in condition 5. E. The written plan and any documentation as required by the plan shall be maintained onsite and available for inspection.

F. The owner or operator shall follow requirements per 40 CFR §60.670 through §60.676.




9. Transferability


Unless the equipment is portable, this permit is not transferable from one location to another or from one piece of equipment to another. See Condition 12.A.(2) for notification requirements for relocating portable equipment (567 IAC 22.3(3)“f”).

10. Construction
































Fax: (319) 653-2856




02-A-017 01-147 Original Permit 1/11/02 Yes 02-A-017-S1 05-166 Amend Control Equipment Language 5/19/05 Yes

02-A-017-S3 18-017 Amend permit limit, add enclosure on Q-03D screen & Establish PM10 Limits 09/06/18 No

END OF PERMIT

[PSP] ¦CPFP¦8201015l¦08272020¦20168¦19A178S2¦






Darin Osland Same


563-324-1931

[email protected]

401 E Front Street

Davenport, IA 52804

Permitted Equipment



EU ID Description Maximum Rated Capacity Control Equipment

Description and ID

* Scale 3 Ingredient Bins* Load-in rate of 45 Tons of ingredient per hour Baghouse (CE CC-17)



Davenport, IA 52761



Project


Stack

Testing

Issuance

Date

20-168 Reduce throughput capacity to 45 TPH and flowrate based on a recent

stack test No 08/27/20



I I

Linwood Mining & Minerals Corp. Scale 3 Ingredient Bins (EP CC-17) Page 2 of 8


PERMIT CONDITIONS

1. Emission Limits




Particulate Matter (PM) – Federal NA NA 0.032 g/dscm3,4 567 IAC 23.1(2)”bbb”3,4


PM10 0.26 6 NA NA NA

PM2.5 NA NA NA NA

Opacity NA NA 40%7, 8 4 ; 567 IAC 23.3(2)“d”



CFR §60.676). Opacity monitoring requirements in Condition 5. 5 PM emissions limit was added to restrict PTE. 6 The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved

into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343). 7 The emission limit is based on a six (6) minute average. 8 An exceedance of the indicator opacity of No Visible Emissions will require the owner or operator to promptly investigate the

emission unit and make corrections to operations or equipment associated with the exceedance. If exceedances continue after the

corrections, the Department may require additional proof to demonstrate compliance (e.g., stack testing).





Time Test Method






Opacity 1 NA 1 hour 40 CFR 60, Appendix A, Method 9 1 Opacity test/monitoring shall be conducted per NSPS Subpart OOO (40 CFR §60.670 – 40 CFR §60.676)



below:





control equipment.



























Parameter Value



Stack Outlet Dimensions (inches) 11

Exhaust Temperature (oF) Ambient







The following emission units exhaust through this emission point:

Emission Unit Maximum Storage Capacity Control

Equipment

Storage Tank CL2 (CC-01K) vents to CE CC-17 during

ash load-in 138 tons of ingredient (limestone or ash)

Baghouse

(CE CC-17) Storage Tank CL3 (CC-01L) vents to CE CC-17 during

ash load-in 138 tons of ingredient (limestone or ash)





These emission units are subject to NSPS Subparts A (General Provisions; 40 CFR §60.1 – 40 CFR §60.19) and OOO

(Standards of Performance for Nonmetallic Mineral Processing Plants; 40 CFR §60.670 – 40 CFR §60.676).





source category.







A. The maximum amount of product loaded-in in each storage tank shall not exceed 45 tons per hour averaged over 3-hr

period.

i. For each hour, the owner or operator shall maintain records of the amount of product loaded-in in tons.

ii. The owner or operator shall maintain records of the 3-hour average the amount of product loaded-in in tons.

B. Per 40 CFR §60.674(c), the owner or operator of any affected facility for which construction, modification, or

reconstruction commenced on or after April 22, 2008, that uses a baghouse to control emissions must conduct quarterly

30-minute visible emissions inspections using EPA Method 22 (40 CFR part 60, appendix A-7). The Method 22 (40

CFR part 60, appendix A-7) test shall be conducted while the baghouse is operating. The test is successful if no visible

emissions are observed. If any visible emissions are observed, the owner or operator of the affected facility must

initiate corrective action within 24 hours to return the baghouse to normal operation. The owner or operator must

record each Method 22 (40 CFR part 60, appendix A-7) test, including the date and any corrective actions taken, in

the logbook required under §60.676(b). The owner or operator of the affected facility may establish a different

baghouse-specific success level for the visible emissions test (other than no visible emissions) by conducting a PM

performance test according to §60.675(b) simultaneously with a Method 22 (40 CFR part 60, appendix A-7) to

determine what constitutes normal visible emissions from that affected facility's baghouse when it is in compliance

with the applicable PM concentration limit in Table 2 of this subpart. The revised visible emissions success level must

be incorporated into the permit for the affected facility.

C. Per 40 CFR §60.676(b), the results of each Method 22 test, including the date and any corrective actions taken.

D. The differential pressure drop across Baghouse (CE CC-17) shall be maintained between 2 and 10 inches of water

column, based on 1-hr block average.

i. The owner or operator shall properly operate and maintain equipment to monitor differential pressure drop

across Baghouse (CE CC-17). The monitoring devices and any recorders shall be installed, calibrated,

operated and maintained in accordance with the manufacturer’s recommendations, instructions and operating

manuals or per written facility specific operation and maintenance plan.

ii. The owner or operator shall collect and record the pressure drop across Baghouse (CE CC-17), in inches of

water, at a minimum of once every 2 minutes. Calculate and record the hourly average for all readings for

each 1-hour block. If the average hourly pressure drop across Baghouse (CE CC-17) falls outside the range

specified in Condition 5.D., the owner or operator shall investigate Baghouse (CE CC-17) and make

corrections to the baghouse. The owner or operator shall maintain a record of all corrective actions taken.

This requirement shall not apply on the days that Baghouse (CE CC-17) is not in operation.

E. The owner or operator shall develop an operating and maintenance plan for the Baghouse (CE CC-17), including a

preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term

maintenance.

i. The owner or operator shall maintain a record of all inspections and maintenance and any action resulting

from the inspection and maintenance of the Baghouse (CE CC-17).



F. When loading-in ash and venting to CE CC-17, only one of the two tanks, Storage Tank CL2 (CC-01K) or Storage

Tank CL3 (CC-01L) shall be operational at one time.

G. The owner or operator shall implement written procedures onsite to ensure only one storage tank (CC-01K or CC-

01L) is operated while loading in ash. These procedures shall be retained onsite and made available for inspection.
























9. Transferability



10. Construction






















C. Amended Permits:











period.



expeditious manner, or the process generating the emissions shall be shutdown within a reasonable period of time, as specified

in 567 IAC 24.1.







(1) Per 567 IAC 22.3(3)“b”:




















the Department.




(30) days.







upset condition.









shall be met.









Air Quality Bureau


502 E. 9th St.


Telephone: (515) 725-8200

Fax: (515) 725-9501

Field Office 6

1023 West Madison


Telephone: (319) 653-2135

Fax: (319) 653-2856

13. Appeal Rights





are unappealable.



14. Permit History


19-A-178 19-130 Original Permit 07/02/19 Yes

19-A-178-S1 19-356 Replace baghouse; change stack characteristics; remove

CC-17A and CC-17B 02/26/20 Yes

END OF PERMIT

I I









Permitted Equipment



EUID Description Maximum Rated Capacity

LP-39 Solid Fuel Crusher Maximum design rate: 20 tons per hour

Process design capacity: 11 tons per hour LP-39A Crusher Burner


7 MMBtu per hour

Control Equipment Descl'iption and ID

Baghouse (CE LP-39)


Project Number· 19-130

[PSP]


Testing Date Decrease exhaust flowrate and unit capacity based on stack test No 07/02/19


:cPFP:s201o1s1:01022019: 19130: 11 Asoss2:

Linwood Mining & Minerals Corp. Solid Fuel Crusher (EP LP-39) Page 2 of 7 Davenport, Iowa 17-A-505-S2

PERMIT CONDITIONS


Pollutant lb/hr1 tons/yr2 Other Limits Reference/Basis Particulate Matter (PM) – State 0.86 5 NA 0.1 gr/dscf 567 IAC 23.4(7) PM10 0.86 6 NA NA NA PM2.5 NA NA NA NA Opacity NA NA 40%3, 4 567 IAC 23.3(2)“d” Sulfur Dioxide (SO2) NA NA 500 ppm 567 IAC 23.3(3) Nitrogen Oxides (NOx) NA NA NA NA Volatile Organic Compounds (VOC) NA NA NA NA Carbon Monoxide (CO) NA NA NA NA Lead (Pb) NA NA NA NA Carbon dioxide (CO2) NA NA NA NA (Single HAP) NA NA NA NA (Total HAP) NA NA NA NA



5 Emission rate established to limit the potential emissions under the Prevention of Significant Deterioration (PSD) significance thresholds.

6 The PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343).





PM10 None NA 1 hour 40 CFR 51, Appendix M, 201A with 202 Opacity None NA 1 hour 40 CFR 60, Appendix A, Method 9

SO2 None NA 1 hour 40 CFR 60, Appendix A, Method 6C NOx None NA 1 hour 40 CFR 60, Appendix A, Method 7E

VOC None NA 1 hour 40 CFR 63, Appendix A, Method 320 or 40 CFR 60, Appendix A, Method 18

CO None NA 1 hour 40 CFR 60, Appendix A, Method 10 Pb None NA 1 hour 40 CFR 60, Appendix A, Method 12

CO2 None NA 1 hour 40 CFR 60, Appendix A, Method 3

HAP None NA 1 hour 40 CFR 63, Appendix A, Method 320 or 40 CFR 60, Appendix A, Method 18





If stack testing is required, the owner or the owner’s authorized agent shall use the test method and run time listed in the “Compliance Demonstration Table” unless another testing methodology is approved by the Department prior to testing. Each emissions compliance test must be approved by the Department. Unless otherwise specified by the Department, each test shall consist of three (3) separate runs. The arithmetic mean of three (3) acceptable test runs shall apply for compliance, unless otherwise indicated by the Department. Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.






The facility is of the source type subject to the New Source Performance Standard (NSPS), Subpart Y, Standards of Performance for Coal Preparation and Processing Plants. These units are not subject to the subpart as the facility does not process more than 200 tons of coal per day.

Linwood Mining & Minerals Corp. Solid Fuel Crusher (EP LP-39) Page 4 of 7 Davenport, Iowa 17-A-505-S2 NOTE: The absence of the inclusion of any NSPS requirements as part of this permit does not relieve the owner or operator



This facility is of the source category for Subpart AAAAA (National Emission Standards for Hazardous Air Pollutants for Lime Manufacturing Plants; 40 CFR §63.7080 – 40 CFR §63.7143) of the National Emission Standards for Hazardous Air Pollutants (NESHAP). However, it is not subject as the facility has conducted testing per 40 CFR §63.7142 and it has been determined the facility is an area source.



5. Operating Requirements with Associated Monitoring and Recordkeeping Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an orderly manner. The operating requirements and associated recordkeeping for this permit shall be: A. The maximum amount of solid fuel crushed in the crusher shall not exceed 11 tons per hour averaged over 3-hr period.

i. For each hour, the owner or operator shall maintain records of the amount of solid fuel crushed in tons. ii. The owner or operator shall maintain records of the 3-hour average of solid fuel crushed in tons.

B. The burner shall be fueled by natural gas only. i. The owner or operator shall maintain records of the type of fuel combusted in the burner.

C. The facility shall not crush any other fuel besides coke/coal in the fuel crusher. i. The owner or operator shall maintain records of the type of fuel crushed in the crusher.

D. The owner or operator shall begin monitoring the differential pressure drop across the baghouse, as specified in condition 5.E. by May 1, 2018.


E. The differential pressure drop across Baghouse (CE LP-39) shall be maintained between 2 and 10 inches of water column, based on 1-hr block average.


ii. The owner or operator shall collect and record the pressure drop across Baghouse (CE LP-39), in inches of water, at a minimum of once every 2 minutes. Calculate and record the hourly average for all readings for each 1-hour block. If the average hourly pressure drop across Baghouse (CE LP-39) falls outside the range specified in Condition 5.E., the owner or operator shall investigate Baghouse (CE LP-39) and make corrections to the baghouse. The owner or operator shall maintain a record of all corrective actions taken. This requirement shall not apply on the days that Baghouse (CE LP-39) are not in operation.

F. The owner or operator shall develop an operating and maintenance plan for the Baghouse (CE LP-39), including a preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance.



Linwood Mining & Minerals Corp. Solid Fuel Crusher (EP LP-39) Page 5 of 7 Davenport, Iowa 17-A-505-S2 7. Department Review This permit is issued under the authority of 567 Iowa Administrative Code (IAC) 22.3. The proposed equipment has been evaluated for conformance with Iowa Code Chapter 455B; 567 IAC Chapters 20 – 35; and 40 Code of Federal Regulations (CFR) Parts 51, 52, 60, 61, and 63 and has the potential to comply. This permit is issued based on information submitted by the applicant. Any misinformation, false statements or misrepresentations by the applicant or by the applicant’s representative(s) shall cause this permit to be void. No review has been undertaken on the engineering aspects of the equipment or control equipment other than the potential of that equipment for reducing air contaminant emissions. The Department assumes no liability, directly or indirectly, for any loss due to damage to persons or property caused by, resulting from, or arising out of the design, installation, maintenance or operation of the proposed equipment.



10. Construction

















Fax: (319) 653-2856


14. Permit History


Testing 17-A-505 17-118 Replace 4 solid fuel crushers 03/13/18 Yes

17-A-505-S1 18-366 Increase crusher burner from 5 MMBtu/hr to 7 MMBtu/hr 03/14/19 No

END OF PERMIT


Permit Number: 17-A-495-Sl







Same

Permitted Equipment


EUID Description Maximum Rated Capacity Control Equipment Descriotion and ID

LP-20 Solid Fuel Hopper 70 TPH of Solid Fuel; 300 Tons Per day of Solid Fuel;

61,000 TPY of Solid Fuel None




l 8-366 Increase capacity to 300 TPD and 61,000 TPY

[PSP]


No 03/14/19


:crFr:s201 o I s1:03142019:1sJ66: 11 A495S 1:

Linwood Mining & Minerals Corp. Solid Fuel Hopper (EP LP-20) Page 2 of 7 Davenport, Iowa 17-A-495-S1

PERMIT CONDITIONS










Time Test Method







Linwood Mining & Minerals Corp. Solid Fuel Hopper (EP LP-20) Page 3 of 7 Davenport, Iowa 17-A-495-S1 2. Compliance Demonstration(s) (Continued) Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.










Linwood Mining & Minerals Corp. Solid Fuel Hopper (EP LP-20) Page 4 of 7 Davenport, Iowa 17-A-495-S1 5. Operating Requirements with Associated Monitoring and Recordkeeping

Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an orderly manner. The operating requirements and associated recordkeeping for this permit shall be:

A. The maximum amount of solid fuel transferred through the hopper shall not exceed 70 tons per hour i. For each hour, the owner or operator shall maintain records of the amount of product transferred in tons.

ii. The owner or operator shall maintain hourly records of the product transferred in tons. B. The maximum amount of solid fuel transferred through the hopper shall not exceed 300 tons per day.

i. For each day, the owner or operator shall maintain records of the amount of solid fuel transferred through the hopper in tons.

ii. The owner or operator shall maintain daily records of the solid fuel transferred in tons. C. The owner or operator shall check for visible emissions from Solid Fuel Hopper (EP LP-20) once per day at a time

while Solid Fuel Hopper (EP LP-20) is in operation. The owner or operator shall record the date and time of the observation and the presence or absence of visible emissions. If the owner or operator observes visible emissions from Solid Fuel Hopper (EP LP-20), the owner or operator shall investigate the emission unit or operations associated with the emission unit and make corrections to the associated operations or equipment. The owner or operator shall maintain a record of all corrective actions taken. This requirement shall not apply on the days that Solid Fuel Hopper (EP LP-20) is not in operation.




Linwood Mining & Minerals Corp. Solid Fuel Hopper (EP LP-20) Page 5 of 7 Davenport, Iowa 17-A-495-S1 9. Transferability Unless the equipment is portable, this permit is not transferable from one location to another or from one piece of equipment to another. See Condition 12.A.(2) for notification requirements for relocating portable equipment (567 IAC 22.3(3)“f”).

10. Construction









Linwood Mining & Minerals Corp. Solid Fuel Hopper (EP LP-20) Page 6 of 7 Davenport, Iowa 17-A-495-S1 12. Notification, Reporting, and Recordkeeping


















Linwood Mining & Minerals Corp. Solid Fuel Hopper (EP LP-20) Page 7 of 7 Davenport, Iowa 17-A-495-S1




Fax: (319) 653-2856


14. Permit History


Testing 17-A-495 17-118 Permit grandfathered equipment & Establish PM10 Limits 03/13/18 No

END OF PERMIT


Permit Number: l 7-A-504-Sl





40 l E Front Street Davenport, IA 52761

Same

Permitted Equipment

Emission Point ID: Solid Fuel-OJ


EU ID Description Maximum Rated Capacity

Solid Fuel-0 I Solid Fuel Pile 61,000 TPY of Solid Fuel


Control Equipment Description and ID Hoop Building (83% enclosure)



Number 18-366 Increase annual TPY throughput

[PSP]

Stack Issuance Testine: Date

No 03/14/19


ICPFPl820 l 0 l 511031420l9118366117 A504S 1 I

Linwood Mining & Minerals Corp. Solid Fuel Pile (EP Solid Fuel-01) Page 2 of 7 Davenport, Iowa 17-A-504-S1

PERMIT CONDITIONS


Pollutant lb/hr1 tons/yr2 Other Limits Reference/Basis Particulate Matter (PM) – State NA NA NA NA PM10 3 NA NA NA PM2.5 NA NA NA NA Opacity NA NA 4 567 IAC 23.3(2)“c”

1 The emission limit is expressed as the average of three (3) runs. 2 The emission limit is based on a twelve (12) month rolling total. 3 The limit for PM10 emissions is established at 0.0079 pounds of PM10 per day estimated using 10.18% moisture for the pile. The

PM10 limit established for attainment and maintenance of PM10 National Ambient Air Quality Standards (NAAQS) as approved into the state implementation plan (SIP) by the U.S. EPA on March 18, 1999 (64 FR 13343).





Time Test Method







Linwood Mining & Minerals Corp. Solid Fuel Pile (EP Solid Fuel-01) Page 3 of 7 Davenport, Iowa 17-A-504-S1 2. Compliance Demonstration(s) (Continued) Per 567 IAC 25.1(7)”a”, at the Department’s request, a pretest meeting shall be held not later than fifteen (15) days before the owner or operator conducts the compliance demonstration. A testing protocol shall be submitted to the Department no later than fifteen (15) days before the owner or operator conducts the compliance demonstration. Representatives from the Department shall attend this meeting, along with the owner and the testing firm, if any. It shall be the responsibility of the owner to coordinate and schedule the pretest meeting. A representative of the Department shall be allowed to witness the test(s). The Department shall reserve the right to impose additional, different, or more detailed testing requirements. The owner shall be responsible for the installation and maintenance of test ports. The unit(s) being sampled shall be operated in a normal manner at its maximum continuous output as rated by the equipment manufacturer, or the rate specified by the owner as the maximum production rate at which this unit(s) will be operated. In cases where compliance is to be demonstrated at less than the maximum continuous output as rated by the manufacturer, and it is the owner's intent to limit the capacity to that rating, the owner may submit evidence to the Department that this unit(s) has been physically altered so that capacity cannot be exceeded, or the Department may require additional testing, continuous monitoring, reports of operating levels, or any other information deemed necessary by the Department to determine whether this unit(s) is in compliance.










Linwood Mining & Minerals Corp. Solid Fuel Pile (EP Solid Fuel-01) Page 4 of 7 Davenport, Iowa 17-A-504-S1 5. Operating Requirements with Associated Monitoring and Recordkeeping Unless specified by a federal regulation, all records as required by this permit shall be kept on-site for a minimum of two (2) years and shall be available for inspection by the Department. Records shall be legible and maintained in an orderly manner. The operating requirements and associated recordkeeping for this permit shall be:

A. The maximum amount of solid fuel stored in the solid fuel pile shall not exceed 61,000 tons per rolling 12-month period.

i. The owner or operator shall maintain monthly records of the amount of solid fuel stored in the solid fuel pile. Calculate and record the12-month rolling totals.

B. The owner or operator shall check for visible emissions from the solid fuel pile (EP Solid Fuel-01) once per day at a

time while the pile is in use. The owner or operator shall record the date and time of the observation and the presence or absence of visible emissions. If the owner or operator observes visible emissions from solid fuel pile, the owner or operator shall investigate the enclosure. The owner or operator shall maintain a record of all corrective actions taken.

C. The owner or operator shall develop an operating and maintenance plan for the building structure, including a

preventative maintenance schedule that is consistent with the manufacturer's instructions for routine and long-term maintenance.

D. The owner or operator shall maintain a record of all inspections and maintenance and any action resulting from the inspection and maintenance of the building structure.




Linwood Mining & Minerals Corp. Solid Fuel Pile (EP Solid Fuel-01) Page 5 of 7 Davenport, Iowa 17-A-504-S1 9. Transferability Unless the equipment is portable, this permit is not transferable from one location to another or from one piece of equipment to another. See Condition 12.A.(2) for notification requirements for relocating portable equipment (567 IAC 22.3(3)“f”).

10. Construction









Linwood Mining & Minerals Corp. Solid Fuel Pile (EP Solid Fuel-01) Page 6 of 7 Davenport, Iowa 17-A-504-S1 12. Notification, Reporting, and Recordkeeping


















Linwood Mining & Minerals Corp. Solid Fuel Pile (EP Solid Fuel-01) Page 7 of 7 Davenport, Iowa 17-A-504-S1




Fax: (319) 653-2856


14. Permit History


Testing 17-A-504 17-118 Permit grandfathered solid fuel pile & Establish PM10 Limits 03/13/18 No

END OF PERMIT

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