Interested Parties:

The Bay Area Air Quality Management District (the District) is seeking written comment on the revised proposed Title V Permit renewal for Lehigh Southwest Cement Company.

Lehigh Southwest Cement Company is a major facility that is required to obtain operating permits under Title V of the 1990 Clean Air Act Amendments, the federal Operating Permit Program and the District’s Regulation 2, Rule 6 - Major Facility Review.  The Title V Permit is a compilation of all existing applicable local, state and federal air quality requirements including emissions limits and standards, monitoring, record-keeping, and reporting requirements.  Title V permits are renewed on a 5-year cycle, and the existing permit remains in effect until permit renewal is completed.

On July 30, 2009, the District issued an initial draft Title V permit renewal for the Lehigh facility.  On January 5, 2010, the District withdrew this initial draft Title V permit renewal.  This was done because U.S. EPA had indicated that it would soon be adopting significantly more stringent standards for mercury and other toxic air contaminants from cement plants in amendments to 40 CFR 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland Cement Manufacturing Industry, and the District wanted to incorporate these more stringent requirements into Lehigh’s permit.  The NESHAP rule amendments were delayed, but were eventually published on September 9, 2010.  EPA also issued further minor amendments to this rule on January 18, 2011.  The District has now incorporated these NESHAP amendments into a revised proposed Title V permit for the Lehigh facility, and made additional revisions to the permit, as follows:

·    Added new standards from the amended NESHAP rule

·    Added a facility-wide permit Condition #24621 to include the Fugitive Dust Control Plan and source test requirement for small sources

·    Added most recent permit applications and conditions for loss of exemption of portable IC engines, mercury and hydrochloric acid reduction

·    Addressed EPA’s comments and updated the Compliance Assurance Monitoring (CAM) Analysis. CAM Condition #24781 was added to the Title V permit

All revisions are noted and explained in detail in the Statement of Basis for the revised proposed Title V Permit renewal.

It should be noted that the District is also in the process of developing a rule for cement manufacturing plants that was identified as a control measure in our 2010 Clean Air Plan.  The focus of this new District rule will be on emissions of nitrogen oxides (NOx), an air pollutant that is not addressed by the NESHAP.  The new District rule will likely be considered for adoption later this year, and its requirements will be incorporated into Lehigh’s Title V permit in a subsequent permit reopening.

Members of the public can provide their input to the District on the revised Title V permit renewal for the Lehigh facility by submitting written comments to Ms. Thu Bui, BAAQMD, 939 Ellis Street, San Francisco, CA, 94109, or via email at tbui@baaqmd.gov.  The public review and comment period commenced on January 21, 2011, and the District will accept comments on the permit through March 25, 2011.  The District will consider all comments submitted. The proposed permit will then be submitted to EPA for their 45 day review.  Questions on this notice, the revised proposed permit, and Statement of Basis, should also be directed to Ms. Bui.