QuarryNo

10570 Blandor Way Los Altos Hills, CA 94024 www.quarryno.com May 18, 2011 Ms. Deborah Jordan Director, Air Division Environmental Protection Agency 75 Hawthorne Street San Francisco, CA 94105 Dear Ms. Jordan, We are writing you in regard to BAAQMD Application 22954 for Facility #A0017 submitted by the Air District to you for approval last week. This Application while key to the new Title V Permit (Application 17947) was deliberately left out of the Title V Permit as circulated for Public comment even though it was received prior to the circulation. The apparent intent was to circumvent Public comment by processing it as a minor revision to the current Title V Permit and reinserting it later into the new Title V Permit as stated on page 4 of this application (22954). It was anything but minor being the key element in reducing Mercury emissions. The BAAQMD had withdrawn an earlier version of the Title V Permit on January 5, 2010 for the express purpose of incorporating “significantly more stringent standards for mercury air contaminants under Amendments to 40 CFR 63, Subpart LLL, National Emission Standards for Hazardous Air Pollutants (NESHAP)”. That has not happened and the Public wound up reviewing an incomplete document missing key elements such as the Carbon Injection system here and the critical Mercury Continuous Emission Monitoring (CEM) system. Hopefully the Carbon Air Injection system contemplated will be a great success but today it has not been demonstrated in the Cement Industry, it is very temperature sensitive and there is the challenge of source monitoring of a 32 bag venting system notorious for leaks and fugitive dust. This application should not be processed separately but should be incorporated into the new Title V Permit along with its Mercury CEM and made available for Public comment. Please consider the Public in your actions. We have had silence on Mercury emissions that exceeded notifications levels for the last 3 years and now we have this manipulation of the Title V process. This is not the role the Public was to play per the Clean Air Act. Thanks for your consideration. Sincerely,

Bill Almon QuarryNo

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX 75 Hawthorne Street San Francisco, CA 94105

June 20, 2011 Mr. William J. Almon QUARRYNO 10570 Blandor Way Los Altos Hills, California 94024 Dear Mr. Almon: Thank you for your letter dated May 18, 2011 to Deborah Jordan regarding the Bay Area Air Quality Management District’s (“BAAQMD” or “District”) minor revision to the Clean Air Act title V permit for facility #A0017, which is the Lehigh Southwest Cement Company (“Lehigh”). Your letter mentions your concerns about the omission of the minor revision from the recent draft title V renewal permit for Lehigh that BAAQMD issued for the public comment that began on January 21, 2011 and concluded on March 25, 2011. According to the District’s Statement of Basis for the minor permit revision, the minor revision incorporates requirements for the installation and operation of an activated carbon injection (“ACT”) system and a mercury continuous emission monitoring system (“CEMS”) at Lehigh’s cement kiln into Lehigh’s title V permit. We contacted the BAAQMD regarding your concerns. The District informed us that Lehigh submitted an application for a New Source Review (“NSR”) construction permit for the ACT system and mercury CEMS on January 10, 2011. The District also informed us it issued a final NSR permit on May 5. 2011. BAAQMD’s minor permit revision to Lehigh’s title V permit will incorporate the NSR permit into the title V permit using the District’s minor revision rule, Rule 2-6-215. The District’s Statement of Basis for the minor permit revision to the title V permit states that the operation of the ACT system and mercury CEMS is a voluntary interim action that is intended to reduce mercury emissions under the California Air Toxics Hot Spots Program, which is a State-only requirement. Because it appears that, at this time, this revision does not address federal applicable requirements, we believe the District may proceed with processing the revision under Rule 2-6-215, which requires a 45-day review period for the Environmental Protection Agency (“EPA”), but does not require public participation. Please note, however, that we are providing a comment to the District on the minor permit revision stating that it is our understanding that the ACT system and the mercury CEMS will be used to demonstrate compliance with requirements in the National Emission Standards for Hazardous Air Pollutants (“NE5HAP”) for Portland Cement Plants. (The emission standard in the NESHAP has a compliance deadline in 2013.) We suggest that the District clarify in the future revision to the title V permit that the ACT system and mercury CEMS will be used to comply with the NESHAP. A copy of this letter is enclosed for your convenience. Please note as well that the renewal of Lehigh’s title V permit will be subject to a 45-day EPA review period later this year. BAAQMD Rule 2-6-411 allows the public allowed to petition EPA to formally

object to the permit based on comments made to BAAQMD or revisions made to the renewal permit that was public noticed. The public may submit a petition 60 days after EPA’s 45-day review period ends. If you have further questions, please feel free to contact me at rios.gerardoepa.gov, or Shaheerah Kelly of my staff for permitting issues at kel1y.shaheerahepa.gov, or Kara Christenson for legal issues at christenson.karaepa.gov. We hope the above intbrmation is useful to you, and thank you for sharing your concerns with EPA. Sincerely,

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Gerardo C. Rios Chief, Permits Office Air Division Enclosure

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX 75 Hawthorne Street San Francisco, CA 94105

June 20, 2011 Mr. Dennis Jang Senior Air Quality Engineer Bay Area Air Quality Management District 939 Ellis Street San Francisco, California 94109 Dear Mr. Jang: Thank you for the opportunity to review the minor revision to the Clean Air Act title V permit for the Lehigh Southwest Cement Company (“Lehigh”). This permit action was submitted to the Environmental Protection Agency (“EPA”) on May 10, 2011. According to the District’s Statement of Basis, the purpose of this minor revision is to incorporate requirements for the installation and operation of an activated carbon injection (“ACT”) system for mercury control and a mercury continuous emission monitoring system (“CEMS”) at Lehigh’s cement kiln into the title V permit. The District’s permit evaluation for this minor revision states that these requirements are voluntary and are intended to reduce mercury emissions under the California Air Toxics Hot Spots Program, which is a State-only requirement. It also states that the ACT system is part of Lehigh’s overall efforts to control mercury emissions from the facility, and that the facility will be making additional modifications, including adding a single stack, to further reduce mercury and other hazardous air pollutants. It is also our understanding that these controls will be used to demonstrate compliance with some or all of the requirements in the National Emission Standards for Hazardous Air Pollutants (“NESHAP”) for Portland Cement Plants that apply to Lehigh, which has a future compliance date in 2013. We suggest that the future revision to the title V permit clarify that the ACT system and mercury CEMS will be used to comply with the NESHAP. If you have any questions, feel free to contact Shaheerah Kelly of my staff at (415) 947-4156 or kel1y.shaheerahepa.gov. Sincerely,

Gerardo C. Rios Chief, Permits Office Air Division

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