Norlite Dust Plan

Norlite, LLC
Tradebe Environmental Services, LLC
FUGITIVE DUST PLAN
Prepared for:
Norlite, LLC
A Division of Tradebe Environmental Services, LLC
October 2014
Prepared by:
SPEC Engineering, PLLC

349 Northern Boulevard, Suite 2
Albany, NY 12204
(518) 487-4800
SPEC Job No. 13-094
Table of Contents
1.0 Introduction and Background............................................................................................................ 1
2.0 Plan Objective................................................................................................................................... 2
3.0 Site Description................................................................................................................................. 3
4.0 Technical Background: Dust Generation and Control ...................................................................... 4
4.1 Dust Generation ............................................................................................................................ 4
4.1.1 Wind Erosion ........................................................................................................................ 4
4.1.2 Vehicle Re-entrainment ........................................................................................................ 4
4.1.3 Material Handling ................................................................................................................. 5
4.2 Fugitive Dust Control ................................................................................................................... 5
4.2.1 General Control Methods...................................................................................................... 5
4.2.2 Controls for Vehicle Re-entrainment .................................................................................... 6
4.2.3 Controls for Material Handling............................................................................................. 6
5.0 Control Methodology Implementation Summary ............................................................................. 7
5.1 Kiln Feed Area.............................................................................................................................. 7
5.1.1 Kiln Rear Chamber System Upgrade.................................................................................... 7
5.2 Kiln Area....................................................................................................................................... 7
5.2.1 Kiln Clinker Storage Pile Operational Changes.................................................................... 7
5.3 Finish Plant Area........................................................................................................................... 7
5.3.1 New Windscreen ................................................................................................................... 7
5.3.2 New Anemometer ................................................................................................................. 8
5.3.3 Block Mix Conveyor to Radial Stacker Transfer Point Redesign ........................................ 8
5.3.4 Drop Distance Rod on Radial Stacker .................................................................................. 8
5.4 Fines Processing Area ................................................................................................................... 9
5.4.1 New Covered Storage Structure............................................................................................ 9
5.5 Roads............................................................................................................................................. 9
5.5.1 Closing Saratoga Street Entrance to Heavy Vehicles ........................................................... 9
5.5.2 Increased Road Watering Frequency .................................................................................... 9
5.6 Conveyors ..................................................................................................................................... 9
5.6.1 Covers on Conveyors ............................................................................................................ 9
5.7 Trees.............................................................................................................................................. 9
5.7.1 Tree Barrier ........................................................................................................................... 9
5.8 Baghouses ..................................................................................................................................... 9
Norlite Fugitive Dust Plan Page i

SPEC Project Number 13-094 October 2014
5.8.1 Elimination of Baghouse Dust Pile and Transfer Points....................................................... 9
5.9 Coal ............................................................................................................................................. 10
5.9.1 Elimination of Coal Pile and Transfer Points ..................................................................... 10
6.0 Current Operations, Dust Sources, and Controls ............................................................................ 11
6.1 Quarry Area ................................................................................................................................ 11
6.2 Primary Area............................................................................................................................... 12
6.2.1 Current Fugitive Dust Control Methodology ...................................................................... 13
6.3 Kiln Feed Area............................................................................................................................ 13
6.3.1 Removal of Kiln Feed Silo and Installation of New Enclosure .......................................... 14
6.4 Kiln Area..................................................................................................................................... 16
6.5 Finish Plant Area......................................................................................................................... 17
6.6 Fines Processing Area ................................................................................................................. 19
6.7 Block Mix Processing Area ........................................................................................................ 20
6.7.1 Current Fugitive Dust Control Methodology...................................................................... 21
6.8 Island Area .................................................................................................................................. 21
6.9 Boneyard Area ............................................................................................................................ 22
6.10 Southern Overburden Storage Area ............................................................................................ 22
6.11 Roads........................................................................................................................................... 22
6.12 Loading Trucks and Piles............................................................................................................ 23
6.12.1 Current Fugitive Dust Control Methodology...................................................................... 23
6.13 Current Conditions of Existing Controls .................................................................................... 23
7.0 Fugitive Dust Emission Calculations Methodology ....................................................................... 24
7.1 Drop Point Emissions ................................................................................................................. 25
7.2 Storage Pile Wind Erosion Emissions ........................................................................................ 25
7.3 Vehicular Traffic on Unpaved Roads ......................................................................................... 26
Norlite Fugitive Dust Plan Page ii

7.4 Vehicular Traffic on Paved Roads .............................................................................................. 27
7.5 Overburden Stripping Emissions ................................................................................................ 27
7.6 Overburden Storage Area Bulldozing Emissions ....................................................................... 28
7.7 Emission Reduction Efficiencies ................................................................................................ 28
8.0 Site-Specific Values........................................................................................................................ 30
8.1 Meteorological Data & Topography ........................................................................................... 30
8.2 Product Characteristics ............................................................................................................... 30
8.3 Mean Vehicle Weights................................................................................................................ 31
8.4 Production Rates ......................................................................................................................... 32
9.0 Fugitive Dust Emission Calculations.............................................................................................. 34
10.0 Discussion ....................................................................................................................................... 44
11.0 References....................................................................................................................................... 52
Norlite Fugitive Dust Plan Page iii

List of Figures
Figure 1: Wind Screen in Finish Plant Area
Figure 2: Primary Area Equipment
Figure 3: #4 and #5 Conveyors in the Kiln Feed Area
Figure 4: New Kiln Feed Storage Pile Enclosure
Figure 5: Chute for Cleaning Kiln Rim Seal
Figure 6: Kiln Clinker Cooler to Clinker Belt Drop Point
Figure 7: 3/4" Aggregate Drop Point
Figure 8: Fines Processing Area
Figure 9: Portable Screens in the Block Mix Processing Area
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List of Tables
Table 1: AP-42 Drop Point Emissions Aerodynamic Particle Size Multiplier1
Table 2: Empirical Constants for Unpaved Industrial Roads1
Table 3: Particle Size Multiplier for Paved Roads1
Table 4: Emissions Reduction Efficiencies
Table 5: Site-Specific Climate Data6
Table 6: Norlite Product Characteristics
Table 7: Mean Vehicle Weights
Table 8: Production Rates
Table 9: Overburden Densities10
Table 10: Other Production Rates
Table 11: Fugitive Dust Emissions Estimate
Table 12: Evaluation of Existing Controls
Note that superscripted numbers relate to an equivalent numbered reference in Section 11.0 References of
this Plan.
Norlite Fugitive Dust Plan Page v

Appendices
Appendix A: Aerial Photographs with Process Areas
Appendix B: Process Flow Diagrams
Appendix C: Fugitive Dust Emissions Calculations
Appendix D: Site-Specific Variables
Appendix E: Photograph Log
Appendix F: December 2013 Stockpile Inventory
Appendix G: Engineering Drawings of Kiln Rear Chamber System and Rim Seal Chutes
Appendix H: Fines and Kiln Silo Study
Appendix I: Texas Commission on Environmental Quality, Air Permits Division, New Source Review
(NSR) Emission Calculations (2008)
Appendix J: Loader Operator Procedure
Norlite Fugitive Dust Plan Page vi

1.0 Introduction and Background
In 1990, the New York State Department of Environmental Conservation (NYSDEC) requested Norlite to
submit a plan for a comprehensive fugitive dust emission control program. The original Fugitive Dust
Plan (Plan) was written in 1990 by Sci-Tech, Inc., including then-current calculations for fugitive dust
emissions from a variety of identified potential fugitive dust sources across the Norlite facility. Since the
document’s creation in 1990, there have been updates made to the Plan in 1995, 2002, and 2010, to
account for changing equipment and/or processes at the facility. According to the Plan, Norlite was
acquired by American NuKEM in 1992, and as a result, many of the proposed changes from 1990 were
not implemented by the time of the 1995 Plan update. The 1995 Addendum included updated fugitive
dust emissions calculations, reflecting proposed changes to emission control methods, and elimination of
select fugitive dust sources.
NYSDEC issued an Order on Consent (R4-2000-0420-27) in July 2000, requesting Norlite re-evaluate the
existing Plan to ensure it was being properly implemented and to include any recommendations for
revisions to the Plan to address new emission sources or changes in operations. Sci-Tech, Inc., on
Norlite’s behalf, submitted a Fugitive Dust Control Evaluation report, dated August 18, 2000, to
NYSDEC. After a NYSDEC August 31, 2001, comment/response letter; a NYSDEC October 30, 2001,
bucket loader procedure letter; and a NYSDEC November 26, 2001, bucket loader procedure revision
letter (all responses to the August 18, 2000, report), Norlite included a 2002 Addendum to their Plan.
This 2002 Addendum included a December 14, 2001, letter from Sci-Tech, Inc., which addressed the
2000 Evaluation results. In 2002, the results were revised or additional controls were recommended at the
facility to further control fugitive dust emissions, including the implementation of recommendations from
the 1995 Plan update. Sketches of various proposed control changes around the facility are part of this
2002 Addendum, along with copies of NYSDEC correspondence with Norlite. A December 31, 2002,
letter from Sci-Tech, Inc. was included at the end of the 2002 Addendum to confirm a recent inspection of
the facility verified that the changes from the December 14, 2001, letter were implemented. None of
these letters or addenda included a recalculation of fugitive dust emissions to account for changes to the
facility or process modifications to reduce potential dust emissions. As in 1995, the 2002 and 2010
Addenda did not include re-calculations of estimated fugitive dust emissions.
The 2010 Addendum, with a detailed photograph log, includes a February 9, 2011, letter from Norlite to
NYSDEC in response to NYSDEC not approving the July 16, 2010, Fugitive Dust Plan Addendum
submittal. The Addendum itself discusses additional changes that were made at the facility since the
2002 Addendum, including the 2007 addition of a lightweight fines wind screen, control methods used for
the block mix processing area, and the discussion of road watering at the Southern Overburden Storage
Area to reduce potential dust emissions.
The Norlite facility, which was acquired by Tradebe Environmental Services, LLC (Tradebe) on April 15,
2011, was inspected by the NYSDEC in early 2012 and a Notice of Violation (NOV) letter was issued on
May 9, 2013. As part of this NOV letter, NYSDEC requested upgrades to the facility’s Fugitive Dust Plan
due to purported inadequacies in the existing plan and Addenda. Norlite retained the services of SPEC
Engineering, PLLC to reanalyze dust sources at the facility. This report describes SPEC’s analysis of the
site and presents the results of the current study.
Norlite Fugitive Dust Plan Page 1

2.0 Plan Objective
Several State and Federal regulations provide standards and guidance for the control of emissions and
fugitive dust from aggregate quarries and aggregate kilns. These regulations, standards and guidance
documents include, but are not limited to:
 Title 40 - Protection of Environment Subpart EEE - National Emission Standards for Hazardous
Air Pollutants from Hazardous Waste Combustors
Title 40 - Protection of Environment. Chapter I - Environmental Protection Agency Subchapter C
- Air Programs Part 63 - National Emission Standards for Hazardous Air Pollutants for Source
Categories
 New York State NYCRR Chapter III, all applicable subparts
 New York State NYCRR Part 211
 US EPA AP-42, Chapter 13
 US EPA-450/3-77-010 Technical Guidance for Control of Industrial Process Fugitive Particulate
Emissions (1977)
 US EPA-450/2-92-004 Fugitive Dust Background Document and Technical Information
Document For Best Available Control Measures (1992)
From AP-42, Chapter 13 defines Fugitive Dust as atmospheric dust that arises from the mechanical
disturbance of granular materials exposed to the air that is not discharged to the atmosphere in a confined
flow stream. AP-42 goes on to state that common sources of fugitive dust include unpaved roadways,
agricultural tilling operations, aggregate storage piles, and heavy construction operations. Norlite
currently has an active quarry operation and lightweight aggregate manufacturing and processing facility
on-site. Sources of fugitive dust across Norlite’s facility are consistent with the AP-42 definition of
fugitive dust and its potential sources.
The purpose of this Fugitive Dust Plan is to provide a review of current aggregate processes, potential
fugitive dust emission sources, and existing fugitive dust control practices at the Norlite facility. The
current review project, culminating in this Fugitive Dust Plan, is a continuation of work started in 1990,
continued in 1995 and supplemented in 2002 and 2010. The review project brings the current Plan into
general compliance with AP-42 guidance standards for calculating and estimating potential fugitive dust
sources. The facility review conducted and descriptions provided in this current Plan present an account
of the facility and aggregate processing for current, existing operations only and does not address past
practices or future conditions should processes change. When calculations are presented in this review,
the input data for which each formula/calculation is based is derived from historic averages over the past
five years (2009-2013). Previous fugitive dust plans are retained for reference purposes and are available
at the facility for review.

3.0 Site Description
The Tradebe Environmental Services, LLC (Tradebe) Norlite facility, in the City of Cohoes, Albany
County, New York, is located approximately 0.25 miles to the west of New York State Route 787 and 0.9
miles to the west of the Hudson River. It is also 0.7 miles north of New York State Route 7 and 3 miles
east of Interstate 87. The facility produces expanded shale aggregate in two dry process rotary kilns. Raw
materials are quarried on-site and transported to the kilns via a mobile fleet, crushing, screening, and
conveyor systems. The output from the kiln is then further crushed, screened, and conveyed to various
storage piles according to material size. The finished product is then transferred to trucks for
transportation off-site to various consumer markets.
The storage and handling of the raw materials and products, as well as vehicular traffic throughout the
site, result in the potential for the emission of fugitive dust, as defined in AP-42, Chapter 13.

4.0 Technical Background: Dust Generation and Control
The following is a general discussion of the basic theory and mechanics of dust generation at an aggregate
processing site like Norlite, as well as general dust control methodologies.
4.1 Dust Generation

Fugitive dust can be generated in several different ways at an aggregate processing site. The three main
sources of generation are wind erosion, vehicle re-entrainment, and material handling.
4.1.1 Wind Erosion

Dust emissions can be generated by wind erosion of open aggregate storage piles and exposed areas
within a facility. This occurs when wind pressure against surface particles overcomes the force of gravity
on the particles as well as the force of adhesion between dust particles and/or the surface upon which the
particles rest. The threshold wind velocity, or the wind velocity required to cause wind erosion, is
dependent on particle type and size. Wind erosion is the main dust source off material stockpiles and
unvegetated surfaces.
The following factors affect the threshold velocity of dust particles:
 Particle size – Particle size affects the threshold velocity because particle size is correlated with
particle weight. Larger, and therefore heavier, particles require more force in order to become
airborne. Particles that are 75 microns or smaller are generally considered to be suspendable in air
due to wind because silt is typically considered to be particles that are 75 micros or smaller, silt
content is often used in calculations for fugitive dust emissions.
 Moisture content – Higher moisture content of material correlates to stronger cohesive forces
between particles. Therefore, materials with high moisture content are less likely to produce
fugitive dust emissions. Conversely, when the material moisture content is low, cohesive forces
are reduced and dust emission potential increases.
 Surface crust – If a material storage pile has a natural or man-made crust on its outer surface, the
cohesive forces between surface particles is stronger and less material is released into the air by
wind erosion.
 Wind speed – Wind speed is a significant variable for dust emissions due to wind erosion. Dust is
generated only if the wind speed is high enough to dislodge dust particles from aggregate storage
piles by the processes described above.
4.1.2 Vehicle Re-entrainment

Once the cohesive forces between particles are overcome and a particle becomes airborne, the wind
velocities necessary to transport these particles are significantly less than those required to dislodge them
from a surface. Therefore, once particles are airborne, wind is not necessarily needed in order to generate
fugitive dust. The most significant means of mechanical dust generation is the passing of vehicles over
dusty surfaces. This is called vehicle re-entrainment and is the result of the action of the tires on the road
surface as well as the turbulence of the “wake” that results from the vehicle moving through the air.
The following factors affect dust emissions that result from vehicles traveling on facility roadways:
 Vehicle speed – Higher tire speeds result in greater forces being exerted upon surface dust
particles. Higher speeds also result in greater turbulence in the “wake” zone around the vehicle.

 Vehicle weight – Heavier vehicles result in greater forces being exerted upon surface dust
particles.
 Surface loading – The amount of silt present on top of a paved road surface affects the amount of
dust generated as a result of vehicle re-entrainment. The same is true for unpaved surfaces.
 Surface material silt and moisture content – As with wind erosion, the number of small particles
contained in a sample as well as the moisture content of the sample contribute to different
amounts of fugitive dust emission. This is mainly applicable to unpaved roads only.
4.1.3 Material Handling

Material handling is another major source of fugitive dust emissions and includes a wide range of
activities (crushing, screening, loading, unloading, and transferring material), types of equipment (trucks,
front end loaders, railcars, ships, conveyors, etc.), and final or intermediate product destinations (storage
piles, hoppers, conveyors, etc.). Dust emissions are produced when the cohesive forces between the dust
particles are overcome by the force of impact onto a surface. Dust can also be emitted due to
windstripping of material as it falls through an airstream, the displacement of material from an area due to
boil-up, and the windstripping of material from a container/vehicle as it moves through the environment.
The following factors affect dust emissions that result from material handling.
 Material silt and moisture content – As with wind erosion and vehicle re-entrainment, material
silt and moisture content have an effect on the amount of dust generated.
 Drop height of the material – Greater drop heights result in greater potential dust emissions
because of greater impact force and because the material is subject to windstripping for a longer
period of time.
 Quantity of material being handled – Potential fugitive dust emissions increase as more material
is handled.
4.2 Fugitive Dust Control

There are a number of methods to control the amount of fugitive dust generated from the aforementioned
categories of emission sources. The following are brief descriptions of some common control
methodologies for each category.
4.2.1 General Control Methods

Potential dust emissions due to wind erosion can be controlled by reducing the wind speed, by reducing
the exposed surface area, or by increasing the cohesive forces between material particles. Slowing down
the wind can be accomplished by natural windbreaks (trees, shrubs, or berms) or artificial windbreaks
(windscreens and fences). Reducing the exposed surface area can be accomplished by pile shaping,
lowering pile heights, constructing enclosures, and increasing cohesive forces by watering, the use of
chemical stabilizers, or compacting the material to reduce the spaces between particles. The following are
brief descriptions of some of these methods.
 Windbreaks – Porous windbreaks are able to reduce wind speed. Trees and shrubs are examples
of natural windbreaks. Windscreens are an example of artificial windbreaks and the use of an
artificial windbreak allows for porosity control.

 Chemical stabilizers – Chemical stabilizers can be applied to storage piles in order to form a
crust on an exposed surface. Although this method is able to control dust emissions, it can also
contaminate a product. There are several classes of chemical stabilizers that differ in cost,
application rate and frequency, crust thickness, water permeability, and durability.
 Pile height – Because wind velocities tend to be greater at higher elevations, it is preferable to
have low pile heights.
 Watering – The addition of water to storage piles can reduce potential dust emissions by
increasing the cohesive forces between dust particles. Furthermore, dust suppression can be
accomplished by using sprayers that disperse water particles into the air. These water drops
collide with dust particles that are already airborne and then weigh down the dust particles so
that they are returned to the material source or the ground, adjacent to a stockpile.
4.2.2 Controls for Vehicle Re-entrainment

Control methods for vehicle re-entrainment fall into three categories: preventing silt material from getting
onto the road surface, removing the material once it is on the road surface, or reducing the impact of the
vehicles on the surface material.
Keeping a product, and therefore dust, contained to its source can prevent dust emissions from vehicle re-
entrainment. This means that reducing dust emissions from storage piles and material handling can
indirectly reduce the dust emissions from vehicle re-entrainment on roadways close to storage areas.
Broom sweepers, vacuum sweepers, or flushing are methods that can be used to remove dust particles
from paved road surfaces. Coarse aggregate placed on roadways helps reduce dust from unpaved
surfaces.
Road emissions can also be reduced by reducing vehicle loads and reducing the number of vehicles using
the roads. Paving, gravel, and chemical stabilizers can also be used for unpaved roads.
4.2.3 Controls for Material Handling

The controls used for handling dust sources are similar to the controls for wind erosion and include
reducing wind speeds, the use of chemical stabilizers, watering, etc. Other controls specific to material
handling include reduction in drop point height, material chutes, conveyor covers and transfer point
enclosures.

5.0 Control Methodology Implementation Summary
The original 1990 Plan and its Addenda included recommendations for control strategies for improved
control of fugitive dust. The control methodologies that were subsequently instituted at the facility were
based, in part, on these recommendations. The following controls have been implemented by Norlite in
the past ten to twenty years.
5.1 Kiln Feed Area

5.1.1 Kiln Rear Chamber System Upgrade
Improvements were made to the kiln feed rear chamber system in 2010 and 2011. On the back end of the
kiln (the feed end), a second seal system was installed behind the existing seal system and both systems
were enclosed. The space between the two seal systems is under a low pressure vacuum system at
approximately -0.12” water column that enables the capture of emissions that may escape from the back
of the kiln during system upsets. The system then feeds the emissions back into the front (flame end) of
the kiln. This negative pressure is maintained by an automated control valve that is connected to a
pressure monitor and a PLC logic program. The current kiln rear chamber now consists of the following:
a double seal system at the back end (feed end) and a single seal system at the front end. Engineering
drawings of this system are attached as Appendix G.
5.2 Kiln Area

5.2.1 Kiln Clinker Storage Pile Operational Changes
The spray headers at the heads of the Kiln 1 and Kiln 2 clinker conveyors were angled outwards
approximately 45 degrees to maximize water coverage on the piles themselves rather than to just the
material dropping from the conveyor. Front end loader operating procedures were put in place and
operators were trained to minimize product drop heights during product transfers between the two clinker
piles. Finally, procedures to keep the water sprays active all weekend-long while the clinker piles rebuild
were put in place to reduce “dry spots” that formed previously.
5.3 Finish Plant Area

5.3.1 New Windscreen
A windscreen was installed northwest of the enclosed fines storage structure in order to mitigate dust
generation from the open fines storage pile, located north of the enclosed fines storage structure. The
windscreen measures approximately 25 feet high and approximately 60 feet long. Each rubber strip is 5
inches wide with about 6 or 7 inches between strips. This wind screen has a porosity range of 55 to 58
percent due to the spacing between the strips.

Figure 1. Wind Screen in Finish Plant Area
The 50%-60% porosity wind screen is in place to the northwest of the fines storage structure, which can be seen on the left side
of this photograph. The piping shown above the wind screen is used to pneumatically convey dust from the kiln baghouses to the
baghouse dust silos, which sit to the east of the fines storage structure. This system is completely enclosed.
5.3.2 New Anemometer

An anemometer was installed approximately ten feet above the top of the fines storage structure in order
to monitor wind speeds in the Finish Plant Area. Meteorological readouts were installed in the finish plant
control room with alarms set at 10 mph, 15 mph, and 20 mph and a logsheet for recording meteorological
parameters and alarm occurrences was established. This has allowed Norlite personnel to monitor wind
speeds and shut down Finish Plant operations if wind speeds are deemed to be too high.
5.3.3 Block Mix Conveyor to Radial Stacker Transfer Point Redesign

The transfer point between the block mix conveyor, which carries material from the baghouse dust silos
and the radial stacker, was improved by installing a new tailings hopper with a circular outlet and rotating
seal. These improvements were made in order to reduce the amount of material spilled onto the ground at
this transfer point. Some of the spillage was due to block mix material sticking to the underside of the
conveyor, so a new “Gorden” belt scraper designed for ultrafine screening was installed in place of the
old belt scrapers. In addition to these improvements, 600 feet of uncovered conveyors in the finish plant
conveyor system were eliminated, the shipping tower was removed, and several drop points related to the
old conveyor configuration were also eliminated. Operators were also trained to prevent “end-of-run”
situations by stopping the block mix run after a set length of time rather than waiting for the material to
run out.
5.3.4 Drop Distance Rod on Radial Stacker

An 18-inch long rod coated with fluorescent paint was installed on the bottom of the radial stacker with a
short section of chain. This improvement was made to assist operators in keeping the radial stacker at an
appropriate height relative to the height of the block mix pile forming underneath it. The operators were

trained to keep the drop distance less than the length of the rod in order to minimize potential dust
emissions as a result of unnecessarily high drop distances.
5.4 Fines Processing Area

5.4.1 New Covered Storage Structure
Installation of a new covered storage structure in the fines processing area was completed in June 2010 to
store the 8x0 product. This structure helps minimize potential fugitive dust from wind erosion. The
storage structure is 55 feet wide by 80 feet long with an arch height of 25 feet and is comprised of a steel
tube arch structure covered in a rubberized canvas. The storage capacity of the structure is approximately
1,200 tons. As the 8x0 product is produced in the fines processing area, it is moved directly into the
storage structure to reduce exposure.
5.5 Roads
5.5.1 Closing Saratoga Street Entrance to Heavy Vehicles
Since the 1990 Plan, heavy vehicles are no longer allowed to enter the facility from the Saratoga Street
entrance and are exclusively using the Elm Street entrance. There are defined, dedicated roads for large
equipment travel at the facility. All LGF and aggregate trucks enter and exit from the Elm Street entrance
(Gate 1) on the south-western portion of the facility. These actions moved all heavy traffic away from the
residences on the eastern border of the facility and cut down on the potential distance (in miles) heavy
traffic may travel on the facility. Cutting down on miles traveled by heavy vehicles helps mitigate the
potential fugitive dust emissions at the facility.
5.5.2 Increased Road Watering Frequency

Since the 2002 Fugitive Dust Plan Addendum, two full-time drivers are now dedicated to road watering,
as conditions may dictate, in order to reduce fugitive dust emissions from roads. These drivers are on a
schedule but provide additional watering as necessary.
5.6 Conveyors
5.6.1 Covers on Conveyors
Covers were added to conveyors at the facility to shield material from wind erosion and particulate
entrainment.
5.7 Trees
5.7.1 Tree Barrier
As of the 1995 Plan Update, a tree line has been added to the eastern side of the facility to mitigate
fugitive dust near a neighboring residential area.
5.8 Baghouses
5.8.1 Elimination of Baghouse Dust Pile and Transfer Points
Since the 1995 Plan Update, Norlite no longer collects dust from baghouses onto an open pile, and any
related activities, such as loading onto trucks and on-site open transport, no longer occur.

5.9 Coal
5.9.1 Elimination of Coal Pile and Transfer Points
Since the 1990 Plan, Norlite has ceased using coal in their operations. Due to this change, the following
potential fugitive dust emission sources have been eliminated from the facility:
 Travel of coal delivery trucks;

 Unloading of coal onto coal pile;
 The coal pile itself; and
 Dumping coal into the coal mill hopper
Eliminating coal use at the facility removed 1,500 tons of coal storage on-site, as well as the processing
equipment.

6.0 Current Operations, Dust Sources, and Controls
An overview of the Norlite facility can be seen in Figure 1 in Appendix A. For discussion and calculation
purposes, the facility is divided into areas as follows:
 Quarry (QA)
 Primary (PR)
 Kiln Feed (KF)
 Kiln (KL)
 Finish Plant (FP)
 Fines Processing (FN)
 Block Mix (BM)
 Boneyard (BY)
 Southern Overburden Storage (OS)
 Island (IS)
 Roads (RD)
The current operations at the Norlite facility are summarized in the flowcharts presented in this report as
Sheets 1 through 11 in Appendix B. The flowcharts are organized into the above areas and show the
material flow through each area along with fugitive dust emission points, identified by unique source ID
numbers. Figures 2 through 12 in Appendix A show the geographical locations of the emission points on
a series of aerial photographs.
Information on operations in each area and their associated controls is based on site visits by SPEC and
on conversations with facility employees. Information on each fugitive dust emission source, including
existing controls and estimated annual emissions, can be found in the summary table in Section 9.0
below, as well as in Appendix C. A photo log that points out each emission source through a series of
photographs is included as Appendix E.
6.1 Quarry Area

Raw shale is mined from the quarry by drilling and blasting. Haul trucks are loaded with raw shale that
transport shale from the Quarry to the Primary Area for processing. On a daily basis, one to two haul
trucks are in use, each making 10 to 15 trips per day, with a daily maximum of 30 to 40 trips per truck.
The haul trucks operate every weekday from 6 AM to 2 PM, as well as some Saturday mornings when
needed.
In addition to the mining operations in the rock quarry itself, overburden stripping occurs in order to
expose new shale areas for mining. The overburden material, which consists primarily of clay and sand, is
stripped using bulldozers and front end loaders, loaded onto haul trucks, and transported to the Southern
Overburden Storage Area. In this operation, three to four haul trucks make 30 to 40 trips hauling
overburden from the quarry to the Southern Overburden Storage Area.
Fugitive dust emission sources in the Quarry Area include drilling, blasting, overburden stripping, and
handling of raw material shale and overburden.

6.2 Primary Area
The Primary Area consists of the shot rock pile, Canal pile, jaw crusher, double deck screens, shale fines
pile, and kiln feed pile. Haul trucks deposit raw shale from the quarry onto the shot rock pile. The raw
shale from this pile is then moved into the jaw crusher hopper via front end loader, goes through the
double deck screen, goes through the primary cone crusher, and is sorted onto either the shale fines pile or
the kiln feed pile. The material in the shale fines pile is later transported to the boneyard or the
overburden storage area. Although some of the crushed raw shale immediately moves onto the Kiln Feed
Area, a portion of it is often moved to the Canal pile where it waits to be added to the kiln feed.
The crushers in the Primary Area typically run only during the week, although they will run for 2 to 3
hours on Saturdays if the need arises. When the Primary Area is active, the crushed raw shale is taken
directly from the kiln feed pile that forms at the output of the crushers. Otherwise, the crushed raw shale
from the Canal stockpile is used to feed the kilns. It should be noted that up to 15% of the material
introduced to the primary crusher can be rejected and is put back through the crusher for reprocessing.
Fugitive dust emissions sources in the Primary Area include the jaw crusher, double deck screen, cone
crusher, conveyor belts, material transfer points, material stockpiles, and material handling by front end
loaders.
Figure 2. Primary Area Equipment

The Primary Area consists of a jaw crusher (off of the photo to the right), conveyor belts to carry raw shale, a double deck screen
(contained within the housing), and a cone crusher (also contained within the housing) to crush material further. Two conveyor
belts (not pictured) are used to transport material from the screen/crusher housing onto the kiln feed and shale fines piles.

6.2.1 Current Fugitive Dust Control Methodology
There are coarse water sprayers installed at the primary crusher and double deck screens in order to
reduce fugitive dust emissions. Although fine water sprayers were initially installed, the fine nozzles were
replaced by coarse nozzles because fine nozzles cannot be properly maintained in this area; fine sprayer
nozzles have a tendency to get clogged. The current sprayers are garden hose type nozzles. A majority of
the equipment in this area is contained within the housing seen in Figure 2.
6.3 Kiln Feed Area

Crushed raw shale from the Primary Area has two methods of entering the Kiln Feed Area. The first
method is through the kiln feed pile that forms as the raw shale exits the primary crusher. The kiln feed
pile has an underground drop point beneath it that transfers the raw shale onto the #4 conveyor. This drop
point onto #4 conveyor in located underground. Alternately, crushed raw shale from the Canal pile can
be added to the kiln feed process by loading the material directly onto the #4 conveyor via front end
loader.
At the end of the #4 conveyor, the material is dropped onto the #5 conveyor and then onto the kiln feed
storage pile. A drop point exists underneath the kiln feed storage pile, giving the pile a concave shape that
keeps pile height to a minimum.
Figure 3. #4 and #5 Conveyors in the Kiln Feed Area

The #4 conveyor, #5 conveyor, and drop point onto the kiln feed storage pile can be seen in this photograph. The #4 conveyor
originates underground under the kiln feed pile in the Primary Area, shown at the far left. The drop point onto the kiln feed
storage pile is enclosed in a chute, shown at the far right.
From the drop point underneath the kiln feed storage pile, the raw shale is transferred onto two
underground conveyors (Kiln 1 feeder belt and Kiln 2 feeder belt), each feeding one of the two kilns. The
raw shale is transported to Kiln 1 via a total of three conveyors (Kiln 1 feeder belt, Kiln 1 lower belt, and
Kiln 1 top belt), while the raw shale is transported to Kiln 2 using four conveyors (Kiln 2 feeder belt, Kiln
2 lower belt, Kiln 2 middle belt, and Kiln 2 top belt). The feeder belts are completely underground and the

lower belts are partially underground, but contain dust covers throughout. All other conveyors are
aboveground and have dust covers to partially enclose them.
The raw shale is fed into the back end of the kilns by AccuRate feeders, which also have dust covers,
acting as partial enclosures. From this point the shale passes through a chute into each kiln, respectively.
The material is heated inside the kiln to 2000°F to 2100°F and then transferred to the clinker coolers. It
then exits the clinker coolers and is added to the clinker piles near the Finish Plant Area. The double seal
rim seals at the back of the kilns are typically cleaned out once a day. This is done through a hopper on
the underside of the back end of the two kilns. This hopper is connected to both seals and has a hinged
chute door. When the door is opened, rim seal dust drops onto the ground and Norlite personnel manually
move it to the muck pile for later reincorporation into the product stream. See Appendix G for an
engineering drawing of the chute and seal system.
Fugitive dust emission sources in the Kiln Feed Area include conveyor belts, material transfer points, the
kiln feed storage pile, and maintenance work, including cleaning out the rim seals and the use of vacuum
trucks to clean out baghouse plugs.
6.3.1 Removal of Kiln Feed Silo and Installation of New Enclosure

A new wind wall and metal overhang were installed around the kiln feed storage pile after the former kiln
feed silo was removed. The kiln feed silo was removed in March-April 2012 based on a structural review
conducted at that time. The majority of the wind wall is located to the north of the pile and small lengths
of it wrap around towards the east and west sides. The metal overhang angles up from north to south and
an enclosed material chute transfers material from the #5 conveyor, through the overhang, and onto the
pile. A pile height sensor was also installed, which alerts Norlite personnel to stop feeding the pile via a
light above the chute. An automated system is also in place that stops feed to the kiln feed stockpile when
the pile height sensor is tripped. Because the shale is transferred to the kiln feeder belts through a drop
point underneath the storage pile, the kiln feed storage pile has a concave shape, which can be seen in
Figure 4.
Figure 4. New Kiln Feed Storage Pile Enclosure

The new kiln feed storage pile enclosure consists of a wind wall and a metal overhang. An enclosed chute guards the drop point
from the #5 conveyor against wind erosion. A height sensor is located beneath the metal overhand and an alert light (located on
top of the chute, off the picture) is used to notify personnel when the pile height approaches its maximum.

All aboveground conveyors in the Kiln Feed Area have dust covers on them to help reduce potential
fugitive dust emissions by eliminating or reducing wind exposure. A more in-depth description of this
structure is included as Appendix H. Figure 3 shows dust covers on both the #4 and #5 conveyors. These
are typical of the conveyor dust covers found throughout the site.
When crushed raw shale is added to the #4 conveyor from the Canal pile, water is added to the #4 belt as
a method of dust suppression. This is due to the fact that the material dries out while being stored in the
Canal pile and therefore has the potential to generate dust. Water is not added to the #4 belt when crushed
raw shale is taken directly from the kiln feed pile because the material in that pile is already wet from the
water sprayers in the Primary Area. Operators may add water if this pile is excessively dry.
A pile height sensor that hangs down from the metal overhang triggers an alarm light at the top of the kiln
feed storage pile to alert facility personnel to stop feeding the kiln feed storage pile. Keeping the pile from
overflowing aids in controlling potential fugitive dust by keeping pile height to a minimum.
Both of the kiln feeder belts that transport material from the kiln feed storage pile are located
underground, which significantly reduces dust emissions. The Kiln 1 lower belt and Kiln 2 lower belt are
both partially located underground, with dust covers over the conveyors after they transition to an area
aboveground. Additionally, the entrance to the underground enclosure for the feeder and lower belts is
covered in a “meat-locker style” curtain to prevent dust from escaping the enclosure. All conveyor-to-
conveyor drops in the Kiln Feed Area are conducted through chutes, which also reduces potential dust
emissions.
Figure 5. Chute for Cleaning Kiln Rim Seal

The kiln rim seals are cleaned out manually through chutes on the undersides of the back of each kiln. When the chute door
opens, material drops onto the ground to be picked up by plant personnel.

A rear chamber system is in-place at the feed of each kiln. This consists of a double seal at the feed end of
the kiln, a single seal at the discharge end, and piping and instrumentation connecting the two ends. The
rear chamber system is kept at a negative pressure of approximately -0.12” water column in order to
prevent emissions from escaping through the feed end. The primary fan is located at the front end of the
kiln and air dampers are located at the front and back ends of the kiln in order to maintain the system at
the appropriate pressure.
6.4 Kiln Area

The Kiln Area consists of the clinker coolers, clinker material exiting the kiln, and the clinker piles.
Material exits the kilns and enters the clinker coolers through grizzlies. Each clinker cooler contains a
grate conveyor that transports the clinker material towards the output of the clinker coolers. The material
is piled approximately one foot high on this conveyor and fans provide cooling air from underneath.
Because the clinker coolers are enclosed systems, operators monitor the clinker coolers through windows
mounted inside the clinker coolers.
After the material goes through the kilns and clinker coolers, it is transferred onto conveyors (Kiln 1
clinker belt or Kiln 2 clinker belt) and deposited onto clinker piles (Kiln 1 clinker pile or Kiln 2 clinker
pile). The drop point between each kiln and conveyor, which ends underground, exists on the outside of
the kiln building and is open to the outside. This transfer point contains a grizzly and can be seen in
Figure 6.
Figure 6. Kiln Clinker Cooler to Clinker Belt Drop Point

The drop point between the clinker cooler and clinker belt exists outside of the clinker cooler building and the material passes
through a grizzly.
A front end loader is used to transfer clinker from the Kiln 2 clinker pile onto the Kiln 1 clinker pile.
From there, it is transferred via an underground drop point onto the #1 conveyor that marks the beginning

of the Finish Plant Area. Because this drop point exists under the material pile, the southern portion of
the Kiln 1 clinker pile has a concave shape.
The Kiln Area also contains the muck pile, which is a collection of material including baghouse dust,
aggregate fines, and other rejected or off-spec product. When material is added to the pile, it is typically
from a vacuum truck and is in the form of a wet slurry. Norlite actively feeds back this material into the
beginning of the finish plant. The kilns are operational 24 hours a day, 7 days a week, 365 days a year,
except during maintenance.
Fugitive dust emission sources in the Kiln Area include the conveyor belts, material transfer points,
material stockpiles, material handling by front end loaders, the kilns, and clinker coolers.

Fugitive dust emissions are reduced in the Kiln Area by placing the beginning of the clinker belts
underground. After the belts emerge from the ground, they are partially enclosed by dust covers. There is
also an option of adding water to the clinker belts, although it is at the operators’ discretion (dependent on
material source). There are also water sprayers at the discharge end of the clinker belts that spray the
material dropping from the belts to the clinker piles as well as at the clinker piles themselves.
All dust collected by the baghouses is pneumatically conveyed to the dust silos in the Finish Plant Area.
Because this system is an enclosed system, there are no dust emissions from the baghouses and pneumatic
conveyance system, with the exception of maintenance work to clean out the baghouses.
6.5 Finish Plant Area

The #1 conveyor takes clinker material from the Kiln 1 clinker pile and deposits the material onto a
grizzly that sorts out material that is considered to be too large. This oversize, consisting of material that
is greater than 3 or 4 inches in diameter, collects on the grizzly pile for later reincorporation into the
product stream. The material that passes through the grizzly is then transported to the screens building for
screening by product size. From here, material is deposited onto various conveyors depending on material
size. Material that passes through the screens building ends up in one of the following categories and is
sorted onto its corresponding conveyor: 3/4” aggregate, 3/8” aggregate, oversized material, or fines. The
3/4” and 3/8” aggregate materials are deposited onto short term storage piles and are then moved to long
term storage piles by front end loader. The material that is sorted onto the fines conveyor is transported to
the enclosed fines storage structure for future addition into block mix. The oversized material is passed
through the El Jay crusher and then returned to the grizzly located between the #1 and #2 conveyors via
the #2 return conveyor. From there, it passes through the screens building again and is sorted by product
size. Approximately half of the material that originally enters the Finish Plant Area is passed through the
El Jay cone crusher before being appropriately sized to proceed onto size-specific short term storage piles.
Of the 50% that passes through the El Jay crusher, 15% will pass through it a second time.
Material from the two baghouse dust silos (baghouse dust silo 1 and baghouse dust silo 2) are dropped
onto a conveyor in the underground shipping tunnel (shipping belt) and are then deposited onto a short
term block mix pile by way of the stationary belt and radial stacker. Norlite personnel are able to control
the drop height off of the radial stacker.

The enclosed fines storage pile is located where a fines silo previously existed. This structure consists of a
square base of concrete blocks roughly 8 feet high and 30 feet long. There are two tiers of metal bracing
above this base that are covered by fabric tarps. A guarded material chute drops in from above, through
the roof, and down into the fines enclosure. Material is removed from this structure from the north end,
where the material spills out onto the ground to form the open fines pile. A wind screen is in place to the
west of the open fines pile to protect the pile from wind erosion. This material can also be fed to its
terminal point through the bottom of the pile via the shipping tunnel, which is below grade. This
structure is discussed in greater detail in Appendix H.
The Finish Plant operates two 8 hour shifts every weekday and one 8 to 10 hour shift on Saturdays. This
schedule can be adjusted slightly to accommodate customer demand as needed.
Fugitive dust emissions sources in the Finish Plant Area include the conveyor belts, material transfer
points, material stockpiles, and material handling by front end loaders.

All of the drop points onto conveyors after material passes through the triple deck finish mill screen occur
within the screen building and are therefore enclosed drop points. Once each conveyor emerges from the
screen building, a dust cover is in-place to reduce dust emissions.
The following emission points in the Finish Plant Area have baghouse dust control: triple deck finish mill
screen, 3/4” discharge conveyor, 3/8” discharge conveyor, oversize discharge conveyor, El Jay crusher,
fines to silo conveyor, stationary belt, and radial stacker. However, the baghouse unit located adjacent to
the screen building is currently not operational, leaving everything but the stationary belt and radial
stacker without any baghouse dust control. Most of the conveyors have dust covers on them to reduce
dust emissions. Larger aggregate fractions are also mixed into the process in this area, which helps
mitigate the potential for fugitive dust.
The drop point to the 3/4” short term storage pile is enclosed by a watered chute, which can be seen in
Figure 7. The water trickles down the entire length of the chute and onto the storage pile, thus providing
dust suppression to the storage pile itself as well.
The 3/8” short term storage pile has a water sprayer that sprays both the drop point onto the pile and the
pile itself.
The enclosed fines storage pile structure provides the storage pile protection from wind erosion, while the
chute above it provides fugitive dust emission reduction during the transfer of material from the conveyor
to the storage pile. The banded wind screen northwest of the structure provides some emission control for
the open fines pile.
The radial stacker that transports material from the baghouse silos to the short term block mix short term
storage pile can be adjusted in height in order to control the material drop height. This is manually
controlled by facility personnel.
All of the short term storage piles that the various conveyors load onto are cleared by front end loader
onto customer trucks as they are being formed. Thus, the size of each pile stays relatively constant

throughout the day. In the event that there is extra inventory, the front end loaders transport the excess
material to long term storage piles in the 8x0 long term storage enclosure.
Figure 7. 3/4" Aggregate Drop Point

The drop point onto the 3/4" short term storage pile is enclosed in a watered chute. Water runs down the entire length of the chute
and is able to flow onto the storage pile itself through the holes along the length of the chute. The 3/4” product also gets
deposited onto the piles through these holes.
6.6 Fines Processing Area

The Fines Processing Area is located at the southeastern portion of the Norlite facility and was put into
operation in the fall of 2007. The area is equipped with a Cedarapids hopper and an Astec 2618 fines
screen to process lightweight aggregate fines and separate the 8x0 product from the 4x0 product. The 8x0
product is stored in the covered storage pile area just north of the Astec screen. Rejected material from

this process is sent back to the Finishing Plant for re-incorporation into the product stream. There may be
a reduction in the volume of material that goes through this process in the future based on current
customer analysis.
Figure 8. Fines Processing Area

The Fines Processing Area consists of a fines screen and several conveyors in order to sort material into 8x0 product and 4x0
product. The 8x0 product is moved into the storage structure to the north of the area and the 4x0 product is moved back to the
Finish Plant Area for reincorporation into product streams.
The covered storage structure was installed in June 2010 and is 55 feet wide, 80 feet long, and has an arch
height of 25 feet. The frame is a steel tube arch structure with a rubberized canvas covering.
Approximately 1,200 tons of material can be stored in the structure, which is approximately a two week
supply based on 2013 demand for the product. The supply this represents may fluctuate with market
conditions. This structure is a significant mitigation measure for minimizing potential fugitive dust.
The Fines Processing area typically operates one shift per day, Monday through Friday. During peak
demand periods, additional run hours may be required, including weekends.

The covered storage structure provides wind erosion protection for the 8x0 long term storage pile in the
Fines Processing Area. This area does not have any other structural emission reduction methods currently
installed. However, there are routine maintenance activities to remove belt tailings and spillage in order
to reduce dust emissions from this area.
6.7 Block Mix Processing Area

The Block Mix Area is located to the west of the Fines Processing Area and is used for both long term
storage of block mix product and screening of the block mix prior to shipping to customers. Prior to
shipment, two portable screens, the Reade screen and the Astec 710T screen, are used to remove clumped
material caused by excess surface moisture from precipitation or intentional watering activities. The

Reade screen has been in-place since 2001 and the Astec 710T screen was added in 2007 as a backup to
the Reade screen. These two screens can be used interchangeably, but rarely simultaneously.
Figure 9. Portable Screens in the Block Mix Processing Area

The Reade and Astec screens in the block mix processing area are used interchangeably to screen block mix material before
loading onto customer delivery trucks. This screening step is necessary in order to remove any ice, contamination, or chunks of
material that may have formed while being stored in the long term block mix storage piles. Front end loaders are used to load
material into and out of these portable screens.

Fugitive dust control in this area consists of proper loading and unloading procedures conducted by
Norlite personnel. A copy of Norlite’s Loader Operator Procedures, which outlines a protocol to
minimize dust “boil-up” to prevent fugitive dust during material transfer, is included as Appendix J.
6.8 Island Area

The Island Area is used to store aggregate product before customer shipping. Several long term storage
piles exist in this area and front end loaders are used to load and unload the storage piles. As of December
2013, when a stockpile inventory was performed by Spectra Environmental Group, Inc., the following
storage piles were present in the Island Area.
 3/4” aggregate long term storage pile (four piles)

 3/8” aggregate long term storage pile (one pile)
 block mix long term storage pile (one pile, not typical)
The size of the piles in this area fluctuates based on customer product demand and the output rate of the
kilns. Therefore, there are times when one or more of these storage piles is non-existent. The stockpile
inventory is attached as Appendix F.

Norlite personnel. A copy of Norlite’s Loader Operator Procedures, which outlines a protocol to
minimize dust “boil-up” to prevent fugitive dust during material transfer, is included as Appendix J.
6.9 Boneyard Area

The Boneyard Area is located north of the Block Mix Processing Area and contains two shale piles,
boneyard shale pile 1 and boneyard shale pile 2. These piles consist of raw shale fines that are produced
in the Primary Area, a portion of which will eventually be taken to the Southern Overburden Storage area.
The remainder will be sold or utilized around the plant. Aside from these two piles, there are
miscellaneous items such as oversized equipment parts and tires that are stored in the area as spare parts.

Norlite personnel and maintenance of low stockpile heights. A copy of Norlite’s Loader Operator
Procedures, which outlines a protocol to minimize dust “boil-up” to prevent fugitive dust during material
transfer, is included as Appendix J.
6.10 Southern Overburden Storage Area

The Southern Overburden Storage Area is located to the west of the Block Mix Processing Area and has
an area of 34 acres. The overburden that is removed from the Quarry Area is moved to this area under
Norlite’s Mine Permit. The overburden is placed in a series of compacted berms with a fill area behind
each berm. The active work area is normally less than five acres. This project has been ongoing since
2008 and is planned to go for at least a total of ten years. Once complete, this project will be terminated
and the entire area will be revegetated and no further fugitive dust will be generated from this area.

One bulldozer runs when the area is receiving stripped overburden from the Quarry. Material is laid down
and a sheepsfoot compactor is used immediately to compact the overburden material down to almost full
compaction. This ensures that all rainwater runs across the area rather than soaking into the soil. At the
end of the day, there is no material that is placed in the Southern Overburden Storage Area that does not
get compacted. Areas that have reached final grade and have been stabilized are seeded to control erosion
and fugitive dust.
6.11 Roads
Various roads are present at the Norlite facility, most of which are unpaved. These roads connect the
various areas to each other and are used by haul trucks, front end loaders, customer delivery trucks, a
water truck, maintenance trucks, LFG delivery trucks, and passenger vehicles.
The Saratoga Street entrance, located at the northeast area of the facility, is paved and is used by
employees and visitors to access the site. The other paved road at the facility is the beginning of the Elm
Street Access Road, used by customer delivery trucks, although this paved portion’s length is negligible.
The Norlite facility uses four front end loaders during day-to-day operations. The loader used in the
Quarry operates for 3 to 4 hours each day and transports shot rock between the quarry wall and haul truck.
Another loader is used in the Primary Area to transport shot rock from the shot rock pile to the jaw

crusher. The loader travels 200 feet back and forth between the pile and the hopper and operates in 3- to
4- hour shifts. The loader that operates near the guard shack also does multiple trips of approximately 200
feet each day. The front end loader with the most mileage is the 988F loader, used for loading product
onto customer trucks, moving the clinker piles, and moving material from short term storage piles to long
term storage piles. The 988F covers approximately 15 miles each day.

Fugitive dust control on unpaved roads is achieved by watering the roads. Water truck activity is greater
during the summer months when the potential for fugitive dust emissions is greater. Typically, there is
one water truck running all day on a schedule, with a second truck added during especially hot and dry
days. On a typical 10-hour work day, a water truck will generally use 10 to 12 loads of water while
watering the roadways, and the shot rock pile, and clinker piles, as needed. The piles in the Fines
Screening Area are also watered as necessary. Although the water truck(s) normally run on a schedule,
there are times when the trucks run more frequently in response to dry conditions.
6.12 Loading Trucks and Piles

Front end loaders and trucks are used throughout the site in order to move material. Haul trucks are used
to transport shot rock from the Quarry to the Primary Area, as well as to transport overburden from the
Quarry to the Southern Overburden Storage Area. Front end loaders are used to load and unload all of the
storage piles on-site, including preparing product for customer pickup.

Norlite has truck loading procedures that operators are required to follow when loading material onto
trucks and piles. This procedure (Appendix J) uses a method for rolling material onto the receiving
surface in order to minimize dust boil up.
6.13 Current Conditions of Existing Controls

According to Norlite personnel, all controls that are in-place around the facility are functional with the
exception of the baghouse located in the Finish Plant Area. This baghouse is currently out of service
because the bottom of it is compromised. However, all of the ductwork for the baghouse are still intact
and connect to the triple deck finish mill screen, the El Jay crusher, and all of the conveyor belts that
transport product out of the finish plant building where the triple deck finish mill screen is housed. There
are also other areas where spray bar piping is non-functional.

7.0 Fugitive Dust Emission Calculations Methodology
Emission rates were estimated for each emission point at the Norlite facility. The sources were identified
by a combination of the following activities: observations during site visits, discussions with Norlite
personnel, review of Norlite’s process flow diagrams and piping and instrumentation diagrams,
preparation of simplified process schematics, and review of schematics by Norlite personnel.
To calculate potential fugitive dust emissions, SPEC primarily used equations from AP-42 Compilation
of Air Pollutant Emission Factors, Fifth Edition 1. These equations are industry standards for calculating
emissions in the aggregate industry. The following is the general equation for emissions estimation.
 ER  (1)
E   EF  A 1  
 100 
E  emissions (ton/yr)
A  activity rate
EF  emission factor
ER  overall emission reduction efficiency (%)
The emission factor (EF) is a representative value that relates the quantity of a material released to the
atmosphere with an activity associated with the release of that material. The factors are usually expressed
as the weight of material divided by a unit weight, volume, distance, or duration of the activity emitting
the material. Most of the emission factors contained in this report have the units pounds of dust emitted
per ton of material processed, i.e., lb/ton. The activity rate’s units are dependent on the emission factor’s
units.
The overall reduction efficiency (based on facility controls) can be a combination of one or more
efficiency value resulting from one or more control measures applied to a potential fugitive dust emission
source. In the case with multiple emission reduction efficiencies, the following equation is used to
compound them into one overall emission factor.
 ER1  ER2   ER3 

(2)
ER  1  1  1  1   ...
 100  100  100 
This overall reduction efficiency can then be used in Equation (1) to determine the emissions from a
single source.
When an equation for the emission factor was available, SPEC used it to calculate a site-specific emission
factor, and then used it in Equation (1), along with an activity rate, in order to estimate the emissions from
the source. In the case that an equation is not available, or if SPEC deemed the equation not applicable to
the Norlite site, a general emission factor provided by AP-42 was used. These general emission factors
were obtained from the United States Environmental Protection Agency’s (EPA) WebFIRE online
emissions factor repository, retrieval, and development tool 2. SPEC chose to favor the use of site-specific
equations over the use of AP-42 emission factors because the AP-42 emission factors are generalized
factors based on EPA studies that may not be suitable for all processes and locations. Conversely,
equations using site-specific information are preferred because they use site- or process-specific values to
calculate the emission factors, and are therefore more accurate.

The following are the equations provided by AP-42 that SPEC used to calculate emission factors for use
in the general emission equation. For emission sources that do not fit any of the following categories,
such as fines screening or crushing operations, the emission factors from WebFIRE were used to calculate
estimated emissions.
7.1 Drop Point Emissions

Drop points are points in a process where material is dropped from one location to another. This can be
batch operations, such as a front end loader depositing material onto a storage pile, or continuous
operations, such as a conveyor dropping material onto another conveyor. The emissions from both types
of drop operations can be estimated using the following equation obtained from AP-42 Section 13.2.4 1.
Note that superscripted numbers relate to an equivalent numbered reference in Section 11.0 References of
this Plan.
1.3
U 
 
5
EF  k (0.0032)   1.4 (3)
M 
 
 2 
EF  emission factor (lb/ton)

k  particle size multiplier (dimensionless)
U  mean wind speed (mph)
M  material moisture content (%)
The particle size multiplier varies with aerodynamic particle size range according to the following table.
Table 1. AP-42 Drop Point Emissions Aerodynamic Particle Size Multiplier 1

< 30 µm < 15 µm < 10 µm < 5 µm < 2.5 µm
0.74 0.48 0.35 0.20 0.053
However, rather than using one of the listed aerodynamic particle size multipliers, SPEC has used k=1 in
order to account for larger total suspended particulate matter (TSP), which results in a conservative
estimate of emissions by capturing particles larger than 30 µm.
7.2 Storage Pile Wind Erosion Emissions

All outdoor storage piles are subject to wind erosion, which is a source of potential fugitive dust. SPEC
has used the emission factor equation for wind erosion from section 11.2.3 of the fourth edition of AP-42
3
rather than the equation given in the fifth edition. This is due to the availability of site-specific data;
SPEC does not have reliable data to calculate emissions based on the equations in the fifth edition of AP-
42 but has reliable data for use in the fourth edition equation.
 s  365  p  f  (4)
EF  1.7    
 1.5  235  15 

EF  total suspended particulate emission factor (lb/day/acre)
s  silt content of aggregate (%)
p  number of days with 0.01 in of precipitation per year
f  percentage of time that the unobstructed wind speed exceeds 12 mph at the mean pile height
The values used for s, p, and f are site-specific values that are detailed in Section 8.0 Site-Specific Values.
The units for the emission factor for wind erosion are not the typical lb/ton but are in lb/day/acre.
Therefore, calculating the emissions from storage piles requires information on the number of days each
stock pile is present annually as well as the surface area of the stockpile.
Most of the stockpile surface areas have been estimated using the surface area of a cone. However, some
stockpiles required different estimation methods. An example of a deviation from the conical assumption
is the open fines storage pile whose surface area has been estimated using a wedge shape.
7.3 Vehicular Traffic on Unpaved Roads

The emission factor equation for vehicular travel on unpaved roads from section 13.2.2 of AP-42 1 takes
into account road silt content, mean vehicle weight, and the number of days in a year with at least 0.01
inches of precipitation. It does not take into account vehicle speed, because AP-42 has found that it does
not have a significant impact on emission calculations.
a b
 s  W   p 
EF  k     1  365  (5)
2  3   
k , a, b  empirical constants dependent on particle size

EF  size-specific emission factor (lb/VMT)
s  surface material silt content (%)
W  mean vehicle weight (ton)
p  number of days in a year with at least 0.01 in of precipitation
SPEC has used the empirical constants provided by AP-42 for PM-30 on industrial roads because PM-30
is assumed to be equivalent to total suspended particulate matter 1. These values can be seen in the
following table.
Table 2. Empirical Constants for Unpaved Industrial Roads 1

PM-2.5 PM-10 PM-30
k (lb/VMT) 0.15 1.5 4.9
a 0.9 0.9 0.7
b 0.45 0.45 0.45
This emission factor has the units of pounds of emission per vehicle mile traveled (VMT), or lb/VMT.
When plugging the emission factor into the general equation for emissions estimation, the activity rate is
then the total number of miles that the particular vehicle type travels annually.

7.4 Vehicular Traffic on Paved Roads
Although most of the roads at the Norlite facility are unpaved, the site contains small segments of paved
roads. In order to calculate the fugitive dust emissions from these roads, SPEC used the following
equation from section 13.2.1 of AP-42 1.
 p  (6)
EF  k ( sL)0.91 (W )1.02 1 
 4 N 
EF  particulate emission factor (same units as k )

k  particle size multiplier for particle size rage and units of interest
sL  road surface silt loading (g/m 2 )
W  average weight of vehicles traveling the road (ton)
p  number of days with at least 0.01 in of precipitation
N  number of days in the averaging period
Table 3. Particle Size Multiplier for Paved Roads 1

PM-2.5 PM-10 PM-15 PM-30
k (lb/VMT) 0.00054 0.0022 0.0027 0.011
Similar to the calculations for unpaved roads, SPEC used the particle size multiplier for PM-30 because it
is assumed to be equivalent to total suspended particulate matter. Unlike the equation for unpaved road
emission factor, the paved road equation takes into account silt loading of the road rather than the silt
content of the road. Although the silt loading value has units of grams per square meter, the particle size
multiplier k includes unit conversions in order to obtain results in lb/VMT. Like calculating emissions
from unpaved roads, the activity rate to determine the tons of annual emissions from paved roads is
required to be in miles.
Because SPEC wanted estimated annual emissions from the Norlite facility, a value of 365 days was used
for N, the number of days in the averaging period.
The value for silt loading used in SPEC’s calculations is 70 g/m2. This is the average value listed in AP-
42 1. An average value was used because an actual site measurement was not available. However, Norlite
personnel stated that silt loading on paved surfaces is minimal and therefore the value used should
provide a conservative estimate of potential fugitive dust emissions from these surfaces.
7.5 Overburden Stripping Emissions

In order to estimate the fugitive dust emissions from overburden stripping in the quarry, SPEC has used
the following equation from section 11.9 of AP-42 1.
0.0021 H 
1.1
EF  (7)
M 
0.3

EF  emission factor (lb/yd3 )
H  drop height (ft)
Because this equation produces an emission factor in pounds per cubic yard (lb/yd3), the volume of
overburden stripped annually was required to calculate the annual emissions from overburden stripping
using the general equation for emissions estimation.
7.6 Overburden Storage Area Bulldozing Emissions

SPEC has used the following equation from section 11.9 of AP-421 to estimate the fugitive dust emissions
from bulldozing the overburden storage area.
5.7  s 
1.2
EF 
M 
1.3
EF  emission factor (lb/hr)

s = material silt content (%)
An estimated number of hours during which bulldozing activities occur is used in calculating the annual
emissions from bulldozing.
7.7 Emission Reduction Efficiencies

SPEC used AP-42, EPA-450/3-77-010, and EPA-450/2-92-004 as references for assigning control
efficiencies to the various emission sources at the Norlite facility.
Table 4. Emission Reduction Efficiencies

Emission Points Controls Efficiency (%)
Unpaved roads Watering 50 4
Loading onto piles Enclosure 70-99 4
Adjustable chutes 75 4
Movement of pile Enclosure 95-99 4
Watering 50 4
Wind erosion Enclosure 95-99 4
Windscreens Very low 4
Overburden removal Watering 50 4
Truck dumping Watering 50 4
Crushing Addition of water to material to be 95 4
crushed and venting to baghouse
Transfer/conveying Enclosed conveyors 90-99 4
Paved road Vacuum sweeping 0-58 5
A 20% reduction is applied for low stockpile heights.

It should be noted that the same AP-42 equations discussed above are used by other organizations to
estimate their fugitive dust emissions. An example of such an agency is the Texas Commission on
Environmental Quality, Air Permits Division, in their New Source Review (NSR) Emission Calculations
11
. This document (Appendix I) contains sample calculations for drop operations using the same equations
that SPEC used to calculate emissions from all drop points, Equation (3).

8.0 Site-Specific Values
All of the equations in the previous section require site-specific values in order to calculate emission
factors. The following are the values SPEC used to calculate fugitive dust emissions as well as the sources
of the values. Note that superscripted numbers relate to an equivalent numbered reference in Section 11.0
References of this Plan.
8.1 Meteorological Data & Topography

Climate data required in some of the equations was obtained from daily weather data for Albany
International Airport in Albany, New York, which is 5.2 miles from the Norlite facility 6. Ten years of
daily weather data for 2004 through 2013 were analyzed in order to obtain the value for p, the number of
days per year with more than 0.01 inches of precipitation; the value for U, the average wind speed at the
site; and the value for f, the fraction of time with wind speeds greater than 12 miles per hour.
The value for p was obtained by counting the number of days with a total precipitation greater than 0.01
inches and dividing by the number of years in the sample, i.e., ten years. The value for U was determined
by taking the average of the daily wind speeds. The value for f was calculated in a similar manner to p:
the number of days with average wind speeds greater than 12 miles per hour were counted and then
divided by the total number of days in the sample. Airport anemometers are typically located at heights of
20 feet to 50 feet 7 while the average storage pile height at the Norlite facility is 10-15 feet. This results in
conservative fugitive dust emission values obtained from SPEC’s calculations because wind speed is
typically lower at lower elevations.
Table 5. Site-Specific Climate Data 6

Variable Value
Number of days with >0.01 in precipitation p 139.4 days
Average wind speed U 7.15 mph
Fraction of time with wind speeds >12 mph f 11.6%
The topography around the Norlite facility is dominated by low hills to the west and the Hudson River to
the east. Small hills and ridges occur on either side of the river and elevations are approximately 50 to 300
feet above sea level within a mile of the facility. The elevation within half a mile of the facility is
approximately 150 feet above sea level. There is a gradual increase in elevation with increased distance
from the river. The highest elevation in the area is five miles northwest of the facility on the west-
northwest side of Mt. Rafinesque at approximately 600 to 700 feet above sea level. The prevalent wind
direction is from west to east year-round.
8.2 Product Characteristics

In order to calculate fugitive dust emissions from aggregate handling processes, it was necessary to define
site- and process- specific product characteristics. This information was provided to SPEC by Norlite in
the form of sieve analyses. Although silt is typically defined as material that passes through the No. 200
sieve 8, 9, SPEC has used a higher percentage for the value of material silt content in order to obtain
conservative estimates of potential emissions. SPEC has used the median of the material passing through
the No. 100 sieve and No. 200 sieve to obtain this conservative estimate of material silt content. Material
moisture content was also obtained from the sieve analysis data. Furthermore, material passing through

the No. 100 and No. 200 sieves can be both silt and clay 8, 9. However, SPEC has assumed that all of the
material passing through these two mesh sizes is silt in order to obtain conservative values for emissions.
Table 6. Norlite Product Characteristics
Moisture content Moisture content

Product Silt content, % (in process), % (post process), %
Raw shale 0.25% 2.00% 2.00%
Shale fines 0.20% 8.00% 8.00%
Clinker 3.30% ≤1.00% 5.00%
3/4" 1.35% 2.50% 7.50%
3/8" 1.48% 2.50% 7.50%
Block mix 9.30% 2.50% 7.50%
3/16" 1.35% 2.50% 7.50%
4x0 6.95% 2.50% 7.50%
8x0 8.95% 2.50% 7.50%
Overburden 61.13% 40.00% 40.00%
Kiln baghouse dust 100.00% ≤1.00% 30.00% (in muck pile)
Kiln rear chamber seal dust 14.65% ≤1.00% 30.00% (in muck pile)
Kiln clinker cooler multiclone dust 32.90% ≤1.00% 30.00% (in muck pile)
Overburden silt content was determined through sieve analysis data collected on the various layers of
overburden (see summary table in Appendix D).
8.3 Mean Vehicle Weights

The equations for unpaved and paved roads require mean vehicle weights in order to calculate the
emission factors. Using information provided by Norlite, SPEC has used the following as mean vehicle
weights. Mean vehicle weight takes into account both empty and full vehicles, such as fuel delivery trucks
and quarry haul trucks.
Table 7. Mean Vehicle Weights

Vehicle Type Mean Weight (ton)
Quarry haul truck 42.5
Lightweight shipment 40
truck (customer)
LGF delivery truck 40
Maintenance truck 10
Passenger vehicle 2
Front end loader 12
Water truck 15.2

SPEC has made the assumption that water trucks can hold an average of 2,500 gallons of water, which
has been factored into the mean weight.
8.4 Production Rates

Information provided by Norlite was used to determine the production rates used in various parts of the
emission calculations. SPEC took the averages of 2009-2013 production rates in order to obtain a facility-
wide average over the last five years.
Table 8. Production Rates

Product Average Production Units
Rate (2009-2013)
Shot rock from quarry 246,000 ton/yr
Overburden 161,000 yd3/yr
(206,265) (ton/yr)
Kiln 1 121,000 ton/yr
Kiln 2 112,000 ton/yr
Shale fines 13,000 ton/yr
3/4” aggregate 69,000 ton/yr
3/8” aggregate 46,000 ton/yr
Block mix 92,000 ton/yr
Aggregate fines 28,000 ton/yr
Because the amount of overburden stripped annually was given to SPEC in volume (cubic yards per
year), it was necessary to convert the average annual volume into average annual weight. The
composition of overburden can vary greatly within the mine site, so SPEC made the assumption that 60-
70% of the overburden is clay and the remainder is sand. This is supported by work conducted in the
Southern Overburden Storage Area. The clay portions are made of up several different layers of clay, so
SPEC used the average density of various clays from Pocket Ref 10. The sand layers are also made up of
several layers of sand types, so an average density was used for sand as well.
Table 9. Overburden Densities 10

Material Density (lb/yd3) Average Density (lb/yd3)
Clay, compacted 2,943
Clay, dry excavated 1,836
Clay, dry lump 1,809
Clay, wet excavated 3,078 2,417
Sand, damp 3,240
Sand, dry 2,700
Sand, loose 2,430
Sand, water filled 3,240 2,903
Overburden 2,562.30
(1.28 ton/yd3)

The following values were used as the production rates of the El Jay cone crusher and the grizzly oversize
pile at the Finish Plant.
Table 10. Other Production Rates
Average
Production
Location Rate Units Information Provided by Norlite Personnel
Of the material that passes through the Primary crusher,
Primary 282,900 ton/yr 15% passes through a second time.
50% of clinker entering Finish Plant is screened off
naturally while the other 50% passes through the El Jay
El Jay cone crusher. Of the material that passes through the El Jay
crusher 133,975 ton/yr crusher, 15% passes through a second time.
Grizzly
oversize pile 1,167 ton/yr 5 tons per 12 hour shift on average.

9.0 Fugitive Dust Emission Calculations
The estimated fugitive dust emission calculations are conservative estimates and are not absolute values.
Furthermore, separate emission estimates for PM-10-particulate matter were not performed, as controls
for total suspended particulate matter (TSP) are generally effective in reducing PM-10 emissions as well.
The following table summarizes estimated emissions from each emission source at the Norlite facility.

Table 11. Fugitive Dust Emissions Estimate
Overall Emission Emission

Source Production Control Factor, Factor, Emission
ID Source Description Rate Units Control Methods Efficiency Calculated AP-42 EF Units Rate, tpy
QA1 Drilling 246,000 tpy Water suppression, mist 50% -- 8.00E-05 lb/ton 0.00492
QA2 Blasting 246,000 tpy None 0% -- 8.00E-02 lb/ton 9.84000
QA3 Quarried stone pile 246,000 tpy Water suppression 50% 5.10E-03 4.00E-02 lb/ton 0.31336
QA4 Load stone into truck 246,000 tpy None 0% 5.10E-03 2.37E-03 lb/ton 0.62671
QA5 Overburden stripping 161,000 cu yd/yr None 0% 3.48E-02 6.00E-02 lb/yd3 2.80154
QA6 Load overburden into truck 206,265 tpy None 0% 7.69E-05 3.70E-02 lb/ton 0.00793
PR1 Loading onto shot rock pile (Canal) 246,000 tpy None 0% 5.10E-03 -- -- 0.62671
PR2 Shot rock pile (Canal) 246,000 tpy None 0% 1.05E-04 -- -- 0.00000
PR3 Unloading shot rock pile 246,000 tpy None 0% 5.10E-03 -- -- 0.62671
PR4 Loading onto shale stockpile 246,000 tpy Water suppression 20% 5.10E-03 3.00E-03 lb/ton 0.50137
PR5 Shale stockpile 246,000 tpy Water suppression 50% 2.10E-01 -- -- 0.00264
PR6 Unloading shale stockpile 246,000 tpy None 0% 5.10E-03 -- -- 0.62671
PR7 Drop point, raw shale drop to jaw crusher 282,900 tpy None 0% 5.10E-03 3.00E-03 lb/ton 0.72072
PR8 Jaw crusher 282,900 tpy Partially enclosed 75% -- 2.80E-01 lb/ton 9.90150
PR9 Drop point, jaw crusher to crusher belt 282,900 tpy Enclosed 90% 5.10E-03 3.00E-03 lb/ton 0.07207
PR10 Crusher belt 282,900 tpy None 0% -- 3.00E-03 lb/ton per 300 ft 0.02166
PR11 Drop point, crusher belt to screen belt 282,900 tpy Enclosed 90% 5.10E-03 3.00E-03 lb/ton 0.07207
PR12 Screen belt 282,900 tpy None 0% -- 3.00E-03 lb/ton per 300 ft 0.02829
PR13 Drop point, screen belt to primary double deck screen 282,900 tpy None 0% 5.10E-03 3.00E-03 lb/ton 0.72072
PR14 Primary double deck screen 282,900 tpy Water suppression, spray bar; Partially enclosed 85% -- 2.20E-03 lb/ton 0.04668
PR15 Drop point, primary double deck screen to primary cone crusher 282,900 tpy Enclosed 0% 5.10E-03 3.00E-03 lb/ton 0.72072
PR16 Primary cone crusher 282,900 tpy Partially enclosed 50% -- 3.00E-03 lb/ton 0.21218
PR17 Drop point, primary cone crusher to primary double deck screen 282,900 tpy None 0% 5.10E-03 -- -- 0.72072
PR18 Drop point, primary double deck screen to shale conveyor 282,900 tpy Enclosed 90% 5.10E-03 3.00E-03 lb/ton 0.07207
PR19 Shale conveyor 233,000 tpy None 0% -- 3.00E-03 lb/ton per 300 ft 0.06191
PR20 Drop point, shale conveyor to kiln feed pile 233,000 tpy None 0% 5.10E-03 3.00E-03 lb/ton 0.59360



PR21 Kiln feed pile 233,000 tpy None 0% 2.10E-01 -- -- 0.00332
PR22 Drop point, double deck screen to shale fines conveyor 13,000 tpy Enclosed 90% 5.10E-03 3.00E-03 lb/ton 0.00331
PR23 Shale fines conveyor 13,000 tpy None 0% -- 3.00E-03 lb/ton per 300 ft 0.00255
PR24 Drop point, shale fines conveyor to shale fines pile 13,000 tpy None 0% 7.32E-04 3.00E-03 lb/ton 0.00476
PR25 Shale fines pile 13,000 tpy Low pile height/wetted material 20% 1.68E-01 -- -- 0.00088
PR26 Loading from shale fines pile to trucks 13,000 tpy None 0% 7.32E-04 3.00E-03 lb/ton 0.00476
KF1 Drop point, shale pile to #4 conveyor 116,500 tpy Enclosed 99% 5.10E-03 3.00E-03 lb/ton 0.00297
KF2 Drop point, loader to #4 conveyor 116,500 tpy None 0% 5.10E-03 -- -- 0.29680
KF3 #4 conveyor 233,000 tpy Partially underground; Dust cover; Water suppression, spray 85% -- 3.00E-03 lb/ton per 300 ft 0.01419
bar
KF4 Drop point, #4 conveyor to #5 conveyor 233,000 tpy Enclosed 90% 5.10E-03 3.00E-03 lb/ton 0.05936
KF5 #5 conveyor 233,000 tpy Dust cover 70% -- 3.00E-03 lb/ton per 300 ft 0.04349
KF6 Drop point, #5 conveyor to shale storage pile 233,000 tpy Enclosed 97% 5.10E-03 3.00E-03 lb/ton 0.01781
KF7 Kiln feed storage pile 233,000 tpy Partially enclosed; Low pile height 90% 2.10E-01 -- -- 0.00034
KF8 Drop point, shale storage pile to kiln 1 feeder belt 121,000 tpy Underground 99% 5.10E-03 3.00E-03 lb/ton 0.00308
KF9 Kiln 1 feeder belt 121,000 tpy Underground 90% -- 3.00E-03 lb/ton per 300 ft 0.00149
KF10 Drop point, kiln 1 feeder belt to kiln 1 lower belt 121,000 tpy Enclosed 80% 5.10E-03 3.00E-03 lb/ton 0.06165
KF11 Kiln 1 lower belt 121,000 tpy Dust cover; Partially underground; Meat locker curtain 70% -- 3.00E-03 lb/ton per 300 ft 0.01104
KF12 Drop point, kiln 1 lower belt to kiln 1 top belt 121,000 tpy Enclosed 80% 5.10E-03 3.00E-03 lb/ton 0.06165
KF13 Kiln 1 top belt 121,000 tpy Dust cover 70% -- 3.00E-03 lb/ton per 300 ft 0.00381
KF14 Drop point, kiln 1 top belt to kiln 1 feed 121,000 tpy Chute 90% 5.10E-03 3.00E-03 lb/ton 0.03083
KF15 Kiln 1 feed (AccuRate feeder) 121,000 tpy Dust cover 0% 5.10E-03 3.00E-03 lb/ton 0.30826
KF16 Kiln 1 rear chamber system (rim seal) 121,000 tpy Dust cover 99% -- 8.40E-01 lb/ton 0.50820
KF17 Kiln 1 front seal 121,000 tpy Vacuum 99% -- 8.40E-01 lb/ton 0.50820
KF18 Drop point, shale storage pile to kiln 2 feeder belt 112,000 tpy Underground 99% 5.10E-03 3.00E-03 lb/ton 0.00285
KF19 Kiln 2 feeder belt 112,000 tpy Underground 90% -- 3.00E-03 lb/ton per 300 ft 0.00138



KF20 Drop point, kiln 2 feeder belt to kiln 2 lower belt 112,000 tpy Enclosed 90% 5.10E-03 3.00E-03 lb/ton 0.02853
KF21 Kiln 2 lower belt 112,000 tpy Dust cover; Partially underground; Meat locker curtain 70% -- 3.00E-03 lb/ton per 300 ft 0.01065
KF22 Drop point, kiln 2 lower belt to kiln 2 middle belt 112,000 tpy Chute 80% 5.10E-03 3.00E-03 lb/ton 0.05707
KF23 Kiln 2 middle belt 112,000 tpy Dust cover 70% -- 3.00E-03 lb/ton per 300 ft 0.00449
KF24 Drop point, kiln 2 middle belt to kiln 2 top belt 112,000 tpy Chute 80% 5.10E-03 3.00E-03 lb/ton 0.05707
KF25 Kiln 2 top belt 112,000 tpy Dust cover 70% -- 3.00E-03 lb/ton per 300 ft 0.00564
KF26 Drop point, kiln 2 top belt to kiln 2 feed 112,000 tpy Chute 80% 5.10E-03 3.00E-03 lb/ton 0.05707
KF27 Kiln 2 feed (AccuRate feeder) 112,000 tpy Dust cover 0% 5.10E-03 3.00E-03 lb/ton 0.28533
KF28 Kiln 2 rear chamber system (rim seal) 112,000 tpy Dust cover 99% -- 8.40E-01 lb/ton 0.47040
KF29 Kiln 2 front seal 112,000 tpy Vacuum 99% -- 8.40E-01 lb/ton 0.47040
KF30 Opening of kiln rim seals for cleaning 438 tpy None 0% -- 3.00E-03 lb/ton 0.00066
KF31 Removal of bag house plug (vacuum truck unloading) 338 tpy Water suppression; Baghouse 0% -- 3.00E-03 lb/ton 0.00051
KL1 Drop point, kiln 1 to kiln 1 clinker cooler 121,000 tpy Enclosed 99% -- 3.00E-03 lb/ton 0.00182
KL2 Kiln 1 clinker cooler 121,000 tpy Enclosed 90% -- 3.00E-01 lb/ton 1.81500
KL3 Drop point, kiln 1 clinker cooler to kiln 1 clinker belt 121,000 tpy Partially enclosed 80% -- 3.00E-03 lb/ton 0.03630
KL4 Kiln 1 clinker belt 121,000 tpy Partially underground; Dust cover; Water suppression, as 70% -- 3.00E-03 lb/ton per 300 ft 0.02122
needed
KL5 Drop point, kiln 1 clinker belt to kiln 1 clinker pile 121,000 tpy Water suppression 50% 1.34E-02 3.00E-03 lb/ton 0.40675
KL6 Kiln 1 clinker pile 121,000 tpy Water suppression 50% 2.78E+00 -- -- 0.01549
KL7 Drop point, kiln 2 to kiln 2 clinker cooler 112,000 tpy Enclosed 99% -- 3.00E-03 lb/ton 0.00168
KL8 Kiln 2 clinker cooler 112,000 tpy Enclosed 90% -- 3.00E-01 lb/ton 1.68000
KL9 Drop point, kiln 2 clinker cooler to kiln 2 clinker belt 112,000 tpy Partially enclosed 80% -- 3.00E-03 lb/ton 0.03360
KL10 Kiln 2 clinker belt 112,000 tpy Partially underground; Dust cover; Water suppression, as 70% -- 3.00E-03 lb/ton per 300 ft 0.01895
needed
KL11 Drop point, kiln 2 clinker belt to kiln 2 clinker pile 112,000 tpy Water suppression, mist 50% 1.34E-02 3.00E-03 lb/ton 0.37650



KL12 Kiln 2 clinker pile 112,000 tpy Water suppression, mist 50% 2.78E+00 -- -- 0.01549
KL13 Transfer kiln 2 clinker pile to kiln 1 clinker pile 112,000 tpy Loader Operator Protocol 0% 1.34E-02 3.00E-03 lb/ton 0.75300
KL14 Muck pile 8,160 tpy Moisture; Pile shaping; Compaction 50% 8.42E+01 -- -- 1.05615
KL15 Loading onto muck pile 8,160 tpy None 0% 1.15E-04 -- -- 0.00047
KL16 Unloading muck pile 8,160 tpy None 0% 1.15E-04 -- -- 0.00047
FP1 Drop point, kiln 1 clinker pile to transfer to #1 conveyor 233,000 tpy Underground 90% -- 3.00E-03 lb/ton 0.03495
FP2 #1 conveyor 233,000 tpy Dust cover; Partially underground 70% -- 3.00E-03 lb/ton per 300 ft 0.01599
FP3 Drop point, #1 conveyor to grizzly 233,000 tpy None 80% 1.34E-02 3.00E-03 lb/ton 0.31330
FP4 Grizzly on lightweight aggregate feed platform 233,000 tpy Partially enclosed 70% 1.34E-02 3.00E-03 lb/ton 0.46995
FP5 Drop point, grizzly to grizzly pile 233,000 tpy None 0% 1.34E-02 3.00E-03 lb/ton 1.56651
FP6 Grizzly reject pile 1,167 tpy None 0% 2.78E+00 -- -- 0.00510
FP7 Drop point, grizzly to #2 conveyor 233,000 tpy Enclosed 90% 1.34E-02 3.00E-03 lb/ton 0.15665
FP8 #2 conveyor 233,000 tpy Dust cover 70% -- 3.00E-03 lb/ton per 300 ft 0.03155
FP9 Drop point, #2 conveyor to triple deck finish mill screen 233,000 tpy Enclosed 90% 1.34E-02 3.00E-03 lb/ton 0.15665
FP10 Triple deck finish mill screen 233,000 tpy Baghouse 0% -- 2.20E-03 lb/ton 0.25630
FP11 Drop point, triple deck finish mill screen to 3/4" discharge conveyor 69,000 tpy Enclosed 90% 3.73E-03 3.00E-03 lb/ton 0.01286
FP12 3/4" discharge conveyor 69,000 tpy Dust cover; Baghouse 70% -- 3.00E-03 lb/ton per 300 ft 0.00647
FP13 Drop point, 3/4" discharge conveyor to 3/4" to stockpile conveyor 69,000 tpy Enclosed 80% 3.73E-03 3.00E-03 lb/ton 0.02572
FP14 3/4" to stockpile conveyor 69,000 tpy Dust cover 70% -- 3.00E-03 lb/ton per 300 ft 0.01273
FP15 Drop point, 3/4" to stockpile conveyor to 3/4" short term storage pile 69,000 tpy Tube; Water suppression 95% 3.73E-03 3.00E-03 lb/ton 0.00643
FP16 3/4" short term storage pile 98,185 tpy Water suppression 50% 1.14E+00 -- -- 0.00449
FP17 Drop point, triple deck finish mill screen to 3/8" discharge conveyor 46,000 tpy Enclosed 80% 3.73E-03 3.00E-03 lb/ton 0.01715
FP18 3/8" discharge conveyor 46,000 tpy Dust cover; Baghouse 70% -- 3.00E-03 lb/ton per 300 ft 0.00289



FP19 Drop point, 3/8" discharge conveyor to 3/8" to stockpile conveyor 46,000 tpy Enclosed 0% 3.73E-03 3.00E-03 lb/ton 0.08575
FP20 3/8" to stockpile conveyor 46,000 tpy Dust cover 70% -- 3.00E-03 lb/ton per 300 ft 0.00660
FP21 Drop point, 3/8" stockpile conveyor to 3/8" short term storage pile 46,000 tpy Water suppression, spray head 50% 3.73E-03 3.00E-03 lb/ton 0.04287
FP22 3/8" short term storage pile 25,550 tpy Water suppression, spray head 70% 1.24E+00 -- -- 0.05191
FP23 Drop point, triple deck finish mill screen to oversize discharge conveyor 133,975 tpy Enclosed 90% 1.34E-02 3.00E-03 lb/ton 0.09007
FP24 Oversize discharge conveyor 133,975 tpy Partially covered; Baghouse 70% -- 3.00E-03 lb/ton per 300 ft 0.01122
FP25 Drop point, oversize discharge conveyor to oversize hopper 133,975 tpy None 0% 1.34E-02 3.00E-03 lb/ton 0.90074
FP26 Oversize hopper 133,975 tpy None 0% -- 3.00E-03 lb/ton 0.20096
FP27 Drop point, oversize hopper to El Jay crusher speed conveyor 133,975 tpy Partially enclosed 70% 1.34E-02 3.00E-03 lb/ton 0.27022
FP28 El Jay crusher speed conveyor 133,975 tpy Dust cover 70% -- 3.00E-03 lb/ton per 300 ft 0.01151
FP29 Drop point, El Jay crusher speed conveyor to El Jay crusher 133,975 tpy Enclosed 90% 1.34E-02 3.00E-03 lb/ton 0.09007
FP30 El Jay crusher 133,975 tpy Baghouse 90% -- 2.50E-02 lb/ton 0.16747
FP31 Drop point, El Jay crusher to El Jay discharge conveyor 133,975 tpy Enclosed 90% 1.34E-02 3.00E-03 lb/ton 0.09007
FP32 El Jay discharge conveyor 133,975 tpy None 0% -- 3.00E-03 lb/ton per 300 ft 0.00804
FP33 Drop point, El Jay discharge conveyor to #2 return conveyor 133,975 tpy Enclosed 80% 1.34E-02 3.00E-03 lb/ton 0.18015
FP34 #2 return conveyor 133,975 tpy Dust cover 70% -- 3.00E-03 lb/ton per 300 ft 0.01398
FP35 Drop point, #2 return conveyor to #2 conveyor 133,975 tpy Enclosed 80% 1.34E-02 3.00E-03 lb/ton 0.18015
FP36 Drop point, triple deck finish mill screen to fines to silo conveyor 28,000 tpy Enclosed 90% 3.73E-03 3.00E-03 lb/ton 0.00522
FP37 Fines to silo conveyor 28,000 tpy Dust cover; Baghouse 70% -- 3.00E-03 lb/ton per 300 ft 0.00840
FP38 Drop point, fines to silo conveyor to enclosed fines storage pile 85,000 tpy Chute 94% 3.73E-03 3.00E-03 lb/ton 0.00951
FP39 Enclosed fines storage pile 85,000 tpy Roof; Concrete enclosure at bottom; Tarps 80% 5.85E+00 -- -- 0.03001
FP40 Open fines storage pile 85,000 tpy Enclosed; Concrete wall to south; Wind screen 80% 5.85E+00 -- -- 0.00981
FP41 Baghouse dust silo 1 85,000 tpy Enclosed 97% 7.83E+00 9.90E-03 lb/ton 0.00153



FP42 Drop point, baghouse dust silo 1 to shipping belt 85,000 tpy Enclosed 99% 3.73E-03 3.00E-03 lb/ton 0.00158
FP43 Baghouse dust silo 2 85,000 tpy Enclosed 97% 7.83E+00 9.90E-03 lb/ton 0.00153
FP44 Drop point, baghouse dust silo 2 to shipping belt 85,000 tpy Enclosed 99% 3.73E-03 3.00E-03 lb/ton 0.00158
FP45 Shipping belt 27,094 tpy Partially underground; Dust cover 90% -- 3.00E-03 lb/ton per 300 ft 0.00102
FP46 Drop point, shipping belt to stationary belt 27,094 tpy Enclosed 90% 3.73E-03 3.00E-03 lb/ton 0.00505
FP47 Stationary belt 27,094 tpy Dust cover; Baghouse; Improved maintenance 70% -- 3.00E-03 lb/ton per 300 ft 0.00369
FP48 Drop point, stationary belt to radial stacker 27,094 tpy Enclosed 90% 3.73E-03 3.00E-03 lb/ton 0.00505
FP49 Radial stacker 27,094 tpy Dust cover; Spray head adjustment 70% -- 3.00E-03 lb/ton per 300 ft 0.00301
FP50 Drop point, radial stacker to block mix short term storage pile 1 27,094 tpy Baghouse; Water suppression; Adjustable discharge height 99% 3.73E-03 3.00E-03 lb/ton 0.00063
FP51 Block mix short term storage pile 1 15,133 tpy Low pile height/bldg 20% 7.83E+00 -- -- 0.07249
FP53 Block mix short term storage pile 3 2,147 tpy Low pile height/small pile/bldg 50% 7.83E+00 -- -- 0.03096
FP55 Block mix short term storage pile 5 33,788 tpy Low pile height 20% 7.83E+00 -- -- 0.27841
FP56 Block mix short term storage pile 6 2,550 tpy Low pile height/small pile 50% 7.83E+00 -- -- 0.05963
FP57 3/4" long term storage pile 5 37,531 tpy Low pile height 20% 1.14E+00 -- -- 0.01717
FP58 Loading 3/4" onto trucks 69,000 tpy Loader Operator Protocol 0% 8.01E-04 3.00E-03 lb/ton 0.02763
FP59 Loading 3/8" onto trucks 46,000 tpy Loader Operator Protocol 0% 8.01E-04 3.00E-03 lb/ton 0.01842
FP60 Loading clinker onto trucks 233,000 tpy Loader Operator Protocol 0% 1.41E-03 3.00E-03 lb/ton 0.16458
FP61 Loading block mix onto piles 92,000 tpy Loader Operator Protocol 0% 8.01E-04 3.00E-03 lb/ton 0.03684
FP62 Loading block mix onto trucks 92,000 tpy Loader Operator Protocol 0% 8.01E-04 3.00E-03 lb/ton 0.03684
FN1 8 X 0 long term storage pile 27,094 tpy Enclosed 85% 7.83E+00 -- -- 0.02218
FN2 4 X 0 fines feed pile 66,839 tpy Low pile height 20% 5.85E+00 -- -- 0.01975



FN3 Loading of block mix into Cedarapids feed hopper (surge bin) 66,839 tpy None 0% 3.73E-03 3.00E-03 lb/ton 0.12459
FN4 Cedarapids feed hopper (surge bin) 66,839 tpy None 0% -- 3.00E-03 lb/ton 0.10026
FN5 Drop point, Cedarapids feed hopper to feeder belt 66,839 tpy None 0% 3.73E-03 3.00E-03 lb/ton 0.12459
FN6 Feeder belt 66,839 tpy None 0% -- 3.00E-03 lb/ton per 300 ft 0.01702
FN7 Drop point, feeder belt to screen feed belt 66,839 tpy None 0% 3.73E-03 3.00E-03 lb/ton 0.12459
FN8 Screen feed belt 66,839 tpy None 0% -- 3.00E-03 lb/ton per 300 ft 0.01154
FN9 Drop point, screen feed belt to Astec 2618 fines screen 66,839 tpy None 0% 3.73E-03 3.00E-03 lb/ton 0.12459
FN10 Astec 2618 fines screen 66,839 tpy None 0% -- 2.00E-03 lb/ton 0.06684
FN11 Drop point, fines screen to #4s belt 66,839 tpy None 0% 3.73E-03 3.00E-03 lb/ton 0.12459
FN12 #4s belt 66,839 tpy None 0% -- 3.00E-03 lb/ton per 300 ft 0.01421
FN13 Drop point, #4s belt to 4 mesh reject pile 66,839 tpy None 0% 3.73E-03 3.00E-03 lb/ton 0.12459
FN14 4 mesh reject pile 27,094 tpy Low pile height 20% 5.85E+00 -- -- 0.01975
FN15 Drop point, fines screen to fines #8s belt 27,094 tpy None 0% 3.73E-03 3.00E-03 lb/ton 0.05050
FN16 #8s belt 27,094 tpy None 0% -- 3.00E-03 lb/ton per 300 ft 0.00580
FN17 Drop point, #8s belt to fines 8 X 0 pile 27,094 tpy None 0% 3.73E-03 3.00E-03 lb/ton 0.05050
FN18 8 X 0 pile 27,094 tpy Low pile height 20% 7.53E+00 -- -- 0.02543
FN19 3/4" long term storage pile 6 9,847 tpy Low pile height 20% 1.14E+00 -- -- 0.00384
FN20 Loading screened fines onto trucks (8 X 0, 4 X 0, 4 mesh reject) 27,094 tpy Loader Operator Protocol 0% 8.01E-04 3.00E-03 lb/ton 0.01085
BM1 Block mix long term storage pile 1 8,376 tpy None 0% 7.83E+00 -- -- 0.25272
BM2 Block mix long term storage pile 2 8,376 tpy Low pile height 20% 7.83E+00 -- -- 0.01598
BM5 Loading block mix into portable screen 89,118 tpy Loader Operator Protocol 0% 8.01E-04 3.00E-03 lb/ton 0.03568
BM6 Astec 710T 44,559 tpy None 0% -- 2.00E-03 lb/ton 0.04456
BM7 Reade screen 44,559 tpy None 0% -- 2.00E-03 lb/ton 0.04456



BM8 Loading onto temporary block mix pile 89,118 tpy Loader Operator Protocol 0% 8.01E-04 3.00E-03 lb/ton 0.03568
BM9 Temporary block mix pile for customer pickup 89,118 tpy Low pile height 20% 7.83E+00 -- -- 0.04084
BM10 Loading block mix onto trucks 89,118 tpy Loader Operator Protocol 0% 8.01E-04 3.00E-03 lb/ton 0.03568
BM11 Loading onto block mix pile 89,118 tpy None 0% 8.01E-04 3.00E-03 lb/ton 0.03568
IS1 3/4" long term storage pile 1 2,840 tpy Low pile height 20% 1.14E+00 -- -- 0.00719
IS5 3/8" long term storage pile 45,642 tpy Low pile height 20% 1.24E+00 -- -- 0.01876
IS6 Block mix long term storage pile 5 2,147 tpy Low pile height 20% 7.83E+00 -- -- 0.02643
IS7 Loading onto 3/4" pile 69,000 tpy None 0% 8.01E-04 3.00E-03 lb/ton 0.02763
IS8 Loading 3/4" onto trucks 69,000 tpy Loader Operator Protocol 0% 8.01E-04 3.00E-03 lb/ton 0.02763
IS9 Loading onto 3/8" pile 46,000 tpy None 0% 8.01E-04 3.00E-03 lb/ton 0.01842
IS10 Loading 3/8" onto trucks 46,000 tpy Loader Operator Protocol 0% 8.01E-04 3.00E-03 lb/ton 0.01842
BY1 Boneyard shale pile 1 9,446 tpy None 0% 1.68E-01 -- -- 0.00410
BY2 Boneyard shale pile 2 9,446 tpy None 0% 1.68E-01 -- -- 0.00410
BY3 Loading shale fines onto boneyard shale piles 9,446 tpy None 0% 7.32E-04 3.00E-03 lb/ton 0.00346
BY4 Loading boneyard shale piles onto trucks 9,446 tpy Loader Operator Protocol 0% 7.32E-04 3.00E-03 lb/ton 0.00346
OS1 Bulldozing 206,265 tpy None 0% 6.56E+00 3.00E-03 lb/ton 2.88506
OS2 Receiving overburden from quarry 206,265 tpy None 0% 7.69E-05 2.00E-03 lb/ton 0.00793
OS3 Wind erosion in overburden storage area -- -- None 0% -- 3.80E-01 ton/acre-year 1.90000
RD1 Transport of stone from quarry to primary 15,504 mi Water 50% 5.68E-01 6.20E+00 lb/mi 2.20290
RD2 Transfer of overburden from quarry to overburden storage area 15,875 mi Water 50% 5.68E-01 6.20E+00 lb/mi 2.25566
RD3 Transport of shales fines to boneyard 1,043 mi Water 50% 5.68E-01 6.20E+00 lb/mi 0.14819
RD4 Transport of product off-site by truck 7,992 mi Water 50% 5.53E-01 6.20E+00 lb/mi 1.10499
RD5 Travel of LGF delivery trucks 550 mi Water 50% 5.53E-01 6.20E+00 lb/mi 0.07598



RD6 Maintenance traffic 2,914 mi Water 50% 2.96E-01 6.20E+00 lb/mi 0.21589
RD7 Passenger vehicle traffic 5,952 mi Water 50% 9.69E-01 -- -- 1.44230
RD8 Transport of shale fines to overburden storage area 1,427 mi Water 50% 5.68E-01 6.20E+00 lb/mi 0.20276
RD9 Water truck movement 3,686 mi Water 50% 3.58E-01 6.20E+00 lb/mi 0.32983
RD10 On-site product movement via front end loader 4,493 mi Water 50% 3.22E-01 6.20E+00 lb/mi 0.36139
Total 61.40307


10.0 Discussion
The calculations shown in Table 11 are based on the most recent emission factors provided in AP-42 or
WebFIRE, the EPA’s online emission factor database, or calculated from the latest appropriate versions
of emission factor estimation equations. The total estimated potential fugitive dust emissions from the
Norlite facility are on the order of 61 tons/year. Actual fugitive dust emissions are likely less than this
estimate for the following reasons:
 Material silt content was estimated based on both 100 and 200 sieve data for each product;
 General EPA AP-42 factors were used for several sources, which provide inherently conservative
emission estimates;
 Re-processed material was included each time it went through a particular process without
reduction in estimated silt content; and
 Conservatively low control factors were used for covered conveyors and low stockpile height.
Areas within the Norlite facility that contribute the largest amount of potential fugitive dust emissions are:
 Quarry Blasting;
 Primary Jaw Crushing;
 Southern Overburden Storage Area earthwork and transport of material;
 Movements along internal roadways;
 Material drop points associated with the clinkers; and
 Wind erosion off select areas, including the Southern Overburden Storage Area and muck
pile.
Quarry blasting emissions have a conservatively high estimate because the calculation is based on an AP-
42 emission factor, which provides consistently high emission estimates when applied in an aggregate
setting. Potential dust emissions, as estimated, are not a significant concern due to the location of the
quarry excavation relative to the facility property line and thick vegetative buffer surrounding the active
blasting area.
Primary jaw crushing and fines screening represent a significant fraction of the calculated potential
fugitive dust emissions at the Norlite facility. Potential dust emissions, as estimated for these sources, are
not of significant concern due to the location of the primary area relative to the facility property line, and
the conservative particle size range used to generate the emissions estimate. A vast majority of the
potential fugitive dust generated from the primary and screens settles within the quarry and facility
itself. These estimates, however, can be reduced by improved water spray application and/or wind
screens in both areas.

Excavation and transportation of overburden in the quarry, transportation of overburden to the Southern
Overburden Storage Area, and mobile equipment moving along internal roadways is another major source
of potential fugitive dust. Continued watering with on-site water trucks effectively manages this potential
source of fugitive dust. As with the discussions above, potential dust emissions, as estimated, are not of
significant concern due to the location of the roadways relative to the facility property line. AP-42,
Chapter 13, specifically discusses fugitive dust from unpaved surfaces and clearly states that dust from
these sources settles in the vicinity of the source itself.
Wind erosion from material drop points and open stockpiles represent the last of the major potential
fugitive dust sources. Continued use of water control devices, conveyor covers, low pile height, and good
housekeeping practices can effectively manage these potential sources of fugitive dust.
The following table (Table 12) identifies each control device for each identified emission source across
Norlite’s facility along with a statement of the functionality of each control device. The table also
identifies when or where additional controls may be useful in reducing potential fugitive dust emissions.

Table 12. Evaluation of Existing Controls
Source Not Effective Modifications Controls

ID Source Description Control Methods Control Condition Warranted As Is Needed Needed
QA1 Drilling Water suppression, mist Functional X
QA2 Blasting None None X
QA3 Quarried stone pile Water suppression Functional X
QA4 Load stone into truck None None X
QA5 Overburden stripping None None X
QA6 Load overburden into truck None None X
PR1 Loading onto shot rock pile (Canal) None None X
PR2 Shot rock pile (Canal) None None X
PR3 Unloading shot rock pile None None X
PR4 Loading onto shale stockpile Water suppression Functional X
PR5 Shale stockpile Water suppression Functional X
PR6 Unloading shale stockpile None None X
PR7 Drop point, raw shale drop to jaw crusher None None X
PR8 Jaw crusher Partially enclosed Functional X X
PR9 Drop point, jaw crusher to crusher belt Enclosed Functional X
PR10 Crusher belt None None X
PR11 Drop point, crusher belt to screen belt Enclosed Functional X
PR12 Screen belt None None X
PR13 Drop point, screen belt to primary double deck screen None None X
PR14 Primary double deck screen Water suppression, spray bar; Partially enclosed Functional; Functional X
PR15 Drop point, primary double deck screen to primary cone crusher Enclosed Functional X
PR16 Primary cone crusher Partially enclosed Functional X X
PR17 Drop point, primary cone crusher to primary double deck screen None None X
PR18 Drop point, primary double deck screen to shale conveyor Enclosed Functional X
PR19 Shale conveyor None None X
PR20 Drop point, shale conveyor to kiln feed pile None None X
PR21 Kiln feed pile None None X
PR22 Drop point, double deck screen to shale fines conveyor Enclosed Functional X
PR23 Shale fines conveyor None None X
PR24 Drop point, shale fines conveyor to shale fines pile None None X
PR25 Shale fines pile Low pile height/wetted material Functional X
PR26 Loading from shale fines pile to trucks None None X
KF1 Drop point, shale pile to #4 conveyor Enclosed Functional X
KF2 Drop point, loader to #4 conveyor None None X
KF3 #4 conveyor Partially underground; Dust cover; Water suppression, spray bar Functional; Functional; Functional X
KF4 Drop point, #4 conveyor to #5 conveyor Enclosed Functional X
KF5 #5 conveyor Dust cover Functional X
KF6 Drop point, #5 conveyor to shale storage pile Enclosed Functional X


KF7 Kiln feed storage pile Partially enclosed; Low pile height Functional; Functional X
KF8 Drop point, shale storage pile to kiln 1 feeder belt Underground Functional X
KF9 Kiln 1 feeder belt Underground Functional X
KF10 Drop point, kiln 1 feeder belt to kiln 1 lower belt Enclosed Functional X
KF11 Kiln 1 lower belt Dust cover; Partially underground; Meat locker curtain Functional; Functional; Functional X
KF12 Drop point, kiln 1 lower belt to kiln 1 top belt Enclosed Functional X
KF13 Kiln 1 top belt Dust cover Functional X
KF14 Drop point, kiln 1 top belt to kiln 1 feed Chute Functional X
KF15 Kiln 1 feed (AccuRate feeder) Dust cover Functional X
KF16 Kiln 1 rear chamber system (rim seal) Vacuum annular space Functional X
KF17 Kiln 1 front seal Vacuum Functional X
KF18 Drop point, shale storage pile to kiln 2 feeder belt Underground Functional X
KF19 Kiln 2 feeder belt Underground Functional X
KF20 Drop point, kiln 2 feeder belt to kiln 2 lower belt Enclosed Functional X
KF21 Kiln 2 lower belt Dust cover; Partially underground; Meat locker curtain Functional; Functional; Functional X
KF22 Drop point, kiln 2 lower belt to kiln 2 middle belt Chute Functional X
KF23 Kiln 2 middle belt Dust cover Functional X
KF24 Drop point, kiln 2 middle belt to kiln 2 top belt Chute Functional X
KF25 Kiln 2 top belt Dust cover Functional X
KF26 Drop point, kiln 2 top belt to kiln 2 feed Chute Functional X
KF27 Kiln 2 feed (AccuRate feeder) Dust cover Functional; Functional X
KF28 Kiln 2 rear chamber system (rim seal) Vacuum annular space Functional X
KF29 Kiln 2 front seal Vacuum Functional X
KF30 Opening of kiln rim seals for cleaning None None X X
KF31 Removal of bag house plug (vacuum truck unloading) Water suppression; Baghouse Functional; Functional X
KL1 Drop point, kiln 1 to kiln 1 clinker cooler Enclosed Functional X
KL2 Kiln 1 clinker cooler Enclosed Functional X
KL3 Drop point, kiln 1 clinker cooler to kiln 1 clinker belt Partially enclosed Functional X
Partially underground; Dust cover; Water suppression, as
KL4 Kiln 1 clinker belt needed Functional; Functional; Functional X
KL5 Drop point, kiln 1 clinker belt to kiln 1 clinker pile Water suppression Not functional X
KL6 Kiln 1 clinker pile Water suppression Partially functional X
KL7 Drop point, kiln 2 to kiln 2 clinker cooler None None X
KL8 Kiln 2 clinker cooler Enclosed Functional X
KL9 Drop point, kiln 2 clinker cooler to kiln 2 clinker belt Partially enclosed Functional X
Partially underground; Dust cover; Water suppression, as
KL10 Kiln 2 clinker belt needed Functional; Functional; Functional X
KL11 Drop point, kiln 2 clinker belt to kiln 2 clinker pile Water suppression, mist Not functional X
KL12 Kiln 2 clinker pile Water suppression, mist Partially functional X
KL13 Transfer kiln 2 clinker pile to kiln 1 clinker pile Loader operator protocol Functional X


KL14 Muck pile Moisture/Pile shaping/Compaction Functional; Functional; Functional X
KL15 Loading onto muck pile None None X
KL16 Unloading muck pile None None X
FP1 Drop point, kiln 1 clinker pile to transfer to #1 conveyor Underground Functional X
FP2 #1 conveyor Dust cover; Partially underground Functional; Functional X
FP3 Drop point, #1 conveyor to grizzly None None X
FP4 Grizzly on lightweight aggregate feed platform Partially enclosed Functional X
FP5 Drop point, grizzly to grizzly pile None None X
FP6 Grizzly reject pile None None X
FP7 Drop point, grizzly to #2 conveyor Enclosed Functional X
FP8 #2 conveyor Dust cover Functional X
FP9 Drop point, #2 conveyor to triple deck finish mill screen Enclosed Functional X
FP10 Triple deck finish mill screen Baghouse Not functional X
FP11 Drop point, triple deck finish mill screen to 3/4" discharge conveyor Enclosed Functional X
FP12 3/4" discharge conveyor Dust cover; Baghouse Functional; Not functional X
FP13 Drop point, 3/4" discharge conveyor to 3/4" to stockpile conveyor Enclosed Functional X
FP14 3/4" to stockpile conveyor Dust cover Functional X
FP15 Drop point, 3/4" to stockpile conveyor to 3/4" short term storage pile Tube; Water suppression Functional; Functional X
FP16 3/4" short term storage pile Water suppression Functional X
FP17 Drop point, triple deck finish mill screen to 3/8" discharge conveyor Enclosed Functional X
FP18 3/8" discharge conveyor Dust cover; Baghouse Functional; Not functional X
FP19 Drop point, 3/8" discharge conveyor to 3/8" to stockpile conveyor Enclosed Functional X
FP20 3/8" to stockpile conveyor Dust cover Functional X
FP21 Drop point, 3/8" stockpile conveyor to 3/8" short term storage pile Water suppression, spray head Functional X
FP22 3/8" short term storage pile Water suppression, spray head Functional X
FP23 Drop point, triple deck finish mill screen to oversize discharge conveyor Enclosed Functional X
FP24 Oversize discharge conveyor Partially covered; Baghouse Functional; Not functional X
FP25 Drop point, oversize discharge conveyor to oversize hopper None None X
FP26 Oversize hopper None None X
FP27 Drop point, oversize hopper to El Jay crusher speed conveyor Partially enclosed Functional X
FP28 El Jay crusher speed conveyor Dust cover Functional X
FP29 Drop point, El Jay crusher speed conveyor to El Jay crusher Enclosed Functional X
FP30 El Jay crusher Baghouse Not functional X
FP31 Drop point, El Jay crusher to El Jay discharge conveyor Enclosed Functional X
FP32 El Jay discharge conveyor None None X
FP33 Drop point, El Jay discharge conveyor to #2 return conveyor Enclosed Functional X
FP34 #2 return conveyor Dust cover Functional X
FP35 Drop point, #2 return conveyor to #2 conveyor Enclosed Functional X
FP36 Drop point, triple deck finish mill screen to fines to silo conveyor Enclosed Functional X
FP37 Fines to silo conveyor Dust cover; Baghouse Functional; Not functional X


FP38 Drop point, fines to silo conveyor to enclosed fines storage pile Chute Functional X
FP39 Enclosed fines storage pile Roof; Concrete enclosure at bottom; Tarps Functional; Functional; Functional X X
FP40 Open fines storage pile Enclosed; Concrete wall to south; Wind screen Functional; Functional; Functional X
FP41 Baghouse dust silo 1 Enclosed Functional X
FP42 Drop point, baghouse dust silo 1 to shipping belt Enclosed Functional X
FP43 Baghouse dust silo 2 Enclosed Functional X
FP44 Drop point, baghouse dust silo 2 to shipping belt Enclosed Functional X
FP45 Shipping belt Partially underground; Dust cover Functional; Functional; Functional X
FP46 Drop point, shipping belt to stationary belt Enclosed Functional X
FP47 Stationary belt Dust cover; Baghouse; Improved maintenance Functional; Functional X X
FP48 Drop point, stationary belt to radial stacker Enclosed Functional X
FP49 Radial stacker Dust cover; Spray head adjustment Functional; Partially functional X X
FP50 Drop point, radial stacker to block mix short term storage pile 1 Baghouse; Water suppression; Adjustable discharge height Functional; Functional; Functional X
FP51 Block mix short term storage pile 1 Low pile height/bldg Functional X
FP53 Block mix short term storage pile 3 Low pile height/small pile/bldg Functional X
FP55 Block mix short term storage pile 5 Low pile height Functional X
FP56 Block mix short term storage pile 6 Low pile height/small pile Functional X
FP57 3/4" long term storage pile 5 Low pile height Functional X
FP58 Loading 3/4" onto trucks Loader operator protocol Functional X
FP59 Loading 3/8" onto trucks Loader operator protocol Functional X
FP60 Loading clinker onto trucks Loader operator protocol Functional X
FP61 Loading block mix onto piles Loader operator protocol Functional X
FP62 Loading block mix onto trucks Loader operator protocol Functional X
FN1 8 X 0 long term storage pile Enclosed Functional X
FN2 4 X 0 fines feed pile Low pile height Functional X
FN3 Loading of block mix into Cedarapids feed hopper (surge bin) None None X
FN4 Cedarapids feed hopper (surge bin) None None X
FN5 Drop point, Cedarapids feed hopper to feeder belt None None X
FN6 Feeder belt None None X
FN7 Drop point, feeder belt to screen feed belt None None X
FN8 Screen feed belt None None X
FN9 Drop point, screen feed belt to Astec 2618 fines screen None None X
FN10 Astec 2618 fines screen None None X X
FN11 Drop point, fines screen to #4s belt None None X
FN12 #4s belt None None X
FN13 Drop point, #4s belt to 4 mesh reject pile None None X
FN14 4 mesh reject pile Low pile height Functional X
FN15 Drop point, fines screen to fines #8s belt None None X


FN16 #8s belt None None X
FN17 Drop point, #8s belt to fines 8 X 0 pile None None X
FN18 8 X 0 pile Low pile height Functional X
FN19 3/4" long term storage pile 6 Low pile height Functional X
FN20 Loading screened fines onto trucks (8 X 0, 4 X 0, 4 mesh reject) Loader operator protocol Functional X
BM1 Block mix long term storage pile 1 None None X
BM2 Block mix long term storage pile 2 Low pile height Functional X
BM5 Loading block mix into portable screen Loader operator protocol Functional X
BM6 Astec 710T None None X
BM7 Reade screen None None X
BM8 Loading onto temporary block mix pile Loader operator protocol Functional X
BM9 Temporary block mix pile for customer pickup Low pile height Functional X
BM10 Loading block mix onto trucks Loader operator protocol Functional X
BM11 Loading onto block mix pile None None X
IS1 3/4" long term storage pile 1 Low pile height Functional X
IS5 3/8" long term storage pile Low pile height Functional X
IS6 Block mix long term storage pile 5 Low pile height Functional X
IS7 Loading onto 3/4" pile None None X
IS8 Loading 3/4" onto trucks Loader operator protocol Functional X
IS9 Loading onto 3/8" pile None None X
IS10 Loading 3/8" onto trucks Loader operator protocol Functional X
BY1 Boneyard shale pile 1 None None X
BY2 Boneyard shale pile 2 None None X
BY3 Loading shale fines onto boneyard shale piles None None X
BY4 Loading boneyard shale piles onto trucks Loader operator protocol Functional X
OS1 Bulldozing None None X
OS2 Receiving overburden from quarry None None X
OS3 Wind erosion in overburden storage area None None X
RD1 Transport of stone from quarry to primary Water Functional X
RD2 Transfer of overburden from quarry to overburden storage area Water Functional X
RD3 Transport of shales fines to boneyard Water Functional X
RD4 Transport of product off-site by truck Water Functional X X
RD5 Travel of LGF delivery trucks Water Functional X
RD6 Maintenance traffic Water Functional X
RD7 Passenger vehicle traffic Water Functional X


RD8 Transport of shale fines to overburden storage area Water Functional X
RD9 Water truck movement Water Functional X
RD10 On-site product movement via front end loader Water Functional X

11.0 References
1. U.S. Environmental Protection Agency, Office of Air And Radiation, Office of Air Quality Planning
And Standards, AP-42 Compilation of Air Pollutant Emission Factors, Fifth Edition.
2. U.S. Environmental Protection Agency, WebFIRE, Available at http://cfpub.epa.gov/webfire/.
3. U.S. Environmental Protection Agency, Office Of Air And Radiation, Office of Air Quality Planning
And Standards, AP-42 Compilation of Air Pollutant Emission Factors, Fourth Edition.
4. U.S. Environmental Protection Agency, Office of Air and Waste Management, Office of Air Quality
Planning and Standards, EPA-450/3-77-010 Technical Guidance For Control Of Industrial Process
Fugitive Particulate Emissions (1977).
5. U.S. Environmental Protection Agency, Office Of Air And Radiation, Office of Air Quality Planning
And Standards, EPA-450/2-92-004 Fugitive Dust Background Document And Technical Information
Document For Best Available Control Measures (1992).
6. National Oceanic and Atomspheric Administration, National Climate Data Center, Available at
http://www.ncdc.noaa.gov/ (2014).
7. AWS Scientific, Inc., Wind Resource Assessment Handbook (1997).
8. U.S. Department of the Interior Bureau of Reclamation, Engineering Geology Field Manual, 2nd ed.
(2001).
9. ASTM International, D2487-11 Standard Practice for Classification of Soils for Engineering Purposes
(Unified Soil Classification System). ASTM International (2011).
10. Glover, T. J., Pocket Ref, 4th ed. (Sequoia Publishing, Inc., Littleton, CO, 2012).
11. Texas Commission on Environmental Quality, Air Permits Division, New Source Review (NSR)
Emission Calculations (2008).

APPENDICES
APPENDIX A
AERIAL PHOTOGRAPHS WITH PROCESS AREAS
•
ENGINEERING, PLLC
1
•
ENGINEERING, PLLC
2
•
ENGINEERING, PLLC
3
•
ENGINEERING, PLLC
4
•
ENGINEERING, PLLC
5
•
ENGINEERING, PLLC
6
•
ENGINEERING, PLLC
7
•
ENGINEERING, PLLC
8
•
ENGINEERING, PLLC
9
APPENDIX B
PROCESS FLOW DIAGRAMS
10
11
12
13
14
15
16
17
18
19
20
21
APPENDIX C
FUGITIVE DUST EMISSION CALCULATIONS
22
Norlite Fugitive Dust Sources and Calculations Calc AP 42
Area Source ID Source Name Source Type Product In/Post Proces P - Production Rate Units Control Condition ER - emissions reduction efficiency, %Emission Factor Type Emission Factor (EF) EF Units EF - Calculated Emission Factor (1-ER/100) E - Emissions, ton/yr via calculations E - Emissions, ton/yr via AP-42 facCombined Emissions
Quarry QA1 Drilling General Raw shale In process 246,000 tpy Water suppression, mist Functional 50% Controlled 8.00E-05 lb/ton No calculated value 0.5 No calculated value 0.00492 0.00492
Quarry QA2 Blasting Blasting Raw shale In process 246,000 tpy None None 0% Uncontrolled 0.08 lb/ton No calculated value 1 No calculated value 9.84000 9.84000
Quarry QA3 Quarried stone pile Drop Operation Raw shale In process 246,000 tpy Water suppression Functional 50% Uncontrolled 0.04 lb/ton 0.00510 0.5 0.31336 2.46000 0.31336
Quarry QA4 Load stone into truck Drop Operation Raw shale In process 246,000 tpy None None 0% Uncontrolled 0.002368 lb/ton 0.00510 1 0.62671 0.29126 0.62671
Quarry QA5 Overburden stripping Dragline Overburden In process 161,000 cu yd/yr None None 0% Uncontrolled 6.00E-02 lb/yd3 0.03480 1 2.80154 4.83000 2.80154
Quarry QA6 Load overburden into truck Drop Operation Overburden In process 206,265 tpy None None 0% Uncontrolled 3.70E-02 lb/ton 0.00008 1 0.00793 3.81591 0.00793
Primary PR1 Loading onto shot rock pile (Canal) Drop Operation Raw shale In process 246,000 tpy None None 0.00510 1 0.62671 #N/A 0.62671
Primary PR2 Shot rock pile (Canal) Storage Pile Raw shale In process 246,000 tpy None None 0% 0.00011 1 0.00000 #N/A 0.00000
Primary PR3 Unloading shot rock pile Drop Operation Raw shale In process 246,000 tpy None None 0.00510 1 0.62671 #N/A 0.62671
Primary PR4 Loading onto shale stockpile Drop Operation Raw shale In process 246,000 tpy Water suppression Functional 20% 3.00E-03 lb/ton 0.00510 0.8 0.50137 0.29520 0.50137
Primary PR5 Shale stockpile Storage Pile Raw shale In process 246,000 tpy Water suppression Functional 50% 0.21047 0.5 0.00264 #N/A 0.00264
Primary PR6 Unloading shale stockpile Drop Operation Raw shale In process 246,000 tpy None None 0.00510 1 0.62671 #N/A 0.62671
Primary PR7 Drop point, raw shale drop to jaw crusher Drop Operation Raw shale In process 282,900 tpy None None 0% Uncontrolled 0.003 lb/ton 0.00510 1 0.72072 0.42435 0.72072
Primary PR8 Jaw crusher General Raw shale In process 282,900 tpy Partially enclosed Functional 75% Uncontrolled 0.28 lb/ton No calculated value 0.25 No calculated value 9.90150 9.90150
Primary PR9 Drop point, jaw crusher to crusher belt Drop Operation Raw shale In process 282,900 tpy Enclosed Functional 90% Uncontrolled 0.003 lb/ton 0.00510 0.1 0.07207 0.04244 0.07207
Primary PR10 Crusher belt Conveyor Raw shale In process 282,900 tpy None None 0% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 1 No calculated value 0.02166 0.02166
Primary PR11 Drop point, crusher belt to screen belt Drop Operation Raw shale In process 282,900 tpy Enclosed Functional 90% Uncontrolled 0.003 lb/ton 0.00510 0.1 0.07207 0.04244 0.07207
Primary PR12 Screen belt Conveyor Raw shale In process 282,900 tpy None None 0% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 1 No calculated value 0.02829 0.02829
Primary PR13 Drop point, screen belt to primary double deck screen Drop Operation Raw shale In process 282,900 tpy None None 0% Uncontrolled 3.00E-03 lb/ton 0.00510 1 0.72072 0.42435 0.72072
Primary PR14 Primary double deck screen General Raw shale In process 282,900 tpy Water suppression, spray bar Functional 50% Uncontrolled 0.0022 lb/ton No calculated value 0.15 No calculated value 0.04668 0.04668
Primary (PR14) Partially enclosed Functional 70% (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Primary PR15 Drop point, primary double deck screen to primary cone crusher Drop Operation Raw shale In process 282,900 tpy Enclosed Functional 0.003 lb/ton 0.00510 1 0.72072 0.42435 0.72072
Primary PR16 Primary cone crusher General Raw shale In process 282,900 tpy Partially enclosed Functional 50% 3.00E-03 lb/ton No calculated value 0.5 No calculated value 0.21218 0.21218
Primary PR17 Drop point, primary cone crusher to primary double deck screen Drop Operation Raw shale In process 282,900 tpy None None 0.00510 1 0.72072 #N/A 0.72072
Primary PR18 Drop point, primary double deck screen to shale conveyor Drop Operation Raw shale In process 282,900 tpy Enclosed Functional 90% Uncontrolled 0.003 lb/ton 0.00510 0.1 0.07207 0.04244 0.07207
Primary PR19 Shale conveyor Conveyor Raw shale In process 233,000 tpy None None 0% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 1 No calculated value 0.06191 0.06191
Primary PR20 Drop point, shale conveyor to kiln feed pile Drop Operation Raw shale In process 233,000 tpy None None 0% Uncontrolled 0.003 lb/ton 0.00510 1 0.59360 0.34950 0.59360
Primary PR21 Kiln feed pile Storage Pile Raw shale In process 233,000 tpy None None 0% 0.21047 1 0.00332 #N/A 0.00332
Primary PR22 Drop point, double deck screen to shale fines conveyor Drop Operation Raw shale In process 13,000 tpy Enclosed Functional 90% Uncontrolled 0.003 lb/ton 0.00510 0.1 0.00331 0.00195 0.00331
Primary PR23 Shale fines conveyor Conveyor Shale fines In process 13,000 tpy None None 0% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 1 No calculated value 0.00255 0.00255
Primary PR24 Drop point, shale fines conveyor to shale fines pile Drop Operation Shale fines In process 13,000 tpy None None 0% Uncontrolled 0.003 lb/ton 0.00073 1 0.00476 0.01950 0.00476
Primary PR25 Shale fines pile Storage Pile Shale fines In process 13,000 tpy Low pile height/wetted material Functional 20% 0.16838 0.8 0.00088 #N/A 0.00088
Primary PR26 Loading from shale fines pile to trucks Drop Operation Shale fines In process 13,000 tpy None None 0% Uncontrolled 3.00E-03 lb/ton 0.00073 1 0.00476 0.01950 0.00476
Kiln Feed KF1 Drop point, shale pile to #4 conveyor Drop Operation Raw shale In process 116,500 tpy Enclosed Functional 99% Uncontrolled 0.003 lb/ton 0.00510 0.01 0.00297 0.00175 0.00297
Kiln Feed KF2 Drop point, loader to #4 conveyor Drop Operation Raw shale In process 116,500 tpy None None 0.00510 1 0.29680 #N/A 0.29680
Kiln Feed KF3 #4 conveyor Conveyor Raw shale In process 233,000 tpy Partially underground Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.15 No calculated value 0.01419 0.01419
Kiln Feed (KF3) Dust cover Functional (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Kiln Feed (KF3) Water suppression, spray bar Functional 50% (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Kiln Feed KF4 Drop point, #4 conveyor to #5 conveyor Drop Operation Raw shale In process 233,000 tpy Enclosed Functional 90% Uncontrolled 0.003 lb/ton 0.00510 0.1 0.05936 0.03495 0.05936
Kiln Feed KF5 #5 conveyor Conveyor Raw shale In process 233,000 tpy Dust cover Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.04349 0.04349
Kiln Feed KF6 Drop point, #5 conveyor to shale storage pile Drop Operation Raw shale In process 233,000 tpy Enclosed Functional 97% Uncontrolled 0.003 lb/ton 0.00510 0.03 0.01781 0.01049 0.01781
Kiln Feed KF7 Kiln feed storage pile Storage Pile Raw shale In process 233,000 tpy Partially enclosed Functional 88% 0.21047 0.1 0.00034 #N/A 0.00034
Kiln Feed (KF7) Low pile height Functional 20% (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Kiln Feed KF8 Drop point, shale storage pile to kiln 1 feeder belt Drop Operation Raw shale In process 121,000 tpy Underground Functional 99% 0.003 lb/ton 0.00510 0.01 0.00308 0.00182 0.00308
Kiln Feed KF9 Kiln 1 feeder belt Conveyor Raw shale In process 121,000 tpy Underground Functional 90% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.1 No calculated value 0.00149 0.00149
Kiln Feed KF10 Drop point, kiln 1 feeder belt to kiln 1 lower belt Drop Operation Raw shale In process 121,000 tpy Enclosed Functional 80% Uncontrolled 0.003 lb/ton 0.00510 0.2 0.06165 0.03630 0.06165
Kiln Feed KF11 Kiln 1 lower belt Conveyor Raw shale In process 121,000 tpy Dust cover Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.01104 0.01104
Kiln Feed (KF11) Partially underground Functional (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Kiln Feed (KF11) Meat locker curtain Functional (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Kiln Feed KF12 Drop point, kiln 1 lower belt to kiln 1 top belt Drop Operation Raw shale In process 121,000 tpy Enclosed Functional 80% Uncontrolled 0.003 lb/ton 0.00510 0.2 0.06165 0.03630 0.06165
Kiln Feed KF13 Kiln 1 top belt Conveyor Raw shale In process 121,000 tpy Dust cover Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.00381 0.00381
Kiln Feed KF14 Drop point, kiln 1 top belt to kiln 1 feed Drop Operation Raw shale In process 121,000 tpy Chute Functional 90% Uncontrolled 0.003 lb/ton 0.00510 0.1 0.03083 0.01815 0.03083
Kiln Feed KF15 Kiln 1 feed (AccuRate feeder) Drop Operation Raw shale In process 121,000 tpy Dust cover Functional 0% Uncontrolled 3.00E-03 lb/ton 0.00510 1 0.30826 0.18150 0.30826
Kiln Feed KF16 Kiln 1 rear chamber system (rim seal) General Kiln rear chamber seal d In process 121,000 tpy Dust cover Functional 99% Uncontrolled 8.40E-01 lb/ton No calculated value 0.01 No calculated value 0.50820 0.50820
Kiln Feed KF17 Kiln 1 front seal General Raw shale In process 121,000 tpy Vacuum Functional 99% Uncontrolled 8.40E-01 lb/ton No calculated value 0.01 No calculated value 0.50820 0.50820
Kiln Feed KF18 Drop point, shale storage pile to kiln 2 feeder belt Drop Operation Raw shale In process 112,000 tpy Underground Functional 99% 0.003 lb/ton 0.00510 0.01 0.00285 0.00168 0.00285
Kiln Feed KF19 Kiln 2 feeder belt Conveyor Raw shale In process 112,000 tpy Underground Functional 90% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.1 No calculated value 0.00138 0.00138
Kiln Feed KF20 Drop point, kiln 2 feeder belt to kiln 2 lower belt Drop Operation Raw shale In process 112,000 tpy Enclosed Functional 90% Uncontrolled 0.003 lb/ton 0.00510 0.1 0.02853 0.01680 0.02853
Kiln Feed KF21 Kiln 2 lower belt Conveyor Raw shale In process 112,000 tpy Dust cover Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.01065 0.01065
Kiln Feed (KF21) Partially underground Functional (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Kiln Feed (KF21) Meat locker curtain Functional (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Kiln Feed KF22 Drop point, kiln 2 lower belt to kiln 2 middle belt Drop Operation Raw shale In process 112,000 tpy Chute Functional 80% Uncontrolled 0.003 lb/ton 0.00510 0.2 0.05707 0.03360 0.05707
Kiln Feed KF23 Kiln 2 middle belt Conveyor Raw shale In process 112,000 tpy Dust cover Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.00449 0.00449
Kiln Feed KF24 Drop point, kiln 2 middle belt to kiln 2 top belt Drop Operation Raw shale In process 112,000 tpy Chute Functional 80% Uncontrolled 0.003 lb/ton 0.00510 0.2 0.05707 0.03360 0.05707
Kiln Feed KF25 Kiln 2 top belt Conveyor Raw shale In process 112,000 tpy Dust cover Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.00564 0.00564
Kiln Feed KF26 Drop point, kiln 2 top belt to kiln 2 feed Drop Operation Raw shale In process 112,000 tpy Chute Functional 80% Uncontrolled 0.003 lb/ton 0.00510 0.2 0.05707 0.03360 0.05707
Kiln Feed KF27 Kiln 2 feed (AccuRate feeder) Drop Operation Raw shale In process 112,000 tpy Dust cover Functional 0% Uncontrolled 3.00E-03 lb/ton 0.00510 1 0.28533 0.16800 0.28533
Kiln Feed KF28 Kiln 2 rear chamber system (rim seal) General Kiln rear chamber seal d In process 112,000 tpy Dust cover Functional 99% Uncontrolled 8.40E-01 lb/ton No calculated value 0.01 No calculated value 0.47040 0.47040
Kiln Feed KF29 Kiln 2 front seal General Raw shale In process 112,000 tpy Vacuum Functional 99% Uncontrolled 8.40E-01 lb/ton No calculated value 0.01 No calculated value 0.47040 0.47040
Kiln Feed KF30 Opening of kiln rim seals for cleaning General Kiln rear chamber seal d In process 438 tpy None None 0% Uncontrolled 3.00E-03 lb/ton No calculated value 1 No calculated value 0.00066 0.00066
Kiln Feed KF31 Removal of bag house plug (vacuum truck unloading) General Kiln rear chamber seal d In process 338 tpy Water suppression Functional 0% Uncontrolled 3.00E-03 lb/ton No calculated value 1 No calculated value 0.00051 0.00051
Kiln Feed (KF31) Baghouse Functional (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Kiln KL1 Drop point, kiln 1 to kiln 1 clinker cooler General Clinker In process 121,000 tpy Enclosed Functional 99% Uncontrolled 0.003 lb/ton No calculated value 0.01 No calculated value 0.00182 0.00182
Kiln KL2 Kiln 1 clinker cooler General Clinker In process 121,000 tpy Enclosed Functional 90% Uncontrolled 3.00E-01 lb/ton No calculated value 0.1 No calculated value 1.81500 1.81500
Kiln KL3 Drop point, kiln 1 clinker cooler to kiln 1 clinker belt General Clinker In process 121,000 tpy Partially enclosed Functional 80% Uncontrolled 0.003 lb/ton No calculated value 0.2 No calculated value 0.03630 0.03630
Kiln KL4 Kiln 1 clinker belt Conveyor Clinker In process 121,000 tpy Partially underground Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.02122 0.02122
Kiln (KL4) Dust cover Functional (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Kiln (KL4) Water suppression, as needed Functional 0% (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Kiln KL5 Drop point, kiln 1 clinker belt to kiln 1 clinker pile Drop Operation Clinker In process 121,000 tpy Water suppression Not functional 50% Uncontrolled 0.003 lb/ton 0.01345 0.5 0.40675 0.09075 0.40675
Kiln KL6 Kiln 1 clinker pile Storage Pile Clinker In process 121,000 tpy Water suppression Partially functional 50% 2.77823 0.5 0.01549 #N/A 0.01549
Kiln KL7 Drop point, kiln 2 to kiln 2 clinker cooler General Clinker In process 112,000 tpy Enclosed Functional 99% Uncontrolled 0.003 lb/ton No calculated value 0.01 No calculated value 0.00168 0.00168
Kiln KL8 Kiln 2 clinker cooler General Clinker In process 112,000 tpy Enclosed Functional 90% Uncontrolled 3.00E-01 lb/ton No calculated value 0.1 No calculated value 1.68000 1.68000
Kiln KL9 Drop point, kiln 2 clinker cooler to kiln 2 clinker belt General Clinker In process 112,000 tpy Partially enclosed Functional 80% Uncontrolled 0.003 lb/ton No calculated value 0.2 No calculated value 0.03360 0.03360
Kiln KL10 Kiln 2 clinker belt Conveyor Clinker In process 112,000 tpy Partially underground Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.01895 0.01895
Kiln (KL10) Dust cover Functional 0% (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Kiln (KL10) Water suppression, as needed Functional (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Kiln KL11 Drop point, kiln 2 clinker belt to kiln 2 clinker pile Drop Operation Clinker In process 112,000 tpy Water suppression, mist Not functional 50% Uncontrolled 0.003 lb/ton 0.01345 0.5 0.37650 0.08400 0.37650
Kiln KL12 Kiln 2 clinker pile Storage Pile Clinker In process 112,000 tpy Water suppression, mist Partially functional 50% 2.77823 0.5 0.01549 #N/A 0.01549
Kiln KL13 Transfer kiln 2 clinker pile to kiln 1 clinker pile Drop Operation Clinker In process 112,000 tpy Loader Operator Protocol Functional 0% Uncontrolled 3.00E-03 lb/ton 0.01345 1 0.75300 0.16800 0.75300
Kiln KL14 Muck pile Storage Pile Kiln baghouse dust Post process 8,160 tpy Moisture; Pile shaping; Compaction Functional; Functional; Functional 50% 84.18870 0.5 1.05615 #N/A 1.05615
Kiln KL15 Loading onto muck pile Drop Operation Kiln baghouse dust Post process 8,160 tpy None None 0% 0.00011 1 0.00047 #N/A 0.00047
Kiln KL16 Unloading muck pile Drop Operation Kiln baghouse dust Post process 8,160 tpy None None 0% 0.00011 1 0.00047 #N/A 0.00047
Finish Plant FP1 Drop point, kiln 1 clinker pile to transfer to #1 conveyor General Clinker In process 233,000 tpy Underground Functional 90% Uncontrolled 3.00E-03 lb/ton No calculated value 0.1 No calculated value 0.03495 0.03495
Finish Plant FP2 #1 conveyor Conveyor Clinker In process 233,000 tpy Dust cover Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.01599 0.01599
Finish Plant (FP2) Partially underground Functional (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Finish Plant FP3 Drop point, #1 conveyor to grizzly Drop Operation Clinker In process 233,000 tpy None None 80% Uncontrolled 0.003 lb/ton 0.01345 0.2 0.31330 0.06990 0.31330
Finish Plant FP4 Grizzly on lightweight aggregate feed platform Drop Operation Clinker In process 233,000 tpy Partially enclosed Functional 70% Uncontrolled 3.00E-03 lb/ton 0.01345 0.3 0.46995 0.10485 0.46995
Finish Plant FP5 Drop point, grizzly to grizzly pile Drop Operation Clinker In process 233,000 tpy None None 0% Uncontrolled 0.003 lb/ton 0.01345 1 1.56651 0.34950 1.56651
Finish Plant FP6 Grizzly reject pile Storage Pile Clinker In process 1,167 tpy None None 0% 2.77823 1 0.00510 #N/A 0.00510
Finish Plant FP7 Drop point, grizzly to #2 conveyor Drop Operation Clinker In process 233,000 tpy Enclosed Functional 90% Uncontrolled 0.003 lb/ton 0.01345 0.1 0.15665 0.03495 0.15665
Finish Plant FP8 #2 conveyor Conveyor Clinker In process 233,000 tpy Dust cover Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.03155 0.03155
Finish Plant FP9 Drop point, #2 conveyor to triple deck finish mill screen Drop Operation Clinker In process 233,000 tpy Enclosed Functional 90% Uncontrolled 0.003 lb/ton 0.01345 0.1 0.15665 0.03495 0.15665
Finish Plant FP10 Triple deck finish mill screen General Clinker In process 233,000 tpy Baghouse Not functional 0% Uncontrolled 2.20E-03 lb/ton No calculated value 1 No calculated value 0.25630 0.25630
Finish Plant FP11 Drop point, triple deck finish mill screen to 3/4" discharge conveyor Drop Operation 3/4" In process 69,000 tpy Enclosed Functional 90% Uncontrolled 0.003 lb/ton 0.00373 0.1 0.01286 0.01035 0.01286
Finish Plant FP12 3/4" discharge conveyor Conveyor 3/4" In process 69,000 tpy Dust cover Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.00647 0.00647
Finish Plant (FP12) Baghouse Not functional 0% (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Finish Plant FP13 Drop point, 3/4" discharge conveyor to 3/4" to stockpile conveyor Drop Operation 3/4" In process 69,000 tpy Enclosed Functional 80% Uncontrolled 0.003 lb/ton 0.00373 0.2 0.02572 0.02070 0.02572
Finish Plant FP14 3/4" to stockpile conveyor Conveyor 3/4" In process 69,000 tpy Dust cover Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.01273 0.01273
Finish Plant FP15 Drop point, 3/4" to stockpile conveyor to 3/4" short term storage pile Drop Operation 3/4" In process 69,000 tpy Tube Functional 90% Uncontrolled 0.003 lb/ton 0.00373 0.05 0.00643 0.00518 0.00643
Finish Plant (FP15) Water suppression Functional 50% (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Finish Plant FP16 3/4" short term storage pile Storage Pile 3/4" In process 98,185 tpy Water suppression Functional 50% 1.13655 0.5 0.00449 #N/A 0.00449
Finish Plant FP17 Drop point, triple deck finish mill screen to 3/8" discharge conveyor Drop Operation 3/8" In process 46,000 tpy Enclosed Functional 80% Uncontrolled 0.003 lb/ton 0.00373 0.2 0.01715 0.01380 0.01715
Finish Plant FP18 3/8" discharge conveyor Conveyor 3/8" In process 46,000 tpy Dust cover Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.00289 0.00289
Finish Plant FP19 Drop point, 3/8" discharge conveyor to 3/8" to stockpile conveyor Drop Operation 3/8" In process 46,000 tpy Enclosed Functional 0% Uncontrolled 0.003 lb/ton 0.00373 1 0.08575 0.06900 0.08575
Finish Plant FP20 3/8" to stockpile conveyor Conveyor 3/8" In process 46,000 tpy Dust cover Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.00660 0.00660
Finish Plant FP21 Drop point, 3/8" stockpile conveyor to 3/8" short term storage pile Drop Operation 3/8" In process 46,000 tpy Water suppression, spray head Functional 50% Uncontrolled 0.003 lb/ton 0.00373 0.5 0.04287 0.03450 0.04287
Finish Plant FP22 3/8" short term storage pile Storage Pile 3/8" In process 25,550 tpy Water suppression, spray head Functional 70% 1.24178 0.3 0.05191 #N/A 0.05191
Finish Plant FP23 Drop point, triple deck finish mill screen to oversize discharge conveyor Drop Operation Clinker In process 133,975 tpy Enclosed Functional 90% Uncontrolled 0.003 lb/ton 0.01345 0.1 0.09007 0.02010 0.09007
Finish Plant FP24 Oversize discharge conveyor Conveyor Clinker In process 133,975 tpy Partially covered Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.01122 0.01122
23
Norlite Fugitive Dust Sources and Calculations Calc AP 42
Area Source ID Source Name Source Type Product In/Post Proces P - Production Rate Units Control Condition ER - emissions reduction efficiency, %Emission Factor Type Emission Factor (EF) EF Units EF - Calculated Emission Factor (1-ER/100) E - Emissions, ton/yr via calculations E - Emissions, ton/yr via AP-42 facCombined Emissions
Finish Plant FP25 Drop point, oversize discharge conveyor to oversize hopper Drop Operation Clinker In process 133,975 tpy None None 0% Uncontrolled 0.003 lb/ton 0.01345 1 0.90074 0.20096 0.90074
Finish Plant FP26 Oversize hopper General Clinker In process 133,975 tpy None None 0% Uncontrolled 3.00E-03 lb/ton No calculated value 1 No calculated value 0.20096 0.20096
Finish Plant FP27 Drop point, oversize hopper to El Jay crusher speed conveyor Drop Operation Clinker In process 133,975 tpy Partially enclosed Functional 70% Uncontrolled 0.003 lb/ton 0.01345 0.3 0.27022 0.06029 0.27022
Finish Plant FP28 El Jay crusher speed conveyor Conveyor Clinker In process 133,975 tpy Dust cover Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.01151 0.01151
Finish Plant FP29 Drop point, El Jay crusher speed conveyor to El Jay crusher Drop Operation Clinker In process 133,975 tpy Enclosed Functional 90% Uncontrolled 0.003 lb/ton 0.01345 0.1 0.09007 0.02010 0.09007
Finish Plant FP30 El Jay crusher General Clinker In process 133,975 tpy Baghouse Not functional 90% Uncontrolled 2.50E-02 lb/ton No calculated value 0.1 No calculated value 0.16747 0.16747
Finish Plant FP31 Drop point, El Jay crusher to El Jay discharge conveyor Drop Operation Clinker In process 133,975 tpy Enclosed Functional 90% Uncontrolled 0.003 lb/ton 0.01345 0.1 0.09007 0.02010 0.09007
Finish Plant FP32 El Jay discharge conveyor Conveyor Clinker In process 133,975 tpy None None 0% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 1 No calculated value 0.00804 0.00804
Finish Plant FP33 Drop point, El Jay discharge conveyor to #2 return conveyor Drop Operation Clinker In process 133,975 tpy Enclosed Functional 80% Uncontrolled 0.003 lb/ton 0.01345 0.2 0.18015 0.04019 0.18015
Finish Plant FP34 #2 return conveyor Conveyor Clinker In process 133,975 tpy Dust cover Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.01398 0.01398
Finish Plant FP35 Drop point, #2 return conveyor to #2 conveyor Drop Operation Clinker In process 133,975 tpy Enclosed Functional 80% Uncontrolled 0.003 lb/ton 0.01345 0.2 0.18015 0.04019 0.18015
Finish Plant FP36 Drop point, triple deck finish mill screen to fines to silo conveyor Drop Operation Block mix In process 28,000 tpy Enclosed Functional 90% Uncontrolled 0.003 lb/ton 0.00373 0.1 0.00522 0.00420 0.00522
Finish Plant FP37 Fines to silo conveyor Conveyor Block mix In process 28,000 tpy Dust cover Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.00840 0.00840
Finish Plant FP38 Drop point, fines to silo conveyor to enclosed fines storage pile Drop Operation 4x0 In process 85,000 tpy Chute Functional 94% Uncontrolled 0.003 lb/ton 0.00373 0.06 0.00951 0.00765 0.00951
Finish Plant FP39 Enclosed fines storage pile Storage Pile 4x0 In process 85,000 tpy Roof Functional 20% 5.85111 0.2 0.03001 #N/A 0.03001
Finish Plant (FP39) Concrete enclosure at bottom Functional 75% (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Finish Plant (FP39) Tarps Functional (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Finish Plant FP40 Open fines storage pile Storage Pile 4x0 In process 85,000 tpy Enclosed Functional 20% 5.85111 0.2 0.00981 #N/A 0.00981
Finish Plant (FP40) Concrete wall to south Functional 50% (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Finish Plant (FP40) Wind screen Functional 50% (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Finish Plant FP41 Baghouse dust silo 1 Storage Pile Block mix In process 85,000 tpy Enclosed Functional 97% Controlled, fabric filter 9.90E-03 lb/ton 7.82955 0.03 0.00153 0.01262 0.00153
Finish Plant FP42 Drop point, baghouse dust silo 1 to shipping belt Drop Operation Block mix In process 85,000 tpy Enclosed Functional 99% 0.003 lb/ton 0.00373 0.01 0.00158 0.00128 0.00158
Finish Plant FP43 Baghouse dust silo 2 Storage Pile Block mix In process 85,000 tpy Enclosed Functional 97% Controlled, fabric filter 9.90E-03 lb/ton 7.82955 0.03 0.00153 0.01262 0.00153
Finish Plant FP44 Drop point, baghouse dust silo 2 to shipping belt Drop Operation Block mix In process 85,000 tpy Enclosed Functional 99% 0.003 lb/ton 0.00373 0.01 0.00158 0.00128 0.00158
Finish Plant FP45 Shipping belt Conveyor Block mix In process 27,094 tpy Partially underground Functional 90% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.1 No calculated value 0.00102 0.00102
Finish Plant (FP45) Dust cover Functional (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Finish Plant FP46 Drop point, shipping belt to stationary belt Drop Operation Block mix In process 27,094 tpy Enclosed Functional 90% Uncontrolled 0.003 lb/ton 0.00373 0.1 0.00505 0.00406 0.00505
Finish Plant FP47 Stationary belt Conveyor Block mix In process 27,094 tpy Dust cover Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.00369 0.00369
Finish Plant (FP47) Baghouse; Improved maintenance Functional; Functional (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Finish Plant FP48 Drop point, stationary belt to radial stacker Drop Operation Block mix In process 27,094 tpy Enclosed Functional 90% Uncontrolled 0.003 lb/ton 0.00373 0.1 0.00505 0.00406 0.00505
Finish Plant FP49 Radial stacker Conveyor Block mix In process 27,094 tpy Dust cover; Spray head adjustment Functional; Partially Functional 70% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 0.3 No calculated value 0.00301 0.00301
Finish Plant FP50 Drop point, radial stacker to block mix short term storage pile 1 Drop Operation Block mix In process 27,094 tpy Baghouse Functional 90% Uncontrolled 0.003 lb/ton 0.00373 0.0125 0.00063 0.00051 0.00063
Finish Plant (FP50) Water suppression Functional 50% (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Finish Plant (FP50) Adjustable discharge height Functional 75% (Additional control) (Additional control) (Additional control) #N/A (Additional control)
Finish Plant FP51 Block mix short term storage pile 1 Storage Pile Block mix In process 15,133 tpy Low pile height/bldg Functional 20% 7.82955 0.8 0.07249 #N/A 0.07249
Finish Plant FP53 Block mix short term storage pile 3 Storage Pile Block mix In process 2,147 tpy Low pile height/small pile/bldg Functional 50% 7.82955 0.5 0.03096 #N/A 0.03096
Finish Plant FP55 Block mix short term storage pile 5 Storage Pile Block mix In process 33,788 tpy Low pile height Functional 20% 7.82955 0.8 0.27841 #N/A 0.27841
Finish Plant FP56 Block mix short term storage pile 6 Storage Pile Block mix In process 2,550 tpy Low pile height/small pile Functional 50% 7.82955 0.5 0.05963 #N/A 0.05963
Finish Plant FP57 3/4" long term storage pile 5 Storage Pile 3/4" Post process 37,531 tpy Low pile height Functional 20% 1.13655 0.8 0.01717 #N/A 0.01717
Finish Plant FP58 Loading 3/4" onto trucks Drop Operation 3/4" Post process 69,000 tpy Loader Operator Protocol Functional 0% Uncontrolled 3.00E-03 lb/ton 0.00080 1 0.02763 0.10350 0.02763
Finish Plant FP59 Loading 3/8" onto trucks Drop Operation 3/8" Post process 46,000 tpy Loader Operator Protocol Functional 0% Uncontrolled 3.00E-03 lb/ton 0.00080 1 0.01842 0.06900 0.01842
Finish Plant FP60 Loading clinker onto trucks Drop Operation Clinker Post process 233,000 tpy Loader Operator Protocol Functional 0% Uncontrolled 3.00E-03 lb/ton 0.00141 1 0.16458 0.34950 0.16458
Finish Plant FP61 Loading block mix onto piles Drop Operation Block mix Post process 92,000 tpy Loader Operator Protocol Functional 0% Uncontrolled 3.00E-03 lb/ton 0.00080 1 0.03684 0.13800 0.03684
Finish Plant FP62 Loading block mix onto trucks Drop Operation Block mix Post process 92,000 tpy Loader Operator Protocol Functional 0% Uncontrolled 3.00E-03 lb/ton 0.00080 1 0.03684 0.13800 0.03684
Fines Processing FN1 8 X 0 long term storage pile Storage Pile Block mix Post process 27,094 tpy Enclosed Functional 85% 7.82955 0.15 0.02218 #N/A 0.02218
Fines Processing FN2 4 X 0 fines feed pile Storage Pile 4x0 In process 66,839 tpy Low pile height Functional 20% 5.85111 0.8 0.01975 #N/A 0.01975
Fines Processing FN3 Loading of block mix into Cedarapids feed hopper (surge bin) Drop Operation 4x0 In process 66,839 tpy None None 0% Uncontrolled 3.00E-03 lb/ton 0.00373 1 0.12459 0.10026 0.12459
Fines Processing FN4 Cedarapids feed hopper (surge bin) General 4x0 In process 66,839 tpy None None 0% Uncontrolled 3.00E-03 lb/ton No calculated value 1 No calculated value 0.10026 0.10026
Fines Processing FN5 Drop point, Cedarapids feed hopper to feeder belt Drop Operation 4x0 In process 66,839 tpy None None 0% Uncontrolled 0.003 lb/ton 0.00373 1 0.12459 0.10026 0.12459
Fines Processing FN6 Feeder belt Conveyor 4x0 In process 66,839 tpy None None 0% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 1 No calculated value 0.01702 0.01702
Fines Processing FN7 Drop point, feeder belt to screen feed belt Drop Operation 4x0 In process 66,839 tpy None None 0% Uncontrolled 0.003 lb/ton 0.00373 1 0.12459 0.10026 0.12459
Fines Processing FN8 Screen feed belt Conveyor 4x0 In process 66,839 tpy None None 0% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 1 No calculated value 0.01154 0.01154
Fines Processing FN9 Drop point, screen feed belt to Astec 2618 fines screen Drop Operation 4x0 In process 66,839 tpy None None 0% Uncontrolled 0.003 lb/ton 0.00373 1 0.12459 0.10026 0.12459
Fines Processing FN10 Astec 2618 fines screen General 4x0 In process 66,839 tpy None None 0% Uncontrolled 0.002 lb/ton No calculated value 1 No calculated value 0.06684 0.06684
Fines Processing FN11 Drop point, fines screen to #4s belt Drop Operation 4x0 In process 66,839 tpy None None 0% Uncontrolled 0.003 lb/ton 0.00373 1 0.12459 0.10026 0.12459
Fines Processing FN12 #4s belt Conveyor 4x0 In process 66,839 tpy None None 0% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 1 No calculated value 0.01421 0.01421
Fines Processing FN13 Drop point, #4s belt to 4 mesh reject pile Drop Operation 4x0 In process 66,839 tpy None None 0% Uncontrolled 0.003 lb/ton 0.00373 1 0.12459 0.10026 0.12459
Fines Processing FN14 4 mesh reject pile Storage Pile 4x0 In process 27,094 tpy Low pile height Functional 20% 5.85111 0.8 0.01975 #N/A 0.01975
Fines Processing FN15 Drop point, fines screen to fines #8s belt Drop Operation 8x0 In process 27,094 tpy None None 0% Uncontrolled 0.003 lb/ton 0.00373 1 0.05050 0.04064 0.05050
Fines Processing FN16 #8s belt Conveyor 8x0 In process 27,094 tpy None None 0% Uncontrolled 0.003 lb/ton per 300 ft No calculated value 1 No calculated value 0.00580 0.00580
Fines Processing FN17 Drop point, #8s belt to fines 8 X 0 pile Drop Operation 8x0 In process 27,094 tpy None None 0% Uncontrolled 0.003 lb/ton 0.00373 1 0.05050 0.04064 0.05050
Fines Processing FN18 8 X 0 pile Storage Pile 8x0 In process 27,094 tpy Low pile height Functional 20% 7.53489 0.8 0.02543 #N/A 0.02543
Fines Processing FN19 3/4" long term storage pile 6 Storage Pile 3/4" Post process 9,847 tpy Low pile height Functional 20% 1.13655 0.8 0.00384 #N/A 0.00384
Fines Processing FN20 Loading screened fines onto trucks (8 X 0, 4 X 0, 4 mesh reject) Drop Operation Block mix Post process 27,094 tpy Loader Operator Protocol Functional 0% Uncontrolled 3.00E-03 lb/ton 0.00080 1 0.01085 0.04064 0.01085
Block Mix BM1 Block mix long term storage pile 1 Storage Pile Block mix Post process 8,376 tpy None None 0% 7.82955 1 0.25272 #N/A 0.25272
Block Mix BM2 Block mix long term storage pile 2 Storage Pile Block mix Post process 8,376 tpy Low pile height Functional 20% 7.82955 0.8 0.01598 #N/A 0.01598
Block Mix BM5 Loading block mix into portable screen Drop Operation Block mix Post process 89,118 tpy Loader Operator Protocol Functional 0% Uncontrolled 3.00E-03 lb/ton 0.00080 1 0.03568 0.13368 0.03568
Block Mix BM6 Astec 710T General Block mix Post process 44,559 tpy None None 0% Uncontrolled 0.002 lb/ton No calculated value 1 No calculated value 0.04456 0.04456
Block Mix BM7 Reade screen General Block mix Post process 44,559 tpy None None 0% Uncontrolled 0.002 lb/ton No calculated value 1 No calculated value 0.04456 0.04456
Block Mix BM8 Loading onto temporary block mix pile Drop Operation Block mix Post process 89,118 tpy Loader Operator Protocol Functional 0% Uncontrolled 3.00E-03 lb/ton 0.00080 1 0.03568 0.13368 0.03568
Block Mix BM9 Temporary block mix pile for customer pickup Storage Pile Block mix Post process 89,118 tpy Low pile height Functional 20% 7.82955 0.8 0.04084 #N/A 0.04084
Block Mix BM10 Loading block mix onto trucks Drop Operation Block mix Post process 89,118 tpy Loader Operator Protocol Functional 0% Uncontrolled 3.00E-03 lb/ton 0.00080 1 0.03568 0.13368 0.03568
Block Mix BM11 Loading onto block mix pile Drop Operation Block mix Post process 89,118 tpy None None 0% Uncontrolled 3.00E-03 lb/ton 0.00080 1 0.03568 0.13368 0.03568
Island IS1 3/4" long term storage pile 1 Storage Pile 3/4" Post process 2,840 tpy Low pile height Functional 20% 1.13655 0.8 0.00719 #N/A 0.00719
Island IS5 3/8" long term storage pile Storage Pile 3/8" Post process 45,642 tpy Low pile height Functional 20% 1.24178 0.8 0.01876 #N/A 0.01876
Island IS6 Block mix long term storage pile 5 Storage Pile Block mix Post process 2,147 tpy Low pile height Functional 20% 7.82955 0.8 0.02643 #N/A 0.02643
Island IS7 Loading onto 3/4" pile Drop Operation Block mix Post process 69,000 tpy None None 0% Uncontrolled 3.00E-03 lb/ton 0.00080 1 0.02763 0.10350 0.02763
Island IS8 Loading 3/4" onto trucks Drop Operation Block mix Post process 69,000 tpy Loader Operator Protocol Functional 0% Uncontrolled 3.00E-03 lb/ton 0.00080 1 0.02763 0.10350 0.02763
Island IS9 Loading onto 3/8" pile Drop Operation Block mix Post process 46,000 tpy None None 0% Uncontrolled 3.00E-03 lb/ton 0.00080 1 0.01842 0.06900 0.01842
Island IS10 Loading 3/8" onto trucks Drop Operation Block mix Post process 46,000 tpy Loader Operator Protocol Functional 0% Uncontrolled 3.00E-03 lb/ton 0.00080 1 0.01842 0.06900 0.01842
Boneyard BY1 Boneyard shale pile 1 Storage Pile Shale fines Post process 9,446 tpy None None 0% 0.16838 1 0.00410 #N/A 0.00410
Boneyard BY2 Boneyard shale pile 2 Storage Pile Shale fines Post process 9,446 tpy None None 0% 0.16838 1 0.00410 #N/A 0.00410
Boneyard BY3 Loading shale fines onto boneyard shale piles Drop Operation Shale fines Post process 9,446 tpy None None 0% Uncontrolled 3.00E-03 lb/ton 0.00073 1 0.00346 0.01417 0.00346
Boneyard BY4 Loading boneyard shale piles onto trucks Drop Operation Shale fines Post process 9,446 tpy Loader Operator Protocol Functional 0% Uncontrolled 3.00E-03 lb/ton 0.00073 1 0.00346 0.01417 0.00346
Overburden Storage OS1 Bulldozing Bulldozing Overburden Post process 206,265 tpy None None 0% Uncontrolled 3.00E-03 lb/ton 6.55695 1 2.88506 0.30940 2.88506
Overburden Storage OS2 Receiving overburden from quarry Drop Operation Overburden Post process 206,265 tpy None None 0% Uncontrolled 2.00E-03 lb/ton 0.00008 1 0.00793 0.20627 0.00793
Overburden Storage OS3 Wind erosion in overburden storage area Overburden Erosion Overburden Post process -- -- None None 0% Uncontrolled 3.80E-01 ton/acre-year No calculated value 1 No calculated value 1.90000 1.90000
Road RD1 Transport of stone from quarry to primary Unpaved Road Shale fines In process 15,504 mi Water Functional 50% Uncontrolled 6.2 lb/mi 0.56834 0.5 2.20290 48062.78750 2.20290
Road RD2 Transfer of overburden from quarry to overburden storage area Unpaved Road Shale fines In process 15,875 mi Water Functional 50% Uncontrolled 6.2 lb/mi 0.56834 0.5 2.25566 49214.02652 2.25566
Road RD3 Transport of shales fines to boneyard Unpaved Road Shale fines In process 1,043 mi Water Functional 50% Uncontrolled 6.2 lb/mi 0.56834 0.5 0.14819 3233.12856 0.14819
Road RD4 Transport of product off-site by truck Unpaved Road Shale fines Post process 7,992 mi Water Functional 50% Uncontrolled 6.2 lb/mi 0.55304 0.5 1.10499 24775.34091 1.10499
Road RD5 Travel of LGF delivery trucks Unpaved Road Shale fines #N/A 550 mi Water Functional 50% Uncontrolled 6.2 lb/mi 0.55304 0.5 0.07598 1703.67898 0.07598
Road RD6 Maintenance traffic Unpaved Road Shale fines #N/A 2,914 mi Water Functional 50% Uncontrolled 6.2 lb/mi 0.29637 0.5 0.21589 9032.71307 0.21589
Road RD7 Passenger vehicle traffic Paved Road Shale fines #N/A 5,952 mi Water Functional 50% 0.96935 0.5 1.44230 #N/A 1.44230
Road RD8 Transport of shale fines to overburden storage area Unpaved Road Shale fines #N/A 1,427 mi Water Functional 50% Uncontrolled 6.2 lb/mi 0.56834 0.5 0.20276 4423.84091 0.20276
Road RD9 Water truck movement Unpaved Road Shale fines #N/A 3,686 mi Water Functional 50% Uncontrolled 6.2 lb/mi 0.35795 0.5 0.32983 11425.92129 0.32983
Road RD10 On-site product movement via front end loader Unpaved Road Shale fines #N/A 4,493 mi Water Functional 50% Uncontrolled 6.2 lb/mi 0.32171 0.5 0.36139 13929.45076 0.36139
24
APPENDIX D
SITE-SPECIFIC VARIABLES
25
Site‐wide Variables & Assumptions
Variable Value Units Comments

a_unpaved 0.7 ‐ Unpaved roadsa
b_unpaved 0.45 ‐ Unpaved roadsa
f 11.6% ‐ Percentage of year with unobstruted wind speeds >12 mph at mean pile heightb
k_drop 1 ‐ Drop operationsa
k_unpaved 4.9 lb/VMT Unpaved roadsa
k_paved 0.011 lb/VMT Paved roadsa
k_conveyor 1 ‐ Conveyora
N 365 days Averaging period
ob_density 1.28 ton/yd3 Average overburden density
p 139.4 days Days with at least 0.01 in of precipitationb
PE 136 ‐ Thornthwaite's evaporation‐precipitation index
STER 1 g/s Short term emission rate
U 7.15 mph Average wind speedb
a
Values obtained from AP‐42.
b
Values obtained from historical daily weather data for Albany International Airport for the years 2004 through 2013.
26
Overburden Characteristics
Silt
Content,
Sample Number Sample %
12580 SAND, fine/medium; some Silt/Clay; some fine Gravel 32.80%
12212 SILT/CLAY; little fine/medium Sand; little Fine Gravel 74.90%
12205 SILT/CLAY; and fine Sand; little fine Gravel 48.30%
12175 SAND, fine/medium; some Silt/Clay; some fine Gravel 31.80%
11707 SILT/CLAY; trace fine Sand; trace fine Gravel 95.10%
11706 SILT/CLAY; and fine/medium Sand; little fine Gravel 46.50%
11705 SILT/CLAY; trace fine Sand 98.50%
Average 61.13%
All values taken from Gifford Engineering's Interim Stablity Report on the Overburden Spoil
Storage Berms dated October 30, 2012.
27
Production Rates & Hours (select examples)
2012 Operating 2013 Operating Average
Average Hours Hours Operating Hours Fraction of Year
Area 2012 (ton/year) 2013 (ton/year) (ton/year) (hours/year) (hours/year) (hours/year) Operational
Quarry: 288,759 272,707 280,733 2,365 3,081 2,723 0.311
Kiln 1: 127,993 107,146 117,570 8,069 7,583 7,826 0.893
Kiln 2: 109,115 103,801 106,458 7,925 7,649 7,787 0.889
28
Product Characteristics
Moisture content (in Moisture content (post
a b c
Product Silt content, % process) , % process), % Density, ton/yd3
Raw shale 0.25% 2.00% 2.00%
Shale fines 0.20% 8.00% 8.00%
Clinker 3.30% 1.00% 5.00%
3/4" 1.35% 2.50% 7.50%
3/8" 1.48% 2.50% 7.50%
Block mix 9.30% 2.50% 7.50%
3/16" 1.35% 2.50% 7.50%
4x0 6.95% 2.50% 7.50%
8x0 8.95% 2.50% 7.50%
Overburden 61.13% 40.00% 40.00%
Kiln baghouse dust 100.00% 0.00% 30.00% 0.42
Kiln rear chamber seal dust 14.65% 0.00% 30.00% 1.20
Kiln clinker cooler multiclone dust 32.90% 0.00% 30.00% 0.93
Block mix baghouse dust 100.00% 2.50% 2.50%
Muck pile baghouse dust 100.00% 30.00% 30.00%
Finish plant baghouse dust 100.00% 2.50% 2.50%
a
Although material passing through a 200 sieve can contain both silt and clay, we assumed that all material passing through a 200 sieve is silt as a
conservative estimate of emissions.
b
The "in process" moisture content for the end products (3/4", 3/8", block mix, 3/16", 4x0, and 8x0) is 2.5%. The average moisture content for
these materials is between 0% and 5%, so an average value of 2.5% has been used in calculations.
c
The "post process" moisture content for the end products (3/4", 3/8", block mix, 3/16", 4x0, and 8x0) is 7.5%. The average moisture content for
these materials is between 5% and 10%, so an average value of 7.5% has been used in calculations.
29
Mean Vehicle Weightsa
Vehicle Type Mean Weight, tons
Quarry haul truck 42.5
Customer delivery truck 40
LGF delivery truck 40
Maintenance truck 10
Passenger vehicle 2
Front end loader 12
Water truckb 15.2
a
All vehicle weights listed here are mean weights (mean
of empty and full vehicles, if applicable).
b
Assume the water trucks can hold an average of 2,500
gal of water.
30
Southern Overburden Storage Area Clay Yardage
3
Year Overburden Stripped, yd Overburden Stripped, tons
2008 187,903.0 240,731.9
2009 339,389.0 434,808.2
2010 108,705.0 139,267.4
2011 150,580.0 192,915.6
2012 146,638.0 187,865.3
2013 61,940.0 79,354.4
Average* 165,859.2 212,490.5
* Excludes 2014 data
31
APPENDIX E
PHOTOGRAPH LOG
32
FUGITIVE DUST
EMISSION POINTS
PHOTOGRAPH LOG
NORLITE, LLC
A DIVISION OF TRADEBE ENVIRONMENTAL SERVICES, LLC
COHOES, NEW YORK
33
QUARRY AREA (QA)
EMISSION POINTS
PHOTOGRAPHS
34
Quarry Photograph 1, facing west:
Drilling (QA1, not pictured) and blasting (QA2, not pictured) operations occur in
the quarry to extract stone from the earth. Facing west, below is a quarried stone
pile (QA3) in the quarry, as a result of those efforts.
35
Quarry Photograph 2, facing west:
Stone is loaded (QA4) into a truck in the quarry. Stripped overburden (QA5, not
pictured) is also loaded (QA6, not pictured), into trucks in the quarry.
Stone loaded
into a truck
(QA4)
36
PRIMARY AREA (PR)
EMISSION POINTS
PHOTOGRAPHS
37
Primary Photograph 1, facing southwest:
Primary operations begin with loading (PR1, not pictured) and unloading (PR3, not
pictured) material onto and from the shot rock pile (PR2, not pictured). Shale from
the quarry is also loaded (PR4, not pictured) onto the shale stockpile (PR5, not
pictured) by front end loaders. A view of stone from the shale stockpile (PR5) being
unloaded (PR6) into the primary jaw crusher (PR7), primary jaw crusher (PR8), and
related drop points (PR9 and PR10).
Unloading Primary jaw

(PR6) of crusher (PR8)
shale
stockpile into
crusher
Drop point –
transfer of raw
shale to primary
crusher (PR7,
Drop point enclosed)
from primary
crusher (PR9)
to crusher belt
(PR10,
enclosed) Shale stockpile
(PR5)
38
Primary Photograph 2, looking west:
A view of the primary jaw crusher (PR8) and where material drops (PR9) onto the
crusher belt (PR10) and drops (PR11) from the crusher belt to the screen belt
(PR12, enclosed).
Primary jaw
crusher (PR8)
Drop point (PR9)

from primary
crusher to crusher
belt (PR10)
Crusher belt
Transfer drop point (PR10)
from crusher belt to
screen belt (PR12)
(enclosed)
39
Primary Photograph 3, looking southwest:
A view of the partially enclosed screen belt (PR12) and where material drops (PR13) into the
double deck screen (PR14). The screen separates material onto two separate conveyor belts
(one to the kiln feed pile (PR21) and the other to the shale fines storage pile (PR25)). Within
the screen, some material is dropped (PR15, unseen) into the primary cone crusher (PR16,
unseen), to further crush material. This material drops (PR17, unseen) from the primary cone
crusher back to the primary crush screen for sorting. Some material, destined for the kiln
feed pile, drops (PR18) from the screen to the shale conveyor belt (PR19).
Screen belt (PR12)

Double deck screen (partially
(PR14) enclosed)
Transfer drop point

(PR13) from
screen belt to
double deck screen
Shale conveyor Transfer drop point

belt (PR19) (PR18) from double deck
screen to shale conveyor
belt (enclosed, not seen)
40
Primary Photograph 4, looking south:
A view of the shale conveyor belt (PR19) and the transfer of material dropping
(PR20) onto the shale kiln feed pile (PR21).
Shale conveyor belt

(PR19)
Transfer drop point

(PR20) from shale
conveyor belt to shale
Shale kiln feed pile kiln feed pile (PR21)
(PR21)
41
Primary Photograph 5, looking northwest:
A view of the second conveyor belt, the shale fines conveyor (PR23), transporting
material (PR24) from the double deck screen (PR15) to the shale fines pile (PR25).
There is also a loader that is used to load the shale fines to trucks (PR26).
Transfer drop point

(PR24) from shale Shale fines
fines conveyor belt conveyor belt
to shale fines pile (PR23)
Front end loader

used to load shale
fines onto trucks
(PR26)
Transfer drop point

(PR22) from double
Shale fines pile (PR25) deck screen to shale
fines conveyor belt
(enclosed, not seen)
42
KILN FEED AREA (KF)
EMISSION POINTS
PHOTOGRAPHS
43
Kiln Feed Area Photograph 1, looking southwest:
Underground and below the shale kiln feed pile (PR21), material drops (KF1, not
pictured) onto the #4 conveyor belt (KF3), which starts underground and extends
aboveground to transfer (KF4) material to the #5 conveyor belt (KF6). The #5
conveyor belt transports material to a drop point that deposits the material into the
kiln feed storage structure. A loader (not pictured) also transfers (KF2) material to
the #4 conveyor belt.
Transfer (KF4) from

#4 conveyor belt
(KF3) to #5 conveyor
belt (KF5)
#5 conveyor belt
(KF5) to shale
storage structure #4 conveyor belt (KF3)
(KF7) (partially underground)
44
Kiln Feed Area Photograph 2, looking northeast:
A full view the transfer (KF4) from #4 conveyor belt (KF3) to the #5 conveyor belt
(KF5), which transfers (KF6) to the shale kiln feed storage structure (KF7) through
an enclosed chute. The shale storage structure is partially enclosed with a roof and
a back wall.
Transfer drop point from

Transfer drop point
#5 conveyor belt (KF6)
from #4 conveyor
belt to #5 conveyor
belt (KF4)
# 4 conveyor belt
(KF3)
Kiln feed shale storage structure

#5 conveyor belt (KF5) (KF7)
45
Kiln Feed Area Photograph 3, looking east:
A close-up view of #5 conveyor belt (KF5) dropping (KF6) material through an
enclosed chute onto the shale kiln feed storage pile (KF7). The shale storage
structure is partially enclosed with a roof and a back wall.
Transfer drop point (KF6) Shale storage
from #5 conveyor belt to structure drop chute
shale storage structure (enclosed)
#5 conveyor belt (KF5)
Shale storage
structure
northern wall
Kiln feed
storage pile
Shale storage structure roof
(KF7)
46
Kiln Feed Area Photograph 4, underground and looking northwest:
The shale kiln feed storage pile (KF7) drops (KF8) material onto the kiln 1 feeder
belt (KF9), which then drops (KF10) onto the kiln1 lower belt (KF11). The kiln 1
lower belt extends outside from underground and transfers material to the kiln 1 top
belt (out of frame).
Transfer drop point (KF8)

from shale storage pile to Kiln
1 feeder belt (KF9)
Kiln 1 feeder belt (KF9)
Transfer drop point from

Kiln 1 feeder belt to Kiln 1
lower belt
Kiln 1 lower belt
47
Kiln Feed Area Photograph 5, looking north:
The kiln 1 lower belt (KF11) drops (KF12) material onto the kiln 1 top belt (KF13).
The kiln 1 top belt drops (KF14) material into the kiln 1 feed (KF15).
Transfer drop point (KF14,

enclosed) from Kiln 1 top
enclosed) from Kiln 1 lower belt
belt (KF13) to the Kiln 1
(KF11) to the Kiln 1 top belt (KF13)
feed (KF15, enclosed)
Kiln 1 top belt (KF13)

Kiln 1 feed (KF15, enclosed)
Kiln 1 lower belt (KF11)
48
Kiln Feed Area Photograph 6 looking northwest:
The kiln 1 feed (KF15, enclosed), feeds material through the kiln 1 rear chamber
system (KF16, enclosed) and the kiln 1 front seal (KF17, enclosed).
Kiln 1 feed (KF15, enclosed

and obscured) feeds
Kiln 1 rear chamber system (rim
material to kiln 1 rear
seal) (KF16, enclosed)
chamber system (KF16,
enclosed)
Kiln 1 front seal (KF17,

Rear Chamber System enclosed)
49
Kiln Feed Area Photograph 7: Underground and looking northwest, the shale kiln
feed storage pile (KF7) drops (KF18) material onto the Kiln 2 feeder belt (KF19),
which then drops (KF20) onto the Kiln 2 lower belt (KF21). The Kiln 2 lower belt
extends from underground to the outside.

from shale storage structure
to kiln 2 feeder belt (KF19)
Kiln 2 feeder belt (KF19)

Kiln 2 lower belt
from kiln 2 feeder belt to
(KF21)
kiln 2 lower belt (KF21)
50
Kiln Feed Area Photograph 8, looking southeast:
The Kiln 2 lower belt (KF21) drops (KF22) material onto the kiln 2 middle belt
(KF23), which drops (KF24) material onto the kiln 2 top belt (KF25). The top belt
drops (KF26) material into kiln 2 feed (KF27, enclosed), which goes directly into
kiln 2 rear chamber system (rim seal) (KF28). Material goes through, internally, to
the kiln 2 front seal (KF29, enclosed and not pictured).

enclosed) from kiln 2 top Kiln 2 top belt (KF25)
belt (KF25) to the kiln 2
feed (KF27, enclosed) Transfer drop point
(KF24, enclosed)
from kiln 2 middle
belt (KF23) to kiln 2
top belt (KF25)
Kiln 2 rear chamber

system (rim seal)
(KF28, enclosed)
Kiln 2 middle belt

(KF23)
enclosed) from kiln 2 lower belt
Kiln 2 lower belt (KF21)
(KF21) to kiln 2 middle belt (KF23)
51
Kiln Feed Area Photograph 9, looking northwest:
The kiln rim seal, which has a chute that can be opened for cleaning (KF30).
Off Photo
Rear Chamber System Kiln rim seal
52
Kiln Feed Area Photograph 10, looking west: The kiln rim seal chute is opened
(KF31) for cleaning.
Kiln rim seal cleaning chute
53
KILN AREA (KL) EMISSION
POINTS PHOTOGRAPHS
54
Kiln Area Photographs 1 and 2:
Underground and looking west, material from Kiln 1 drops (KL1, out of frame) to the Kiln 1
clinker cooler (KL2, unseen – in building). Looking north, material then drops (KL3) below
to the Kiln 1 clinker belt (KL4), which advances outside from underground.
Fugitive dust
source IDs KL1
(Kiln 1 material
drop) and KL2
(Kiln 1 clinker
cooler) originate
inside of this
building.
The kiln 1 clinker

belt (KL4) emerges
from underground
and extends outside
Material drops
The kiln 1 clinker (KL3) from kiln 1
belt (KL4), clinker cooler
partially
underground
55
Kiln Area Photograph 3:
Looking west, material from kiln 1 clinker belt (KL4) drops (KL5) to the kiln 1
clinker pile (KL6). Material from the kiln 2 clinker pile (KL12, not pictured) is also
transferred (KL13) to the kiln 1 clinker pile.
The kiln 1 clinker

Kiln 1 clinker belt belt drop point
(KL4) (KL5) onto kiln 1
clinker pile
Kiln 1 clinker pile

(KL6)
56
Kiln Area Photographs 4 and 5:
Looking west, material from kiln 2 drops (KL7, unseen – in building) to the kiln 2
clinker cooler (KL8, unseen – in building). Material then drops (KL9) below to the
Kiln 2 clinker belt (KL10), which advances outside from underground.
Fugitive dust source IDs KL7 (kiln 2 material

drop) and KL8 (kiln 2 clinker cooler) originate
inside of this building.
The kiln 2 clinker

belt (KL10)
emerges from
underground and
extends outside
Material drops The kiln 2 clinker

(KL9) from kiln 2 belt (KL10),
clinker cooler partially
underground
57
Kiln Area Photograph 6:
Looking west, material from kiln 2 clinker belt (KL10) drops (KL11) to the kiln 2 clinker pile
(KL12). Material in the kiln 2 clinker pile is transferred (KL13) to combine with the kiln 1
clinker pile (KL6). Material from the kiln 2 clinker pile (KL12) is also transferred (KL13) to
the kiln 1 clinker pile.
Kiln 2 clinker belt Material drops

(KL10) (KL11) from
belt to pile
Kiln 2 clinker pile

(KL12)
Material being
loaded for transfer
(KL13) to the Kiln
1 clinker pile
58
Kiln Area Photograph 7, looking north: This is the muck pile (KL14), from where
material is loaded (KL15, not pictured) and unloaded (KL16, not pictured).
Muck pile (KL14)
Kiln 2 clinker pile

(KL12)
59
FINISHING PLANT AREA (FP)
EMISSION POINTS
PHOTOGRAPHS
60
Finishing Plant Area Photograph 1, looking west: The material in the kiln 1 clinker
pile (KL6) is dropped (FP1, underground and not pictured) onto the #1 conveyor
(FP2), which begins underground and extends above ground.
#1 conveyor
(FP2)
Kiln 1 clinker
pile (KL6)
Kiln 1 clinker pile

(FP1, underground)
61
Finishing Plant Area Photograph 2, looking northwest:
The material on the #1 conveyor (FP2) drops (FP3) into the grizzly (FP4), which is a
small screen that sits on the lightweight aggregate feed platform. Material drops (FP5)
from the grizzly onto the grizzly reject pile (FP6).
Drop point (FP3) into

the grizzly (FP4)
Grizzly (FP4)
#1 conveyor (FP2)
Drop point (FP5)

area for material
rejected by
grizzly screening
Grizzly reject pile

(FP6)
62
Finishing Plant Area Photograph 3, looking north:
The accepted material from the grizzly drops (FP7) onto the #2 conveyor (FP8),
which then drops (FP9) the material to the triple deck finish mill screen (FP10).
#2 conveyor (FP8)
Drop point (FP7)

onto the #2
conveyor (FP8)
Drop point (FP9, inside

enclosure) into the triple Triple deck finish
deck finish mill screen mill screen (FP10,
(FP10, inside enclosure) enclosed)
63
Finishing Plant Area Photograph 4, looking northwest:
The material in the triple deck finish mill screen (FP10) drops (FP11) material onto the 3/4”
discharge conveyor (FP12). Material from the 3/4” discharge conveyor (FP12) then drops
(FP13, out of frame) onto the 3/4” to stockpile conveyor (FP14, out of frame).
Triple deck finish

mill screen
(FP10, enclosed)
Drop point (FP11,

inside enclosure) onto
3/4” discharge 3/4” discharge
conveyor (FP12) conveyor (FP12,
obscured from view)
64
Finishing Plant Area Photograph 5, looking east:
Material from the 3/4” discharge conveyor (FP12) drops (FP13) onto the 3/4” to
stockpile conveyor (FP14). Material on the 3/4” to stockpile conveyor then drops
(FP15) onto the 3/4” short term storage pile (FP16).
Drop point (FP15,

enclosed by chute)
onto 3/4” short term
storage pile (FP16)
3/4” stockpile
conveyor (FP14)
Drop point (FP13)

3/4” discharge Part of 3/4” short term
onto 3/4” stockpile
conveyor (FP12, storage pile (FP16)
conveyor (FP14)
obscured from view)
65
Finishing Plant Area Photograph 6, looking east: The material in the triple deck finish mill
screen (FP10) drops (FP17, internal and not pictured) material onto the 3/8” discharge
conveyor (FP18). Material from the 3/8” discharge conveyor drops (FP19) onto the 3/8” to
stockpile conveyor (FP20). Material on the 3/8” to stockpile conveyor drops (FP21) onto the
3/8” short term storage pile (FP22).
Triple deck finish Drop point (FP19)

mill screen (FP10, from 3/8” discharge
internal) conveyor to 3/8”
stockpile conveyor
(FP20)
3/8” stockpile
conveyor (FP20)
Drop point (FP17)
onto 3/8” discharge
conveyor (FP18)
Drop point (FP21)
from 3/8” stockpile
conveyor to 3/8”
short term storage
pile (FP22)
3/8” discharge
conveyor (FP18) 3/8” short term
storage pile (FP22)
66
Finishing Plant Area Photograph 7, looking east:
The material in the triple deck finish mill screen (FP10) drops (FP23, enclosed and not pictured)
material onto the oversize discharge conveyor (FP24). Material from the oversize discharge
conveyor drops (FP25) into the oversize hopper (FP26). The material in the oversize discharge
hopper (FP26) drops (FP27) onto the El Jay crusher speed conveyor (FP28). From here, material
drops (FP29) into the El Jay crusher (FP30) where the oversized material is crushed down into
Triple deck finish smaller sizes.
mill screen (FP10,
internal) Drop point (FP25,
enclosed with chute)
Drop point (FP23, Oversize hopper (FP26)
from FP24 to FP26.
not seen) from FP10
to FP24.
Oversize discharge
conveyor (FP24)
El Jay crusher speed

El Jay crusher conveyor (FP28)
(FP30) Drop point (FP29) Drop point (FP27) from
from FP28 to FP30. FP26 to FP28.
67
Finishing Plant Area Photograph 8, looking northeast:
After material is re-crushed in the El Jay crusher (FP30), it is dropped (FP31) onto the El Jay
discharge conveyor (FP32), which transfers (FP33) material to the #2 return conveyor (FP34).
The #2 return conveyor returns (FP35) material to the #2 conveyor (FP8), which brings the
material back (FP9) to the triple deck finish mill screen (FP10) for re-sorting.
Triple deck finish
mill screen (FP10, El Jay crusher (FP30)
#2 conveyor (FP8) internal)
Drop point
(FP31, obscured
from view) from
FP30 to FP32
Drop point (FP35) from

FP34 to FP8
Drop point (FP33, El Jay discharge

obscured from view) conveyor (FP32,
#2 return conveyor (FP34) from FP32 to FP34 obscured from view)
68
The material in the triple deck finish mill screen (FP10) drops (FP36, enclosed and not
pictured) material onto the fines to silo conveyor (FP37). Material from the fines to silo
conveyor drops (FP38) down an enclosed chute into the enclosed fines storage pile (FP39).
Drop point
(FP38) from
FP37 to FP39
Fines to silo
conveyor (FP37)
Drop point
(FP36, enclosed)
from FP10 to
FP37
Enclosed fines
storage pile (FP39)
69
A view of the open fines storage pile (FP40), which is to the immediate north of the
enclosed fines storage pile (FP39). Included in this photo is a view of the baghouse
dust silo 1 (FP41) and baghouse dust silo 2 (FP43).
Baghouse dust silo

2 (FP43)
Baghouse dust silo

1 (FP41)
Enclosed fines storage pile

(FP39)
Open fines storage pile

(FP40)
70
Finishing Plant Area Photograph 11, looking north: Material drops (FP42, underground, not
viewed) material from Baghouse dust silo 1 (FP41) onto the shipping belt (FP45, mostly
obscured from view). Material is also dropped (FP44) from Baghouse dust silo 2 (FP43) onto
the shipping belt. Material is then transferred (FP46) onto the stationary belt (FP47), which
transfers (FP48) the material to the radial stacker (FP49). The radial stacker drops (FP50)
material onto the Block mix short term storage pile 1 (FP51).
Baghouse dust silo Baghouse dust silo

Radial stacker (FP49) 1 (FP41) 2 (FP43)
Drop point (FP50) from

FP49 to FP51 Shipping belt (FP45)
Block mix short term

storage pile 1 (FP51)
Drop point (FP48) from Stationary belt Drop point (FP46) from
FP47 to FP49 (FP47) FP45 to FP47
71
Finishing Plant Area Photograph 12, looking north: The radial stacker (FP49)
transfers (FP50) material to block mix short term storage piles 1 through 6 (FP51
through FP56). Below is an example of what these short term storage piles may
look like at any given time.
Radial stacker (FP49)

Block mix short term Block mix short term

storage pile 1 (FP51) storage pile 3 (FP53)
72
Finishing Plant Area Photograph 13: Looking west, 3/4” long term storage pile 5
(FP57).
3/4” long term storage

pile 5 (FP57)
73
Finishing Plant Area Photograph 14: Looking northwest, a front-end loader is loading
(FP61) block mix on block mix short term storage pile 2 (FP52). A front-end loader
would similarly be used to load (FP58) 3/4” onto truck, load (FP59) 3/8” onto trucks,
load (FP60) clinker onto trucks, and load (FP62) block mix onto trucks.
Loading (FP61) of
block mix onto piles

74
FINES PROCESSING AREA
(FN) EMISSION POINTS
PHOTOGRAPHS
75
Fines Processing Area Photograph 1: Looking east, the 8x0 long term storage pile
(FN1), which is partially enclosed. The 8x0 pile (FN18, partially obscured) sits
outside and to the direct south of the 8x0 long term enclosure. The 4x0 fines feed
pile (FN2, not pictured) and the 4 mesh reject pile (FN14, not pictured) are also
stockpiles in the same row of stockpiles to the south of this enclosure in the fines
processing area. The 3/4” long term storage pile 6 (FN19, not pictured) sits to the
north of the pictured enclosure.
8x0 long term

storage pile
(FN1)
8x0 pile,
partially
obscured
(FN18)
76
Fines Processing Area Photograph 2, looking southwest: Block mix is loaded (FN3,
not pictured) into the Cedarapids feed hopper (FN4), which then drops (FN5)
material onto the feeder belt (FN6). The feeder belt transfers (FN7) the material
onto the screen feed belt (FN8).
Drop point
(FN7) from
FN6 to FN8
Cedarapids feed Feeder belt (FN6)

hopper (FN4)
Drop point (FN5)

from FN4 to FN6
Screen feed belt (FN8)
77
Fines Processing Area Photograph 3: Looking west, material is carried on the
screen feed belt (FN8) and dropped (FN9) from the screen feed belt to the Astec
2618 fines screen (FN10).
Drop point
(FN9, partially
Screen feed belt (FN8)
obscured) from
FN8 to FN10
Astec 2618 fines

screen (FN10)
78
Fines Processing Area Photograph 4, looking northeast: Material is separated though
the Astec fines screen (FN10) and is dropped (FN9) from the screen feed belt to the
Astec 2618 fines screen (FN10). Material that has not passed through the No. 4
sieve screen is transferred (FN11) to the #4s belt (FN12). Material that does not pass
through the No. 8 sieve screen is transferred (FN15, not pictured) to the #8s belt
(FN16, mostly obscured).
Astec 2618
fines screen
#8s belt (FN16, mostly (FN10)
obscured)
Drop point
(FN11) from
FN10 to FN12
#4s belt (FN12)
79
Fines Processing Area Photograph 5, looking northwest: A portable conveyor, the
#8s belt (FN17), is used to drop (FN18) material onto the 8x0 pile (FN18), which
sits to the south of the 8x0 long term storage pile (FN1). Similarly, the #4s belt
drops (FN12, not pictured) material onto the 4 mesh reject pile (FN14, not
pictured), which sits to the south of the 8x0 pile. Partially obscured in the
background, there is a front-end loader, which is used to load (FN20) screened fines
onto a truck, which is also in the background
Front-end loader, Drop point
which loads (FN20) (FN16) from
screened fines onto #8s belt
FN17 to FN18
trucks (FN17)
8x0 pile
(FN18)
80
BLOCK MIX AREA (BM)
EMISSION POINTS
PHOTOGRAPHS
81
Block Mix Area Photograph 1, looking southeast: Material is dropped (BM11) onto
the block mix long term storage piles 1 through 4 (BM1 through BM4) by way of
multiple, movable conveyor belts, which sit in the block mix area.
82
Block Mix Area Photograph 2, looking west: The block mix is loaded (BM5, not
pictured) into a portable screen, such as the Astec 710T (BM6) or the Reade screen
(BM7).
Astec 710T
portable screen
Reade screen (BM6)
(BM7)
83
Block Mix Area Photographs 3 & 4: Looking southeast, the block mix is loaded (BM8, not in
picture) onto the temporary block mix pile (BM9) for customer pickup. the block mix is
loaded (BM10) onto trucks and loaded (BM11) onto a block mix pile.
Block mix loaded

onto block mix pile
(BM11)
Block mix loaded

onto a truck
(BM10)
Temporary block
mix pile (BM9) for
customer pickup
84
ISLAND AREA (IS) EMISSIONS
POINT PHOTOGRAPHS
85
Island Area Photograph 1, looking northeast: An example of the 3/4” long term storage piles 1
through 4 (IS1 through IS4), which vary in size depending on customer demand. A 3/8” long
term storage pile (IS5, not pictured) and the block mix long term storage pile 5 (IS6, not
pictured) are also located in the island area of the facility. Material is loaded (IS7) onto the
3/4” pile (IS1 through IS4) or loaded (IS9) onto the 3/8” pile (IS5). The loading (IS8) of 3/4”
material onto trucks and the loading (IS10) of 3/8” material onto trucks also occurs in the
island area, but is not pictured.
3/4” long term

storage pile 4 (IS4)
86
BONEYARD AREA (BY)
EMISSION POINTS
PHOTOGRAPHS
87
Boneyard Area Photograph 1, looking southwest: A view of the boneyard shale
piles (BY1 and BY2), which vary in size.
88
APPENDIX F
DECEMBER 2013 STOCKPILE INVENTORY
89
90
91
92
APPENDIX G
ENGINEERING DRAWINGS OF KILN REAR CHAMBER SYSTEM AND RIM SEAL
CHUTES
93
94
95
96
97
98
99
APPENDIX H
FINES AND KILN SILO STUDY
100
FUGITIVE DUST EMISSIONS
CALCULATIONS
FOR LIGHTWEIGHT AGGREGATE FINES
STOCKPILES AND KILN FEED STOCKPILE
Prepared for:
Norlite, LLC
A Division of Tradebe Environmental Services, LLC
May 8, 2014
Prepared by:
SPEC Engineering, PLLC

349 Northern Boulevard, Suite 2
Albany, NY 12204
(518) 487-4800
SPEC Job No. 13-094
Page 1 of 14
101
INTRODUCTION
The Tradebe Environmental Services, LLC (Tradebe) Norlite facility, located in the City of Cohoes,
Albany County, New York, was inspected by the New York State Department of Environmental
Conservation (NYSDEC) in early 2012 and received a Notice of Violation (NOV) letter on May 9, 2013.
As part of this NOV letter, NYSDEC is requesting upgrades to the facility’s Fugitive Dust Plan (Plan)
because they have expressed concern regarding the Plan. Specifically, NYSDEC is concerned that two
existing material silos were removed for what Norlite identified as safety considerations and is requesting
information regarding the need for replacement of the former lightweight fines and kiln feed silos. The
current aggregate stockpiles in question, which are the subject of this study and report, are: a
substantially-enclosed fines stockpile in the former fines silo footprint (enclosed fines), an open fines
stockpile (open fines) that is located just to the north of the enclosed fines, and a substantially-enclosed
shale feed stockpile (kiln feed). The following report details SPEC’s efforts to evaluate the existing
material storage areas and estimates potential fugitive dust emissions from each source.
BACKGROUND INFORMATION
Tradebe approached SPEC to seek third-party evaluation of potential fugitive dust emissions at Norlite.
To do this, SPEC reviewed the adequacy and accuracy of the existing Plan. The existing Plan includes
data for fugitive dust sources and control methods for the Norlite facility from 1990 and 1995 and
estimates for proposed updates and changes to control methods and fugitive dust sources in 1990 and
1995. SPEC conducted an in-depth review of the former lightweight fines and shale feed silos to provide
a third-party estimate of whether or not replacement silos are needed. Specific information regarding the
former kiln feed and lightweight fines silos, as outlined in the existing Plan, is outlined below.
Former fines and kiln feed silos
The original lightweight fine aggregate material silo was referenced in the existing Plan multiple times on
the following pages: 3-6, 3-10, 3-14, 4-4, 5-2, 5-4, 5-10, 8-1, and 8-23 (Appendix A). This silo was also
mentioned in Table 8-1 of the existing Plan and in two letters from SCI-TECH, INC. to Timothy Lachell
of Norlite, dated December 14, 2001, and December 31, 2002. All of these references to the original silo
are merely mentions of there being a silo present, that it is a potential fugitive dust source, and suggested
improvements to the silo. Most of the references to the silo are about the screens for the silo and not the
silo itself. The silo is identified as housing fine aggregates.
Upon review of these references in terms of dust control, SPEC asserts that the silo was never taken into
account in the 1990 calculations as a control device used to mitigate dust emissions as it was never
explicitly mentioned. Further, the existing Plan Source ID 40 (“Fines Silo Screens”) has the following
description: “TSP emissions are generated from the screening of fines transferred to the fines silos. Two
Screens serve the three silos. The emissions are controlled by an enclosure.” When fugitive dust
calculations were completed in 1990 for the Source ID pages, a screen house existed on top of the silo,
serving as a control method for fugitive dust emissions from the conveyor belt/screen atop the silos. It is
this enclosure that the Source ID description mentions at the time of the 1990 calculation and not the silo
itself. The screen house was removed sometime between 1990 and 1993 due to changes in the material
handling process. There is confusion over the word “enclosure” referring to the fines silo itself, when
what is specifically referenced is the screen enclosure atop the silos. The silos themselves were never
calculated to be emission control devices.
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102
There is little mention of a kiln feed silo in the existing Plan. The few references in the existing plan are
in Tables 3-1, 3-2, 4-1, and 5-2, referring to “Silo Conveyor to Kiln Feed Silo” as a fugitive dust source,
but there is no description and no other substantial information about the kiln feed silo itself in the
existing Plan. Along these lines, no credit is ever applied to the kiln feed silo as an emissions control
device.
CURRENT CONDITIONS OF KILN FEED AND FINES CONTAINMENT
An aerial photograph showing the three (3) pile areas important to this report is included below as Photo
1.
Photo 1. Overhead map of the Norlite facility, showing the spatial locations of the three (3) areas in question in relation to each
other and in relation to the facility as a whole.
With the removal of the lightweight fines silos, the enclosed fines product is currently contained in a
structure made of square concrete blocks roughly eight (8) feet high and approximately thirty feet (30)
long on all sides. There are two (2) tiers of metal bracing above the concrete base covered by heavy tarps.
The roof of the original silo is still in place and helps to enclose the lightweight fines. A guarded material
chute drops in from above, through the roof and down into the fines enclosure. The enclosed chute sits
just above the stockpile within the structure, creating a short material transfer point. Below are a photo of
the fines stockpile structure and a diagram of the chute (Photo 2 and Figure 1).
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103
Photo 2. The enclosed fines structure, including chute coming in from above structure, tarp surrounding structure, and other
structure details.
Figure 1. Diagram showing the specs of the chute for the enclosed fines material structure (provided in Norlite’s existing Plan).
Page 4 of 14
104
The second material storage area is the open fines pile located on the northern side of the enclosed fines
structure. The open fines stockpile sits in a low profile and is situated in a topographic depression
adjacent to the enclosed fines structure. The open fines are substantially blocked by a three (3) to four (4)
foot high concrete retaining wall that is adjacent to the structure and is also blocked from wind erosion by
the enclosed fines structure itself. There is also a banded wind screen on the west side of the open fines
stockpile. Below are photos of the open fines storage area (Photos 3, 4, and 5).
Photo 3. View of open fines area from western side, showing the wind screen.
Photo 4. Open fines area, showing concrete wall on eastern side of pile which acts as a barrier against wind erosion.
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105
Photo 5. Open fines area, showing wind screen on western side of area.
With the removal of the former kiln feed silo, the kiln feed pile has a concrete wind wall on the north end
of the pile and is covered overhead by a newly constructed metal overhang. There is an enclosed material
chute that drops down from the conveyor above, through the roof, and ends just above the kiln feed
stockpile. Material is transferred from the bottom of the pile (surge pile) directly into a conveyor system
that delivers material into the kiln, giving the pile a concave shape. The kiln feed pile has a pile height
sensor that hangs down from the metal overhang of the enclosure and limits pile height. When the
material in the pile touches the sensor, an alarm sounds to alert personnel to stop feeding the kiln feed
pile. Below are photos of the kiln feed pile (Photos 6 and 7).
Photo 6. Kiln feed pile, showing concrete wind wall in back, metal overhang, and chute above pile.
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106
.
Photo 7. Close-up on back wall, chute, and height sensor that hangs above kiln feed pile. Note the limited accumulation of dust
on the wall and roof structure.
FUGITIVE DUST CALCULATIONS METHODOLOGY: KILN FEED, ENCLOSED FINES

STORAGE, AND OPEN FILES PILES
To calculate potential fugitive dust emissions, SPEC used equations from AP-42 Compilation of Air
Pollutant Emission Factors1 (Fourth and Fifth Editions, called referred to as AP-42 for the remainder of
this report) which specifically calculate emission factors from wind erosion and material drop operations.
These equations are the industry standard for calculating emissions in the aggregate industry. The
calculated emission factors were then used in AP-42’s general emissions equation in order to calculate the
total fugitive dust emissions from each source. Storage pile wind erosion calculations will be discussed
first, followed by drop point calculations.
The following is EPA AP-42’s general emission rate equation and takes into account activity rate, an
emission factor, and emission reductions from control methods.
 ER   ER 
E   A EF  1  1   1  2  ... (Equation 1)
 100   100 
E  emissions (lb/yr)
A  activity rate (units depend on the units of the emissions factor)
EF  emission factor (varies)
ER  emission reduction efficiency (%)
1
AP-42 Compilation of Air Pollutant Emission Factors, Fourth and Fifth Editions, United States Environmental
Protection Agency
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107
Note: Emissions reduction efficiencies can be compounded for multiple emissions reduction methods
(ER1, ER2, etc.), serving as a multiplying variable in the series.
The units on the activity rate depend on the units on the emission factor. As can be seen below, the units
of the emission factor for wind erosion are lb/day/acre. Therefore, the activity rate has units of day-
acre/year. The emission factor units for the drop point are lb/ton, so the activity rate units are ton/year.
Although AP-42 provides emission factors for numerous products and processes, they are generalized
factors based on studies that the EPA has conducted and may not be suitable for all processes. AP-42
provides many equations that can be used to calculate these emission factors, which typically provide
more accuracy than the factors that are provided by AP-42 because they use site- or process-specific
values to calculate the emission factors.
The following equation, taken from the fourth edition of AP-42, can be used to calculate the emission
factor for wind erosion on product stockpiles. This equation takes into account material silt content as
well as information regarding the site’s climate.
 s  365  p  f 
EF  1.7     (Equation 2)
 1.5  235  15 
EF  total suspended particulate emission factor (lb/day/acre)
s  silt content of aggregate (%)
p  number of days with 0.01 in of precipitation per year
f  percentage of time that the unobstructed wind speed exceeds 12 mph at the mean pile height
This equation takes into account material silt content and climate factors in order to obtain more accurate
results.
The emission factor for the drop operations onto the storage piles can be calculated using the AP-42
equation for drop operations. This equation is applicable to both batch drop operations, such as product
addition onto the open storage pile, and continuous drop operations, such as product addition onto the kiln
feed pile and the enclosed fine pile.
1.3
U 
 
5
EF  k (0.0032)   1.4 (Equation 3)
M 
 
 2 
EF  emission factor (lb/ton)
k  particle size multiplier (dimensionless)
U  mean wind speed (mph)
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108
This equation for drop operations takes into account mean wind speed for the site as well as the product
material moisture content. The particle size multiplier k is a dimensionless factor that is applied in order
to calculate emissions of different particulate matter.
The emission factor values obtained in Equations 2 and 3 were then applied to Equation 1 in order to
calculate the annual emissions from each of the three (3) emission sources.
FUGITIVE DUST ESTIMATES: METHODOLOGY AND INPUTS
During SPEC’s site visit on October 21, 2013, SPEC personnel observed the controls currently in place
and used these observations to determine which emission reduction efficiency values should be used for
each pile’s calculations. EPA-450/3-77-010Technical Guidance for Control of Industrial Process Fugitive
Particulate Emissions2 (EPA-450/3-77-010) and EPA-450/2-92-004 Fugitive Dust Background Document
and Technical Information Document for Best Available Control Measures3 (EPA-450/2-92-004) were
used as guidelines for assigning emission reduction efficiency values. Field observations were conducted
during dry, moderately high wind conditions.
All three (3) piles are subject to wind erosion and have material dropped onto them. The enclosed fines
storage pile and the kiln feed pile have emissions from the material drop operations onto them. The Open
fines storage pile does not have a drop point emission value to it due to the nature of the pile formation:
the pile forms as a result of the enclosed fines storage pile overflowing onto it rather than a conveyor or
front end loader manually adding material to it.
The enclosed fines storage pile was assigned emission reduction efficiencies of 20% for the roof and 75%
for the concrete enclosure for wind erosion calculations. For drop point calculations, the enclosed fines
storage pile is assigned emission reduction efficiencies of 75% for its enclosure and 75% for the
elongated drop chute, both observed in Photo 2 above.
The open fines pile does not have a defined enclosure and has limited built-in containment based on its
location. For wind erosion calculations, SPEC assigned emission reduction efficiencies of 50% for the
enclosed fines storage pile’s concrete wall that blocks wind to the open fines pile, 50% for wind reduction
due to the wind screen to the west of the pile, and 20% for the stockpile’s low height, which decreases the
potential for erosion. These control features for wind-borne erosion can be observed in Photos 3, 4, and 5
above. For drop point calculations, the concrete wall and wind screen were both given emission reduction
efficiency values of 50% each.
Based on field observations, SPEC assigned the kiln feed pile emission reduction efficiencies of 50% for
the roof, 75% for the concrete wind wall, and 20% for low pile height. Similar to the enclosed fines
storage pile, the kiln feed pile has an enclosed chute that drops material onto the pile. The storage pile’s
height is controlled by a height sensor that alerts personnel of high pile levels. Because the kiln feed pile
is located at the lower end of a steep incline, there is also built-in topographical shielding from wind. For
drop point calculations, SPEC assigned the following emission reduction efficiencies: 75% for the
concrete wall on the north side, 50% for the metal overhang above the storage pile, and 75% for the
2
EPA-450/3-77-010 Technical Guidance for Control of Industrial Process Fugitive Particulate Emissions, US EPA
March 1977
3
EPA-450/2-92-004 Fugitive Dust Background Document and Technical Information Document for Best Available
Control Measures, US EPA September 1992
Page 9 of 14
109
enclosed chute. All of these control features can be observed in Photos 6 and 7 above. These assigned
control efficiencies are consistent with EPA AP-42 and EPA-450/3-77-010. Relevant efficiency values
from these two documents are compiled in the following table.
Table 2. Control Efficiency Values

Emission points Control methods Control efficiencies
Wind erosion Enclosure 95%-99%
Watering 50%
Loading onto a pile Enclosure 70%-99%
Wind guard 50%
Adjustable/telescopic chutes 75%
Watering 50%
Material silt content and material moisture content was determined from sieve analysis data provided by
Norlite to SPEC. Although silt is typically defined as material that passes through the No. 200 sieve,
SPEC used a higher value in order to establish a conservative estimate of fugitive dust emissions. The
medians of the percentages of material passing through the No. 100 sieve and No. 200 sieve were used for
calculations.
SPEC obtained the values for p and f for Equation 2 through analysis of daily local weather data for
Albany International Airport in Albany, NY. This weather data collection site is 5.2 miles from the
Norlite site. Typical airport anemometer heights are between 20 feet to 50 feet high4. This gives us an
overestimation of the average wind speeds at the height of the storage piles, leading to conservative
fugitive dust emission numbers. The equation from the fourth edition of AP-42 was used instead of the
equation found in the fifth edition due to the availability of applicable accurate site-specific data. Storage
piles were assumed to be present 365 days per year for wind erosion calculations.
Rather than using one of the listed aerodynamic particle size multipliers from AP-42 (Table 3 below),
SPEC has used k=1 in order to account for larger total suspended particles (TSP) in the equation for drop
point emissions (Equation 3).
Table 3. AP-42 Drop Point Emissions Aerodynamic Particle Size Multiplier

< 30 µm < 15 µm < 10 µm < 5 µm < 2.5 µm
0.74 0.48 0.35 0.20 0.053
RESULTS AND ANALYSIS
Calculations
The following table summarizes the results of the wind erosion calculations using Equations 1 and 2. For
all three (3) storage piles, the following numbers were used: p = 139.4 days for number of days annually
with at least 0.01 in of precipitation, f = 11.6% for percentage of time with winds above 12 mph, and 365
days for the number of days annually that each pile is present.
4
Wind Resource Assessment Handbook: Fundamentals for Conducting a Successful Monitoring Program, AWS
Scientific, Inc., prepared for National Renewable Energy Laboratory, April 1997
Page 10 of 14
110
These calculations are updates to the calculations performed by SCI-TECH, INC. in the 1990s due to the
availability of newer fugitive dust emission factor estimation equations. Thus, although the SCI-TECH,
INC. report calculation numbers were accurate at the time, they are no longer an accurate representation
of the fugitive dust emissions at the Norlite site.
Table 4. Wind Erosion Emissions Calculations

Pile s Emission Area ER1 ER2 ER3 Emissions Emissions
(silt factor (acre) (lb/yr) (ton/yr)
content) (lb/day/acre)
Enclosed 6.95% 5.85 0.141 20% 75% - 60.21 0.0301
fines
Open fines 6.95% 5.85 0.046 50% 50% 20% 19.64 0.0098
Kiln feed 0.25% 0.21 0.087 50% 75% 20% 0.67 0.0003
The following table summarizes the results of the drop point calculations using Equations 1 and 3. For all
three (3) storage piles, the following numbers were used: k = 1 for particle size multiplier and U = 7.15
mph for average wind speed.
Table 5. Drop Point Emissions Calculations

Pile Activity M Emission ER1 ER2 ER3 Emissions Emissions
Rate (material factor (lb/yr) (ton/yr)
(ton/yr) moisture (lb/ton)
content)
Enclosed 85,000 2.05% 0.0049 75% 75% - 26.17 0.0131
fines
Kiln feed 244,028 2.00% 0.0051 75% 50% 75% 38.85 0.0194
By adding the values from the wind erosion calculations and the drop point calculations, SPEC has
estimated the annual emissions from each of these emission sources. These results are summarized in
Table 5.
Table 6. Total Emissions from Each Storage Pile

Emissions from wind Emissions from
erosion material drop point Total emissions
Pile (ton/yr) (ton/yr) (ton/yr)
Enclosed fines 0.0301 0.0131 0.0432
Open fines 0.0098 - 0.0098
Kiln feed 0.0003 0.0194 0.0198
Totals 0.0402 0.0325 0.0728
Page 11 of 14
111
CONCLUSION
Analysis of current piles
SPEC asserts that the current sum of 0.0728 tons of annual emissions potential is typical. Based on this
analysis, SPEC does not see the need for the reconstruction of the lightweight aggregate fines or kiln feed
silos.
Table 7. Current Relative Fugitive Dust Percentages

Pile Material Fines content Calculated Fugitive dust,
production (tpy) fugitive dust percentage of
(tpy) (tpy) potential fugitive
dust
Enclosed fines 85,000 5,908 0.0432 0.0007%
Open fines 52,000 3,614 0.0098 0.0003%
Kiln feed 244,028 610 0.0198 0.0032%
Total production 244,028 10,132 0.0728
Suggestions to further reduce fugitive dust emissions
Based on the emissions rates detailed in this report, SPEC does not recommend the installation of a new
silo. SPEC has no recommendations for improvements to the kiln feed enclosure. The kiln feed area is
well contained by its roof, its concrete wall, its surge pile, and its pile height restriction. Similar to the
kiln feed area, SPEC has no recommendations for improvements to the open lightweight fines pile that is
north of the enclosed fines structure aside from continued good housekeeping practices. The open fines
area is adequately contained by the banded wind screen, the concrete retaining wall that blocks wind,
maintenance of a low height profile, and its position in a topographic depression. The area also benefits
from the enclosed fines enclosure to the south, as the open fines area is effectively screened on three sides
from wind erosion.
Although the potential fugitive dust emissions are low, SPEC has several recommendations for the
enclosed fines structure. Though a new silo is not recommended, SPEC proposes the following alternative
cost-effective solutions for improving fugitive dust emissions from the enclosed fines enclosure.
 Improvements to the lightweight fines enclosure: Currently, the enclosure consists of concrete
blocks with tarps for two tiers and is open from the upper tarp to the roof. SPEC suggests that
the bottom tier of tarp be removed and sheet metal be installed in its place. If sheet metal is
not an option, SPEC recommends wind screen bands, similar to the banded wind screen, to be
installed in place of the lower tarp. This will reduce dust from both wind erosion and from
product accumulating on the tarp itself. The fabric of the lower tarp tends to accumulate and
concentrate fine material that then becomes fugitive dust. It is believed that sheet metal siding
will not accumulate the fine fraction and will adequately provide for wind screening above
the concrete blocks.
 Addition of misters: SPEC suggests the addition of water misters. Spraying the air around the
material will reduce the amount of fugitive dust that leaves the area surrounding the storage
pile. It is SPEC’s understanding that the material cannot be directly wetted because of
Page 12 of 14
112
customers’ moisture constraints. Misters will only add minimal moisture content to the fines
and should not exceed maximum moisture content limits.
 Addition of a height sensor above enclosed fines piles within the silo: The kiln feed storage
pile has a sensor hanging above the pile, highlighted in Photo 7 above. This sensor’s purpose
is to detect when the aggregate pile has reached the maximum height for operational
efficiency. When the aggregate reaches the sensor, it triggers a signal to stop the feed onto the
pile. Installation of a similar device in the fines enclosure will prevent material from
overstepping the concrete block walls.
 Housekeeping: Fugitive dust may also be reduced by additional pile housekeeping and
improved housekeeping methods. Housekeeping improvements include:
o More frequent clearing of fines that overstep the concrete block walls
o Repair or replace any damaged parts of the elongated chute
 Adding wind speed alarms to enclosed fines pile : Much like the height sensor suggested
above, a wind alarm would also provide an additional method of monitoring the potential for
fugitive dust emissions. An anemometer would serve as a sensor to wind conditions around
the facility, potentially hanging above a pile like the height alarm sensors do. According to
page 6 of a letter to Timothy Lachell from SCI-TECH dated December 14, 2001, this
instrument has already been installed near the eastern property boundary tree line. If relocated
to the fines structure, this alarm would notify Norlite personnel to observe the area or areas at
risk and use judgment to determine if the pile needs additional misting, needs additional
cover, if material loading activities should be suspended, etc.
Calculations estimating reduction of fugitive dust emissions from the enclosed fines pile
SPEC calculated an estimated reduction of fugitive dust emissions if a few suggested improvements were
implemented. If the enclosed fines structure were improved by adding the sheet metal as part of the
containment in place of the lower tarp, the emissions reduction efficiency would increase. SPEC assumes
this could increase the emission reduction of the enclosure from 75% to 90%. This improvement would
impact the emissions from both wind erosion and the drop point. If misters were employed around the
enclosed fines pile, water suppression could be added as an additional control method for the drop point
with an efficiency of 50%. The results of these improvements are summarized in the following two tables.
Table 8. Wind Erosion Potential Emissions with Improved Controls

Pile s Emission Area ER1 ER2 ER3 Emissions Emissions
(silt factor (acre) (lb/yr) (ton/yr)
content) (lb/day/acre)
Enclosed 6.95% 5.85 0.141 20% 90% - 24.16 0.0120
fines
Page 13 of 14
113
Table 9. Drop Point Potential Emissions with Improved Controls
Pile Activity M Emission ER1 ER2 ER3 Emissions Emissions
Rate (material factor (lb/yr) (ton/yr)
(ton/yr) moisture (lb/ton)
content)
Enclosed 85,000 2.05% 0.0049 90% 75% 50% 5.23 0.0026
fines
The total emissions from these three storage piles after improvements have been made to the enclosed
fines storage pile are summarized in Table 9.
Table 10. Total emissions from each storage pile

Emissions from wind Emissions from
erosion material drop point Total emissions
Pile (ton/yr) (ton/yr) (ton/yr)
Enclosed fines 0.0120 0.0026 0.0146
Open fines 0.0098 - 0.0098
Kiln feed 0.0003 0.0194 0.0198
Totals 0.0221 0.0220 0.0442
REFERENCES
1. AP-42 Compilation of Air Pollutant Emission Factors, Fourth and Fifth Editions, United States
Environmental Protection Agency
2. EPA-450/3-77-010 Technical Guidance for Control of Industrial Process Fugitive Particulate
Emissions, US EPA March 1977
3. EPA-450/2-92-004 Fugitive Dust Background Document and Technical Information Document
for Best Available Control Measures, US EPA September 1992
4. New Source Review (NSR) Emission calculations, Texas Commission on Environmental Quality,
Air Permits Division, May 2008.
5. Wind Resource Assessment Handbook: Fundamentals for Conducting a Successful Monitoring
Program, AWS Scientific, Inc., prepared for National Renewable Energy Laboratory, April 1997
Page 14 of 14
114
APPENDIX I
TEXAS COMMISSION ON ENVIRONMENTAL QUALITY, AIR PERMITS DIVISION,
NEW SOURCE REVIEW (NSR) EMISSION CALCULATIONS (2008)
115
Texas Commission on Environmental Quality
Air Permits Division
New Source Review (NSR) Emission Calculations
This information is maintained by the Chemical NSR Section and is subject to change.
Last update was made May 2008. These emission calculations represent current NSR
guidelines and are provided for informational purposes only. The emission calculations
are subject to change based on TCEQ case by case evaluation. Please contact the
appropriate Chemical NSR Section management if there are questions related to the
emission calculations.
Sample Petroleum Coke Storage and Transfer Calculations
The emissions resulting from the storage and transfer of petroleum coke can be calculated by
using the AP-42 emission factors and equations for aggregate handling and storage piles.
Aggregate Handling and Storage Piles

Total dust emissions from aggregate storage piles result from several distinct source
activities within the storage cycle:
1. Loading of aggregate onto storage piles (batch or continuous drop operations).

2. Equipment traffic in storage area.
3. Wind erosion of pile surfaces and ground areas around piles.
4. Load out of aggregate for shipment or for return to the process stream (batch or
continuous drop operations).
Drop Operations
Either adding aggregate material to a storage pile or removing it usually involves
dropping the material onto a receiving surface. Truck dumping on the pile or loading out
from the pile to a truck with a front-end loader are examples of batch drop operations.
Adding material to the pile by a conveyor stacker is an example of a continuous drop
operation.
The quantity of particulate emissions generated by either type of drop operation, in

pounds per ton of material transferred, may be estimated using the following empirical
expression:
1.3
⎛ U
⎞
⎜ ⎟
E
=
k(0.0032) ⎝
⎠
1.4
5
⎛ M
⎞
⎜ ⎟
⎝
2
⎠
116
Where: E = emissions factor (lb/ton)
k = particle size multiplier (dimensionless)
U = mean wind speed (miles/hr)
M = material moisture content (%)
The particle size multiplier in the equation, k, varies with aerodynamic particle size
range, as follows:
Aerodynamic Particle Size Multiplier (k)

< 30 μm < 15 μm < 10 μm < 5 μm < 2.5 μm
0.74 0.48 0.35 0.2 0.053
Drop Operation Example
Company A is capable of loading a maximum of 200 tons per hour and a total of 300,000 tons per
year of petroleum coke. The mean wind speed at the facility is 10 miles per hour while the
moisture content in the coke is 8 percent. PM10 emissions resulting from the drop operations
would be:
1.3
⎛ U
⎞
⎜ ⎟
E
=
k(0.0032) ⎝
⎠
1.4
5
⎛ M
⎞
⎜ ⎟
⎝
2
⎠
1.3
⎛ 10
⎞
⎜ ⎟
E = 0.35(0.0032)
⎝
⎠1.4
5

⎛ 8
⎞
⎜ ⎟
⎝
2
⎠
E
= 0.0004 lb PM 10 / ton coke
⎛ 0.0004lb PM 10 ⎞⎛ 200tons coke ⎞

HourlyEmissions =
⎜⎜ ⎟⎟⎜ ⎟
⎝ ton coke ⎠⎝ hr ⎠
HourlyEmissions = 0.08lb PM 10 / hr
⎛ 0.0004lb PM 10 ⎞⎛ 300,000tons coke ⎞⎛ 1ton ⎞

Annual Emissions =
⎜⎜ ⎟⎟⎜⎜ ⎟⎟⎜⎜ ⎟⎟
⎝ ton coke ⎠⎝ yr ⎠⎝ 2000lb ⎠
Annual Emissions = 0.06 TPY PM10
117
Conveyors
The transfer (drop) of material from one conveyor belt to a different conveyor belt should
be treated as a drop point and potential emissions should be calculated using the
methodology in the preceding example. However, drop of material from the conveyor
belt directly onto the storage pile is not considered a drop point. Emissions from
dropping material from the conveyor onto the pile are accounted for in calculation of
emissions from wind erosion that follows.
Fugitive emissions can be expected from the conveying and transferring of material due
to wind, belt vibration, scrapers or brushes, etc. For an estimation of fugitive emissions
along conveyors, a conservative assumption of one drop per 1,000 feet of conveyor
length is made.
Example
Company B uses a 2,000 foot conveyor to transport petroleum coke to its storage pile.
The conveyor is capable of transporting 25 tons per hour to the pile and, moves 4,000
tons of coke annually. Mean wind speed at this facility is 12 miles per hour and the
moisture content of the coke is 10 percent. The PM10 emissions resulting from this
conveyor would be:
1.3
⎛ U
⎞
⎜ ⎟
⎛ length of conveyor ⎞
E
=
k(0.0032) ⎝
⎠
1.4
5
⎜⎜ ⎟⎟
⎛ M
⎞ ⎝ 1,000 ft ⎠
⎜ ⎟
⎝
2
⎠
1.3
⎛ 12
⎞
⎜ ⎟
⎛ 2,000 ft ⎞
E
=
0.35(0.0032)
⎝
⎠
1.4
5
⎜⎜ ⎟⎟
⎛ 10
⎞ ⎝ 1,000 ft ⎠
⎜ ⎟
⎝
2
⎠
E
= 0.0007 lb PM 10 / ton coke
⎛ 0.0007 lb PM 10 ⎞⎛ 25tons coke ⎞

HourlyEmissions =
⎜⎜ ⎟⎟⎜ ⎟
⎝ ton coke ⎠⎝ hr ⎠
HourlyEmissions = 0.02lb PM 10 / hr
⎛ 0.0007 lb PM 10 ⎞⎛ 4,000tons coke ⎞⎛ 1ton ⎞

Annual Emissions =
⎜⎜ ⎟⎟⎜⎜ ⎟⎟⎜⎜ 2000lb ⎟⎟
⎝ ton coke ⎠⎝
yr ⎠⎝ ⎠
118
Annual Emissions = 0.0014 TPY PM10
Wind Erosion from Stockpiles
Emissions expected due to wind erosion of stockpiles may be estimated by:
13.2( Number of Active Days )( Acreage of the Pile )(Control Factor )

E=
2000
Where: E = Emissions from the pile (tons/yr)

Number of Active Days = Days per year where there is at least 8 hours of
activity occurring at the piles
Control Factor = For wet material, the control factor is 0.5
For sprayed material, the control factor is 0.3
For dry material, the control factor is 1
Example
Company C has a petroleum coke stockpile that covers 4 acres. There is activity at the site 300
days per year and the coke pile is routinely sprayed with water. PM10 emissions due to wind
erosion would be:
13.2( Number of Active Days )( Acreageof the Pile )(Control Factor )

E=
2000
13.2(300 )(4)(0.3)
E=
2000
E = 2.38 TPY PM 10
119
APPENDIX J
LOADER OPERATOR PROCEDURES
120
121

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Norlite, LLC

Tradebe Environmental Services, LLC

FUGITIVE DUST PLAN

SPEC Engineering, PLLC

Norlite Fugitive Dust Plan Page i

Norlite Fugitive Dust Plan Page ii

Norlite Fugitive Dust Plan Page iii

Norlite Fugitive Dust Plan Page iv

Norlite Fugitive Dust Plan Page v

Norlite Fugitive Dust Plan Page vi

Norlite Fugitive Dust Plan Page 1

Norlite Fugitive Dust Plan Page 2

Norlite Fugitive Dust Plan Page 3

4.1 Dust Generation

4.1.1 Wind Erosion

The following factors affect the threshold velocity of dust particles:

4.1.2 Vehicle Re-entrainment

Norlite Fugitive Dust Plan Page 4

4.1.3 Material Handling

4.2 Fugitive Dust Control

4.2.1 General Control Methods

Norlite Fugitive Dust Plan Page 5

4.2.2 Controls for Vehicle Re-entrainment

4.2.3 Controls for Material Handling

Norlite Fugitive Dust Plan Page 6

5.1 Kiln Feed Area

5.2 Kiln Area

5.3 Finish Plant Area

Norlite Fugitive Dust Plan Page 7

5.3.2 New Anemometer

5.3.3 Block Mix Conveyor to Radial Stacker Transfer Point Redesign

5.3.4 Drop Distance Rod on Radial Stacker

Norlite Fugitive Dust Plan Page 8

5.4 Fines Processing Area

5.5.2 Increased Road Watering Frequency

Norlite Fugitive Dust Plan Page 9

 Travel of coal delivery trucks;

Norlite Fugitive Dust Plan Page 10

6.1 Quarry Area

Norlite Fugitive Dust Plan Page 11

Figure 2. Primary Area Equipment

Norlite Fugitive Dust Plan Page 12

6.3 Kiln Feed Area

Figure 3. #4 and #5 Conveyors in the Kiln Feed Area

Norlite Fugitive Dust Plan Page 13

6.3.1 Removal of Kiln Feed Silo and Installation of New Enclosure

Figure 4. New Kiln Feed Storage Pile Enclosure

Norlite Fugitive Dust Plan Page 14

Figure 5. Chute for Cleaning Kiln Rim Seal

Norlite Fugitive Dust Plan Page 15

6.4 Kiln Area

Figure 6. Kiln Clinker Cooler to Clinker Belt Drop Point

Norlite Fugitive Dust Plan Page 16

6.4.1 Current Fugitive Dust Control Methodology

6.5 Finish Plant Area

Norlite Fugitive Dust Plan Page 17

6.5.1 Current Fugitive Dust Control Methodology

Norlite Fugitive Dust Plan Page 18

Figure 7. 3/4" Aggregate Drop Point

6.6 Fines Processing Area

Norlite Fugitive Dust Plan Page 19

Figure 8. Fines Processing Area

6.6.1 Current Fugitive Dust Control Methodology