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<br />product. This material is pugmilled with water and loaded into trucks for storage <br />in our old quarr)~ pits. <br />The raw material containing most of the sulfur is our shale. The sulfur is <br />contained in the kerogen (shale oil) impregnated in the shale. Although there is <br />some fuel value contributed by the shale, the sulfur creates many process <br />problems, espec;ially the wasting of large amounts of CKD. We must purge the <br />system of sulfur and this typically requires the elimination of over 200 tons per <br />day from the kiln system. <br />We are experimenting with the reduction or elimination of this shale from our kiln <br />mix. We are introducing a small amount of flyash and increasing our use of <br />limestone in the kiln feed mi:K. This is showing promising results. It appears that <br />we have been able to cut CY;D loss in half; while, increasing production by 5 to <br />7%. The only n~sgative of this program so far is the fact that it may use up our <br />limestone supply in Dowe Flats faster than we originally planned. In addition, we <br />must dig much deeper and rnove a lot more overburden in order to recover the <br />additional limestone. This additional rock movement also requires changes to <br />existing permits. This is the second key area we have requested permit changes <br />for. <br />Permit Change Requests and Emission Netting <br />Boulder County is included in the metro-Denver "Non-Attainment with EPA <br />Ambient Air Quality Standards" regarding particulate. Although the air quality is <br />generally very good compared to these standards, there has been an historic <br />pattern where sensors locatc;d typically in Boulder and Denver have recorded 1 <br />or more days per year above this standard. As a consequence, Southdown or <br />any company can only change their permits if emissions are reduced or do not <br />increase by a significant level. <br />In order to make the permit changes required to support the projects outlined <br />above, it was necessary for Southdown to demonstrate improvement or no <br />significant increase in emissions ±o the State of Colorado Department of Public <br />Health and Environment. For the types of changes we are planning the typical <br />method is to complete a series of calculations which "model" past/current <br />operations and compare these emissions to "future" planned emissions. A <br />company is allovved to use its baseline from the last two years as the existing <br />operations. The company is also allowed to use improvements to its existing <br />and planned future operations in addition to the requested changes. <br />Southdown has been making several changes to operations which were used in <br />these calculations and will result in a major reduction in emissions within the next <br />6 months. <br />2 <br />