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SPECIAL CONDITIONS

Permit Numbers 5933 and PSD-TX-63M3

EMISSION STANDARDS, FEDERAL APPLICABILITY, AND OPERATIONAL LIMITS

1. This permit covers only those sources of emissions listed in the attached table entitled "Emission Sources -

Maximum Allowable Emission Rates," and those sources are limited to the emission limits and other conditions

specified in that attached table. Compliance with the annual emission limits is based on a rolling 12-month year

rather than the calendar year. This permit authorizes start-up, shutdown, and maintenance (SSM) emissions

which comply with the emission limits in the maximum allowable emission rates table (MAERT).

2. Emission limits are based upon the permit application representations dated February 3, 2006, and subsequent

submittals dated June 19, 2006; July 5, 2006; August 24, 2006; September 29, 2006; and October 18, 2006.

3. These facilities shall comply with the applicable requirements of the following regulations:

A. The U.S. Environmental Protection Agency Standards of Performance for New Stationary Sources (NSPS)

promulgated in Title 40 Code of Federal Regulations Part 60 (40 CFR Part 60),

(1) Subpart A - General Provisions;

(2) Subpart F - Portland Cement Plants;

(3) Subpart Y - Coal Preparation Plants; and

(4) Subpart OOO - Nonmetallic Mineral Processing Plants.

B. The EPA regulations on National Emission Standards for Hazardous Air Pollutants (NESHAPS) for Source

Categories promulgated in 40 CFR Part 63,

(1) Subpart A - General Provisions; and

(2) Subpart LLL - Portland Cement Manufacturing Industry.

C. Kiln and Precalciner No. 1 (Kiln Line 1), identified as Emission Point Number (EPN) 1-DE-3, shall comply

with the TCEQ regulations in Title 30 Texas Administrative Code Chapter 117 (30 TAC Chapter 117),

Division 4 - Cement Kilns.

D. If any condition of this permit is more stringent than the regulations so incorporated, then for the purposes of

compliance, the permit shall govern and be the standard by which compliance shall be demonstrated.

4. The following contaminants and sources are subject to the federal Prevention of Significant Deterioration (PSD)

rules as adopted in 30 TAC § 116.160:

A. Particulate matter (PM), including particulate matter equal to or less than 10 microns in diameter

(PM/PM10), and sulfur dioxide (SO2) from all sources at site; and

B. Carbon monoxide (CO), nitrogen oxides (NOx), and volatile organic compounds (VOC) from Kiln and

Precalciner No. 2 (Kiln Line 2), identified as EPN 2-DE-3.

5. Stack emissions shall meet the following:

A. Kiln Line 1 NOx, 30-day rolling average,

(1) 1.95 lbs NOx/ton clinker, from April 1 through October 31; and

(2) 390 lbs per hour, from November 1 through March 31.
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B. Kiln Line 2,

(1) NOx - 1.95 lbs/ton clinker, 30-day rolling average;

(2) SO2 - 0.08 lbs/ton clinker, 12-month rolling average;

(3) PM - 0.007 grain per dry standard cubic foot (gr/dscf), front half;

(4) Total Hydrocarbons/VOC - 0.10 lb/ton clinker; and

(5) CO - 1.58 lb/ton clinker.

C. No. 2 Clinker Cooler, identified as EPN 2-DE-4, PM - 0.005 gr/dscf, front half.

D. Finish Mill No. 3, identified as EPN 2-GE-1, PM - 0.00137 grain/actual cubic foot (gr/acf), front half.

6. Opacity of emissions shall not exceed the following limitations, averaged over a six-minute period, except for those

periods, as applicable, described in EPA regulations in 40 CFR Part 60, Subpart A, § 60.11(c):

A. From the main kiln exhaust stacks,

(1) 20 percent from Kiln Line 1; and

(2) 10 percent from Kiln Line 2.

B. From the clinker cooler baghouse stacks,

(1) 10 percent from the Line 1 cooler, EPN 1-DE-4; and

(2) 10 percent from the Line 2 cooler, EPN 2-DE-4.

C. From the Finish Mills, identified as EPNs 1-GE1, 1-GE2, and 2-GE-1, no visible emissions.

D. From any transfer point on belt conveyors, 10 percent.

E. From any material, clinker, or cement handling baghouse or bulk storage silo baghouse, 5 percent.

F. From the rail and/or the truck loading points, 5 percent.

G. No visible emissions from stockpiles or material handling leaving the plant property boundary. If this condition is

violated, further controls shall be installed and/or implemented as required to limit visible emissions.

7. Kiln feed, production and operation hours are limited as follows:

A. Kiln Line 1, a maximum rate of 195 tons per hour of dry feed to the preheater tower; and

B. Kiln Line 2, a maximum clinker production of:

(1) 150 tons per hour, averaged over a 30-day period, and

(2) 1,250,000 tons per year, based on a rolling 12-month year.

8. Emissions of PM from the coal mill baghouse, identified as EPN 1-EE-1, shall not exceed 0.031 gr/dscf. Emissions

shall be determined by using the emission factor of 0.031 gr/dscf or by actual stack sampling information.

FUEL SPECIFICATIONS
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9. Fuels used in the cement kilns and precalciners shall meet the requirements of this condition.

A. Authorized fuels are as follows:

(1) For Kiln Lines 1 and 2:

(a) pipeline-quality natural gas containing no more than 0.25 grain of hydrogen sulfide and 5 grains of

total sulfur per 100 dry standard cubic feet;

(b) coal containing a maximum sulfur content of 2.5 percent by weight as burned;

(c) petroleum coke containing a maximum sulfur content of 5.0 percent by weight as burned; and

(d) tire-derived fuel (TDF), either whole tires or tire chips, containing a maximum sulfur content of

2.0 percent by weight as burned.

(2) For Kiln Line 1, alternate, non-hazardous fuels which meet the requirements of Special Condition No.

12. (01/00)

(3) Use of any other fuel or fuel additive not meeting Special Condition No. 12 shall require an

amendment to this permit.

B. Fuel usage restrictions for Kiln Line 1:

(1) Maximum total kiln and precalciner system heat input, based on fuel lower heating value (LHV), is

440 MMBtu/hr.

(2) Fuel sulfur is limited to a maximum of 3.4 percent by weight of total fuel input as burned.

(3) Petroleum coke shall:

(a) not be co-fired with TDF or other alternate fuels;

(b) be limited to:

(i) 52 percent (229 MMBtu/hr, LHV) of the total kiln system heat input while co-firing with

coal; and

(ii) 50 percent (220 MMBtu/hr, LHV) of the total kiln system heat input while co-firing with

natural gas, or with coal and natural gas.

(4) The TDF shall:

(a) enter the kiln system only in the pre-calciner riser duct or at the kiln hood;

(b) be burned only in substitution for coal and/or petroleum coke; and

(c) not exceed 25 percent (110 MMBtu/hr, LHV) of the total kiln system heat input.

C. Fuel usage restriction for Kiln Line No. 2: TDF shall not exceed 25 percent of the total kiln system heat

input.

D. Upon request by a representative of the TCEQ, federal, or any air pollution control program having

jurisdiction, the permittee shall provide a sample and/or an analysis of the fuels utilized in this facility or

shall allow air pollution control agency representatives to obtain a sample for analysis.

FLEXIBILITY IN ALTERNATIVE MATERIALS

10. The permittee is authorized to burn nonhazardous residue from lime softening/clarification processes at surface
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water treatment facilities, as an alternative raw material in the production of portland cement, in Kiln Line 1 and

2, with the following not-to-exceed limitations:

A. feed rate of residue - 5 tons per hour;

B. maximum substitution of residue - 2.56 percent of the total kiln feed; and

C. hourly metals input to the kiln feed from the residue - the metals input represented in the amendment

application dated May 12, 1998, for the use of filter catch material (CIWA filter residue) from a water

filtering process at the Channel Industries Water Association. (11/98)

11. Spent fluid catalytic cracking (FCC) unit and nickel catalyst may be fed to Kiln Line 1 with the following

limitations.

A. FCC catalyst shall not exceed a maximum rate of 7.6 tons per hour.

B. FCC catalyst approved for raw material substitution is subject to the representations made in the application

for the permit amendment approved February 18, 1997.

C. FCC catalyst and nickel catalyst with trace metal concentrations greater than the concentrations approved in

the referenced amendment may be used as raw material provided that the feed rate of such catalyst is

adjusted so that the total feed rate of each metal from catalyst use is no greater than the maximum feed rate

for that metal from catalyst use represented in the application for the referenced amendment. The maximum

metal feed rates from catalyst use approved in the referenced amendment appear in the permit file in the

submittal to the Texas Natural Resource Conservation Commission dated October 4, 1996 on the table

entitled "TXI Operations, LP; Hunter Cement Plant; Metals Removal Efficiency Determination With FCC

Catalyst."

12. In addition to the alternate materials allowed in Special Condition Nos. 10 and 11, this permit allows the use of

new alternative materials as supplements to or in lieu of Kiln Line 1 feedstocks in the clinker production process.

New alternative materials may be used if they meet the following conditions: (01/00)

A. The new alternate materials shall serve the same basic function as the material replaced, and the emissions

shall be emitted from the same location as the replaced material emissions.

B. The maximum system input rate for each trace metal identified and submitted as part of the permit

application shall not be exceeded. A summary listing of the trace metals and their respective application

rates are set forth in Appendix B of the June 1999 permit amendment application.

C. The use of any new or replacement material shall not result in an increase in total emissions or an increase in

toxicity from any emission point covered by Special Condition No. 1 over those set forth in Appendix B of

the June 1999 permit amendment application.

D. The use of any new or replacement material containing one or more of the trace metals not listed in

Appendix B of the June 1999 permit amendment application or use of these materials at a source not

evaluated as part of the permit application dated June 1999 (revised) will require an amendment to the

permit.

OPERATIONAL LIMITATIONS, WORK PRACTICES, AND PLANT DESIGN

13. All permanent in-plant roads shall be paved and cleaned as necessary to achieve maximum control of dust

emissions. Other areas on the property subject to vehicle traffic shall be watered, treated with dust-suppressant

chemicals, oiled, or paved and cleaned as necessary to achieve maximum control of dust emissions.

14. All quarry roads shall be sprinkled with water and/or chemicals as necessary.

15. Outgoing railroad cars and trucks used in transporting cement and coal shall be cleaned and maintained as

necessary to minimize fugitive dust.

16. Spillage of cement, clinker, or additives shall be immediately cleaned up and contained or dampened such that dust
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emissions from wind erosion, vehicle traffic, and other fugitive dust emissions are minimized.

17. All exposed stockpiles shall be sprinkled with water and/or dust-suppressant chemicals when appropriate and as

necessary to control dust emissions.

18. Coal and petroleum coke stockpiles shall be sprayed with water and/or chemicals as necessary to control the

emissions of dust to the minimum level possible under existing conditions.

19. All transfer points not enclosed or equipped with dust collection equipment shall be sprinkled with water and/or

dust suppressant chemicals when appropriate and as necessary to control dust emissions.

20. Water sprays shall be installed and operated as necessary at the feed hopper and at the transfer point where the

incline belt discharges into the coal feed bin.

21. All hood, duct, and collection systems shall be effective in capturing emissions from this equipment and in

preventing fugitive emissions from all buildings. The hood and duct system shall be maintained free of holes,

cracks, and other conditions that would reduce the collection efficiency of the emission capture system.

22. All air pollution abatement equipment shall be properly maintained and operated during the operation of these

facilities. Cleaning and maintenance of the abatement equipment shall be performed as recommended by the

manufacturer and as necessary so that the equipment efficiency can be adequately maintained.

23. Sampling ports and platforms shall be incorporated into the design of each kiln stack, the No. 2 Clinker Cooler

stack, and the No. 3 Finish Mill stack, according to the specifications set forth in the attachment entitled "Chapter

2, Stack Sampling Facilities." Alternate sampling facility designs may be submitted for approval by the TCEQ

Regional Director.

INITIAL DEMONSTRATION OF COMPLIANCE AND FUEL TESTING REQUIREMENTS

24. The permittee shall perform initial stack sampling and other testing to establish the actual quantities of air

contaminants being emitted into the atmosphere. Unless otherwise specified in this Special Condition No. 24, the

sampling and testing shall be conducted in accordance with the methods and procedures specified in Special

Condition No. 25. The permittee is responsible for providing sampling and testing facilities and conducting the

sampling and testing operations at his expense. The TCEQ Executive Director or his designated representative

shall be afforded the opportunity to observe all such sampling.

A. For Kiln Line 2, EPN 2-DE-3:

(1) Demonstrate compliance with the performance standards of Special Condition No. 3B, 5B, and the

hourly emission rates of the MAERT, applicable to normal operations, using the average of three onehour stack sampling test runs for each contaminant.

(2) Air contaminants to be sampled and analyzed under (1) above include: NOx, SO2, CO, VOC, H2SO4,

HCl, HF, PM, PM10, NH3, Hg, and dioxins/furans. Diluents to be measured include O2 or carbon

dioxide (CO2).

(3) Demonstrate compliance with the performance standard of Special Condition No. 6 applicable to normal

operations, using the average of 30 six-minute readings as provided in 40 CFR § 60.11(b).

(4) Kiln production during testing shall be representative of future operating conditions. If the kiln is unable

to operate at maximum rates during testing, then additional stack testing may be required when higher

production rates are achieved.

B. For the No. 2 Clinker Cooler, demonstrate compliance with the PM performance standards of Special

Condition Nos. 3B and 5C, using the average of three one-hour stack sampling test runs.

C. For the No. 3 Finish Mill, demonstrate compliance with the PM performance standard of Special Condition

No. 5D, using the average of three one-hour stack sampling test runs.
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D. For each Kiln Line 2 or modified Line 1 raw material, clinker, or finished product storage bin; conveying

system transfer point; bagging system; and bulk loading or unloading system, demonstrate compliance with

Special Condition No. 3B in accordance with the procedures specified in EPA regulations in 40 CFR Part

63, Subpart LLL.

E. For any Kiln Line 2 or modified Line 1 emission source not regulated under Special Condition No. 3B,

demonstrate compliance with the applicable opacity limits of this permit and 40 CFR Part 60, Subparts F, Y,

and OOO, using:

(1) If the source is a stack, 40 CFR Part 60, Appendix A, Reference Method 9; and

(2) if the source is a fugitive emissions, 40 CFR Part 60, Appendix A, Reference Method 22.

F. Requests to waive testing for any pollutant specified in this condition shall be submitted to the TCEQ Office

of Permitting, Remediation, and Registration, Air Permits Division. Test waivers and alternate or equivalent

procedure proposals for NSPS testing which must have EPA approval shall be submitted to the TCEQ

Austin Compliance Support Division.

G. Sampling as required by this condition shall occur within 60 days after achieving the maximum production

rate at which Kiln Line 2 will be operated, but not later than 180 days after initial start-up of Kiln Line 2 and

at other such times as may be required by the Executive Director of the TCEQ. Requests for additional time

to perform the sampling shall be submitted to the TCEQ Regional Office. Additional time to comply with

the applicable requirements of 40 CFR Parts 60 and 63 requires EPA approval, and requests shall be

submitted to the TCEQ Compliance Support Division in Austin.

TEST METHODS AND PROCEDURES

25. A. Sampling shall be conducted in accordance with the appropriate procedures of the TCEQ Sampling Procedures

Manual; EPA Methods in 40 CFR Part 60, Appendix A (in the following list Appendix A refers to Part 60

unless otherwise specified); 40 CFR Part 51, Appendix M; 40 CFR Part 63, Appendix A; EPA Conditional

Test Methods; and American Society for Testing and Materials (ASTM) as follows:

(1) Appendix A, Methods 1 through 4, as appropriate, for exhaust flow, diluent, and moisture

concentration;

(2) Appendix A, Method 5 or 17, modified to include back-half condensibles, for the concentration of PM;

(3) Appendix A, Method 5 or 17, for the filterable concentration of PM (front-half catch);

(4) Appendix A, Method 6, 6a, 6c, or 8, for the concentration of SO2;

(5) Appendix A, Method 7E for the concentrations of NOx and O2, or equivalent methods;

(6) Appendix A, Method 8 or a modified Method 8 for H2SO4;

(7) Appendix A, Method 9 for opacity;

(8) Appendix A, Method 10 for the concentration of CO;

(9) Appendix A, Method 19, for applicable calculation methods;

(10) Appendix A, Method 23, for dioxins/furans;

(11) Appendix A, Method 25A, modified to exclude methane and ethane, for the concentration of VOC

(to measure total hydrocarbon as propane);

(12) Appendix A, Method 26 or 26A, or Part 63, Appendix A, Method 320 or 321, for HCl and HF;
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(13) EPA Conditional Test Method 27 (CTM-027), for NH3;

(14) Appendix M, Methods 201A and 202, or Appendix A, Reference Method 5, modified to include

back-half condensibles, for the concentration of PM less than 10 microns in diameter, PM10;

(15) Appendix M, Methods 201A or Appendix A, Reference Method 5, for the filterable concentration of

PM less than 10 microns in diameter, PM10 (front-half catch);

(16) ASTM D6784-02, Standard Test Method for Elemental, Oxidized, Particle-Bound, and Total

Mercury in Flue Gas Generated from Coal-Fired Stationary Sources (also known as the Ontario Hydro

Method), or other approved EPA methods.

(17) Any deviations from those procedures must be approved by the Executive Director of the TCEQ

prior to sampling.

B. The TCEQ San Antonio Regional Office shall be given notice as soon as testing is scheduled but not less than

30 days prior to sampling to schedule a pretest meeting.

(1) The notice shall include:

(a) Date for pretest meeting.

(b) Date sampling will occur.

(c) Name of firm conducting sampling.

(d) Type of sampling equipment to be used.

(e) Method or procedure to be used in sampling.

(2) The purpose of the pretest meeting is to review the necessary sampling and testing procedures, to provide

the proper data forms for recording pertinent data, and to review the format procedures for submitting

the test reports. The permittee shall present at the pretest meeting the manner in which stack sampling

will be executed in order to demonstrate compliance with emission standards found in this permit,

40 CFR Part 60, Subparts F, Y, and OOO, and 40 CFR Part 63, Subpart LLL.

(3) Prior to the pretest meeting, a written proposed description of any deviation from sampling procedures

specified in permit conditions or TCEQ, EPA or ASTM sampling procedures shall be made available

to the TCEQ. The TCEQ Regional Director or the TCEQ Austin Compliance Support Division shall

approve or disapprove of any deviation from specified sampling procedures.

C. Information in the test report shall include the following data for each test run:

(1) hourly coal (or other fuel) firing rate (in tons);

(2) average coal Btu/lb as-received and dry weight;

(3) average clinker production rate in short tons per hour;

(4) control device operating rates, including SNCR reagent injection rate and baghouse inlet temperature;

(5) emissions in the units of the limits of this permit, lb/hr and lb/short ton of clinker produced, three-hour

or 30-day average, as appropriate; and

(6) any additional records deemed necessary during the stack sampling pre-test meeting.

D. Two copies of the final sampling report shall be forwarded to the TCEQ within 60 days after sampling is

completed. Sampling reports shall comply with the attached conditions of Chapter 14 of the TCEQ

Sampling Procedures Manual. The reports shall be distributed as follows:

One copy to the TCEQ San Antonio Regional Office.

One copy to the TCEQ Austin Office of Permitting, Remediation, and Registration,
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 Air Permits Division.

26. If the results of any testing while burning tire chip fuel, whole tire fuel, or spent catalysts indicate a prevention of

a significant deterioration major increase in carbon monoxide emissions or violation of any permit condition,

then the permittee shall immediately stop firing the tested fuel. An amendment to this permit shall be required

prior to further usage of a fuel for which authorization was terminated by this special condition.

CONTINUOUS DETERMINATION OF COMPLIANCE

27. Kiln Line 1 NOx Continuous Emission Monitoring System (CEMS). The permittee shall install, calibrate and

maintain a CEMS to measure and record the concentration of NOx from Kiln Line 1, EPN 1-DE-3. (10/01)

A. The CEMS shall meet the design and performance specifications, pass the field tests, and meet the

installation requirements specified in Performance Specification No. 2, 40 CFR Part 60, Appendix B.

B. Each system shall be zeroed and spanned daily, and corrective action taken when the 24-hour drift exceeds

two times the amount specified in Performance Specification 2, 40 CFR Part 60, Appendix B. Zero and span

is not required on weekends or holidays if instrument technicians are not normally scheduled on those days.

C. Each monitor shall be quality-assured at least quarterly using cylinder gas audits (CGA) in accordance with

40 CFR Part 60, Appendix F, Procedure 1, Section 5.1.2, with the following exception: a relative accuracy

test audit (RATA) is not required once every four quarters (i.e., four successive quarterly CGA may be

conducted). An equivalent quality assured method approved by the TCEQ may also be used. Successive

quarterly audits shall occur no closer than two months.

D. Excess emissions of NOx are each day during which the 30-day rolling average of emissions of NOx as

measured and recorded by the CEMS exceed the emission limitations listed on the MAERT.

28. Kiln Line 1 Continuous Opacity Monitoring System (COMS). The permittee shall install, calibrate and maintain a

COMS to measure and record the opacity from Kiln Line 1, EPN 1-DE-3. The Kiln Line 1 COMS shall follow

the requirements for the Kiln Line 2 COMS described in Special Condition No. 30.

29. For Kiln Line 1,

A. Daily average fuel use rates shall be used to demonstrate compliance with the fuel use restrictions of Special

Condition No. 9B. An LHV of 15,000 Btu/lb shall be used for TDF unless more representative batchspecific test data is available.

B. When petroleum coke is fired:

(1) the total hourly sulfur input to the precalciner and main burner shall be calculated, based on the measured

solid fuel feed rates and sulfur content, to demonstrate compliance with Special Condition No. 1;

(2) the sulfur content of coal, petroleum coke, and alternate solid fuels shall be tested daily; and

(3) a sulfur content of 2.0 percent by weight shall be used for TDF, unless more representative batch-specific

test data is available.

30. Kiln Line 2 CEMS and COMS.

A. For the Kiln Line 2 exhaust stack, EPN 2-DE-3, the permittee shall install, calibrate, operate, and maintain a

(1) CEMS to measure and record the concentration of SO2, NOx, and CO;

(2) continuous opacity monitoring system (COMS) to measure and record the opacity; and

(3) continuous flow rate sensor to measure and record the exhaust flow rate.

B. The CEMS shall meet the design and performance specifications, pass the field tests, and meet the
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installation requirements and the data analysis and reporting requirements specified in the applicable

Performance Specification Nos. 2 through 4, 40 CFR Part 60, Appendix B.

C. The COMS shall meet the design and performance specifications, pass the field tests, and meet the

installation requirements and the data analysis and reporting requirements specified in Performance

Specification No. 1 (PS-1), 40 CFR Part 60, Appendix B. In order to demonstrate compliance with PS-1, the

COMS shall meet the manufacturer’s design and performance specifications, and undergo performance

evaluation testing as outlined in 40 CFR Part 60, Subpart A, § 60.13. The TCEQ Regional Director shall be

notified 30 days prior to the certification.

D. The CEMS and COMS shall be zeroed and spanned daily and corrective action taken when the 24-hour

span drift exceeds two times the amounts specified in 40 CFR Part 60, Appendix B, or as specified by the

TCEQ if not specified in Appendix B. Zero and span is not required on weekends and plant holidays if

instrument technicians are not normally scheduled on those days, unless the monitor is required by a subpart

of NSPS or NESHAPS, in which case zero and span shall be done daily without exception.

E. Each CEMS shall be quality-assured at least quarterly in accordance with 40 CFR Part 60, Appendix F,

Procedure 1, § 5.1.2. All cylinder gas audit results and any CEMS downtime shall be reported quarterly to

the appropriate TCEQ Regional Director, and necessary corrective action shall be taken if the downtime

exceeds 10 percent of the kiln operating hours in the quarter. Failure to complete any corrective action as

directed by the TCEQ San Antonio Regional Office may be deemed a violation of the permit. For nonNSPS sources, an equivalent method approved by the TCEQ may be used.

F. Each SO2, NOx, and CO CEMS shall complete a minimum of one cycle of sampling, analyzing, and data

recording for each successive 15-minute period.

G. One-hour averages shall be computed from normally at least four, and a minimum of two data points equallyspaced over each one-hour period. The gaseous monitoring data shall also be reduced to units of the permit

allowable emission rates in pounds per hour and pounds per ton of clinker produced. Data recorded during

periods of CEMS breakdowns, repairs, calibration checks, and zero and span adjustments shall not be

included in the computed data averages.

H. The opacity monitor shall complete a minimum of one cycle of data recording for each successive tensecond period. Six-minute averages shall be computed from normally at least 36 and a minimum of 18 data

points equally-spaced over each six-minute period. Data recorded during periods of COMS breakdowns,

repairs, calibration checks, and zero and span adjustments shall not be included in the computed data

averages.

I. The TCEQ Regional Director shall be notified as soon as possible after the discovery of any CEMS or

COMS malfunction which is expected to result in more than 24 hours of lost data. Supplemental stack

concentration measurements may be required at the discretion of the appropriate TCEQ Regional Director in

case of extended CEMS or COMS downtime.

J. Each CEMS and the COMS shall be operational during 95 percent of the operating hours of the Kiln Line 2,

exclusive of the time required for zero and span checks. If this operational criteria is not met for the

reporting quarter, the permittee shall develop and implement a monitor quality improvement plan. The plan

should address the downtime issues to improve availability and reliability. The plan should provide

additional assurance of compliance including record keeping of reagent flow rates for NOx CEMS downtime

periods and for COMS, EPA Reference Method 9 support during daytime monitor downtime periods and

parametric support for nighttime monitor downtime periods.

K. The TCEQ San Antonio Regional Office shall be notified in writing at least 30 days prior to the quarterly

cylinder gas audit required by Appendix F in order to provide the TCEQ staff the opportunity to observe the

testing.

L. The SO2, NOx, and CO CEMS and the continuous flow rate sensor shall be used as a continuous emission

rate monitoring system for SO2, NOx, and CO.
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M. Recertification of the COMS, if required, shall be based on the requirements of 40 CFR Part 60, Appendix B,

PS-1 in effect at the time of initial certification.

31. Ammonia CEMS. Prior to start-up of Kiln Line 2, the holder of this permit shall install, calibrate, operate, and

maintain CEMS to measure and record the concentration of NH3 from EPNs 1-DE-3 and 2-DE-3. The CEMS

data shall be used to determine continuous compliance with the NH3 emission limits in the MAERT. Any other

method used for measuring NH3 slip shall require prior approval from the TCEQ San Antonio Regional Office,

with consultation between the Regional Office and the TCEQ Austin Air Permits Division.

32. Upon request by the TCEQ, the permittee, at his expense, shall make sufficient property line sampling, stack

sampling analysis, or other tests, to prove satisfactory equipment performance and compliance with this permit.

All sampling and testing procedures shall be approved by the TCEQ and coordinated with the regional

representatives of the TCEQ. All testing results shall be retained and submitted with all permit renewal

applications.

RECORDKEEPING

33. Records identified in this Special Condition No. 33 shall be made for each kiln line, maintained on-site for at least

five years, and made available for inspection by the TCEQ and any air pollution control program having

jurisdiction.

A. Raw materials:

(1) daily tons of limestone, clay, mill scale, gypsum, and anhydrite handled;

(2) hourly and daily tons of dry raw meal feed rates to the preheater;

(3) hourly and daily FCC catalyst, nickel catalyst, and water treatment residue feed rates and calculated

pounds of metals input from these materials for periods of feed substitution; and

(4) documentation of trace metal concentrations for each source of FCC catalyst, nickel catalyst, and water

treatment residue shall be obtained or the appropriate analyses shall be performed by the permittee.

B. Fuels:

(1) hourly and daily natural gas, coal, petroleum coke, TDF, and alternate fuel consumption in the

precalciner and main burner, in pounds and Btu (LHV);

(2) monthly values of the LHV of the coal and petroleum coke;

(3) batch-specific values, if any, of the LHV of TDF or alternate fuels; and

(4) for Kiln Line 1 only, when petroleum coke is fired,

 (i) daily test samples of sulfur content of coal, petroleum coke, and alternate solid fuels

(ii) batch-specific values, if any, of the sulfur weight percent of TDF; and

(iii) calculations of hourly total fuel sulfur input based on daily sulfur test samples

C. Production records:

(1) hourly and daily tons of clinker produced;

(2) daily kiln operating hours; and

(3) daily cement production.
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D. Upkeep of abatement devices:

(1) Records of preventive maintenance, scheduled maintenance, and repairs performed on any abatement

device. Records shall be made at the time each action occurs.

(2) Records of malfunctions in the process and malfunctions of any air pollution abatement devices.

34. A copy of this permit shall be kept at the plant site and made available at the request of personnel from the TCEQ

or the local air pollution control agency.

REPORTING REQUIREMENTS

35. The permittee shall comply with the applicable reporting requirements of NSPS, NESHAPS, 30 TAC Chapter 101,

Subchapter F, concerning Emissions Events and Scheduled Maintenance, Startup, and Shutdown Activities, and

30 TAC Chapter 122, concerning Federal Operating Permits.

BAGHOUSE UPGRADES PRIOR TO START-UP OF KILN LINE 2

36. Prior to initial start-up of Kiln Line 2, the permittee will retrofit the baghouses listed below with PTFE membrane

lined high efficiency bags, or equivalent, that achieve an outlet grain loading of PM of no more than 0.00137

gr/acf for the finish mill separator baghouses and 0.005 gr/dscf for the other listed baghouses. The TCEQ

Regional Office in San Antonio shall be contacted at least five days prior to operating Kiln Line 2 to provide an

opportunity to confirm that the baghouses have been upgraded under this special condition and the permit

representations of Special Condition No. 2.

Baghouse Name EPN

Finish Mill Separator No. 1 1-GE-1

Finish Mill Separator No. 2 1-GE-2

Rock Crushing and Transfer 1-AE-1

Air Slide Feed Bucket Elevator 1-DE-2a

Clinker Bin 1-FE-1

Clinker Barn 1-FE-2

Gypsum Transfer 1-FE-3

Gypsum Bins 1-FE-4

Clinker Merrick Feeder 1-FE-6

Clinker Transfer Point No. 1 1-FE-7

Fringe Bin 1-FE-8

Fringe Bin 1-FE-9

Gypsum/Anhydrite Merrick Feeder 1-FE-14

Clinker Bin 1-FE-16

Clinker into Hopper 1-FE-17

No. 1 Gypsum Transfer 1-GE4

Finish Silo Vent 1-HE-1

Finish Silo Vent 1-HE-2

FK Pump 1-HE-3

Load Bin 1-HE-4

Load Bin 1-HE-5

FK Pump 1-HE-6

Loadout 1-HE-7

Baghouse Name EPN

Loadout 1-HE-8

No. 3 Loadout Bin 1-HE-10
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Dated January 11, 2007