SPECIAL CONDITIONS

Permit Numbers 1360A and PSD-TX-632M1

GENERAL REQUIREMENTS AND FEDERAL APPLICABILITY

1. General Requirements

A. This facility shall be constructed and operated in accordance with and subject to the 

Texas Clean Air Act (TCAA) as amended, the Texas Health And Safety Code, Chapter 

382, (Vernon 1992) and all applicable rules, regulations, and orders of the Texas 

Commission on Environmental Quality (TCEQ) in effect at the time of issuance. Said 

construction and operation is subject to any additional or amended rules, regulations, and 

orders of the TCEQ adopted pursuant to the TCAA. (3/01)

B. A copy of this permit, the August 7, 1995, renewal application, the March 10, 1998 

amendment application, and all subsequent submittals pursuant to each application’s 

technical review shall be kept at the plant site and made available at the request of 

personnel from the TCEQ or any air pollution control agency with jurisdiction.

C. This permit covers only those sources of emissions listed in the enclosed table entitled 

“Emission Sources - Maximum Allowable Emission Rates;” as those sources are limited 

to the emission limits and other conditions specified in that attached table. If one 

emission rate limitation is more stringent than another emission rate limitation, then the 

more stringent limitation shall govern and be the standard by which compliance will be 

demonstrated. The annual rates are based on a rolling 12-month period.

D. Acceptance of a permit by a permit application constitutes an acknowledgment and 

agreement that the holder will comply with all rules, regulations, and orders of the 

Commission issued in conformity with the TCAA and the conditions precedent to the 

granting of the permit. If more than one state or federal rule or regulation or permit 

condition are applicable, then the most stringent limit or condition shall govern and be 

the standard by which compliance shall be demonstrated. Acceptance includes consent 

to the entrance of Commission employees and agents into the permitted premises at 

reasonable times to investigate conditions relating to the emission or concentration of air 

contaminants, including compliance with the permit. (3/01)

E. The facilities covered by the permit shall not be operated unless all air pollution 

emission capture and abatement equipment is maintained in good working order and 

operating properly during normal facility operations. This facility shall not produce a 

nuisance that may cause or contribute to a condition of “air pollution” as defined in Title 

30 Texas Administrative Code § 101.4 (30 TAC § 101.4). If the TCEQ Executive 

Director determines that such a condition or violation does occur, the holder of this 
SPECIAL CONDITIONS

Permit Numbers 1360A and PSD-TX-632M1

Page 2

permit shall implement additional abatement measures as necessary to control or prevent 

the condition or violation. This facility shall provide notification of a major upset and 

maintenance to the TCEQ Regional Office as required in 30 TAC §§ 101.201 and 

101.211. (9/05)

F. Upon request by the Executive Director of the TCEQ or local agency, the holder of this 

permit shall perform ambient air monitoring or other testing as required to establish the 

actual pattern and quantities of air contaminants being emitted into the atmosphere.

G. Records required by this permit shall be recorded in a form suitable for inspection and 

made available upon request by the TCEQ and any local air pollution control programs. 

Scheduled and unscheduled maintenance performed shall comply with 30 TAC § 

101.201 and 101.211, and these records shall be made available for inspection by the 

TCEQ and any local air pollution program having jurisdiction. Records shall be 

maintained on-site, at minimum, for a rolling two-year period. (9/05)

H. The facilities covered by this permit shall be constructed and operated as specified in 

this permit application and the Part B application required under Title 40 Code of 

Federal Regulations § 270.10 (40 CFR § 270.10). (3/01)

I. To the extent practicable, the permittee shall physically identify and mark in a 

conspicuous location all equipment that has the potential of emitting air contaminants as 

follows:

(1) The facility identification numbers as submitted to the Emissions Inventory Section 

of the TCEQ.

(2) The emission point numbers (EPNs) as listed on the maximum allowable emission 

rates table (MAERT).

J. At the request of the Executive Director of the TCEQ or designated representative, the 

holder of this permit shall provide an analysis of any fuel listed in Special 

Condition Nos. 8 and 9 or any available batch of waste-derived fuel or clinker quench 

wastewater received from a generator or supplier. The holder of this permit shall allow 

the Executive Director of the TCEQ or designated representative to obtain samples of 

these materials for analysis upon request. (3/01)

K.This permit action authorizes the construction of a dry process preheater precalciner kiln 

with associated raw material, solid fuel, and product handling systems, and associated 
SPECIAL CONDITIONS

Permit Numbers 1360A and PSD-TX-632M1

Page 3

abatement equipment. This action permits the construction of new sources and affects 

the operation of numerous other permitted, exempted, and grandfathered sources as listed 

below. (1/01)

(1) New Construction:

E1-27 Secondary Crusher

E1-28 Conveyor Transfer

E1-29 Enclosed Storage Building

E1-30 Underground Belt Feeder

E1-31 Raw Material Bins Baghouse

E1-32 Sand Hopper

E1-32a Sand Hopper to Conveyor

E2-7 Blending Silo Baghouse

E2-7a Blending Silo Air Slide Baghouse

E2-7b Pre-heater Tower Feed Baghouse

E2-11 Lime Delivery Road Emission

E2-11b Lime Tank Baghouse

E2-22 No. 5 Kiln Exhaust Stack

E3-52 Clinker Pan Conveyor to Belt Baghouse

E3-53 Clinker Transfer Baghouse

E3-54 No. 6 Finish Mill Bins Baghouse

E3-55 No. 6 Finish Mill Separator Baghouse

E3-56 No. 6 Finish Mill Baghouse

E4-12 Cement Silo Baghouse

E6-27 Solid Fuel Transfer

E6-28 Coal Bin

E6-29 Coal Weigh Feeder

E6-30 Coal Mill Exhaust Baghouse

E6-31 Coal Fines Baghouse

(2) Consolidation of all sources previously authorized under Permit Nos. 22329 

and X16044:

E1-24 Primary Crusher

E1-25 Transfer Point No. 1

E1-26 Transfer Point No. 2

E1-27 Transfer Point No. 3

E3-6 Surge Bin to 700, 703 to Pan Baghouse
SPECIAL CONDITIONS

Permit Numbers 1360A and PSD-TX-632M1

Page 4

E3-10 Clinker Silos 15-18 Baghouse

E3-11 Belt Transfer 707 Tail Pulley Baghouse

E3-12 Belt Transfer Head Wheel 703, 704, 721 Baghouse

E3-15 Transfer Head Pull 702 Pan; 748 Drag Baghouse

E3-24 Belt Transfer 707, 708, 780 Baghouse

E3-26 Belt Transfer 742, 703, 740, 741 Baghouse

E3-29 No. 2 Cooler Tunnel Baghouse

E3-30 No. 1 Cooler Tunnel Baghouse

E3-33 Transfer 708, 712, 713 Baghouse

E3-34 Surge Bin Transfer 713, 715, 717, 718 Baghouse

E3-35 Drag Conveyor 706 Baghouse

E3-37 Transfer 700, 704, 701 Baghouse

E3-38 712 Tunnel, Clinker Building Baghouse

E3-41 East Door, Clinker Building Baghouse

E3-42 West Door, Clinker Building Baghouse

(3) Consolidation of sources previously authorized under Permit No. 6698:

E1-7 Gypsum Drop to Pile

E3-23 Lower Reclaim Belt Baghouse

E3-50 Rail Drop to Hopper

E3-51 Hopper Drop to Belt

(4) Permitting of sources previously authorized under standard exemption: (1/01)

E1-30A Overland Conveyor Transfer

E1-31A Limestone Transfer Baghouse

E2-10a CKD Drop to Pile

E2-10b CKD Bin Baghouse

E2-12 Iron Component Road Emissions

E2-13 Iron Component Drop to Pile

E2-14 Iron Component Loader Road Emissions

E2-15 Iron Component Loader to Hopper

E2-16 Iron Component System Baghouse

(5) Permitting of previously grandfathered sources:

E1-1 Raw Material Delivery, Road Emission

E1-2 Cement Truck, Road Emission

E1-8 Anhydrite Pile, Drop Fugitive

E1-11 Sand Pile Drop

E1-12 Quarry Operations (Drilling and Blasting)

E1-13 Quarry Loader Road Emissions

E1-16 Limestone Belt Hopper
SPECIAL CONDITIONS

Permit Numbers 1360A and PSD-TX-632M1

Page 5

E1-20 Front End Loader Road

E1-21 Sand Truck Road Emissions

E1-22 CKD Truck Road

E4-1 Cement Silo Baghouse

E4-3 Cement Silo Baghouse

E4-5 Cement Silo Baghouse

E4-6 Finish Silo Group 1 Baghouse

E4-7 Finish Silo Group 1 Baghouse

E4-8 Finish Silo Group 1 Baghouse

E4-9 Rail Loading Baghouse

E4-10 Rail Loading Baghouse

E4-11 Cement Rail Loadout Baghouse

E4-13 Truck Loadout Baghouse

E4-16 Cement Truck Loadout Baghouse

E4-17 Cement Truck Loadout Baghouse

E4-18 Cement Truck Loadout Baghouse

E4-19 Packhouse Elevator Baghouse

E4-20 Bagging Machine Baghouse

E4-21 Masonary Rail Loading Baghouse

E4-22 Cement Truck Loadout Baghouse

E4-25 Masonry Baggings Baghouse

CKDL-1 CKD Bulldozer, Road Emission

CKDL-2 CKD Pile, Wind Blown Fugitive

2. Federal Applicability

A. These facilities shall comply with all applicable requirements of the U.S. Environmental 

Protection Agency (EPA) regulations in 40 CFR Part 60, Subpart A on Standards of 

Performance for New Stationary Sources promulgated, and the following:

(1) Subpart F - Portland Cement Plants; includes Kiln No. 5 (E2-22), Finish Mill 

No. 6, raw material and clinker storage, roller mills, and clinker cooler.

(2) Subpart Kb - Standards of Performance for Volatile Organic Liquid Storage 

Vessels; includes storage tanks in the hazardous waste storage and unloading area.

(3) Subpart Y - Coal Preparation Plants; includes the coal processing and conveying 

equipment (including breaker and/or crusher), coal storage systems, and coal 

transfer and loading systems

(4) Subpart OOO - Nonmetallic Mineral Processing Plants; includes the overland 
SPECIAL CONDITIONS

Permit Numbers 1360A and PSD-TX-632M1

Page 6

conveyor system and handling of all raw materials from the quarry operations to 

entry of the kiln system.

B. (1) Facilities involved with the treatment, storage, or disposal of hazardous waste, 

including Kilns No. 1 through 4 and the hazardous waste storage and unloading 

area, shall comply with all applicable requirements of the EPA regulations 

in 40 CFR Part 61, Subparts A, J, and FF on National Emission Standards 

for Hazardous Air Pollutants (NESHAPS) promulgated pursuant to authority 

granted under the Federal Clean Air Act, Section 112 as amended and contained.

These facility units shall also be operated in compliance with all applicable 

requirements relating to air quality in the Resource Conservation and Recovery 

Act (RCRA) and the rules promulgated thereunder, and in 30 TAC 

Chapter 335, Subchapter F (relating to Permitting Standards for Owners and 

Operators of Hazardous Waste Storage, Processing, and Disposal Facilities) 

promulgated by the TCEQ pursuant to the Solid Waste Disposal Act, Chapter 361 

of the Texas Health and Safety Code (Vernon 1992).

(2) These facilities, including Kiln Nos. 1 through 5, shall be operated in compliance 

with all applicable requirements of the EPA regulations in 40 CFR Part 63, 

Subparts A and LLL, the NESHAPS from the Portland Cement Manufacturing 

Industry. (9/05)

C. Prior to the initial start-up of Kiln No. 5 (E2-22), the permittee will: (1/01)

(1) Retrofit the baghouses of the existing Clinker Coolers No. 1 and 4 (EPNs E2-101 

and E2-107) with high efficiency singed nomex membrane lined bags, or 

equivalent, such that they will achieve an outlet grain loading of particulate matter 

(PM) of no more than 0.005 grain per dry standard cubic feet (gr/dscf). The 

baghouses of the existing Clinker Coolers Nos. 2 and/or 3 shall be retrofitted as 

described in this condition, if operated as specified in Special Condition No. 2D. 

(1/01)

(2) Retrofit the baghouses that control PM from the sources which formerly emitted 

from EPNs E3-21, E4-5, E4-6, E4-7, E4-8, E4-9, E4-10, E4-11, E4-12, E4-13, 

E4-16, E4-17, E4-18, E4-19, E4-20, E4-21, E4-22, E4-25 with PTFE membrane 

lined high efficiency bags, or equivalent, such that each will achieve an outlet grain 

loading of PM of no more than 0.005 gr/dscf.
SPECIAL CONDITIONS

Permit Numbers 1360A and PSD-TX-632M1

Page 7

In addition, the permittee will modify Permit No. 6698 to authorize a modification 

to the baghouse that controls Finish Mill No. 5 (EPN E3-21) with PTFE membrane 

lined high efficiency bags, or equivalent, such that the baghouse will achieve an 

outlet grain loading of PM of no more than 0.005 gr/dscf.

D. Kiln Nos. 2 and 3 (EPNs E2-4 and E2-6) are not authorized to operate under any 

circumstances while Kiln No. 5 (EPN E2-22) is operating or in start-up mode with the 

following exception. Any two of the four wet kilns may operate in conjunction with 

Kiln No. 5, provided the clinker cooler baghouse associated with any wet kiln that 

operates with Kiln No. 5 has been upgraded with high efficiency bags as described in 

Special Condition No. 2C(1). The TCEQ Arlington Regional Office shall be contacted 

at least five days prior to operating Kiln No. 2 and/or Kiln No. 3 in conjunction with 

Kiln No. 5, to provide an opportunity to confirm that the applicable clinker cooler 

baghouse has been upgraded with high efficiency bags. After the Kiln Nos. 2 or 3 

clinker cooler baghouse has been upgraded under this special condition, at least three of 

the four clinker cooler baghouses shall be operated with high efficiency bags at any time 

that all four wet kilns are in operation. (1/01)

E. The facilities proposed for construction in the March 10, 1998, permit application have 

been reviewed for maximum achievable control technology (MACT) in accordance 

with 30 TAC Chapter 116, Subchapter C. The conditions of this permit and MACT 

requirements support the determination of compliance with the MACT requirements. If 

the EPA subsequently promulgates a MACT standard applicable to these facilities which 

is less stringent than the determination made during the review of this permit, the 

requirements of this permit shall apply.

F. The following EPNs have relied upon reduced emissions as a result of retrofitting fabric 

filter baghouses with (PTFE) membrane lined high efficiency bags: EPNs E1-31, E2-7, 

E2-7B, E3-1, E3-2, E3-6, E3-11, E3-26, E3-33, E4-1, E4-2, E4-3, and E6-30. (1/01)

G. Kiln Nos. 1 through 4 (EPNs E2-2, E2-4, E2-6 E2-8) shall comply with all applicable 

requirements of 30 TAC 117, Subchapter B, Division 4 (Cement Kilns). (9/05)

FUGITIVE DUST SOURCES

3. Paved and Unpaved Roads
SPECIAL CONDITIONS

Permit Numbers 1360A and PSD-TX-632M1

Page 8

A. The roadways of this facility shall comply with 30 TAC § 111.147.

B. A street sweeper and other mobile equipment shall pick up debris from the plant roads 

and dump inside an enclosed structure. A front-end loader shall pick up the dust and 

debris from this structure and load it onto trucks for disposal. The contents of the truck 

shall be controlled as necessary to prevent emissions during transit.

C. Plant roads shall be controlled as represented in Tables 4.2 and 4.3 of the 

March 10, 1998, permit application. Current copies of these tables shall be kept with 

this permit. All roads shall be paved and either water sprinkled or swept, and 

quarry roads shall be sprinkled with water and treated with dust suppressant chemicals to 

control the emission of dust.

4. Solid Fuel Handling

A. Solid fuel (including coal and petroleum coke) stockpiles shall be sprayed with water 

and/or chemicals as necessary to control fugitive dust emissions to the minimize fugitive 

dust emissions.

B. Solid fuel crushing (EPNs 6 through 10) emission limits for Kiln Nos. 1 through 

No. 4 are based on a maximum hourly coal throughput of 150 tons and a maximum 

annual throughput of 280,000 tons of coal crushed. (9/99)

C. Water spray systems, reduced fall, full enclosures, and/or other abatement devices, as 

represented in Tables No. 4.1 and No. 4.4 and Appendix E of the March 10, 1998, 

permit application shall be operated, as necessary, to minimize fugitive dust emissions at 

the coal crusher, rail dump hopper, coal bin, weigh feeder, surge bin, coal mill, and all 

subsequent material transfer and drop points. Current copies of these tables shall be 

kept with the permit.

5. Raw Material Handling

A. Compliance with these permitted emission limits is based on a maximum hourly 

throughput rate of 1,600 tons and a maximum annual throughput rate of 4,000,000 tons 

of limestone and shale crushed. (9/99)
SPECIAL CONDITIONS

Permit Numbers 1360A and PSD-TX-632M1

Page 9

B. Opacity of emissions from any transfer point on belt conveyors must not exceed 

5 percent averaged over a six-minute period except for those periods described 

in 30 TAC § 111.111(a)(1)(E).

C. Opacity of emissions from the Primary and Secondary Crushers (EPNs E1-24 and 

E1-27) must not exceed 5 percent averaged over a six-minute period except for those 

periods described in 30 TAC § 101.201 and 101.211.

D. Sprays of foamable wetting agents shall be installed at the grizzly feeder that precedes 

the crusher inlet at the outlet of the crusher, and at all conveyor drop points except the 

final conveyor drop point which empties into the raw material storage and blending 

building. These sprays of wetting agents at the grizzly feeder and at the crusher outlet 

shall be operated at all times while the crusher is operating. The sprays of wetting agent 

installed at material transfer points shall be operated as necessary to achieve maximum 

control of dust emissions. (9/99)

E. Fixed conveyors shall be covered and transfer/drop points shall be enclosed.

F. Water spray systems, reduced fall, full enclosures, and/or other abatement devices, as 

represented in Tables No. 4.1 and No. 4.4 and Appendix E of the March 10, 1998 permit 

application shall be operated, as necessary, to minimize fugitive dust emissions 

associated with handling limestone, shale, sand, and iron component raw materials. 

Current copies of these tables shall be kept with the permit.

G. Outside storage piles of raw materials, including limestone, shale, sand, and iron 

components, shall be watered and/or treated with dust suppressant chemicals to achieve 

maximum control of dust emissions. (9/99)

6. Clinker and Finished Product Handling (1/01)

A. The cement distribution system to the main truck and rail car loading process shall not 

exceed 300 tons per hour per load spout. (1/01)

B. Opacity of emissions from clinker handling facilities, finish mills, storage silos and 

loadouts must not exceed 5 percent averaged over a six-minute period except for those 
SPECIAL CONDITIONS

Permit Numbers 1360A and PSD-TX-632M1

Page 10

periods described in 30 TAC § 101.201 and 101.211.

C. The top of all conveyor belts shall be covered. All conveyor belt transfer points shall 

be enclosed. To the extent necessary to achieve compliance with opacity limits, these

transfer points will either be vented to a dust collector or equipped with a water 

spray. The dust collectors or water sprays shall be operated as necessary to achieve 

compliance with the opacity limits.

D. Outgoing railroad cars and trucks used in transporting cement and clinkers shall be 

cleaned and maintained as necessary to minimize fugitive emissions. Dust emissions 

from cement loading into trucks or railcars shall be controlled with a self-sealing shroud 

at the loading point and venting of the displaced air to the fabric filter.

7. Miscellaneous Fugitive Requirements

A. Material collected by air pollution abatement equipment which is not returned to the 

process shall be disposed of on-site in a manner that minimizes any emissions in transit 

and prevents any emissions after disposal. A water sprinkler system or water truck shall 

be used to control dust emissions from any baghouse dust disposed of in on-site 

landfills.

B. All hoods, ducts, and collection systems shall be effective in preventing fugitive 

emissions. Compliance with this condition shall be determined by the EPA Reference 

Method 22 with no visible emissions persisting for more than one six-minute period 

in a half-hour.

C. As determined by a trained observer, no visible emissions shall leave the plant site. If 

this condition is violated, further controls shall be installed and/or implemented as 

required to limit visible emissions.

D. The active portion of the CKD landfill (CKDL-2) shall not exceed a size of 1.0 acre 

(4,050 m

2

) and be covered as necessary to minimize fugitive emissions. (9/99)

CEMENT KILN EMISSION STANDARDS AND FUEL SPECIFICATIONS

8. Kiln Nos. 1 through No. 4 (EPNs E2-2, E2-4, E2-6, and E2-8)

A. The maximum sulfur content of fuels fired in the Kilns (EPNs E2-2, E2-4, E2-6, and 

E2-8) shall not exceed the following:
SPECIAL CONDITIONS

Permit Numbers 1360A and PSD-TX-632M1

Page 11

(1) Pipeline-quality natural gas - 0.25 grain hydrogen sulfide and 5.0 grains total sulfur 

per 100 dscf.

(2) Fuel oil - 1.5 percent by weight.

(3) Coal or coke - 3.5 percent by weight.

(4) Waste-derived fuel - 1.0 percent by weight.

B. Emissions from the cement kiln exhaust stacks shall not exceed 30 percent opacity 

(except at times when the only fuel burned in a kiln is fuel oil in which case the opacity 

limit is 20 percent opacity averaged over a six-minute period) as determined by the EPA 

Reference Method 9 or by the continuous opacity monitoring systems (COMS) required 

pursuant to Special Condition No. 13A. Also, while firing pumpable hazardous waste, 

emissions from any stack shall not exceed 20 percent opacity on a six-minute 

average, except for uncombined water, other than for those periods described in 

30 TAC § 111.111.

C. The clinker production rate of each of Kiln Nos. 1 through 4 shall not exceed 

375,000 tons of clinker per year.

D. The average oxygen (O2) content measured at the kiln exit of Kilns No. 1 through 4 shall 

be maintained at/or above 0.75 percent by volume on a five-minute average. Monitoring 

of the kiln exit average O2 content will be in accordance with Special Condition No. 

13A.

E. Pursuant to 30 TAC § 111.124(2), hydrogen chloride (HCl) emissions from each kiln 

stack greater than 4.0 lbs/hr shall be controlled with a minimum removal efficiency of 

95.0 percent. At no time shall the emissions exceed the MAERT limits for HCl.

9. Kiln No. 5 (EPN E2-22)

A. Fuels fired in the main burner and precalciner of Kiln No. 5 (EPN E2-22) shall be 

limited as follows:

(1) Pipeline-quality, sweet natural gas containing no more than 5.0 grains of sulfur 

per 100 dscf.
SPECIAL CONDITIONS

Permit Numbers 1360A and PSD-TX-632M1

Page 12

(2) Coal containing no more than 3.5 percent sulfur by weight. (1/02)

No hazardous waste, as defined by the RCRA and the rules implementing that Act, may 

be fired in the dry process kiln or precalciner.

B. Opacity of emissions from the Kiln No. 5 (EPN E2-22) must not exceed 10 percent as 

determined by the EPA Reference Method 9 or by COMS, averaged over a six-minute 

period, except for those periods described in 30 TAC § 111.111 or as otherwise 

allowed by law.

C. The clinker production rate of Kiln No. 5 (E2-22) shall not exceed 2,800,000 tons of 

clinker per year. (9/05)

INITIAL DETERMINATION OF COMPLIANCE

10. Kiln Nos. 1 Through No. 4 (Epns E2-2, E2-4, E2-6, E2-8) - Compliance Testing Required 

by this Permit Was Conducted for Kiln Nos. 1 Through No. 4 in May 1988, July 1990, and 

April 1991.

11. Kiln No. 5 (E2-22)

A. Sampling ports and platform(s) shall be incorporated into the design of the kiln stack 

according to the specifications set forth in the enclosed entitled “Chapter 2, Stack 

Sampling Facilities.” Alternate sampling facility designs may be submitted for 

approval by the TCEQ Regional Director or the Director of the TCEQ Austin 

Compliance Support Division.

B. The holder of this permit shall, within 180 days of start-up of Kiln No. 5, perform stack 

sampling and other testing, as required, to establish the actual pattern and quantities of 

oxides of nitrogen (NOx), carbon monoxide (CO), sulfur dioxide (SO2), sulfuric acid 

mist (H2SO4), total hydrocarbons, front and back-half PM and PM equal to or less than 

10 microns in diameter within 10 percent of the maximum proposed production rate 

with the raw mill operating. Additionally, sampling within 10 percent of the maximum 

production rate shall be performed for SO2, and H2SO4 with the raw mill down. 

Sampling must be conducted in accordance with appropriate procedures of the TCEQ 

Sampling Procedures Manual and in accordance with the EPA Reference Methods. 

The holder of this permit is responsible for providing sampling and testing facilities and 

conducting the sampling and testing operations at its expense. (01/02)
SPECIAL CONDITIONS

Permit Numbers 1360A and PSD-TX-632M1

Page 13

(1) The TCEQ Arlington Regional Office shall be contacted as soon as testing is 

scheduled, but not less than 45 days prior to sampling to schedule a pretest 

meeting. 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.

The purpose of the pretest meeting is to review the necessary sampling and testing 

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

the format and procedures for submitting the test reports.

A written proposed description of any deviation from sampling procedures 

specified in permit conditions or the TCEQ or EPA sampling procedures shall be 

made available to the TCEQ prior to the pretest meeting. The TCEQ Arlington 

Regional Director or the Director of the TCEQ Austin Compliance Support 

Division shall approve or disapprove of any deviation from specified sampling 

procedures.

Test waivers and alternate/equivalent procedure proposals for New Source 

Performance Standards (NSPS) testing which must have the EPA approval shall 

be submitted to the TCEQ Austin Compliance Support Division.

(2) The deadlines for the sampling specified above may be extended. Requests for 

additional time to perform sampling shall be submitted to the TCEQ Arlington 

Regional Office. Additional time to comply with the applicable requirements of 

40 CFR Part 60 requires the EPA approval, and requests shall be submitted to 

the TCEQ Austin Compliance Support Division.

(3) Primary operating parameters that enable determination of production rate shall be 

monitored and recorded during the stack test. These parameters are to be 

recorded, at a minimum, once every 15 minutes and shall be reported on an hourly 

average basis.

In addition, operating parameters for the abatement equipment shall be recorded 

during each testing scenario. Parameters include the outlet temperature of the 

regenerative thermal oxidizer and corresponding stack exit temperature; the pH and 

density of the scrubber liquid; the recirculation, concentration, and absorbent flow 
SPECIAL CONDITIONS

Permit Numbers 1360A and PSD-TX-632M1

Page 14

rates to the scrubber; and pressure differential across the main and alkali bypass 

baghouses and their respective cleaning cycles. 

(4) Copies of each sampling report shall be forwarded to the TCEQ within 90 days 

after sampling is completed unless an extension is granted by the TCEQ Regional 

Office. Sampling reports shall comply with the enclosed provisions of 

Chapter 14 of the TCEQ Sampling Procedures Manual. The reports shall be 

distributed as follows:

One copy to the TCEQ Arlington Regional Office.

One copy to the TCEQ Austin Office of Permitting, Remediation, and Registration,

 Air Permits Division.

One copy to the TCEQ Austin Compliance Support Division.

12. Any Authorized Unit Covered by this Permit and Listed on the MAERT. (9/05)

A. If sampling of stacks or process vents is required, the permit holder shall contact the 

TCEQ Compliance Support Division prior to sampling to obtain the proper data forms 

and procedures. The permit holder is also responsible for providing sampling facilities 

and conducting the sampling operations or contracting with an independent sampling 

consultant. All sampling and testing procedures must be approved by the Executive 

Director of the TCEQ and coordinated with the regional representatives of the 

Commission. The TCEQ Arlington Regional Office shall be notified at least 45 days 

prior to the initial start-up of new or modified facility units authorized by this permit 

and prior to any required monitoring or sampling in such a manner that a representative 

of the TCEQ may be present at the time of the initial start-up, monitoring, or sampling.

B. Upon request by the Executive Director of the TCEQ, the permittee shall conduct 

sufficient sampling or other tests to prove satisfactory equipment performance. All 

calibration, sampling, and testing procedures shall be approved by the Executive 

Director of the TCEQ and coordinated with the TCEQ Arlington Regional Office 

representatives.

C. It shall be the responsibility of the permit holder to demonstrate or otherwise justify the 

equivalency of emission control methods, sampling or other emission testing methods, 

and monitoring methods proposed as alternatives to methods indicated in the conditions 

of this permit. Alternative methods shall be applied for in writing and must be 

reviewed and approved by the TCEQ Executive Director prior to their use in fulfilling 
SPECIAL CONDITIONS

Permit Numbers 1360A and PSD-TX-632M1

Page 15

any requirements of the permit.

CONTINUOUS DETERMINATION OF COMPLIANCE

13. Kiln Nos. 1 through 4 (EPNs E2-2, E2-4, E2-6, E2-8):

A. The holder of this permit shall operate, calibrate, and maintain continuous emission 

monitoring systems (CEMS) to measure and record the concentrations of NOx, SO2, O2, 

and opacity in the kiln stacks and kiln O2 at the kiln exits of each cement kiln. The 

holder of this permit shall operate, calibrate, and maintain continuous flow rate sensors 

to measure and record the exhaust flow rate in each kiln stack. (3/01)

(1) Each CEMS 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 the applicable Performance Specifications 

in 40 CFR Part 60, Appendix B (or equivalent procedures specified by the TCEQ 

Compliance Support Division for kiln exit O2 CEMS). Each flow rate sensor 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 40 CFR Part 60, Appendix B, Performance Specification 6. (The SO2 and 

opacity CEMS performance test results were approved by the TCEQ in August, 

1986). Performance tests for the NOx and O2 CEMS, flow rate sensors, and if 

required by the TCEQ, kiln exit O2 CEMS shall be conducted during the sampling 

completed in Special Condition No. 10. Written copies of the results shall be 

submitted within 60 days of completion of the tests to the TCEQ Arlington 

Regional Office and the TCEQ Compliance Support Division in Austin.

(2) Each CEMS shall be zeroed and spanned daily and corrective action taken 

when the 24-hour span drift exceeds two times the amount specified in 

40 CFR Part 60, Appendix B for opacity, SO2, O2, and NOx stack analyzers, or the 

amount specified by the TCEQ Austin Compliance Support Division for kiln exit 

O2 analyzers. 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.

(3) Each SO2 and NOx CEMS shall complete a minimum of one cycle of sampling, 

analyzing, and data recording for each successive 15-minute period. One-hour 

averages shall be computed from normally at least four, and a minimum of two, 
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data points equally spaced over each one-hour period.

Data recorded during periods of CEMS breakdowns, repairs, calibration checks, 

and zero and span adjustments shall not be included in the computed data 

averages. A minimum of 23 hourly averages shall be generated per day. 

Three-hour rolling SO2 averages shall be computed for each kiln. The three-hour 

rolling average shall consider each clock hour and the two preceding clock hours.

A 30-day rolling NOx average shall be computed for each kiln. A 30-day rolling 

average is generated for each day as the average of all the day's hourly NOx

emission data and the preceding 29 days of hourly emission data (representing only 

hours of kiln operation). The gaseous monitoring data shall be reduced to units of 

the permit allowable emission rate in pounds per hour (lbs/hr), calculated as a 

three-hour rolling average for SO2, and a 30-day rolling average for NOx at least 

once every week.

(4) The opacity monitor shall complete a minimum of one cycle of data recording for 

each successive ten-second period and one cycle of data recording for each 

successive six-minute period.

(5) The kiln exit and stack O2 monitor shall complete a minimum of one cycle of data 

recording for each successive 10-second period and one cycle of date recording for 

each successive 5-minute period. The kiln exit O2 monitoring data shall be 

reduced to five-minute average concentrations using normally at least 20 

equally-spaced data points from each five-minute period. (3/01)

(6) Each SO2 and opacity CEMS shall be operated in accordance with the 

quality-assurance/quality control (QA/QC) plan approved by the TCEQ 

Regional Director. Each NOx CEMS shall be quality-assured at least quarterly 

using cylinder gas audits (CGA). The CGA method to be used is contained 

in 40 CFR Part 60, Appendix F, Procedure 1, Section 5.1.2. The kiln exit O2

CEMS shall be operated in accordance with a QA/QC plan approved by the 

TCEQ Regional Director. The QA/QC plan for O2 CEMS shall be submitted 

within 60 days of completion of the tests completed in Special Condition No. 10 to 

the TCEQ Arlington Regional Office and Director of the TCEQ Compliance 

Support Division in Austin.

(7) All CGA exceedances of greater than ±15 percent accuracy and any CEMS 

downtime shall be reported to the TCEQ Arlington Regional Director, and 

necessary corrective action shall be taken. The TCEQ Regional Director shall 
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be notified as soon as possible after discovery of any CEMS 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 TCEQ 

Regional Director.

(8) For NSPS sources subject to Appendix F, the TCEQ Arlington Regional Office 

shall be notified at least 30 days prior to each annual relative accuracy testing audit 

(RATA) in order to provide the TCEQ staff the opportunity to observe the testing.

After the required demonstrations of initial compliance for these facilities, 

the CEMS and plans required in this condition shall be used to determine 

continuous compliance with the conditions of this permit and the rules and 

regulations of the TCEQ. Compliance with the emission limitations may also be 

determined by any TCEQ compliance sampling method.

(9) The CEMS for each kiln will not be inoperable in excess of 100 hours out of any 

calendar month.

14. Kiln No. 5 (E2-22)

A. The holder of this permit shall install, calibrate, operate, and maintain a COMS for 

opacity and a CEMS to monitor the in-stack concentrations of SO2, NOx, total 

hydrocarbons (THC), and CO from the Kiln No. 5 Stack (EPN E2-22). The holder of 

this permit shall install, calibrate, and maintain a continuous flow rate sensor to 

measure and record the exhaust flow rate in the dry kiln stack. (9/05)

(1) The CEMS, COMS, and flow rate sensor 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 the applicable Performance 

Specifications (No. 2, No. 4 and No. 8A for the CEMS, No. 1 for the COMS, and 

No. 6 for the flow rate sensor) of 40 CFR Part 60, Appendix B. (9/05)

(2) The CEMS, COMS, and flow rate sensor 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 
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required by a subpart of NSPS or NESHAPS, in which case zero and span shall be 

done daily without exception.

Each CEMS, COMS, and flow rate sensor shall be quality-assured at least 

quarterly in accordance with 40 CFR Part 60, Appendix F. At a minimum, Data 

Assessment Reports and any downtime shall be reported to the appropriate TCEQ 

Regional Director on a quarterly basis. Necessary corrective action shall be taken 

if the downtime exceeds 5 percent of the kiln operating hours in a quarter. Failure 

to complete any corrective action as directed by the TCEQ Arlington Regional 

Office may be deemed a violation of the permit. For non-NSPS sources, an 

equivalent method approved by the TCEQ may be used.

(3) Each CEMS and flow rate sensor shall complete a minimum of one cycle of 

sampling, analyzing, and data recording for each successive 15-minute period. 

One-hour averages shall be computed from normally at least four, and a minimum 

of two, data points equally-spaced over each one-hour period. Data recorded 

during periods of CEMS breakdowns, repairs, calibration checks, and zero and 

span adjustments shall not be included in the computed data averages.

The CEMS data shall also be reduced to units of the permit allowable emission rate 

in lbs/hr.

The COMS shall complete a minimum of one cycle of data recording for each 

successive ten-second 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.

(4) The TCEQ Regional Director shall be notified as soon as possible after the 

discovery of any COMS or CEMS 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 COMS or CEMS downtime.

(5) The TCEQ Arlington Regional Office shall be notified at least seven days prior to 

the quarterly CGA required by Appendix F in order to provide the TCEQ staff the 

opportunity to observe the testing.
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(6) The SO2, NOx, THC, and CO CEMS and the continuous flow rate sensor shall be 

used as a continuous emission rate monitoring system for SO2, NOx, THC, and CO 

to demonstrate continuous compliance with this permit. (9/05)

(7) The THC CEMS shall be installed and the requirements specified in paragraph (1) 

of this condition shall be completed within six months after issuance of the permit 

amendment to reduce operation of the regenerative thermal oxidizer. (9/05)
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Permit Numbers 1360A and PSD-TX-632M1

Page 20

B. For purposes of demonstrating compliance with the Special Condition No. 1C the 

holder of this permit shall monitor the wet scrubber as follows:

(1) Uptime (in hours) as a percentage of kiln operating hours.

(2) Scrubbing liquid pH, density, and flow rate recorded at least once per hour.

C. Within 90 days of start-up of Kiln No. 5 (E2-22), the permittee will submit revised 

tables for all new and affected facilities which accurately represent the as-built 

specifications of the equipment proposed.

D. (1) The holder of this permit must control THC emissions in the Kiln 5 gas stream to 

the levels identified in the MAERT by operating the existing regenerative thermal 

oxidizer when Kiln 5 is in operation. THC compliance will be based on a 30-day 

rolling average. (9/05)

(2) The holder of this permit shall install, calibrate, operate, and maintain a continuous 

emissions monitoring system (CEMS) to measure and record the concentration of 

THC in the Kiln 5 exhaust stack. The CEMS shall adhere to the conditions for 

CEMs listed for Kiln 5 under Special Condition 14 of this permit. (9/05)

(3) The THC CEMS requirements of this permit are applicable at all times Kiln 5 is in 

operation. (9/05)

REPORTING

15. Kiln Nos. 1-No. 4 (EPNs E2-2, E2-4, E2-6, and E2-8)

A. The holder of this permit shall submit to the TCEQ Arlington Regional Office quarterly 

CEMS reports. Such reports are required for each kiln which is required to be 

monitored pursuant to Special Condition No. 13. All such reports shall be postmarked 

by the 30th day following the end of each calendar quarter and shall include the 

following information for each monitor:

(1) The magnitude of excess emissions and the date and time of commencement and 

completion of each time period of excess emissions.

(2) For each period of excess emissions, the nature and cause of any malfunction 
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Permit Numbers 1360A and PSD-TX-632M1

Page 21

(if known), the corrective action taken, or preventive measures adopted.

(3) The date and time identifying each period during which the CEMS was inoperative 

(except for zero and span checks) and the nature of the system repairs or 

adjustments which occurred during the downtime.

(4) When no excess emissions have occurred or the CEMS has not been inoperative, 

repaired, or adjusted, such information shall be stated in the report.

(5) The reporting of excess emissions required by this condition does not relieve the 

holder of this permit from the notification requirements for emission events or 

scheduled maintenance as required by 30 TAC §§ 101.201 and 101.211. (9/05)

(6) All NOx CEMS data from the first quarter of monitoring following the NOx CEMS 

performance test shall be submitted to the TCEQ Arlington Regional Office with 

the first quarterly report following the test.

B. For the purposes of reporting pursuant to Special Condition No. 15A, noncomplying 

emissions are defined as follows:

(1) Noncomplying emissions of SO2 are each rolling three-hour average period of 

operation during which the average hourly emissions of SO2, as measured and 

recorded by the CEMS, exceed the emission limitations of the MAERT.

(2) Noncomplying emissions of NOx are each rolling 30-day average period of 

operation during which the average hourly emissions of NOx, as measured and 

recorded by the CEMS, exceed the emission limitations of the MAERT.

(3) Noncomplying emissions of opacity are each six-minute period of operation during 

which the average opacity, as measured and recorded by the CEMS, exceeds the 

emission limitation of Special Condition No. 8B.

(4) Noncomplying kiln stack emissions of organic compounds, HCl, hydrogen 

fluoride, or metals are each period during which the laboratory and feed 

rate calculations of Special Condition No. 22A(6) predict an exceedance of 

the emission limitations of Special Condition No. 1C.

16. Kiln No. 5 (E2-22)

A. In addition to applicable NSPS reporting requirements, the holder of this permit shall 
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Page 22

submit one copy of quarterly CEMS and COMS reports to the TCEQ Arlington 

Regional Office in a format deemed acceptable by the TCEQ Regional Office. All 

reports shall be postmarked by the 30th day following the end of each calendar quarter 

and shall include the following information for each monitor:

 (1) The date and duration of time from the commencement to the completion of an 

event which resulted in excess emissions of any pollutant.

 (2) The date and time of the commencement and completion of each specific time 

period of excess emissions within that event.

 (3) The total time duration of excess emissions.

 (4) The magnitude of the emissions, including the highest emission rate, and the 

average emission rate. All excess emissions shall be converted into the units of 

the permit. All conversion factors and equations shall be included.

 (5) The nature and cause of any malfunction resulting in excess emissions and the 

corrective action taken and/or preventative measures adopted.

 (6) The date and time identifying each period during which a CEMS or COMS was 

inoperative, except for zero span checks, and the nature of the system repairs 

and/or adjustments which occurred during the downtime.

 (7) When no excess emissions have occurred or the CEMS or COMS have not been 

inoperative, repaired, or adjusted, such information shall be stated in the report.

 (8) The total tons of SO2, NOx, THC, and CO emitted during the quarter and the total 

hours of kiln operation during the quarter shall be reported; and the total hours of 

raw mill operation during the quarter shall be maintained on-site and in a form 

suitable for inspection. (9/05)

 (9) In addition to the other information required in this special condition, a summary 

of the excess emissions shall be reported as required by Subpart A of 40 CFR 

Part 60.

(10) The reporting of excess emissions required by this condition does not relieve the 

holder of this permit from notification requirements of emission events as required 

by 30 TAC § 101.201 or notification of scheduled maintenance as required by 30 

TAC § 101.211. (9/05)
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(11) Quarterly CGA reports and RATA pursuant to Appendix F of 40 CFR Part 60.

B. For the purposes of reporting pursuant to Special Condition No. 16A, excess emissions 

are defined as follows: (3/01)

(1) Excess emissions of SO2 are each rolling averaging period of operation specified 

in the MAERT during which the hourly average emissions of SO2 as measured and 

recorded by the CEMS, exceed the emission limitations of the MAERT.

(2) Excess emissions of NOx are each period of operation during which the 30-day 

rolling average of emission of NOx as measured and recorded by the CEMS, 

exceed the emission limitations of the MAERT. (3/01)

(3) Excess emissions of CO are each one-hour average period of operation during 

which the hourly average emissions of CO, as measured and recorded by the 

CEMS, exceed the emission limitations of the MAERT.

(4) Excess periods of opacity are each six-minute period of operation during which 

the average opacity, as measured and recorded by the COMS, exceed the emission 

limitations of Special Condition No. 9B.

(5) Excess emissions of THC are each daily period of operation during which the 

30-day rolling average emission of THC as measured and recorded by the CEMS, 

exceed the emission limitations of the MAERT. (9/05)

RECORDKEEPING

17. A copy of the permit along with information and data sufficient to demonstrate compliance 

with the permit shall be maintained in a file at the plant site and made available at the 

request of personnel from the TCEQ or any air pollution control program having 

jurisdiction. For facilities that normally operate unattended, this information shall be 

maintained at the nearest staffed location within Texas specified by the permit holder in the 

Part B permit application. this information shall include, but is not limited to, production 

records and operating hours. Additional recordkeeping requirements may be specified in 

special conditions of this permit. Information in the file shall be retained for at least two 

years on a rolling retention basis following the date that the information or data is obtained. 
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Permit Numbers 1360A and PSD-TX-632M1

Page 24

(03/01)

18. Kilns No. 1 through 4 (EPNs E2-2, E2-4, E2-6, and E2-8)

A.The CEMS Records Pursuant to Special Condition No. 13A

(1) Average hourly NOx, SO2, and O2 concentrations, and six-minute average opacities 

which are monitored pursuant to Special Condition No. 13A; and

(2) The holder of this permit shall maintain a raw data file of all measurements 

(including continuous monitoring systems, monitoring device, and performance 

testing measurements), all continuous monitoring device calibration checks and 

adjustments, and maintenance performed on these systems or devices. The file 

shall be kept in a permanent form suitable for inspection.

(3) The records required in this condition shall be maintained at the plant site on 

a rolling two-year retention basis following the date of such measurements, 

maintenance, reports, or records and shall be made available to the TCEQ or 

any local air pollution agency having jurisdiction, upon request.

19. Kiln No. 5 (E2-22)

The following records shall be kept and made available upon request to the TCEQ or any air 

pollution control program having jurisdiction. Records shall be maintained on-site on a 

rolling two-year retention basis.

(1) Daily clinker production rates reported in tons per hour and summed on an annual basis.

(2) Daily fuel consumption of coal and natural gas. Fuel consumption records shall be 

summed monthly.

(3) Fuel sulfur content for coal shall be obtained with each fuel contract and recorded as a 

percent weight. Sulfur content may be verified by a vendor statement, on-site analysis 

or third-party analysis. Fuel sulfur records for coal need only be updated if the supplier 

is changed.

(4) Fuel sulfur content for natural gas in grains per 100 dscf. A single vendor statement 

verifying compliance with the natural gas sulfur limits of this permit shall suffice in 

complying with this requirement. Fuel sulfur records for natural gas need only be 

updated if the supplier is changed.
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(5) Daily amounts of raw material inputs to the kilns reported by type and in lbs/hr.

(6) Malfunctions of any air pollution abatement systems. 

(7) Documentation of air pollution control equipment maintenance and repair.

(8) Continuous monitoring and recording of opacity shall be performed for EPN E2-22 as 

detailed in Special Condition No. 14A(3).

20. Raw Material Handling

A. Daily and annual throughput records for limestone, shale, anhydrite, iron components, 

and records of maintenance and malfunction of pollution abatement equipment shall be 

kept on-site for a rolling two-year period and made available at the request of TCEQ and 

local air pollution control programs.

B. The permittee shall maintain documentation which demonstrates that the overland 

conveyor system is achieving compliance with all conditions of the permit. This 

documentation shall consist of a statement explaining how each requirement in a 

condition is being met. It will also include a sample of each record sheet required to be 

maintained by any condition.

21. Clinker Handling System

A. Daily production records shall be recorded and made available for inspection by the 

TCEQ and any local air pollution control programs. Preventative maintenance, 

scheduled maintenance, and repair maintenance performed shall comply with the 30 TAC 

§ 101.211, and these records shall be made available for inspection by the TCEQ and any 

local air pollution program having jurisdiction. Records shall include daily cement 

production and malfunctions in the process; daily raw material processing and handling; 

and malfunctions of any air pollution abatement device system(s). These records shall 

be summed monthly and shall be maintained on-site for a rolling two-year period. (9/05)

B. The permittee shall maintain documentation which demonstrates that the clinker handling 

system is achieving compliance with all conditions of this permit. This documentation 

shall consist of a statement explaining how each requirement in a condition is being met. 

It will include a sample of each record sheet required to be maintained by any condition.
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Page 26

WASTE-DERIVED FUEL AND CLINKER QUENCH WASTEWATER CONDITIONS

22. Kiln Nos. 1 through 4 (EPNs E2-2, E2-4, E2-6, and E2-8)

A.The waste-derived fuel shall contain no more than 1.5 percent by weight of the following 

compounds: creosote, creosols, cresylic acid, and coal tars.

B. The clinker quench wastewater, as received at the facility, shall not 

containChlorofluorocarbon.

C. The holder of this permit shall comply with these requirements for all equipment items 

which contact waste-derived fuel or clinker quench wastewater, except relief valves and 

sump pumps.

(1) These conditions shall not apply (1) where the volatile organic compound (VOC) 

have an aggregate partial pressure or vapor pressure of less than 0.05 psia at 20°C, 

(2) to piping and valves two inches nominal size and smaller, or (3) operating 

pressure is at least 5 kilopascals (0.725 psi) below ambient pressure. Equipment 

excluded from this condition shall be identified in a list to be made available upon 

request.

 (2) Construction of new and reworked piping, valves, pump systems, and compressor 

systems shall conform to applicable American National Standards Institute, 

American Petroleum Institute, American Society of Mechanical Engineers, or 

equivalent codes.

 (3) New and reworked underground process pipelines shall contain no buried valves 

such that fugitive emission monitoring is rendered impractical.

 (4) To the extent that good engineering practice will permit, new and reworked valves 

and piping connections shall be so located to be reasonably accessible for 

leak-checking during plant operation. Nonaccessible valves shall be identified in 

a list to be made available upon request.

 (5) New and reworked piping connections shall be welded or flanged. Screwed 

connections are permissible only on piping smaller than two-inch diameter. No 

later than the next scheduled quarterly monitoring after initial installation or 

replacement, all new or reworked connections shall be gas-tested or 

hydraulically-tested at no less than normal operating pressure and 

adjustments made, as necessary, to obtain leak-free performance. Flanges shall 
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Page 27

be inspected by visual, audible, and/or olfactory means at least weekly by 

operating personnel walk-through.

Each open-ended valve or line shall be equipped with a cap, blind flange, plug, or a 

second valve.

 (6) Accessible valves shall be monitored by leak-checking for fugitive emissions at 

least quarterly using an approved gas analyzer with a directed maintenance 

program. Sealless/leakless valves (including, but not limited to, bellows and 

diaphragm valves) and relief valves equipped with a rupture disc or venting to a 

control device are not required to be monitored. For valves equipped with rupture 

discs, a pressure gauge shall be installed between the relief valve and rupture disc 

to monitor disc integrity. All leaking discs shall be replaced at the earliest 

opportunity, but no later than the next process shutdown.

A directed maintenance program shall consist of the repair and maintenance of 

components assisted simultaneously by the use of an approved gas analyzer such 

that a minimum concentration of leaking VOC is obtained for each component 

being maintained.

 (7) All new and replacement pumps and compressors shall be equipped with a shaft 

sealing system that prevents or detects emissions of VOC from the seal. These seal 

systems need not be monitored and may include (but are not limited to) dual pump 

seals with barrier fluid at higher pressure than process pressure, seals degassing to 

vent control systems kept in good working order, or seals equipped with an 

automatic seal failure detection and alarm system. Submerged pumps or sealless 

pumps (including, but not limited to, diaphragm, canned, or magnetic driven 

pumps) may be used to satisfy the requirements of this condition and need not 

be monitored.

All other pump and compressor seals emitting VOC shall be monitored with an 

approved gas analyzer at least quarterly.

 (8) Damaged or leaking valves, flanges, compressor seals, and pump seals found to 

be emitting VOC in excess of 500 ppmv or found by visual inspection to be leaking 

(e.g., dripping liquids) shall be tagged and replaced or repaired. Every reasonable 

effort shall be made to repair a leaking component, as specified in this paragraph, 

within 15 days after the leak is found. If the repair of a component would require a 

unit shutdown, the repair may be delayed until the next scheduled shutdown. All 
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leaking components which cannot be repaired until a scheduled shutdown shall be 

identified for such repair by tagging. The TCEQ Executive Director, at her 

discretion, may require early unit shutdown or other appropriate action based on the 

number and severity of tagged leaks awaiting shutdown.

 (9) The results of the required fugitive monitoring and maintenance program shall be 

made available to the TCEQ Executive Director or her designated representative 

upon request. Records shall indicate appropriate dates, test methods, instrument 

readings, repair results, and corrective actions taken. Records of flange inspections 

are not required unless a leak is detected.

(10) Compliance with the requirements of this condition does not assure compliance 

with requirements of 30 TAC Chapter 115, an applicable NSPS, or an applicable 

NESHAPS and does not constitute approval of alternative standards for 

these regulations.

(11) Audio, olfactory, and/or visual checks for any piping, valves, pumps, agitator seals 

or other components in hazardous waste service within the operating area shall be 

made at least weekly. (3/01)

A. Immediately, but no later than one hour upon detection of a leak, plant personnel shall 

take the following actions: (3/01)

(1) Isolate the leak.

(2) Use a leak collection or containment system to prevent the leak until repair or 

replacement can be made if immediate is not possible. Date and time of each 

inspection shall be noted in the operator’s log or equivalent. Records shall be 

maintained at the plant site of all repairs and replacements made due to leaks. These 

records shall be made available to representatives of the TCEQ or any other local 

program with jurisdiction upon request.

(3) The facility must maintain a closed vapor vent back/vapor balance system on all tanks 

in Hazardous Waste Service. (3/01)

(4) The holder of this permit shall clean up any spills of VOC or inorganic compounds as 

expeditiously as possible. All colleted liquids and spills shall be stored and disposed 

of in a vapor-tight container such that no detectable emissions to the atmosphere will 

result. Records of all spills (date of spill, time of spill, and corrective action taken) 
SPECIAL CONDITIONS

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Page 29

shall be maintained on-site for a two year rolling retention basis following the date of 

recorded information and made available to the TCEQ or any other local program 

with jurisdiction. (3/01)

(5) Operation without visible liquid leaks or spills shall be maintained at the storage and 

unloading facility, regardless of vapor pressure. This does not apply to momentary 

dripping associated with the initial connection or disconnection of fittings. Any 

liquid spills that occur during unloading shall be reported pursuant to 30 TAC §§ 

101.201 and 101.211, and shall be cleaned up immediately, to minimize air 

emissions. (9/05)

(6) The holder of this permit shall make and maintain records of the following on a 

two-year rolling retention basis:

a. Kiln Fuels:

(1) The received percent sulfur for the kiln fuels; and

(2) The percent sulfur of the fuels as burned.

b. Clinker Quench Wastewater: quantity of wastewater accepted. (3/01)

c. Waste-Derived Fuel: quantity of waste-derived fuel accepted. (3/01)

d. Monitoring and Maintenance Records Pursuant to Special Condition No. 22C.

(1) A list of all components affected by this condition;

(2) Checklists indicating that the daily inspections are being performed;

(3) Checklists indicating the hydrocarbon analyzer inspections are being 

performed;

(4) Summaries including date, time, equipment identification, and monitoring 

results for all leaking items;

(5) Summaries including date, time, equipment identification, and corrective 

actions for all isolations, replacements, and/or repairs performed, including 

monitoring results immediately after repairs; and
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(6) Records of the calibration of the portable monitoring instruments.

The records required in this condition shall be maintained at the plant site on 

a rolling two-year retention basis following the date of such measurements, 

maintenance, reports, or records and shall be made available to the TCEQ or 

any local air pollution agency having jurisdiction, upon request.

(7) After the required demonstrations of initial compliance for these facilities, 

the CEMS and QA/QC plans required in Special Condition No. 13A shall be 

used to determine continuous compliance with the conditions of this permit 

and the rules and regulations of the TCEQ. Compliance with the emission 

limitations may also be determined by any TCEQ compliance sampling 

method.

(8) Information and data concerning the date, type and quantity of wastes 

managed, waste analyses, facility inspections, operating hours, sampling, and 

monitoring data shall be maintained in the operating record at the plant site in 

a form suitable for inspection and made available at the request of personnel 

from the TCEQ, or any local government having jurisdiction under the Texas 

Clean Air Act. (3/01)