**S pecial**  **C onditions**  Permit Number 1
**E mission**  **L imitations** 
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.
2 . The sources shall not exceed the following emission limits (in addition to the limits identified in the maximum allowable emission rates table [MAERT] for the sources): **(5/12)** A. Reconstructed No. 3 Cement Kiln [Emission Point Number ( EPN) 331.SK410 ] : (1) Nitrogen Oxides (NO x)
- 1.5 pounds per ton (lb/T) clinker, 30

- day rolling average; (2) Carbon Monoxide (CO)

- 1.23 lb/T clinker, 30

- day rolling average; (3) Sulfur Dioxide ( SO 2 )
- 0.4 lb/T clinker, 30

- day rolling average; (4) Particulate Matter (PM) filterable (PM/ PM 10 / PM 2.5 )
- 0.01 lb/T clinker, 30

- day rolling average; ( 5 ) Total Hydrocarbons (THC)

- 24 parts per million by volume dry (ppmvd) corrected to 7 percent oxygen ( O 2 ), 30
- day rolli ng average (6 ) Mercury (Hg)
- 21 lb/million tons clinker, 30 - day rolling average ; (7) Dioxins/Furans (D/F)
- 0. 4 0 nanogram per dry standard cubic meter (TEQ), corrected to 7 percent O 2 ; and (8 ) Ammonia (NH 3 )
- 35 ppmvd corrected to 7 percent O 2 , 24 -hour rolling average. B. Solid Fuel Mill Baghouse Stack (EPN 461.SK405): (1) PM and PM 10 filterable

- 0.01 grain per dry standard cubic foot (gr/dscf) (2) PM 2.5 filterable

- 0.004 gr/dscf (3) NO x - 30 ppmvd corrected to 3 percent O 2 C. Solid Fuel Transfer BC05 0 to BC080 Baghouse (EPN 461.BF020) (1) PM and PM 10 filterable

- 0.01 gr/dscf (2) PM 2.5 filterable

- 0.004 gr/dscf D. Solid Fuel Transfer BC080 to Solid Fuel Mill Baghouse (EPN 461.BF040) (1) PM and PM 10 filterable

- 0.01 gr/dscf (2) PM 2.5 filterable

- 0.004 gr/dscf **Fuel Specifications** 3 . Fuel shall be limited as follows:Special Conditions

Permit Number 1 Page 2
A. Fuel fired in Kiln Nos. 1, 2, and 3 : **(10/01)** (1) Coal, (2) Coke , (3) New or used oil, (4) Wood chips, (5) Tire
- derived fuel (TDF), and (6) Natural gas
. B . Firing of TDF is limited to a maximum of 35 percent of total British thermal units requirements for Kiln Nos. 1, 2, and 3 [Facility Identification Numbers ( FINs ) 2 - 1, 2 - 2, and 2

- 3 ]
. C
. Fuel fired in the Reconstructed No. 3 Cement Kiln ( FIN 431.KL100 ) : **(5/12)** (1) Coal, (2) Coke , (3) New or used oil, and (4) Natural gas
. D . Fuel fired in the Precalciner ( FIN 421.CI400 ) : **(5/12)** (1) Coal, (2) Coke , (3) New or used oil, (4) Wood chips, (5) TDF, and (6) Natural gas
. E . Fuel fired in the Hot Gas Generator ( FIN 461.HG700 ) : natural gas. **(5/12)** F . Fuel fired in the Emergency Diesel Generator: diesel containing no more than 15 ppm by weight sulfur. **(5/12)** 4 . Upon request by the Executive Director of the Texas Commission on Environmental Quality (TCEQ) or the TCEQ Regional Director or any local air pollution control program having jurisdiction, the holder of this permit shall provide a sample and/or an analysis of the fuels utilized in these facilities or shall allow air pollution control program representatives to obtain a sample fo r analysis. **Federal Applicability** 5 . These facilities shall comply with all applicable requirements of the U.S. Environmental Protection Agency (EPA) regulations on Standards of Performance for New StationarySpecial Conditions

Permit Number 1 Page 3 Sources (NSPS) in Title 40 Code of Federal Regulations (40 CFR) Part 60 , specifically the following: A. Subpart A
- General Provisions; B. Subpart F

- Portland Cement Plants (applies to facilities listed below) ; **(5/12)** Facility FIN EPN Kiln No. 3 2 - 3 12 No. 3 Clinker Cooler Stack 3 - 3 13 Reconstructed No. 3 Cement Kiln 431.KL100 331.SK410 Dryer/Crusher 411.DC100 331.SK410 Precalciner 421.CI400 331.SK410 Preheater Cyclone 421.CN010 331.SK410 Precalciner Cyclone 421.CN110 331.SK410 Clinker Cooler Belt 3 - 4H F
- MB2 C. Subpart Y

- Coal Preparation and Processing Plants (applies to facilities listed below) ; **(5/12)** Facilities that commenced construction, reconstruction , or modification after October 27, 1974, and on or before April 28, 2008: Facility FIN EPN Railcar Unloading Hopper 6
- 1 6
- 1 Drop from Conveyor to Stack Conveyor 6
- 2 6
- 2 Drop from Coal Stacker to Stock Pile 6
- 3 6
- 3 East Transfer from Stock Pile to Reclaim Hopper 6
- 5A 6
- 5A West Transfer from Stock Pile to Reclaim Hopper 6
- 5B 6
- 5B East Drop from Reclaim Hopper to Conveyor 6
- 6
- 1 6
- 6A West Drop from Reclaim Hopper to Conveyor 6
- 6
- 2 6
- 6B East Drop from Hopper Conveyor to Conveyor Crusher 6
- 6
- 1 6
- 6C West Drop from Hopper Conveyor to Conveyor Crusher 6
- 6
- 2 6
- 6D Coal Crusher and Drops 6
- 6A, 6
- 7, 6
- 8 6
- 6E, 6
- 7, 6
- 8 Drop to Day Tank 6
- 9 6
- 9 Inside Building Transfer Points 6
- 10A, 6
- 10B, 6
- 10C 6
- 10Special Conditions

Permit Number 1 Page 4 Facilities that commenced construction, reconstruction , or modification after

May 27, 2009: Facility FIN EPN Solid Fuel Transfer Solid Fuel Day Tank Conveyor to BC050 6
- 15A/B/C 6
- 15 Clinker Cooler 441.CC100 461.SK405 Solid Fuel Mill 461.RM100 461.SK405 Hot Gas Generator 431.HG700 461.SK405 Pulverized Fuel Bin A 461.BI550A 461.BF560A Pulverized Fuel Bin B 461.BI550B 461.BF560B Solid Fuel Transfer BC050 to BC080 461.BC050 461.BF020 S olid Fuel Transfer BC080 to Solid Fuel Mill 461.BC080 461 BF040 D . Subpart OOO

- Nonmetallic Mineral Processing Plants (applies to limestone and shale handling/processing facilities ) ; and **(5/04)** E. Subpart IIII

- Stationary Compression Ignition Internal Combustion Engines (applies to the Emergency Diesel Generator). **(5/12)** 6
. These facilities shall comply with all applicable requirements of the EPA regulations on National Emission Standards for Hazardous Air Pollutants for Source Categories (NESHAP) i n 40 CFR Part 63, specifically the following: A. Subpart A

- General Provisions ; B. Subpart LLL

- Portland Cement Manufacturing Industry ( applies to facilities listed below); and **(5/12)** Facility FIN EPN Kiln No. 1 2 - 1 2 Kiln No. 2 2 - 2 6 Kiln No. 3 2 - 3 12 Reconstructed No. 3 Cement Kiln 431.KL100 331.SK410 Dryer/Crusher 411.DC100 331.SK410 Precalciner 421.CI400 331.SK410 Preheater Cyclone 421.CN010 331.SK410 Precalciner Cyclone 421.CN110 331.SK410 C. Subpart ZZZZ

- Reciprocating Internal Combustion Engines (applies to the Emergency Diesel Generator) **(5/12)**Special Conditions

Permit Number 1 Page 5
7 . If any condition of this permit is more stringent than the regulations so incorporated, the permit shall govern and be the standard by which compliance shall be demonstrated. **(5/12) O** **pa city**  **/V isible**  **E mission**  **L imitations**  8
. Except for those periods described in Title 30 Texas Administrative Code ( 30 TAC) §§ 101.201 and 101.211, no visible emissions, when adjusted for uncombined water vapor, shall leave the plant property as determined by Method 22 for a three

- minute period out of any 30 - minute period. If this condition is violated, further controls shall be installed and/or implemented as required to limit visible emissions. 9 . Opacity of emissions from the EPNs listed in the table below shall not exceed 5 percent averaged over a six

- minute period, and according to EPA Test Method 9 or equivalent. **(5/12)** EPNs 1 - 2A 1 - 2B 1 - 2C 1 - 2F 1 - 6C 1 - 6D 1 - 12 1 - 18 1 - 19 1 - 21 1 - 23 1 - 25 1 - 29 1 - 30 1 - 31 3 - 15 4 5 5 - 2A 8 9 10 11 23 24 25 27 28 29 30 32 33 35 461.BF560A 461.BF560B 461.BF020 461.BF040 10 . Opacity of emissions from EPNs 331.SK410 ( Reconstructed No. 3 Cement Kiln) and 461.SK405 (Solid Fuel Mill Stack) shall not exceed 10 percent averaged over a six

- minute period. **(5/12) O** **perational L** **imitations , W** **ork P** **ractices , A**  **nd P** **lant D**  **esign**
1 1 . The Reconstructed No. 3 Cement Kiln ( FIN 431.KL100 , EPN 331.SK410 ) production rate shall not exceed 1 3 0 tons per hour of clinker and 949,000 tons per year of clinker on a rolling 12

- month basis. **(5/12)**
1 2 . Emissions from the following facilities shall be collected and exhausted through a fabric filter. **( 5**  **/ 12**  **)** Facility FIN Facility FIN Transfers to / from Quarry Belt 3 1 - 2 B Transfers into CKD Tank 1 2 - 4 Transfers to/from Quarry Belt 4 1 - 2A Transfers into CKD Tank 2 2 - 5 Transfers to/from Quarry Belt 5 1 - 2C Transfers into Clinker Silo 1 3 - 4F , 3 - 5Special Conditions

Permit Number 1 Page 6
Transfers to/from Quarry Belt 6 1 - 2 E Transfers into Clinker Silo 2 3 - 4 F, 3 - 5 Transfers to/from Quarry Belt 7 1 - 2 D Transfers into Clinker Silo 21 3 - 4 G, 3 - 6 Transfers from the Slag Elevator 1 - 12 Transfers into Clinker Silo 22 3 - 4 G, 3 - 6 Slag Conveyor 2 1 - 13 Transfers onto Clinker Belt 1 3 - 7 Transfers into Slag Silo 1 1 - 14 Transfers onto Clinker Belt 2 3 - 8 Transfers into Slag Silo 2 1 - 15 Transfers to/from the Clinker Stacker 3 - 9 Transfers into Slag Silo 3 1 - 16 Finish Mill 1 4 - 1 Transfers to/from Quarry Conveyor 1 1 - 18 Finish Mill 2 4 - 2 Transfers into Limestone Day Tank 1 - 19 Transfers into Gypsum Sil o 1 and Transfers from Gypsum Conveyor 1 to Gypsum Conveyor 2 4 - 3
Transfers to Limestone Belt 2 1 - 21 Transfers into Gypsum Silo 2 4 - 4 Transfers to Limestone Belt 3 1 - 23 Transfers from Gypsum Weigh Conveyor No. 2 4 - 6 New Crusher 1 - 25 Cement Loading

- Railside 5 - 3 Transfers to/from Quarry Fixed Conveyor 3 1 - 26 Cement Loading

- Truck 5 - 4 Limestone Bin 1 - 29 Cement Loading

- Special 5 - 5 Limestone Transfer onto Finish Mill Collection Belt 1 1 - 30 Cement Railcar Unloading 5 - 6 Limestone Transfer onto Finish Mill Collection Belt 2 1 - 31

1 3 . Outdoor stockpiles (i.e. , gypsum, clinker, coal, sand, and mill scale and the cement kiln dust (CKD) disposal area) shall be sprinkled with water as necessary to control fugitive dust emissions. **(5/04)**
1 4 . Emission Sources (EPNs 1
- 4A, 1
- 5A, 1 - 6A, 2
- 7A, 2
- 7B , 6
- 2, 6
- 3, 6
- 4C, 6
- 4 D, 6
- 11, 6
- 12, 6
- 13, and 6

- 14 ) shall employ wet material and reduced drop as represented in the permit application to reduce fugitive dust emissions. **(5/ 12**  **)**
1 5 . Emission Sources (FINs 1
- 6A, 3
- 4D, and 3

- 4E) shall be enclosed as represented in the permit application to reduce fugitive dust emissions. **(5/04)**
1 6
. Transfer of CKD from storage silos to the Pugmill (FIN 2

- 6) shall be through an enclosed conveyor. Also, the transfer to the Pugmill shall be enclosed. **(5/04)**Special Conditions

Permit Number 1 Page 7

1 7 . Emission Sources (FINs 1
- 6B, 1
- 7A, 1
- 7B, 1
- 7C, 1
- 7D, 1
- 7E, 3
- 4A, 3
- 4B, 3
- 4C, 3
- 7, 3 - 8, 4
- 3, 4 - 4, and 4

- 5) shall employ partial enclosure as represented in the permit application to reduce fugitive dust emissions. **(3/07)**
1 8
. The following facilities and operations are authorized by the indicated standard exemption (SE) or permit by rule (PBR) : **(5/ 12**  **)** Facility/ Operation EPN Authorization Fuel Oil Truck Unloading 18 SE 51 (July 15, 1988 ) Waste Oil Fuel Tank Nos. 1 through 4 36 SE 51 ( October 4, 1995 ) Storage Tank Piping 7- 1 SE 51 ( October 4, 1995 ) Unloading Piping 7- 2 SE 51 ( October 4, 1995 ) Kiln Transfer Piping 7- 3 SE 51 ( October 4, 1995 ) Line Heater 15 SE 7 (April 25, 1986 ) CKD Silo 3 and Pug Mill 2 - 9 PBR Registration No. 71845 CKD Silo 3 Truck Spout 2 - 10 PBR Registration No. 7 1845 CKD Silo 3 Pug Mill Loadout 2 - 11 PBR Registration No. 71845
1 9 . Paved plant roads shall be swept or washed and unpaved roads shall be sprinkled with water and/or environmentally sensitive dust suppressant chemicals as necessary to control dust emis sions. **(5/04)** 20 . All hoods, ducts, and collection systems shall be effective in preventing fugitive emissions. When compliance with this condition is required to be tested, compliance 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. **(5/04)**
2 1 . The on

- site oil storage tanks that store oil for kiln fuel are authorized to store used oil meeting the requirements of 40 CFR Part 279, Standards for the Management of Us ed Oil.
2 2 . Each kiln (Kiln Nos. 1, 2, and 3) shall have an individual maximum allowable sulfur dioxide ( SO 2 ) emission rate of 1,131 pounds per hour (lb/hr). Additionally, all three kilns in aggregate shall operate under a total combined SO 2 emission rate of 2,100 lb/hr. Records demonstrating compliance with this condition shall be kept accordingly and, upon request, made immediately available to representatives of the TCEQ or any local air pollution program having jurisdiction.
2 3 . Ammonia emissions f rom each of the kiln stacks, when using Selective Non

- Catalytic Reduction, shall not exceed a limit of 35 ppmvd at 7.0 percent O 2 , on a 24 -hour rolling average basis. **(9/10)**Special Conditions

Permit Number 1 Page 8

2 4 . Emission rates are based on and the facilities shall be limited to the following: **(5/12)** Facility/Operation Max Hourly Throughput (Tons) Max Annual (Tons) Stamler Feeder (FIN1

- 24) 800 2,500,000 Outdoor Storage Hopper (FIN 1

- 6) 200 1,001,100 Coal Crusher/Hammer Mill (FIN 6

- 7) 150 873,600 Kiln Nos. 1, 2, and 3 (FINs 2

- 1, 2 - 2 , and 2

- 3) 45 (Clinker, each) 394,200 (Clinker, each)

2 5 . The Emergency Diesel Generator is limited to operating 1 0 0 hours per year on a rolling 12 - month basis for non

- emergency operation. **(5/12) Initial Determination of Compliance**  **(5/12)**
2 6
. To demo nstrate compliance with the MAERT and with emission performance levels as specified in the special conditions, the holder of this permit shall perform stack sampling and/or other testing as required to establish the actual pattern and quantities of air contaminants being emitted into the atmosphere from the Reconstructed No. 3 Cement Kiln Stack (EPN 331.SK410) , Solid Fuel Mill Stack (EPN 461.SK405), Solid Fuel Transfer BC050 to BC080 Stack (EPN 461.BF020), and Solid Fuel Transfer BC080 to Solid Fuel Mill Stack (EPN 461.BF040) . Sampling shall be accomplished within 60 days of achieving maximum production but not later than 180 days after initial startup of the Reconstructed No. 3 Cement Kiln Project . Sampling must be conducted in accordance with the TCEQ Sampling Procedures Manual and in accordance with applicable EPA 40 CFR 60, Appendix A, or other applicable reference method procedures . Any deviations from those procedures must be approved by the TCEQ Executive Director prior to sampling. A. Air contamin ants emitted from the Reconstructed No. 3 Cement Kiln Stack (EPN 331.SK410) to be tested for include PM 10 , PM 2.5 , D/F, lead, and methane
. Initial determination of compliance for PM, NO x, CO, SO 2 , THC, and Hg shall be performed in accordance with the appli cable initial compliance requirements of NSPS Subparts A and F, and NESHAP Subpart LLL
. Initial determination of compliance for volatile organic compounds (VOC) shall be performed in accordance with Special Condition No. 32H . B. Air contaminants emitted from the Solid Fuel Mill Stack (EPN 461.SK405) to be tested for include filterable PM , VOC, and NO x, except NO x testing is not required if there is vendor data for the Hot Gas Generator showing compliance with the NO x limit in Special Condition No. 2B(3)
. Testing for VOC shall be performed while the regenerative thermal oxidizer ( RTO ) is operating and while the RTO is not operating, in order to determine the RTO control efficiency. Compliance with the pounds per hour VOC emission limit in the MAERT for th e Solid Fuel Mill Stack is not required while performing initial testing with the RTO not operating. The stack testing dataSpecial Conditions

Permit Number 1 Page 9
may be used to determine compliance with the limits in Special Condition No. 2 and

the MAERT. C. Air contaminants emitted from the Solid Fuel Transfer BC050 to BC080 Stack ( EPN 461.BF020) to be tested for include filterable PM
. The stack testing data may be used to determine compliance with the limits in Special Condition No. 2 and the MAERT. D. Air contaminants emitted from the Solid Fuel Transfer BC080 to Solid Fuel Mill Stack ( EPN 461.BF040 ) to be tested for include filterable PM
. The stack testing data may be used to determine compliance with the limits in Special Condition No. 2 and the MAERT. **Demonstration of Continuous Comp liance** 
2 7 . Upon request by the TCEQ Executive Director or the TCEQ Regional Director having jurisdiction, the holder of this permit shall perform stack sampling and/or other testing as required to establish the actual pattern and quantities of air contami nants being emitted into the atmosphere from the cement kilns to demonstrate compliance with the MAERT and with emission performance levels as specified in the special conditions and/or otherwise prove satisfactory equipment performance. Sampling must be conducted in accordance with the TCEQ Sampling Procedures Manual or in accordance with the applicable EPA 40 CFR procedures. Any deviations from those procedures must be approved by the TCEQ Executive Director or the appropriate TCEQ Regional Director pri or to conducting sampling. Air contaminants emitted from the kilns to be tested for include (but are not limited to) PM , NO x, CO, VOC, and SO 2 . **(4/12)** 28
. The permit holder shall make visible emissions observations for the fabric filter baghouses or dedusting filters with the EPNs listed in the table below. Visible emissions observations shall be made and recorded once per week. **(5/12)** EPNs 1 - 2A 1 - 2B 1 - 2C 1 - 2F 1 - 6C 1 - 6D 1 - 12 1 - 18 1 - 19 1 - 21 1 - 23 1 - 25 1 - 29 1 - 30 1 - 31 3 - 15 4 8 23 24 25 27 28 29 30 32 33 35 461.BF560A 461.BF560B 461.BF020 461.BF0 4 0 461.SK405 Note that to properly determine the presence of visible emissions, all sources must be in clear view of the observer. The observer shall be at least 15 feet, but not more than 0.25 mile, away from the emission source during the observation. The observer shall select a position where the sun is not directly in the observer’s eyes. If the observations cannot beSpecial Conditions

Permit Number 1 Page 10 conducted due to weather conditions, the date, time, and specific weather conditions shall be recorded. When condensed water vapor is present within the plume, as it emerges from the emissions outlet, observations must be made beyond the point in the plume at which condensed water vapor is no longer visible. When water vapor within the plume condenses and becomes visible at a distance from the emissions outlet, the observation shall be evaluated at the outlet prior to condensation of water vapor. Deviation Limit: If visible emissions are observed, the permit holder shall report a deviation. As an alternative, the permit holder may determine the opacity consistent with Test Method 9, as soon as practicable, but no later than 24 hours after observing visible emissions. If a Test Method 9 is performed, the opacity limit is 5 percent , except the opacity limit for EPN 461.SK405 is 10 percent . If the result of the Test Method 9 is opacity above the applicable limit, the permit holder shall report a deviation. 29 . The permit holder shall make visible emissions observations pursuant to Special Condition No. 8 (property line visible emissions observations) on a quarterly basis and maintain records of the observations. Contributions from uncombined water shall not be included in determining compliance with this condition. If visible emissions are observed crossing the property line for more than a cumulative three

- minute period out of the 30

- minute period, then an evaluation and identification of the source and cause of the visible emissions shall be conducted within 24 hours and documented. Co rrective action to eliminate the source of visible emissions shall be taken promptly and documented within one week of first observation of the visible emissions. **(5/12)** 30 . The NH 3 concentration s at Kiln Nos. 1, 2, and 3 (EPNs 2, 6, and 12) and the Recon structed Kiln 3 ( EPN 331.SK410 ) shall be monitored or calculated according to one of the methods listed below and shall be tested or calculated according to the associated frequency listed below. Testing for NH 3 slip is only required when the selective no n - catalytic reduction (SNCR) unit is in operation. **(5/12)** A. The holder of this permit may install, calibrate, maintain, and operate a continuous emissions monitoring system ( CEMS ) to measure and record the concentrations of NH 3 . The NH 3 measurements sh all be used to determine compliance with the MAERT. B. The NH 3 slip may be measured using a sorbent or stain tube device specific for NH 3 measurement in the appropriate range. The frequency of sorbent or stain tube testing shall be monthly. (1) If the s orbent or stain tube testing indicates an ammonia (NH 3 ) slip concentration that exceeds 10 parts per million (ppm) at any time, the permit holder shall begin NH 3 testing by either the Phenol

-Nitroprusside Method, the Indophenol Method, or EPA Conditional Test Method (CTM) 27 on a quarterly basis in addition to the monthly sorbent or stain tube testing.Special Conditions

Permit Number 1 Page 11 (2) If the quarterly testing indicates NH 3 slip is 10 ppm or less, the Phenol

Nitroprusside Indophenol CTM 27 tests may be suspended until sorbent or stain tube testing again indicate 10 ppm NH 3 slip or greater. C. The permit holder may install and operate a second NO x CEMS probe located between the kiln and the SNCR, upstream of the stack NO x CEMS, which may be used in association with the SNCR efficiency and NH 3 injection rate to estimate NH 3 slip. This condition shall not be construed to set a minimum NO x reduction efficiency on the SNCR unit. D. The permit holder may install and operate a dual stream system of NO x CEMS at the exit of the SNCR. One of the exhaust streams would be routed, in an unconverted state, to one NO x CEMS, and the other exhaust stream would be routed through a NH 3 converter to convert NH 3 to NO x and then to a second NO x CEMS. The NH 3 slip concentration shall be calculated from the delta between the two NO x CEMS readings (converted and unconverted). E. Any other method used for measuring NH 3 slip shall require prior approval from the TCEQ Air Permits Division in Austin. 31 . The sulfur content of the diesel fuel to be used in the Emergency Diesel Generator shall be demonstrated by an annual representative sample analysis. The fuel sample may be performed by the permit holder, a service contractor, fuel vendor, or any other qualified agency. The permit holder may elect not to monitor the fuel provided that the fuel quality characteristics in a valid purchase contract specify that the fuel meets the requirements of Special Condition No. 3
. **(5/12) Compliance Assurance Monitoring**  32 . The holder of this permit shall install, calibrate, maintain, and operate a continuous opacity monitoring system (COMS) to measure and record the opacity of the No. 3 Clinker Cooler Stack (EPN 13) and each kiln stack (EPNs 2, 6, and 12), and a continuous emission monitoring system (CEMS) to measure and record the in

- stack concentration of NO x, CO, SO 2 , and oxygen from each kiln (EPNs 2, 6, and 12). The holder of this permit shall install, calibrate, maintain, and operate a CEMS to measure and record the in

- stack concentration of NO x, CO, SO 2 , PM , THC, Hg , and oxygen from the Reconstructed No. 3 Cement Kiln (EPN 331.SK410). Additionally, the holder of this permit shall install, calibrate, maintain, and operate a continuous flow rate sensor to measure and record the exhaust flow rate in the stack. **(5/12)** A. Each CEMS and 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 the applicable Performance Specifications No. 1 through 4, 8A, or 11 of 40 CFR Part 60, Appendix B, as applicable. If there are no applicable performance specifications in 40 CFR Part 60, Appendix B, contact theSpecial Conditions

Permit Number 1 Page 12 TCEQ Office of Air, Air Permits Division in Austin for requirements to be met.

**(5/12)** B. The 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 Performance Specification No. 6, 40 CFR Part 60, Appendix B. **(12/ 04)**  C. The SO 2 , NO x, CO, PM, and THC CEMS and the continuous flow rate sensor shall be used as a continuous emission rate monitoring system for SO 2 , NO x, CO, PM, and VOC. **(5/12)** For EPN 331.SK410, after the initial determination of compliance, the PM CEMS shall be used to determine continuous compliance with the opacity limitations in Special Condition No. 10 . Compliance with the PM mass emission limit will be considered to demonstrate compliance with the opacity limit; however, the TCEQ may use EPA Test Method 9 to determine opacity at any time. **(5/12)** D. Each system 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 TCE Q if not specified in Appendix B. Zero and span are 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 National Emission Standards for Hazardous Air Pollutants, in which case zero and span shall be done daily without exception. Each monitor shall be quality

- assured at least quarterly in accordance with the appropriate audit specified in 40 CFR Part 60, Appendix F, Procedure 1 (gaseous CEMS) , Procedure 2 (PM CEMS), or Procedure 5 (Hg CEMS). An equivalent quality assurance method approved by the TCEQ may also be used. Successive quarterly audits shall occur no closer than two months. Cylinder gas audits of CEMS with exceedances of 15 percent accuracy shall be reported to the TCEQ Regional Director, and necessary corrective action shall be taken. The TCEQ Regional Director shall be notified as soon as possible after the discovery of any CEMS malfunction which is expected to result in more th an 24 hours of lost data. At the discretion of the TCEQ Regional Director, the permit holder may be required to take supplemental stack concentration measurements. **(12/04)** E. The monitoring data shall be reduced to hourly average concentrations at least once every day, using a minimum of four equally

- spaced data points from each one

-hour period. The individual average concentrations shall be reduced to units of the permit allowable emission rate in lb/hr at least once every week.Special Conditions

Permit Number 1 Page 13
F. All monitoring data and quality

- assurance data shall be maintained by the source for a period of five years and shall be made available to the Executive Director of the TCEQ or designated representative upon request. The data from the CEMS may, at the discretion of the TCEQ, be used to determine compliance with the conditions of this permit. **(5/12)** G. For NSPS sources subject to Appendix F, the appropriate TCEQ Regional Office shall be notified at least 30 days prior to each annual relative accuracy testing audit in order to provide them the opportunity to observe the testing. H. The VOC mass emission rate for EPN 331.SK410 shall be calculated from the THC emission rate determined using the THC emission rate monitoring system by multiplying the THC mass emission rate by a Methane Reduction Factor. The following equation shall be used

VOC = THC * Methane Reduction Factor Where, the Methane Reduction Factor is the methane concentration divided by the THC concentration subtracted from 1 [i.e., methane reduction factor = (1
- (methane/THC))]
. The methane concentration shall be determined using periodic stack testing for methane. The methane concentrations measured shall be used to determine the Methane Reduction Facto r to be used in the subsequent calculations for VOC. Th e methane concentration shall be determined by performing stack testing on a quarterly basis for the first four tests, then annually thereafter. Once four stack tests have been performed, the methane concentration used to determine VOC emissions will be the average of the four stack tests. Thereafter, the methane concentration used to determine VOC emissions will be the average of the most recent four stack tests. 3 3 . The permit holder shall make visible emissions observations for the fabric filter baghou ses on EPNs 3, 5 , 7, 9, 10, 11, and 5 - 2A. Visible emissions observations shall be made and recorded once per day and in accordance with the requirements specified in 40 CFR § 64.7(c). Note that to properly determine the presence of visible emissions, all sources must be in clear view of the observer. The observer shall be at least 15 feet, but not more than 0.25 mile, away from the emission source during the observation. The observer shall select a position where the sun is not directly in the observer’s eyes. If the observations cannot be conducted due to weather conditions, the date, time, and specific weather conditions shall be recorded. When condensed water vapor is present within the plume, as it emerges from the emissions outlet, observations must be made beyond the point in the plume at which condensed water vapor is no longer visible. When water vapor within the plume condenses and becomes visible at a distance from the emissions outlet, the observation shall be evaluated at the outlet prior to condensation of water vapor.Special Conditions

Permit Number 1 Page 14 Deviation Limit: If visible emissions are observed, the permit holder shall report a deviation. As an alternative, the permit holder may determine the opacity, consistent with Test Method 9, as soon as practicable but no later than 24 hours after observing visible emissions. If a Test Method 9 is performed, the opacity limit for EPNs 5, 9, 10, 11, and 5

- 2A, is 5 percent, and for EPNs 3 and 7 the opacity limit is 30 percent. If the result of Test Method 9 is opacity above the applicable limit, the permit holder shall report a deviation. **( 9**  **/1 0**  **)** Sampling Requirements **(4/12)** 3 4 . The holder of this permit is responsible for providing sampling and testing facilities and conducting the sampling and testing operations at their own expens e. Sampling ports and platforms shall be incorporated into the design of the stacks according to the specifications set forth in the attachment entitled " Chapter 2, Stack Sampling Facilities " prior to stack sampling. Alternate sampling facility designs m ay be submitted for approval by the TCEQ Regional Office with jurisdiction. 3 5 . Sampling shall be conducted in accordance with the TCEQ Sampling Procedures Manual and EPA Test Methods in 40 CFR Part 60, Appendix A, and other applicable reference test method procedures, as follows: A. Test Methods 1 through 4, as appropriate, for exhaust flow, diluent, and moisture concentration; B. Test Method 5 or 17, modified with a controlled condensate method subject to approval from the TCEQ prior to sampling, for the concentration of total PM; C. Test Method 5 or 17 for the filterable concentration of PM (front

-half catch); D . Test Method 7E, or equivalent methods, for the concentrations of NO x ; E . Test Method 10 for the concentration of CO; F . Test Method 25A (measuring total carbon as propane) in order to quantify THC and ASTM Method D6348

- 03 or EPA Method 18, in order to speciate and exclude methane and ethane from THC, for an accurate concentration and representation of VOC ; G. Test Method 9 for opacity; H . Test Method 6, 6A, or 6 C for the concentration of SO 2 ; and I. Test Method 201, 201A, or 202 for in stack PM 10 , or condensable PM, 40 CFR 51, Appendix M.Special Conditions

Permit Number 1 Page 15
3 6
. If stack sampling and/or other testing is required pursuant to Special Condition Nos. 26 or 27, a pretest meeting shall be held with personnel from the TCEQ before the required tests are performed. The TCEQ Regional Office with jurisdiction shall be notified not less than 30 days prior to sampling to schedule a pretest meeting. The notice shall in clude: A. Date for pretest meeting; B. Date sampling will occur; C. Points or sources to be sampled; D. Name of firm conducting sampling; E. Type of sampling equipment to be used; and F. Method or procedure to be used in sampling. The purpose of th e 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. 3 7 . Alternate sampling methods and representative unit testing may be proposed by the permit holder. A written proposed description of any deviation from sampling procedures or emission sources specified in permit conditions or TCEQ or EPA sampling procedures shall be made available to the TCEQ prio r to the pretest meeting. Such a proposal must be approved, in writing, by the TCEQ Regional Office with jurisdiction and the TCEQ Office of Air, Air Permits Division in Austin at least two weeks prior to sampling. 3 8
. Requests to waive testing for any p ollutant specified shall be submitted, in writing, for approval to the TCEQ Office of Air, Air Permits Division in Austin. 3 9 . During stack sampling emission testing, the facilities shall operate at maximum represented production rates. Primary operating parameters that enable determination of production rates shall be monitored and recorded during the stack test. These parameters are to be determined at the pretest meeting. If the plant is unable to operate at the maximum represented production/throughput rates during testing, then additional stack testing shall be required when the production rate exceeds the previous stack test production rate by +10 percent unless otherwise determined, in writing, by the TCEQ Executive Director. 40 . Requests for additional time to perform sampling shall be submitted to the TCEQ Regional Office with jurisdiction. Additional time to comply with the applicable federal requirements requires EPA approval, and requests shall be submitted to the TCEQ Regional Office with jurisdiction.Special Conditions

Permit Number 1 Page 16
4 1 . 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 provisions of Chapter 14 of the TCEQ Sampling Procedures Manual . The reports shall be distributed as follows: A. One paper copy and one computer compact disc (CD) to the TCEQ Regional Office with jurisdiction. B. One paper copy to the TCEQ Office of Air, Air Permits Division in Austin. C. O ne paper copy to each appropriate local air pollution control program with jurisdiction. 4 2 . If, as a result of stack sampling, compliance with the permitted emission rates cannot be demonstrated, the holder of this permit shall adjust any operating parameters so as to comply with Special Co ndition No. 1 and the permitted emission rates. 4 3 . If the holder of this permit is required to adjust any operating parameters for compliance, then beginning no later than 60 days after the date of the test conducted, the holder of this permit shall submit to the TCEQ, on a monthly basis, a record of adjusted operating parameters and daily records of production sufficient to demonstrate compliance with the permitted emission rates. Daily records of production and operating parameters shall be distributed as follows: A. One copy to the TCEQ Regional Office with jurisdiction. B. One copy to the TCEQ Office of Air, Air Permits Division in Austin. **R eporting**  **R equirements**  44 . The holder of this permit shall submit quarterly NO x, SO 2 , and CO CEMS reports for Kiln Nos. 1, 2, and 3 ( EPN 2, 6, and 12 ) (one copy) and quarterly PM, NO x, CO, SO 2 , THC, and Hg CEM S reports for the Reconstructed No. 3 Cement Kiln Stack (EPN 331.SK410) to the TCEQ Regional Office; however, submission of opacity data is not required. I n addition to hard copies, all CEMS reports shall be submitted electronically either as an electronic spreadsheet file, a Portable Document Format (.pdf), or another format acceptable to the TCEQ Regional Director. All reports shall be postmarked by the 3 0th day following the end of each calendar quarter and shall include the following information for each monitor: **(5/12)** A. The date and duration of time from the commencement to the completion of an event which resulted in excess stack emissions. B. The date and time of the commencement and completion of each specific time period of excess stack emissions within that event.Special Conditions

Permit Number 1 Page 17 C. The total time duration of excess stack emissions. D. The magnitude of the excess stack emissions including the highest and average (hourly) emission rate(s). For the purposes of this quarterly CEMS report, all excess stack emissions shall be converted into the units of the permit with conversion factors and equations included. E. The nature and cause of any malfunction resulting in excess emissions and the corrective action taken and/or preventative measures adopted. F. The date and time identifying each period during which a CEMS was inoperative, except for zero span checks, and the nature of the system repairs and/or adjustments which occurred during the downtime. G. When no excess emissions have occurred or the respective CEMS has not been inoperative or repaired, such information shall be stated in the report. H. The total tons of NO x, SO 2 , and CO emitted during the quarter from Kiln Nos. 1, 2, and 3 (EPNs 2, 6, and 12), the total tons of PM, NO x, CO, SO 2 , VOC, and Hg emitted during the quarter from the Reconstructed No. 3 Cement Kiln Stack (EPN 331.SK410), and the total hours of kiln operation. **(5/12)** I. 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, start

- up, and shutdown as required by 30 TAC § 101.211. J. Written records of all test results from quarterly gas audits. 45. The permit holder shall submit annual reports of the rolling 12

- month VOC emissions calculated in accordance with Special Condition No. 32 (H) to the TCEQ Regional Office. The reports shall be submitted by March 31 of each year for the previous calen dar year. **M iscellaneous**  4 6
. The holder of this permit shall physically identify (minimum 3 " letters/numbers) and mark in a conspicuous location all equipment that has the potential of emitting air contaminants as follows within 90 days of the approval of these revised conditions: A. The FINs as submitted to the Emissions Inventory Section of the TCEQ. B. The EPNs as listed on the MAERT.Special Conditions

Permit Number 1 Page 18
**R ecordkeeping**  **R equirements**  47. The following records shall be kept at the plant site for the life of the permit. All records required in this permit shall be made available at the request of personnel from the TCEQ, EPA, or any air pollution control agency with jurisdiction. **(5/12)** A. A copy of this permit. B . A complete copy of the testing reports and records of the initial performance testing and initial determination of compliance completed pursuant to Special Condition No. 26 to demonstrate initial compliance. C
. Stack sampling results or other air emissions testing (other than CEMS data) that may be conducted on units authorized under this permit after the date of issuance of this permit. 4 8
. The following information shall be maintained at th e plant site and made available at the request of personnel from the TCEQ , EPA, or any air pollution control agency with jurisdiction to demonstrate compliance with permit limitations. These records shall be totaled (as applicable) for each calendar month, retained for a rolling 60

- month peri od, and include the items identified below. Records generated before May 16, 2010 are not subject to the 60

- month retention requirement. **(5/12)** A. Hourly and annual Stamler Feeder (FIN 1
- 24) raw material throughput. B. Hourly and annual Outside Hopper (FIN 1
- 6) throughput. C. Hourly and annual Hammer Mill/Coal Crusher (FIN 6

- 7) throughput. D. Hourly and annual clinker throughput for Kiln Nos. 1, 2, and 3 (FINs 2

- 1, 2 - 2, and 2

- 3 ) and the Reconstructed No. 3 Cement Kiln (FIN 431.KL100)
. **( 5/12)**  The h ourly Stamler Feeder throughput shall be calculated from records of the material throughput and hours of operation for the calendar month and recorded by the 15th day of the month following the month to which the records pertain. A rolling 12 - month total throughput for the Stamler Feeder shall be based on monthly throughput records and recorded by the 15th day of the month following the month to which the records pertain. The hourly outside hopper and hammer mill/coal crusher throughput shall be calculated and recorded at least once per calendar year from measurements of the time required to move a known quantity of material through these facilities. A rolling 12 - month total throughput for the outside hopper and hammer mill/coal crusher shall be based on monthly throughput records and recorded by the 15th day of the month following the month to which the records pertain.Special Conditions

Permit Number 1 Page 19 The hourly throughputs for Kiln Nos. 1, 2, and 3 and the Reconstructed No. 3 Cement

Kiln shall be calculated from daily records of clinker throughputs and hours of operation for Kilns Nos. 1, 2, and 3 and the Reconstructed No. 3 Cement Kiln . A rolling 12

- month total clinker throughput for Kilns 1, 2, and 3 and the Reconstructed No. 3 Cement Kiln shall be based on monthly throughput records and recorded by the 15th day of the month following the month to which the records pertain. **(5/ 12**  **)** E. Records of daily visible emissions observations for the EPNs required by Compliance Assurance Monitoring required in Special Condition No. 33 . **(9/10 )**  F. Records of weekly visible emissions observations for the EPNs required by Periodic Monitoring required in Special Condition No. 2 8
. **(9/10)** G. Records of quarterly property line visible emissions observations and any corrective action taken as requi red by Periodic Monitoring required in Special Condition No. 2 9 . **(5/12)** H . Records of any Test Method 9 conducted as specified in Special Condition Nos. 2 8 and 33 . **(9/10)** I. Records of NH 3 concentrations monitored or calculated pursuant to Special Condition No. 30 and the corresponding NH 3 emissions
. **(5/12)** J. Records of sulfur content of diesel fuel pursuant to Special Condition No. 31. **(5/12)** K. Records of NO x, CO, diluent gases ( O 2 or CO 2 ), PM, SO 2 , THC, and Hg CEMS emissions data , as applicable, and continuous flow rate monitoring data to demonstrate compliance with the emission rates listed in the MAERT . **(5/12)** L . Raw data files of all CEMS data including calibration checks and adjustments and maintenance performed on these systems. **(5/12)** M . Records of methane concentrations and VOC emissions calculated pursuant to Special Condition No. 32H. **(5/12)** N . Records of the hours of operation of the Emergency Diesel Generator to demonstrate compliance with Special Condition No. 25
. **(5/12) Specia** **l Provision** 4 9 . After completion of construction and initial shakedown of the Reconstructed No. 3 Cement Kiln, Kiln Nos. 1 and 2 shall be shut down and rendered permanently inoperable. During the 180

- day shakedown period following completion of construction, the Reconstructed No. 3 Cement Kiln may operate for clinker production only while Kiln Nos. 1 and 2 are not operating for production of clinker. **(5/12)**Special Conditions

Permit Number 1 Page 20
50 . Upon completion of construction of the Reconstructed No. 3 Cement Kiln , the permit holder shall notify the TCEQ Regional Office of the project completion within 30 days and submit a permit alteration to the TCEQ Air Permits Division within 180 days to revise this permit to remove the shutdown facilities and associated requirements. **(5/12)**

Dated : May 2 5 , 2012