Special Conditions

Permit Number 1

Emission Limitations

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 (NOx) - 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 (SO2) - 0.4 lb/T clinker, 30-day rolling average;

(4) Particulate Matter (PM) filterable (PM/PM10/PM2.5) - 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 (O2), 30-day rolling average

(6) Mercury (Hg) - 21 lb/million tons clinker, 30-day rolling average;

(7) Dioxins/Furans (D/F) - 0.40 nanogram per dry standard cubic meter (TEQ), 

corrected to 7 percent O2; and

(8) Ammonia (NH3) - 35 ppmvd corrected to 7 percent O2, 24-hour rolling average.

B. Solid Fuel Mill Baghouse Stack (EPN 461.SK405):

(1) PM and PM10 filterable - 0.01 grain per dry standard cubic foot (gr/dscf) 

(2) PM2.5 filterable - 0.004 gr/dscf

(3) NOx - 30 ppmvd corrected to 3 percent O2

C. Solid Fuel Transfer BC050 to BC080 Baghouse (EPN 461.BF020)

(1) PM and PM10 filterable - 0.01 gr/dscf

(2) PM2.5 filterable - 0.004 gr/dscf

D. Solid Fuel Transfer BC080 to Solid Fuel Mill Baghouse (EPN 461.BF040)

(1) PM and PM10 filterable - 0.01 gr/dscf

(2) PM2.5 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 for 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 Stationary 
Special 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

6-10
Special 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

Solid 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) in 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)

Opacity/Visible Emission Limitations

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)

Operational Limitations, Work Practices, And Plant Design

11. The Reconstructed No. 3 Cement Kiln (FIN 431.KL100, EPN 331.SK410) production rate 

shall not exceed 130 tons per hour of clinker and 949,000 tons per year of clinker on a 

rolling 12-month basis. (5/12)

12. 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 1-2B 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, 

3-5
Special Conditions

Permit Number 1

Page 6

Transfers to/from Quarry Belt 6 1-2E Transfers into Clinker Silo 2 3-4F, 

3-5

Transfers to/from Quarry Belt 7 1-2D Transfers into Clinker Silo 21 3-4G,

3-6

Transfers from the Slag Elevator 1-12 Transfers into Clinker Silo 22 3-4G,

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 Silo 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

13. 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)

14. Emission Sources (EPNs 1-4A, 1-5A, 1-6A, 2-7A, 2-7B, 6-2, 6-3, 6-4C, 6-4D, 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)

15. 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)

16. 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

17. 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)

18. 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. 71845

CKD Silo 3 Pug Mill Loadout 2-11 PBR Registration No. 71845

19. 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 emissions. (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)

21. 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 Used Oil.

22. Each kiln (Kiln Nos. 1, 2, and 3) shall have an individual maximum allowable sulfur dioxide 

(SO2) emission rate of 1,131 pounds per hour (lb/hr). Additionally, all three kilns in 

aggregate shall operate under a total combined SO2 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.

23. Ammonia emissions from each of the kiln stacks, when using Selective Non-Catalytic 

Reduction, shall not exceed a limit of 35 ppmvd at 7.0 percent O2, on a 24-hour rolling 

average basis. (9/10)
Special Conditions

Permit Number 1

Page 8

24. 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)

25. The Emergency Diesel Generator is limited to operating 100 hours per year on a rolling 

12-month basis for non-emergency operation. (5/12)

Initial Determination of Compliance (5/12)

26. To demonstrate 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 contaminants emitted from the Reconstructed No. 3 Cement Kiln Stack (EPN 

331.SK410) to be tested for include PM10, PM2.5, D/F, lead, and methane. Initial 

determination of compliance for PM, NOx, CO, SO2, THC, and Hg shall be performed 

in accordance with the applicable 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 NOx, except NOx testing is not required if 

there is vendor data for the Hot Gas Generator showing compliance with the NOx

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 the Solid Fuel Mill Stack is not required 

while performing initial testing with the RTO not operating. The stack testing data 
Special 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 Compliance

27. 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 contaminants 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 prior 

to conducting sampling.

Air contaminants emitted from the kilns to be tested for include (but are not limited to) 

PM, NOx, CO, VOC, and SO2. (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.BF040 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 be 
Special 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. Corrective 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 NH3 concentrations at Kiln Nos. 1, 2, and 3 (EPNs 2, 6, and 12) and the Reconstructed 

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 NH3 slip is only required when the selective non-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 

NH3. The NH3 measurements shall be used to determine compliance with the 

MAERT.

B. The NH3 slip may be measured using a sorbent or stain tube device specific for NH3

measurement in the appropriate range. The frequency of sorbent or stain tube testing 

shall be monthly.

(1) If the sorbent or stain tube testing indicates an ammonia (NH3) slip 

concentration that exceeds 10 parts per million (ppm) at any time, the permit 

holder shall begin NH3 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 NH3 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 NH3 slip or greater.

C. The permit holder may install and operate a second NOx CEMS probe located 

between the kiln and the SNCR, upstream of the stack NOx CEMS, which may be used 

in association with the SNCR efficiency and NH3 injection rate to estimate NH3 slip. 

This condition shall not be construed to set a minimum NOx reduction efficiency on 

the SNCR unit.

D. The permit holder may install and operate a dual stream system of NOx CEMS at the 

exit of the SNCR. One of the exhaust streams would be routed, in an unconverted 

state, to one NOx CEMS, and the other exhaust stream would be routed through a 

NH3 converter to convert NH3 to NOx and then to a second NOx CEMS. The NH3 slip 

concentration shall be calculated from the delta between the two NOx CEMS readings 

(converted and unconverted).

E. Any other method used for measuring NH3 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 NOx, CO, 

SO2, 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 NOx, CO, SO2, 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 the 
Special 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 SO2, NOx, CO, PM, and THC CEMS and the continuous flow rate sensor shall be 

used as a continuous emission rate monitoring system for SO2, NOx, 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 TCEQ 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 than 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 Factor to be used in the subsequent calculations for VOC.

The 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.

33. The permit holder shall make visible emissions observations for the fabric filter baghouses 

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. 

(9/10)

Sampling Requirements (4/12)

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

conducting the sampling and testing operations at their own expense. 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 may be submitted for approval by the TCEQ 

Regional Office with jurisdiction. 

35. 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 NOx;

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 6C for the concentration of SO2; and

I. Test Method 201, 201A, or 202 for in stack PM10, or condensable PM, 40 CFR 51, 

Appendix M.
Special Conditions

Permit Number 1

Page 15

36. 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 include:

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 the pretest meeting is to review the necessary sampling and testing 

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

the format procedures for submitting the test reports.

37. 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 prior 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.

38. Requests to waive testing for any pollutant specified shall be submitted, in writing, for 

approval to the TCEQ Office of Air, Air Permits Division in Austin.

39. 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

41. 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. One paper copy to each appropriate local air pollution control program with 

jurisdiction.

42. 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 Condition No. 1 and the permitted emission rates.

43. 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.

Reporting Requirements

44. The holder of this permit shall submit quarterly NOx, SO2, and CO CEMS reports for Kiln 

Nos. 1, 2, and 3 (EPN 2, 6, and 12) (one copy) and quarterly PM, NOx, CO, SO2, THC, and 

Hg CEMS 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. In 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 30th 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 NOx, SO2, and CO emitted during the quarter from Kiln Nos. 1, 2, 

and 3 (EPNs 2, 6, and 12), the total tons of PM, NOx, CO, SO2, 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 calendar year.

Miscellaneous

46. 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

Recordkeeping Requirements

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.

48. The following information shall be maintained at the 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 period, 

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 hourly 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. 28. (9/10)

G. Records of quarterly property line visible emissions observations and any corrective 

action taken as required by Periodic Monitoring required in Special Condition No. 29. 

(5/12)

H. Records of any Test Method 9 conducted as specified in Special Condition Nos. 28

and 33. (9/10)

I. Records of NH3 concentrations monitored or calculated pursuant to Special Condition 

No. 30 and the corresponding NH3 emissions. (5/12)

J. Records of sulfur content of diesel fuel pursuant to Special Condition No. 31. (5/12)

K. Records of NOx, CO, diluent gases (O2 or CO2), PM, SO2, 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)

Special Provision

49. 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 25, 2012