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COMPLIANCE ORDER ON CONSENT fa the Maser of CEMEX, INC. AIRS # Ol3/0003 10. Cemex is required to use permit-specific emission factors in calculating the estimated emissions from sources and activities at the Plant for Air Pollutant Emissions Notice ("APEN") reporting and fee purposes, and to maintain and make available for inspection records of the calculations upon request. The records maintained by Cemex'used incorrect emission factors to calculate the Plant's emissions of particulate matter ("PM" and/or "PM~o") from the screening and crushing activities, raw material storage silos, Raw Mill Grinding activities, and Homogenizing and Blending activities, in violation of Permit No. 950PB0082, Section II, conditions 6.2, 7.2, 8.2, 9.2, respectively. Additionally, the records maintained by Cemex used the incorrect emission factor to calculate the emissions of hydrochloric acid ("HCl") from the Plant's Clinker Cooler, in violation of Permit No. 950PB0082, Section II, condition 10.10. Cemex has corrected the APEN submittals, and properly paid the emission fees. 11. Permit No. 950PB0082, Section II, condition 10.4 establishes PM emissions limits for the Plant's Kiln and Clinker Cooler. The permit requires Cemex to monitor PM and PM10 emissions and to keep production records. Cemex kept production records, but did not calculate PM emissions based on such production records. Additionally, Cemex should be required to maintain records estimating PM and PM10 emissions, on a monthly basis, and should be required to maintain such records a1 the Plant. Such emissions estimates should be calculated in the manner prescribed in Subpart F, section b0.64(b)(1-3). Cemex has agreed to perform such calculations and maintain such records. 12. Permit No. 950PB0082, Section II, condition 10.4.4 requires Cemex to operate the Kiln and Clinker Cooler continuous opacity monitors ("COMs") in accordance with Subpart A, section 60.13. Cemex reported opacity exceedance times to the Division, but the exceedance times were not calculated in the manner specified by Subpart A, section 60.13(h). Cemex has since changed its practice to calculate opacity exceedance times as specified in Subpart A, section 60.13. As a mitigating factor, Cemex asserts that it over reported opacity violations. 13. Cemex is required to ensure that the paved travel areas used by the front-end loaders and paved azeas of particulate emission producing sources are (I) swept regularly with a high efficiency vacuum sweeper to minimize material buildups, (2) watered as necessary, and (3) vehicle traffic suspended or rerouted if fugitive emissions become a concern Mr. Carr observed significant material buildup and fugitive emissions from the paved areas near the Plant's Outdoor Clinker Storage azea, the result of spillage from the front loader during transference of material from the clinker drop area to the stockpile areas. Water trucks and the vacuum sweeper vehicle were observed on several occasions during the inspections; however, based'upon observations made on March 26, May 2 and May 13, 2003, the frequency of material deposited on the paved areas from the handling of clinker in the Outdoor Clinker Storage area exceeds Cemex' ability to minimize fugitive emissions, in violation of Permit No. 950PB0082, Section II, conditions 3.5.6 and 11.6.6. 14. During the inspections, Mr. Carr observed excessive emissions from the Plant's Outdoor Clinker Storage area, noting that, as during the 2002 inspection discussed in pazagraph 6 above, such emissions were the result of Cemex' failure to maintain a seal between the hopper and material during loading operations.