Requested Actions:

Ensure Consistent and Regular Monitoring:

1) Mandate the use of CEMS for real-time tracking of all critical emissions (every stack).

• Specifically, mandate the use of CEMS for real-time tracking of CO2, NOx, and PM emissions, in line with the Clean Air Act under 40 CFR Part 60.

• Specify immediate corrective actions for violations, such as temporary shutdowns or mandatory technology upgrades.

2) Remove the four-hour loophole and require daily visible emissions observations regardless of operational status to capture any unexpected emission events.

3) Daily, rather than monthly, compliance checks.

4) Direct monitoring of PM and PM10 emissions rather than reliance on emission factors.

5) Revise the language to specify what constitutes "operations" and "cement plant" with clear examples and scenarios that necessitate monitoring; any activity that may result in emissions, not just the processing and manufacturing aspects, should be included.

Reduce Emissions Limits

6) Revise allowable emissions rates to align with the facility's current operational use, rather than its design capacity.

7) Establishment of a RACT-based VOC emission limit that reflects the maximum degree of control achievable given the outcomes of these feasibility studies.

Improve Opacity Limit Enforcement

8) Clear definitions of the activities and sources subject to opacity limits.

9) Immediate opacity testing when visible emissions are observed.

10) Implement more stringent opacity limits based on modern control technologies.

11) Require EPA recommendations for minimizing and preventing CKD dust emissions by including the following language (ref. Condition 10.6.2.1):

• On-site handling of CKD in closed, covered vehicles and conveyance devices; and

• Keeping cement kiln dust in enclosed tanks, containers, and buildings when temporarily stored for disposal or sale.

Improve Transparency and Accountability

12) Mandate detailed recordkeeping and reporting for all instances where visible emissions observations are deemed unnecessary, with clear criteria that must be met and documented.

13) Include a requirement for third-party verification of compliance with these conditions to enhance transparency and community trust.

14) Remove the "Emergency Provisions" condition in Section IV.

Requested Actions:

1) Mandate the implementation of corrective actions such as upgrading to cleaner technology, consistent with the "Best Available Control Technology" (BACT) standards under the Clean Air Act.

2) Establishment of a RACT-based VOC emission limit that reflects the maximum degree of control achievable given the outcomes of these feasibility studies.

3) Mandate the use of CEMS for real-time tracking of all critical emissions (every stack).

4) Incorporate a "three-strikes" policy supported by the "Prevention of Significant Deterioration" (PSD) provisions under the Clean Air Act.

5) Require specific protocols like recording and responding to incidents such as spills, high speeds, insufficient moisture, and malfunctioning sprinklers. These steps should be aimed at preventing CKD dust from escaping and complement existing obligations to monitor and address dust emissions post-occurrence. (Ref. Condition 12.7.1)

6) Require EPA recommendations for minimizing and preventing CKD dust emissions by including the following language (ref. Condition 10.6.2.1):

• On-site handling of CKD in closed, covered vehicles and conveyance devices; and

• Keeping cement kiln dust in enclosed tanks, containers, and buildings when temporarily stored for disposal or sale.

7) Require the paving of frequently used haul roads to effectively control and reduce fugitive dust emissions. This modification is justified by the significant increase in truck traffic, more than 100%, and is economically viable, considering CEMEX's production of cement. The paving would also alleviate the ongoing issue of material spillage onto Highway 66. (Ref. Condition 13.4 and Subsections)

8) Require the installation of cameras across active plant areas to continuously monitor and promptly address the origins of dust emissions, with video footage retained for verification purposes. Given the discrepancy between plant records and community-reported fugitive dust events, more frequent review of operations would pinpoint issues, necessitate timely interventions, or confirm the current observation practices' effectiveness. (ref. Condition 15.1)

Requested Actions:

1) Require a comprehensive Air Quality Impact Assessment that evaluates the cumulative impact of all emission sources at the facility.

2) Mandate the inclusion of additional emission factors related to Dowe Flats and a detailed accounting of "process fugitives".

3) Denial of CEMEX's request to remove the crusher and conveyor from their emissions limits be denied until such equipment is fully deconstructed and verified as non-operational. Given the facility's history of noncompliance, it is imperative to ensure that these pieces of equipment are not merely idled but are completely removed to prevent any potential for unaccounted emissions.

4) Require a third party assessment of the full environmental impact of CEMEX’s requested modification to remove the limestone throughput limits.

5) Include emissions from mobile sources directly related to CEMEX's business activities, including but not limited to trucking and other transportation means, in the facility's total emissions counts with appropriate monitoring, limits, and consequences for violations in place.

6) Require Additional Monitoring/Reporting to Determine Raw Material Inventory and Throughputs

7) Revise the language to specify what constitutes "operations" and "cement plant" with clear examples and scenarios that necessitate monitoring; any activity that may result in emissions, not just the processing and manufacturing aspects, should be included.

Requested Actions:

1) Include explicit penalties, fines, and corrective actions for every violation. Review of the control plan, the current ‘penalty’, has been proven ineffective for 30+ years.

2) Implement 24/7 monitoring for fugitive dust events and the control measures in place that are intended to prevent them.

3) Include explicit and timely penalties, fines, and corrective actions for every violation of the control plan; waiting for penalties from annual inspections, which are issued 12-18 months after inspection, is unacceptable.

4) Implement a "three-strikes" policy, where after three violations, the facility must cease operations until it can demonstrate compliance.

Requested Actions:

1) Conduct a comprehensive health impact assessment, including potential risks to marginalized communities in line with Environmental Justice principles.

2) Require a comprehensive Air Quality Impact Assessment that evaluates the cumulative impact of all emission sources at the facility.

3) As a condition of the Title V Operating Permit, require that CEMEX conduct and complete Phase 1 and Phase 2 Environmental Site Assessments. The results must be publicly disclosed and integrated into permit revisions.

4) Provide a public hearing for CEMEX’s permit renewal that includes a transparent presentation of all proposed changes, data, and environmental impact assessments. The community has a right to be fully informed and engaged in decisions that affect their health and environment.