MEMORANDUM

FROM:  Keith Barnett, EPA/OAR/OAQPS/SPPD MMG

TO: Portland Cement Administrative Record

RE:  Portland Cement Kiln Permit Limits

	Attached to this memo is information supplied by the State of Florida
on the cement kilns in Florida that have permit limits.  Based on
conversations with Cindy Mulkey of the State of Florida, it appears that
the permit limits are determined based on information sent in by the
affected source.  The source estimates their annual mercury emissions
based on the mercury in their raw materials.  They then calculate an
estimated annual mercury emission level and request it as a permit
limit.  

I also spoke with Joe Horton of Suwannee American Cement who confirmed
that they typically perform materials analyses and do a worst case
estimate by assuming that if no mercury is detected they use the mercury
detection limit to estimate emissions.  Once they begin operation, they
try to do analyses with a lower detection limit (most of their analyses
are non-detects).  This provides a built in “pad” so they don’t
exceed their permit limits.

 

I also spoke with personnel in the State of Michigan about the Michigan
permit limits.  These limits (for the two facilities that have them) are
based on the measured emissions.  So the facilities don’t have to take
any action to control mercury.

The final State the provided information was the State of Maine.  They
have one cement kiln whose permit limit is set by State law.  The kiln
currently meets this level without any mercury control being required.

