MEMORANDUM

TO:  Portland Cement NESHAP Docket

FROM:  Keith Barnett, USEPA/OAQPS/SPPD/MMG

DATE:  August 7, 2008

SUBJECT:  July 31, 2008 meeting between US Environmental Protection
Agency (EPA) and Portland Cement Association (PCA) at the EPA Offices in
Research Triangle Park, NC

I.  Introduction and Objectives

Representatives from the EPA and the PCA met on July 31, 2008 at EPA’s
headquarters in Research Triangle Park, NC.  The meeting was led by Mr.
Keith Barnett of EPA’s Sector Policies and Programs Division in the
Office of Air Quality Planning and Standards. The meeting agenda is
included as Attachment 1

The purpose of the meeting was to describe EPA’s current regulatory
activities as they relate to the portland cement manufacturing industry
and to solicit discussion and input regarding these activities from the
industry representatives. Current regulatory activities include the
NESHAP for portland cement, the review of the NSPS for portland cement
manufacturing, and the cement sector project. 

II.  Meeting Participants

A list of persons attending the meeting and those participating by
telephone and their affiliation is included as Attachment 2.  

III.  Meeting Summary

NESHAP

A. Section 114 data and subcategorization methodology

Mercury

PCA presented an approach for subcategorization and establishment of the
MACT floor. In their approach they subcategorized kilns based on the
mercury concentration of the kiln feed: kilns where the mercury
concentration of the kiln feed is <= 20ppb, > 20 ppb, and high emitting
kilns. In arriving at a suggested MACT floor, the PCA approach assessed
the variability associated with fuels, limestone, and other raw
materials and then combined the variability’s to arrive at the floor.
Identical kilns at a cement facility were treated as a single source for
purposes of evaluating MACT floors; PCA understood that for compliance
purposes identical kilns could not be treated as a single source.  In
the PCA analysis additives are everything except limestone.  

EPA briefly described some of the approaches it was considering to
subcategorizing kilns.

Variability of mercury data was discussed including the variability in
the 30 days of sampled material, plant-to-plant variability and
month-to-month variability.

PCA agreed to provide EPA with a copy of their statistical analysis for
review.  (This item is included as an attachment to this docket entry
along with the mercury and THC data provided by EPA to the PCA at the
meeting).

EPA reminded the PCA that they had submitted a request to PCA and the
nine companies that responded to the ICR for mercury and total organic
carbon (TOC) data for supplemental information on the sources of raw
materials. EPA stated that this information was important to EPA’s
development and assessment of MACT floor options.

THC

PCA described an approach to arrive at a MACT floor for THC. Looking at
THC emissions data by type of kiln, they found THC emissions varied by
whether the raw mill was on or off. EPA stated that they did not see
much variation between the raw mill on and off conditions in the THC
emissions data they examined. Differences in the THC data sets used by
PCA and EPA may explain some of the observed differences.

PCA recommended that, as part of their evaluation of RTO for THC
control, EPA should consider factors such as the nonavailability of
natural gas in some parts of the country, as well as any adverse impacts
such as increased greenhouse gas emissions from RTOs.

B. Reconsideration Schedule

EPA explained that currently they are proceeding under the premise that
they will propose a rule by the middle of September as promised to the
DC Circuit Court.

NSPS

A. Proposed scope

The proposed rule applies to new kilns, all of which the PCA and EPA
expect to be PH/PC kilns.  Since 1990, all new kilns have been PH/PC
kilns. Also, kilns that are reconstructed and converted to PH/PC kilns
would be subject to the proposed rule.

If a kiln is modified such that it causes regulated emissions to
increase, NSPS is triggered. The PCA stated that it is likely that some
existing long wet or dry kilns will undergo some modifications that will
cause them to become subject to the proposed NOx and SO2 limits, which
they will not be able to meet. EPA stated that they will address this in
the final rule. PCA suggested that only PH/PC kilns be subject to the
NOx and SO2 limits. EPA stated that another option mentioned was to
subcategorize by kiln type and have different limits for each
subcategory.

B. Proposed NOx, SO2 and PM standards

NOx

The PCA identified the 1.5 lb/ton NOx limit as the most significant
issue in the proposed NSPS amendments and stated that the proposed
emission limit was only achievable at research facilities. According to
the PCA, problems with the NOx limit include NOx emissions from alkali
bypasses where the gases are diverted before they can be subject to
SNCR. A white paper describing the alkali bypass issue was prepared by
the industry and sent to EPA previously. PCA stated that data used as a
basis for the limit came from kilns in Florida and California where the
raw materials burn more easily and have lower alkali content.

EPA stated that a possible approach would be to set separate NOx limits
for the alkali bypass. EPA asked for information on the specifications
that define feed burnability and what limits would be appropriate where
such material is part of the raw feed.

PCA also questioned EPA’s use of a 50% removal efficiency for SNCR
systems and asked for the information source for the 50% efficiency,
stating that they could not find supporting documentation in the NSPS
docket. EPA stated that they would locate the documentation and get back
to the PCA with the information source.

PM

PCA stated that the proposed PM limit, including the use of lb/ton of
clinker units, was problematic for several reasons. In some cases, PM
emissions in gr/dscf were converted to lb/ton of clinker using a
standard value of 54,000 dscf/ton of feed. They stated that the
conversion value is not appropriate in all cases. Also, factors such as
moisture content, exhaust gases from clinker cooler combined with kiln
gases increases the mass to the baghouse. They suggested that a
concentration-based PM limit would avoid many of the problems associated
with the output based standard.

EPA stated that historically one of the problem associated with the
concentration-based limit is the potential for leakage into the exhaust
gases.

PCA stated that there are problems associated with the use of membrane
bags that EPA should consider. They stated that in the power industry,
membrane bags have the disadvantage of not forming a cake which reduces
acid gas emissions as well as Hg removal. PCA stated that EPA did not
account for situation in which clinker cooler and coal mill exhaust
gases are routed to the baghouse along with the exhaust gases from
kilns. The longevity and cost of membrane bags were also mentioned as
negative factors.

SO2

The PCA stated that the proposed rule is not clear as to where the 90%
reduction option applies. They stated it could be interpreted to mean
90% reduction of the sulfur in the system as well as 90% reduction of
the sulfur (SO2) in the kiln exhaust gases.

C. EPA approach used for technology cost effectiveness analyses

EPA described the approaches used to establish a best demonstrated
technology for each of the pollutants and the data and factors taken
into account in establishing the proposed emission limits.

D. Schedule/PCA Request for Comment Extension

EPA noted that the proposed rule was signed on May 30, 2008 and
published in the Federal Register on June 16, 2008. It was available on
EPA’s web site prior to appearing in the Federal Register.

Citing their efforts to collect and analyze data in order to properly
respond to the proposed rule, PCA requested a 60-day extension of the
comment period (to October 16, 2008). EPA responded that they often
grant extensions to allow commenters additional time to prepare their
comments. However, due to the court ordered deadline of May 31, 2009 for
promulgation, EPA will consider extending the comment period to
September 30, 2008.

V. Sector Approach

EPA described recent activity in their program to develop integrated
rulemakings for industry sectors. Recent activities include continuation
of economic modeling and evaluating combinations of controls to reduce
multiple air pollutants.

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