EPA/PCA Meeting on NESHAP and NSPS

Meeting Date:	January 29, 2009

Location:	US Environmental Protection Agency

		Research Triangle Park, NC

Participants:	Portland Cement Association and Industry Representatives

Andy O’Hare, PCA

Tim Matz, Lehigh

Nancy Garnett, TXI

Meg Garakani, Holcim

Dan Nugent, Buzzi Unicem

Fran Streitman, Ash Grove Cement

Hector Ybanez, Holcim

Bob Sullivan, Cemex

Charles Robertson, Titan Cement

Other cement company personnel

(Some of the industry representatives attended by phone)

US Environmental Protection Agency

Keith Barnett

Susan Thornloe

Elineth Torres

Steve Silverman

Research Triangle Institute

Mike Laney

Participants met to discuss issues and status of the NESHAP and NSPS for
portland cement manufacturing and other issues. The key items discussed
in relation to EPA’s development of the NESHAP and NSPS included:

NESHAP

Mercury

The data and the approach being used to establish MACT floors.

Use of scrubbers and wasting cement kiln dust as mercury control.

Issues associated with use of subcategories, especially
subcategorization based on the mercury concentration with limestone.

Use of the cement plant, as opposed to each kiln, as the affected
source.

Determining the appropriate approach to estimating variability
associated with mercury emissions.

In light of recent court ruling on emissions during startup, shutdown
and malfunction (SSM), how or whether to account for emissions during
SSM in emission limits.

Raw material (other than limestone) substitution as an approach for
reducing mercury emissions.

THC

Use of HAP specific limits as alternative to limit for THC.

Difficulties of identifying subcategories in developing MACT floors for
THC.

HCl

Background leading to EPA decision to set MACT floor limits for HCl.

Options being considered.

PM

Requirements under the urban air toxics provisions that led to the
decision to establish PM for area sources.

The current EPA data sets being used in floor development for mercury,
THC and HCl were distributed to the meeting attendees.

NSPS

Difficulty reducing NOx limits sufficiently where an alkali bypass is
used.

Experience of individual plants that have not been able to reduce their
NOx down to the proposed limit even when using SNCR and reasons for the
difficulties.

Issue of kiln modifications and whether modified kilns would be subject
to the NSPS.

Issues of measuring SO2 reductions in the case of dry lime injection
instead of a wet scrubber.

Comingling of gases (e.g., kiln and clinker cooler gases) and effects on
the ability of a facility to meet the proposed PM emissions limit.

On the modification issue, industry representatives noted that it is
possible to modify a kiln and also trigger PSD.  In that case, even if
hourly emissions did not increase, or the facility took action control
NOx to avoid an hourly increase, the source could still have to perform
a BACT determination.  This would require that the proposed NSPS level
be the lowest allowable standard.  This could result in long kilns or
preheater kilns being required to meet the 1.5 lb/ton clinker NSPS
level.  

Another concern is that it is sometime difficult to predict the hourly
NOx emission level post modification.  This could result in a situation
where a facility modified thinking there will be no hourly NOx increase,
but after modification finds out an increase, in fact, did exist.

