"Linero, Alvaro" <Alvaro.Linero@dep.state.fl.us> 
02/13/2009 08:50 AM	To
	Keith Barnett/RTP/USEPA/US@EPA
	cc
	
	bcc
	
	Subject
	Cement Hg-CEMS
	
	


Hi Keith.
 
Thanks very much for coming down to Florida.
 
Here is a further clarification from the German government regarding 
Hg-CEMS.
 
We already knew they require Hg-CEMS on kilns that use waste (and I'm sure
that means any waste, not just hazardous).
 
They also require Hg-CEMS on kilns that do not burn waste (alternative 
fuels)
if they emit at least 2.5 gm Hg/hr.
 
That would be about 40 lb Hg/yr at 8,000 hours.
 
Per the attachement, there are 34 Hg-CEMS at kilns in Germany.
 
I think this information is worthy of the cement MACT docket!
 
Thanks.
 
Al Linero.

   



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   From: Bernicke, Maja [mailto:maja.bernicke@uba.de] 
   Sent: Thu 2/12/2009 3:08 AM 
   To: Weiguo Wu 
   Cc: Ebertsch, Gerald; Hummel, Hans-Joachim; Linero, Alvaro; Plickert,
Sebastian 
   Subject: AW: Cement Hg-CEMS
   
   
   Dr. Mr. Wu,
   I would like to answer your questions raised in your e-mail as
follows:
   A. Based on article 17 (2) of the IPPC Directive, the European
Integrated Pollution Prevention and Control (IPPC) Bureau was set up to
organise an exchange of information between Member States and industry on
Best Available Techniques (BAT). The results of this information exchange 
are
reference documents on Best Available Techniques for different industrial
sectors, called BREFs. "BREFs are the main reference documents used by
competent authorities in Member States when issuing operating permits for 
the
installations that represent a significant pollution potential in Europe."
(see also http://eippcb.jrc.es/ <http://eippcb.jrc.es/> ) 
   The revision of the BREF for the cement, lime and dead burned
magnesia industry has been started in 2005. It is expected to be finalised
before summer.
    
   B. Hg CEM is also legally mandatory in Germany for cement kilns that
do not use alternative fuels (i.e. do not burn waste), if the mass flow of
mercury is above 2,5 g/h.
    
   C. The major problems were the quality assurance and the installation
of the devices themselves.  Now for most of the CEMs guidelines for quality
assurance, which set also requirements for the maintenance procedure, are
available. Due to the increased experiences with the equipment the problems
with the installation are minimised, too. 
    
   D. We subscribe to the view of Mr. Ebertsch: The Hg-CEMs are working
successfully.
   If there are further questions, do not hesitate to contact me again
or our expert for monitoring issues Mr. Hans-Joachim Hummel (mailto:
hans-joachim.hummel@uba.de).

   Kind regards 
   Maja Bernicke 

   __________________________________________________ 

   Federal Environment Agency 
   Section III 2.2 "Minerals and Metal Industry" 
   Maja Bernicke 
   Wörlitzer Platz 1 
   D-06844 Dessau-Roßlau 

   phone: +49 (0340) 2103-3691 
   fax : +49 (0340) 2104-3691 

   e-mail  : maja.bernicke@uba.de 
   homepage: www.umweltbundesamt.de <file://www.umweltbundesamt.de/>  


  _____  

   Von: Weiguo Wu [mailto:Weiguo.Wu@gov.ab.ca] 
   Gesendet: Montag, 9. Februar 2009 17:19
   An: Bernicke, Maja
   Cc: Linero, Alvaro; Ebertsch, Gerald; Plickert, Sebastian; Hummel,
Hans-Joachim
   Betreff: RE: Cement Hg-CEMS
   
   


   Dear Dr. Bernicke: 

   Thank you very much for your time and response. 

   Regarding the attached document in your e-mail, I have some questions
as follows: 

   A.      What does "BREF" mean? What kind of document is it?  

   B.      In note 1 of the document it was mentioned: "For German
cement kilns without using alternative fuels the technical requirement for
continuous monitoring of mercury (mass flow of mercury is above 2,5 g/h) is
laid down in the Technical Instructions on Air Quality Control – TA Luft." 

           
           Does this mean that use of Hg CEMS is also legally mandatory
in Germany for cement kilns that do not use alternative fuels (i.e. do not
burn waste)?

   C.      The document mentioned the following: "There were problems in
the application of the mercury CEMs (Continuous Emission Monitors) at the
beginning"; "Many efforts have been undertaken especially by the cement
industry to find out the reasons for problems and failures."; "it was
necessary to modify the commercially available devices". 

           What were the major problems, reasons for failures, and
necessary modifications for commercially available devices?  

   D.      Based on UBA's past experience, what is UBA's overall view
regarding the Hg CEMS currently available? Are they considered accurate and
reliable at present?

   Thanks again, Dr. Bernicke, for your time and help. 

   Warm regards, 

   Weiguo Wu, Ph.D., P. Eng. 
   Industrial Approvals Engineer 
   Alberta Environment 
   2nd Floor, Deerfoot Square 
   2938 - 11 Street NE 
   Calgary, AB T2E 7L7 
   * Weiguo.Wu@gov.ab.ca 
   * (403) 297-6385 
   * (403) 297-2749 


   -----Original Message----- 
   From: Bernicke, Maja [mailto:maja.bernicke@uba.de
<mailto:maja.bernicke@uba.de> ] 
   Sent: Monday, February 09, 2009 7:24 AM 
   To: Weiguo Wu 
   Cc: Linero, Alvaro; Ebertsch, Gerald; Plickert, Sebastian; Hummel,
Hans-Joachim 
   Subject: AW: Cement Hg-CEMS 

   Dear Mr. Wu, 
   please find enclosed the German contribution concerning the use of
Hg-CEMs in the cement industry for the BREF revision. It should answer your
questions in the main. We hope, this information will be integrated in the
final draft of the BREF.

   If there are further questions, do not hesitate to contact me again
or our expert for monitoring issues Mr. Hans-Joachim Hummel (mailto:
hans-joachim.hummel@uba.de).

   Kind regards 
   Maja Bernicke 

   __________________________________________________ 

   Federal Environment Agency 
   Section III 2.2 "Minerals and Metal Industry" 
   Maja Bernicke 
   Wörlitzer Platz 1 
   D-06844 Dessau-Roßlau 

   phone: +49 (0340) 2103-3691 
   fax : +49 (0340) 2104-3691 

   e-mail  : maja.bernicke@uba.de 
   homepage: www.umweltbundesamt.de <file://www.umweltbundesamt.de/>  




   -----Ursprüngliche Nachricht----- 
   Von: Linero, Alvaro [mailto:Alvaro.Linero@dep.state.fl.us
<mailto:Alvaro.Linero@dep.state.fl.us> ] 
   Gesendet: Sonntag, 8. Februar 2009 23:04 
   An: Weiguo Wu 
   Cc: Bernicke, Maja; Plickert, Sebastian;
Gerald.Ebertsch@lfu.bayern.de 
   Betreff: RE: Cement Hg-CEMS 

   O.k. Weiguo: 

   I think it is mandatory for cement plants that use waste to use
Hg-CEMS. 

   And it does not have to be categorized as hazardous waste for the
requirement to apply. 

   See references to daily and 1/2 hourly Hg limits to cement in: 

   
www.bmu.bund.de/files/pdfs/allgemein/application/pdf/17bimschv_eng.pdf
<
file://www.bmu.bund.de/files/pdfs/allgemein/application/pdf/17bimschv_eng.p
d
f>  

   See discussion in the site of the German Cement Research Institute: 

   www.vdz-online.de/190.html?&lang=en#a4067
<file://www.vdz-online.de/190.html?&lang=en#a4067>  

   Almost all cement plants in German burn some kind of waste so most
have Hg-CEMS. 

   I would expect that some that don't burn waste might also monitor due
to local requirements. 

   For purposes of this hemisphere, I think just using fly ash from a
power plant that is not usable for making concrete constitutes waste use.

   Given that the requirement has been in the German rules since 2003,
they certainly believe there are accurate Hg-CEMS. 


   Maybe you can ask Dr. Maja Bernicke of the German Umweltbundesamt or
her colleagues if they can recommend someone to write you about this.

   (note:  Weiguo works for the Province of Alberta, Canada and is
reviewing possibility of Hg-CEMS for a cement plant). 

   In this country I have not seen them. 

   I may have been the first person to require Hg-CEMS at a cement plant
and also at a waste-to-energy plant. 

   The nature of Hg emissions (non uniformity) is good reason for
requiring Hg-CEMS or sorbent traps or very accurate material and fuel
testing.

   I did not do an extensive survey about all this.  I found enough
technical justification to require Hg-CEMS (at least for new plants) and
proceeded on that basis.

   Of course, my own eyes saw the one at Solnhofer cement. 

   Best regards. 

   Al Linero. 

   Florida Department of Environmental Protection. 



           From: Weiguo Wu [mailto:Weiguo.Wu@gov.ab.ca
<mailto:Weiguo.Wu@gov.ab.ca> ] 
           Sent: Fri 2/6/2009 1:16 PM 
           To: Linero, Alvaro 
           Cc: 
           Subject: RE: Cement related information 


           Hi Al, 

           Would you please help me with the following questions?  Many
thanks. 

           A.  Is it mandatory for all cement plants in Germany to
install Hg CEMS, or only those cement plants that burn some waste?

           B.  Are the Hg CEMS installed in cement plants in Germany
used for regulatory compliance purpose, or just for voluntary data
collection?

           C.  Do you have some contacts with German environmental
regulatory agencies who are familiar with the above regulations? If you 
have,
would you mind giving me some contacts?

           Have a nice weekend, Al! 

           Best regards, 


           Weiguo 


     _____ 

           From: Linero, Alvaro [mailto:Alvaro.Linero@dep.state.fl.us
<mailto:Alvaro.Linero@dep.state.fl.us> ] 
           Sent: Thursday, January 29, 2009 4:46 PM 
           To: Weiguo Wu 
           Subject: RE: Cement related information 


           O.K. Weiguo: 

           I only visited Solnhofen, Germany and Monselice, Italy. 

           I believe all cement plants in Germany that burn some waste
have the Hg-CEMS. 

           At Solnhofen they certainly seemed satisfied with their
Hg-CEMS and I got the general impression that such sampling is routine.

           I could tell that they take great pride in operating all of
the many CEMS in the best manner. 

           Best regards. 

           Al.
