Meeting Summary

EPA and National Cement Company of Alabama, Inc. 

September 8, 2008

Research Triangle Park, NC

I.  Attendees

EPA

Keith Barnett, OAQPS/SPPD

Steve Fruh, OAQPS/SPPD

RTI

Marvin Branscome

National Cement Company Personnel and their representatives

Sid Trant, Bradley Arant Rose & White LLP

Jody Foster, Hogan & Hartson

Russell Kemp, Environ

Spencer Weitman, Natiojla Cement

Serge Brazzolotto, National Cement

John Holmes, AEMS L.L.P.

Patrick Raher, Hogen & Hartson

II.  Discussion Items

Background

The National Cement Company of Alabama is located in Birmingham, has 155
employees, and is one of two U.S. cement plants owned by the Vicat Group
(a family-owned French cement and concrete company).  The other plant is
in California.

The company has filed an application for a prevention of significant
(PSD) permit to construct a new kiln to replace the existing one.  They
will be ready soon to start construction on the $300 to $320 million
project.

The new kiln will be efficient with respect to fuel conservation, energy
use, and emissions.  The preheater/precalciner kiln will produce 5,000
metric tons per day, and 70% of the energy requirements will be met
using alternative fuels.

The company requested the meeting with EPA to discuss concerns and to
offer suggestions about the pending regulations that will impact the new
kiln:  the NSPS and revised MACT standards.  

Emission limits and controls

The kiln and emission control system will be designed to achieve PM
limits of 0.01 gr/dscf and 0.12 lb/ton of clinker for the main stack
and 0.10 lb/ton for the cooler.  SO2 limits will be 2.5 lb/ton (30-day
average) and 5.0 lb/t (24-hr average).  NOx will be limited to 1.95
lb/t.

+

PM emissions will be controlled by a baghouse.  Low-NOx burners and
selective non-catalytic reduction will be used for NOx control.  Dry
lime injection will be used to scrub SO2.

Company representative stated the kiln would be able to meet the limits
for dioxin/furans, PM, and mercury that are in the MACT standard. 
However, they are concerned that they will not be able to achieve the
THC limit of 20 ppm.

THC emissions range from 22 to 69 ppm and average 44 ppm with the raw
mill on and 33 ppm with the raw mill off.  They believe much of the THC
is from the release of entrapped methane and ethane when the limestone
is ground.

The company asked that EPA consider an equivalent alternative standard
of 5 ppm organic HAP based on a report in the rulemaking docket that
stated organic HAP averaged 23 percent of THC (in terms of
concentration).   They agreed to check with other companies to ask if
additional data were available relating organic HAP and THC.

They identified 11 HAP as candidates for analysis and suggested
compliance would be determined by sampling for the organic HAP within 18
months of startup, with repeat performance tests every 30 months.  

They recommended that THC CEMS not be required because of the high
variability in THC concentrations from the kiln, but suggested
parametric monitoring instead, such as the temperature at the exit of
the precalciner and the oxygen content of the exhaust at the top of the
preheater.

For mercury, they stated their kiln could meet 25 µg/m3 (raw mill on)
and 41 µg/m3 (raw mill off).  They stated that activated carbon
injection has not been done commercially at cement kilns.  They also
stated the cost effectiveness for add-on mercury controls would be much
higher for them ($20,000 to $40,000 per lb) than for a plant like Ash
Grove Cement ($5,000/lb).

For the NSPS, the new kiln can achieve the PM limit of 0.086 lb/ton. 
However, they expressed concern that they could not meet the NOx and SO2
limits.  They stated the planned controls will achieve a 60 percent
reduction in NOx and meet 1.95 lb/ton, but can’t meet the limit of 1.5
lb/ton even with more ammonia. The emissions without SNCR are estimated
to be 3.2 to 3.5 lb/ton clinker.  They expect the dry lime scrubber to
reduce SO2 emissions from 4.3 lb/ton to 2.3 lb/ton, but do not believe
they can meet a limit of 1.33 lb/ton or 90 percent reduction.

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