MEMORANDUM

TO:  Portland Cement NESHAP Docket

FROM:  Keith Barnett, US EPA

DATE:  January 14, 2011

SUBJECT:  List of Facilities that Have the Potential to Idle Until Market Conditions Improve 

In the Regulatory Impact Analysis for the Portland Cement NESHAP EPA identified 10 domestic plants with negative operating profits and significant utilization changes that could temporarily idle until market demand conditions improve.  The actual plants on this list are shown below:


Plant No.
Parent Company
City
State
Kiln Type
Year Built
1
California Portland Cement
Colton
CA
2 Dry
1962
2
Cemex
Brooksville
FL
1 preheater
1987
3
Suwannee American Cement
Branford
FL
1 precalciner
2003
4
Essroc
Buckeystown (Frederick)
MD
2 wet
1958
5
Buzzi
Pryor
OK
3 dry
1960, 1962, 1980
6
Lafarge
Harleyville
SC
1 precalciner
1988
7
Cemex
Knoxville
TN
1 precalciner
1978
8
Texas Industries
New Braunfels
TX
1 precalciner
1979
9
Buzzi
Maryneal
TX
3 preheater
1971
10
Holcim
Midlothian
TX
2 precalciner
1987, 2000


Thought we believe the analysis we did was appropriate based on the data available to us at that time, we realize there are limitations to this analysis.  For example:

   * The CEMEX, Brooksfield facility added a new precalciner kiln in 2008 that is reportedly already meeting the mercury limit without having use add on controls.  Because we would expect that the older kiln uses the same fuels and raw materials, this implies that the older kiln will also be able to meet the mercury emissions limit without add on controls.  Thus control costs for this facility are likely overstated in EPA's cost analysis.

   * The Suwannee American facility is relatively new, and thus it would be expected to be more efficient than older kilns which should mean its production costs would be expected to be low.  The control costs for this facility do not appear to be unusually high, so we are unsure why the economic model projects that this kiln would idle.  

   * The Essroc, Buckeystown facility has reportedly already been shut down due to poor market conditions, though the shutdown had actually been planned for several years.

   * The Holcim, Midlothian, facility shows high costs because our analysis assumes a thermal oxidizer is required due to high current THC emissions levels.  However, this facility is a few miles from the TXI Midlothian facility.  The TXI Midlothian kiln already has a thermal oxidizer and appears to be competitive since it is still operating.      
