Summary of EPA–PCA Discussion on NESHAP Reconsideration

December 1, 2011

EPA Participants:

Keith Barnett, OAQPS

Sharon Nizich, OAQPS

Peter Westlin, OAQPS

Mike Laney, RTI

Matt Hakos, RTI

PCA Participants:

Curtis Lesslie, Ash Grove

Jason Morin, Holcim

Andy O’Hare, PCA

Mike Pelan, Lafarge

Adam Swercheck, Buzzi Unicem

Satish Sheth, CEMEX

Hector Ybanez, Holcim

Clinker Piles 

EPA is planning to drop the clinker pile design and management
requirements in lieu of imposing work practice standards, similar to
those employed for coal piles under NSPS Subpart Y.

STATUS: EPA is still on track to replace the design and management
standards with a menu of work practices similar to those under Subpart Y
for coal piles, but selected on a site-specific basis.  EPA also plans
to propose something very similar to the PCA proposed definition of
“open clinker piles”: unenclosed outdoor accumulations of clinker of
more than 50,000 tons in place for more than six months.  Lastly, there
was a back and forth regarding implementation of the work practice
standards.  PCA expressed a desire for them to be self implementing as
with similar obligations already outlined in Title V permits, in lieu of
having to have the site-specific practices themselves approved by a
permitting authority.

Modifications to the Total Hydrocarbon Standard

EPA plans to propose to allow facilities to correlate their THC
compliance value with the 9 ppmv organic HAP alternative limit.  

STATUS: EPA still plans to propose to allow facilities to scale up their
site-specific THC standard to be equivalent to a 9 ppm oHAP limit.

HCl, PM and Mercury Monitoring During Start-up and Shutdown (previously
two separate issues)

EPA is planning to drop the emission standards for start-up and shutdown
and replace them with work practice standards.

STATUS: EPA is still proposing to drop the emission standards during
start up and shutdown and to replace them with work practice standards. 
There was a brief discussion regarding the type of work practices that
EPA has in mind, and PCA was encouraged to review the anticipated boiler
NESHAP proposal to see where EPA was headed.  Lastly, there was a
discussion regarding the definitions of startup and shutdown.  EPA plans
to propose that startup begins when the kiln ID fan is running and the
kiln is combusting fuel.  Startup ends once feed is fed to the kiln. 
Shutdown begins when feed is no longer fed to the kiln.  

HCl Continuous Emission Monitors Associated with Dry Scrubbers

EPA plans to propose that facilities equipped with dry scrubbers do NOT
have to continuously monitor HCl emissions. 

STATUS: EPA still plans to propose to drop the HCl continuous emission
monitor obligation for those kilns using dry scrubbers.  The Agency also
suggested that they may require facilities using dry scrubbers to use
SO2 emissions as a surrogate for HCl compliance.  PCA explained at
length why this is a bad idea, explaining that SO2 emissions are not
tied to HCl emissions even though both may be controlled in varying
degrees by dry (and wet) scrubbing.  PCA suggested that a parameter,
such as lime injection molar ratios, may be used instead of a
relationship with SO2 emissions.  PCA agreed to provide more specific
details on the molar ratio concept.  Lastly, PCA expressed general
concern about the use of continuous HCl monitors, explaining that the
performance specification for the devices is not final.  PCA suggested
that EPA consider dropping this continuous monitoring obligation all
together. 

Alternative Particulate Matter (PM) Equation

EPA plans to propose the PCA recommended expanded alternative PM
equation, allowing for site-specific consideration of various commingled
sources, including clinker coolers, coal mills when computing a
site-specific PM emission limit.

STATUS: EPA plans to propose the alternative PM equation suggested by
PCA, or something very similar. 

Regulatory Status of Various Coal Mill Configurations

EPA plans to propose that coal mills with separate stacks which receive
cooler air or kiln gases be regulated under NSPS Subpart Y.  Facilities
with “in-line” coal mills (those that use kiln gases and then route
them back to the kiln stack from the coal mill) will be regulated under
Subpart LLL. 

STATUS:  There was an extended discussion regarding the three categories
of coal mills that have been under discussion, with EPA confirming that
the first category (coal mills receiving cooler air with separate stack)
would be under Subpart Y.  EPA also confirmed that the “in-line”
coal mills would be under Subpart LLL.  The discussion focused primarily
on those coal mills that receive kiln gases that vent through a separate
coal mill stack.  At issue, was how to account for mercury, and to a
lesser extent, total hydrocarbons, present in the kilns gases used by
the coal mill.  PCA suggested, and EPA agreed, that mercury emissions
from coal mills are likely to be very minimal because of the low
temperatures in the mills and the mercury scrubbing effect of the mill. 
PCA suggested that the mercury concern may be satisfactorily addressed
by conducting an initial and subsequent confirming performance test (no
more often than every 30 months (with 60 month intervals being
preferable) of the mercury emissions coming from the coal mill stack. 
No continuous mercury monitoring would be necessary.  

PM Limit for Modified Sources Under the NSPS

EPA plans to propose that the PM emission standard for modified NSPS
sources be the same as the existing source NESHAP PM standard.  

STATUS: EPA will propose a PM emission standard for modified NSPS
sources of 0.04 lbs/ton of clinker to replace the 0.01 lbs/ton of
clinker standard in the September 2010 rule.

Lastly, there was also a discussion regarding the EPA electronic
reporting tool, which requires sources to report by December 2011 on
certain performance/compliance test information.  EPA clarified that the
reporting obligation applies only to new requirements, not existing
requirements.  So, PCA members will not be required to report on testing
associated with compliance with the recent NESHAP changes until after
the compliance date.  Update from this meeting:  sources must report to
ERT 60 days after a performance test, if a performance test is done past
December 31, 2011.  Thus, the submittal is not tied into the compliance
date of 2013, but rather is tied into the actual date of the performance
test, even if the test has been performed before the compliance date.

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