Portland Cement Reconsideration 

Technical Support Document

DRAFT

May 31 2012



Table of Contents

  TOC \o "1-2" \h \z \u    HYPERLINK \l "_Toc326223092"  1.	Introduction
  PAGEREF _Toc326223092 \h  1  

  HYPERLINK \l "_Toc326223093"  2.	Outdoor Clinker Storage Pile Work
Practice Standard Development	  PAGEREF _Toc326223093 \h  1  

  HYPERLINK \l "_Toc326223094"  2.1	Control Measure Results	  PAGEREF
_Toc326223094 \h  2  

  HYPERLINK \l "_Toc326223095"  2.2	Emission Standard Results	  PAGEREF
_Toc326223095 \h  3  

  HYPERLINK \l "_Toc326223096"  3.	Continuously Monitored Parameters for
Alternative Organic HAP Standard (with THC Monitoring Parameter)	 
PAGEREF _Toc326223096 \h  4  

  HYPERLINK \l "_Toc326223097"  4.	Coal Mills	  PAGEREF _Toc326223097 \h
 5  

  HYPERLINK \l "_Toc326223098"  5.	Allowing Sources With Dry Caustic
Scrubbers to Comply With HCl Standard Using Performance Tests.	  PAGEREF
_Toc326223098 \h  10  

  HYPERLINK \l "_Toc326223099"  6.	PM Standard for Modified Sources
Under the NSPS	  PAGEREF _Toc326223099 \h  11  

  HYPERLINK \l "_Toc326223100"  7.	Alternative PM Limit	  PAGEREF
_Toc326223100 \h  12  

  HYPERLINK \l "_Toc326223101"  8.	MACT Floor Development	  PAGEREF
_Toc326223101 \h  12  

  HYPERLINK \l "_Toc326223102"  8.1	Hydrogen Chloride (HCl)	  PAGEREF
_Toc326223102 \h  13  

  HYPERLINK \l "_Toc326223103"  8.2	Mercury (Hg)	  PAGEREF _Toc326223103
\h  14  

  HYPERLINK \l "_Toc326223104"  8.3	Particulate Matter (PM)	  PAGEREF
_Toc326223104 \h  15  

  HYPERLINK \l "_Toc326223105"  8.4	Total Hydrocarbon (THC)	  PAGEREF
_Toc326223105 \h  15  

  HYPERLINK \l "_Toc326223106"  8.5	Organic HAP (oHAP)	  PAGEREF
_Toc326223106 \h  16  

  HYPERLINK \l "_Toc326223107"  9.	Impacts of Revised PM Standard	 
PAGEREF _Toc326223107 \h  16  

  HYPERLINK \l "_Toc326223108"  10.	Summary	  PAGEREF _Toc326223108 \h 
18  

 

List of Tables

  TOC \h \z \c "Table"   HYPERLINK \l "_Toc321127038" Table 1: Summary
of 2012 Proposed NESHAP for Existing Sources	  PAGEREF _Toc321127038 \h 
13  

 HYPERLINK \l "_Toc321127039" Table 2: Summary of 2012 Proposed NESHAP
for New Sources	  PAGEREF _Toc321127039 \h  13  

 Introduction 

In response to two separate events, the EPA is proposing amendments to
the National Emission  Standards for Hazardous Air Pollutants (NESHAP)
for the Portland cement industry (40 CFR part 63 subpart LLL) and to the
New Source Performance Standards (NSPS) for Portland cement plants (40
CFR part 60 subpart F) issued under the Clean Air Act (CAA). 

In response to industry petitions for administrative reconsideration to
reconsider the NESHAP standards and specific issues in the NESHAP, and
to reconsider the NSPS PM standards, the EPA granted reconsideration of
portions of the reconsideration petitions on May 17, 2011 (76 FR 28318).
The issues in the NESHAP on which EPA granted reconsideration include:
amendments to address the regulation of fugitive emissions from open
clinker piles, organic hazardous air pollutant (HAP) compliance
demonstration, applicability of standards to coal mills, requirements
for monitoring hydrochloric acid (HCl) when controlled using dry
scrubbers, , the equations used to calculate the PM limits, the
affirmative defense for malfunctions and specific issues relating to
startup, shutdown and malfunction standards. EPA also granted
reconsideration of the new source performance standards for particulate
matter (PM) emissions from modified sources. 

The proposed amendments also respond to the D.C. Circuit’s opinion in
Portland Cement Ass’n v. EPA, 665 F. 3d 177 (D.C. Cir. 2011).  In that
case, the court rejected all challenges to the methodology EPA used to
establish the NESHAP but remanded the NESHAP so that EPA could account
for the effects of EPA’s Non-Hazardous Secondary Materials (NHSM)
rule. 

EPA is proposing to amend the NESHAP new and existing source standards
for PM, and to make corresponding amendments to the NSPS for PM. EPA is
also proposing to amend the alternative organic HAP limit in the NESHAP,
and to propose amendments regarding many of the issues listed above.  In
addition, we are proposing corrections and clarifications to the
rule’s testing and monitoring provisions.  Because the proposed
changes in the PM limits could affect compliance strategies for some
sources, EPA is proposing to extend the date for compliance with the
existing source NESHAP to September 9, 2015, two years from the
presently applicable compliance date.

This Technical Support Document contains pertinent data, calculations,
and discussions regarding new emissions and work practice standards
reflected in the proposal. For purposes of estimating cost and
environmental impacts of the proposed amendments, the data used in
estimating the impacts of the 2010 final rule were used with the
exception that 24 kilns (14 facilities) burning commercial and
industrial solid waste (CISWI kilns) were excluded. The modified data
set consist of 116 existing kilns and 16 new kilns at 86 plants

Outdoor Clinker Storage Pile Work Practice Standard Development 

The Portland Cement Association (PCA) has stated that most Title V
permits contain provisions that reduced fugitive emissions from open
clinker piles. To confirm this and to gather information on the types of
measures required for outdoor storage piles, EPA reviewed 88 portland
cement manufacturing facilities’ permits.  Permits were first reviewed
to confirm the existence of outdoor clinker storage piles and to
identify the permit conditions addressing air emissions from these
storage piles.  EPA also examined these permits for provisions regarding
analogous types of piles, such as those for feed materials. Finally, EPA
reviewed permits to identify any facility-wide permit conditions
relating to fugitive dust, visible emissions or opacity requirements. It
was assumed that facility wide conditions apply to any outdoor storage
piles, unless the permit stated otherwise.

For the purposes of this review, “control measures” were considered
to be permit provisions requiring the facility to implement some
physical measure to control emissions relating to outdoor storage piles.
 Examples of control measures include:

Requirements for:

application of asphalt, oil, water, or other suitable chemicals

full or partial enclosure

wind barriers

moisture content 

silt content

coverings

traffic on and around storage pile(s)

earthen berm and biological wind break

“Emission standards” were broken into three sub-categories, as
follows:

General duty requirements – any general requirement for the facility
to “prevent” fugitive dust / particulate emissions.  

Example: The Permittee shall not cause, allow, or permit organic or
inorganic dust producing material to be stacked, piled, or otherwise
stored without taking reasonable precautions to prevent excessive
amounts of particulate matter from becoming airborne.

Visible emissions limitation – any requirement requiring the facility
not to allow visible emissions or fugitive dust / particulate to leave
the “facility property line.”

Example: Emissions of fugitive dust from any transport, handling,
construction or storage activity at this facility shall not be visible
in the atmosphere beyond the property line of the facility.

Example: The permittee shall maintain plant roads and grounds in the
vicinity of the source permitted herein in the following manner so that
dust will not leave the permittee’s property

Opacity limitations – any requirement specifying a numerical opacity
limit not to be exceeded.

Example: Opacity of an emission from any fugitive dust source shall not
be greater than 40% measured in accordance with EPA Reference Method 9. 

Control Measure Results

The detailed results of the control measures review are presented in
Appendix I.  A summary of the results is presented below:

Outdoor clinker storage piles – 7 permits contained a specific control
measure 

Outdoor storage piles – 16 permits contained a specific control
measure 

Facility-wide permit conditions – 31 permits contained a facility-wide
control measure.

Emission Standard Results

The detailed results of the emission standards review are presented in
Appendix J.  A summary of the results is presented below:

Outdoor clinker storage piles – 8 permits contained specific emission
standards. The division of requirements is presented below:

Outdoor Clinker Storage Piles

General duty requirements	Visible emissions limitation	Opacity
limitations

1	1	6

Outdoor storage piles – 18 permits contained specific emission
standards. Please note that one facility had more than one type
(example: general duty and opacity) of requirement. The division of
requirements is presented below:

Outdoor Storage Piles

General duty requirements	Visible emissions limitation	Opacity
limitations

6	2	12

Facility-wide permit conditions – 77 permits contained facility-wide
emission standards. Please note that many facilities had more than one
type (example: general duty and opacity) of requirement. The division of
requirements is presented below:

Facility-wide Permit Conditions

General duty requirements	Visible emissions limitation	Opacity
limitations

27	31	59

Of the 88 permits reviewed in this analysis, 87 had either a control
measure or an emission standard (i.e., general duty requirement, visible
emission limit, or opacity limit) relating to fugitive dust /
particulate matter control from outdoor storage (assuming that
facility-wide conditions pertain to outdoor piles).  The permit reviewed
for one Ohio facility appeared to lack control measures or emissions
standards.

It is important to note that the state of Ohio does have fugitive dust
and opacity standards relating to fugitive emissions from storage piles
(refer to rule 3745-17-07(B) and 3745-17-08(B)).  However these
standards only apply to facilities located within certain designated
areas of the state.  For example, the other facility in Ohio evaluated
under this analysis has portions of its operations located in an area
required to implement these standards.

In conclusion, it appears nearly all facilities evaluated have some sort
of standard relating to fugitive dust from storage piles.  However, for
general duty requirements it is difficult to determine the extent to
which a facility has actually complied with “preventative” measures.
 Additionally, facility-wide requirements were generally assumed to
apply to any outdoor storage piles, unless stated otherwise.
Facility-wide requirements are required by state rules and regulations,
which vary state to state.  Therefore, there is inherent uncertainty
regarding the intent of each state regulation and if/how it would apply
to storage piles. Although the degree to which any of the work practices
successfully prevent fugitive emissions will vary, if applied properly
various sources report emission reductions of 75 to over 90 percent
(Western Regional Air Partnership Fugitive Dust Handbook, September 7,
2006; USEPA, Technical Background Document on Control of Fugitive Dust
at Cement Manufacturing Facilities, 1998). These work practices have
also been identified and are promoted by air pollution control agencies
as effective fugitive dust control  measures (Pima County Department of
Environmental Quality, Dust Control Measures,    HYPERLINK
"http://www.deq.pima.gov/air/pdf/DustBrochures/Dust_Methods_Constr.PDF" 
http://www.deq.pima.gov/air/pdf/DustBrochures/Dust_Methods_Constr.PDF ;
City of Albuquerque Environmental Health Department, Air Quality
Division, Fugitive Dust Control, 12//05,
http://www.cabq.gov/airquality/pdf/dustcontrolmethods.pdf).

Continuously Monitored Parameters for Alternative Organic HAP Standard
(with THC Monitoring Parameter)

EPA is proposing a revision to the alternative organic HAP limit from
the 2010 rule’s 9 ppm to 12 ppm based on the method detection
capabilities for Method 320 and Method 18, the two methods appropriate
for the compounds measured when determining compliance with the
alternative organic HAP limit. For the total organic HAP emissions data,
we applied the following procedure for determining an RDL for methods
used in measuring organic HAPs. We determined method detection
capabilities for Method 320 and Method 18 as appropriate for the various
compounds (e.g., Method 320 for aldehydes, Method 18 for arenes). We
believe that this approach is representative of procedures practiced by
the better performing testing companies and laboratories using the
reasonably applicable and sensitive analytical procedures. We determined
for each of the organic HAPs the expected method detection level for the
respective method based on internal experience and method capabilities
reported by testing companies. With these reported values, we identified
the resulting mean of the method detection levels as the representative
detection level (RDL) because it is characteristic of accepted source
emissions measurement performance. The following table summarizes those
findings.

Pollutant	Method used	RDL

ppmv, as measured	RDL

ppmv @7% O2 dry

Formaldehyde	Method 320	0.15	0.23

Acetaldehyde	“	1.50	2.34

Benzene	Method 18 (adsorbent tube)	0.04	0.08

Toluene	“	0.04	0.08

Styrene	“	0.04	0.08

Xylenes (m,p,o)	“	0.12	0.24

Napthalene	“	0.03	0.06



The second step in the process is to calculate 3xRDL for the sum or
total of the organic HAPs to compare with the emissions limit in the
final rule. This step is similar to calculation of a practical
quantitation limit in other NESHAP including the 2010 final portland
cement NESHAP.  See 75 FR at 54984. We use the multiplication factor of
3 to reduce the imprecision of the analytical method until the
imprecision in the field sampling reflects the relative method precision
as estimated by the ASME ReMAP study. That study indicates that such
relative imprecision remains a constant 10 to 20 percent over the range
of the method. For assessing a potential standard relative to
measurement method capabilities, if 3xRDL were less than the candidate
standard, we would conclude that the standard can be reliably measured. 
If, on the other hand, the value equal to 3xRDL were greater than the
standard, we would conclude that the calculated standard could not be
measured reliably (or, put another way, failed to account adequately for
measurement variability). Where such was the case, we increase the
calculated standard level to the value equal to 3xRDL. This would result
in a standard where the method would produce measurement accuracy on the
order of 10 to 20 percent, similar to other EPA test methods and the
results found in the ASME ReMAP study.

We summed the RDLs adjusted for dilution and moisture as shown in the
table above. We determined 3xRDL for the sum of the adjusted pollutants
to be 11.2 ppmv @ 7 percent O2, dry. This value is greater than the
final 9 ppmv @ 7 percent O2, dry, in the final rule. As a result, we are
proposing to adjust the total organic HAP limit to 12 ppmv @ 7 percent
O2, dry.  At this level, we believe that currently available emissions
testing procedures and technologies provide the measurement certainty
sufficient for sources to reliably demonstrate compliance.  Section 10.5
below contains additional information regarding derivation of the
relevant RDLs.

Coal Mills 

Cement kilns burn coal as their main fuel, and mill the coal before
firing it.  From the standpoint of air emissions, these coal mills are
sometimes physically distinct from the cement kiln, generating emissions
solely attributable to the coal mill and emitting exhaust through a
dedicated stack.  However, some kilns are configured so that coal mill
emissions are commingled with kiln exhaust and the emissions are
discharged through the main kiln stack.  Finally, there are some
configurations whereby kiln emissions are routed to the coal mill and
discharged through the coal mill stack.

First, EPA has promulgated new source performance standards (40 CFR Part
60 subpart Y) for coal mills. See 74 FR 51952 (October 8, 2009).  These
standards apply to coal mills, including coal mills at cement
manufacturing facilities, which emit through a dedicated stack.  These
standards do not apply to coal mills at cement facilities whose only
heat source is kiln exhaust. See section 60.251 (definition of indirect
thermal dryer).  This leaves at least partially ambiguous the regulatory
treatment of the situations where a kiln whose coal emissions are
discharged through the main kiln stack, and the coal mill whose
emissions which receives some exhaust from the cement kiln so that some
portion of the coal mill exhaust reflect cement kiln emissions.  Because
we did not address these issues in the 2010 final NESHAP for portland
cement kilns, we granted reconsideration in order to do so.  See 76 FR
at 28326.

A cement kiln which commingles emissions from its coal mill with all
other emissions and discharges through kiln emission points would have
to meet all of the NESHAP.  In the case of PM, the additional flow from
the coal mill would be accounted for in the equation used to determine
an alternate PM limit from commingled flows.  See section 7 below.

In the case of a coal mill which receives and discharges some of the
cement kiln exhaust, the regulatory concern is that this re-routing of
kiln exhaust not become a means of avoiding the NESHAP controls for
cement kiln HAP. 

Our basic principle for this situation would be that the kiln
demonstrate that it is meeting all of the NESHAP standards for
pollutants not regulated under the subpart Y coal mill standard, that is
mercury, THC, and HCl.  Because the subpart Y standards contain a PM
standard predicated on use of fabric filter control technology, we do
not believe it necessary to account for diverted PM emissions.  

We are proposing the following compliance mechanisms for the mercury,
THC, and HCl standards in this situation. 

We are proposing that the sum of the kiln emissions and diverted kiln
emissions (i.e. the kiln exhaust diverted to the coal mill) must not
exceed the subpart LLL NESHAP emission limits for each respective HAP or
HAP surrogate. The proposed rule contains requirements to document the
contribution of the emissions diverted to the coal mill.  With respect
to THC and HCl, because coal may be a source of these emissions, we are
proposing that performance tests for THC and HCl be performed upstream
of the coal mill. For mercury, tests would be required downstream to
account for any mercury removal in the coal mill air pollution control
device (APCD), and to avoid double counting emissions of mercury from
mercury that becomes re-entrained in the coal which is then burned by
the cement kiln (which emissions are otherwise accounted for in the
NESHAP). 

An analogous situation is when a cement kiln has an alkali bypass which
receives and exhausts emissions from the kiln.  We are proposing that
these emissions be subject to the same principle – the total
emissions of the kiln and alkali bypass must meet the subpart LLL
NESHAP – and would use the same monitoring procedures to document
compliance. The one (slight) exception is PM.  Because there is no
independent PM standard for an alkali bypass (unlike the situation for
coal mills, where subpart Y regulates PM emissions), the summed PM
emissions from the kiln and alkali bypass would have to be equal to or
less than the PM limit in the subpart LLL NESHAP. Tests for PM from the
alkali bypass would be downstream of the alkali bypass APCD to account
for those emission reductions. 

a.	Mercury.  Although mercury from the main stack is monitored using a
CEMS, there is no need for such monitoring for the gas streams from the
coal mill.  The gas stream to the coal mill is small in comparison to
the kiln exhaust, operation of the coal mill is intermittent, and the
cost of requiring additional CEMS for coal mills would be overly
burdensome. Instead, we are proposing that performance tests for mercury
be conducted at such a coal mill once per year, and, as explained above,
that the tests be conducted downstream of the coal mill. The proposed
amendments require performance tests for mercury to be conducted using
either Methods 29 or 30B in Appendix A-8 to 40 CFR Part 60.  These
performance tests would be required annually until the tested mercury
levels are below the method detection limits for two consecutive years,
after which tests may be conducted every 30 months. If test results at
any time exceed the method detection limit, annual performance testing
would again be required until mercury levels are below the method
detection limit for two consecutive years. The results of the
performance test would then be summed with the emissions from the kiln
stack to determine compliance with the mercury emissions limit. Since
kiln stack emissions are measured continuously with a CEMS, the coal gas
emissions would need to be normalized on both a CEMS and production
basis (lb/MM ton clinker) in order to be summed with the kiln stack
emissions.  To do so, we are proposing that the flow rate to the coal
mill be continuously monitored. Using the results of the annual
performance test and the flow rate, the owner or operator would develop
a mercury hourly mass emission rate for the coal mill. Using the hourly
mass emissions rate and continuous flow rate, hourly mercury emissions
from the coal mill could be determined and summed with the mercury
emissions from the kiln to determine continuous compliance (the same
approach would be applied to a kiln with an alkali bypass that exhausts
to a separate stack):

((Qab×Cab)+(Qcm×Ccm)+(Qks×Cks))/P ≤ MACT Limit

Where:

Qab 	= 	Alkali bypass flow rate (volume/hr)

Cab 	= 	Alkali bypass concentration (lb/dscf)

Qcm	= 	Coal mill flow rate (volume /hr)

Ccm	= 	Coal mill concentration (lb/dscf)

Qks	= 	Kiln stack flow rate (volume /hr)

Cks	= 	Kiln stack concentration (lb/dscf)

P 	= 	Kiln production rate (million tons clinker/hr)

MACT Limit	= 	Limit for mercury (55 lb mercury/MM tons clinker)

Thus, if the normalized test results  at the coal mill control device
outlet shows mercury emissions of 10 lb/MM tons clinker, emissions from
the kiln would have to be less than 45 lb/MM tons of clinker to be in
compliance with the proposed mercury emissions limit.

For kilns also equipped with an alkali bypass, the same procedure as
that for the coal mill would apply. Where a portion of kiln gases are
diverted to a coal mill and to an alkali bypass, emissions from the coal
mill and alkali bypass would be tested, normalized, and summed and with
the mercury emissions from the kiln to determine compliance with the
emissions limit. 

As stated above, the proposed amendments require performance tests for
mercury to be conducted using either Methods 29 or 30B in Appendix A-8
to 40 CFR Part 60. A cost of a single test would be $22,800 per year per
kiln and $45,600 if tests are done on the coal mill and alkali bypass.
The number of sources with separate stacks that would have to be tested
is not known. If it is assumed that one-half of the 133 kilns (67 kilns)
would require test on both the coal mill and alkali bypass, total
nationwide cost would be $3.1 million per year (45600*67). The capital
cost of a single flow meter would be $35,780 and $71,560 if installed on
the coal mill and alkali bypass stacks. Annualized cost for a single
flow meter is $11,275 and $22,550 for two. Nationwide, the capital cost
of flow meters would be $4.8 million (71560*67) with annualized cost of
$1.5 million (22550*67).

b.	THC and HCl.  Because THC and HCl are concentration-based limits, the
proposed compliance demonstration differs in certain details from the
procedure described above for the production based limits for mercury.
We  are proposing that kiln stack emission limits (to be continuously
monitored) be calculated taking into consideration the volumetric
exhaust gas flow rates and concentrations of all applicable effluent
streams (kiln stack, coal mill, and alkali bypass) for the kiln unit as
follows:   

((Qab×Cab)+(Qcm×Ccm)+(Qks×Cks))/((Qab+ Qcm+Qks) )≤MACT Limit

Where:

Qab 	= 	Alkali bypass flow rate (volume/hr)

Cab 	= 	Alkali bypass concentration (ppmvd)

Qcm	= 	Coal mill flow rate (volume /hr)

Ccm	= 	Coal mill concentration (ppmvd)

Qks	= 	Kiln stack flow rate (volume /hr)

Cks	= 	Kiln stack concentration (ppmvd)

MACT Limit	= 	Limit for THC or HCl (ppmvd)

This equation requires all values to be at or corrected to 7 % oxygen. 

≤((MACT Limit×(Qab+Qcm+Qks))-(Qab×Cab)-(Qcm×Ccm))/Qks

This equation is based on the following: 

The total allowable mass emissions of THC and HCl for the kiln unit can
be determined with the sum of all flow rates (coal mill, alkali bypass,
and kiln stack) and the applicable MACT limit (THC or HCl)
concentration.  This yields the total allowable mass emissions per unit
of time for the kiln unit according to the MACT limits and the site
specific flow rates for the coal mill, alkali bypass, and kiln stack.

By testing the coal mill and alkali bypass streams for concentration and
flow rate, the actual mass of THC and HCl emitted per unit of time can
be determined.

Subtracting the actual mass emissions of THC and HCl leaving the coal
mill and alkali by pass from the total allowable mass emissions for the
kiln unit determines the remainder of allowable mass emissions that can
be emitted through the kiln stack.

With knowledge of the flow rate at the kiln stack (measured by CEMS) and
the allowable mass emissions (i.e. remainder) that can be emitted
through the kiln stack, a site specific concentration can be determined.
 The equation above provides a simplified approach to determining this
value. 

As an illustration of how the site specific limit would be calculated,
we have provided the following example for calculating a site specific
THC emission limit. In this example, we assume a kiln stack, coal mill
and alkali bypass with the following volumetric flow rates and THC
concentrations:

Effluent

Stream	Flow Rate

(dscm/hr)	THC Concentration

(ppmvd)

(@ 7% O2)	Notes	MACT LIMIT

(ppmvd)

(@ 7% O2)

Alkali Bypass	Qab	38,233	Cab	56	Determined through test	24

Coal Mill	Qcm	57,349	Ccm	56	Determined through test

	Kiln Stack	Qks	286,746	Cks	TBD	Flow rate monitored by CEMS

	

With the simplified equation provided above, the THC value that must not
be exceeded in the kiln stack (verified with CEMS) is determined as
follows: 

Cks≤((3024×(38,233+57,349+286,746))-(38,233×56)-(57,349×56))/286,74
6

Using the equation above, Cks is less than or equal to 13.3 ppmvd @ 7%
O2.  This site specific value would be monitored by a CEMS in order to
demonstrate compliance with the 24 ppmvd MACT limit for THC. 

The proposal for THC and HCl is thus essentially the same as that for
mercury (except that concentrations are involved rather than
production-normalized mass): the flow-weighted averages of THC and HCl
must be less than or equal to the subpart LLL NESHAP.  The kiln stack
emissions are measured by a CEMS (for THC) or by other applicable means
(for HCl).  The flow-weighted contributions from other sources (the
alkali bypass and the kiln exhaust diverted to the coal mill) are
assessed by annual testing and applied continuously with flow being
measured continuously (explained further in the next paragraph).  As
noted above, the testing of the kiln exhaust diverted to the coal mill
would be conducted upstream of the coal mill for THC and HCl so that
only the kiln exhaust contribution is assessed. 

To monitor compliance continuously, we are proposing that gas flow rate
from the coal mill and alkali bypass be monitored continuously and that
a parametric limit for gas flow be established during the annual
performance test. This flow rate measured during the annual performance
test would be the maximum flow rate allowed during the year. If a higher
flow rate is observed, the owner/operator would have to retest THC and
HCl to obtain a new flow-weighted concentration which would be summed
with the kiln main stack THC or HCl concentration to determine whether
the kiln is still in compliance. Because of this requirement, the
owner/operator should perform their test at a flow rate that would cover
the range of conditions expected. For HCl, the performance test would be
performed using Method 321 in Appendix A to 40 CFR Part 63. For
measurement of THC, Method 25A in Appendix A-7 to 40 CFR Part 60 would
be required. Annual cost of a single test would be $20,000 per kiln for
HCl and $8,000 for THC. Annual cost if tests are done on coal mill and
alkali bypass stacks would be $40,000 and $16,000 for HCl and THC,
respectively. The number of kilns with separate stacks that would have
to be tested is not known. If it is assumed that one-half of the 133
kilns would require the test, total nationwide cost would be $2.7
million per year (40000*67) for HCl and $1.1 million per year (16000*67)
for THC.

c.	PM.  As explained above, in the situation where a cement kiln diverts
some exhaust to an integrated coal mill, the coal mill would have to
meet the subpart Y standards, and the kiln would have to meet the
subpart LLL NESHAP standard but would not have to account for the
diverted exhaust in doing so.  In all other situations, PM contribution
from a coal mill (or from an alkali bypass) would be accounted for via
the equation discussed in section 7 below. If the alkali bypass
discharges separately, it would have to sum its PM emissions with those
from the main stack and the summed emissions would have to be less than
or equal to the subpart LLL NESHAP standard for PM. 

Allowing Sources With Dry Caustic Scrubbers to Comply With HCl Standard
Using Performance Tests.

The September 2010 final rule allows sources equipped with wet scrubbers
to comply with the HCl standard by means of periodic performance tests
rather than with continuous monitoring of HCl with a CEMS. Sources
electing to comply by means of stack tests must establish continuously
monitored parameters including liquid flow rate, pressure and pH and are
required to perform an initial compliance test using Method 321 and to
test every 30 months thereafter.

Industry commented that this compliance option should not be limited to
wet scrubber equipped units, but should also be available for units
equipped with dry caustic scrubbers, in part because some sources will
be equipped with dry scrubbers (due to water shortages) and should have
the same operating flexibilities as wet scrubber equipped kilns.

A recent review of data from a vendor of acid gas controls using a
standard hydrated lime and a high performance hydrated lime at a US
cement manufacturing plant, revealed that HCl removal from dry scrubbers
on kilns ranged from 90 to 95 percent HCl removal, depending on lime
injection rates (Lhoist North America, Cement Industry Experience, DSI
for Acid Gas Control, October 5, 2011). The results also showed the
plant could meet the 3 ppm HCl limit. EPA also evaluated HCl removal
efficiency using dry sprayer absorber with a fabric filter as part of
the electric utility generating (EGU) MACT rulemaking. Removal
efficiencies ranged from 95 percent to nearly 100 percent with an
average of about 99.8 percent (Hutson to Nizich, HCl control using
SDA/FF, November 29, 2011). In addition, information from the National
Lime Association
(http://www.lime.org/uses_of_lime/environmental/flue_gas.asp) and the
Institute for Clean Air Companies
(http://www.icac.com/i4a/pages/index.cfm?pageid=3401)report HCl
emissions reductions using dry lime injection technology of 95 to 99
percent from coal-fired boilers in the electric utility industry, from
municipal waste-to-energy facilities and from other industries. In the
secondary aluminum industry, reductions in HCl emissions greater than 99
percent have been achieved (National Lime Association, Flue Gas
Desulfurization,
http://www.lime.org/uses_of_lime/environmental/flue_gas.asp). 

Given these high reported removal efficiencies, we propose to extend the
same option provided to kilns equipped with wet scrubbers to dry
scrubber-equipped kilns.  EPA is proposing that dry scrubber-equipped
kilns have the same option as kilns equipped with wet scrubbers for
complying with the HCl limit by means of an initial and periodic stack
test rather than continuous compliance monitoring with a CEMS. The
proposed amendment would require that the lime injection rate used
during the performance test demonstrating compliance with the HCl limit
be recorded and then continuously monitored between performance tests to
show that the injection rate remains at or above the rate used during
the performance test. The number of sources that are likely to select
this alternative monitoring approach is not known and impacts were not
estimated.

EPA is also proposing additional alternatives for kilns that are
equipped with a dry or wet scrubber. Where either wet or dry scrubbers
are used, we are proposing that an owner or operator would have the
option of using sulfur dioxide (SO2) monitoring as a monitoring
parameter.  We are also proposing to reduce the frequency of stack
testing for scrubber-equipped kilns using SO2 monitors for parametric
monitoring. Under this alternative, SO2 would serve as an indicator of a
scrubber’s performance and not as a direct indicator of HCl emissions.
 Kilns equipped with dry or wet scrubbers that choose to use SO2
monitoring would need to conduct an initial performance test for HCl
while monitoring SO2 to establish an SO2 level that would indicate
compliance with the HCl limit. EPA is proposing that a performance test
be conducted again in five years, at which time the SO2 parameter could
be reset.  As alternatives to the required HCl CEMS monitoring
requirement, impacts were not estimated.

PM Standard for Modified Sources Under the NSPS

Under the September 2010 final NESHAP, existing kilns are subject to the
NESHAP PM limit. If the kiln undergoes modification, it would continue
to be subject to the NESHAP PM limit, but would now be subject as well
to the NSPS limit for new sources. EPA believes that it is more
appropriate for modified kilns to meet the NESHAP PM limit for existing
sources and is proposing that existing kilns that are subject to the
NESHAP existing source emissions limit would continue to be subject to
that limit and not to the more stringent limit for new sources under the
NSPS.  EPA examined the cost that a modified kiln would incur if they
had to reduce emissions to the NSPS level and the amount of PM
reduction.  For an existing kiln to go from complying with a 0.07
lb/ton clinker limit to the new source limit of 0.02 lb/ton clinker ( a
reduction in long term average emissions of 0.01967 lb/ton), it was
assumed that the reduction would be achieved by changing out baghouse
bags every year rather than every 5 years.  For a 1.2 million ton/yr
kiln, annual baghouse cost would increase by $0.4 million/yr. The
reduction in PM emissions for this example kiln would be 12 tons/yr.
Thus a kiln would realize a modest reduction in PM emissions at a cost
of about $34,000 per ton of PM reduced (See Appendix G).

Alternative PM Limit

Some kilns combine kiln exhaust gas with exhaust gas from other unit
operations, such as the clinker cooler. The September 2010 final rule
sought to accommodate commingled flows from the kiln and clinker cooler
by providing a site specific PM limit and an equation for calculating
the limit. In its reconsideration petition, industry brought to EPA’s
attention, that other flows, such as coal mill exhausts and alkali
bypass exhaust flows in addition to the exhaust gas flow from the
clinker cooler can be commingled as well. Without an allowance for these
additional flows, the site specific PM limit is stricter than EPA
intended (since the PM concentration will be divided by a lower number
in the implementing equation), and penalizes the energy-saving practice
of commingling these flows. Although the form of the equation is
correct, the equation is not written to accommodate sources other than
exhaust gases from the clinker cooler. EPA is, therefore, proposing the
following revised equation corrected to includes exhaust gas flows for
all sources that would potentially be combined into a single exhaust gas
stream, including the kiln, alkali bypass, coal mill and clinker cooler:

PM alt  =  0.006 x 1.65 x (Qk + Qc + Qab + Qcm)/(7000)  		

Where: 

PM alt is the alternative PM emission limit for commingled sources. 

0.006 is the PM exhaust concentration (gr/dscf) equivalent to 0.070 lb
per ton clinker where clinker cooler and kiln exhaust gas are not
combined. 

1.65 is the conversion factor of lb feed per lb clinker

Qk is the exhaust flow of the kiln (dscf/ton raw feed)

Qc is the exhaust flow of the clinker cooler (dscf/ton raw feed).

Qab is the exhaust flow of the alkali bypass (dscf/ton raw feed).

Qcm is the exhaust flow of the coal mill (dscf/ton raw feed).

7000 is the conversion factor for gr per lb.

If exhaust gases for any of the sources contained in the equation are
not commingled and are exhausted through a separate stack, their value
in the equation would be zero. The alternative PM equation for new
sources is identical to the existing source equation except the PM
exhaust concentration used in the equation is 0.002 grams per dry
standard cubic foot, which is equivalent to the new source PM limit of
0.020 lb/ton clinker. 

MACT Floor Development

Applying the definition of solid waste developed in the NHSM rule, EPA
has determined that 24 cement kilns in the database which EPA used to
develop the 2010 final NESHAP are now identified as commercial
incinerators.  Even though applying the reclassified kiln designation
for the 24 kilns would have resulted in slightly different existing
source emission standards for mercury, THC and PM, EPA is not proposing
to amend the existing source standards for mercury and THC. The reasons
for this decision are presented in the preamble to the proposed rule.
EPA is proposing to revise the existing and new source PM standards.
Also as described above in section 3, the limit for the alternative
organic HAP limit (with parametric monitoring of THC) is being amended
to reflect the limits of detection in the available measurement
technology. The derivation of the limit for the alternative organic HAP
is described in section 10.5 below. A summary of the amended NESHAP for
existing sources is presented in Table 1. 

Table   SEQ Table \* ARABIC  1 : Summary of 2012 Proposed NESHAP for
Existing Sources

Pollutant	Unit of Measure	2010 Final NESHAP	2012 Proposed NESHAP

Hydrogen Chloride	ppmvd	3	3

Mercury	lb/MM tons clinker	55	55

Particulate Matter	lb/ ton clinker	0.04	0.07

Total Hydrocarbon	ppmvd	24	24

Organic HAP	ppmvd	9	12



With respect to new source standards, EPA does not believe that any
reclassification and reanalysis is necessary under the court’s
opinion.  New source floors can be based on the performance of “the
best controlled similar source,” as opposed to existing source floors
which must reflect performance of sources “in the category or
subcategory.”  CAA section 112 (d) (3) and (d)(3)(A).  The changes to
the particulate matter (PM) and organic HAP (oHAP) standards are not
related to removal of the 23 kilns identified as incinerators.  These
changes are discussed below in the applicable sections.  A summary of
the amended NESHAP for new sources is presented in Table 2. 

Table   SEQ Table \* ARABIC  2 : Summary of 2012 Proposed NESHAP for New
Sources

Pollutant	Unit of Measure	2010 Final NESHAP 	2012 Proposed NESHAP

Hydrogen Chloride	ppmvd	3	3

Mercury	lb/MM tons clinker	21	21

Particulate Matter	lb/MM tons clinker	0.01	0.02

Total Hydrocarbon	ppmvd	24	24

Organic HAP	ppmvd	9	12



Hydrogen Chloride (HCl)

a.	Existing Sources

The 2012 proposed HCl NESHAP for existing sources was developed by
removing any kilns from the 2010 Final data set that were identified as
commercial incinerators and adding in any new kilns that now fall into
the NESHAP pool (top 12 %).  The 2012 proposed HCl NESHAP for existing
sources was developed with this new pool of kilns using the UPL method
with pooled variance.  As shown in Appendix A, the 2012 result of the
UPL analysis for existing sources is less than three times the
representative method detection level.  As was done in the 2010 Final,
EPA is proposing to retain the current limit (3ppmvd) developed as three
times the highest method detection level.

b.	New Sources

As shown in Appendix B, the best performing kiln used to set the HCl
NEHSAP for new sources in the 2010 Final was not identified as a
commercial incinerator, so the same kiln was used for this analysis. As
such, there is no reason the new source standard would change.

Mercury (Hg)

a.	Existing Sources

EPA calculated the  99th confidence UPL for Hg after removing kilns from
the 2010 final data set that were identified as commercial incinerators
and replacing them with cement kilns to create the pool of best
performing 12 % of sources.  The UPL for existing sources was developed
with this new pool of kilns using the UPL method with pooled variance,
corrected for temporal autocorrelation with intraquarry variability. 
This process was identical to that used in the 2010 final rule with the
exception of the kilns in the pool data set.  Appendix C contains the
calculations used to develop the 2012 proposed Hg NESHAP for existing
sources (58 lb/MM tons clinker). 

As discussed in the preamble to the proposed rule, EPA is not proposing
to revise the mercury limit for existing sources.  We are proposing,
however, to adopt 55 lb/MM ton clinker as a beyond the floor standard. 
This is the level of the 2010 final standard. The only difference in
cost between the floor level of 58 lb/MM ton clinker and the proposed
standard of 55 lb/MM ton clinker is the incremental cost of removing
slightly more mercury. This is because the control equipment needed for
mercury (an activated carbon injection [ACI] system) would not alter,
would not need to be sized differently, and would need to perform on
average, nearly identically at either a 55 lb/MM tons clinker or 58
lb/MM tons clinker level. That is, in planning compliance, kilns would
calibrate to achieve an average performance of 34.1 lb/MM tons clinker
for a standard of 58 lb/MM tons clinker, and 31.7 for a standard of 55
lb/MM tons clinker, which translates to an additional reduction of 2.4
lb/MM tons of clinker per year. This equates to an estimated 180 pounds
of nationwide mercury emissions per year. To estimate the additional
cost of going beyond the floor, we assumed that the rate of carbon
injection would be increased to increase the mercury removal rate. The
additional cost would then be the increased usage of activated carbon.
Under the 2010 rule, we based the cost of compliance in part on an
activated carbon injection rate of 3 pounds per million ACFM. Cost for
an ACI system were developed for the 2010 final rule using costs from
the state of New Jersey and the OAQPS Cost Manual. See Docket items
EPA-HQ-OAR-2002-0051-1891, 1872, 3398 and 3457 for background
information and an explanation of cost estimates. The mercury reduction
of 2.4 lb/MM tons of clinker is a 7 percent reduction from the level
needed for long term compliance and we initially considered that the
amount of carbon injected might also only need to be increased by 7
percent, from 3 lb to 3.2 lb per million ACFM. However, to allow for
variability of removal effectiveness, pollutant loading and other
uncertainties, we estimated the additional cost using an injection rate
of 4 lb/ million ACFM.   To achieve this additional reduction, we
estimated an additional cost of approximately $359,000 for the industry,
to purchase additional carbon injection materials.  This equates to a
cost-effectiveness of $2,000/lb of mercury reduction per year (see
Appendix P).

b. 	New Sources

With respect to new source standards, as shown in Appendix D, applying
this same method to the new sources would produce a slightly less
stringent UPL (and we include this calculation for purposes of
information).  As discussed in preamble, EPA does not believe that any
reclassification and reanalysis for new sources is necessary under the
court’s opinion because new source floors can be based on the
performance of “the best controlled similar source.”  Therefore, EPA
is proposing to retain the new source Hg NESHAP developed under the 2010
Final (21 lb/MM tons clinker).

Particulate Matter (PM)

a.	Existing Sources

The 2012 proposed PM NESHAP for existing sources was developed by
removing any kilns from the 2010 final data set that were identified as
commercial incinerators and adding in any cement kilns that now fall
into the NESHAP pool (top 12 %).  The 2012 proposed PM NESHAP for
existing sources was developed with this new pool of kilns using the UPL
method with pooled variance.  This process was identical to that used in
the 2010 final with the exception of the kilns in the pool data set.
Finally, in applying the UPL equation, EPA used m = 3 to be consistent
with the proposed requirement to determine compliance using a three run
Method 5 test rather than a 30 day rolling average. Appendix E contains
the calculations used to develop the 2012 proposed PM NESHAP for
existing sources (0.07 lb/MM tons clinker).

b.	New Sources

The best performing kiln used to set the PM NEHSAP for new sources in
the 2010 Final was not identified as a commercial incinerator, so the
same kiln was used for this analysis. We are proposing a standard of
0.02 lb./MM tons clinker rather than the 2010 final rule level of 0.01
lb/MM tons clinker  because a 3-run test will be used to determine
compliance rather than a 30-day rolling average, the calculation of the
UPL uses m = 3 rather than 30. Appendix F contains the calculations used
to develop the 2012 proposed PM NESHAP for new sources (0.02 lb/MM tons
clinker).

Total Hydrocarbon (THC)

a.	Existing Sources

The THC data for the 2010 standard consist of CEMS data for 15 kilns.
After removing the four CISWI kilns, nine kilns remain. Thus, the MACT
floor kilns consisted of 12 percent of these nine kilns, or two kilns.
The top two kilns were Suwannee and Holcim. When CISWI sources are
removed from the database for the 2010 standards, the existing source
floor for THC becomes more stringent from 24 parts per million by volume
(ppmv) to 15 ppmv, and the new source standard would drop from 24 ppmv
to 11 ppmv (see Appendix K). This change results from removing from the
database a CISWI cement kiln (the Lehigh Union Bridge kiln) with the
lowest daily average performance but with more associated variability
than the other kilns. However, notwithstanding this calculation, the EPA
is not proposing to reduce the level of either the new source and or
existing source THC standard.

With respect to existing source standards, EPA does not believe that the
existing floor level (15 ppmv) would be technically appropriate. It
omits the variability of the similar source with the best average
performance for THC (the Union Bridge kiln), and so may not be fully
representative of variability of best performing sources. If the
variability of the Union Bridge kiln is included along with the
variability of the two best performing cement kilns, and applied to the
two best performing cement kilns’ performance, the floor would be 24
ppm, which EPA is proposing as a floor (see Appendix O).

b.	New Sources

The basis for the new source standard was explained in the 2010 final
rule.  See 75 FR at 54981.  As a best controlled similar source, the new
source standard can continue to be based on the performance of this kiln
(the Lehigh Union Bridge kiln).  See the preamble to the proposed rule
for more discussion of the proposed THC standards.

Organic HAP (oHAP)

a. 	Existing and New Sources

For the total oHAP emissions data, EPA applied the following procedure
for determining a representative detection level (RDL) for test methods
used in measuring oHAPs. EPA determined method detection capabilities
for Method 320 and Method 18 as the most appropriate for the various
compounds (e.g., Method 320 for aldehydes, Method 18 for arenes) emitted
by kilns. EPA determined for each of the oHAPs the expected method
detection level for the respective method based on internal experience
and method capabilities reported by testing companies. With these
values, EPA identified the resulting mean of the method detection levels
as the RDL because it is characteristic of accepted source emissions
measurement performance. EPA summed the RDLs of each oHAP in the data
set and adjusted for dilution and moisture, then multiplied by three.
Appendix H contains the calculations used to develop the 2012 proposed
oHAP NESHAP for existing and new sources (12 ppmvd).

Impacts of Revised PM Standard

For PM, EPA is proposing to change the limit for existing sources from
0.04 lb/ton clinker to 0.07 lb/ton clinker. The PM limit for new sources
also would be changed to 0.02 lb/ton clinker from 0.01 lb/ton clinker.
The standard would be measured on a 3-run basis rather than on a 30-day
basis with a CEMS (see the final paragraph of this section).  The
proposed changes in the PM standards, while not considered significant
in absolute terms will result in a small increase in total nationwide
emissions.  As explained in the impacts analysis for the 2010 rule (see
Docket item EPA-HQ-OAR-2002-0051-3438), emission reductions were
estimated by comparing baseline emissions to the long-term average
emissions of the MACT floor kilns. The average emissions, rather than
the emissions limit, must be used because to comply with the limit all
or most of the time, emissions need to be reduced to the average of the
MACT floor kilns. Under the 2010 rule, the average PM emissions from the
existing floor kilns was 0.02296 lb/ton clinker. Under the
reconsideration, the average PM emissions of the existing floor kilns is
0.02655 lb/ton clinker (see Appendix E). This is an increase of 0.00359
lb/ton clinker over the 2010 rule. The average emissions for new kilns
did not change, so there would be no change in emissions from new kilns.
In the 2010 rule, total clinker production from existing kilns was
75,355,116 tons per year. With an increase in PM emissions under the
proposed rule of 0.00359 lb/ton clinker compared to the 2010 rule,
nationwide emissions of PM would increase by 135 tons per year (0.00359
x 75,355,116/2000). These calculations are not so precise as to reliably
predict to the third decimal point to the right of zero, so this
difference should be viewed as suggesting a directional difference in
the standards. 

	Kiln type	2010 rule	Proposed rule	Increment

Emissions limit (lb/ton clinker	Existing	0.04 (30-day average with a
CEMS)	0.07 

(3-run stack test)	NA

MACT  average emissions for compliance (lb/ton clinker	Existing	0.02296
0.02655	0.00359

2010 baseline emissions (tons/yr)

10,326	10,326	NA

Nationwide emissions reduction (tons/yr)	Total	9,489	9,354	135



Although the final measures that the industry will take to implement the
final standards will be site specific and cannot be accurately estimated
here, it is possible that the industry would now be able to use existing
PM control devices with less extensive modification rather than planned
under the 2010 standard or rather than replacing them. Compliance
strategies for the other HAPs, all of which involve some element of PM
control, also may be affected.  Cost savings from these alternatives
could be significant.  For example, we have performed a case study from
the data set used in the 2010 impacts analysis.  In this case study, the
21 ESP-equipped kilns no longer need to install membrane bags on a
downstream polishing FF, and one FF retains their standard fabric bags
rather than replacing them with membrane bags. The difference in annual
cost for PM control under this case study and the more stringent 2010
scenario is $18.6 million in capital cost and annualized cost of $4.2
million (see Appendix M). EPA believes this case study is a reasonable
type of bounding estimate.  Under this comparison, the annual cost of
compliance will be $4.2 million less than under the 2010 rule. Under
this comparison, the additional cost of reducing PM emissions to the
2010 rule level would be approximately $31,000 per ton of PM ($4.2
million/135 tons PM). Assuming that 1 percent of PM is HAP (Docket item
EPA-HQ-OAR-2002-0051-3438), the cost effectiveness would be
approximately $3,000,000 per ton of HAP .

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At $15,000 per year for a single Method 5 test, the proposed rule will
cost  $60,000 less for testing than would be required under the PS 11
requirements for five tests at a cost of $75,000At a savings of $60,000
per kiln, nationwide savings for 133 new and existing kilns, would be
$7.98 million per year.

Summary

A summary of the costs for the proposed amendments are summarized in
Table 3. 

Table 3. Cost of Proposed Amendments

Proposed Amendment	Capital Cost	Annualized Cost	Emissions Reduction

Coal mill testing and monitoring (section 4)

Mercury

THC

HCl

Flow meter

Total	

$4,794,520

$4,794,520	

$3,055,200

$1,072,000

$2,680,000

$1,510,850

$8,318,050	

0

Mercury beyond the floor  (section 7.2)	0	$359,000	180 lb

Revised PM standard (section 8)	$18,640,106 (savings)	$4,200,000
(savings)	135 tons (emissions increase)

Replace PM CEMS with PM CPMS (section 8)	0	$7,980,000 (savings)	0

Total	$13,845,586

(savings)	$3,503,000

	135 tons (emissions increase)

. 

 Note that this figure would change correspondingly if the EPA were to
amend the existing source PM standard. The same is true of the PM term
in the new source equation.

  PAGE   \* MERGEFORMAT  ii 

  PAGE   \* MERGEFORMAT  7 

