UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

	1650 Arch Street

	Philadelphia, Pennsylvania  19103

DATE:	April 25, 2010

SUBJECT:	Technical Support Document – Commonwealth of Pennsylvania –
Control of Nitrogen Oxides from Portland Cement Kilns

			/s/

FROM:	Rose Quinto, Environmental Engineer

		Office of Air Program Planning

TO:		File

			/s/

THRU: 	Cristina Fernandez, Associate Director

Office of Air Program Planning

A.  BACKGROUND

On July 23, 2010, the Pennsylvania Department of Environmental
Protection (PADEP) submitted a State Implementation Plan (SIP) revision
pertaining to the control of nitrogen oxides (NOx) emissions from
Portland cement kilns.  Portland cement manufacturing is an energy
intensive process in which cement is made by grinding and heating a
mixture of raw materials such as limestone, clay, sand, and iron ore in
a rotary kiln.  NOx emissions are generated during fuel combustion by
oxidation of chemically-bound nitrogen in the fuel and by thermal
fixation of nitrogen in the combustion air.  This SIP revision is based
on the Ozone Transport Commission (OTC) control measure to reduce NOx
emissions from cement kilns.  The OTC members include Pennsylvania,
Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire,
New Jersey, New York, Rhode Island, Vermont, Virginia, and the District
of Columbia.  The OTC was created under section 184 of the Clean Air Act
(CAA) to establish regulatory programs to reduce ozone precursor
emissions, which includes the reduction of NOx emissions from cement
kilns.

B.  STATE SUBMITTAL

The SIP revision amends the NOx emission standards in the Title 25 of
the Pennsylvania Code (25 Pa. Code) Chapter 145, Subchapter C,
“Emissions of NOx from Cement Manufacturing,” for Portland cement
kilns during the ozone season, from May 1 through September 30, 2011,
and for each year thereafter.  

The SIP revision added new definitions and terms:  

Calcine – To heat a substance to a high temperature, but below its
melting or fusing point, to bring about thermal decomposition or a phase
transition in its physical or chemical constitution.

Long dry-process cement kiln – A Portland cement kiln that employs no
preheating of the feed.  The inlet feed to the kiln is dry.

Long wet-process cement kiln – A Portland cement kiln that employs no
preheating of the feed.  The inlet feed to the kiln is slurry.

Precalciner cement kiln – A Portland cement kiln where the feed to the
kiln system is preheated in cyclone chambers and a second burner is used
to calcine material in a separate vessel attached to the preheater prior
to the final fusion in a kiln that forms clinker.

Preheater cement kiln – A Portland cement kiln where the feed to the
kiln system is preheated in cyclone chambers prior to the final fusion
in a kiln that forms clinker.

System-wide – Two or more Portland cement kilns under the common
control of the same owner or operator, or multiple owners, in the
Commonwealth. 

The other definitions mentioned in this SIP revision were already
approved by EPA on December 10, 2009 (74 FR 65446): continuous emissions
monitoring system (CEMS), clinker, Portland cement, and Portland cement
kiln.  Therefore, these terms are not included in this action.

Standard Requirements

Section 145.143(b) was revised to provide that the owner or operator of
a Portland cement kiln cannot operate a Portland cement kiln that
results in NOx emissions in excess of its allowable emissions.  Section
145.143(b)(1) added a compliance date of May 1 through September 30,
2005, and each year thereafter, the owner or operator will determine
allowable emissions by multiplying the tons of clinker produced by the
Portland cement kiln for the period by 6 pounds per ton of clinker
produced.  Section 145.143(b)(2) was also revised to require the owner
or operator of a Portland cement kiln determine allowable emissions of
NOx by multiplying the tons of clinker produced by the Portland cement
kiln for the period from May 1 through September 30, 2011 and for each
year thereafter by: 

 3.88 pounds of NOx per ton of clinker produced for long wet-process
cement kilns.

 3.44 pounds of NOx per ton of clinker produced for long dry-process
cement kilns.

 2.36 pounds of NOx per ton of clinker produced for preheater and
precalciner cement  kilns.

A minor change was made to section 145.143(c) clarifying that the owner
or operator of a Portland cement kiln subject to section 145.143(b)(1)
will install and operate a CEMS and report CEMS emissions data.  

The other sections mentioned in this SIP revision under section 145.143
were already approved by EPA on December 10, 2009 (74 FR 65446):
Sections 145.143(a), 145.143(b)(1), and 145.143(d) through (h). 
Therefore, these sections are not included in this action.

The following sections were added to the SIP revision:

Section 145.144. Compliance Determination Requirements

By April 15, 2011, the SIP revision requires the owner or operator of a
Portland cement kiln:

To install, operate and maintain CEMS for NOx emissions.

To report CEMS emissions data to PADEP in accordance with the CEMS
requirements of 25 Pa. Code Chapter 139, Subchapter C, relating to the
requirements for source monitoring for stationary sources.

Calculate actual emissions using the CEMS data reported to PADEP.

A data invalidated under 25 Pa. Code Chapter 139, Subchapter C will be
substituted either by the highest valid 1-hour emission value that
occurred under similar source operating conditions during the reporting
quarter for an invalid data period during that quarter, or an
alternative method of data substitution as approved by PADEP in writing.
 If no valid data were collected during the reporting quarter, the
highest valid 1-hour emission value that occurred under similar source
operating conditions during the most recent quarter for which valid data
were collected, or the highest valid 1-hour emission value that occurred
under similar source operating conditions during an alternative
reporting period, shall be reported to PADEP.

Additionally, under this section, the owner or operator of a Portland
cement kiln will submit to PADEP quarterly reports of CEMS monitoring
data in pounds of NOx emitted per hour, in a format approved by PADEP,
which is in compliance with 25 Pa. Code Chapter 139, Subchapter C. 
Also, the CEMS for NOx installed under the requirements of this section,
must meet the minimum data availability requirements in 25 Pa. Code
Chapter 139, Subchapter C.

Section 145.145. Compliance Demonstration and Reporting Requirements

By October 31, 2011, and each year thereafter, the owner or operator of
a Portland cement kiln will submit a written report to PADEP which
includes the following:

The difference between the actual NOx emissions from the kiln during the
interval from May 1 through September 30 and the allowable emissions for
that period.

The calculations used to determine the difference in emissions,
including the CEMS data and clinker production data used to show
compliance with the allowable emission limits.  The clinker production
data must consist of the quality of clinker, in tons, produced per day
for each kiln.

The owner or operator of a Portland cement kiln must demonstrate
compliance with the emission requirements on a kiln-by-kiln basis, a
facility-wide basis or a system-wide basis among Portland cement kilns. 


Section 145.146. Recordkeeping Requirements

The owner or operator of a Portland cement kiln must maintain an
operating log for each Portland cement kiln.  The operating log must
contain the following on a monthly basis:

 

The total hours of operation.

The type and quantity of fuel used.

The quantity of clinker produced.  

The records maintained by the owner or operator of a Portland cement
kiln must include the following: 

Source tests and operating parameters established during the initial
source test and subsequent testing.  

The date, time and duration of any start-up, shutdown or malfunction of
a Portland cement kiln or emissions monitoring system.

The date and type of maintenance, repairs or replacements performed on
the kilns, control devices an emission monitoring systems. 

Furthermore, the owner or operator of a Portland cement kiln must
maintain the records onsite for five years and be made available to
PADEP upon request. 

C.  EPA EVALUATION

This regulation will reduce emissions of NOx from cement kilns to reduce
levels of ground-level ozone.  Ground-level ozone is not directly
emitted by pollution sources, but is created as a result of a chemical
reaction of NOx and volatile organic compounds (VOC) in the presence of
light and heat.  The reduction of NOx emissions will also help protect
the public health from high levels of fine particulate matter (PM2.5),
of which NOx is a precursor component.  PM2.5, as well as ozone, is
health hazards.  The reduction of NOx emissions also reduces visibility
impairment and acid deposition.

D.  CONCLUSIONS AND RECOMMENDED AGENCY ACTION

The regulation to control NOx emissions from Portland cement kilns
adopted by the Commonwealth of Pennsylvania will result in the reduction
of NOx emissions from cement kilns and will help the Commonwealth in
attaining compliance with the 8-hour ozone and PM2.5     national
ambient air quality standards (NAAQS).  EPA approval of the SIP revision
is recommended.

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