1

MEMO to DOCKET

SUBJECT: “Communications on Errors_PCA August 2015

FROM: Sharon Nizich, US EPA OAQPS SPPD, Mi nerals and Manufacturing Group

DATE: August 31, 2015

The following emails were received from representatives of the Portland Cement Association concerning errors they found in the final rule dated July 27, 2015 ((80 FR 44772). All of these issues are related to monitoring requirements in the rule.

From: HolmesAems@aol.com

Sent: Friday, August 07, 2015 10:00 AM

To: Nizich, Sharon; Barnett, Keith

Cc: Fruh, Steve Subject: Re: Portland Cement NESHAP

Sharon, Can we have a call on Monday to discuss these items? I am available all day. Also, I am in the process of writing up a fourth issue and can discuss that one as well. Thanks,
Joh n

In a message dated 7/24/2015 3:45:15 P.M. Eastern Daylight Time, HolmesAems@aol.com

writes: Sharon and Keith,

PCA has begun its review of the final rule and appreciates the agency’s consideration and response to comments that we filed. However, there are three unanticipated changes that are of concern. While other issues may surface as we study the final rule in more detail, I wanted to share these three concerns with you now so that we can consider the best way to address them. Here is an overview of each of the three concerns. I would be happy to follow up with a phone conversation.

Changes to Performance Specification 8A Under the current rule, the THC CEMS is to conform to performance specification (PS) 8A. PS 8A is specific to the use of a Flame Ionization Detector (FID) as the measurement technology. PS 8 is not. Because some of the industry was considering the use of non

- FID methods, PCA asked that PS 8 be added as an alternative. The addition of PS 8 was proposed in November, PCA suppo rted that proposal, and PS 8 now appears as an
alternative.2

What surprised us was the alteration of requirements for on

- going QA for monitors certified under PS 8A that appears in the final rule but was not in the November proposal.
The rule now contains the following change to the use of PS 8A:

“The THC continuous emissions monitoring systems certified under Performance Specification 8A, conduct relative accuracy test audits required under Procedure 1 in accordance with Performance Specificatio n 8, Sections 8 and 11 using Method 25A in appendix A to 40 CFR part 60 as the reference method; the relative accuracy must meet the criteria of Performance Specification 8, Section 13.2.”

This change presents several serious concerns, not the least of w hich is that it was not proposed and there was no opportunity to comment on this change. We note that the absence of RATA requirements in Performance Specification 8A is not an omission. The introduction to Section 6 of PS 8A states: “The test procedures described in this section are in lieu of a RATA and ACA.” When PS 8A was created, it was understood that at relatively low THC concentrations, a RATA comparison of an FID instrument in the CEMS to another
FID instrument via Method 25A would not ensure t he accuracy of either instrument. FID analyzers have instrument

- specific responses to various organic compounds present in the effluent and are simply calibrated relative to propane.

Unlike SO2, NO or other gas analyzers, FID analyzers do measure a spe cific compound in the effluent and are not amenable to a relative accuracy test specification. The calibration drift test and the calibration error test that are in Section 6 of PS 8A are appropriate and reasonable. This change will create significant co sts with no improvement in accuracy. The cement industry is facing an added cost of an ineffective requirement.

The test procedures that are in PS 8A are practical and effective and don’t need to be changed. However, if the agency feels that there is a deficiency in PS 8A, the correct action is to develop a proposal to change to PS 8A and sent it out for comment. A last minute edit to a final rule that goes into effect in a few months is not an appropriate means of changing a standardized performance s pecification.

Changes to Performance Specification 15 We have a similar concern with a last minute change to the application of requirements
for FTIR

- based HCl CEMS certified in accordance with PS 15 under this rule. While we and you have spent consid erable time over the last year on the new alternative Performance Specification 18, including the span value and calibration requirements that would apply to any CEMS certified by a method other than PS 15, there was no proposal or discussion of changing t he requirements for monitors certified under PS 15. In the proposed rule issued in November at 63.1350(l)(1), there is language that is in the current rule and was not changed (emphasis added):3

“The span value and calibration requirements in paragraphs (l )(1)(i) and (ii) below apply to
HCL CEMS other than those installed and certified under PS 15.”

PCA supported this specific language in its comments. However, we now find that the final rule has changed this language. It now says (emphasis added):

“The span value and calibration requirements in paragraphs (l)(1)(i) and (ii) of this section apply to all HCl CEMS used under this subpart.”

The extension of these requirements to HCl CEMS certified under PS 15 was not proposed and we were given no opportuni ty to comment. This is a significant change.

An HCl CEMS certified under PS 15 had no specified span values and no requirements to perform above span calibration checks. The span could simply be set at a sufficiently high value to include all expect ed measurement concentrations. Only a zero and single upscale HCl standard were required for daily operation. These changes would potentially require cement plant operators that chose the PS15, Appendix F, Procedure 1 approach to now (1) purchase new cal ibration standards at 2

- 3 ppm, and 5

- 6 ppm HCl for quarterly audits which are less reliable than higher level gases, (2) purchase and install additional high level gases for above span calibrations, and modify calibration manifolds and calibration

sequence s to allow their use, (3) develop and implement special DAS programming to automate above span calibration sequences because the time when these procedures must be performed cannot be predicted, and interface the DAS activation of the above span calibratio ns with the HCl CEMS operation, (4) implement DAS programming for data normalization that is not now available in the existing DAS systems, and (5) revise monitoring plans and QA plans that have already been created.

Elimination of Option to Test for oHAPs after an Inline Coal Mill

As you are aware, if a kiln has kiln exhaust routed to an inline coal mill, the emissions from that mill’s outlet must be accounted for. Our concern is with an unanticipated language change that presents significant practical concerns for determining oHAP emissions associated with an inline coal mill. For THC, the rule provides an option to determine THC emissions either at the inlet or outlet of the coal mill. This makes sense. If the grinding of
the coal is relea sing significant amounts of THC into the exhaust, the THC at the outlet could be very high and it will not be a reflection of the kiln exhaust which is being regulated. Measuring upstream of the coal mill allows one to avoid this distortion of the
level o f kiln related THC emissions. On the other hand, if there is no significant THC coming from the coal, testing the cleaner coal mill outlet (after the baghouse) will be easier. Under the oHAP alternative to the THC limit, one must also account for the oHA P in the kiln gases going to any inline coal mill. In the November proposed rule, a sentence on this topic was added at 63.1349(b)(7)(v) stating:4

“If your kiln has an inline coal mill, and you are required to measure at the coal mill inlet, you must also measure oHAP at the coal mill inlet and calculate a weighted average for all emission sources including the inline coal mill and the alkali bypass.”

We read this to mean that the agency wanted consistency in the measurement location
for THC and oHAP. If one needed to measure THC at the inlet of the coal mill to avoid coal related THC distortions, then the agency wanted the oHAP measurement to be on the
same basis. We did not read this to exclude measurement of oHAP at the coal mill outlet. However, in the final rule, this language has been changed. It now reads:

“If your kiln has an inline coal mill and/or an alkali bypass with separate stacks, you are required to measure and account for oHAP emissions from their separate stacks. You are required to measure oHAP at the coal mill inlet and you must measure oHAP at the alkali bypass outlet. You must then calculate a flow weighted average oHAP concentration for all the emissions source including the inline coal mill and the alkali bypass.”

This languag e eliminates the option of measuring oHAP at the outlet of the coal mill. This is problematic for several reasons. First, some kiln owners have found that it is not safe to try to sample before the coal mill. Second, the particulate loading can be so hi gh prior to the mill that oHAP testing cannot be done, because the Method 18 and Method 320 sampling equipment cannot handle the very high dust loading. In these instances, sampling after the dust collector on the coal mill exhaust is the only viable opti on. Lastly, testing has shown that in some instances oHAP is removed through adsorption to the coal and that control can only be accounted for by testing at the coal mill outlet. PCA members need the option to test oHAP emissions at either the outlet or inlet of an inline coal mill, as is presently the case for THC emissions.

As I said earlier, I would be happy to discuss these concerns further at your earliest

convenience.

John Holmes

From: HolmesAems@aol.com

Sent: Monday, August 10, 2015 8:10 AM

To: Nizich, Sharon

Cc: jimpeeler@mindspring.com Subject: Above Span Language Changes for Subpart LLL

Sharon.5

Here is a description of the additional issue I mentioned last week. I have asked Jim Peeler to join us on the call at 10 am. We have ano ther new issue which we can discuss and provide a write up later.

John

There are two places in the revised Subpart LLL regulation where there is what appears to be some “unintended language” which applies to the weekly above span linearity. One is for Hg measurements and the other is for HCl measurements. Both are similar, but are not exactly the same. For the Hg monitoring, the sentence of concern is found at the end of 63.1350(k)(2)(ii) and it says: “In this manner values measured by the Hg CEM S during the above span linearity challenge exceeding +/

- 20 percent of the certified value of the reference gas must be normalized using Equation 22.”

It says that the values measured during the above span linearity challenge need to be adjusted. Values measured “during” the linearity challenge are measurements of the high level reference gas. It is the monitoring data exceeding the span value that need adjusting. Deleting the sentence would remove the confusion. The preceding sentence in
this sectio n directs the reader to what must be done. The sentence in question is merely commentary. Alternatively, the sentence could be re

- written as follows:

“In this manner all hourly average values exceeding the span value measured by the Hg CEMS during the w eek following the above span linearity challenge when the CEMS response is exceed ing +/

- 20 percent of the certified value of the reference gas must be normalized using Equation 22.”

One consideration is whether the normalization should apply to the week p eriod before or after the weekly above span linearity check. Importantly, choosing the week following
avoids situations where the normalization of CEMS data would result in the need to over

write the hourly averages in the DAS files and the 30

- day rolling averages computed by the DAS at the end of each day and then manually re

- compute 30

- day rolling averages for each day in the prior week as well as the potential for the adjustment to result in a retroactive

non

- compliance period.

For HCl monitoring the s ame sentence of concern is not included. If the agency chooses the make the edits shown above, then the last sentence in the HCl section at 63.1350(l)(ii)(B) could benefit from revisions parallel to those suggested above:

“Any HCl CEMS above span lineari ty challenge response exceeding +/

- 20 percent of the certified value of the reference gas requires that all above span data hourly averages during the week following the above span linearity challenge must be normalized using Equation 23.”6

In a messag e dated 8/7/2015 10:43:03 A.M. Eastern Daylight Time, Nizich.Sharon@epa.gov writes: Let’s discuss issues with John Holmes on the final amendments published July 27th. John, please also send your fourth issue and I will distribute, before call. Thanks.

Call in is 919 541 1590

Dated Tuesday August 11 th , from Sharon Nizich to John Holmes:

Thank you. This was a simple typo. The two sentences should have been removed, as reflected in the response to comments. The technical correction notice will remove

them. Thanks.

Sharon Nizich Environmental Engineer U.S. EPA/OAR/OAQPS Sector Policies and Programs Division (SPPD) 109 TW Alexander Dr. (D243

- 04) Research Triangle Park, NC 27711 (919) 541

- 2825

– Office (919) 541

- 5450

– Fax

From: HolmesAems@aol.com [ mailto:HolmesAems@aol.com ]

Sent: Tuesday, August 11, 2015 11:05 AM

To: Nizich, Sharon; Barnett, Keith

Cc: jimpeeler@mindspring.com ; tharman@cement.org Subject: Subpart LLL Data Substitution/Hourly Average Determination During Hg and HCl

Abo

Sharon and Keith,

Here is a write up on the additional issue we discussed on yesterday's call. If you have any questions, please let Jim and me know.7

New language in the Subpart LLL final amendments creates the possibility for recording

non

- representative Hg and/or HCl emission averages and significantly complicates data
acquisi tion system (DAS) programing issues. These provisions should be modified. PCA previously commented that it was inappropriate to require data substitution for hours during above span calibration checks. EPA’s response to comments document indicates

EPA’s agreement on this issue and states that actions were taken to accommodate PCA’s comments on this matter, but the opposite appears in the final amendments.

The issues of concern appear in two locations in the final amendments:

· Under the third opt ion for quality assurance of Hg CEMS data that exceed the span value at §63.1350(k)(2)(iii) the new language includes:

“If the ‘‘above span’’ calibration is conducted during the period when measured emissions are above span and there is a failure to colle ct at least one valid data point in an hour due to the calibration duration, then you must determine the emissions average for that missed hour as the average of hourly averages for the hour preceding the missed hour and the hour following the missed hour. In an hour where an ‘‘above span’’ calibration is being conducted and one or more data points are collected, the emissions average is represented by the average of all valid data points collected in
that hour.”

· Similar language is found at §63. 1350(l)(1)(ii)(C) with the revisions indicated in the
EPA redline version:

“If the “ above span ” calibration is conducted during the period when measured emissions are above span and there is a failure to collect the one data point in an hour due to the calibration duration, then you must determine the emissions average for that missed hour as the average of hourly averages for the hour preceding the missed hour and the hour following the missed hour. In an hour where an “ above span” calibration is being conducted and one or more data points are collected, the emissions average is represented by the average of all valid data points collected in
that hour.

Issues with Using Limited Data to Determine a Valid Hour

1. For both Hg and HCl, the requirement to determine the value representing the hourly average based on one or more valid data points may well lead to a highly non

representative hourly value because emission concentrations may be highly transitory during th e mill off period and the use of one data point may greatly over estimate or
under estimate the true value.8

2. Standard DAS programs validate each hour of data based on the requirements in the general provisions which require that CEMS sample, analy ze and record measurement values at least once each 15 minute period, and that hourly averages are computed
from at least one measurement in each 15

- minute quadrant of the hour, except for hours when quality assurance activities are performed in which case the average may be determined from data in two quadrants of the hour. These are well established data validation rules that have been widely implemented. The new language would require complex reprograming the DAS so that it would automatically recogniz e that the CEMS status was in the “above span” mode and then circumvent its normal validation requirements and compute an average from all values which may represent a single one

- minute data point or many data points. The re

- programing is not
trivial. Th is new approach is also not appropriate because:

a. The DAS would need to maintain duplicative records of valid hours for calculating emissions and for determining monitor downtime because the new language does not change the requirements for valid h ours used to determine and report CEMS downtime.
b. These special data calculation requirements apply to those users that select one of the three options for QA of Hg and/or HCl above span data. Therefore the determination of average Hg and/or HCl em issions would be inconsistent between cement plant operators choosing different options.

Issues with Data Substitution

1. The new requirement to substitute the average of the hour before and the hour following a missing hour of Hg or HCl CEMS data wh en above span calibration checks are performed has a much wider impact in the final amendments because it is now applied to both Hg and HCl CEMS. (Previously it applied only to HCl CEMS certified and operated under PS18/Procedure 6. Many more cement kiln s will use Hg CEMS than will use PS18/P6 HCl CEMS.)

2. PCA has submitted comments objecting to the previous HCl data substitution requirement in several previous Subpart LLL rulemakings. Most recently, PCA
submitted comments to the Docket No. EPA

- H Q

- OAR

- 2011

- 0817 in response to the EPA’s proposed rule published in the Federal Register on November 19, 2014, at 79 Fed. Reg. 68821. The following is a restatement of comment 8(f):

f. “The missing data substitution requirement in (l)(1)(ii)(C) s hould be removed because it is inconsistent with the procedures specified for the other two HCl options for quality assurance of “above span” HCl data. Furthermore, missing data substitution requirements are not included in any Part 60 or Part 63 regulati ons. Therefore, the last sentence in this section (shown below) should
be deleted:9 “ If the ‘above span’ calibration is conducted during the period when measured emissions are above span and there is a failure to collect the required minimum number of da ta points in an hour due to the calibration duration, then you must determine the emissions average for that missed hour as the average of hourly averages for the hour preceding the missed hour and the hour following the missed hour .”

3. The “Response to Comments Final Reconsideration May 2015” under “ 10. Quality assurance of mercury CEMS data above the span value” page 8 (second to last paragraph) states: “With respect to the issue of data substitution in (l)(1)(ii)(C), the EPA agrees with th e reasons stated by the commenter and has removed the requirement for missing data
substitution.”

Similarly, the same document under “ 11. HCL CEMS requirements” page 13 (sixth paragraph) states:

“And with respect to the issue of data substitution in (l) (1)(ii)(C), the EPA agrees with the reasons provided by the commenter and has removed the requirement for missing
data substitution.”

4. There was a similar data substitution issue in Subpart F requirements of the same series of rulemakings regardi ng the calculation of SO 2 and NO x 30

- day rolling

averages. The preamble of the proposed technical amendments (Federal Register / Vol. 79, No. 223 / Wednesday, November 19, 2014 page 68824 states:

We propose to remove 40 CFR 60.64(c)(2), which applied when sources did not have
valid 15

- minute CEMS data. This provision allowed for inclusion of the average emission rate from the previous hour for which data were available. This provision was inadvertently added to the final rule, but this substitution is not an allowable action.
We solicit comment on removal of this subsection.

The EPA red

- line and the final published regulation show that the proposed data substitution requirement in 60.64(c)(2) was removed.

Recommendation

Deleting the language in §63.13 50(k)(2)(iii) and §63.1350(l)(1)(ii)(C) specifically cited above eliminates the conflicts with Part 63 Subpart A General Provision requirements for Hg and HCl CEMS data reduction and the determination of valid hours, avoids recording and use of non

- represe ntative emission values, avoids complex DAS programing, avoids inconsistent approaches for operators choosing different QA options, and eliminates concerns about data substitution in Part 60 and Part 63 regulations. Very little data will be affected as ce ment kiln operators try to arrange10

above span calibration procedures in a manner to maximize CEMS data availability to
avoid monitor downtime.

From: Jim Peeler <jimpeeler@mindspring.com>

Sent: Friday, August 14, 2015 6:46 AM

To: Nizich, Sharon; HolmesAe ms@aol.com

Cc: Barnett, Keith; Johnson, Steffan Subject: RE: errors found in the final July notice

Sharon Nizich: I agree that the six changes indicated below correctly resolve the associated issues. In your items 3 and 6, the last two sentences are removed from (k)(2)(iii) and (l)(1)(ii)(C) respectively as shown below.

I believe there is an additional typographical error that should be corrected. 63.1349 includes: “(4) THC emissions test. (i) If you are subject to limitations on THC emissions, you must operate a CEMS in accordance with the requirements in § 63.1350(i). For the purposes of conducting the accuracy and quality assurance evaluations for CEMS, the THC span value (as propane) is 50 ppmvd ....” Because the
THC measurement is on a wet basi s, I think that ppmv or ppmvw is appropriate. (The section on the OHAP requirement includes: “(iv) If your organic HAP emissions are below 75 percent of the organic HAP standard and you determine your operating limit with paragraph (b)(7)(vii) of this sec tion your THC CEMS must be calibrated and operated on a measurement scale no greater than 180 ppmvw, as carbon, or 60 ppmvw as propane. This is correct as written.)

Regarding the outstanding PS8A RATA issues, we look forward to speaking with you after

yo u have discussed this with the HWC project team.

If we come across additional errors we will let you know.

Thanks,

Jim Peeler, Emission Monitoring Inc.

252 586

- 7938

From: Nizich, Sharon [mailto:Nizich.Sharon@epa.gov] Sent: Thursday, August 13, 2015 8:00 AM To: HolmesAems@aol.com; jimpeeler@mindspring.com Cc: Barnett, Keith; Johnson, Steffan11

Subject: errors found in the final July notice

Hello John and Jim

These are the tech correction areas that we see as an issue. Please let me know if you
hav e any more. This will be our last correction notice. I plan to process this mid to late
next week

– thanks!

1. Section 63.1349(b)(7)(v), we will be changing 2nd sentence to: “You are required to measure oHAP at the coal mill inlet or outlet and you must also measure oHAP at the alkali bypass outlet.”

Section 63.1350

–

2. (k)(2)(ii) last sentence will be changed to read: “In this manner all hourly average values exceeding the span value measured by the Hg CEMS during the week following the above span linearity challenge when the CEMS response exceeds +/

- 20 percent of the certified value of the reference gas must b e normalized using Equation 22.” 3. (k)(2)(iii), last sentence will be removed: If the “above span” calibration is conducted during the period when measured emissions are above span and there is a failure to collect at least one valid data point in an hour due to the calibration duration, then you must determine the emissions average for that missed hour as the average of hourly averages for the hour preceding the missed hour and the hour following the missed hour. In an hour where an “above span” calibrati on is being conducted and one or more data points are collected, the emissions average is represented by the average of all valid data points collected in that hour. 4. (l)(1) last sentence to read: “The span value and calibration requirements in paragraph s (l)(1)(i) and (ii) of this section apply to HCl CEMS other than those installed and certified
under

PS

- 15.” 5. (l)(1)(ii)(B)

– last sentence to read: “Any HCl CEMS above span linearity challenge response exceeding +/

- 20 percent of the certified value o f the reference gas requires that all above span hourly averages during the week following the above span linearity challenge must be normalized using Equation 23.” 6. (1)(1)(ii)(C) last sentence will be removed: If the “above span” calibration is conduct ed during the period when measured emissions are above span and there is a failure to collect at least one valid data point in an hour due to the calibration duration, then you must determine the emissions average for that missed hour as the average of hou rly averages for the hour preceding the missed hour and the hour following the missed hour. In an hour where an “above span” calibration is being conducted and one or more data points are collected, the emissions average is represented by the average of al l valid data points collected in that hour.12

Sharon Nizich Environmental Engineer U.S. EPA/OAR/OAQPS Sector Policies and Programs Division (SPPD) 109 TW Alexander Dr. (D243

- 04) Research Triangle Park, NC 27711 (919) 541

- 2825

– Office (919) 541

- 5450

– Fax

From: HolmesAems@aol.com

Sent: Friday, August 28, 2015 2:33 PM

To: Nizich, Sharon

Cc: Barnett, Keith Subject: Clarification of Performance Test Frequency Requirements

Sharon, One more issue has surfaced that I am hoping you can correct/clarify in the technical corrections package. It has to do with the performance testing intervals. In the PCA comments we asked that the annual testing be allowed to happen within 13 months and
the 30 month interval be with 31 months so that folks could test at the same time each interval, rather than having to move the test up on the calendar to be sure the interval is not missed. The response to comments said that this was accepted. However, the rule has an apparent window of time in which the testing must be done. For example, it now says that annual testing must be done within a window of 11 to 13 months.

We are concerned that under this language testing earlier than the 11th month coul d be viewed as a violation. Cement kilns are not always running and are purposefully taken down for extended periods of time for any number of reasons, primarily inventory control or planned major maintenance. At times, we cannot work around a performanc e testing requirement that must occur within a specific timeframe. We can, however, perform the test early to avoid the downtime period. However, as written this is currently not allowed under the regulation.

With this in mind, we ask that you impleme nt the following clarification which I believe does not modify the intend of the rule but avoids an odd situation where testing earlier than the 11 to 13 month period would be viewed as a violation. We propose that the following be used in 40 CFR 63.1349( c):“Performance test frequency. Performance tests are required at regular intervals for affected sources that are subject to a dioxin, organic HAP or HCl emissions limit. These performance tests are required every 30 months and must be completed no later than 31 calendar months after the previous performance test, except where that specific pollutant is monitored using a CEMS.13

Performance tests for PM are required every 12 months and they must be completed no later than 13 calendar months after the previ ous performance test.”

Thanks, John Holmes