1 Ju ly 1 9 , 2011



### Summary of July 18 EPA

- PCA Meeting Meeting Attendees

EPA: Keith Barnett, OAQPS Peter Tsirigotis, OAQPS Steve Silverman, OGC

PCA: ( by conference phone ) Craig Campbell, Lafarge Paul Detterline, Capital Nancy Garnett, TXI Juge Gregg, Sidley Curtis Lesslie, Ash Grove Brett Lindsay, Salt River Materials Tim Matz, Lehigh Jason Morin, Holcim Dan Nugent, Buzzi Unicem Andy O’Hare, PCA Mike Pelan, Lafarge Satish Sheth, CEMEX

1

. C linker P ile S tandards :

July 18 Recommendation : Eliminate clinker pile design and management standards under Section 63.1343(c)

. Include “open clinker piles” among the list of affected sources under Section 63.1340(b). Define “open clinker piles” under Section 63.1341. An “open clinker pile”
is: “ an outdoor , unenclosed acc umulation of clinker on the ground, which contains in excess of X tons of clinker, and is utilized for a continuous period in excess of X days.” In doing the foregoing, fugitive emissions from open clinker piles would be addressed by the NESHAP general du ty to minimize emissions under Section 63.1348(d).

Summary of Meeting Discussion : EPA is willing to drop the clinker pile design and management standards in exchange for some type of obligation to minimize emissions from clinker piles. The Agency would like PCA to share a list of work practice methods the industry employs to
minimize clinker pile emissions, such as tarps, water sprays, surfactants, foams, etc (Subpart Y may have examples for coal piles) and the effectiveness of these strategies. The Agency may then explain these practices in proposed changes to the NESHAP as a means of justifying dropping design and management standards. EPA would also like to know whether there are2 any permanent outdoor stockpiles of clinker (it was explained that the vast majority of these piles are seasonal, intended to address market conditions).

2

. The affirmative defense for malfunctions : This issue was no t discussed during the July 18 meeting.

3

. Modifications to the THC Standard :

July 18 Recommendation : P lants that opt to comply with the o HAP limit would be allowed to either: (1) demonstrate compliance with the oHAP limit annually without having to continuously monitor THC emissions, or (2) through testing, establish a surrogate THC emission limit proportional to the 9 ppmv oHAP limit and continuously monitor THC emissions to verify complianc e with the THC surrogate standard.

Summary of Meeting Discussion : EPA is willing to propose either of these alternatives, though was more inclined to support the option with continuous monitoring (option 2)

.

4

. HCl Monitoring During Start

- up and Shutdown :

July 18 Recommendation : EPA should apply at least a 23 ppm (risk

- based threshold) HCl standard during periods of start

- up and shutdown. HCl continuous emission monitors during

start

- up and shutdown would be required only for those facilities that DO NO T employ a wet or dry scrubbing technology (see issue below)

. Summary of Meeting Discussion : EPA generally agreed that HCl continuous emission monitors should not be required for facilities that elect to employ dry scrubbers (as is the case for
facilities that use wet scrubbers) , while at the same time, rejected the PCA suggested risk

- based
HCl emission standard for start

- up and shutdown. T here was then an extended discussion regarding the difficulties of monitoring HCl (or any other pollutant for that matter) during start

up and shutdown be cause of irregular gas flows. etc . EPA explained that the Agency is not obliged to set an emission standard if it can be demonstrated that emission s may not be reliably measured during these periods. PCA agreed to c onsider this issue further and may request an analysis to support the difficulty in monitoring during these periods. If it is demonstrated that emissions may not be measured, EPA may then apply a work practice designed to minimize emissions in lieu of an emission limit.

5

. HCl Continuous Emission Monitor (CEM) for Dry Scrubbers :

July 18 Recommendation : As indicated above, those facilities equipped with a wet scrubber or dry scrubbing device (meeting the following criteria) to limit HCl emissions would not be required to use an HCl CEM. For dry scrubbers t o qualify, cement plant operators would have3 to demonstrate that the d evice when operating is capable of ensuring compliance with the 3 ppm standard during normal operations

.
Summary of Meeting Discussi on : As indicated above, EPA generally concurred that facilities equipped with a dry scrubber would not have to continuously monitor HCl emissions , provided they demonstrate compliance with the emission limit through testing when the dry scrubber is operati ng. In a perfect world, EPA would like to have actual data verifying the efficacy of dry scrubbers to continuously achieve the HCl emission limit during normal operations. PCA explained that such data is not, and will not likely be, available in the near future. Finally, EPA suggested, that in lieu of continuous emission monitoring for dry scrubbers, EPA may require facilities to do some type of parametric monitoring, as currently required for wet scrubbers. Or, alternatively rely on SO 2 monitors as a s urrogate for HCl emissions.

6

. Alternative Particulate Matter (PM) Standard Equation :

July 18 Recommendation : See below:

PM alt = 0.004 x 1.65 x Qs /7000 (Eq. 1)

PM alt= 0.004 x 1.65 x (Qs + Qb)/7000 (Eq. 2)

Where: 0.004 is the PM exhaust concentration (gr/dscf) equivalent to 0.04 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

Qs = Qk + Qc + Qm + Qb (inputs to the equation based on plant ’s gas flow conf igu ration vented
to the main kiln stack , reflecting maximum kiln production )

Qb is the exhaust flow from an alkali bypass stack (dscf/ton raw feed)

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

Qc is the exhaust flow of the clinker cooler (dscf/to n raw feed)

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

Equation 2 would be used by those plants equipped with a separate alkali bypass stack.

Summary of Meeting Discussion : EPA concurred with the PCA recommended approach for calculating a new PM limit for commingled sources. There was then an extended discussion regarding by

- pass stacks and whether and how to continuously monitor their emissions. Th ree alternatives were i dentified and will require additional thought, as follows: (1) do continuous monitoring of the by

- pass stack, (2) duct the by

- pass to the main stack, or (3) c onduct an annual test of by

- pass emissions and subtract them from the main stack emissions (for H g and PM).4 7

. Continuous Monitoring for Mercury and PM during Start

- up and Shutdown :

July 18 Recommendation : The NESHAP stipulates the use of a 7

- day rolling average when computing compliance with the PM and mercury standards. The rule further stipulate s that the 7 day period be consecutive operating days, were an operating day is any daily 24

- hour period during which the kiln operates. This creates confusion, as one could interpret the rule to require compliance only when the start

- up/shutdown period l asts at least 7 consecutive days. This situation may be remedied by applying on e of the two options:

1

. Employ a total of 168 hours rolling for any start

- up or shutdown period. 2

. Use a weighted average

- daily value during start

- up or shutdown periods.

Optio n 1 would eliminate any bias created when an operating day has one or a fewer operating hours. It would allow hours to be carried forward to the next startup/shutdown period. This would facilitate calculation of a true 168

- hour rolling average.

Option 2 would require that the source track emissions and number of hours per day, thereby allowing it to calculate a weighted

- average value for the 7

- day startup/shutdown period. Additionally, the calculation is carried forward to the next startup/shutdown even t, so a true 7

- day rolling average can be calculated for any startup/shutdown period.

Summary of Meeting Discussion : This issue was addressed during the discussion of Issue number 4 above. If the industry demonstrates that it is impossible to accurately monitor emissions of these pollutants during start

- up and shutdown, EPA may impose some type of work practice geared to minimize emissions in lieu of an emission standard.

8

. Regulatory Status of Coal Mills : The three categories of coal mills include:

a

. Coal Mills Receiving Only Hot Air from Clinker Coolers, Vented through a Separate Stack
b

. Coal Mills Receiving Kiln Gases, Vented through a Separate Stack

c

. Coal Mills Receiving Kiln Gases, Vented back to the Kiln Exhaust

July 18 Recommendation: Th e first two categories of coal mills would be regulated under NSPS Subpart Y for particulate mat ter emissions only (Subpart Y PM limit) , as there is no separate combustion source used to dry coal in the mill for these process configurations. For the third category of “inline coal mills,” as indicated above under issue 6, the PM equation for commingl ed sources would be modified to account for the PM coming from coal mills and for THC, the oHAP compliance alternative would be employed.5 Summary of Meeting Discussion : There was an extended discussion regarding the three configurations. EPA was in gene ral agreement that the first configuration should be regulated under Subpart Y for PM. For the second configuration, EPA did not object to the recommendation that these be regulated under Subpart Y, though the Agency wonder ed how
the reduced main stack em issions would impact compliance with the NESHAP

. It was suggested that for the second and third configurations a plant may be obliged to confirm compliance with
the NESHAP standards before the kiln gases are routed to the coal mill.

9

. PM L imit for M odified S ources under NSPS :

July 18 Recommendation : Applying the existing source NESHAP PM standard (as modified through potential rule changes) is preferred to what was in the final NSPS rule, however, this issue is being litigated and resolution may ne ed to wait the outcome of the DC Circuit decision.

Summary of Meeting Discussion : Though this issue was not discussed in great detail, it was suggested that if EPA planned to apply the NESHAP existing source PM limit to modified NSPS
facili ties that EPA s hould simply indicate in modifications to the NSPS rule that there is no new regulatory obligation fpr PM , as all existing facilities must comply with the new existing source

PM NESHAP standard.