Memorandum 

TO: Portland Cement Project Team 

FROM: Keith Barnett, US EPA 

SUBJECT: Revised Portland Cement NESHAP Floors with CISWI kilns removed 

DATE: March 21, 2011 

Revision of Emission data base to remove possible CISWI kilns 

The following table lists kilns that had been identified as potential CISWI kilns in the proposal of 

the CISWI rule. This list was compiled based on responses to an EPA survey and was based on 

the proposed definition of non-hazardous solid waste. 

Table 1. List of CISWI Cement Kilns 

at Proposal of the CISWI Rule

ALCemexDemopolis

ALLafargeRobertaPlant

ALLehighCementCoLeeds

CACAPortlandCementColton

CALehighSouthwestReddingPlant

CAMitsubishiCement

CANationalCementofCA

FLCemexBrooksville

FLCemexMiami

FLFloridaRock

FLRinkerBrooksville

GACemexClinchfield

IALafargeBuffalo

IALehighCementMasonCity

IDAshGroveInkom

ILBuzziUnicemOglesby

ILLafargeJoppaPlant

KSMonarchCementCoHumboldt

MDESSROCFrederickPlant

OKLafargeTulsaPlant

OKLoneStarPryor

ORAshGroveDurkee

PAEssrocItalcementiGroupBessemer
PALafargeWhitehallPlant

PALehighCementEvansville

PALehighCementYork

SCLafargeHarleyville

TNCemexKnoxville

TXAshGroveMidlothian

TXCemexBalconesPlant

TXHolcimMidlothianPlant

TXLoneStarMaryneal

UTAshGroveLeamington

UTHolcimDevilsSlide

WAAshGroveSeattle

WALafargeSeattle

Follow up questions were sent by EPA to these facilities to gain additional information on some 

of their fuels, specifically used oil, tires, wood waste and spent seed corn. These responses 

were then reviewed based on the final solid waste definition rule signed on February 21, 2011. 

The final solid waste rule states that tires that come from an established tire collection 

program, clean wood, clean biomass, and used oil that is on spec are not solid waste. We 

eliminated the kilns that burned only these alternative fuels from the CISWI list. The remaining 

CISWI kilns are shown below in Table 2. 

 

Table 2. CISWI Cement Kilns

FacilityID UnitID

CALehighSouthwestReddingPlant In-Line Kiln/Raw Mill (S260)

FLCemexMiami Cement Kiln

IALafargeBuffalo Kiln 1

IALehighCementMasonCity 302.203

PALafargeWhitehallPlant Kiln 2

PALafargeWhitehallPlant Kiln 3

PALehighCementEvansville 122

PALehighCementEvansville 121

PALehighCementYork 200

TXHolcimMidlothianPlant Kiln 2

TXHolcimMidlothianPlant Kiln 1

UTHolcimDevilsSlide Kiln 1

 

 
In addition to the kilns above, the recent ICR follow up on alternative fuels indicates the 

following kilns in Table 3 would also be CISWI kilns (though they were not in the CISWI data 

base). 

Table 3. Additional Kilns identified as CISWI Units (but are not in CISWI data base) 

Location Number of Kilns Why is it CISWI? 

Lehigh, Union Bridge MD 1 Burns dried biosolids as a fuel 

Lafarge, Alpena MI 5 Burns Plastics 

 

Note that it is EPA’s position that combustion does not occur in the cold end of a cement kiln. 

Materials that enter the cold end of the kiln are gradually heated until they reach the 

temperature where clinker formation takes place. This is in contrast to combustion where fuel 

is introduced into the kiln at a location where the temperature is sufficient to immediately 

commence the process of combusting the fuel. (Fuels are never burned in the cold end of a 

cement kiln, and our interpretation reflects that understanding.) This means that cement kilns’ 

practices of using non-hazardous secondary materials in the cold end of the cement kiln would 

not make the kilns “solid waste incineration unit[s]” within the meaning of section 129 (g)(1) of 

the CAA since kilns would not “combus[t]” those materials. Consequently, we do not include 

any cement kiln in this analysis based on utilization of non-hazardous secondary materials in 

the cold end of the cement kiln. 

For purposes of this analysis, all of the kilns shown in Tables 2 and 3 were taken out of the 

Portland cement emissions data base and the floors recalculated as shown below. That is, we 

recalculated the floors as if the recently promulgated definition of non-hazardous secondary 

materials which are solid wastes had been in place at the time of the cement kiln NESHAP 

rulemaking. 

Mercury Floor 

The mercury floor was calculated based on a data base of 89 kilns where we had approximately 

30 days of data on all mercury inputs. Seventeen of the 18 CISWI kilns shown above were part 

of the mercury data base. Removing the 17 CISWI kilns leaves 72 kilns. The best performing 12 

percent would be 9 kilns. 

Of the best performing 11 kilns that were used in the previous floor calculation, two would 

have been CIWSI, 1589, and 1248. Removing these kilns from the MACT floor pool leaves the 9 

best performing kilns. The single best performing kiln now becomes kiln 1650. 

The floors were recalculated (See attachment 1) based on the best performing 9 kilns and the 

new source floor was recalculated based on kiln 1650. The results were as follows: 

Existing Source floor: 58 lb/MM tons clinker (versus 55 in the current rule) 
New Source Floor: 24 lb/M tons clinker (versus 21 in the current rule) 

THC Floor 

The THC Floor was re estimated using the THC data set used in the final rule. This data set 

consisted of 15 kilns where we had continuous monitoring data. Of these 15 kilns, four would 

have been CISWI kilns (including Union Bridge, the best performer on average). This leaves 9 

kilns, and the best 12 percent would be two. The best performing kilns on average become 

Suwannee, Branford and Holcim Trident. The resulting floor based on the 99th percentile of the 

data of the two floor kilns is 15 ppmvd and the new source floor would be 11 ppmvd. The 

corresponding organic HAP limits (under the alternative standard) would be 6 and 4 ppmvd 

respectively. 

PM Floor 

There were 45 kilns in the PM data set. Removing the CISWI kilns left 31 kilns. The best 

performing kilns would be the top 4. New source MACT does not change; it is still the 

Mitsubishi kiln. 

The existing source MACT floor using the four best performing kilns is 0.05. 

HCl Floor 

There were HCl test data for 21 kilns. Four of the 21 were CSWI kilns, leaving 17 NESHAP kilns. 

The best performing 12 percent would be 3, which is unchanged from the promulgated rule. 

However, one of the three used in the NESHAP rulemaking is a CISWI kiln. This was replaced 

with the next best performer. The result was a floor of 1 ppmvd, which is still below the 

minimum quantification limit of 3 ppmvd. This standard thus would be unchanged.