Memorandum

TO: Portland Cement Project Team

FROM: Keith Barnett, US EPA

SUBJECT: Revised Portland Cement NE SHAP 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 identi fied 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

PAEssrocItalceme ntiGroupBessemerPALafargeWhitehallPlant

PALehighCementEvansville

PALehighCementYork

SCLafargeHarleyville

TNCemexKnoxville

TXAshGroveMidlothian

TXCemexBalconesPlant

TXHolcimMidlothianPlant

TXLoneStarMaryneal

UTAshGroveLeamington

UTHolcimDevilsSlide

WAAshGroveSeattle

WALafargeSeattle

Follow up questions were sent by EPA to these fac ilities to gain additional information on some of their fuels, specifically used oil, tires, w ood 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 th at come from an established tire collection program, clean wood, clean biomass, and used o il that is on spec are not solid waste. We eliminated the kilns that burned only these altern ative 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 1In 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 CI SWI Units (but are not in CISWI data base) Location Number of Kilns Why is it CISWI? Lehigh, Union Bridge MD 1 Burn s dried biosolids as a fuel Lafarge, Alpena MI 5 Burns Plastics

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

Materials that enter the cold end of the k iln 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 wh ere 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 materi als 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 ut ilization 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 floor s recalculated as shown below. That is, we recalculated the floors as if the recently prom ulgated definition of non-hazardous secondary materials which are solid wastes had been in pl ace 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. Seventee n 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 no w 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 resu lts were as follows:

Existing Source floor: 58 lb/MM tons clinker (versus 55 in the current rule)New Source Floor: 24 lb/M tons clin ker (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 mo nitoring 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 99 th percentile of the data of the two floor kilns is 15 ppmvd and the new source floor wo uld 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. Removi ng the CISWI kilns left 31 kilns. The best performing kilns would be the top 4. New so urce MACT does not change; it is still the

Mitsubishi kiln.

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

HCl Floor

There were HCl test data for 21 kiln s. Four of the 21 were CSWI kilns, leaving 17 NESHAP kilns. The best performing 12 percent would be 3, wh ich is unchanged from the promulgated rule. However, one of the three used in the NESHAP ru lemaking is a CISWI kiln. This was replaced with the next best performer. The result wa s a floor of 1 ppmvd, which is still below the minimum quantification limit of 3 ppmvd. This standard thus would be unchanged.