From: O’Hare, Andrew <AOhare@cement.org>

To: Keith Barnett/RTP/USEPA/US@EPA

Date: 08/28/2009 01:23 PM Subject: Draft THC Data Colllection Plan

Keith,

Attached please find a draft THC data collection plan. We will discuss with

you on the call later this afternoon.

Regards,
Andy

Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

500 New Jersey Avenue, N.W., 7th Floor
Washington, DC 20001

PH: (202) 408

‐ 9494

FX: (202) 408

‐ 0877

CELL: (202) 270

‐ 0094

e

‐ mail: aohare@cement.org (See attached file: Draft PCA THC plan 8

‐ 28

‐ 09.DOC)August 28, 2009

8-28-09 PCA Plan for Supplementing the MACT Decision Making Record

With Additional THC CEMS Data

Background

In December 2006, EPA finalized its rulema king for a revised PC MACT. At the same time the rule was published in the Federal Register, EPA also published a second notice advising that it was r econsidering the rule.

Due to continued pressure and court ac tions by those challe nging the rulemaking and the timeliness of EPA’s efforts to issue a final rule, in March 2007, EPA set out a Section 114 notice to the nine largest cemen t companies requesting that they provide emissions data for mercury, THC, and HCl. EPA sent the request to only nine companies, because requesting information from the entire industry would have required time consuming procedural steps that woul d have slowed down the data collection process. EPA was therefore limited to collecting information from less than ten companies via the Section 114 process.

Those companies represented only 89 of the 167 PC MACT kilns in the United

States at the time. The Secti on 114 request mandated that fac ilities collect raw material and fuel samples for 30 consecutive days in June 2007, and have them analyzed for mercury and total organic carbon (TOC). EP A planned to use these data to develop

material balances needed to estimate mercur y and THC emissions from cement kilns. In addition to the raw material and fuel sampli ng, EPA also requested that these companies provide all stack testing and CEMS data in their possession related to mercury, THC, and HCl. All data was collected and submitted to EPA prior to the end of 2007.

EPA reviewed and analyzed the data pr ovided by the cement industry for several months. Near the end of 2008, EPA concluded that they could not effectively estimate THC emissions from the TOC data provided (bec ause they did not request stack testing in conjunction with raw material testing), and instead, decide d to rely on the THC CEMS data provided by approximately 11 plants (14 k ilns). These data cons isted of less than 30 days to, in very few cases, more than 2 year s of data. EPA then ranked these data, and using a MACT basis of the average of the best 12% performing units with CEMS data,

established a THC MACT floor for kilns and raw material dryers relying on an average of the two lowest emitting kilns. No data was collected for raw material dryers.

Current Status of Available Data

Since the time of the submittal of the S ection 114 data, all of the sources that reported THC CEMS data have collected additional data. These data will be submitted to EPA as part of PCA’s comments on the propos ed rulemaking. Based on PCA’s analysis of this longer term data, PCA believes that EPA will be comfortable that there is enough THC CEMS data to develop a defensible floor for most of the industry. In the next

1August 28, 2009

couple of days, PCA will send to EPA this data and will welcome the opportunity to discuss the data with you.

PCA has analyzed this longer term data (now all > 1 year in duration) from 5 kilns along with data provided by EPA for other kilns not included in the original Section 114 data request, to determine a revised MACT floor. The analysis shows that there is

sufficient data to establish a MACT floor based on the 99 th percentile. Using the data, PCA will propose a THC MACT floor in its comments to the proposed rule. Further

THC CEMS data from a random selection of kilns will likely not impact a MACT floor analysis beyond the data curren tly being reviewed, and PCA be lieves that gather of such data will not be helpful to EPA and will impose an unnecessary burden on the industry.

The data does not show, however, whethe r the limestone reserves available to units in the existing data pool or other units have significant variati ons in the nature and amount of organics. To addr ess this uncertainty, PCA welc omes the opportunity to work with EPA on conducting an industry-wide effo rt to gather more THC CEMS data to address this issue and possibl y provide support for subcategories given the variations in

the raw materials. Such a focused effort to gather longer term THC CEMS data is

warranted for several reasons:

• It is likely that the high THC levels fo r some kilns can be attributed to a combination of the level of organics in th e limestone, the form of the organics in the limestone and a kiln configuration th at has one or more source of organic releases downstream of the kiln (in part icular in-line raw mills and in-line coal mills venting to the main stack.) While a few of the units with THC CEMS have high THC emissions, the data on limestone organics have not been collected or

correlated to these kiln emissions.

• EPA has assumed the stand alone raw mills and coal mills operated on kiln gases should meet the kiln THC limit, but EPA ha s no data to show that this is an appropriate extension of kiln THC measur ements. We have limited data that suggests that these units have low volum e, higher THC emissions than kilns.

• Separate standards (which could be a sub category or distinct affected source) for stand alone raw mills operated with supplem ental fuel firing, raw material dryers and those kilns with high THC levels due to organics in the co-located quarry may be appropriate. This cannot be done without a strong database of THC CEMS readings and feed material charact eristics supporting the best possible presentation on the need for one or mo re added subcategories for THC limits.

• However, for stand alone raw mills that use supplemental fuels and coal mills that use kiln or cooler gases, there is no da ta to suggest that organic HAPs are even

emitted.

THC Monitoring Program Goals

The first goal of the testing program is to gather sufficient kiln THC emissions CEM data and raw materials organics charac terization data (over several months) such

that PCA can determine if there is a basis for one or more subcategories for high THC

emissions kilns related to the characteristics of the limestone. Furthermore, where either

2August 28, 2009

3 coal mill and/or raw material dryer exhaust are co-mingled with the kiln stack emissions, it is important to determine whether either case warrants subcate gorization. The second goal will be to collect organi c HAP data for stand alone raw material dryers and coal mills that use kiln gases for drying to determine whether these sources emit organic

HAPs. If it is determined that these sources emit significant HAPs, then CEMS monitoring may be necessary to establish a floor. Prior to commencing such an investigation, PCA will statistically design the project to ensure all elements are included.

Program Approach

Once candidate plants have been identified, member companies will install CEMS and gather raw material samples and complete analyses consistent with a standard project protocol. PCA will hire a third-party contract or to oversee the testing program, working with the individual firms on completing the m onitoring activities and then interpreting the

data. Each of the selected f acilities will be requi red to install a THC CEMS at their own expense and collect data for at least 6 months. In parallel, the limestone will be analyzed during the same period for organics content as well as the level and nature of releases during grinding and drying.

Proposed Schedule

As you know, the majority of PCA's and its member companies' efforts are currently focused on preparing comments on the proposed rule, which are due next week. By September 15, PCA will develop a proposed test plan for EPA review. PCA is committed to working with EPA to ensure that the test plan is supported by EPA and the scope and objectives are clearly establishe d and known to all parties. After obtaining EPA's concurrence on the scope and sche dule of the study by September 30, PCA will initiate testing with the expectation of providing data to EPA in the spring of 2010.