500 New Jersey Avenue, N.W., 7 th Floor

Washington, DC 20001 202.408.9494 Fax 202.408.0877

www.cement

.org May 24 , 2012
Keith Barnett Office of Air Quality Planning and Standards U.S. Environmental Protection Agency Research Triangle Park, NC 27711

Steve Silverman
Office of General Counsel U.S. Environmental Protection Agency Washington, DC 20460

RE: Imp lications of Altered Particulate Matter Limit on PCA Technology Analysis

Dear Keith and Steve,

Thank you for providing PCA with some of the Agency’s preliminary thinking on key issues anticipated to be included in upcoming proposed revisions to the port land cement national emission standard for hazardous air pollutants (NES H AP). I am following up on your specific request for PCA to reconsider an analysis the association conducted of the impact a change to the particulate matter (PM) emission limit could have on emission control technologies selected by the industry for compliance.

The analysis in question, dated April 9, 2012 (another copy attached), was designed to
address the impact a change in the PM limit would have on emission control equipment d ecisions of the cement industry and the time needed to carry out those decisions, subsequent to finalization of a change in the limit. When the analysis was conducted , PCA assumed that the new limit would be in the range of 0.06 to 0.08 pounds / ton of clin ker

, with compliance premised upon on a 30

- day rolling average and the use of a continuous emission monitoring (CEM) device

. The PCA analysis concluded
that more than half of all existing kilns (representing a significant percentage of U.S. cement product ion capacity) are going to need to redefine their PM control strategy and the optimal approach for addressing the other regulated pollutants (hydrochloric acid, mercury, and total hydrocarbons). Further more , assuming th at the revised PM standard is finali zed at the end of 2012, the industry will need until September of 2015 to carry out the ne cessary engineering, procurement, fabrication, on site construction, commissioning of equipment and performance testing

, prior to a new compliance deadline. As we wi ll not know the final outcome of the rule changes until the end of 2012, we will not be able to make definitive plans and commitments until that time.

You inquired as to whether the conclusions of the April 9 report would be impacted if EPA
elected to alt er the approach for compliance with the PM limit. Specifically, you noted that EPA anticipates proposing a PM limit of 0.07 pounds / ton of clinker

, with compliance demonstrated through a stack test and the use of a continuous parameter monitoring system (C PMS) , rather than a

CEM . Based on discussions with the PCA members that participated in our survey, we conclude that the findings in the PCA analysis are unchanged by this alternative compliance determination method.2 Importantly, the numerical limit th at EPA is considering for PM is consistent with our earlier assumption. Moreover , while compliance through a stack test can be different from that associated with a CEM, the requirement to operate a CPMS and show compliance with the selected operating

par ameter on a 30

- day average basis

, makes the two approaches to compliance quite similar. Regardless of which compliance plan is eventually adopted, we will not be able to make plans to accommodate it until the rule changes are complete in December 2012. Thus, the need for a September 2015 compliance deadline remains unaffected. Of course, once the proposed rule is out
for comment

, we will be in a position to provide more detailed feedback.

Thank you again for sharing with PCA some highlights of the upcoming EPA proposal. I would be happy to address any questions you may have regarding PCA’s perspectives on this matter and may be reached at (202) 408

- 94 94 or aohare@cement.org

.

Sincerely

,

Andrew T. O’Hare Vice President, Regulatory Affairs

Attachment : PCA April 9, 2012 Technology Analysis