500 New Jersey Avenue, N.W., 7th 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: Implications 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 portland cement national emission 

standard for hazardous air pollutants (NESHAP). 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 decisions 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 clinker, 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 

production 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). Furthermore, assuming that the revised PM standard is finalized at the end of 2012, 

the industry will need until September of 2015 to carry out the necessary engineering, procurement, 

fabrication, on site construction, commissioning of equipment and performance testing, prior to a 

new compliance deadline. As we will 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 alter 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 (CPMS), 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 that 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 

parameter 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) 408-9494 or aohare@cement.org. 

Sincerely,

Andrew T. O’Hare

Vice President, Regulatory Affairs

Attachment: PCA April 9, 2012 Technology Analysis