UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 19103
DATE: April 25, 2010 SUBJECT: Technical Support Document

– Commonwealth of Pennsylvania

– Control of

Nitrogen Oxides from Portland Cement Kilns /s/ FROM: Rose Quinto, Environmental Engineer

Office of Air Program Planning TO: File /s/ THRU: Cristina Fernandez , Associate Director

Office of Air Program Planning
A. BACKGROUND On July 23, 2010, the Pennsylvania Department of Environment al Protection (PADEP) submitted a State Implementation Plan (SI P) revision pertaining to the control of nitrogen oxides (NOx) emissions from Portland cement kilns. Portland cement manufacturing is an energy intensive process in which cement is made by gri nding and heating a mixture of raw materials such as limestone, clay , sand , and iron ore in a rotary kiln. NOx emissions are generated during fuel combustion by

oxidation of chemically
- bound nitrogen in the fuel and by thermal fixation of n itrogen in the combustion air. This SI P revision is based on the Ozone Transport Commission (OTC) control measure to reduce NOx emissions from cement kilns. The OTC members include Pennsylvania, Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey , New York, Rhode I sland, Vermont, Virginia, and the District of Columbia. The OTC was created under section 184 of the Clean Air Act ( CAA ) to establish regulatory programs to reduce ozone precursor emissions, which includes the reduction of NOx emi ssions from cement kilns.
B. STATE SUBMITTAL The SI P revision amends the NOx emission standards in the Title 25 of the Pennsylvania Code (25 Pa. Code) Chapter 145, Subchapter C , “Emissions of NOx from Cement Manufacturing , ” for Portland cement kilns during the ozone season, from May 1 through September 30, 2011, and for each y ear thereafter. The SI P revision added new definitions and terms:2

1. Calcine

– To heat a substance to a high temperature, but below its melting or fusing point, to bring about thermal decomposition or a phase transition in its phy sical or chemical constitution. 2. Long dry

-

process cement kiln

– A Portland cement kiln that employ s no preheating of the feed. The inlet feed to the kiln is dry
. 3. Long wet

-

process cement kiln

– A Portland cement kiln that employ s no preheating of the feed. The inlet feed to the kiln is slurry
. 4. Precalciner cement kiln

– A Portland cement kiln where the feed to the kiln sy stem is preheated in cyclone chambers and a second burner is used to calcine materi al in a separate vessel attached to the preheater prior to the final fusion in a kiln that forms clinker. 5. Preheater cement kiln

– A Portland cement kiln where the feed to the kiln sy stem is preheated in cyclone chambers prior to the final fusion in a kiln that forms clinker. 6. System

- wide

– Two or more Portland cement kilns under the common control of the same owner or operator, or multiple owners, in the Commonwealth. The other definition s mentioned in this SI P revision were already approved by

EPA on De cember 10, 2009 (74 FR 65446): continuous emi ssions monitoring sy stem (CEMS) , c linker , Portland cement , and Portland cement kiln
. Therefore, these terms are not included in this action. Standard Requirements Section 145.143(b) was revised to provide th at the owner or operator of a Portland cement kiln cannot operate a Portland cement kiln that results in NOx emissions in excess of its allowable emissions. Section 145.143(b)(1) added a compliance date of May 1 through September 30, 2005, and each y ear thereafter, the owner or operator will determine allowable emissions by multiplying the tons of clinker produced by the Portland cement kiln for the period by 6 pounds per ton of clinker produced. Section 145.143(b)(2) was also revised to require the owner or operator of a Portland cement kiln determine allowable emissions of NOx by multiplying the tons of clinker produced by the Portland cement kiln for the period from May 1 through September 30, 2011 and for each y ear thereafter by : (1) 3.88 pounds of NOx per ton of clinker produced for long wet
- process cement kilns. (2) 3.44 pounds of NOx per ton of clinker produced for long dry
- process cement kilns.3

(3) 2.36 pounds of NOx per ton of clinker produced for preheater and precalciner cement kilns. A minor change was made to section 145.143(c) clarifying that the owner or operator of a Portland cement kiln subject to section 145.143(b)(1) will install and operate a CEMS and report CEMS emissions data
. The other sections mentioned in this SI P revision under sect ion 145.143 were already approved by EPA on December 10, 2009 (74 FR 65446): Sections 145.143(a), 145.143(b)(1), and 145 .143(d) through (h). Therefore, these sections are not included in this action. The following sections were added to the SI P revision : Section 145.144. Compliance Determination Requirements By April 15, 2011, the SI P revision requires the owner or operator of a Portland cement kiln : 1. T o install, operate and maintain CEMS for NOx emissions. 2. To report CEMS emissions data to PADEP in ac cordance with the CEMS requirements of 25 Pa. Code Chapter 139, Subchapter C, relating to the requirements for source monitoring for stationary sources. 3. Calculate actual emissions using the CEMS data reported to PADEP
. A data invalidated under 25 Pa. Cod e Chapter 139, Subchapter C will be substituted either by the highest valid 1
- hour emission value that occurred under similar source operating conditions during the reporting quarter for an invalid data period during that quarter, or an alternative method of data substitution as appro ved by PADEP in writing. If no valid data were collected during the reporting quarter, the highest valid 1
- hour emission value that occurred under similar source operating conditions during the most recent quarter for which va lid data were collected, or the highest valid 1
- hour emission value that occurred under similar source operating conditions during an alternative reporting period, sha ll be reported to PADEP
. Additionally , under this section, the owner or operator of a Po rtland cement ki ln will submit to PADEP quarterly

reports of CEMS monitoring data in pounds of NOx emitted per hour, in a f ormat approved by PADEP , which is in compliance with 25 Pa. Code Chapter 139, Subchapter C. Also, the CEMS for NOx installed under t he requirements of this section, must meet the minimum data availability requirements in 25 Pa. Code Chapter 139, Subchapter C.4

Section 145.145. Compliance Demonstration and Reporting Requirements By October 31, 2011, and each y ear thereafter, the owne r or operator of a Portland cement kiln will submit a written report to PADEP which includes the following:

1. The difference between the actual NOx emissions from the kiln during the interval from May 1 through September 30 and the allowable emissions for that period. 2. The calculations used to determine the difference in emissions, including the CEMS data and clinker production data used to show compliance with the allowable emission limits. The clinker production data must consist of the quality of clinker , in tons, produced per day for each kiln. The owner or operator of a Portland cement kiln must demonstrate compliance with the emission requirements on a kiln
- by
- kiln basis, a facility
- wide basis or a sy stem - wide basis among Portland cement kilns
. Se ction 145.146. Recordkeeping Requirements T he owner or operator of a Portland cement kiln must maintain an operating log for each Portland cement kiln. The operating log must contain the following on a monthly basis: (1) The total hours of operation. (2) T he ty

pe and quantity

of fuel u sed. (3) T he quantity

of clinker produced. The records maintained by the owner or operator of a Portland cement ki ln must include the following: (1) S ource tests and operating parameters established during the initial source test a nd subsequent testing
. (2) The date, time and duration of any start - up, shutdown or malfunction of a Portland cement kiln or e missions monitoring sy stem. (3) T he date and ty

pe of maintenance, repairs or replacements performed on the kilns, control devices an e mission monitoring sy stems. Furthermore, the owner or operator of a Portland cement kiln must maintain the records onsite for five y ears and be made available to PADEP upon request.5

C . EPA EVALUATION This regulation will reduce emissions of NOx from c ement kilns to reduce levels of ground
- level ozone. Ground
- level ozone is not directly emitted by

pollution sources, but is created as a result of a chemical reaction of NOx and volatile organic compounds (VOC) in the presence of light and heat. The redu ction of NOx emissions will also help protect the public health from high levels of fine particulate matter (PM 2.5 ), of which NOx is a precursor component. PM 2.5 , as well as ozone, is health hazards. The reduction of NOx emissions also reduces visibility impairment and acid deposition.
D . CONCLUSION S AND RECOMMENDED AGENCY ACTION The regulation to control NOx emissions from Portland cement kilns adopted by the Commonwealth of Pennsylvania will result in the reduction of NOx emi ssions from cement kilns and w ill help the Commonwealth in attaining compliance with the 8
- hour ozone and PM 2.5 national ambient air quality standards (NAAQS ) . EPA approval of the SI P revision is recommen de d.