DRAFT

Subject: Meeting with Portland Cement Association and Affiliates – NESHAP Monitoring

Issues

Location: U.S. Environmental Protection Agency, Research Triangle Park, NC

Date: March 22, 2012

Participants:

Portland Cement Association (PCA)

Andy O’Hare, PCA

Dan Nugent, Buzzi Unicem

Mike Pelan, Lafarge 

Satish Sheth, Cemex

Hector Ybanez, Holcim

U.S. Environmental Protection Agency (EPA)

Keith Barnett

Colin Boswell

Sharon Nizich

Robin Segall

Peter Westlin

RTI International

Matt Hakos

Mike Laney

A conference call was held with the PCA for the purpose of discussing monitoring issues 

identified by industry. The list of issues identified by industry and submitted to EPA is attached.
DRAFT

PCA -- NESHAP Monitoring Issues (12-17-10)

Parameter Issue Citation Requirement Issue Recommendation Comments

PM 

(Kiln/Cooler)

Performance §63.1348(a)(1); 

§63.1349(b)(1)

Use first 30 operating days with CEMS There are many issues to discuss 

on PM CEMS that were not in the 

original proposal, so they were not 

in our original comments.

EPA needs to revisit PM CEMS as they apply to 

cement plants.

See Lafarge settlement terms for 30-

day sum of PM Mass readings 

divided by 30 days of clinker 

production.

Additional question on the issue: 

Throughout this section, the phrase 

“must be determined based on the 

first 30 operating days you operate” 

the CEM is used. Does this mean that 

if a source is equipped with that 

monitor prior to the compliance date, 

it must use that data to determine 

initial compliance in the first 30 days 

of operation?

PM 

(Kiln/Cooler)

Performance §63.1349(b)(1)

(iii) and (iv)

Discusses initial compliance based on first 30-days of 

CEMS; requires an emission rate computed for each run

based on concentrations in gr/scf. Includes equations for 

stack emissions and for stack+bypass emissions.

Is “each run” represented by each 

hour since the clinker data 

required is an hourly rate? Or each 

15 minutes since §63.1350(b)(4) 

requires readings to be collected at 

least every 15 minutes. Then 

hourly data to be summed to daily 

data and then averaged into a 30-

day rolling average.

Clarify PCA will provide suggested language

PM 

(Kiln/Cooler)

Compliance §60.63(c)(1); 

§63.1348 

(b)(2)(i); 

§63.1350(b)

PM CEMS per PS-11 and Procedure 2; Performance test 

method for PS-11 must be Method 5 or 5i; Relative 

Response Audits annually and Response Correlation Audits 

every 3 years; §60.63 (f) also references PS-2

In order to range the PM CEMS 

for correlations the facility must 

operate short term above the PM 

limit by intentionally increasing 

PM emissions. Such periods may 

include times prior to and after the 

test run to establish, verify and 

equilibrate the elevated emissions 

and to address testing issues or retests. Also, PM correlation testing 

may require a minimum of 20 

runs, which could require multiple 

weeks.

Expand §63.1357 · These periods should not be 

included in the compliance determination. · EPA 

should explicitly state that it is acceptable to operate 

above the limit for this purpose. · EPA should 

explicitly protect owners or operators against any 

enforcement actions, penalties. or citizens suits.

Partially covered in existing §63.1357 

“Temporary, conditioned exemption 

from particulate matter and opacity 

standards”
Parameter Issue Citation

PM 

(Kiln/Cooler)

Compliance §60.63 (c)(3); 

§63.1350(b)(4) NSPS – 30-operating day rolling average =

NESHAP - Collect readings at least every 15 minutes. Sum 

the hourly data to daily data and then into a 30

average. 

PM 

(Kiln/Cooler)

Compliance §60.64(b)(1) Compliance based on 

average); PM emission rate is calculated on an equation for 

main stack emissions.

PM 

(Kiln/Cooler)

Other PS-11 PM correlation for CEMS

DRAFT

PCA -- NESHAP Monitoring Issues (12-17-10)

Requirement Issue

operating day rolling average =

Collect readings at least every 15 minutes. Sum 

the hourly data to daily data and then into a 30-day rolling 

Is there any inconsistency here 

between NSPS and NESHAP?

How do you have a reading every 

15 minutes if the clinker rate is 

calculated hourly? Or do you take 

the mass of PM each 15 minutes 

and add together then divide by 

the hourly clinker production? 

is it actually 30-days worth of 

summed PM mass readings 

divided by 30-days of clinker 

production? This is the only place 

and only parameter for which the 

EPA mentions how to do a 30

rolling average.

Compliance based on §60.63(c) (i.e., CEMS 30-day 

average); PM emission rate is calculated on an equation for 

main stack emissions.

Discusses compliance based on a 

CEMS 30-day rolling average in 

§60.63(c), but §60.64(b)(1) 

requires an emission rate 

computed based on concentrat

in gr/scf and with no reference to 

30 days.

PM correlation for CEMS The cement industry asserts that 

changes in particle size, refractive 

index, particle density, etc. may 

adversely affect the 

representativeness of the PS 11 

PM correlation over time, and 

EPA has not adequately 

investigated these issues at the 

variety of kiln systems and plant 

configurations where PM CEMS 

will be required.

10)

Recommendation Comments

Is there any inconsistency here 

between NSPS and NESHAP?

How do you have a reading every 

15 minutes if the clinker rate is 

calculated hourly? Or do you take 

the mass of PM each 15 minutes 

and add together then divide by 

the hourly clinker production? Or 

days worth of 

days of clinker 

production? This is the only place 

and only parameter for which the 

EPA mentions how to do a 30-day 

Need to address the averaging methodology for all

parameters. Should be consistent. Should not require 

15-minute values, which conflicts with 60.8(g)(3) 

requiring reduction of CEMS data to hourly values. 

Task Force agreed for clinker based emissions limits 

that rolling 30 day average should be the summed 30 

days of mass emissions over the summed 30 days of 

clinker production. Also address issue of PS-2 vs. PS6. Also see reporting requirements near bottom of this 

table.

See Lafarge settlement terms for 30

day sum of PM Mass readings 

divided by 30 da

production. 

1350(b)(4)- This paragraph must be 

modified to more clearly indicate that 

the PM 30-day average is computed 

by “Sum the hourly data ... into a 30

day average.”

Discusses compliance based on a 

day rolling average in 

computed based on concentrations 

in gr/scf and with no reference to 

Clarify. PS 11 requires evaluating performance relative 

to PM concentration, but recording in units of the 

standard. Equation should be flexible to work with 

units as reported by CEMS.

PCA will provide sugge

The cement industry asserts that 

changes in particle size, refractive 

index, particle density, etc. may 

representativeness of the PS 11 

PM correlation over time, and that 

investigated these issues at the 

variety of kiln systems and plant 

configurations where PM CEMS 

When such changes are suspected, the plant may 

choose to perform new correlation testing or other 

investigations, and a new correlation may be 

established, and the results of previous monitoring may 

be adjusted or rejected as non-representative.

PCA will provide suggested language

See Lafarge settlement terms for 30-

day sum of PM Mass readings 

divided by 30 days of clinker 

This paragraph must be 

modified to more clearly indicate that 

day average is computed 

by “Sum the hourly data ... into a 30-

PCA will provide suggested language

PCA will provide suggested language
DRAFT

PCA -- NESHAP Monitoring Issues (12-17-10)

Parameter Issue Citation Requirement Issue Recommendation Comments

Opacity 

(RM/FM)

Performance §63.1349(b)(2) 3-hr Method 9 §63.1348(a)(2) for initial opacity 

compliance only addresses those 

sources in §63.1345, which does 

not include RM and FM, but the 

Performance testing requirements 

under §63.1349(b)(2) is not 

restricted as such

§63.1348(a)(2) should address RM and FM at major 

sources.

PCA will provide suggested language

Opacity 

(RM/FM)

Compliance §63.1348(b) (3)(i) 

§63.1350(f)(2)

Daily 6-minute VEs by Method 22 on mill sweep and air 

separator dust collectors. If VEs observed retest w/in 24 

hours. If still VEs do 30-minute Method 9 and implement 

corrective action w/in 1 hour if >10%

§63.1348(b)(3) for continuous 

opacity compliance only addresses 

those sources in §63.1345, which 

does not include RM and FM, but 

under §63.1348(b)(3)(i) it 

references §63.1350(f)(2) which is 

for RM and FM and under 

§63.1348(b)(3)(ii) and (iii) it 

references COMS and BLD in lieu 

of daily VEs which are for RM 

and FM.

§63.1348(b)(3) should also apply to RM and FM at 

major sources.

There is no specified opacity standard 

for Raw Mills and Finish Mills in 

1345, but there are in 1350(f). PCA 

will provide suggested language.

Opacity 

(RM/FM)

Compliance §63.1350(f) Indicates monitoring per O&M developed per §63.1350(p) 

and opacity emissions monitoring plan per §63.1350(o)

§63.1350(o) has nothing to do 

with emission monitoring plans. 

§63.1350(p) is not an O&M plan it 

is an emissions monitoring plan.

Reference opacity emissions monitoring plan per 

§63.1350(p)

Make recommended change.

Opacity (Other) Compliance §63.1350(f) Indicates monitoring per O&M developed per §63.1347. Why not per opacity emissions 

monitoring plan per §63.1350(p)?

Reference opacity emissions monitoring plan per 

§63.1350(p)

Make recommended change.

D/F Performance §63.1348(a)(3)(ii) 

and (iii); 

§63.1349(b)(3)(iv) 

and (vi)

References temperature and injection rate operating limits in 

§63.1344

§63.1344 deals with Affirmative 

Defense

Make corrections Make recommended change.
DRAFT

PCA -- NESHAP Monitoring Issues (12-17-10)

Parameter Issue Citation Requirement Issue Recommendation Comments

D/F Compliance §63.1348(b)(4); 

§63.1350(g)

Continuous temperature monitors at inlets to dust collectors. 

3-hour rolling average.

Currently the requirement is a 3-

hour rolling average temperature 

based on 180 successive oneminute averages (i.e., each minute 

compute a new 3-hour average 

using the previous 179 valid data 

points) and new rule is a 3-hour 

rolling average each hour 

calculated using the previous three 

hours of available 1-minute data 

(could be less than 180 data 

points). For in-line mills each 3-

hour rolling average begins anew 

when mill goes up or down.

Keep the current methodology. Facilities are already 

set up to monitor that way. Otherwise EPA needs to 

explain why they changed it and how it provides better 

compliance.

Per the definitions in §63.1341, 

"Rolling Average" means the average 

of all one-minute averages over the 

averaging period. 

1350(g)(4) - Did EPA really mean to 

include the words "Each hour"? It 

should be "each minute" to preserve 

the current methodology for D/F.

THC Performance §63.1348(a)(4)(i); 

§63.1349(b)(4)(i)

§63.1349(b)(4)(i)(A) states that compliance is demonstrated 

with a RATA when CEMS accuracy is w/in 20% or RATA 

is w/in 10% of the standard. THC span (as propane) is 50 

ppmvd. §63.1349(b)(4)(i)(B) states that initial compliance 

is based on the first 30 operating days with CEMS

Which is used for demonstrating 

compliance?

Make corrections This is just an error by EPA, it means 

that the RATA is SUCESSFUL when 

the criteria are met, compliance with 

emission standard is based on the 

monitoring results

THC Compliance §63.1348(b)(6); 

§63.1350(i)(1)

THC CEMS per PS-8 and Procedure 1 PS-8 requirement is to be w/in 

2.5% of the span of 50 ppmvd, 

which is only 1.25 ppmvd for the 

CD, where as previously 

acceptable PS-8A allowed 3 

ppmvd for the CD. The proposed 

NESHAP was for PS-8A, 

therefore we did not get an 

opportunity to comment on PS-8.

Allow previously acceptable PS-8A. PS8A CD limits are +/- 3 ppm or 

+/13% of span, Span is 50 to 100 

ppm. Always used PS8A and 100 

ppm span for cement plants burning 

hazardous waste.

THC Compliance §63.1350(i)(2) For alkali bypass stack may use initial and subsequent 

performance tests.

Not mentioned for 

performance/initial compliance

PCA will provide suggested language
DRAFT

PCA -- NESHAP Monitoring Issues (12-17-10)

Parameter Issue Citation Requirement Issue Recommendation Comments

Alt. THC/ 

OHAPs

Performance §63.1348(a)(4)(ii 

through v); 

§63.1349(b)(4)(ii)

Method 320 or ASTM D6348-03. FTIR, three 1-hr runs 

mill-on & mill-off. Use average HAPs concentrations for 

initial compliance and weighted (mill-on and mill-off) 

average THC CEMS concentration to set site-specific THC 

limit. Repeat every 30 months.

Method 320 quantitation limits > 9 

ppm. §63.1352 allows the 

alternate use of Method 18 “solely 

for use in applicability 

determinations” per §63.1340 (in 

which they never discuss 

applicability determinations). 

Note: the HAPs is based on the 

average value for mill-on/mill-off 

but the alternate THC CEMs value 

is based on a weighted average. 

Also need to define "weighted 

average".

Allow alternate methods for compliance. The HAPs 

concentrations should be for the weighted average for 

mill-on and mill-off values. Define how "weighted 

average" is calculated.

What exactly is a weighted THC 

average for Mill on/Mill off?

Seek EPA insight and PCA will 

provide suggested language.

Alt. THC/ 

OHAPs

Performance §63.1341 (Total 

Organic HAP 

definition)

Only the measured concentration of the listed analytes that 

are present at concentrations exceeding one-half the 

quantitation limit of the analytical method are to be used in 

the sum. If any of the analytes are not detected or are 

detected at concentrations less than one-half the quantitation 

limit of the analytical method, the concentration of those 

analytes will be assumed to be zero for the purposes of 

calculating the total organic HAP for this subpart.

Method 320 quantitation limits > 9 

ppm.

Allow alternate methods for compliance. Requires definitions of 

"quantification limit" and "detection 

limit". Encourages use of bad testers 

and poor test equipment to game the 

system. Such data will not withstand 

any legal scrutiny. Contrary to 

reasonable scientific principles and 

practices. Method 18 must be 

allowed in rule or by response to 

petitions.

Alt. THC/ 

OHAPs

Compliance §63.1348(b)(6); 

§63.1350(j)

THC CEMS per PS-8 and Procedure 1 (same as above) or 

PS-15 and Procedure 1.

Is the facility out of compliance 

until the alternate limit is set? 

Must alternate limit be set prior to 

the compliance date? The 

proposed NESHAP was for PS8A, therefore we did not get an 

opportunity to comment on PS-8.

Provide sufficient time after the compliance date to set 

the alternate TCH limit without the facility being 

considered to be out of compliance.

The PS8 RATA which compares FID 

to FID is arbitrary. If both the 

installed and test FIDs disagree when 

both are calibrated to known 

standards, which is correct? What is 

the appropriate corrective action for a 

failed RATA?

Seek EPA insight and PCA will 

provide suggested language.
DRAFT

PCA -- NESHAP Monitoring Issues (12-17-10)

Parameter Issue Citation Requirement Issue Recommendation Comments

Hg Performance §63.1348(a)(5); 

§63.1349(b)(5)

Use first 30 operating days with CEMS, or 30 daily(?) 

sorbent traps

Are sorbent traps daily for the 

initial compliance?

Throughout this section, the phrase 

“must be determined based on the 

first 30 operating days you operate” 

the CEM is used. Does this mean that 

if a source is equipped with that 

monitor prior to the compliance date, 

it must use that data to determine 

initial compliance in the first 30 days 

of operation?

Seek EPA insight and PCA will 

provide suggested language.

Hg 63.1348(b)(7) Demonstrate continuous compliance by a 30-day rolling 

average Hg emission rate (normal operation) and 7-day 

rolling average Hg concentration (startup/shutdown). 

How does the facility utilize a 

sorbent trap system and 

demonstrate compliance with two 

different emissions standards over 

two different operating 

modes/periods?

Clarify Once the facility switches from 

"startup mode" to "normal operation," 

the emissions standards change. 

However, the sorbent traps do not 

capture the distinction between 

startup and normal operation. Do the 

traps need to be replaced every time 

there is a change between startup 

mode and normal operation? Should 

there be dual sorbent trap systems 

such that one is used for 

startup/shutdown operation and one is 

used for normal operation? 

Seek EPA insight and PCA will 

provide suggested language.

Hg 63.1348(b)(7) Demonstrate continuous compliance by a 30-day rolling 

average Hg emission rate (normal operation) and 7-day 

rolling average Hg concentration (startup/shutdown). 

Compliance with the Hg standard 

after that fact.

If this method provides acceptable data (it mimics the 

reference method and from my understanding has 

demonstrated average data availability of 95%), EPA 

should lengthen averaging periods to greater than 7 

days for startup/shutdown (e.g., 30 days) and greater 

than 30-days for normal operation (e.g., 90 days).

Assuming a sorbent trap can operate 

for a period of 7 days (during normal 

operation), between 20-25% of the 

30-day compliance period will be 

determined after the fact. This leaves 

the facility with less opportunity to 

"adjust" the system in response to 

adverse compliance data. A 90-day 

compliance period leaves 7-8% 

uncertainty during the "last" 7-day 

sorbent trap period. With this 

approach, the facility has more 

opportunity to adjust the system.
DRAFT

PCA -- NESHAP Monitoring Issues (12-17-10)

Parameter Issue Citation Requirement Issue Recommendation Comments

HCl Performance §63.1348(a)(6)(i); 

§63.1349(b)(6)(i)

Wet scrubber. Method 321 and establish operating 

parameters. Initial compliance is the arithmetic average of 

all runs. Repeat every 30 months.

EPA has specified a “typical 

lower quantification range” of 0.1 

– 1 ppm for Method 321, but has 

not provided a definition of how to 

calculate or procedure to 

determine the quantification range, 

particularly in the presence of 

water vapor and as effected by the 

sampling train/PM filter.

EPA should delete "typical lower quantification range, 

should revise Method 321 and include DL and PQL 

determination procedures, performance based

HCl Performance §63.1348(a)(6)(ii); 

§63.1349(b)(6)(ii)

No wet scrubber. Use first 30 operating days with CEMS HCl CEMS are not currently 

available that can meet the 

specified requirements or reliably 

continuously monitor HCl 

emissions at the levels required to 

demonstrate compliance with the 

standards.

No NIST Traceable cal gas.

PS-15 is not adequate, EPA 

acknowledges in Response to 

Comments that an HCl-specific PS 

is needed.

EPA should provide documentation on HCl CEMS 

capable of meeting these requirements.

Need NIST traceable cal gas.

EPA should stay this requirement until HCl-specific 

PS is developed.

Note in the Proposed CISWI MACT 

the EPA stated: "Although final 

performance specifications are not yet 

available for HCl CEMS and multimetals CEMS, EPA is considering 

development of performance 

specifications." EPA has proposed 

PS-13 (Specifications and Test 

Procedures for Hydrochloric Acid 

Continuous Monitoring Systems in 

Stationary Sources) of appendix B of 

40 CFR part 60.

There is currently no known HCl 

CEM available that operates in the 

range specified by the rule. Thermo 

agrees with PCA assessment.
DRAFT

PCA -- NESHAP Monitoring Issues (12-17-10)

Parameter Issue Citation Requirement Issue Recommendation Comments

HCl Compliance §63.1348(b)(8)(i); 

§63.1350(l)(1)

No wet scrubber. HCl CEMS per PS-15 and Procedure 1, 

except RATA requirements per section 11.1.1 and 12.0 of 

PS-15.

Allow other analytical techniques. Argue against EPA's assertion that 

such CEMs are available. Get 

statements from reputable CEMS 

manufacturers. Note in the Proposed 

CISWI MACT the EPA stated: 

"Although final performance 

specifications are not yet available for 

HCl CEMS and multi-metals CEMS, 

EPA is considering development of 

performance specifications." EPA 

has proposed PS-13 (Specifications 

and Test Procedures for Hydrochloric 

Acid Continuous Monitoring Systems 

in Stationary Sources) of appendix B 

of 40 CFR part 60.

There is currently no known HCl 

CEM available that operates in the 

range specified by the rule. Thermo 

agrees with PCA assessment.

HCl Other §63.1352(a) Allows the alternate use of Method 320 “solely for use in 

applicability determinations” per §63.1340

Method 320 is not appropriate for

measurement of HCl especially at 

low concentrations, does not 

address the necessary 

considerations contained in 

Method 321

Method 320 for HCl should not be allowed.

Parameter 

Monitoring & 

Continuous 

Emission Rate 

Monitoring

§63.1350(n)(3) CERM flow rate monitor 5% accuracy Per RATA this should be 10% Accuracy needs to be per RATA requirements.

Parameter 

Monitoring & 

Continuous 

Emission Rate 

Monitoring

§63.1350(o)(4&5) Alternate Monitoring – Administrator will notify you of 

approval or denial within 90 days.....Neither submittal of the 

application or the Administrator’s failure to approve or 

disapprove the application relieves you of the responsibility 

to comply with any provision...

Even if you submit information in 

a timely manner if the 

Administrator does not take 

action, the facility must still be in 

compliance.

If Administrator does not take action within the 

specified time-frame, the alternate method should be 

approved.

PCA will suggest language.
DRAFT

PCA -- NESHAP Monitoring Issues (12-17-10)

Parameter Issue Citation Requirement Issue Recommendation Comments

Parameter 

Monitoring & 

Continuous 

Emission Rate 

Monitoring

§63.1343(a) Ensure appropriate corrections for moisture are made when 

measuring flowrates used to calculate particulate matter 

(PM) and mercury emissions. 

Why only applicable to Hg and 

PM? Also confirm that default 

moisture from annual RATA is 

acceptable.

Why is the moisture correction on 

PM and HCl only? Concentration 

based standards. Does this 

REQUIRE continuous moisture 

monitoring?

If moisture corrections are required, the default 

moisture from annual RATA is acceptable.

This is what EPA is proposing for 

GHG Reporting rule.

Seek insight from EPA and PCA will 

provide suggested language.

Emissions 

Monitoring 

Plan & other 

General 

Monitoring 

Requirements

§60.63 (f) (i)(1); 

§63.1350 (p) 

§60.64(b)(4) cross 

references to 

§63.1350 (p) also

Develop emissions monitoring plan, and submit upon 

request.

As referenced per other NESHAP 

sections - PM CEMS, Opacity 

and Clinker refer to §63.1350(o), 

which has to do with alternate 

monitoring not emission 

monitoring plans

“(o)” should be “(p)” Opacity emissions monitoring plan 

required – if using alternative 

monitoring. Does this apply to prior 

AMRs?

Emissions 

Monitoring 

Plan & other 

General 

Monitoring 

Requirements

§60.63 (f) (i)(1) Submit this site-specific monitoring plan, if requested, at 

least 60 days before the initial performance evaluation of 

your CMS.

Notice to regulators is usually 30 

days before the test and that is the 

point at which the regulator might 

request the plan.

Change to 30 days. If regulator requests plan less than 

30 days prior to the tests, then the test does not need to 

be delayed.

Emissions 

Monitoring 

Plan & other 

General 

Monitoring 

Requirements

§63.1348 (b)(1)(i) “...site specific monitoring plan required by §63.1350 (o).” “(o)” is for alternate monitoring “(o)” should be “(p)”

Emissions 

Monitoring 

Plan & other 

General 

Monitoring 

Requirements

§63.1350 (p)(2) “...must also address (o)(2)(i) through (iii) of this section.” These sections do not exist. “(o)” should be “(p)”
DRAFT

PCA -- NESHAP Monitoring Issues (12-17-10)

Parameter Issue Citation Requirement Issue Recommendation Comments

O&M Plan §63.1347(a) Develop O&M plan and submit for approval with part 70 

permit application

1347(a) - Most, if not all plants 

already have a Title V permit. If 

the Title V permit has already 

been issued or a renewal 

application has already been 

deemed complete, must the OMP 

still be submitted to the 

Administrator for review and 

approval? If approval is required, 

what does the Title V have to do 

with it and by what date must the 

plan be submitted?

Clarify PCA will suggest language.

Performance 

Test Reporting 

& Other 

Reporting

§63.1349(d) All reports must be signed by the "facility's manager" How is "facility manager" 

defined?

Define "facility manager" PCA suggests the same language as 

that under Part 75 for "designated 

representative"

Performance 

Test Reporting 

& Other 

Reporting

§63.1354(b)(9)(vi) Semi-annual reports - (vi) Monthly rolling average mercury, 

THC, PM, and HCl (if applicable) emissions levels in the 

units of the applicable emissions limit for each kiln, clinker 

cooler, and raw material dryer.

Is this an average of the 30-day 

rolling averages calculated each 

day for that month, or is this an 

average of the daily values for the 

30 (or 31) calendar days for the 

month?

Changes to SSM Semi-Annual 

Report formats effective 11/8/10?

Address this with issue of rolling averages for all 

parameters.

PCA will suggest language.

Operating Days §63.1341; 

§63.1343

For 30-day rolling averages, operating days include only 

days of normal operation and do not include periods of 

operation during startup or shutdown. The 30-day period 

means 30 consecutive operating days.

§63.1343(a) – the period of 

“consecutive” operating days 

applies Hg, PM and THC, but for 

HCl it does not reference 

“consecutive” operating days.

HCl should also be subject to “consecutive” operating 

days.

Address this with issue of rolling 

averages for all parameters.

The HCl discussion in 1343(a) makes 

no reference to “consecutive”. Why 

should HCl be computed differently 

than mercury, THC and/or PM?

Operating Days §63.1341; 

§63.1343

For 7-day rolling averages, operating days include only days 

of operation during startup and shutdown and do not include 

periods of normal operation. The 7-day period means 7 

consecutive operating days.

§63.1343(a) – the period of 

“consecutive” operating days 

applies Hg, PM and THC, but for 

HCl it does not reference 

“consecutive” operating days.

HCl should also be subject to “consecutive” operating 

days.

Address this with issue of rolling 

averages for all parameters.

The HCl discussion in 1343(a) makes 

no reference to “consecutive”. Why 

should HCl be computed differently 

than mercury, THC and/or PM?
DRAFT

PCA -- NESHAP Monitoring Issues (12-17-10)

Parameter Issue Citation Requirement Issue Recommendation Comments

NOx - NSPS Compliance §60.64 (c) Calculate and record the 30-operating day rolling emission 

rate of NOx as the total of all hourly emissions data for a 

cement kiln in the preceding 30 days, divided by the total 

tons of clinker produced in that kiln during the same 30-

operating day period using Equation 3.

Refers to a NOx concentration in

gr/scf. Should be “...preceding 

30-operating days....”

Clarify. Equation should be flexible to work with units 

as reported by CEMS.

Gas concentrations should all be ppm 

not mg/m3 except Hg which is 

ug/m3. When fixed it has no impact.

SO2 - NSPS Compliance §60.64 (c) Calculate and record the 30-operating day rolling emission 

rate of SO2 as the total of all hourly emissions data for a 

cement kiln in the preceding 30 days, divided by the total 

tons of clinker produced in that kiln during the same 30-

operating day period using Equation 3.

Refers to a SO2 concentration in 

gr/scf. Should be “...preceding 

30-operating days....”

Clarify. Equation should be flexible to work with units 

as reported by CEMS.

Gas concentrations should all be ppm 

not mg/m3 except Hg which is 

ug/m3. When fixed it has no impact.

Opacity (Other) Other §60.64(b)(4) Any sources other than kilns (including associated alkali 

bypass and cooler) subject to the 10 percent opacity limit 

must follow the appropriate monitoring procedures in § 

63.1350(f), (m)(1) through (4), (m)(10) through (11), (o), 

and (p) of this chapter.

Therefore, any miscellaneous 

source per §60.62(c), which would 

include those located at Area 

Sources constructed, reconstructed 

or modified after Aug. 17, 1971, 

are subject to the requirements in § 

63.1350(f), (m)(1) through (4), 

(m)(10) through (11), (o), and (p). 

Also, when would the complaince 

date be for existing facilities? 

Should only apply to major sources.

§63.1340(b)(6)

§63.1340(b)(7)

§63.1340(b)(8)

Affected sources noted in these subsections can be at ANY 

portland cement plant.

Other sections (e.g., 63.1345) 

exclude these sources at area 

source facilities

Clarify in 63.1340 that these sources are only subject at 

Major source facilities

PCA will provide suggested language

Operating Days §60.62(a); 

§63.1341; 

§63.1343

Operating day means any daily 24-hour period during which 

the kiln operates. Data attributed to an operating day 

includes all valid data obtained during the daily 24-hour 

period and excludes any measurements made when the kiln 

was not operating.

Poorly defined. Does one-minute 

of operation constitute an 

operating day, or does a period 

that results in a valid CEMS data 

value constitute an operating day? 

How is “operate” defined; when

fuel is burning? Startup and 

shutdown are in preamble but not 

defined in the rule.

Redefine PCA will provide suggested language
DRAFT

PCA -- NESHAP Monitoring Issues (12-17-10)

Parameter Issue Citation Requirement Issue Recommendation Comments

§63.1343(a) 1343(a) defines the meaning of 30-day and 7-day rolling 

average as being consecutive for PM, mercury and THC 

only. The section also indicates that an operating day 

includes all valid data obtained during the daily 24-hour 

period and excludes any measurements made when the kiln 

was not operating.

If data are excluded for a period 

that may comprise a day or more, 

how can it be consecutive if we 

must jump from one valid data set 

to the next?

Addition detail must be provided in this section to 

account for prolonged kiln down time.

PCA will provide suggested language

§63.1343(b) Provides emissions limits and emission calculation methods 

for kiln and bypass stacks

Preamble notes "If a coal mill is 

heated with kiln exhaust, it is 

subject to all the emissions limits, 

and all associated monitoring, 

reporting, and recordkeeping 

requirements of this subpart." No 

provision for separately vented inline coal mill in regulations. 

Facilities with in-line coal mills 

vented separately from the main 

stack need to know what, if any, of 

the continuous monitoring 

requirements apply to the coal mill 

stack

Clarify if separately vented inline coal mill emissions 

need to be accounted. If so, main stack monitoring 

should suffice, with the same concentrations as the kiln 

exhaust applied to the in-line coal mill percentage of 

total flow.

Reference Ash Grove alternative 

monitoring request

PM 

(Kiln/Cooler)

§63.1343(b)(2) Alternate PM Limit Only allows adjustment for flow 

from kiln and cooler – what about 

exhaust from coal mill and/or bypass if they go to main stack. An 

issue that came up in our internal 

discussions today. For PM on a 

combined stack, when and how 

often is the alternate PM limit 

determined? Do you use the 

average exhaust flows for the 

same first 30-day CEMS operating 

performance period for the initial 

compliance? Is it conducted and 

changed annually based on the 

average flows measured for the 

RATA?

Allow adjustment for flow from all sources to the main 

stack.

PCA will work on developing 

proposed alternative language.

Current language establishes a 

different standard for each kiln based 

on site specific clinker factor and air 

flow.
DRAFT

PCA -- NESHAP Monitoring Issues (12-17-10)

Parameter Issue Citation Requirement Issue Recommendation Comments

HCl Other §63.1343 Table 1 

Footnote 4

If the kiln does not have a HCl CEM, the emissions limit is 

zero. 

This implies that if you have a wet 

scrubber and therefore do not need 

an HCl CEMS that your limit is 

zero – but you still have to prove 

compliance every 30-months by 

Method 321, and there will be 

some HCl in the emissions. Also 

note that the footnote only applies 

to #4 – existing kiln startup and 

shutdown, and #6 – new kiln 

normal operation.

Cannot have an emission limit of “zero”. Limit should 

also be 3 ppmvd. Also applying to S/S at an existing 

kiln but normal operation at a new kiln is arbitrary.

The Footnote of 1343 (b) Table 1 

states that emissions limit for HCl 

from major source kilns is ZERO in 

some cases, but not all. Existing 

kilns under normal operations and 

new kilns during S/S are not 

footnoted.

§63.1348(a)(3)

§63.1346(c), (d) 

& (e)

(iii) If activated carbon injection is used and you are subject 

to a D/F emission limitation under §63.1343(b), you must 

demonstrate initial compliance with the activated carbon 

injection rate operating limits specified in §63.1344 by using 

the performance test methods and procedures in 

§63.1349(b)(3)(v). The average of the run injection rates will 

determine the applicable injection rate limit.

Although the definition "sorbent" 

broadly applies to ACI used to 

control any HAPs, 1348(a)(3) only 

indicates operating limits for ACI 

usage only apply if ACI is used for 

D/F compliance. Need to clarify if 

ACI injection monitoring and 

limits only apply to D/F control 

strategies versus if ACI were used 

for THC or Hg compliance.

Clarify if ACI monitoring and injection rates only 

apply if ACI is necessary for D/F control.

Verify EPA intent and consider 

language changes that would help 

clarify that intent.

§63.1346(f) Fly ash cannot be used in a cement kiln if it was from a 

process that used activated carbon to control Hg emissions, 

unless it can be shown that its use will not increase Hg 

emissions from the kiln. Once the kiln must comply with a 

mercury limit specified in § 63.1343, this paragraph no 

longer applies.

The last sentence of this section 

implies that this paragraph 

becomes effective on 11/8/10 and 

is no longer applicable after 

9/9/13.

Need to confirm compliance dates and for portions of 

this citation.

This should be in technical correction 

of compliance dates.

§63.1348(a)(6) HCl demonstration of initial compliance Section only considers compliance 

using wet scrubbers and tray 

towers. No consideration for 

compliance via dry sorbent

injection.

Include initial compliance measures for alternative 

control techniques.

Was mentioned in the reconsideration 

supplemental list. PCA will develop 

proposed alternative language.

§63.1348(a)(6)(ii) If a source does not have a wet scrubber or tray tower, initial 

HCl compliance must be demonstrated using CEMS

Would using a dry scrubber also 

exempt the source from the HCl 

CEM requirement?

If so, rule should be appropriately revised to specify 

this.

Was mentioned in the reconsideration 

supplemental list. PCA will develop 

proposed alternative language.
DRAFT

PCA -- NESHAP Monitoring Issues (12-17-10)

Parameter Issue Citation Requirement Issue Recommendation Comments

§63.1348(b)(1)(ii) (ii) Except for periods of monitoring system malfunctions, 

repairs associated with monitoring system malfunctions, and 

required monitoring system quality assurance or quality 

control activities (including, as applicable, calibration checks 

and required zero and span adjustments), you must operate 

the monitoring system and collect data at all required 

intervals at all times the affected source is operating. Any 

period for which data collection is required and the 

operation of the CEMS is not otherwise exempt and for 

which the monitoring system is out-of-control and data are 

not available for required calculations constitutes a 

deviation from the monitoring requirements.

Any quantity of missing data is an 

automatic deviation under the 

Clean Air Act. The term deviation 

is too stringent for minor 

occurrences of monitoring missing 

data.

PCA will develop proposed 

alternative language.

§63.1349(d) (d) Clinker Production Monitoring Requirements. If you are 

subject to an emissions limitation on particulate matter, 

mercury, NOx, or SO2 emissions (lb/ton of clinker), you 

must:

It does not seem appropriate for a 

MACT requirement to be triggered 

by NOx and SO2 limitations.

Request applicability for clinker production monitoring 

to not be triggered by NOx and SO2 limits.

PCA will propose removal of NOx 

and Sox reference

EPA's Policy 

Memo; May 16, 

1995

facilities may switch to area source status at anytime until 

the "first compliance date" of the standard.

It is not clear whether the existing 

major sources can opt in as area 

sources of if once-in, always-in 

applies to the kilns.

Request clarification for once-in, always-in Seek insight from EPA and PCA will 

provide suggested language.

Clinker 

Production 

Monitoring 

Requirements

§60.63 (b)(2); 

§63.1350(d)(2)

Determine, record and maintain an accuracy of the system 

for clinker or kiln feed within 30 days of the effective date of 

this rule (for existing sources). During each quarter 

determine, record and maintain ongoing accuracy.

Why must this be done within 30 

days of the effective date of the 

rule if we do not have to comply 

with a clinker based emission limit 

for 3 years?

Should not be applicable until 3 years. 1350(d) - Is raw feed monitoring 

really due by 12/8/10? Or, is it really 

just that we only have to "Determine, 

record, and maintain a record of the 

accuracy of the system of measuring 

hourly clinker production " as 

literally written? This would not 

impose the +/-5% accuracy 

provisions of the previous paragraph 

until 9/9/2013.
DRAFT

PCA -- NESHAP Monitoring Issues (12-17-10)

Parameter Issue Citation Requirement Issue Recommendation Comments

§63.1345 Emissions limits for affected sources other than kilns; inline kiln/raw mills; clinker coolers; new and 

reconstructed raw material dryers; and raw and finish 

mills, and open clinker piles.

The owner or operator of each new or existing raw material, 

clinker, or finished product storage bin; conveying system 

transfer point; bagging system; and bulk loading or 

unloading system; and each existing raw material dryer, at a 

facility which is a major source subject to the provisions of 

this subpart must not cause to be discharged any gases from 

these affected sources which exhibit opacity in excess of ten 

percent.

Crushers are obviously not subject 

to the Subpart per 1340(c). 

However, it is not obvious whether 

other sources associated with raw 

material handling and storage 

including screen, material transfer 

points, etc. are included or not.

Clarify when OOO ends and LLL begins PCA will develop proposed 

alternative language.

63.1348(a)(1), (4), 

(5) and (6)

Initial compliance with the respective standard must be 

demonstrated based on "the first 30 operating days" of CEM 

operation

1) The requirement implies that 

the initial compliance 

demonstration can preceed the 

Complaince Date if the facility 

installs and certifies the CEM 

prior to that date.. 2) The 

requirement does not make 

provisions for the occurrence of 

SU/SD events within the first 30 

days of CEM operation.

The regulations should be revised to state that initial 

compliance is not required to be demonstrated before 

the Compliance date. The regulation shouild be 

revised to reflect that the initial compliance 

demonstration should exclude SU/SD operating days 

PCA will develop proposed 

alternative language.

63.1343(b)(2?) Aternate PM limit for combined kiln/cooler emissions. 1) The prescribed formula relies 

on flow rate weighting per ton of 

"raw feed", but fails to define raw 

feed How is this to be 

determined? 2)The basis for flow 

determination is also not defined. 

It is unclear as to how the facilityspecific PM limit is to be applied 

(i.e.. on a flow capacity basis or on 

an actual flow basis). 

Clarify the term "raw feed" and clairfy that the limit is 

to be detyermined on a flow capacity basis.

PCA will develop proposed 

alternative language.
DRAFT

PCA -- NESHAP Monitoring Issues (12-17-10)

Parameter Issue Citation Requirement Issue Recommendation Comments

63.1350(d)(3) "Record the daily clinker production rates and kiln feed 

rates."

Facilities that choose to monitor 

clinker production directly do not 

need to, and should not be 

required to, monitor and record 

kiln feed rates.

Clarify that moniytoring/recording of kiln feed rates is 

not required if clinker production is directly measured.

PCA will develop proposed 

alternative language.

63.1350(k)(1) The span value of the Hg CEM "must include the intended 

upper limit" of the mercury concentration measurement 

range.

The term "intended limit" is so 

vague as to be impossible to 

determine what is needed to 

comply.

The regulation should be revised with a more definitive 

requirement for the upper limit and one that the 

regulated entity can plan for in acquiring commercially 

available equipment.

PCA will develop proposed 

alternative language.

63.1350(l) Must comply with (m)(1) through (m)(4) The regulation at (m)(3) requires 

the determination (and presumably 

recording) of 3-hour block 

averages. Since the limit is on a 

30-day RA basis, why are 3-hour 

blocks needed?

Eliminate the requirement for 3-hr block averages.

63.1349(b)(6) The HCl PT requirements include collecting stack gas 

volumetric flow rate data.

The HCl standard is a ppm-based 

standard and does not rely on stack 

flow. The requirement to collect 

flow data is superfluous.

Elimiate the requirement for flow data.

63.1350(g) Each hour, calculate "the three-hour" average temperature This revised requirement 

changesw the monitoring basis of 

the APCD temperature from a 

180-minute RA to a 3-hour hourly 

RA. It is unclear whether this 

revision will require a new 

"initial" performance test.

Revert back to the use of 180-minute RA or clarify that 

this change does not require a new inital PT.

63.1357 Temporary exemption from PM and opacity standards for 

purposes of PM-CEM correlation testing.

EPA failed to extend this 

exemption to clinker coolers. 

Since these will now also require 

PM-CEMS, they need to be 

provided a similar exemption.

Revise the requirement to accomodate coolers. PCA will develop proposed 

alternative language.