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§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?

§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 

Clarify PCA will provide suggested language

stack+bypass emissions. 15 minutes. Then hourly data to be summed 

to daily data and then averaged into a 30-day

rolling average.

§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

In order to range the PM CEMS for 

correlations the facility must operate short 

term above the PM limit by intentionally

Expand §63.1357 · These periods should not be 

included in the compliance determination. · EPA 

should explicitly state that it is acceptable to 

Partially covered in existing §63.1357 “Temporary, conditioned 

exemption from particulate matter and opacity standards”

§63.1350(b) Method 5 or 5i; Relative Response Audits annually

and Response Correlation Audits every 3 years; 

§60.63 (f) also references PS-2

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.

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.

§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-day rolling average. 

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 is it actually 30-days worth 

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 

See Lafarge settlement terms for 30-day sum of PM Mass readings 

divided by 30 days of clinker 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.”

production? Or 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-day rolling average.

emissions over the summed 30 days of clinker 

production. Also address issue of PS-2 vs. PS-6. 

Also see reporting requirements near bottom of 

this table.

§60.64(b)(1) §60.64(b)(1) Compliance based on §60.63(c) (i.e., CEMS 30-day Compliance based on §60.63(c) (i.e., CEMS 30-day Discusses compliance based on a CEMS 30- Clarify. PS 11 requires evaluating performance PCA will provide suggested language

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 concentrations in gr/scf 

and with no reference to 30 days.

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 suggested language

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PS-11 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 that EPA has not 

adequately investigated these issues at the 

variety of kiln systems and plant 

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 nonrepresentative.

PCA will provide suggested language

variety of kiln systems and plant 

configurations where PM CEMS will be 

required.

§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

§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 

§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.

hour if >10% §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.

§63.1350(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.

per §63.1350(o) O&M plan it is an emissions monitoring plan.

§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.

§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.

and (vi)

§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 

one-minute 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 

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.

hour rolling average begins anew when mill 

goes up or down.

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§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

§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.

PS-8.

§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

§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 

Method 320 quantitation limits > 9 ppm. 

§63.1352 allows the alternate use of Method 

18 “solely for use in applicability

Allow alternate methods for compliance. The 

HAPs concentrations should be for the weighted 

average for mill-on and mill-off values. Define 

What exactly is a weighted THC average for Mill on/Mill off?

Seek EPA insight and PCA will provide suggested language.

§63.1349(b)(4)(ii) 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.

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".

average for mill-on and mill-off values. Define 

how "weighted average" is calculated.

§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 

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.

those analytes will be assumed to be zero for the 

purposes of calculating the total organic HAP for 

this subpart.

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§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 PS-8A, 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.

§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.

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 

How does the facility utilize a sorbent trap 

system and demonstrate compliance with two 

different emissions standards over two 

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 

(startup/shutdown). different operating modes/periods? 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.

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 

30-days for normal operation (e.g., 90 days). more opportunity more opportunity to adjust the sy to adjust the system.

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§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

the sampling train/PM filter.

§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 

EPA should provide documentation on HCl 

CEMS capable of meeting these requirements.

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 

at the levels required to demonstrate performance specifications." EPA has proposed PS-13 

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.

Need NIST traceable cal gas.

EPA should stay this requirement until HClspecific PS is developed.

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.

§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.

§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 

Method 320 for HCl should not be allowed.

use in applicability determinations” per §63.1340 measurement of HCl especially at low 

concentrations, does not address the 

necessary considerations contained in Method 

321

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

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§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.

§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.

§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?

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

requested, at least 60 days before the initial 

Notice to regulators is usually 30 days before 

the test and that is the point at which the 

Change to 30 days. If regulator requests plan 

requested, at least 60 days before the initial less than 30 days prior to the tests, then the test 

performance evaluation of your CMS.

the test and that is the point at which the 

regulator might request the plan.

less than 30 days prior to the tests, then the test 

does not need to be delayed.

§63.1348 (b)(1)(i) “...site specific monitoring plan required by

§63.1350 (o).”

“(o)” is for alternate monitoring “(o)” should be “(p)”

§63.1350 (p)(2) “...must also address (o)(2)(i) through (iii) of this 

section.”

These sections do not exist. “(o)” should be “(p)”

§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.

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§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"

§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.

§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?

§63.1341; §63.1343 §63.1341; §63.1343 For 7-day For 7-day rolling averages, operating day rolling averages, operating days include s include §63.1343(a) – the period of “consecutive” HCl should also be subject to “consecutive” Address this with issue of rolling averages for all parameters.

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?

§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 

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.

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.

days....”

§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.

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