## PCA - NESHAP Monitoring Issues Version 12-9-2010

**Citation Requirement**  **Issue Recommendation**  **Comments**

§63.1348(a)(1); §63.1349(b)(1) Use first 30 operating day s 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 theyapply to cement plants. See L afarge settlement terms for 30-day sum of PM Mass readings divided by

30 day s of clinker production.

Additional question on the issue: Throughout this section, the phrase “must be determined based on the first 30 operating day s y ou 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 day s of operation?

§63.1349(b)(1)(iii) and (iv) Discusses initial compliance based on first 30-day s

of CEMS; requires an emission rate computed for each run based on concentrations in gr/scf. In cludes equations for stack emissions and for stack+by pass 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+by pass 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 Inorder 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 y ears; §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 elevatedemissions 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 y ou have a reading every 15 minutes if the clinker rate is calculated hourly ? Or do
yo u take the mass of PM each 15 minutes and add together then divide by the hourly

clinker production? Or is it actually 30-day s worth Need to address the averaging methodologyfor

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 day s of mass emissions over the summed 30 day s of clinker See L afarge settlement terms for 30-day sum of PM Mass readings divided by

30 day s 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-day s worth of summed PM mass readings divided by30- day s 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 day s 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) 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 §60.64(b)(1) 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 concentrations in gr/scf and with no reference to 30 day s. 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

1

## PCA - NESHAP Monitoring Issues Version 12-9-2010

**Citation Requirement**  **Issue Recommendation**  **Comments**

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 sy stems 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 sy stems 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. I f VEs observed retest w/in 24 hours. I f 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 BL D in lieu of daily VEs which are for RM and FM.

§63.1350(f) In dicates 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) In dicates 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"? Itshould be "each minute" to preserve the current methodology for D/F.

hour rolling average begins anew when mill goes up or down.

2

## PCA - NESHAP Monitoring Issues Version 12-9-2010

**Citation Requirement**  **Issue Recommendation**  **Comments**

§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 day s 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. Alway s used PS8A and 100 ppm span for cement plants burning hazardous waste.

PS-8.

§63.1350(i)(2) For alkali by pass 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. FTI R, 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 analy tes that are present at concentrations exceeding one-half the quantitation limit of the analy tical method are to be used in the sum. I f any of the analy

tes are not detected or are detected at concentrations less than one-half the quantitation limit of the analy

tical method, the concentration of those analy

tes 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
sy stem. 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 analy

tes will be assumed to be zero for the purposes of calculating the total organic HAP for this subpart.

3

## PCA - NESHAP Monitoring Issues Version 12-9-2010

**Citation Requirement**  **Issue Recommendation**  **Comments**

§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 FI D to FI D is arbitrary . I f both the installed and test FI Ds 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 day s 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 day s y ou 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 day s 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
sy stem 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
sy stems 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 day s for startup/shutdown (e.g., 30 day s) and greater than 30-day s for normal operation (e.g., 90 day s). Assuming a sorbent trap can operate for a period of 7 day s (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 sy stem 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 sy stem. 30-day s for normal operation (e.g., 90 day s). more opportunity to adjust the sy

4

## PCA - NESHAP Monitoring Issues Version 12-9-2010

**Citation Requirement**  **Issue Recommendation**  **Comments**

§63.1348(a)(6)(i); §63.1349(b)(6)(i) Wet scrubber. Method 321 and establish operating

parameters. I nitial compliance is the arithmetic average of all runs. Repeat every 30 months. EPA has specified a “ty pical 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 "ty pical 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 day s 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 CI SWIMACT the EPA stated: "Although final performance specifications are not y et available for HCl CEMS and multi-metals CEMS, EPA is considering development of performance specifications." EPA has proposed PS-13 at the levels required to demonstrate compliance with the standards.

No NI ST Traceable cal gas.

PS-15 is not adequate, EPA acknowledges in Response to Comments that an HCl-specific PS is needed. Need NI ST 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 Hy drochloric Acid Continuous Monitoring Sy stems 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 analy tical techniques. Argue against EPA's assertion that such CEMs are available. Get statements from reputable CEMS manufacturers. Note in the Proposed CI SWIMACT the EPA stated: "Although final performance specifications are not y et 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 Hy drochloric Acid Continuous Monitoring Sy stems 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.

5

## PCA - NESHAP Monitoring Issues Version 12-9-2010

**Citation Requirement**  **Issue Recommendation**  **Comments**

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

yo u of approval or denial within 90 day s.....Neither submittal of the application or the Administrator’s failure to approve or disapprove the application relieves y ou of the responsibility to comply

with
any provision... Even if y ou 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 REQUI RE 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 day s before the initial Notice to regulators is usually 30 day s before the test and that is the point at which the Change to 30 day s. I f regulator requests plan less than 30 day s prior to the tests, then the test requested, at least 60 day s before the initial performance evaluation of y our CMS. the test and that is the point at which the regulator might request the plan. less than 30 day s prior to the tests, then the test does not need to be delay ed.

§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. I f 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? I f 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.

6

## PCA - NESHAP Monitoring Issues Version 12-9-2010

**Citation Requirement**  **Issue Recommendation**  **Comments**

§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 dry er. 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 day s 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 day s include only day s of normal operation and do not include periods of operation during startup or shutdown. The 30-day

period means 30 consecutive operating day s. §63.1343(a) – the period of “consecutive” operating day s applies Hg, PM and THC, but for HCl it does not reference “consecutive” operating day s. HCl should also be subject to “consecutive” operating day s. 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 For 7-day rolling averages, operating day 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. §63.1341; §63.1343 For 7-day rolling averages, operating day s include only day s of operation during startup and shutdown and do not include periods of normal operation. The 7-day

period means 7 consecutive operating day s. §63.1343(a) – the period of “consecutive” operating day s applies Hg, PM and THC, but for HCl it does not reference “consecutive” operating day s. HCl should also be subject to “consecutive” operating day s. 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 day s....” 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 day s, divided by

the total tons of clinker produced in that kiln during the same 30-operating day period using Equation 3. day s....”

§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 day s, 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 day s....” 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.

7