e LEAGUE OF WOMEN VOTERS 

O F TEXAS 

1212 Guadalupe St., Suite 107 • Austin, TX 78701-1800 

(512) 472-1100 • Fax (512) 472-4114 • lwvtexas@lwvtexas.org 

August 16, 2012 

EPA 

Docket Center ( 61 02T) 

National Emission Standards for 

Hazardous Air Pollutant From the Portland Cement Manufacturing Industry Docket 

Docket ID No. EPA-HQ-OAR-20 11-0817 

1200 Pennsylvania Ave., NW 

Washington, DC 20460 

On behalf of the League of Women Voters of Texas and the League of Women Voters of 

the United States, we want to thank you for holding this hearing in Arlington, Texas. 

Unfortunately, we must express our disappointment for EPA's proposal to dilute the 

previously proposed regulations to reduce and better monitor the emissions of the 

Portland cement manufacturing industry. Texas has 11 of the 93 cement manufacturing 

facilities in the U.S. While the 93 facilities average less than two kilns per facility, many 

of the facilities in Texas have a number of kilns, including the largest, TXl in Midlothian, 

with five kilns. Of the 11 cement manufacturing facilities in Texas, eight are arrayed 

along the limestone deposits of the Interstate 35 corridor between Dallas-Fort Worth to 

the North and San Antonio to the South. This area had a 2010 population of almost 11 

million, representing over 43 percent of the Texas population. So the impacts of the 

cement kiln emissions affect a large population. 

Our specific comments are as follows: 

Compliance deadline. We support implementation in 2013 as originally proposed. 

Delaying implementation of stricter emission standards until September 2015 would keep 

our air dirtier and embolden the industry to continue its efforts to defeat even these 

watered-down standards. 

Mercury continuous emission monitors CCEMS). We continue to support CEMS for 

mercury emissions because we understand that when EPA monitored mercury emissions 

at select cement plants, their emission readings were significantly higher than the 

formula-based, self-reported numbers currently used to report emissions. Actual mercury 

emission data are needed to ascertain the probable impact of emissions on the 

surrounding watersheds. We also support CEMS for monitoring other emissions because 

without accurate monitoring, it is difficult to determine compliance with emission 

standards. 
Emission Standards for Startup, Shutdown, and Malfunction. We support emission 

standards for startup, shutdown, and malfunction equal to normal operating conditions. 

We do not support industry monitoring of startups and shutdowns via recordkeeping. as 

the new regulations propose. 

Standards for Mercury, Hydrogen Chloride, and Total Hydrocarbons (THCs). We 

support keeping the emission standards for these pollutants at their current proposed 

levels. 

Particulate Matter (PM - We are concerned about the new particulate matter emission 

standards given the negative health impacts of this form of air pollution. 

Midlothian, Texas, in the Dallas-Fort Worth Consolidated Metropolitan Area (CMSA), 

has the largest concentration of cement plants in the U.S. The Midlothian cement kilns 

are also the largest stationary source of air pollution in the Dallas-Fort Worth (CMSA). 

Thus the previously proposed emission standards would greatly enhance the region's 

ability to meet air quality standards. 

Thank you for the opportunity to comment on these proposed regulations. Please 

reconsider the dilution of the previously approved rules, which had the potential to 

greatly enhance the air and water quality in Texas and the nation. 

Sincerely, 

Linda Krefting, President 

League of Women Voters ofTexas 

Elisabeth MacNamara, President 

League of Women Voters ofUnited States