The Cement Industry Can Meet These Standards 

A lot, if not most, of what you'll hear from industry are their complaints that 

these new rules establish emission standards that are not achievable with 

current technology. 

But that's not true. Every piece of pollution control equipment they need to 

comply with these rules is being used with great effectiveness on a cement 

plant in the US right now. 

For example, wet scrubbers to reduce Hydrochloric Acid and Sulfur Dioxide 

have been used successfully for years now in Midlothian. Why were 

scrubbers necessary so early here in Texas? 

It wasn't because industry thought it was a good idea. It was because EPA 

told Holcim in 1989 that without them on its new cement plant, the 

Midlothian area would likely violate the Clean Air Act for too much Sulfur 

Dioxide pollution. There were already too many cement kilns operating 

without scrubbers and another one would put the area over the line. 

Regardless of how they got here, they've worked to reduce both 

Hydrochloric Acid and SOx significantly from the 3 dry kilns that use them. 

Unfortunately, there are seven other wet kilns, built from 1960 to 1975 that 

do not have them, even now. One of the most valuable pieces of air pollution 

control equipment these rules could require is installation of wet scrubbers -

a standard piece of operating equipment in every other heavy industry but 

still a novelty in the cement industry. 

TXI''s Kiln #5 and both Holcin1 kilns in Midlothian have advanced 

baghouses for the capture of Particulate Matter, an insidious and dangerous 

pollutant. But the same seven older \Vet kilns that lack scrubbers, also lack 

this pollution control device. They still rely on the same kind of equip1nent 

they \Vere using in the 1970's \vhen PM control \Vas first being discussedElectro-Static-Precipitators. They're much less efficient and protective than 

n1icro filtered baghouses. Because of the amount of dust and soot generated 

by 1 0 kilns in a sn1all area, advanced baghouses should be required on all 

DF\\1 kilns, 

TXI's Kiln #5 also has had a Regenerative Thermal Oxidizer up and running 

since 2000, \Vhich controls the en1issions of Total I-Iydrocarbons. It acts as 

an afterburner for the 'l olatiles in the TXI exhaust. Reducing THC \vill help 

reduce our red ozone days. 

In Oregon, the cornpleted testing and installation of a Carbon i\bsorption 

unit for ~1crcury pollution at an Ash Grove cc1nent p!ant has dc1nonstrated it 

can be up to 900r cffccti ve in reinoving ~1ercury frorn the exhaust strcarn. I 
am submitting an article about this unit into the record. 

Because we have the largest concentration of cement manufacturing 

facilities in the US, we should also have the best cement making technology 

in the US. That technology is available and ready to be adapted to the entire 

US cement industry. 

The EPA's cost analysis proves the public health benefits far outweigh the 

cost to industry for upgrading their equipment. 

I want to thank you for proposing these excellent rules, urge you to 

withstand the industry's opposition and adopt them in final form. 

Rebecca A. Bornhorst 

1405 Indian Creek Drive 

DeSoto, TX 75115 

becky. bomhorst@ gmail.com