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Summary of EPA–PCA Discussion on NESHAP Reconsideration

December 1, 2011

EPA Participants:

• Keith Barnett, OAQPS

• Sharon Nizich, OAQPS

• Peter Westlin, OAQPS

• Mike Laney, RTI

• Matt Hakos, RTI

PCA Participants:

• Curtis Lesslie, Ash Grove

• Jason Morin, Holcim

• Andy O’Hare, PCA

• Mike Pelan, Lafarge

• Adam Swercheck, Buzzi Unicem

• Satish Sheth, CEMEX

• Hector Ybanez, Holcim

1. Clinker Piles 

EPA is planning to drop the clinker pile design and management requirements in lieu of imposing 

work practice standards, similar to those employed for coal piles under NSPS Subpart Y.

STATUS: EPA is still on track to replace the design and management standards with a menu of 

work practices similar to those under Subpart Y for coal piles, but selected on a site-specific basis. 

EPA also plans to propose something very similar to the PCA proposed definition of “open clinker 

piles”: unenclosed outdoor accumulations of clinker of more than 50,000 tons in place for more 

than six months. Lastly, there was a back and forth regarding implementation of the work 

practice standards. PCA expressed a desire for them to be self implementing as with similar 

obligations already outlined in Title V permits, in lieu of having to have the site-specific practices 

themselves approved by a permitting authority.

2. Modifications to the Total Hydrocarbon Standard

EPA plans to propose to allow facilities to correlate their THC compliance value with the 9 ppmv 

organic HAP alternative limit. 

STATUS: EPA still plans to propose to allow facilities to scale up their site-specific THC standard to 

be equivalent to a 9 ppm oHAP limit.

3. HCl, PM and Mercury Monitoring During Start-up and Shutdown (previously two separate 

issues)
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EPA is planning to drop the emission standards for start-up and shutdown and replace them with

work practice standards.

STATUS: EPA is still proposing to drop the emission standards during start up and shutdown and 

to replace them with work practice standards. There was a brief discussion regarding the type of 

work practices that EPA has in mind, and PCA was encouraged to review the anticipated boiler 

NESHAP proposal to see where EPA was headed. Lastly, there was a discussion regarding the 

definitions of startup and shutdown. EPA plans to propose that startup begins when the kiln ID 

fan is running and the kiln is combusting fuel. Startup ends once feed is fed to the kiln. 

Shutdown begins when feed is no longer fed to the kiln. 

4. HCl Continuous Emission Monitors Associated with Dry Scrubbers

EPA plans to propose that facilities equipped with dry scrubbers do NOT have to continuously 

monitor HCl emissions. 

STATUS: EPA still plans to propose to drop the HCl continuous emission monitor obligation for 

those kilns using dry scrubbers. The Agency also suggested that they may require facilities using 

dry scrubbers to use SO2 emissions as a surrogate for HCl compliance. PCA explained at length

why this is a bad idea, explaining that SO2 emissions are not tied to HCl emissions even though 

both may be controlled in varying degrees by dry (and wet) scrubbing. PCA suggested that a 

parameter, such as lime injection molar ratios, may be used instead of a relationship with SO2

emissions. PCA agreed to provide more specific details on the molar ratio concept. Lastly, PCA 

expressed general concern about the use of continuous HCl monitors, explaining that the 

performance specification for the devices is not final. PCA suggested that EPA consider dropping 

this continuous monitoring obligation all together. 

5. Alternative Particulate Matter (PM) Equation

EPA plans to propose the PCA recommended expanded alternative PM equation, allowing for sitespecific consideration of various commingled sources, including clinker coolers, coal mills when 

computing a site-specific PM emission limit.

STATUS: EPA plans to propose the alternative PM equation suggested by PCA, or something very 

similar. 

6. Regulatory Status of Various Coal Mill Configurations

EPA plans to propose that coal mills with separate stacks which receive cooler air or kiln gases be 

regulated under NSPS Subpart Y. Facilities with “in-line” coal mills (those that use kiln gases and 

then route them back to the kiln stack from the coal mill) will be regulated under Subpart LLL. 

STATUS: There was an extended discussion regarding the three categories of coal mills that have 

been under discussion, with EPA confirming that the first category (coal mills receiving cooler air 

with separate stack) would be under Subpart Y. EPA also confirmed that the “in-line” coal mills 

would be under Subpart LLL. The discussion focused primarily on those coal mills that receive kiln 
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gases that vent through a separate coal mill stack. At issue, was how to account for mercury, and 

to a lesser extent, total hydrocarbons, present in the kilns gases used by the coal mill. PCA 

suggested, and EPA agreed, that mercury emissions from coal mills are likely to be very minimal 

because of the low temperatures in the mills and the mercury scrubbing effect of the mill. PCA 

suggested that the mercury concern may be satisfactorily addressed by conducting an initial and 

subsequent confirming performance test (no more often than every 30 months (with 60 month

intervals being preferable) of the mercury emissions coming from the coal mill stack. No 

continuous mercury monitoring would be necessary. 

7. PM Limit for Modified Sources Under the NSPS

EPA plans to propose that the PM emission standard for modified NSPS sources be the same as the 

existing source NESHAP PM standard. 

STATUS: EPA will propose a PM emission standard for modified NSPS sources of 0.04 lbs/ton of 

clinker to replace the 0.01 lbs/ton of clinker standard in the September 2010 rule.

Lastly, there was also a discussion regarding the EPA electronic reporting tool, which requires 

sources to report by December 2011 on certain performance/compliance test information. EPA 

clarified that the reporting obligation applies only to new requirements, not existing 

requirements. So, PCA members will not be required to report on testing associated with 

compliance with the recent NESHAP changes until after the compliance date. Update from this 

meeting: sources must report to ERT 60 days after a performance test, if a performance test is 

done past December 31, 2011. Thus, the submittal is not tied into the compliance date of 2013, 

but rather is tied into the actual date of the performance test, even if the test has been 

performed before the compliance date.