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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 thos e 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 pl an**  **s to propose**  **something very similar to the PCA**  **proposed definition of “open clinker**  **piles”: unenclosed outdoor accumulation s of clinker**  **of more than 50,000 tons in place for more than six months. Lastly, there was a back and forth regarding implementati**  **on 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)2

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 runni ng 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 d ry 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 usi**  **ng 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) scr**  **ubbing. 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 th**  **e 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 site

specific consideration of various commingled sources, including clinker coolers, coal mills when computing a site

- specific PM emission limit. **STATUS: EPA plans to pro pose 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 co al 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 discuss ion focused primarily on those coal mills that receive kiln** 3

**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**  **su ggested, 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 necessa ry.**  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 sou rces 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 perfo**  **rmance/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 chang es 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.**