Subject: Meeting with Portland Cement Association and Affiliates

Location: U.S. Environmental Protection Agency, Research Triangle Park, NC

Date: November 7, 2012

Participants:

Portland Cement Association (PCA)

Andy O’Hare, PCA

Curtis Lesslie, Ash Grove

Jason Morin, Holcim 

Tim Matz, Lehigh Hanson

Dan Nugent, Buzzi Unicem

Michael Pelan, LaFarge

Satish Sheth, CEMEX

John Holmes, AEMS Inc.

Brent Wilkerson, Monarch (by telephone)

U.S. Environmental Protection Agency (EPA)

Sharon Nizich

Stef Johnson

Peter Tsirigotis

Steven Fruh

Steven Silverman (by telephone)

RTI International

Matt Hakos

The purpose of the meeting was to discuss specific issues raised by the cement industry in their 

comments on the July 18, 2012 proposed amendments to the portland cement NESHAP and 

NSPS. A summary of the technical content of the meeting is provided below. 

Start-up/Shutdown Definitions/Work Practices – PCA reiterated their position that testing and 

monitoring of numerical emission standards is impracticable during start-up and shut down. 

PCA also indicated that the proposed theoretical emissions calculation methodology is 

impractical and opens the door for citizen suits against the cement industry. PCA also stressed 

that applying the current numerical operating limits to start-up and shut down is illogical, as no 

testing has been done to support that these limits are achievable or appropriate during start-up 

and shut down. Furthermore, emissions cannot be tested during start-up and shutdown, as no 

EPA testing methodologies currently exist for start-up and shutdown.

PCA stated that the current definitions for start-up and shutdown need to be revised to include 

when the periods of start-up and shutdown end. Suggested revisions were provided (see

attachment).

PCA also provided suggested work practices for start-up and shutdown (see attachment).

THC/o-HAP and PM – PCA discussed their support for allowing scaling of the THC/o-HAP 

and PM equations and explained how not allowing scaling would disproportionally penalize the 

best performers by requiring frequent retesting even though the sources were still in compliance.

PCA provided suggested methodologies for scaling (see attachment).
Clinker Pile Definition – PCA conveyed the importance of having a specific clinker pile

definition in the rule. PCA is concerned that without a definition, miniscule buildup/piles of 

clinker would be subject to work practice standards and enforcement. PCA did not provide any 

further information to support why their suggested definition of a clinker pile (outlined in PCA 

comments) is comprehensive and representative of the industry.

Coal Mill Recommendations – PCA demonstrated the difficulties of a one size fits all 

regulation for diverted kiln gas to coal mills, as actual coal mill configurations vary significantly 

in the industry (see attachment). In order to account for this variability PCA feels that significant 

revisions to the rule are required. In lieu of specific provision for coal mills, PCA indicated that 

it supports monitoring diverted kiln exhaust prior to any secondary-use and adding it to the main 

kiln stack values. 

Coordination of Compliance Testing – PCA stated that the current overlapping compliance 

schedule for all testing is burdensome. PCA suggested that all compliance testing be coordinated 

on a 30 month schedule.

HCl CEMS – PCA outlined the impracticalities of requiring HCl CEMS while PS-15 cannot be 

used for certification on the majority of HCl CEMS due to calibration gas issues. PCA requested 

that the requirement for HCl CEMS be deferred until such a time that PS-18 is promulgated. 

During the deferral period, PCA suggested that stack testing should be used for compliance 

demonstration. 
Attachment 1: PCA Meeting Agenda and Supporting Data
2

EPA – PCA Meeting

November 7, 2012

RTP, NC 

1:00–3:00 p.m., EST

Tentative Agenda

Conference Call Number: (888) 387-8686, then 4089494

1:00 I. Introductions

1:05 II. Start-up/Shutdown Definitions/Work Practices 

• Testing and Monitoring Difficulties

• Concerns with Citizens Suits

1:30 III. THC/o-HAP and PM Equations

1:45 IV. Clinker Pile Definition

2:00 V. Coal Mill Recommendations

2:20 VI. Coordination of Compliance Testing 

2:30 VII. Other Issues

2:45 VIII. Next Steps

3:00 IX. Adjourn
3

Start-up/Shutdown

Definitions:

“Start-up period Commences: when both the ID fan draft is running and fuel combustion 

is present in the main burner of the kiln.

Startup period Ends: when feed has been fed continuously to the kiln for a period of at 

least 120 minutes OR when the kiln feed rate exceeds 60 percent of the kiln design 

limitation rate. 

Shutdown period Commences: when the kiln feeder is shut off.”

“Shutdown period Ends when continuous kiln rotation ceases.”

Work Practices:

Start-up: As a general matter, operators will focus on employing 

good combustion practices for the purpose of minimizing emissions 

during these periods. Accordingly, the air pollution control device will be 

turned on and operating before any fuels are combusted. Once the air 

pollution control device is running, start up fuel (generally natural gas or 

fuel oil) will be combusted to bring the kiln gradually up to approximately 

1200-1300°F. Combustion of primary fuel (generally coal or petroleum 

coke) will then begin and small amounts of kiln feed may be introduced 

into the kiln concurrently. Start-up concludes when feed has been 

continuously fed to the kiln for at least 120 minutes or when the kiln feed 

rate exceeds sixty percent of the kiln design rate. Oxygen concentrations, 

feed input and the temperature profile in the kiln system will be 

monitored during start-up as a means of ensuring good combustion. The 

type and duration of each start-up will be recorded. 

Shutdown: Shutdown will commence once the feed to the kiln is 

turned off. Emissions during this period will be minimized, as the air 

pollution control device will continue to run until the kiln ceases to rotate 

continuously, which is when the shutdown period concludes. The type 

and duration of each shutdown will be recorded. 
4

THC/o-HAP and PM Equations

THC/o-HAP Equation:

where:

• o-HAP@7%O2 = Mean of the N test runs (3 or more runs) o-HAP determinations 

corrected to 7%O2 dry basis

• STDM = Standard deviation of the mean of the N o-HAP determinations

• THCSelected = The THC value selected as the threshold for monitoring o-HAP 

compliance. In PCA’s proposed approach, this would be 110% of the highest 

daily-average THC value during the 30 days ending with the o-HAP 

performance test.

• THCAdjusted = The adjusted alternative compliance limit, wich is a conservative 

estimate of the THC concentration equivalent to the 12 ppm OHAP limit at 7% 

O2 based on the mean and standard deviation of the mean of the o-HAP test 

runs.

• Note: The THCSelected and THCAdjusted values in the above equation are corrected to 

7%O2

PM Equation:

PMAdjusted Operating Limit = × PMSite-specific Operating 

Limit

where:

• PMCompliance Test = The average PM emissions level demonstrated in the 

compliance test, computed as the mean of the N test runs and stated on the 

basis of lbs/ton of clinker. 

• STDMean = The standard deviation of the mean of the N test runs conducted 

during the compliance test. If N test runs are conducted, the standard deviation 

of the mean equals the standard deviation of the individual test runs divided by 

the square root of N.

• PMSite-specific Operating Limit = The PM threshold value for monitoring PM compliance 

determined during the compliance test. The threshold value would equal 110% 

of the highest hourly value measured by the PM CPMS during the PM 

compliance test. (110% is included to be consistent with what has been 

established for the alternate site-specific THC limit to trigger retesting)

• PMAdjusted Operating Limit = The adjusted site-specific PM operating limit, a 

conservative estimate of the PM CPMS value that is equivalent to the 0.07 

lbs/ton of clinker standard based on the mean and standard deviation of the 

mean for the individual PM test runs. 
5

Clinker Piles

PCA Proposed Definition: “Open clinker storage pile” means an outdoor, unenclosed 

accumulation of clinker on the ground, which contains in excess of 50,000 tons of 

clinker, and is utilized for a continuous period in excess of 180 days.” 

Coal Mill Recommendations

Scenarios 1a and 1b: Emissions associated with these two configurations remain under 

the regulatory purview of Part 63, Subpart LLL (“Subpart LLL” – portland cement 

NESHAP), as the coal mill exhaust is used in series as combustion air in the kiln and 

therefore takes on kiln regulatory status. Compliance with the Subpart LLL standards 

would be determined by monitoring emissions in or before the kiln stack. 

Scenario 1c: Facilities with this configuration would determine compliance with the 

Subpart LLL standards by either: (1) monitoring all the kiln gases at a single point after 

the affected source and before any diversion to another source, or (2) monitoring at a 

point after the affected source and after the kiln gas diversion point(s) and monitoring 

prior to the inlet of the coal mill, or (3) monitoring all of the combined gases in the main 

kiln stack. Under options 1 and 2, the coal mill is subject to Part 60, Subpart Y (“Subpart 

Y”), if applicable, and the kiln gases are subject to Subpart LLL. 

Scenario 1d: Facilities with this configuration would determine compliance with the 

Subpart LLL standards by either: (1) monitoring all the kiln gases at a single point after 

the affected source and before any diversion to another source, or (2) monitor at a 

point after the affected source and after the kiln gas diversion point(s) and monitor 

prior to the inlet of the coal mill, or (3) monitoring both the kiln and coal mill exhaust. 

Under options 1 and 2, the coal mill is subject to Subpart Y, if applicable, and the kiln 

gases are subject to Subpart LLL. 

Scenarios 2a and 2b: For both configurations, the kiln emissions are subject to Subpart 

LLL and the coal mill emissions subject to Part 60, Subpart Y, as applicable. For 

configuration 2b, the applicable Subpart Y requirements will have to be modified to 

clearly indicate applicability for coal mills using cooler air as a heat source.

Scenario 3: As with scenario 1c, facilities with this configuration would determine 

compliance with the Subpart LLL standards by either: (1) monitoring all the kiln gases at 

a single point after the affected source and before any diversion to another source, or 

(2) monitor at a point after the affected source and after the kiln gas diversion point(s) 

and monitor prior to the inlet of the coal mill, or (3) monitoring both the kiln and coal 

mill exhaust. Under options 1 and 2, the exhaust from the coal mill would be subject to 

Subpart Y, as applicable. For option 3, the coal mill exhaust would be subject to Subpart 

LLL.
Kiln Fuel

(Coal, Coke, etc.) Coal

Mill

Kiln Fuel

(Coal, Coke, etc.)

Kiln

Coal Mill

Exhaust Gas

Coal Mill

Heat Source

(Natural Gas, etc.)

Kiln

Exhaust Gas

Kiln

Exhaust Gas

Kiln Fuel

(Coal, Coke, etc.) Coal

Mill

Kiln Fuel

(Coal, Coke, etc.)

Kiln

Coal Mill

Exhaust Gas

Kiln

Exhaust Gas

Stack

Kiln

Exhaust Gas

Coal Mill Kiln Exhaust Gas

Heat Source

(Natural Gas, etc.)

Emission Limits

Kiln/Coal Mill (normal operation)

Existing – NESHAP LLL

PM - 0.07 lb/ton clinker

D/F - 0.2 ng/dscm TEQ (7% O2)

Mercury - 55 lb/MM tons clinker

THC - 24 ppmvd (7% O2)

HCl - 3 ppmvd (7% O2 - only for major sources)

Monitoring Requirements

Coal Mill Stack

N/A – no stack

Kiln Stack

PM - PM CPMS, rolling 30 operating day avg

D/F - temperature CMS, rolling 3-hr avg

Activated carbon injection - record rolling 3-hr

avg injection rate & rolling 3-hr avg ACI carrier

gas parameter

Mercury - Hg CEMS or sorbent trap-based

integrated monitoring system, exhaust flow rate

monitor, 30 day rolling avg

THC - THC CEMS

HCl - (1) HCl CEMS & CPMS to monitor wet or

dry scrubber or tray tower parameters, or (2) if

equipped with wet or dry scrubber or tray tower, option to use SO2 CEMS

Clinker production - Weigh scale system

Reference §63.1350

Note: Alkali bypasses are not shown on the diagram, but any configuration could include an alkali bypass.

1a. Direct-Fired Kiln, Separate Heat Source

PMk

D/Fk

Hgk

THCk

HClk

Stack

PMk

D/Fk

Hgk

THCk

HClk

XXk - Monitoring Location for Kiln

1b. Direct-Fired Kiln, Kiln Exhaust Heat Source

1c. Combined Coal Mill / Kiln Stack, Kiln Exhaust Gas Heat Source

Kiln Fuel

(Coal, Coke, etc.) Coal Mill

Kiln Fuel

(Coal, Coke, etc.) Kiln

Kiln

Exhaust Gas

Stack

Kiln & Coal Mill

Exhaust Gas

Kiln

Exhaust

Gas

Kiln & Coal Mill

Exhaust Gas

PMk

D/Fk

Hgk

THCk

HClk

Kiln Fuel

(Coal, Coke, etc.) Coal Mill

Kiln Fuel

(Coal, Coke, etc.) Kiln

Kiln

Exhaust Gas

Stack

Kiln / Coal Mill

Exhaust Gas

Cooler/Coal Mill

Exhaust Air

Cooler

Air Cooler

PMk

D/Fk

Hgk

THCk

HClk

1d. Combined Coal Mill / Kiln Stack, Cooler Exhaust Gas Heat Source

Scenario 1. Coal Mill Exhaust Routed Through Kiln or Kiln Stack
Scenario 3. Separate Coal Mill Stack with Kiln Exhaust Heat Source

Kiln Fuel

(Coal, Coke, etc.) Coal Mill

Kiln Fuel

(Coal, Coke, etc.) Kiln

Kiln

Exhaust Gas

Stack

Kiln

Exhaust Gas Stack

Kiln & Coal Mill

Exhaust Gas

Emission Limits

Coal Mill

NESHAP Subpart LLL – same as kiln

PM – not addressed

Kiln (normal operation)

Existing – NESHAP LLL

PM - 0.07 lb/ton clinker

D/F - 0.2 ng/dscm TEQ (7% O2)

Mercury - 55 lb/MM tons clinker

THC - 24 ppmvd (7% O2)

HCl - 3 ppmvd (7% O2 - only for major sources)

Monitoring Requirements

Coal Mill Stack

PM, D/F - not addressed

Mercury - annual Hg perf test (if below method

detection for 2 consec, every 30 months), exhaust flow rate monitor [Rule text does not

specify location for Hg measurement--preamble

suggests after coal mill stack]

THC - Annual THC performance tests

[63.1349(b)(4)(i)(D) specifies THC must be

measured upstream of the coal mill]

HCl - Performance test every 30 months

[63.1349(b)(6)(c) preamble specifies THC must

be measured upstream of the coal mill

Kiln Stack

PM - PM CPMS, rolling 30 operating day avg

D/F - temperature CMS, rolling 3-hr avg

Activated carbon injection - record rolling 3-hr

avg injection rate & rolling 3-hr avg ACI carrier

gas parameter

Mercury - Hg CEMS or sorbent trap-based

integrated monitoring system, exhaust flow rate

monitor, 30 day rolling avg

THC - THC CEMS

HCl - (1) HCl CEMS & CPMS to monitor wet or

dry scrubber or tray tower parameters, or (2) if

equipped with wet or dry scrubber or tray tower, option to use SO2 CEMS

Clinker production - Weigh scale system

Reference §63.1350

Kiln Exhaust Gas

PMk

D/Fk

Hgk

THCk

HCl/SO2k THCcm (test only)

HClcm (test only)

Hgcm (test only)

Stack Gas Flow @ 7% O2

Scenario 2. Separate Coal Mill Stack with Non-Kiln Heat Source

Kiln Fuel

(Coal, Coke, etc.) Coal

Mill Kiln Fuel

(Coal, Coke, etc.)

Kiln

Coal Mill

Exhaust Gas

Coal Mill

Heat Source

(Natural Gas, etc.)

Kiln

Exhaust Gas

Stack

Kiln

Exhaust Gas Stack

Emission Limits

Coal Mill

NSPS Subpart Y

Kiln (normal operation)

Existing – NESHAP LLL

PM - 0.07 lb/ton clinker

D/F - 0.2 ng/dscm TEQ (7% O2)

Mercury - 55 lb/MM tons clinker

THC - 24 ppmvd (7% O2)

HCl - 3 ppmvd (7% O2 - only for major sources)

Monitoring Requirements

Coal Mill Stack

See NSPS Subpart Y

Kiln Stack

PM - PM CPMS, rolling 30 operating day avg

D/F - temperature CMS, rolling 3-hr avg

Activated carbon injection - record rolling 3-hr avg

injection rate & rolling 3-hr avg ACI carrier gas

parameter

Mercury - Hg CEMS or sorbent trap-based

integrated monitoring system, exhaust flow rate

monitor, 30 day rolling avg

THC - THC CEMS

HCl - (1) HCl CEMS & CPMS to monitor wet or

dry scrubber or tray tower parameters, or (2) if

equipped with wet or dry scrubber or tray tower, option to use SO2 CEMS

Clinker production - Weigh scale system

Reference §63.1350

PMk

D/Fk

Hgk

THCk

HClk

const, reconst, mod after April 28, 2008: BLDScm (baghouse)

CPMScm (wet scribber or other) const, reconst, mod before April 28, 2008: Tempcm

2a. Separate Heat Source

Kiln Fuel

(Coal, Coke, etc.) Coal Mill

Kiln Fuel

(Coal, Coke, etc.)

Kiln

Kiln

Exhaust Gas

Stack

Kiln

Stack Exhaust Gas

Cooler/Coal Mill

Exhaust Air

Cooler

Air

Cooler

PMk

D/Fk

Hgk

THCk

HClk

const, reconst, mod after April 28, 2008: BLDScm (baghouse)

CPMScm (wet scrubber or other)

Const, reconst, mod before April 28, 2008: Tempcm

Note: Alkali bypasses are not shown on the diagram, but any configuration

could include an alkali bypass.

2b. Cooler Heat Source

XXk - Monitoring Location for Kiln

XXcm - Monitoring Location for Coal Mill