Nizich, Sharon 

From: 

Sent: 

Vivek Kapur < Kapur.Vivek@azdeq.gov> 

Friday, April OS, 2013 ll:S7 AM 

To: Nizich, Sharon 

Cc: 

Subject: 

Attachments: 

Balaji Vaidyanathan; Latha K. Toopal 

Comment on 40 CFR Subpart LLL 

Vivek Kapur.vcf 

Hi Sharon, 

One more observation of 40 CFR Subpart LLL: 

40 CFR 63.1349(b)(7)(viii) reads as below: 

"(viii) If the average of your three organic HAP performance test runs is at or above 75 percent of your organic HAP 

emission limit, you must determine your operating limit using Equation 14 by averaging the THC CEMS output values 

corresponding to your three organic HAP performance test runs that demonstrate compliance with the emission limit. If 

your new THC CEMS value is below your current operating limit, you may opt to retain your current operating limit, but 

you must still submit all performance test and THC CEMS data according to the reporting requirements in paragraph 

{d)(1) of this section. 

Where: 

X1 =The THC CEMS data points for all runs i. 

Y, =The organic HAP total value for runs i. 

n = The number of data points. 

T, =Your site specific operating limit, in ppmvw THC." 

Comment: The equation appears to be incomplete as it does not have Y1. 

Thanks 

rr-+ve/{)(flpur 

Environmental Engineering Specialist 

Air Quality Permits Section 

Arizona Department of Environmental Quality 

Tel: (602) 771-2323 

E-mail: kapur .vivek@azdeq.gov 

NOTICE: This e-mail (and any attachments) may contain PRIVILEGED OR CONFIDENTIAL information 

and is intended only for the use of the specific individual(s) to whom it is addressed. It may contain information 

that is privileged and confidential under state and federal law. This information may be used or disclosed only 

in accordance with law, and you may be subject to penalties under law for improper use or further disclosure of 

the information in this e-mail and its a.ttachments. If you have received this e-mail in error, please immediately 

notify the person named above by reply e-mail, and then delete the original e-mail. Thank you. 

1 
Nizich, Sharon 

From: 

Sent: 

To: 

Cc: 

Subject: 

Attachments: 

Hi Sharon, 

Vivek Kapur < Kapur.Vivek@azdeq.gov> 

Thursday, April 18, 2013 1:19 PM 

Nizich, Sharon 

Latha K. Toopal; Balaji Vaidyanathan 

PC MACT-more comments 

PC MACT Comments-2.doc 

As we talked today morning, here are some more inaccuracies we have noticed during our review of PC MACT. The 

inaccuracies are in red font, and the suggested corrections are in italics. 

Thanks 

o/iveft1(apur 

Environmental Engineering Specialist 

Air Quality Permits Section 

Arizona Department of Environmental Quality 

Tel: (602) 771-2323 

E-mail: kapur.vivek@azdeq.gov 

NOTICE: This e-mail (and any attachments) may contain PRIVILEGED OR CONFIDENTIAL information 

and is intended only for the use of the specific individual(s) to whom it is addressed. It may contain information 

that is privileged and confidential under state and federal law. This information may be used or disclosed only 

in accordance with law, and you may be subject to penalties under law for improper use or further disclosure of 

the information in this e-mail and its attachments. If you have received this e-mail in error, please immediately 

notify the person named above by reply e-mail, and then delete the original e-mail. Thank you. 

1 
§ 63.1349 Performance testing requirements. 

(b)( 1) 

(viii) When there is an alkali bypass and/or an inline coal mill with a separate stack associated 

with a kiln, the main exhaust and alkali bypass and/or inline coal mill must be tested 

simultaneously and the combined emission rate of PM from the kiln and alkali bypass and/or 

inline coal mill must be computed for each run using Equation 8 of this section. 

{Eq. ~l 

Where: 

E" = Combined hourly emission rate of PM from the kiln and bypass stack and/or in line coal mill, lb/ton of 

kiln clinker production. 

EK = Hourly emissions of PM emissions from the kiln, lb. 

E. = Hourly PM emissions from the alkali bypass stack, lb. 

Ec = Hourly PM emissions from the inline coal mill stack, lb. 

P = Hourly clinker production, tons. 

The equation has 2 Ecs. This may need correction. 

§ 63.1354 Reporting requirements. 

(b) The owner or operator of an affected source shall comply with the reporting requirements 

specified in § 63.10 of the general provisions of this part 63, subpart A as follows: 

(9) The owner or operator shall submit a summary report semiannually which contains the 

information specified in § 63.1 O(e)(3)(vi). In addition, the summary report shall include: 

(i) All exceedences of maximum control device inlet gas temperature limits specified 

in§ 63.1344(a) and (b); should be 63.1346(a) and (b) 

(ii) All failures to calibrate thermocouples and other temperature sensors as required 

under§ 63.1350(f)(7) of this subpart; and 

There is no 63.1350(f)(7). It should be 63.1350(g)(1)(iii) 

(iii) All failures to maintain the activated carbon injection rate, and the activated 

carbon injection carrier gas flow rate or pressure drop, as applicable, as required 

under§ 63.1344(c). Should be 63.1346(c)(2) 

(iv) The results of any combustion system component inspections conducted within 

the reporting period as required under§ 63.1350(i). Should be 63.1347(a)(3) 

(v) All failures to comply with any provision of the operation and maintenance plan 

developed in accordance with§ 63.1350(a). Should be 63.1347(a) 
Nizich, Sharon 

From: 

Sent: 

To: 

Cc: 

Subject: 

Hi AndyNizich, Sharon 

Monday, July 01, 2013 12:41 PM 

O'Hare, Andrew 

Barnett, Keith 

Item in your NESHAP Issue list 

Just wanted to mention and we can talk about this next week- but in your issue list, you have that Sec 

63.1354(a) references Table 1 when it should be Table 3. 

However, as explained to me by the FR office rep, Table 1 is correct at the end of the eCFR, because it is Table 

1 to the entire subpart, whereas the Table 1 that you find under Section 63.1343(b) is Table 1 for that 

particular section. 

Thanks. 

Sharon Nizich 

Minerals and Manufacturing Group 

OAQPS Sector Policies and Programs Division 

US EPA 

Research Triangle Park, NC 

919 541 2825 

1 
Nizich, Sharon 

From: 

Sent: 

To: 

Cc: 

Subject: 

Sharon, 

HolmesAems@aol.com 

Monday, July 01, 2013 1:19 PM 

Nizich, Sharon 

Barnett, Keith 

Re: A few Portland Cement NSPS Questions 

One other issue I have encountered. Section 60.63 (i)(2) of the NSPS appears to have been added in 2010. It looks as 

though it is the exact language that is in the NESHAP rule for monitoring plans, including a number of references to the 

general provisions for NESHAP. Is there a chance that this language does not belong in the NSPS? If you are making 

corrections, I wonder if you want to address this language as well. 

John 

In a message dated 7/1/2013 12:07:19 P.M. Eastern Daylight Time, Nizich.Sharon@epa.gov writes: 

Hi JohnI have to look into your first question on CISWI and applicability, and on the second- we are discussing how to 

fix this right now- may go out with the technical correction proposal but I should know something more 

definitive in a week or so. 

I'll get back to you as I get some answers- thanks. 

Sharon Nizich 

Minerals and Manufacturing Group 

OAQPS Sector Policies and Programs Division 

US EPA 

Research Triangle Park, NC 

919 541 2825 

From: HolmesAems@aol.com [mailto:HolmesAems@aol.com] 

Sent: Monday, July 01, 2013 11:22 AM 

To: Nizich, Sharon 

Subject: A few Portland Cement NSPS Questions 

1 
Sharon, 

I see in the recent NESHAP guidance that a CISWI kiln is not covered by the Portland Cement NSPS. In that 

context, if the unit triggered NSPS when it was built, do the old limits still apply or, now that the unit is CISWI, 

does the old NSPS no longer apply? 

Second, awhile ago I mentioned that I could not find the old Portland Cement NSPS in the electronic CFR. Was I 

correct that it had been deleted? Is it going to be reinstated? 

Thanks, John Holmes 

2 
Nizich, Sharon 

From: 

Sent: 

O'Hare, Andrew <AOhare@cement.org> 

Monday, July 01, 2013 2:50 PM 

To: Nizich, Sharon 

Subject: RE: NESHAP Issue list 

Sharon, 

I will get you the most up to date list shortly, as we dropped a few from the chart we discussed with Keith. 

Regards, 

Andy 

From: Nizich, Sharon [mailto:Nizich.Sharon@epa.gov] 

Sent: Monday, July 01, 2013 2:32 PM 

To: O'Hare, Andrew 

Subject: NESHAP Issue list 

Andy- Could you please send me the PCA document that you all went over when I was out of the office, 

covering tech corrections? Thanks! 

Sharon Nizich 

Minerals and Manufacturing Group 

OAQPS Sector Policies and Programs Division 

US EPA 

Research Triangle Park, NC 

919 5412825 

1 
Nizich, Sharon 

From: 

Sent: 

O'Hare, Andrew <AOhare@cement.org> 

Monday, July 01, 2013 4:14 PM 

To: Nizich, Sharon 

Subject: RE: NESHAP Issue list 

Attachments: NESHAP Issues Next Steps 6-14-13 A.docx 

Sharon, 

Attached is the NESHAP issue list, reflecting next steps, etc. This is the document, you, Keith and I can discuss at your 

earliest convenience. 

Thanks, 

Andy 

From: Nizich, Sharon [mailto:Nizich.Sharon@epa.gov] 

Sent: Monday, July 01, 2013 2:32 PM 

To: O'Hare, Andrew 

Subject: NESHAP Issue list 

Andy- Could you please send me the PCA document that you all went over when I was out of the office, 

covering tech corrections? Thanks! 

Sharon Nizich 

Minerals and Manufacturing Group 

OAQPS Sector Policies and Programs Division 

US EPA 

Research Triangle Park, NC 

919 5412825 

1 
6-14-13 

NESHAP Issue List 

NESHAP Issues Needing Technical Correction 

Issue Concern Desired Outcome Highli

Application of HCI CEMs The requisite Periodic stack testing should be allowed EPA sensitive 

for Those Facilities w/o a performance until EPA has completed work on PS-18. Agency will c

Wet or Dry Scrubber specification is still a stack test alt

(§63.1350(1)(1)) work in progress 

THC Performance Rule only allows for the Add PS-8 as an allowable method. EPA will disc

Specification use of PS-8A. PS-8 to allow the 

(§63.1349(b)(4) and should also be allowed 8A. 

§63.1350(i)) 

Definition of "Rolling Inconsistent application One, consistent definition of the term should EPA explaine

Average" of term in rule be employed in the rule. Agency's inte

methodolog

compute rol

revisit the iss

THC Mill-on Testing The phrase: "highest Reference to this term should be dropped This issue is 

§63.1349(b)(7)(xi) load or capacity" is here and elsewhere in the rule. 

vague and difficult to 

demonstrate? 

Obligation to Turn On ALL It may not be safe or Amend §63.1346(g)(3) and §63.1386 (b){9) EPA understa

Air Pollution Control necessary to have all to include the modifying phrase: "subject to with having t

Devices at Start-up and control devices the design, technical and safety limitations controls rega

Shutdown (§63.1346(g){3) operating during start- of the device and in accordance with the safe or appro

and §63.1386 (b)(9)) up and shutdown (such facility's operation and maintenance plan." agreed to pr

as SNCR for NOx) EPA should also clarify that only those specific text 

devices that control NESHAP pollutants are resolve the m

affected. 
Performance Test Testing frequency Revise testing frequency from annual to 30- EPA will con

Frequency Should be should be every 30 months for PM. Revise §63.1349(c) regarding P

Harmonized months for PM as accordingly. Also, note Regarding t

specified foro-HAP and §63.1349(b)(7)(xii)(B) for THC and rule in cons

HCI in §63.1349(b)(7)(vi) §63.1350(i)(2) for by-pass and coal mill the correcti

and §63.1349(c), stacks, still reference annual test, when the 

respectively preamble specifies a 30-month frequency. 

This needs to be corrected. 

Time Weighted Average Unclear that o-HAP is Add time weighted average language to This issue is 

(TWA) for Mill On/Off o- time weighted average. determination of o-HAP compliance in recently iss

HAP Emissions and Also the 75% §63.1348(a)(4)(iv) and add cross reference 

Associated THC Limit (§63. adjustment of the THC to the 75% adjustment using Equation 13 to 

1348(a)(4)(iv) and operational limit needs §63.1349(b)(7)(ix). 

§63.1349(b)(7)) to apply to kilns with in 

line raw mills 

The Alternative THC Limit Could be confusing Is this really a problem? Or, just a potential This issue is 

is a Wet, Uncorrected when the numerical issue for which the industry should be 

Value. See Eq. 12 and 13. value for the alternative aware? 

limit is less than the 

numerical value for the 

standard, e.g., 33 

ppmvd@7% 02 = 19.5 

ppmvd@8% moisture 

and 12%02 

§63.1350(j) foro-HAPs References PS-15 for Reference should be to PS-8 or PS-8A. EPA will ma

Testing THC CEMs during o-HAP change, reg

testing they allow f

Start-up/Shutdown §63.1348(b)(l)(ii) §63.1350(a)(2) is no longer relevant, and EPA will ma

Recordkeeping exempts facilities from likely a holdover from the prior rule, as there technical co

( §63.1348(b)(1)(ii)) collecting data during are no S/S emission standards. It should be 

S/S. §63.1350(a)(2) dropped. 
requires monitoring 

data during S/S to be 

recorded and averaged 

Emission Standards for Confusion regarding Modify equations to account for There was a 

' Commingled Sources how to compute commingled sources reflecting the presence regarding th

emission standards and of by-pass stacks and free standing coal mill clear remedy

document compliance stacks. perhaps add

for commingled sources, basis. EPA w

including those with by- allowing fac

pass stacks and separate inlet to a coa

coal mill stacks. 

§63.1350(k) Mercury Less frequent testing By-pass stack testing frequency should also EPA will con

Monitoring Requirements limited to coal mill be reduced, if the emissions are below the 

stacks method detection limit. 

PM Initial Compliance Unclear when mill Add reference to the use of a TWA for initial EPA explaine

Testing; Subsequent on/mill off testing is PM compliance testing in §63.1349(b)(1)(ix) not intend fo

Performance Testing and required and confirm that subsequent performance limits, raw m

Compliance Monitoring (§63.1349(b)(l)(vi) and tests in §63.1349(b)(l)(vi) require one set of that a single 

Operating Limit Under (ix)). If such testing is three one-hour runs under mill conditions computed. 

§63.1349(b)(1) required, approach for expected to have the highest PM load. 

computing time CPMS limit should be the average of the 

weighted averages three highest one-hour PM test runs. A 

(TWA) for PM cross reference to the 75% adjustment to set 

compliance and the CPMS operating limit using Equations 4 

associated operating and 5 should also be added. 

limit need specification 

Definition of "Conveying Does not specifically Exclude by adding at the end of the This issue is 

System Transfer Point" exclude transfers to and definition, "but does not include transfers to 

(§63.1341) from mobile equipment and from mobile equipment." 

Definition of "Kiln" Includes inline coal mills Remove reference to "inline coal mills" in This issue is 

(§63.1341) in computation of second phrase of definition. 
emission limits 

Reference to Table 2 Table 2 removed from Either remove §63.1343(d) or re-add Table EPA plans to 

(§63.1343(d}) regulatory text 2. 

Improper Table §63.1354(a) references Make corrections. EPA will mak

References Table 1 when it should 

be Table 3. Also new 

kiln D/F in Table 1 

references footnote #1 

(for PM) and should 

reference footnote #2. 

Computation of There is an The calculation for existing and new sources EPA will add 

Alternative PM limit under inconsistency the should be the same and by-pass stack should source calcu

§63.1343 (b)(2) calculations for existing be noted. 

and new kilns on which 

combined flows are 

subject to the alternate 

PM limit. The section 

also does not mention 

by-pass exhaust which is 

in the PM equation. 

Moisture Correction Equation 10 allows The moisture correction requirement should This issue is 

Associated with concentration and flow be dropped. 

§63.1343(a) for Mercury either on wet or dry 

Standard basis, so why is this 

needed. 

Monitoring SOz In-lieu of §63.1349(b)(6)(iii) The SOz operating limit should be highest EPA intende

Using and HCI CEMs requires the use of the SOzemission value recorded for any 60 the SOz emis

(§63.1349(b)(6)(iii)) "highest 1-hr average. minute period during the HCI test. The stack test an

This conflicts with adjustment of the SOz operating limit when an adjustme

§63.1349(b)(8) which the HCIIevel is below 75% of the standard operating lim

stipulates the use of the_ should be added. emissions ar
"average of the S02 standard. EP

emissions recorded 

during the HCI stack 

test." 

Monitoring S02 In-lieu of The section references Make correction. EPA will corr

Using and HCI CEMs THC when it should be 

(§63.1349(b}(8)((vi)) HCI. 

Alternative Monitoring §63.1350(o)(3) Reference should be to §63.1350(o)(3)(i)-(iii) EPA already 

Requirements references Will fix in a t

(§63.1350(o)) §63.1350(m)(3}(i) rule. 

through (iii) 

Open Clinker Storage Piles There is no limitation on A size limit should be identified for those There was an 

the size of "temporary" temporary piles subject to the clean up of this issue. 

piles (§63.1343(c)(3)) requirement (e.g., >X tons), The number of proposal for 

days allowed for cleanup shou.ld be addressing w

extended from 3 to 7. "temporary" 

recommend 

"open clinke

"New" Source Compliance Should be July 18, 2012, 'New" source trigger date should be July 18, EPA will cons

Date (78 Fed. Reg. 10025) rather than May 6, 2009 2012. 

NESHAP Issues Needing Clarification 

Issue Concern Desired Outcome 

Applicability of Opacity Opacity monitoring EPA should clarify accordingly. Next steps fo

Monitoring Requirements should only be required were not cle

for Subpart F only for sources 

( §60.62(b )(1)(ii)} constructed, 

reconstructed or 

modified after June 16, 

2008 

HCI and Hg CEMs Span issues are TBD There was an 

(§63.1350(k}, §63.1350(1) unworkable regarding HC
concerns. A

with monito

considered. 

Compliance Deadline for Ambiguity in the scope §63.1351(d) stipulates that the compliance EPA explaine

New Sources (§63.1341) of the definition of "new date for "new sources" is February 12, 2013 deadline for 

Other Than Kilns, Coolers source," which focuses or startup, whichever is later. The definition than the kiln

and Dryers on kilns, coolers and of "new source" addresses only kilns, cooler upon startup

dryers, but not other and raw material dryers. What compliance affecting the 

new equipment such as deadline applies to other new sources, such unchanged f

transfer points. as, for example, conveyor transfer points. NESHAP. 
Nizich, Sharon 

From: 

Sent: 

Matousek, David <DMatousek@idem.IN.gov> 

Monday, July 15, 2013 9:29AM 

To: Nizich, Sharon 

Subject: RE: 40 CFR 63, Subpart LLL - Missing Table 

Sharon, 

Thanks for the link. I will most likely incorporate Table under the authority of our state rule until Subpart LLL is 

revised. Thank you for your quick reply. 

From: Nizich, Sharon [mailto:Nizich.Sharon@epa.gov] 

Sent: Friday, July 12, 2013 7:37 AM 

To: Matousek, David 

Subject: RE: 40 CFR 63, Subpart LLL - Missing Table 

Yes we are aware that it was inadvertently removed during the publication process. We developed guidance that also 

touches on this and I'm sending the link to you- however, we have been informed by our office of general counsel that 

I have one misstatement in the guidance that I am changing today and that is- a facility is still subject to the Section 111 

NSPS (subpart F) even if they are burning nonhazardous waste and are now subject to the CISWI NSPS. So not sure if 

that affects your permit or not. The corrected guidance should be up on the web on Monday July 15, but here is the link 

to what we have up there now, so you can see the table. The table is on page 3. 

http://www .epa .gov /ttn/atw /pee m/ru legu ida ncemay2013. pdf 

Sharon Nizich 

Minerals and Manufacturing Group 

OAOPS Sector Policies and Programs Division 

US EPA 

Research Triangle Park, NC 

919 541 2825 

From: Matousek, David [mailto:DMatousek@idem.IN.gov] 

Sent: Thursday, July 11, 2013 4:55 PM 

To: Nizich, Sharon 

Subject: 40 CFR 63, Subpart LLL - Missing Table 

Dear Ms. Nizich: 

I was incorporating this NESHAP into a Part 70 permit for a local industry and I noticed a table was missing in the final 

rule. The text provided in 40 CFR 63.1343(d), 78 FR 10037, Feb. 12, 2013, references Table 2; however, this table does 

not exist in the text of the rule. The text I reference is shown below: 

(d) Emission limits in effect prior to September 9, 2010. Any source defined as an existing source in§ 63.1351, and that 

was subject to a PM, mercury, THC, D/F, or opacity emissions limit prior to September 9, 2010, must continue to meet 

the limits shown in Table 2 to this section until September 9, 2015. 

1 
David Matousek 

Indiana Department of Environmental Management 

Office of Air Quality 

Permits Branch 

dmatouse@idem.IN.gov 

David Matousek 

IDEM, OAQ 

Permits Branch 

dmatouse@idem.IN.gov 

2 
Nizich, Sharon 

From: 

Sent: 

To: 

Cc: 

Subject: 

Keith, 

O'Hare, Andrew <AOhare@cement.org> 

Friday, August 09, 2013 4:07 PM 

Barnett, Keith 

Nizich, Sharon 

Clinker Piles 

Here are some ofthe ideas we were kicking around re: clinker piles. 

The first suggestion is mine: 

Refine the definition of "open clinker storage pile," to make it more definitive with the objective of only having those 

piles that meet that definition be subject to the work practice standards. All other collections of clinker, temporary or 

otherwise, would not be subject to the management standards or the NESHAP for that matter. 

To make this work, EPA would also have to remove the language under Section 63.1343(c)(3), which states: "Temporary 

piles of clinker that result from accidental spillage or clinker storage cleaning operations must be cleaned up within 3 

days." 

Here is the existing definition of "open clinker storage pile": "means a clinker storage pile on the ground for more than 3 

days that is not completely enclosed in a building or structure." 

Here is a proposed alternative: "means a collection of clinker, not completely enclosed in a building or structure, created 

to address the annual fluctuations of the construction market and associated cement sales." 

Michael Pelan responded to my suggestion with the following: 

I've broken the definition into two parts-- "clinker storage pile" and "open clinker storage pile". 

Clinker Storage Pile: Any location (other than silos or bins) within a cement manufacturing plant that clinker is 

temporarily stored after being removed from the manufacturing process but prior to its use in the production of 

cement. 

"Open" Clinker Storage Pile: Any Clinker Storage Pile that is not partially or fully enclosed by a building or other 

structure to protect the clinker from wind, rain and other deleterious impacts. 

This can be refined further and/or combined into a single definition if needed. 

My thought h~re was to provide a definition of "clinker storage pile" that could apply to a pile of any type (totally 

enclosed, partially enclosed, open). I also wanted the definition to specify that the clinker could come from any part of 

the manufacturing process (cooler, silos, etc.) but had to be "removed" with the intention of storing it (versus spillage, 

etc.). While I liked the reference to fluctuations in the construction market and associated cement sales, I felt it needed 

to be left more vague. For example, if we clean out a silo and create a temporary pile, this is not to manage clinker for 

fluctuations. 

For the "open clinker storage pile" definition, I wanted to capture partial and full enclosure as not inclusive of regulation 

under this rule. 

1 
Your thoughts are most welcome. 

Regards, 

Andy 

Andrew (Andy) T. O'Hare, CAE 

Vice President, Government Affairs 

Portland Cement Association 

500 New Jersey Avenue NW, 7th Floor 

Washington, DC 20001 

Office: (202) 408-9494 

Direct: (202) 719-1974 

Fax: (202) 408-0877 

Cell: (202) 270-0094 

e-mail: aohare@cement.org 

2 
Nizich, Sharon 

From: Nizich, Sharon 

Sent: Friday, September 20, 2013 3:13 PM 

To: 

Subject: 

O'Hare, Andrew; Barnett, Keith; Cozzie, David 

RE: Conf Call 

Hello Andy1 can go through scheduler and try to get something set up for the week of September 30- can you give me some times? 

Thanks. 

Sharon Nizich 

Minerals and Manufacturing Group 

OAQPS Sector Policies and Programs Division 

US EPA 

Research Triangle Park, NC 

919 541 2825 

From: O'Hare, Andrew [mailto:AOhare@cement.org] 

Sent: Wednesday, September 18, 2013 3:51 PM 

To: Barnett, Keith; Cozzie, David; Nizich, Sharon 

Subject: Conf Call 

Keith, David and Sharon, 

Hope all goes well on your end. I am writing to see if we would arrange a time for a conference call to discuss where the 

agency is on the outstanding NESHAP and CISWI issues we have discussed previously. 

I would plan to include a few of my members in the discussion. Please let me know when would be convenient on your 

end over the next few weeks. 

Thanks, 

Andy 

Andrew (Andy) T. O'Hare, CAE 

Vice President, Government Affairs 

Portland Cement Association 

500 New Jersey Avenue NW, 7th Floor 

Washington, DC 20001 

Office: (202) 408-9494 

Direct: (202) 719-1974 

Fax: (202) 408-0877 

Cell: (202) 270-0094 

e-mail: aohare@cement.org 

1 
Nizich, Sharon 

Subject: 

Location: 

Start: 

End: 

Recurrence: 

Meeting Status: 

Organizer: 

Required Attendees: 

Placeholder for call with PCA 

KBO 

Wed 11/6/2013 2:00 PM 

Wed 11/6/2013 4:00 PM 

(none) 

Meeting organizer 

Nizich, Sharon 

Barnett, Keith; Johnson, Steffan 

A call was held with Andy O'Hare of the Portland Cement Association and several industry representatives. Discussion 

centered around attached list of technical corrections for the upcoming Portland Cement amendments. 

1 
Updated 7-9-13, reflecting discussion with EPA on 7-9 (reflectea m 01ue text). Questions/comments for 11/6/13 call in re

reflecting discussion with EPA on 11/6 noted in purple. 

Issue 

Application of HCI CEMs for 

Those Facilities w/o a Wet 

or Dry Scrubber 

(§63.1350(1)(1)) 

HC Performance 

Specification 

(§63.1349(b)(4) and 

§63.1350(i)) 

efinition of "Rolling 

NESHAP Issue List 

N.ESHAP:'Issues Needlng1'echnlcal Corr:ection 

Concern 

The requisite 

performance 

p~s-stlll a work 

11 in progress . 

,~~'J-

\t,r-1 · 0~ V'? 1 

\ ~~ ~~ . I • 

also be allowed 

Inconsistent application 

of term in rule 

Desired Outcome 

Periodic stack testing should be allowed until 

EPA has comp et t;~'P

rlt?

S-1~. ( 

\ 

) 

/ 

Add PS-8 as an allowable method. 

Highl

EPA appeare

concerns abo

completion o

contemplate 

alternative. 

EPA policy qu

discussion. W

developmen

PCA will arra

alternative m

with EPA. 

EPA will discu

to allow the 

EPA plans t<? 

a rule text ch
methodology 

issue. 

EPA plans to 

approach for 

averages. Ho

accomplished

The approach 

averages will 

upcoming pro

THC Mill-on Testing The phrase: "highest load Reference to this term should be dropped This issue is n

§63.1 49(b)(7)(xi) or capacity" is vague and here and elsewhere in the rule. Some PCA m

difficult to demonstrate? concerned ab

believe the re

\ removed. 

EPA will remo

"highest load 

on represent

in general pr

. Obligation to Turn On ALL It may not be safe or Amend §63.1346(g)(3) and §63.1386 (b)(9) to EPA understa

Air Pollution Control necessary to have all include the modifying phrase: "subject to the having to tur

Devices at Start-up and control deyices operating design, technical and safety limitations of the regardless of 

Shutdown (§63.1346(g)(3) during start-up and device and in accordance with the facility's appropriate t

nd;~386{~TI 

shutdown (such as SNCR operation and maintenance plan." EPA should prepare tech

for NOx) also clarify that only those devices that control EPA to consid

v· 'Q· NESHAP pollutants are affected. matter . . The primary 

operation of 

devices. PCA

to be address
guidance. La

technology s

procedures, t

they may be 

plans. Plant-

address this 

approach. 

When to turn 

control techn

will be addre

O&M plan. 

Performance Test Testing frequency should Revise testing frequency from annual to 30- While EPA wa

Frequency Should be be every 30 months for months for PM. Revise §63.1349{c) concern rega

Harmonized PM as specified for a-HAP accordingly. Also, note §63.1349{b)(7)(xii)(B) harmonizatio

and HCI in for THC and §63.1350{i){2) for by-pass and coal testing the ag

§63.1349{b){7){vi) and mill stacks, still reference annual test, when committal ab

§63.1349{c), respectively the preamble specifies a 30-month frequency. for PM. Reg

This needs to be corrected. preamble and 

EPA will mak

months. 

EPA policy qu

discussion. W

current think

PM testing? 

EPA plans to 

testing obliga

Time Weighted Average Unclear that a-HAP is Add time weighted average language to This issue is r

A) for Mill On/Off o- time weighted average. determination of a-HAP compliance in issued EPA gu

' HAP Emissions and Also the 75% adjustment §63.1348{a){4){iv) and add cross reference to 

Associated THC Limit {§63. of the THC operational the 75% adjustment using Equation 13 to Resolved. 
1348(a)(4)(iv) and limit needs to apply to §63.1349(b)(7)(ix). 

§63.1349(b)(7)) kilns with in line raw mills 

The Alternative THC limit is Could be confusing when Is this really a problem? Or, just a potential This issue is 

a Wet, Uncorrected Value. the numerical value for issue for which the industry should be aware? 

See Eq. 12 and 13. the alternative limit is 

,() less than the numerical value for the standard, e.g., 33 ppmvd@7% 02 = 19.5 ppmvd@8% 

moisture and 12% 02 

§63.13500) foro-HAPs References PS-15 for THC Reference should be to PS-8 or PS-8A. EPA will mak

,; ng 

CEMs during o-HAP change, rega

testing allow for the 

EPA making 

How? 

. 

/ Will be made 

sirUp/Shutdown §63.1348(b)(l)(ii) §63.1350(a)(2) is no longer relevant, and likely EPA will mak

R ordkeeping exempts facilities from a holdover from the prior rule, as there are no technical cor

[) 63.1348(b)(l)(ii)) collecting data during S/5. S/S emission standards. It should be dropped. 

§63.1350(a)(2) requires EPA making 

I 

monitoring data during How? 

S/S to be recorded and 

averaged Will be made 

Emission Standards for Confusion regarding how Modify equations to account for commingled There was a 

1 

] mingled Sources to compute emission sources reflecting the presence of by-pass regarding thi

standards and document stacks and free standing coal mill stacks. remedy, oth

compliance for address it on 

commingled sources, EPA will, how

including those with by- facilities to m

pass stacks and separate coal mill. 

coal mill stacks. 
EPA believes 

prohibition o

the inlet to th

recommends 

remaining am

alternative m

§63.1350(k) Mercury Less frequent testing By-pass stack ~esting frequency should also be EPA will cons

/ itoring Requirements limited to coal mill stacks reduced, if the emissions are below the 

method detection limit. EPA will make 

Will be made 

proposal. 

PM Initial Compliance Unclear when mill on/mill Add reference to the use of a TWA for initial EPA explained 

Testing; Subsequent off testing is required PM compliance testing in §63.1349(b)(1)(ix) not intend fo

Performance Testing and (§63.1349(b)(1)(vi) and and confirm that subsequent performance limits, raw m

Comr;Hance Monitoring (ix)). If such testing is tests in §63.1349(b)(1)(vi) require one set of a single TWA 

Op ating Limit Under required, approach for three one-hour runs under mill conditions 

§6 .1349(b)(1) computing time weighted expected to have the highest PM load. CPMS EPA plans to 

averages (TWA) for PM limit should be the average of the three 

compliance and highest one-qour PM test runs. A cross Will be made 

I, associated operating limit reference to the 75% adjustment to set the 

need specification CPMS operating limit using Equations 4 and 5 

\. should also be added. 

= ion of "Conveying Does not specifically Exclude by adding at the end of the definition, This issue is n

m Transfer Point" exclude transfers to and "but does not include transfers to and from 

341) from mobile equipment mobile equipment." 

D;~n of "Kiln" Includes inline coal mills Remove reference to "inline coal mills" in This issue is n

{§6 1341) in computation of second phrase of definition. 

emission limits 

renee to Table 2 Table 2 removed from Either remove §63.1343(d) or re-add Table 2. EPA plans to 

3.1343(d)) regulatory text 

I 

--

EPA will add t
~ Improper Table References :1 '1 . /" \'J~\t) Computation of Alternativev 

PM limit under §63.1343 

(b)(2) 

; 

Standard 

Monitoring SOz In-lieu of 

Using and HCI CEMs 

§63.1354(a) references Make corrections. 

Table 1 when its ~ ~~'1 ~,_) SO 

Table 3. Also new kiln -.\-'V1'r l:> {1 / 

D/F in Table 1 references "( ~ \ at \ ~~ ~ . 

footnote#1(forPM)and fll5 <:>t~ should reference 1' rf\ 

footnote #2. 

There is an inconsistency 

the calculations for 

existing and new kilns on 

which combined flows 

are subject to the 

alternate PM limit. The 

section also does not 

mention by-pass exhaust 

which is in the PM 

equation. 

Equation 10 allows 

concentration and flow 

either on wet or dry 

basis, so why is this 

needed. 

§63.1349(b)(6)(iii) 

requires the use of the 

The calculation for existing and new sources 

should be the same and by-pass stack should 

be noted. 

The moisture correction requirement should 

be dropped. 

The SOz operating limit should be highest 

SOzemission value recorded for any 60 minute 

reference. In 

Will be made 

EPA will make 

rule text chan

Footnote refe

corrected in 

EPA will add c

source calcul

While the rul

on how to sp

by-pass stack 

performance 

rule i 

fa ilities to a

st ck emissio

fro the tota

limit to show 

SHOU ~OP

This issue is n

EPA intended 

the SOz emis
(§63.1349(b )(6)(iii)) "h~st 1-hr average. period during the HCI test. The adjustment of stack test and 

This conflicts with the S02 operating limit when the HCIIevel is adjustment t

§63.1349(b)(8) which below 75% ofthe standard should be added. limit when th

stipulates the use of the 75% below th

"average of the S02 clarify. 

emissions recorded 

during the HCI stack test." EPA policy qu

discussion. S

I EPA still delib

make this ch

~onitoring so, In-lieu of The section references Make correction. EPA will corre

sing and HCI CEMs THC when it should be change? 

/ (§63.1349{b)(8)((vi)) HCI. 

I Will be made 

A(ternative Monitoring §63.1350(o)(3) Reference should be to §63.1350(o)(3)(i)-(iii) EPA already c

I 

,l J;equirements references Will fix in a te

(§63.1350(o)) §63 .1350( m )( 3 )( i) rule. Yes? 

through (iii) 

~ 

Will be made 

Piles There is no limitation on A size limit should be identified for those There was an 

the size of "temporary" temporary piles subject to the clean up of this issue. 

piles (§63.1343(c)(3)) requirement (e.g., >X tons), The number of proposal for 

\ days allowed for cleanup should be extended addressing w

from 3 to 7. "temporary" 

recommend 

"open clinke

This issue co

and annoying 

A perspective, 

that EPA is n

make any su
discussed wi

more specific 

clinker storag

other collect

not meet tha

be subject to 

managemen

alternative d

Peter T. (will 

EPA will clari

work practice 

applies to pe

clinker piles. 

"New'' Source Compliance Should be July 18, 2012, 'New" source trigger date should be July 18, EPA will cons

Date (78 Fed. Reg. 10025} rather than May 6; 2009 2012. appear willin

EPA policy qu

discussion. W

this issue? 

EPA does no

the emission 

more stringe

compared to 

·' 

•" -- NESHAP Issues Needing Clarification - - -

Issue Concern Desired Outcome 

Applicability of Opacity Opacity monitoring EPA should clarify accordingly. Next steps fo

? Monitoring Requirements should only be required were not cle

for Subpart F only for sources 

(§60.62(b}(1}(ii)) constructed, EPA will discu

reconstructed or with OGC. St

modified after June 16, 
2008 Needs furthe

within EPA. 

HCI and Hg CEMs Span issues are TBD There was an 

(§63.1350(k), §63.1350(1) unworkable regarding HCI 

. concerns. Ad

monitoring ex

considered . 

EPA monitori

these concern

Will be addre

proposal. Complian~e Deadline for Ambiguity in the scope of §63.1351(d) stipulates that the compliance EPA explained 

New Sources (§63.1341) the definition of "new date for "new sources" is February 12, 2013 or deadline for n

Other Than Kilns, Coolers source," which focuses on startup, whichever is later. The definition of the kiln, cool

and Dryers kilns, coolers and dryers, "new source" addresses only kilns, cooler and startup, as th

but not other new raw material dryers. What compliance affecting the 

equipment such as deadline applies to other new sources, such unchanged fr

transfer points. as, for example, conveyor transfer points. NESHAP. ~ger an 

I 

~ 0
Nizich, Sharon 

From: 

Sent: 

To: 

Subject: 

Attachments: 

All, 

HolmesAems@aol.com 

Wednesday, August 20, 2014 11:19 AM 

Nizich, Sharon; Barnett, Keith; Johnson, Steffan; Fruh, Steve 

Re: Discussion with John Holmes 

DraftNotesCementNSPS_NESHAP.docx 

I have attached my draft notes from our conversation. Pis let me know if you have any comments or edits by the end of 

the day. Thanks for your assistance and the productive conversation we were able to have. 

John Holmes 

1 
August 20, 2014 

Draft Notes on Remaining Issues Related to the Portland Cement NSPS and NESHAP 

The list of issues dated July 7th has been shared with EPA. EPA is planning both a supplemental 

rulemaking and additional guidance and the agency intends to address many of the issues in one way or 

the other. In a review of the issues, it was agreed that a number of them would benefit from further 

discussions. EPA is considering a meeting with PCA members to that end in their offices the week of 

September 15th and they understand that the preference would be for Friday the 19th. 

Here are specific issues from the list that will benefit from further discussion: 

• HCI CEMS and the associated performance specification: The comment period has closed on the 

new PS-18 and EPA is targeting finalizing it in December or January. Additional information 

should be shared on two points. First, will a final PS-18 allow enough time for compliance using 

CEMS and, if not, exactly what will be the problem(s). Second, what are the two or three key 

changes needed to the draft PS-18 and what is the cost or technical implications of those 

changes not occurring? 

• The requirement to have all control devices on during startup and shutdown: It will be helpful 

for PCA to describe the technical problems that may arise with HAP controls such as lime or 

carbon injection during startup or shutdown, and suggest specific criteria that could be 

provided, such as a link to the dew point, in the form of guidance. 

• The reference to Table 1 in 63.1354(a) is correct and the party raising this issue should 

reconsider it and be prepared to discuss it, if that is still necessary. 

• The agency is not anticipating any new action on the open clinker pile requirements and in 

particular will not be addressing the size or duration of temporary piles. If there is a very 

specific concern, the PCA should be prepared to discuss it. 

• The applicability of opacity monitoring under Subpart F is listed as a "NESHAP" issue. If it is a 

NESHAP issue, that will need further explanation. 

• EPA intends to reinstate in the NSPS the limits that applied prior to the latest rule changes. 

However, the application of the revised monitoring requirements (monitoring plan) to sources 

triggering NSPS prior to the rule change was intentional. (A similar action occurred when the 

use of COMS was added to the NSPS.) If this presents significant problems for the older NSPS 

units, the PCA will need to provide a specific explanation. Regarding the new COM QA rule, that 

may apply between now and the NESHAP compliance date, the PCA will need to explain the 

hardship that comes with that obligation, should it apply for less than a year. 

• The NSPS is not clear as to whether CPMS is required for demonstrating compliance with the 

prior PM limit or only the new limit. EPA is considering a clarification that the use of CPMS 

applies only to those units subject to the newest NSPS PM limit. 

• The agency will be prepared to discuss the fate ofthe NSPS limits when the provisions of 

60.62(d) are accounted for. 
A meeting was held on September 17, 2014 between the US EPA and representatives from the 

Portland Cement Industry, to discuss the agenda that was submitted by John Holmes of AEMA 

(attached). 

Those in attendance were: 

Tim Matz, Lehigh Cement 

John Holmes, AEMS 

Satish Sheth, CEM EX 

Jay Willis, Titan America 

Michael Pelan, LaFarge 

Curtis Lesslie, Ash Grove 

Travis Reed, Counsel to PCA 

Dick Stoll, Counsel to PCA 

Brent Lindsey, Phoenix Cement 

Tom Harman, PCA 

EPA representatives: 

Sharon Nizich 

Keith Barnett 

Paul Versace 

Toni Jones 

David Cozzie 

Michael Toney 

Candace Sorrell 

Steve Fruh 

Stef Johnson 

Ray Merrill 
Proposed Agenda for the September 17th Meeting between PCA members and EPA on Corrections and 

Clarifications of NSPS, NESHAP and CISWI Requirements 

NSPS and NESHAP 

CISWI 

Key Discussion Topics 

• Startup and Shutdown Control Device Requirements 

• NSPS C:rosslink to NESHAP on opacity monitoring for transfer points 

• Reinstating prior NSPS limits, without CPMS applying retroactively 

• NESHAP cooler stack flow monitoring 

• Status and concerns with PS-18 

Quick review of the remaining items on the PCA list of July 7th 

Action items coming out ofthe discussion. 

Key Discussion Topics: 

• Reconsideration of the PM limit 

• Startup and Shutdown requirements 

• Requirements for commingled sources 

Quick review of the remaining items on the PCA list of July 7th 

Action items coming out of the discussion.