# 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 of40 CFR Subpart LLL: 40 CFR 63.1349(b)(7)(viii) reads as below: "(viii) Ifthe average ofyour three organic HAP performance test runs is at or above 75 percent ofyour 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 newTHC CEMS value is below your current operating limit, you may opt to retain yourcurrent operating limit, but you muststill submitall performance test and THC CEMS data according to the reporting requirements in paragraph {d)(1) ofthis section. Where: 

# X1 =TheTHC CEMS data points for all runs i. 

# Y, =The organic HAP total value for runs i. n = The numberofdata points. T, =Your site specific operating limit, in ppmvwTHC." 

# Comment: The equation appears to be incomplete as itdoes not have 

# Y1. Thanks 

# rr-+ve/{)(flpur EnvironmentalEngineeringSpecialist Air 

# QualityPermitsSection ArizonaDepartmentofEnvironmental Quality Tel: (602) 771-2323 E-mail: kapur.vivek@azdeq.gov 

# NOTICE: This e-mail (and any attachments) may containPRIVILEGED ORCONFIDENTIAL information and is intendedonlyfor the use ofthe specific individual(s) to whomitis addressed. It

# may contain information that is privileged and confidentialunder state and federal law. This informationmaybe used ordisclosed only in accordance with law, and youmaybe subjectto penalties under lawfor improperuse orfurther disclosure of the informationinthis e-mail andits a. ttachments. Ifyouhave received this e-mail inerror, please immediately notifythe personnamed above byreply e-mail, andthen 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 EnvironmentalEngineering Specialist Air 

# QualityPermitsSection ArizonaDepartmentofEnvironmental Quality Tel: (602) 771-2323 E-mail: kapur.vivek@azdeq.gov 

# NOTICE: This e-mail (and any attachments) maycontainPRIVILEGED ORCONFIDENTIAL information and is intended only for the use ofthe specific individual(s) to whomitis addressed. It

# may containinformation that is privileged and confidentialunder state and federal law. This informationmaybe used or disclosed only in accordance withlaw, andyoumaybe subjectto penalties under lawfor improperuse or further disclosure of the informationinthis e-mail andits attachments. Ifyouhave received this e-mail in error,pleaseimmediately notifythe personnamed above byreply e-mail, and thendelete the original e-mail. Thank you.

1

# § 63.1349 Performancetesting 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 ofthis section. {Eq.**~l** 

# Where: E"

# = Combined hourly emission rate of PM from the kiln and bypass stack and/or inline 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 mayneedcorrection. 

# § 63.1354 Reporting requirements. (b) The owner or operator ofan affected source shall comply with the reporting requirements specified in 

# § 63.10 ofthe general provisions ofthis part 63, subpart A as follows: (9) The owner oroperator shall submit a summary report semiannually which contains the information specified in 

# § 63.1O(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); 

# shouldbe 63.1346(a) and(b) (ii) All failures to calibrate thermocouples and othertemperature sensors as required under§ 

# 63.1350(f)(7) ofthis subpart; and There is no 63.1350(f)(7). 

# Itshouldbe 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). Shouldbe 63.1346(c)(2) (iv) The results ofany combustion system component inspections conducted within the reporting period as required under§ 

# 63.1350(i). Shouldbe 63.1347(a)(3) (v) All failures to comply with any provision ofthe operation and maintenance plan developed in accordance with§ 

# 63.1350(a). Shouldbe 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 aboutthis next week- but in your issue list, you have that Sec 63.1354(a) references Table 1when itshould be Table 3. However, as explained to me by the FR office rep, Table 1 is correct at the end ofthe eCFR, because it is Table 1tothe entire subpart, whereas theTable 1thatyou find underSection 63.1343(b) is Table 1forthat 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) ofthe 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 numberof references to the general provisions for NESHAP. Is there a chance that this language does not belong in the NSPS? Ifyou are making corrections, Iwonder ifyou wantto 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 intoyour first question on CISWI and applicability, and on the second- we are discussing howto fix this right now- may go outwith the technical correction proposal but Ishould knowsomething more definitive in a week or so. I'll get back to you as Iget 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 notcovered by the Portland Cement NSPS. In that context, ifthe unittriggered NSPS when itwas built, do the old limits still apply or, nowthat the unit is CISWI , does the old NSPS no longer apply? Second, awhile ago I mentioned that I could notfind 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, Iwill getyou the most up to date list shortly, as we dropped afew 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 documentthatyou all went over when Iwas out ofthe office, coveringtech 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 atyour 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 documentthatyou all went over when Iwas out ofthe office, coveringtech corrections? Thanks! Sharon Nizich Minerals and Manufacturing Group OAQPS Sector Policies and Programs Division US EPA Research Triangle Park, NC 

# 919 5412825

16-14-13 

### NESHAP Issue List NESHAP Issues Needing Technical Correction
Issue Concern Desired Outcome Highlights/Next Steps

Application of HCI CEMs The requisite Periodic stack testing should be allowed EPA sensitive to PCA's concerns;

for Those Facilities w/o a performance until EPA has completed work on PS

- 18. Agency will contemplate the PCA

Wet or Dry Scrubber specification is still a stack test alternative

. (§63.1350(1)(1)) work in progress THC Performance Rule only allows for the Add PS-8 as an allowable method. EPA will discuss internally whether Specification use of PS-8A. PS-8 to allow the use of either PS 8 or (§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 explained that it was the
Average"

of term in rule be employed in the rule. Agency's intent to have a single methodology be employed to compute rolling averages and will revisit the issue.

THC Mill-on Testing The phrase: "highest Reference to this term should be dropped This issue is no longer a concern. §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 understands PCA concern

Air

Pollution Control necessary to have all to include the modifying phrase: "subject to with having to turn on ALL HAP

Devices

at Start-up and control devices the design, technical and safety limitations controls regardless of whether it is Shutdown

(§63.1346(g){3) operating during start - of the device and in accordance with the safe or appropriate to do so. PCA

and

§63.1386 (b)(9)) up and shutdown (such facility's operation and maintenance plan." agreed to preparetechnologyas SNCR for NOx) EPA should also clarify that only those specific text for EPA to consider to devices that control NESHAP pollutants are resolve the matter. affected. 1Performance Test Testing frequency Revise testing frequency from annual to 30- EPA will consider the PCA concern Frequency

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

Harmonized months for PM as accordingly. Also, note Regarding the THC preamble and specified

foro-HAP and §63.1349(b)(7)(xii)(B) for THC and rule in consistency, EPA will make

HCI

in §63.1349(b)(7)(vi) §63.1350(i)(2) for by-pass and coal mill the correction to 30-months

.

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 resolved in the

(TWA)

for Mill On/Off o- time weighted average. determination of o-HAP compliance in recently issued EPA guidance.

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 no longer a concern.

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 make the recommended

Testing THC CEMs during o-HAP change, regardless of whether
testing they allow for the use of 8 and 8A

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

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

(

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

S/S. §63.1350(a)(2) dropped. 2requires monitoring data during S/S to be recorded and averaged Emission Standards for Confusion regarding Modify equations to account for There was a lengthy discussion

'

Commingled Sources how to compute commingled sources reflecting the presence regarding this concern with no emission

standards and of by-pass stacks and free standing coal mill clear remedy, other than to document compliance stacks. perhaps address it on a site

- by-site

for commingled sources, basis. EPA will, however, consider including those with by- allowing facilities to monitor at the

pass stacks and separate inlet to a coal mill.

coal mill stacks. §63.1350(k) Mercury Less frequent testing By-pass stack testing frequency should also EPA will consider this request.

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 explained that the Agency did
Testing;

Subsequent on/mill off testing is PM compliance testing in §63

. 1349(b)(1)(ix) not intend for there to be two PM Performance

Testing and required and confirm that subsequent performance limits, raw mill on and off, and Compliance Monitoring (§63.1349(b)(l)(vi) and tests in §63.1349(b)(l)(vi) require one set of that a single TWA should be 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 no longer a concern.

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 no longer a concern. (§63.1341)

in computation of second phrase of definition. 3emission limits Reference to Table 2 Table 2 removed from Either remove §63.1343(d) or re-add Table EPA plans to re-insert Table 2 (§63.1343(d})

regulatory text 2. Improper Table §63

. 1354(a) references Make corrections. EPA will make the corrections. 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 coal mills to the new Alternative

PM limit under inconsistency the should be the same and by-pass stack should source calculation. §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 no longer a concern. 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 intended to use an average of

Using

and HCI CEMs requires the use of the SOzemission value recorded for any 60 the SOz emissions during the HCI (§63.1349(b)(6)(iii)) "highest 1-hr average. minute period during the HCI test. The stack test and then also allow for

This conflicts with adjustment of the SO z operating limit when an adjustment to the SO z §63.1349(b)(8)

which the HCIIevel is below 75% of the standard operating limit when the HCI stipulates the use of the

_ should be added. emissions are 75% below the 4"average of the S02 standard. EPA will clarify. emissions recorded during the HCI stack test." Monitoring S0 2 In

- lieu of The section references Make correction. EPA will correct

.

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 clarified in guidance.

Requirements references Will fix in a technical correction of (§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 i dentified for those There was an extended discussion

the size of "temporary" temporary piles subject to the clean up of this issue. PCA will prepare a

piles

(§63

. 1343(c)(3)) requirement (e

. g., >X tons), The number of proposal for EPA to consider
days allowed for cleanup shou

. ld be addressing work practices for extended from 3 to 7. "temporary" clinker piles and recommend a threshold (size) for "open clinker storage piles

. "

"New"

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

Date

(78 Fed. Reg. 10025) rather than May 6, 2009 2012. NESHAP Issues Needing Clarification
Issue Concern Desired Outcome Applicability of Opacity Opacity monitor i ng EPA should clarify accordingly. Next steps for resolving this issue Monitoring

Requirements should only be required were not clear.

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 extended discussion

(§63 . 1350(k}

, §63.1350(1) unworkable regarding HCI and Hg CEMs 5

### concerns. Additional meetings I 

### with monitoring experts will be considered . Compliance Deadline for Ambiguity in the scope §63.1351(d) stipulates that the compliance EPA explained that the compliance

New Sources 

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

Other

Than Kilns, Coolers 

## source," which focuses or startup, whichever is later. The definition than the kiln, cooler or dryer is

and

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

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

new

equipment such as deadline applies to other new sources, such unchanged from the original transfer points. as, for example, conveyor transfer points. NESHAP

. 6

# 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 forthe link. Iwill most likely incorporateTable under the authority ofourstate rule until Subpart LLL is revised. Thank you foryour 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 itwas 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 ofgeneral counsel that I have one misstatement in the guidance that Iam changing today and that is- afacility is still subject to the Section 111 NSPS (subpart F) even ifthey are burning nonhazardous waste and are now subject to the CISWI NSPS. So notsure if that affects your permitor not. The corrected guidance should be up on the web on MondayJuly 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 /peem/ruleguidancemay2013.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: Iwas incorporating this NESHAP into a Part 70 permitfor a local industry and I noticed atable 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, thistable does not exist in the text ofthe rule. The text I reference is shown below: (d) Emission limits in effect priorto September 9, 2010. Any source defined as an existing source in§ 63.1351, and that was subject to a PM, mercury, THC, D/F, oropacity emissions limit priorto September 9, 2010, must continue to meet the limits shown in Table 2to this s ection until September 9, 2015. 1

# David Matousek Indiana Department of Environmental Management Office ofAir 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 ofonly having those piles that meetthat definition be subject tothe work practice standards. All othercollections ofclinker, temporary or otherwise, would not be subject tothe management standards orthe NESHAP forthat matter. To make this work, EPA would also have to remove the language under Section 63.1343(c)(3), which states: "Temporary piles ofclinkerthat result from accidental spillage orclinker storage cleaning operations must be cleaned up within 3 days." Here is the existing definition of "open clinkerstorage pile": "means aclinker storage pile on the ground for more than 3 days that is not completely enclosed in a building orstructure." Here is a proposed alternative: "means acollection ofclinker, not completely enclosed in a building or structure, created to address the annual fluctuations ofthe construction market and associated cement sales." Michael Pelan responded to my suggestion with the following: 

# I've broken the definition into two parts-- "clinkerstorage pile" and "open clinker storage pile". Clinker Storage Pile: 

# Any location (otherthan silos or bins) within acement manufacturing plant that clinker is temporarily stored after being removed from the manufacturing process but priorto its use in the production of cement. "Open" Clinker Storage Pile: 

# Any Clinker Storage Pile that is not partially orfully enclosed by a building orother structure to protectthe clinker from wind, rain and other deleterious impacts. This can be refined further and/orcombined into asingle definition ifneeded. Mythought**h~re** 

# was to provide adefinition of "clinker storage pile" that could apply to a pile ofany type (totally enclosed, partially enclosed, open). Ialso wanted the definition to specify thatthe clinker could come from any part of the manufacturing process (cooler, silos, etc.) but had to be "removed" with the intention ofstoring it (versus spillage, etc.). While I liked the reference to fluctuations in the construction market and associated cement sales, Ifelt it needed to be left more vague. For example, ifwe clean out asilo and create atemporary pile, this is notto manage clinker for fluctuations. For the "open clinker storage pile" definition, Iwanted to capture partial and full enclosure as not inclusive of regulation underthis rule. 1

# Yourthoughts are most welcome. Regards, Andy 

# Andrew (Andy) T. O'Hare, CAE Vice President, GovernmentAffairs Portland Cement Association 500 NewJersey 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 forthe week ofSeptember 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: ConfCall Keith, David and Sharon, Hope all goes well on your end. Iam writing to see ifwe would arrange atime 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 afew of my members in the discussion. Please let me know when would be convenient on your end overthe nextfew weeks. Thanks, Andy Andrew (Andy) T. O'Hare, 

# CAE Vice President, Government Affairs Portland Cement Association 500 NewJersey 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 ofthe Portland Cement Association and several industry representatives. Discussion centered around attached list oftechnical corrections forthe upcoming Portland Cement amendments.

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

. Issue status
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



## 1 1 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

. Highlights/Next Steps EPA appeared sensitive to PCA's concerns about the timing for completion of PS-18 and will contemplate the PCA stack test alternative. EPA policy question under internal discussion. What is the status of the development of PS-18? PCA will arrange a call to discuss alternative monitoring approaches with EPA. EPA will discuss internally whether
to allow the use of either PS 8 or 8A. EPA plans t<? allow use of 8 or 8A. In

a rule text change?methodology and will revisit the issue. I EPA plans to harmonize the approach for computing rolling averages . How will this be accomplished? In rule or guidance? The approach to computing rolling averages will be harmonized in upcoming proposal.

THC Mill-on Testing The phrase: "highest load Reference to this term should be dropped This issue is no longer a concern.

§63.1

49(b)(7)(xi) or capacity" is vague and here and elsewhere in the rule. Some PCA members remain difficult to demonstrate? concerned about this issue and still believe the reference should be

\ removed. EPA will remove reference to "highest load or capacity" and rely
on representative testing language

in general provisions.

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

Air Pollution Control necessary to have all include the modifying phrase: "subject to the having to turn on ALL HAP controls

Devices at Start-up and control deyices operating design, technical and safety limitations of the regardless of whether it is safe or
Shutdown

(§63

. 1346(g)(3) during start-up and device and in accordance with the facility's appropriate to do so. PCA agreed to **nd;~386{~TI** shutdown (such as SNCR operation and maintenance plan." EPA should prepare technology-specific text for

for NOx) also clarify that only those devices that control EPA to consider to resolve the


# v · 'Q · NESHAP pollutants are affected. matter

.

. The primary concern is the safe operation of air pollution control devices. PCA's preference is for this
to be addressed in the O&M 2guidance. Lafarge is investigating technology specific start-up procedures, to determine whether they may be incorporated into O&M plans. Plant-specific guidance to address this issue is still the desired approach. When to turn on HAP emission control technologies during start-up will be addressed in plant-specific O&M plan. Performance Test Testing frequency should Revise testing frequency from annual to 30- While EPA was sensitive to PCA's Frequency Should be be every 30 months for months for PM. Revise §63.1349{c) concern regarding the Harmonized PM as specified for a-HAP accordingly. Also, note §63.1349{b)(7)(xii)(B) harmonization of performance

and HCI in for THC and §63.1350{i){2) for by-pass and coal testing the agency was ' non- §63.1349{b){7){vi)

and mill stacks, still reference annual test, when committal about making the change §63.1349{c), respectively the preamble specifies a 30 - month frequency

. for PM. Regarding the THC

This needs to be corrected. preamble and rule in consistency, EPA will make the correction to 30- months. I EPA policy question under internal discussion. What is the Agency's I I current thinking on the frequency of PM testing? EPA plans to retain annual PM testing obligation.

Time Weighted Average Unclear that a - HAP is Add time weighted average language to This issue is resolved in the recently

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

' 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. 31348(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 no longer a concern.

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 make the recommended

, ; ng CEMs during o-HAP change, regardless of whether they
testing allow for the use of 8 and 8A. EPA making the necessary change

. How?

.

/ Will be made in upcoming proposal. sirUp/Shutdown §63.1348(b)(l)(ii) §63.1350(a)(2) is no longer relevant, and likely EPA will make the necessary

R

ordkeeping exempts facilities from a holdover from the prior rule, as there are no technical correction.

[) 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 the necessary change.

I monitoring

data during How?

S/S to be recorded and averaged Will be made in upcoming proposal.
Emission Standards for Confusion regarding how Modify equations to account for commingled There was a lengthy discussion

1 ] mingled Sources to compute emission sources reflecting the presence of by-pass regarding this concern with no clear standards and document stacks and free standing coal mill stacks. remedy, other than to perhaps compliance for address it on a site-by-site basis

. commingled

sources, EPA will, however, consider allowing including those with by- facilities to monitor at the inlet to a

pass

stacks and separate coal mill.

coal mill stacks. - 4EPA believes that there is no prohibition on monitoring before the inlet to the coal mill. EPA recommends addressing any remaining ambiguity through alternative monitori ng req u ests

. §63.1350(k)

Mercury Less frequent testing By-pass stack

**~esting** frequency should also be EPA will consider this request.

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

. EPA will make this change. How? Will be made un upcoming proposal.

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

Testing;

Subsequent off testing is required PM compliance testing in §63.1349(b)(1)(ix) not intend for there to be two PM Performance Testing and (§63.1349(b)(1)(vi) and and confirm that subsequent performance limits, raw mill on and off, and that

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

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 clarify. How? averages (TWA) for PM limit should be the average of the three compliance and highest one- q our PM test runs. A cross Will be made in upcoming proposal.

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 no longer a concern.

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 no longer a concern.

{§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 re-insert Table 2 3.1343(d)) regulatory text

I EPA will add the appropriate

-- 5**~** Improper Table References :1 '1

. /" **\'J~\t)** Computation of Alternative v 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 a rule text change? Will be made in upcoming proposal. EPA will make the corrections. In a rule text change? Footnote reference will be corrected in upcoming proposal. EPA will add coal mills to the new source calculation

. While the rule is technically silent on how to specifically account for by-pass stack emissions during a performance test, EPA believes the rule i requ i re

fa ilities to account for the by - a s s

st ck emissions (i.e

. , subtract

**t~m** fro

the total kiln stack emissi o n lim i t to show compliance

. ISSUE SHOU **~OPPED** This issue is

**no l<mge**  **~!J) /**  EPA intended to use an average of the SOz em i ssions during the HCI / 6(§63.1349(b )(6)(iii))

**"h~st** 1-hr average. period during the HCI test. The adjustment of stack test and then also allow for an

This conflicts with the S02 operating limit when the HCIIevel is adjustment to the S02 operating §63.1349(b)(8) which below 75% ofthe standard should be added. limit when the HCI emissions are stipulates the use of the 75% below the standard. EPA will "average of the S02 clarify. emissions recorded during the HCI stack test." EPA policy question under internal discussion . Status?

I EPA still deliberating on

**~et~~** make

this change/ rf'.P **~onitoring** so

, I n-lieu of The section references Make correction. EPA will correct. In a rule text

sing and HCI CEMs THC when it should be change?

/ (§63.1349{b)(8)((vi)) HCI.

I Will be made in upcoming proposal.

A ( ternat i ve Monitoring §63.1350(o)(3) Reference should be to §63.1350(o)(3)(i)-(iii) EPA already clarified in guidance.

I Will

fix in a technical correction of

, l J;equirements references (§63 . 1350(o)) §63 .1350( m )( 3 )( i) rule. Yes? through (iii) Will be made in upcoming proposal. **~** P il es There is no limitation on A size limit should be identified for those There was an extended discussion

the size of "temporary" temporary piles subject to the clean up of this issue. PCA will prepare a

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

\ days allowed for cleanup should be extended addressing work practices for
from 3 to 7. "temporary" clinker piles and recommend a threshold (size) for "open clinker storage piles." This issue continues to be thorny and annoying from a compliance


### A perspective, however, it was agreed that EPA is not likely to be willing to make any substantive changes. PCA 7discussed with EPA the need for a more specific definition of "open clinker storage pile," such that all other collections of clinker that do not meet that definition would not
be subject to the open clinker pile management standards. Proposed alternative definitions shared with Peter T. (will resend). EPA will clarify in guidance that work practice obligation only applies to permanent or long-term clinker piles.

"New'' Source Compliance Should be July 18, 2012, 'New" source trigger date should be July 18, EPA will consider, but did not

Date (78 Fed. Reg. 10025} rather than May 6; 2009 2012. appear willing to change. EPA policy question under internal discussion. Where is the Agency on this issue? EPA does not plan to change date as the emission standards were not more stringent in the 2013 rule compared to the 2010 rule.

•" -- NESHAP Issues Needing Clarification

·' - - -
Issue

Concern Desired Outcome Applicability of Opacity Opacity monitoring EPA should clarify accordingly

. Next steps for resolving this issue

? Monitoring Requirements should only be required were not clear.

for Subpart F only for sources (§60.62(b}(1}(ii)) constructed, EPA will discuss applicability issue reconstructed or with OGC. Status? modified after June 16, - 82008 Needs further internal discussion within EPA.

HCI and Hg CEMs Span issues are TBD There was an extended discussion (§63.1350(k), §63.1350(1) unworkable regarding HCI and Hg CEMs

. concerns. Additional meetings with monitoring experts will be considered . EPA monitoring staff working on I these concerns. Status?. Will be addressed in upcoming proposal. **Complian~e** Deadline for Ambiguity in the scope of §63.1351(d) stipulates that the compliance EPA explained that the compliance

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

Other Than Kilns, Coolers source

, " which focuses on startup, whichever is later. The definition of the kiln, cooler or dryer is upon

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

but not other new raw material dryers. What compliance affecting the other sources are equipment such as deadline applies to other new sources, such unchanged from the original transfer points. as, for example, conveyor transfer points. NESHAP. **~ger** an issue.._

I \ **~** 0 ' 9

# 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 ourconversation. Pis let me know ifyou 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 asupplemental rulemaking and additional guidance and the agency intendsto address many ofthe issues in one way or the other. In a review ofthe issues, itwas agreed that a numberofthem would benefit from further discussions. EPA is considering a meeting with PCA members to that end in theiroffices the week of September 15th and they understand thatthe preference would be for Friday the 19th. Here are specific issues from the list that will benefitfrom 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 orJanuary. Additional information should be shared on two points. First, will afinal PS-18 allow enough time for compliance using CEMS and, ifnot, exactly what will be the problem(s). Second, what are the two orthree key changes needed to the draft PS-18 and what is the cost ortechnical implications ofthose changes notoccurring? • The requirement to have all control devices on during startup and shutdown: Itwill be helpful for PCA to describe the technical problemsthat 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 ofguidance. • 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, ifthat 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 orduration oftemporary piles. Ifthere is avery specific concern, the PCA should be prepared to discuss it. • The applicability ofopacity monitoring underSubpart Fis listed as a "NESHAP" issue. Ifit is a NESHAP issue, that will need further explanation. • EPA intends to reinstate in the NSPS the limits that applied priorto the latest rule changes. However, the application ofthe revised monitoring requirements (monitoring plan) to sources triggering NSPS priorto the rule change was intentional. (A similar action occurred when the use ofCOMS was added to the NSPS.) Ifthis presents significant problems forthe 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 itapply for less than ayear. • The NSPS is not clear as to whetherCPMS is required for demonstrating compliance with the prior PM limitoronlythe new limit. EPA is considering a clarification that the use ofCPMS applies onlyto 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 thatwas submitted by John Holmes ofAEMA (attached). Those in attendance were: Tim Matz, Lehigh Cement John Holmes, AEMS Satish Sheth, CEMEX 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 MichaelToney Candace Sorrell Steve Fruh StefJohnson Ray Merrill

# Proposed Agenda forthe 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 monitoringfortransfer points • Reinstating prior NSPS limits, without CPMS applying retroactively • NESHAP coolerstack flow monitoring • Status and concerns with PS-18 Quick review ofthe remaining items on the PCA list ofJuly 7th Action items coming out ofthe discussion. Key Discussion Topics: • Reconsideration ofthe PM limit • Startup and Shutdown requirements • Requirements for commingled sources Quick review ofthe remaining items on the PCA list ofJuly 7th Action items coming out ofthe discussion.