MEMORANDUM

To: Portland Cement NESHAP Docket

FROM: Keith Barnett, US EPA

Subject: Record of EPA attempts to gather additional THC data from kilns which use

continuous emissions monitors.

DATE: August 1,2010.

Attached to this memorandum is a record of attempts by EPA to obtain additional information on

THC emissions from the Portland Cement Industry in a timely fashion. Here are the key points

supported by this record:

o On August 26,2009, EPA notified the industry of its intent to require additional testing

of THC emissions using continuous emissions monitors under the authority of Section

114 of the Clean Air Act

o On August 26,2009, the Portland Cement Association (PCA) responded to EPA that they

were preparing a THC test plan in response a previous meeting with EPA.

. On October I,2009, EPA gave tentative approval of an industry sponsored test plan that

would obviate the need for a Sectionll4letter.

o On November 3,2009 EPA approved the test plan submitted by the PCA. In that plan

the industry committed to supply the requested data no later than March 31, 2010. In that

approval we requested that facilities submit data to EPA as they collected it. On

November 9, the participating companies also submitted a letter committing their

I "ompanies 

to meet the requirements of the THC test plan

o On February 19,2010 the PCA submitted a status update to EPA that indicated that a

number of plants now had more than 30 days of data. EPA requested to see the data from

those kilns. This request was not met.

o On March 1,2010 EPA again requested to see the data. That request was not met.

¡ On April4,2010 EPA again requested to see the data collected to date, and noted that if

this request was not met we might have to use the data currently available to finalize the

THC standard.

o On April 14, 2010, we again requested to see the data collected to date. That request was

not met.

. April 15,2010, the PCA indicated they would share preliminary results very soon. This

did not happen.
On May II,2010I called Andy O'Hare of the PCA and told him I needed the THC dara

as soon as possible. He stated he thought he could supply the data in a week or two. This

did not happen

o On May 28,2010,I sent an email to Andy O'Hare of the PCA. In that email I stated that

THC data must be received by June 3,2010. Otherwise EPA could not guarantee that the

data would be considered in the final rulemaking. The PCA responded that they would

send the data no later than Ju.ly 7,2010.

The data was finally received by EPA on Jute 16,2010 at 5:45 PM. As noted above, prior to

June 16, no information on the results of testing was transmitted to EPA, despite numerous EPA

requests.
Request for Additional Total Hydrocarbon Testing

curtis. lesslie, leslie.white, lillianf.deprimo,

gina.henry, ruksana.mirza, meg.garakani,

Keith Barnett to: hegtor.ybanez, Michelle.Ferguson,

craig.campbell, michael.pelan, tmatz,

daniel.nugent, ngarnett, lfaciane, sisaacson,

Farr, Jerry, gary.molchan

Cc: "Andrew O'Hare"

081261200911:03 AM

As Peter Tsirigotis mentioned in the meeting between Gina McCarthy and the cement industry on August

13, we believe that obtaining more total hydrocarbon emissions data based on continuous monitor

measurements will potentially result on a better THC standard. We have polled the industry to determine

if they are going to submit more THC data, and the results indicate there are no plans to do so. ln the

August 13 meeting, Peter specifically indicated that he would like to hear from the cement industry on this

issue, but we have not received any communications since that meeting.

As a result, we are planing to send out letters, under the authority of Section 114 of the Clean Air Act,

requiring facilities to install THC monitors and submit at least 30 days of data to us. lt is important that the

results be representative of normal operations. ln the current data set the shortest time peiiod is 31 days,

so I would say a month of readings is enough. lf startup, shutdown, and malfunction periods are includód

they need to be identified. A draft of the letter and survey instrument are attached. We need feedback as

soon as possible on the survey so we can be sure our request is clear. lf anyone currently has any testing

plans, we need to know this so we don't duplicate our efforts. lf the industry has (or is deúeloping) some

acceptable alternative, we need to know now.

I recommend we have conference call this week or early next week to discuss this request.

E4r

THI Data collection t*ttu#tr.unt-Draft-8-28-[9 doc

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-02

Research Triangle Park, NC 27711

91 9-541 -5605

barnett. keith@epa. gov

1|41 _-l

THC Data collection letter-Draft.8-26-D5.doc
Name

Title

Company

Mailing Address

City, State Zip

Re: Requirement to provide information according to Title 42 of the Unites States Code,

Chapter 85, Subchapter I, Part A, section 74I4 (42 U,S.C 7414)

Dear Mr./Ms. fName]:

The U.S. Environmental Protection Agency (EPA) is collecting additional information

about your industry, Portland Cement Manufacturing. This information is for the purpose of

developing standards under Section ll2 (d) of the Clean Air Act for the industry, and assessing

the Section 112(d) standards which EPA has akeady promulgated for the industry. Specifically,

EPA is reconsidering the new and existing source total hydrocarbon standards in the Portland

Cement Manufacturing NESHAP amendments promulgated on Decemb er 20,2007 . See 7l FR

76553. Based on comments raised in the reconsideration, and a recent decision by the D.C.

Circuit Court of Appeals in Sierra Club v. EPA,479 F. 3d 875 (2007), EPA is gathering data to

better assess the variability of total hydrocarbon emissions for individual kilns,

We are requesting this information under the authority of Section 114 of the Clean Air

Act (CAA) (42 U.S.C. section 7414), and, as also authorizedby Section 1 i4, require that you

send the requested information to us by 90 days from the receipt of this letter. Specifically,

Section 1la (g) allows EPA to require source owners to furnish "such other information as the

Administrator may reasonably require". Because this information relates directly to a critical

issue for the Portland Cement Manufacturing NESHAP, namely the amount of intra-kiln

variability associated with hydrocarbon emissions from Portland cement kilns, it is reasonable to

require Portland cement facilities to generate and submit this information.

In the enclosed survey, we request information on emissions of total hydrocarbons (THC)

from your cement kilns. We are requesting the emissions be measured using a total

hydrocarbon continuous emissions monitor (CEM) that meets the requirements of PS-84. If

you do not currently have a THC CEMS installed on your kilns, we are requesting you install a

THC CEMS to provide this data.

As noted in Enclosure 1, we are requiring the THC data be provided for each facility

operated by your company. For facilities with multiple kilns, you must test each kiln.

Detailed instructions are included within the enclosure. Using the information you provide to

us in these surveys, along with similar information we receive from other companies in your

industry, we will update our data base of total hydrocarbons emissions information.

Enclosure 2 contains a summary of our legal authority in Section 114 of the CAA to

obtain the information requested in these surveys. If you believe that providing any specific

information to us would reveal a trade secret, please identify this information clearly in your
response. However, please do not label your entire response "Confidential" if only a portion

includes trade secrets. You can see in Enclosure 2 the type of information that EPA may ask of

you at alater time to prove that any information you have so identified is truly confidential.

Any information determined to be a trade secret will be protected by 18 U.S.C. 1905. If you do

not claim as confidential any of the information in your returned survey, we can make this

information available to the public without notifying you further (40 CFR Part2.203,

September l,1976). Because Section 114 of the CAA does not allow emission data to be

claimed as confidential, the emission data you provide to us can be made available to the public.

A detailed explanation of what we consider to be emission data is contained in Enclosure 3.

We have contracted RTI International (RTI) (Contract No. EP-D-06-1 18) to help us

gather information about your industry. As noted in Enclosure 4,we have designated RTi to be

our authorized representatives. Therefore, RTI has the same rights discussed above and in

Enclosure 2 as EPA has. This means that RTI will have access to all information provided to us

in your completed survey. As a designated representative of the Agency, RTI must, by law, also

abide by the requirements of 42 U.S.C, 7al4@) in regard to the confidentiality of what you claim

to be trade secrets.

Enclosure 5 summarizes our policies and procedures for handling trade secret information

and describes how our contractor also is required to use the same procedures as we do. Because

our contractors or other authorizedrcpresentatives are required to follow the requirements in

Enclosure 4, we believe that we can ensure your rights and protect any privileged information

you submit to us.

If you have questions regarding the need for this survey or need clarification on the

information we are requesting, please contact Mr. Keith Barnett with EPA's Office of Air

Quality Planning and Standards at 919-5 4I-5605 (e-mail barnett.keith@epa.gov). As we have

previously discussed, it is natural that questions will arise, and EPA will work with affected

plants to mutually and reasonably resolve these questions.

Please return the completed survey form(s) to Mr. Barnett at the address by 90 days from

the receipt of this letter. However, if you can not meet this date due to unavoidable delays

(such as a plant outage) we will grant an extension. Should you need an extension, please lease

contact Mr. Barnett by phone or email with an estimated completion date and the reason(s) for

the unavoidable delay. Mr. Bamett's address and other contact information are:

Mr. Keith Barnett

US EPA Mailroom (D243-02)

United States Environmental Protection Agency

Office of Air Quality Planning and Standards

Research Triangle Park, NC 27711

919-s47-560s

B arnett. kei th@ep a. gov
I am sure you rmderstand how important it is for the EPA to use the very best information

available to develop the most meaningful standard. Yourhelp in providing this information is

greatly appreciated.

Peter Tsirigotis

Director, Sector Policies and Programs Division

OfÍice of Air Quality Planning and Standards

5 Enclosures

cc: State AQM Office

U.S. EPA Region (w/o Enclosures)
Enclosure 1

PORTLAND CEMENT MANUFACTURING

THC EMISSIONS INFORMATION COLLECTION

GENERAL INSTRUCTIONS

Please provide the information requested below. If you have other relevant information

that would assist us in interpreting the total hydrocarbon information we are requesting please

provide this information as well. Use additional copies of the request forms, as needed, for your

response.

If you believe the disclosure of the information requested would compromise a trade

secret, clearly identify such information as discussed in the cover letter. Any information

subsequently determined to constitute a trade secret will be protected under 18 U.S.C. 1905. If

no claim of confidentiality accompanies the information when it is received by EPA, it may be

made available to the public by EPA without further notice (40 CFR 2.203, September I,1976).

Because section 11a(c) of the Clean Air Act exempts emission data from claims of

confidentiality, the emission data you provide may be made available to the public, A definition

of what the EPA considers emissions data is provided in 40 CFR 2.301(a)(2)(i) and in

Enclosure 3.

We are requesting for each cement kiln at each of your Portland cement manufacturing

facilities at least 30 days of THC emissions data measured using a continuous emissions monitor

(CEMS). The monitor should be installed and certified according to protocol PS-84 of

Appendix B to 40 CFR Part 60 or the equivalent. V/e also need to know the fuels fired during

that period. If the types of fuels varied, we also need to know during what time periods the

different fuels were fired, and any other variations in kiln operating parameters that may have

affected THC emissions. If the data you provide include periods of startup, shutdown, or

malfunction, these periods should be indicated in your response.

Please include in you data submission the following information:

. ppm THC measured as propane
. ppm THC measured as propane, dry basis

. oxygen content of the exhaust gas at the THC measurement location

. ppm THC measured as propane, dry basis, corrected to 7 percent oxygen

If you have kilns that have been shutdown temporarily due to maintenance or low

demand for cement, we are not requiring at this time that you restart these kilns only to comply

with this information request. \ùy'e are requiring you to provide us a list of anl¿ kilns )¡ou cannot

Please identify the specific kiln where the measurements were obtained using the same

naming system as you used on your response to our previous request for information dated May

8,2007 . Also identify any controls or work practices used to reduce emissions of THC for each

kiln for which you submit data, unless the controls are unchanged from your previous response.

If you are submitting information for a new kiln that was not included in your previous response,

please fill out the general facility information form below for any such new kilns.

Questions regarding this information request should be directed to Mr. Keith Barnett at

(91e) s41-s60s.

Return this information request and any additional information to:

Mr. Keith Barnett

U,S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Mail Code D234-02

Research Triangle Park, North Carolina 277I1

GENERAL INFORMATION FOR NEW KILNS WHERE YOU HAVE NOT PREVIOUSLY

SIIBMITTED THIS NFORMATION

L Name of legal owner of facility:

2. Name of legal operator of facility, if different from legal
owner:

3. Address of legal owner or_operator:

4. Complete street address of facility (physical

location):

5. Provide facility mailing address if different from physical location:

6. Name and title of contact(s) able to answer technical questions about the completed

survey:

7. Contact(s)telephonenumber(s):

and e-mail address(es):

8. What fuels are fired in the cement kilns (if you have multiple kilns at this facility, note

which kilns bum which fuels)

coal pet coke TDF _ natural gas other

(specify___________-)

9. If coal is fired, indicate which type of coal is utilized:

- 

lignite 

- 

subbituminous (including waste coal)

- 

bituminous (including waste coal or gob) _ anthracite (including waste coal or culm)
i0' Kiln identification (or designation), design kiln capacity (tpy of clinker production) for each kiln located at this facility (do not include any kilns that burn hazardous waste).

Kiln ID

Design kiln

capacrty

(Tons per

year)

Does this kiln have an alkali

blpass? If so, what percentage of

the exhaust goes to bypass?

Kiln Type

(Wet, long dry, preheater,

preheaterþrecalciner)

Does the kiln have an in-line raw

mill? If so, what percentage of the

time does the raw mill operate?
1 1. For each kiln noted in Part I, question 10, provide the following information:

Kiln ID NO* controll S02 control2 PM control3 THC/VOC controla

lExamples: low-NO* burners; selective catalytic reduction (SCR);

selective non-catalytic reduction (SNCR)

'Examples: wet flue gas desulfurization (FGD; any type); dry scrubbing

(any type); compliance (low sulfur) coal 3Examples: fabric filter; cold-side electrostatic precipitator (ESp)

a Examples: thermal oxidizer; carbon injection
Page I of2

FW: Request for Additional Total Hydrocarbon Testing

O'Hare, Andrew

to:

Keith Barnett

08/26/2009 12:47 PM

Show Details

History: This message has been forwarded.

Keith,

Just left you a voicemail about this draft data collection request. As I indicated in my voicemail message,

following the meeting with Gina and Peter we agreed to prepare a test plan to collect more THC data which we

had every intension of sharing with EPA in advance of a meeting to discuss. I think it would be preferable to

discuss how best to incorporate the thoughts of the anticipated plan (expected any time now) into any 1 14.

We are ready and willing to have a call as soon as it can be arranged to discuss our intensions and their

relationship to a 114.

Please let me know when you would be available for such a call.

Thanks,

Andy

Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

500 New Jersey Avenue, N.W., 7th Floor

Washington, DC 20001

PH: (202) 408-9494

FX: (202) 408-0877

CELL: (202) 270-0094

e-mail : aohare@cement.org

From: Barnett.Keith@epamail.epa.gov fmailto:Barnett.Keith@epamail.epa.gov]

Sent: Wednesday, August 26,2009 11:03 AM

To: cuttis.lesslie@ashgrove.com; leslie.white@cemex.com; lillianf.deprimo@cemex.com; gina.henry@cemex.com;

ruksana,mirza@holcim.com; meg.garakani@holcim,com; hector.ybanez@holcim.com;

Michelle,Ferguson@holcim.com; craig.campbell@lafarge-na.com; michael,pelan@lafarge-na.com;

tmatz@htcnam.com; daniel.nugent@buzziunicemusa.com; ngarnett@b<i.com; lfaciane@b<i.com;

sisaacson@calpotland,com; Farr, Jerry; gary,molchan@essroc,com

Cc: O'Hare, Andrew

Subject: Request for Additional Total Hydrocarbon Testrng

As Peter Tsirigotis mentioned in the meeting between Gina McCarthy and the cement industry on August 13, we

believe that obtaining more total hydrocarbon emissions data based on continuous monitor measurements will

potentially result on a better THC standard. We have polled the industry to determine if they are going to submit

more THC data, and the results indicate there are no plans to do so. ln the August 13 meeting, Þetei specifically

indicated that he woLild like to hear from the cement industry on this issue, but we have not received any

communications since that meeting.

As a result, we are planing to send out letters, under the authority of Section 114 of the Clean Air Act, requiring

facilities to install THC monitors and submit at least 30 days of data to us. lt is important that the results be

representative of normal operations. ln the current data set the shorlest time period is 31 days, so I would say a

file://C:\Documents and Settings\kbamett\Local Settings\Temp\notesFCBCEE\-web9254.htm 81112010
Page 2 of 2

month of readings is enough. lf startup, shutdown, and malfunction periods are included they need to be

identified. A draft of the letter and survey instrument are attached. We need feedback as soon as possible on

the survey so we can be sure our request is clear. lf anyone currently has any testing plans, we need to know

thissowedon'tduplicateourefforts. lftheindustryhas(orisdeveloping)someacceptablealternative,weneed

to know now.

I recommend we have conference call this week or early next week to discuss this request.

Keith W. Barnett

USEPAJOAQPS/SPPD/MMG

Mail Code D243-02

Research Triangle Park, NC 27711

91 9-541 -5605

barnett.keith@epa. gov

file://C:\Documents and Settings\kbamett\Local Settings\Temp\notesFCBCEE\-web9254.htm 8lIlZ0I0
Draft THC Data Colllection Plan

O'Hare, Andrew

to:

Keith Bamett

08128/24A9 01:23 PM

Show Details

History: This message has been forwarded.

Keith,

Attached please find a draft THC data collection plan. We will discuss with you on the call later this afternoon,

Regards,

Andy

Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

500 New Jersey Avenue, N.W., 7th Floor

Washington, DC 20001

PH: (202) 408-9494

FX: (202) 4A8-0877

CELL: (202)270-0094

e-mail: aohare@ceme_ nt o¡g

file:/iC:\Documents and Settings\kbarnett\Local Settings\Temp\notesFCBCEE\-web8095.htm 81T12010
August 28,2009

8-28-09

PCA Plan for Supplementing the MACT Decision Making Record

With Additional THC CEMS Data

Backsround

In December 2006, EPA finalized its rulemaking for a revised PC MACT. At the

same time the rule was published in the Federal Register, EPA also published a second

notice advising that it was reconsidering the rule.

Due to continued pressure and court actions by those challenging the rulemaking

and the timeliness of EPA's efforts to issue a final rule, in March 2007, EPA set out a

Section 114 notice to the nine largest cement companies requesting that they provide

emissions data for mercury, THC, and HCl. EPA sent the request to only nine

companies, because requesting information from the entire industry would have required

time consuming procedural steps that would have slowed down the data collection

process. EPA was therefore limited to collecting information from less than ten

companies via the Section 114 process.

Those companies represented only 89 of the 167 PC MACT kilns in the United

States at the time. The Section 114 request mandated that facilities collect raw material

and fuel samples for 30 consecutive days in June 2007, and have them analyzed, for.

mercury and total organic carbon (TOC). EPA planned to use these data to develop

material balances needed to estimate mercury and THC emissions from cement kilns. In

addition to the raw material and fuel sampling, EPA also requested that these companies

provide all stack testing and CEMS data in theii possession related to mercury, THC, and

HCl. All data was collected and submitted to EpA prior to the end of 2007 .

EPA reviewed and analyzed the data provided by the cement industry for several

months. Near the end of 2008, EPA concluded that they could not effectively estimate

THC emissions from the TOC data provided (because they did not request stack testing in

conjunction with raw material testing), and instead, decided to rely on the THC CEMS

data provided by approximately 1 1 plants (14 kilns), These data consisted of less than 30

days to, in very few cases, more than 2 years of data. EPA then ranked these data, and

using a MACT basis of the average of the best l2Yo performing units with CEMS data,

established a THC MACT floor for kilns and raw material dryers relying on an average

of the two lowest emitting kilns. No data was collected for raw material dryers.

Current Status of Available Data

Since the time of the submittal of the Section ll4 data, all of the sources that

reported THC CEMS data have collected additional data. These data will be submitted to

EPA as part of PCA's comments on the proposed rulemaking. Based on PCA's analysis

of this longer term data, PCA believes that EPA will be comfortable that there is enough

THC CEMS data to develop a defensible floor for most of the industry. In the next
August 28,2009

couple of days, PCA will send to EPA this data and will welcome the opportunity to

discuss the data with you.

PCA has analyzed this longer term data (now all > 1 year in duration) from 5

kilns along with data provided by EPA for other kilns not included in the original Section

ll4 data request, to determine a revised MACT floor. The analysis shows that there is

sufñcient data to establish a MACT floor based on the 99th percentile. Using the data,

PCA will propose a THC MACT floor in its comments to the proposed rule. Further

THC CEMS data from a random selection of kilns will likely not impact a MACT floor

analysis beyond the data currently being reviewed, and PCA believes that gather of such

data will not be helpful to EPA and will impose an unnecessary burden on the industry,

The data does not show, however, whether the limestone reserves available to

units in the existing data pool or other units have significant variations in the nature and

amount of organics. To address this uncertainty, PCA welcomes the opportunity to work

with EPA on conducting an industry-wide effort to gather more THC CEMS data to

address this issue and possibly provide support for subcategories given the variations in

the raw materials. Such a focused effort to gather longer term THC CEMS data is

warranted for several reasons:

o It is likely that the high THC levels for some kilns can be attributed to a

combination of the level of organics in the limestone, the form of the organics in

the limestone and a kiln configuration that has one or more source of organic

releases downstream of the kiln (in particular in-line raw mills and in-line coal

mills venting to the main stack,) While a few of the units with THC CEMS have

high THC emissions, the data on limestone organics have not been collected or

correlated to these kiln emissions.

o EPA has assumed the stand alone raw mills and coal mills operated on kiln gases

should meet the kiln THC limit, but EPA has no data to show that this is an

appropriate extension of kiln THC measurements. We have limited data that

suggests that these units have low volume, higher THC emissions than kilns.

o Separate standards (which could be a subcategory or distinct affected source) for

stand alone raw mills operated with supplemental fuel firing, raw material dryers

and those kilns with high THC levels due to organics in the co-located quaruy may

be appropriate. This cannot be done without a strong database of THC CEMS

readings and feed material characteristics supporting the best possible

presentation on the need for one or more added subcategories for THC limits.

o However, for stand alone raw mills that use supplemental fuels and coal mills that

use kiln or cooler gases, there is no data to suggest that organic HAPs are even

emitted.

THC Monitoring Program Goals

The first goal of the testing program is to gather sufficient kiln THC emissions

CEM data and raw materials organics characterization data (over several months) such

that PCA can determine if there is a basis for one or more subcategories for high THC

emissions kilns related to the characteristics of the limestone. Furthermore, where either
August 28,2009

coal mill and/or raw material dryer exhaust are po-mingled with the kiln stack emissions,

it is important to determine whether either case waffants subcategorization. The second

goal will be to collect organic HAP data for stand alone raw material dryers and coal

mills that use kiln gases for drying to determine whether these sources emit organic

HAPs. If it is determined that these sources emit significant HAPs, then CEMS

monitoring may be necessary to establish a floor. Prior to commencing such an

investigation, PCA will statistically design the project to ensure all elements are included.

Program Approach

Once candidate plants have been identified, member companies will install CEMS

and gather raw material samples and complete analyses consistent with a standard project

protocol. PCA will hire a third-party contractor to oversee the testing program, working

with the individual firms on completing the monitoring activities and then interpreting the

data. Each of the selected facilities will be required to install a THC CEMS at their own

expense and collect data for at least 6 months. In parallel, the limestone will be analyzed

during the same period for organics content as well as the level and nature of releases

during grinding and drying.

Proposed Schedule

As you know, the majority of PCA's and its member companies'efforts are

currently focused on preparing comments on the proposed rule, which are due next week,

By September 15, PCA will develop a proposed test plan for EPA review. PCA is

committed to working with EPA to ensure that the test plan is supported by EPA and the

scope and objectives are clearly established and known to all parties. After obtaining

EPA's conculrence on the scope and schedule of the study by September 30, PCA will

initiate testing with the expectation of providingdatato EPA in the spring of 2010.
Page 1 of 1

THC Test Plan

O'Hare, Andrew

to:

Keith Barnett, Peter Tsirigotis

09115/2009 09:24 ANI

Show Details

Keith and Peter,

Attached is the latest version of the THC test plan for your review and consideration in advance of the conference

call to discuss the details. Please let me know when would be a good time for a one hour call to move this

process fon¡,¡ard.

Regards,

Andy

Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

500 New Jersey Avenue, N.W., 7th Floor

Washington, DC 20001

PH" (202) 408-9494

FX: (202) 408-0877

CELL: (202) 270-0494

e-m a il : aoh a rq@cementctg

flrle://C:\Documents and Settings\kbarnett\Local Settings\Temp\notesFCBCEE\-web0313.htm 8lIl20l0
PCtu

:ì:;¡'tì.; i li.i i''erri'¿iti- Âs5 * ti¿liall

September 15,2009

Design of the PCA THC Sub-Categorization Study

In comments to the EPA dated August 28,2009, the Portland Cement Association (PCA)

proposed to collect additional data to determine whether subcategories should be established for

the THC limit under the MACT standards applicable to Portland cement facilities. For the limit

applicable to the kiln exhaust, consideration will focus on a potential subcategory for units with

inherently high THC emissions. The high emissions may be related to the composition of the

raw materials, including the level and/or form of organics in the limestone and shale, the

inclusion of raw mill, raw material dryer or coal mill exhaust in the main kiln exhaust and the

kiln type. In addition, there is concern regarding EPA's proposal that standalone raw material

dryers meet the same THC standard as kilns.

Because the existing data on THC emissions and raw material organic content are insufficient to

resolve these issues, the PCA sub-categorization study will collect emissions data on a

substantial sample of kilns, along with characterizingthe limestone and shale inputs to the kilns.

The data should be adequate to determine the need to establish subcategories (where appropriate)

and, if possible, to estimate MACT standards for such subcategories. The data should also be

adequate to determine whether standalone raw material dryers emit a significant amount of

organics HAPs and warrant a specific THC limit.

This paper discusses some of the key considerations in the design of the samples for this study,

organized into two investigations: Kiln Sub-Categoñzationfor THC, and Standalone Raw

Material Dryer Organic HAPs Assessment.

Kiln Sub-Catesorization for THC

After review of the existing data on kiln emissions and operations, PCA members have identified

three primary factors that may lead to the need for sub-categorization of the THC limit:

o Kiln type, divided into three major groups: (1) long kilns (wet or dry), (2) pre-heaterlprecalciners or preheaters with in-line raw mills, and (3) pre-heaters or

preheaterþrecalciners without inline raw mills. For example, long kilns may be

distinctive from others because of the temperature profile that the raw material

experiences. Units with in-line raw mills may have higher THC emissions due to losses

during grinding.

o Commingling of coal mill or raw material dryer exhaust with the kiln exhaust increases

the loading of the kiln exhaust with THC relative to a kiln with a stand alone coal mill or

raw material dryer.

¡ Beyond process t1pes, the types of organic materials within the limestone and shale will

directly influence THC emissions. Therefore, it is important to characterize the types of

organic materials within the limestone and shale by the level of organics liberated in the

so-called evolved organic matter or off-gassing test as well as the level of organics

liberated during grinding.
One of the challenges of this investigation is to create a workable number of test categories. The

proposed sample design for kiln sub-categorization is to stratify with 12 cells -- 3 (kiln type) x 2

(with or without commingled mill/dryer exhaust) x2 (high or low organics raw materials). Work

is underway to characterize the full kiln population for kiln type and the presence of commingled

mill or dryer exhaust. This should be doable for most of the kiln population. What is more

diff,rcult is determining which kilns have high emissions of THC and therefore are in the high or

low emissions planes of the 3 x 2 x 2 cell structure. Even if it is not possible to obtain data to

charccterize the entire kiln population according to technology and emissions, it is expected that

sufficient information can be obtained to determine which of the 12 cells are signihcant and to

support recruitment of kilns for the study.

Limestone and shale are not sufficiently characterized in existing data with respect to the nature

of the organics influencing THC emissions, nor has such composition data been correlated with

kiln emissions to understand the role of organic composition in THC emissions. There is

considerable data on Total Organic Carbon in raw materials but that has not been helpful in

determining high emitters. Thus, it is not possible based on existing data to cleanly determine

which kilns have compositional factors leading to high or low emissions. Instead, surrogate data

must be used to recruit and assign units to the high or low emissions planes as best as possible.

For example, kilns for which existing CEMS or stack testing show high (or low) emissions

compared to the average will be clear candidates for the high (or low) emission planes.

Qualitative information from kiln operators can also be used to assist in this classihcation and a

quick survey is in progress. Because little is known about the role of material composition on

THC emissions, the study will have to rely on the existing data and make reasonable choices for

the sample, with the expectation that the resulting sample will have sufficient variation in the

compositional factors to prove useful for the analysis.

A number of factors will be considered in selecting the total sample size for the study and

determining its allocation among tbe 12 cells. The statistical considerations in sample size

determination and allocation relate to obtaining satisfactory coverage of the population and

enough data to provide sufficient statistical po\¡/er. Once all of the analytical considerations are

applied, the total sample size should be one that is: proportionate to the importance of the

problem it addresses; and appropriate given the state of the art in the area (neither too small to

provide useful answers, nor so large as to be a poor allocation of resources). These are not

statistical considerations, but rather management considerations to judge the soundness of the

project in the real world.

In this study, the sample size cannot simply be allocated by cell in proportion to the distribution

of the US kiln population, because the study is to answer questions on whether individual cells

differ statistically from other cells. Instead, a minimum sample size will be set for each cell for

which separate analysis is desired. This approach leads to a stratified sample that is distributed

in a manner that differs from the distribution of the kiln population. As a practical matter, 3 units

will be the minimum sample size for each cell, because 3 units is the smallest sample that

permits computation of confidence intervals and also permits the identification of an erroneous

data point (an outlier) in comparison to the other data points. A larger sample is generally

desirable in each cell, but may not be possible given time and resource constraints and kiln

availability.
With 12 total cells in the sample design, a minimum of 36 units is implied for the overall sample

size, which would be a large study involving a major commitment of resources industry-wide

and participation by 20 percent of the 167 kilns in the US. It is likely that the total sample size

will not be this large because it is unlikely that all cells are represented in the US kiln population

or will justify separate analysis. The sample selection will start with a targe| of 3 kilns per cell

and then apply the following considerations to select the final design and sample size:

. , Cells not represented in the US kiln population are obviously dropped from the study

design entirely

o If cells are represented by only I or 2 kilns in the entire population (or at least the portion

of the population that can be characterized), then it is not possible to obtain a sample of

more than I or 2. Even if there are more than 3 units in the population, it may not be

possible to recruit a sample of 3. One challenge for this study is the fact that the

downturn in the economy has cause a number of kilns to not be in operation on a

continuing basis in 2009.

o For cells representing avery small number of kilns, itmay or may not be appropriate to

retain the cells in the sample design. If the available information indicates that the kilns

all have low emissions, then there may be no benefit to including the cell in the study.

On the other hand, if available information indicates that kilns are technologically unique

or likely to have distinctive emissions characteristics, then the cell could be retained in

the study, and one could consider whether to increase the sample for that cell to more

than three.

o It is likely that a small number of cells in the sample design will be found to represent a

majority (perhaps alarge majority) of the US kiln population. For these cells, we will

consider increasing the sample size above the minimum of three so that the data set has

greater power for detecting emissions differences. An increase of sample size from 3 to 5

kilns narrows the 95o/o confidence interval for the cell by 19 percent.

o Finally, one can take advantage of circumstances that permit increasing sample size aI

low cost - for example, by adding kilns that have pre-existing CEMS, one can contribute

to the study at the cost of the limestone and shale composition testing only.

To judge how the sample is allocated, one wants to know how much power the resultin g data

will have for detecting differences among cells and for supporting the establishment of subcategories. Power is simply the ability to detect the presence of an effect of a given size. A

powerful dataset could detect a small effect with strong statistical significance. A less powerful

dataset could detect only a larger effect with the same significance, and it might fail to detect the

smaller effect, when actually present.

The most common statistical test performed in the sub-category analysis will be to determine if

mean emissions in one cell (or group of cells) are statistically different from those in another cell

(or group) at a stated confidence level. This test depends on the variances of the means in each

cell (or group), which in tum is based on the length of the test period and the differences in

emissions across units. Typical variances can be estimated from the existing CEMS data and

then can be used to determine whether an effect of X percent in size can be detected with a

sample of size N units. This can be summarizedin a curye that gives the smallest detectable
effect as a function of sample size, which can be used to judge the adequacy of the proposed

sample allocation.

The nature of the sub-category analysis is that it will look broadly for evidence that one or more

cells, or groups of cells, show statistically significant evidence for differences in emissions

compared to other cells or groups. It will also look broadly at the question of how material

composition affects emissions and whether that relationship varies with technology. It will not

simply test whether each cell is statistically different than other cells. When many cells are

grouped together, the available sample size is greater and the dataset becomes more powerful for

identifying differences. The sample size and power are smaller when the differences being

examined pertain to only a few cells.

The outcome of the sub-category analysis may take a number of different forms:

o To recommend establishing a sub-category for one or more individual cells, because the

collected data demonstrate that the kilns in the cells are distinctive and significantly

different than other kilns with respect to THC emissions.

o To recommend establishing a sub-category for a group of cells, because the data

demonstrate that the group, taken as whole, is distinctive and signihcantly different than

other kilns, while finding no evidence to support subdividing kilns within the group.

o To demonstrate the relationship between material composition and THC emissions and,

based on that relationship, recommend establishing sub-categories for kilns facing

distinctive and significantly different material compositions that lead to higher emissions.

Materials-based sub-categories could be defined solely by the composition of materials

used by the kilns or by a combination of material composition and kiln type, where it is

found that the materials effect is important in only some kiln t1pes.

PCA's proposed study will require that THC CEMS be installed on participating units and that

data be collected for periods of at least 6 months, with data from the hrst 3 months used to

provide EPA will a preliminary assessment of sub-category potential. It is important that the

data collection period be long enough to adequately charactertze the variance in emissions, both

because the variance is an important factor in setting the MACT floor and because a higher

variance in emissions might itself be a basis for establishing a sub-category. The existing data

submitted to the EPA docket can be used to examine this question by plotting the variance in 30-

day average emissions versus the length of the time series used to compute it. Generally, PCA

has found that the variance increases as the time series length increases (and there is more chance

for a variety of factors affecting emissions to come into play) before tending to stabilize (with

continuing fluctuations) around some level. One wants to collect data for a long enough period

of time to allow the variance to approach or reach its full and stabilized value.

To move forward with the sub-categorization study, the following steps are being taken:

o PCA is preparing a profile of all the kilns as to type and the presence of commingled coal

mill or raw material dryer exhaust to see how many units are in the 3 x 2 technology

cells. This is being done by amending the kiln inventory from EPA and adding codes for

coal mills and raw mills as follows:
Coal Mills

L Stand alone stack

2. Vented to a kiln stack

Raw Mills

1. In line or vented to the kiln stack

2. Stand alone stack

o The next step is to characterize the kiln population for THC emissions. PCA has created

two categories for this purpose: THC emissions below 50 ppm and THC emissions over

50 ppm. Where available, CEMS and stack test data will be used to classify kilns.

Additionally, PCA members have been asked to classify each of their units as high or low

emitters to the extent they are able with any testing for VOCs or THC they may have

done. Use this input, we will stratify each technology cell into expected low emitter,

expected high emitter and unknown.

o PCA is preparing the protocol for generating data, including specifications for THC

CEMS and testing of shale and limestone (and coal if the commingled exhaust is from a

coal mill). The raw material testing will be a combination of ofÊgassing organics

quantification and grinding loss testing using a method developed recently by FLS.

Standalone Raw Material Dryer Organic HAPs Assessment

EPA has proposed that standalone raw material dryers and raw mills that remove moisture from

the feed material meet the kiln THC limit, without data to substantiate that the assumption is

appropriate'. A se"ottdpartof the study is to test a sample of raw mills and raw matárial dryers

to determine their emission characteristics. One hypothesis is that these standalone units do not

generate any significant organic HAP emissions.

This part of the study involves establishing a separate sample of standalone mills and dryers and

measuring their organic HAP and THC emissions. Stack testing will be performed, rather than

installing a CEMS for THC. When stack testing is used, a total of 3 back-to-back tests will be

performed. The organic HAPs to be measured will be those listed in the THC limit alternative

compliance method in the proposed ru1e2.

Many of the same considerations of sample design and selection are encountered here, and the

discussion given for the sub-categorization sample applies. The primary difference is that the

sample drawn for this part of the study will be stratified for only two technology types: raw

material dryers and raw mills. As a result, one will not build up the sample from individual cells

consisting of at least 3 units each. Instead, we are planning on a sample of at least 5 mills that

t All inlitte and stand-alone coal mills that vent to the atmosphere are regulated by Subpart Y. However, PCA has

requested a Subparl Y exemption for inline coal mills where gases are vented through the kiln main stack. PCA

believes that such kilns should be regulated under Subpart LLL.

'Thore organic HAPs are formaldehyde, benzene, toluene, styrene, m-xylene, p-xylene, o-xylene, acetaldehyde and

naphthalene.
meet the def,rnition for dryer and 5 true dryers. A sample of 5 in each category allows for

improved confidence intervals (compared to a sample of 3) and will permit useful analysis to be

done even if data on 1 or 2 units were to be compromised in some manner.

It is useful to consider the sample size in the following way, If the question is posed as

determining whether organic HAP emissions from raw mills or dryers are significant, there are

three different outcomes that are possible from a given sample size:

o One finds that the estimated emissions are too small in some sense to be meaningful or of

concern. Given the variance, one concludes that there is no evidence that standalone

units have significant organic HAP emissions. This is a conclusive result.

. One finds that the estimated emissions are large enough to be meaningful and, given the

variance, one concludes that standalone units do represent sources of organic HAP

emissions. This is also a conclusive result, and it comes about when the estimated effect

(emissions increase) is at least 1.96 times the standard deviation (for a 95% confidence

interval, two-sided).

. One finds that the estimated emissions are large enough to be meaningful, but the

variance is high enough to prevent finding that they are statistically significant. This is a

less conclusive result, but one that could be changed through more testing.

The primary risk posed in selecting atotal sample size is always that it is insufficient to achieve a

conclusive result. It is impossible to guarantee that a given sample size will be adequate (to do

so would require knowing the answer before conducting the study). Whatever sample size is

used initially, the risk of an inconclusive result may be remedied by extending the testing to

include more units over a longer period of time.

Next steps with this part of the study will be:

o PCA is surveying its members to find standalone raw mills and raw material dryers.

o PCA is developing a test protocol. The plan will address the organic HAPs listed in the

THC compliance alternative in the proposed rule and the test methods will be those

recommended in the PCA comments on that compliance alternative.

Other Considerations

PCA and its members are committed to the conduct of this study but we face a number of

challenges. First, with the current economy, a number of kilns will not be operating this winter

when data gathering is to occur. Second, we believe that we can secure the necessary number of

THC CEMS but we have not been able to confirm this with the vendors. Lastly, this study will

be costly. The installation and operation of the THC CEMS is expected to cost between S10,000

and $30,000/month depending on the existing monitoring capability at the kiln and the onsite

staff expertise. Raw material testing will be an additional cost but those costs have not been

determined. The organic HAP testing for mills and dryers is expected to run between $25,000

and $50,000 per unit.

In the interest of time, this study design is being submitted to EPA for comment. While it is

under review, PCA will begin completing the tasks listed above and recruiting participants in the

study.
Re: THC plan J

Keith Barnett to: O'Hare, Andrew 10/01/2009 04:35 PM

Yes.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

Mail Code D243-02

Research Triangle Park, NC 27711

91 9-541 -5605

barnett. keith@epa. gov

O'Hare, Andrew Keith, I got your message this afternoon regardi... 10101t2009 04:31:00 pM

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

To: Keith BarneIURTP/USEPA/US@EPA Date: 1010112009 04:31 PM Subject: THC plan

Keith,

I got your message this afternoon regarding the THC test plan. We are busy identifying facilities for the

various cells reflecting the September 15'n version of the plan we discussed with you a week or so ago.

Regarding the draft plan, when we discussed it most recently, you indicated that you were going to review

it in greater detail and then get back to me with a "thumbs up" or "thumbs down." Should I take your

message today as being a "thumbs up" to proceed as outlined in the 9li5 draft?

Thanks,

Andy

Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

500 New Jersey Avenue, N.W., 7th Floor

Washington, DC 20001

PH: (202) 408-9494

FX: (202) 408-0877

CELL: (202) 270-0094

e-mail : aohare@cement.orq
Re: THC plan *ì

Keith Barnett to: O'Hare, Andrew 1010112009 04:39 PM

Yes proceed as outlined in the g/15 draft.

Also, just so you know, the Florida Rinker kilns (now Cemex) had THC Cems in case you had not been

told. We actually have data from those kilns supplied by the State of Florida, but Florida does not have

any data on the ppm levels, their data is pounds of emlsslons.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-02

Research Triangle Park, NC 27711

919-541-5605

barnett. keith@epa. gov

O'Hare, Andrew Keith, I got your message this afternoon regardi... 1010112009 04:31:00 pM

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

To: Keith BarneIVRTP/USEPA/US@EPA Date: 10t01t2009 04:31 PM Subject: THC plan

Keith,

I got your message this afternoon regarding the THC test plan. We are busy identifying facilities for the

various cells reflecting the September 15'n version of the pfan we discussed with you a week or so ago.

Regarding the draft plan, when we discussed it most recently, you indicated that you were going to review

it in greater detail and then get back to me with a "thumbs up" or "thumbs down." Should I take your

message today as being a "thumbs up" to proceed as outlined in the gll, draft?

Thanks,

Andy

Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

500 New Jersey Avenue, N.W., 7th Floor

Washington, DC 20001

PH: (202) 408-9494

Fx: (202) 408-0877

CELL: (202)270-0094

e-mail : aohare@cement.orq
Page 1 of I

Tentative Agenda

O'Hare, Andrew

to:

Keith Bamett

1110212009 01:08 PM

Show Details

Keith,

Attached please find a tentative agenda for the meeting tomorrow. As we discussed, it is focused primarily on the

THC test plan with a brief opportunity at the end to discuss your thoughts on our comments on the proposal.

Some of my members would like to participate in the meeting tomorrow by conference call. I am happy to host

the conference call (at indicated on the tentative agenda), provided you can arrange for a conference phone in the

meeting room.

Thank you and see you tomorrow,

Andy

Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

500 New Jersey Avenue, N.W., 7th Floor

Washington, DC 20001

PH: (202) 408-9494

Fx: (202) 408-0877

CELL: (202) 270-0094

e-mail : aohare@cement.org

file://C:\Documents and Settings\kbarnett\Local Settings\Temp\notesFCBCEE\-web2289.htm 81112010
EPA - PCA Meeting

November 3, 2009

RTP, NC

12:30 - 3:00 p.m.

Tentative Agenda

(888) 387-8686, then 4089494

12:30 l. lntroductions

12:35 ll. THG Test Plan Discussion

. Test Plan Overview (J. Holmes)

. Test Plan Matril/Candidates (J Holmes, All)

. Raw Material Sampling (H Ybanez, A O'Hare, All)

2:30 lll. Portland Gement NESHAP Gomment

o Review EPA's Perspectives on PCA's Comments on Proposed

Changes to NESHAP

2:50 lV. Other Business

3:00 V. Adjourn
Approval of Portland Cement Association THC Test Plan

Keith Barnett to: Andrew O'Hare

Cc: Peter Tsirigotis, Torres.Elineth, Steve Fruh

by EPA

1110312009 04:20 PM

Dear Andy:

I want thank you , your staff, and your members for the effort they have put into developing the THC

subcategorization study test plan you presented in today's meeting. I spoke with my division director,

Peter Tsirigotis, and he agreed that you may consider this email to be approval of the plan by EPA.

We appreciate the significant time and expense of this testing effort for your members. I want to also state

that we recognize that the actual testing schedule and may change due to factors beyond anyone's

control, such as conditions of the cement market, and the availability of monitoring equipment. However,

we do ask that we be kept apprised of progress. Specifically please ask the facilities being tested to let us

know the following:

o The schedule for obtaining and installing monitoring equipment.

o The anticipated schedule to begin collecting information and number of days they expect to

operate.

o Any changes to the two items above.

I would also encourage the facilities to submit data as they collect it (maybe on a monthly basis) and not

view March 31, 2010 is an absolute cut-off date for submitting data should they have more data available

after that date.

Please ask the participating companies to sent to us their commitment to participate in this testing

program at their earliest convenience.

Thanks,

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-02

Research Triangle Park, NC 27711

91 9-541 -5605

barnett. keith@epa. gov
,d RE: Approval of Portland Cement Association THC Test Plan by EPA '4r O'Hare,'Andrew to: Keith Barnett 11l}4l2o0g 10:38 AM

Keith,

Thanks for your message and for your time yesterday. I will pass on to my

members and be back 1n touch with the follow-ups we dlscussed yesterday.

Regards,

Andy

Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

500 New Jersey Avenue, N.W., 7th FÌoor

Washington, DC 20001

PH: (202) 408-9494

FX: (202) 408-0811

GELL:' (202) 210-0094

e-mail : aohareGcement. org

-----OriginaÌ Message-----

From: Barnett.KeithGepamal-L.epa.gov [mailto:Barnett.KeithGepamail.epa.qov]

Sent: Tuesday, November 03, 2009 4:20 PM

To: O'Hare, Andrew

Cc: Tslrlgotis . PeterGepamail . epa. qov; Torres . trlinethGepamail . epa. qov;

trruh. SteveGepamail. epa. qov

Subject: Approval of Portland Cement Association THC Test Plan by EPA

Dear Andy:

I want thank you , your staff, and your members for the effort they have

put into deveÌoping the THC subcategorizatlon study test plan you

presented in todayrs meeting. r spoke with my division dlrector, peter

Tsirigotls, and he agreed that you may consider this email to be

approval of the plan by EPA.

We appreciate the slgnificant time and expense of this testinq effort

for your members. I want to also state that we recognize that the

actual testing schedule and may change due to factors beyond anyone's controÌ, such as conditions of the cement market, and the availabrlity

of monitoring equipment. However, we do ask that we be kept apprlsed of

progress. Specrfically please ask the facilities being tested to let us

know the foll-owing:

The schedufe for obtalning and installing monltoring equipment.

The anticipated scheduÌe to begin co-Llecting information and

number of days they expect to operate.

Any changes to the two ltems above,

I would afso encourage the facil-itles to submit data as they collect it

(maybe on a monthly basis) and not view March 31, 2010 is an absolute

cut-off date for submitting data shoufd they have more data available

af t-er that date.
PÌease ask the participating companies to sent to us the-ir commitment to

participate in this testing program at their earfiest convenience.

Thanks,

Keith W. Barne L t

US EPA/OAQPS /S PPD/MMG

Maif Code D243-02

Research Triangle Park, NC 211L7

9r9-54 1-5 605

barnett . keithGepa. gov
THC Plan Commitment Letter

O'Hare, Andrew

to:

Keith Bamett, Peter Tsirigotis

111091200912:56 PM

Show Details

History: This message has been forwarded.

Keith and Peter,

Please see the attached letter conveying commitments to ímplement the THC test plan as discussed last week.

Please call with any questions.

Regards,

Andy

Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

500 New Jersey Avenue, N.W., 7th F.loor

Washington, DC 20001

PH: (202) 408-9494

FX: (202) 408-0877

CELL: (202)270-0094

e-majl : aohare@cement.org

file://C:\Documents and Settings\kbarnett\Local Settings\Temp\notesFCBCEE\-web1258.htm 81112010
PClt*

i. + i : i ;) 11,..j i. t : tri t: tiI L*i t: t i. aii ri zl

November 9, 2009

Mr. Keith Barnett

Metals and Minerals Group (D243-02)

Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

Research Triangle Park, NC 27711

Re: PGA Member Support for lmplementation of Total Hydrocarbon (THG) Test

Plan

Dear Keith,

I am writing regarding the proposed PCA plan to collect additional THC data,

which was shared with you in September and was the subject of more detailed

discussion at the meeting between PCA and EPA, held on Tuesday, November 3, 2009.

Thanks to you and Mr. Tsirigotis for your expression of approval and support for the

plan, which we received on November 3. As we discussed during the recent meeting,

PCA members are committed to making the necessary investments in THC continuous

emission monitoring equipment and associated raw material sampling to carry out the

plan. The undersigned PCA member companies and company representatives stand

by this commitment.

As you know, the current economic situation will present some challenges to the

industry in carrying out the plan. Many U.S cement plants have been shut down

because of market circumstances and it is difficult to predict at this time what impact

market dynamics will have on plant operations. ln reflection of this situation, we have

carefully crafted the list of test plan candidates, discussed with you on November 3, to

focus on those plants that plan to be operational for at least 30 days before the end of

March 2010.

The other significant potential uncertainty will be the amount of time necessary to

obtain and install the THC monitors. Monitor vendors currently indicate that they will be

able to satisfy the demand and conform with the anticipated program start date, though

unanticipated delays are possible. As we implement the plan, we will keep you apprised

of developments and provide you will timely updates on our progress.

Thank you again for supporting our proposed plan. We look fon¡rard to working

with you and your colleagues on this project. Please call with any questions regarding

the plan or plan implementation. You may reach me at (202) 408-9494 (or

aohare@cement.orq) to address any questions.

500 New Jersey Avenue, NW

7th Floor

Washington, D.C. 2000'l
Sincerely,

A^^a o'Hú^

Andrew T. O'Hare

Vice President, Regulatory Affairs

Cc: Peter Tsirigotis, EPA-OAQPS

Commitments of THC Test Plan

Candidates:

Larry Alexander Bernard Terver

Alamo Cement Co. Holcim (US) lnc.

Curtis Lesslie Craig Campbell

Ash Grove Cement Co. Lafarge North America lnc.'

Dan Nugent Tim Matz

Buzzi Unicem USA lnc. Lehigh Hanson Cem ent Co.

Jay Grady Michael Stevens

CalPortland National Cement Co.

Satish Sheth Martin Vroegh

CEMEX St. Marys Cement /VCNA

Gary Molchan Marty Fallon

Essroc Cement Corp. Suwannee American Cement

Doug Roark Nancy Garnett

GCC of America lnc. Texas lndustries, lnc,

Lane Smith Jay Willis

Giant Cement Holding Titan America LLC
Page 1 of2

THC Plan Update

O'Hare, Andrew

to:

Keith Barnett

12118/2009 01:36 PM

Cc:

Peter Tsirigotis

Show Details

History: This message has been replied to and forwarded.

Keith,

Below please find a table which summar¡zes the status of THC plan implementation as of 12-1-0g. We

have 36 kilns in the work plan (the most recent version of which is attached). As you can see, we are

moving fonvard across the board. My members continue to be challenged by the time it is taking to

secure and install THC CEMS and, more importantly, by kiln shutdowns associated with low demand

for cement. I should note that a number of the units that did not have the CEMS installed on December

1st were shutdown at the time and remain off line. For those facilities, the goal is to have the CEMS

installed and ready to run when the unit is back in service, early next year.

I will provide you with an update to this status report early in the New Year.

Happy Holidays!

Andy

Status Category Number of Kilns

in the Cateoorv

Data Gathering Undenruay (have

less than 30 davs of data)

3

Data Gathering Started; Kiln

Shutdown (have less than 30 days

of data)

3

CEMS lnstalled; Data Gathering

Not Beoun

I

CEMS Order Placed 7

CEMS Bids Rec'd and Under

Review

10

CEMS Spec. Out for Bid 3

Unit Out of Study - Not Operatinq 1

Unit Out of Study - Technical

Problems

1

36 total

Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

file://C:\Documents and Settings\kbarnett\Local Settings\Temp\notesFCBCEE\-web3315.htm 811l2}l0
Page2 oï2

500 New Jersey, Avenue, NW

Washington, DC 20001

Phone: (202) 408-9494

Fax: (202) 408-0877

Cetl: QA) 270-0094

e-mail : aohare@cement.org

file://C:\Documents and Settings\kbarnett\Local settings\Temp\notesFCBCEE\-web3315,htm 8lll20l0
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December 18,2009

Design of the PCA THC Sub-Categorization Study

Introduction

In comments to the EPA dated August 28,2009, the Porlland Cement Association (PCA)

proposed to collect additional data to determine whether subcategories should be established for

the THC limit under the MACT standards applicable to Portland cement facilities. The data

gathering will focus on potential subcategories for kilns with inherently high THC emissions and

to address other process design distinctions. The high emissions may be related to the

composition of the raw materials, including the level and/or form of organics in the limestone, or

the inclusion of raw mill or coal mill exhaust in the main kiln exhaust and the kiln type.

Because the existing data on THC emissions and raw material organic content are insufficient to

resolve these issues, the PCA sub-categorization study will collect emissions data on a

substantial sample of kilns, along with characterizingthe raw material inputs to these kilns. The

data should be adequate to determine the need to establish subcategories (where appropriate)

and, if possible, to estimate MACT standards for such subcategories. This paper discusses some

of the key considerations in the design of the sample population for this study and presents an

overview of the process used to select kilns for the study, the characteristics of the kilns that are

participating in the study, the stack THC monitoring and raw material analyses that are being

done, and the current plans for data analysis.

Study Desien

After a review of the existing data on kiln emissions and operations, PCA members have

identified three primary factors that may lead to the need for sub-categorization of the THC

limit:

o Kiln type, divided into three major groups: (1) long kilns (wet or dry), (2) pre-heater/precalciners or preheaters with in-line raw mills, and (3) pre-heaters or

preheaterþrecalciners without inline raw mills. For example, long kilns may be

distinctive from others because of the temperature profile that the raw material

experiences. Units with in-line raw mills may have higher THC emissions, due to losses

during grinding.

. Commingling of coal mill exhaust with the kiln exhaust may increase the loading of the

kiln exhaust with THC relative to a kiln with a stand alone coal mill.

o Beyond process types, the types of organic materials within the raw materials, and

limestone in particular, will directly influence THC emissions. Therefore, it is important

to characterize the types of organic materials within the limestone and all of the kiln feed

by the level of organics liberated in the so-called evolved organic matter or preheater offgassing test as well as the level of organics liberated during raw material grinding (where

those emissions are present in the kiln exhaust).
One of the challenges of this investigation is to create a workable number of test categories. The

sample design for kiln sub-categorization started with a stratification of the current kiln

population into 12 cells -- 3 (kiln type) x 2 (with or without commingled mill/dryer exhaust) x 2

(high or low organics raw materialsr). Characterizingthe full kiln population by kiln type and the

presence of commingled mill exhaust was straight forward for most of the population. What is

more difficult is determining which kilns have high levels of THC and therefore are in the high

or low emissions planes of the 3 x 2 x 2 cell structure. 'While it was not possible to obtain data to

characterize the entire kiln population according to technology and emissions with specihcity,

sufficient information was obtained to classify units to the 12 cells and recruit kilns for the study.

Limestone and feed materials are not sufficiently characterized in existing data with respect to

the nature of the organics influencing THC emissions, nor has such data been correlated with

kiln emissions to understand the role of organic composition in THC emissions. There is

considerable data on Total Organic Carbon in raw materials, but that has not been helpful in

determining high emitters of THC. Thus, it is not possible based on existing data to determine

which kilns have compositional factors leading to high or low emissions. Instead, surrogate data

were used to recruit and assign units to the high or low emissions planes as best as possible. For'

example, kilns for which existing CEMS or stack testing show high (or low) emissions compared

to the aveÍage are clear candidates for the high (or low) emission planes. Qualitative information

from kiln operators also was used to assist in this classification.

A number of factors were considered in deciding on the total sample size for the study and

determining its allocation among the cells. The statistical considerations in sample size

determination and allocation relate to obtaining satisfactory coverage of the population and

enough data to provide sufficient statistical power. In this study, the sample size could not

simply be allocated by cell in proportion to the distribution of the US kiln population, because

the study is to answer questions on whether individual cells differ statistically from other cells.

Instead, a minimum sample size was set for each cell for which separate analysis was desired.

This approach leads to a stratified sample that is distributed in a manner that differs from the

distribution of the kiln population. As a practical matter,3 kilns was viewed as the minimum

sample size for each cell, because 3 kilns is the smallest sample that permits computation of

confidence intervals and also permits the identification of an erroneous data point (an outlier) in

comparison to the other data points. A larger sample is generally desirable in each cell.

V/ith 12 total cells in the sample design, a minimum of 36 units is implied for the overall sample

size, which would be a large study involving a major commitment of resources industry-wide

and participation by 20 percent of the 167 kilns in the US. However, it was anticipated that a

number of the cells would have few or no kilns in the current population while others would be

highly populated. Therefore, the sample selection started with 3 kilns per cell and an overall

number of kilns in the study targeted at between 30 and 40 kilns. Next, the following

considerations were applied to select kilns for the study:

o Cells not represented in the US kiln population were dropped from the study entirely.

Additional units were recruited for the cells with the largest number of units.

I To assign units to the high or low THC cells, a cutoff of 50 ppm or greater THC as propane in the exhaust was

used.
. Where there are two or more kilns of the same design at the same location, only one was

considered for inclusion in the study so as to obtain the greatest diversity in the kilns

being studied.

o Kilns not expected to operate for 30 days or more between December 1't and March 3 1't

were not considered.

o Kilns with stack measurement concems (multiple stacks; stacks with commingled

emissions from a power plant) were not considered.

o The kilns selected for the study were distributed among the PCA members and

geographically across the U.S.

Study Participants

Once the full population of kilns was distributed among the 72 cells, only seven cells were

populated. Applyrng the kiln selection criteria listed above, 36 kilns from those seven cells were

selected for testing. For each cell, the number of kilns selected out of the number of "unique"

kilns is listed below, That is, where a cement plant has more than one of the same type of kiln, it

was consider as a single entry in the population. Shutdown units were not considered. Of the 36

kilns selected for study, ten have existing THC CEMS for which some past data have been

provided to EPA. The location and owner of each kiln by cell is as follows:

Cell 1: Long wet or dry, kiln alone, low THC (7 of 23 in this cell)

Ash Grove Midlothian Lafarge Ravena

Cemex'Wampaum Lafarge Tulsa

Holcim Trident Lehigh Evansville

Lafarge Joppa

Cell2: Long wet or dry, kiln alone, high THC (3 of 3 in this cell)

Holcim Ada Lafarge Seattle

BuzziPryot

Cell 3: PH and PH/PC inline mill, kiln alone, low THC (10 of 34 in this cell)

Alamo San Antonio Cemex Miami

Buzzi Challanooga Essroc Speed

CalPortland Mojave GCC Rapid City
Cemex Clinchfield Lehigh Redding (may not be

operational before 3-3 I -10)

Cemex Fairborr Titan Roanoke

Suwannee Branford

Cell 4: PH and PH/PC inline mill, kiln alone, high THC (3 of 3 in this cell)

Cemex Demopolos I TXI Midlothian K 5

(upstream of RTO; may not

Lehigh Mason City I be feasible)

Cell5: PH and PH/PC inline mill, commingling, low THC (5 of 10 in this cell)

Ash Grove Durkee National Ragland

Lafarge Sugar Creek Titan Perursuco

Lehigh Union Bridge

Cell 6: PH and PH/PC inline mrll, commingling, high THC (4 of 4 in this cell)

Giant Dragon Thomaston Holcim Midlothian

Holcim Devil's Slide Holcim Portland

cell 7: PH and PH/PC no inline mill, kiln alone, low THC (4 of l0 in this cell)

Cemex Knoxville

Holcim Theodore

Lafarge Whitehall

Testins Methods

As a part of this study, each participating kiln will have a THC CEMS and will gather limestone

and raw feed samples for organic content testing. For the THC CEMS, the kiln owner will

operate a THC continuous emission monitoring system in accordance with Performance
Specification 84, of appendix B to part 60.2 The monitoring results will be reported as daily

averages and 30 day averages for the days that the kiln is operating. THC levels will be

expressed in parts per million volume dry, as propane, adjusted to 7Yo oxygen.

Raw Material Sampline

Off Gas Samplins: For each kiln in the study, during the period of operation with the THC

CEMS in service, a daily 0.5 kg grab sample of limestone and adaily 0.5 kg grab sample of kiln

feed (that which enters the kiln/preheater) will be taken for each day that the THC CEMS is in

operation. The limestone sample should be taken from the raw mill feed area and dried (at less

than 105'C) and ground to a fineness similar to the kiln feed (it is recommended, but not

necessary, to grind the limestone sample the same day that it is taken). Both the daily kiln feed

and daily dried/ground limestone samples should be stored in an airtight container.

After thirty days of operation with the THC CEMS in service and samples being taken (and

which may not be consecutive days), a 30 day composite 1 kg sample should be created, both for

the kiln feed and the limestone. These two samples should be packed separately in airtight

containers, labeled, and shipped to the FlSmidth laboratory in Whitehall, PA as per the attached

shipping instructions. These first two samples should be labeled as follows:

- "First 30 days Composite Kiln Feed Sample for Kiln No, ???? at the ???? facility that

is operated by ????"

- "First 30 days Composite Limestone Sample for Kiln No. ???? at the ???? facility that

is operated by ????"

The daily samples used to create the composite samples should be retained for ayear, if that is

possible. After the next 30 days of monitoring and sampling are completed, composites of the

kiln feed and limestone should be created and shipped to Flsmidth with the notation "second

30 days composite....", 'When the third 30 days are done, composites of the kiln feed and

limestone should be created and shipped to FlSmidth with the notation "Third 30 days

composite....". If at any time the THC CEMS monitoring is discontinued before the full 90 days

of monitoring and sampling occurs, create afinal composite of the kiln feed and limestone

samples for whatever days, short of thirty days, you have and they should be labeled and sent to

FLSmidth.

Grindine THC Sampline: A grinding THC sample is onlyrequired if initial data from the THC

test with the THC CEMS being in service indicates an increase in THC emissions when the raw

mill is running versus when the raw mill is down. If the grinding THC sample is required, two

separate daily grab samples of the limestone should be taken during the testing period. The days

that the samples are taken should be spread out during the THC monitoring period, with one

sample taken during the first 30 days and one during the second 30 days, with the two separated

by at least three weeks. The physical material size required for this testing is 6 inches or larger,

so it is requested that the limestone sample be taken before the primary crusher. Each of the two

samples should be a minimum of 10 kgs in size, stored in airtight containers, properly labeled,

2 Any minor variations from the 8A requirements necessary due to the fact that these are temporary CEMS retlofits

that must be executed quickly will be noted in the final report on THC data gathered under this study.
and shipped to the FlSmidth laboratory in Denmark (as per the attached shipping instructions)

via air freight. Each sample should be sent to the lab as soon as it is ready for shipping. Each

sample should be labeled as follows:

- "First (or Second) Grinding Sample of Limestone taken on (date) for Kiln No. ???? at

the ???? facility that is operated by ????

Schedule

Kiln owners have been asked to order and install THC CEMS on an expeditious basis. Some

will be buying and installing CEMS; others will be leasing. The CEMS are targeted to be in

operation by December 1" or as soon as possible thereafter. THC data gathering at each kiln will

be dependent on the time it takes to get the CEMS installed and calibrated as well as the

operating schedule for the kiln. Units with existing CEMS are being asked to begin data

gathering for this study on December 1't. While the THC data are being gathered, the sites will

collect composite samples of total raw feed and limestone for testing as described above. Data

analysis will begin in late February with the goal of providing an initial data report to EPA at the

end of March. That report will address the scope of the data gathered, and the initial analysis of

the prospects for subcategories. Data gathering and data analyses are expected to extend beyond

March for a number of units, depending in part on the initial findings.

Data Analysis

All data will be provided to PCA for analysis and in tum to EPA for the rulemaking record.

PCA's analysis of the results will focus on whether there is evidence of a subcategory for THC

and the characteristics of that subcategory relative to both technology and material

characteristics. The initial statistical test to be performed in the sub-category analysis will be to

determine if mean emissions in one cell (or group of cells) are statistically different from those in

another cell (or group) at a stated confidence level. This test depends on the variances of the

means in each cell (or group), which in turn is based on the length of the test period and the

differences in emissions across units. Beyond that test, the sub-category analysis will look

broadly for evidence that one or more cells, or groups of cells, show statistically significant

evidence for differences in emissions compared to other cells or groups. It will also look broadly

at the question of how material composition affects emissions and whether that relationship

varies with technology. It will not simply test whether each cell is statistically different than

other cells. When many cells are grouped together, the available sample size is greater and the

dataset becomes more powerful for identifying differences. The sample size and power are

smaller when the differences being examined pertain to only a few cells.

The outcome of the sub-category analysis may take a number of different forms:

o To recommend establishing a sub-category for one or more individual cells, because the

collected data demonstrate that the kilns in the cells are distinctive and significantly

different than other kilns with respect to THC emissions.

o To recommend establishing a sub-category for a group of cells, because the data

demonstrate that the group, taken as whole, is distinctive and signihcantly different than

other kilns, while finding no evidence to support subdividing kilns within the group.

. To demonstrate the relationship between material composition and THC emissions and,

based on that relationship, recommend establishing sub-categories for kilns facing
distinctive and significantly different material compositions that lead to higher emissions,

Materials-based sub-categories could be defined solely by the composition of materials

used by the kilns or by a combination of material composition and kiln type, where it is

found that the materials effect is important in only some kiln types.
THC Study Supplemental Guidance (as of December 18, 2009)

THC CEMS Operations

1. Relative Accuracy Test Audit (RATA) is not required. Instead, it will be acceptable to

conduct the daily calibrations (with two calibration gases) to prove accuracy; do a manual

calibration (with 3 calibration gases) from time to time to prove linearity and a 7-day drift

test. There is no specific minimum frequency for the linearity test and it can be keyed to

the results of the daily calibration tests.

2. Performance Specification 8A says that the calibration gases should be introduced into

the sampling system as close to the sampling probe outlet as practical. This is the

recommended practice. However, in the interest of time and the short term nature of

these tests, it is not necessary to run the calibration gases all the way out to the probe;

calibration gas6 may be injected directly into the báck of the analyzer,provided daily

sample line leak checks are perfotmed and pass. If you have an existing CEMS system

that you are connecting into for the THC sample, the confirmation of the integrity of that

system will be adequate for this purpose.

3. Is EPA Protocol gas required or can calibration gas be used? Given the potential delays

associated with securing Protocol gas, calibration gas will be acceptable. Protocol gas is

preferable and should be added when available, if possible.

4. Determination of the oxygen level for pulposes of adjusting the oxygen level to 7%, can

be done with a continuous monitor pursuant to EPA Method 3A but it can also be done

with a grab or integrated sample pursuant to EPA Method 38. If the individual sample is

used, the test should be done at the outset of the THC monitoring and on a regular basis,

to be decided by the site.

5. Determining the stack gas moisture content for purposes of adjusting to dry conditions

should be conducted in accordance with EPA Method 4, atleast once within the 3-month

, PCA data collection period, unless the source corrects for moisture for other pollutants

under an applicable CAA permit, in which case the correction method used for that

purpose may be used. For units with inline raw mills, moisture correction factors should

be established for both mill on and mill off conditions.

Raw Material Sampling

1. While the original protocol call for drying of limestone samples before the composite was

created and shipped to FLS, it is now preferred that samples not be dried. Drying of the

limestone samples should only be done to the extent needed to grind the daily samples

and create the composite sample. It should be air drving rather than oven drl¿ing (at a

temperature less than 30 deqrees Celsius). In any event, final drying will be done by

FLS. Additionally, for wet kiln raw material samples, it is appropriate to take daily

samples of slurry, and create a composite slurry sample to be shipped to FLS. Again no

drying before shipping is now the preferred approach, If earlier samples were dried, they

are still acceptable however.
While the possibility of taking samples of limestone and raw feed only on week days was

discussed, it is expected that samples will be taken on each and every day that the kiln is

running and the THC monitor is recording. Once thirty days of sampling is done

(consecutive or not), the 30 day composite sample is created and daily sampling for the

next composite begins.

Containers for samples need to air tight but no particular glass or plastic for the

containers is specified.

THC Data Template

1. What should be the definition of start up and shutdown? We have no precise def,nition

except that start up is not finished until there is feed to the kiln and shutdown cannot

occur until feed is discontinued.

2' What is meant by recordingC2 and CO at the "top of the shelf' for preheater/precalciner

units? Remember the 02 and CO data submittal is optional. And the template will be

revised to say the "top of the tower."

2

3.
Page 1 of I

THC Plan Update

O'Hare, Andrew

to:

Keith Barnett

0112112010 09:51 AM

Show Details

History: This message has been replied to and forwarded.

Keith,

Pasted in below please find an update on the status of the THC test plan. lexpect more kilns to come on

line by the end of the month.

Please call with any questions.

Regards,

Andy

THC Test Plan Status as of Jan 1st:

Status Categorv Kiln Number

Kiln Operating; Data Gathering Underway; have less than 60 days

of data

!

Kiln Operating; Data Gathering Underway; have less than 30 days

of data

1.

Kiln Shutdown; Data Gathering Started; have less than 30 days of

data

5

Kiln Shutdown; CEMS lnstalled; Data Gathering Not Begun 3

Kiln Operating, CEMS lnstalled; Data Gathering Not Begun 10

Kiln Shutdown; CEMS Order Placed 8

Kiln Operating; CEMS Order Placed 5

Unit Out of Studv - Shuttins Down 1.

Unit Out of Study - Not Operatine 1

Unit Out of Studv - Technical Problems 1

36 total

Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

500 New Jersey, Avenue, NW

Washington, DC 20001

Phone: (202) 408-9494

Fax: (202) 408-0877

Cell: (202) 270-0094

e-mail : aohare@cement.org

file://C:\Documents and Settings\kbarnett\Local Settings\Temp\notesFCBCBE\-web9965.htm 81112010
Page 1 of 1

THC Test Plan Update

O'Hare, Andrew

to:

Keith Barnett

0211812010 03:54 PM

Show Details

History: This message has been replied to.

Keith,

Pasted in below, please find the latest monthly update on the THC data collection effort.

Also, I will call you back to address the question you posed to me in a voicemail message about the

statistical information.

Regards,

Andy

THC Test Plan Status as of February 1,2010

Status CategorV Number

Kiln Operating; Data Gathering Underway; have less than 60 days

of data

6

Kiln Operating; Data Gathering Underway; have less than 30 days

of data

5

Kiln Shutdown; Data Gathering Started; have less than 30 days of

data

7

Kiln Shutdown; CEMS lnstalled; Data Gathering Not Besun 1.

Kiln Operating, CEMS lnstalled; Data Gathering Not Begun 6

Kiln Shutdown; CEMS Order Placed 5

Kiln Operating; CEMS Order Placed 3

Unit Out of Study - Shutting Down 1)

Unit Out of Study - Not Operating 1

Unit Out of Study - Technical Problems I

36 total

Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

500 New Jersey, Avenue, NW

Washington, DC 20001

Phone: (202) 408-9494

Fax: (202) 408-0877

Cett. (202) 270-0094

e-mail : aohare@cement.org

flrle://C:\Documents and Settings\kbarnett\Local Settings\Temp\notesFCBCEE\-web8966.htm 8lit12010
Re: THC Test Plan Update r)

Keith Barnett to: O'Hare, Andrew 0211912010 08:57 AM

We would like to see the data where they have less than 60 days (but I assume more than 30) to see

where the numbers are falling.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

Mail Code D243-02

Research Triangle Park, NC 27711

91 9-541 -5605

barnett. keith@epa. gov

O'Hare, Andrew Keith, Pasted in below, please find the latest mo... 02118t2010 03:54:03 pM

From: O'Hare, Andrew <AOhare@cement.org> To: Keith BarneIURTP/USEPA/US@EPA Dare; 02/1812010 03:54 PM Subject THC Test Plan Update

Keith,

Pasted in below, please find the latest monthly update on the THC data collection effort.

Also, I will call you back to address the question you posed to me in a voicemail message about

the statistical information.

Regards,

Andy

THC Test Plan Status as of February 1,2010

Status Category Number

Kiln Operating; Data Gathering Underway; have less than 60

days of data

6

Kiln Operating; Data Gathering Underway; have less than 30

days of data

5

Kiln Shutdown; Data Gathering Started; have less than 30

days of data

7

Kiln Shutdown; CEMS lnstalled; Data Gathering Not Begun 1.

Kiln Operating, CEMS lnstalled; Data Gathering Not Begun 6

Kiln Shutdown; CEMS Order Placed 5

Kiln Operating; CEMS Order Placed 3

Unit Out of Study - Shutting Down 1

Unit Out of Study - Not Operating '1.

Unit Out of Study - Technical Problems I

36 total
Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

500 New Jersey, Avenue, NW

Washington, DC 20001

Phone: (202) 408-9494

Fax: (202) 408-0877

Cett: (202) 270-a094

e-mail; aohare@cement.org
RE: Meeting and THC data

O'Hare, Andrew to: Keith Barnett 031011201011:06 AM

Thanks. I{ilf caff to discuss the THC data..

Andrew T. OrHare, CAE

Vice President, Regulatory Affairs

Portl-and Cement Assoclation

500 New Jerseyr Avenue, NVI

Washington, DC 20001

Phone: (202) 408-9494

Fax: (202) 408-0811

Celf : (202) 2'10-0A94

e-mail-: aohareGcement. orq

-----OrlginaÌ Message-----

From: Barnett.KêithGepamall-.epa.gov [mailto:Barnett.Keith6epamaif.epa.gov] Sent: Monday, March 01, 2010 10:46 AM To: OtHare, Andrew

Subject: Re: Meeting and THC data

f am checking on avallabifity of my projeet team members.

on another matter - it would be helpful if we could get preJ-iminary data flles for klÌns that have 30 days of THC data or more now so we can see where the numbers are trending.

Keith W. Barnett

USEPA/OAQPS / SPPD/MMG

Malf Code D243-02

Research Trlangle park, NC 2ljII

9I9-541-5605

barnett . keithGepa. g'ov

From: I

I O' Hare, Andrew <AOhareßcement.org>

To: I

------------l

I Keith Barnett/RTp/USEPA/USGEpA

I
-l
Page I of 2

Tentative Agenda/THC Update

O'Hare, Andrew

to:

Keith Barnett

0311112010 01:50 PM

Cc:

Peter Tsirigotis

Show Details

History: This message has been replied to and forwarded.

Keith,

Attached please find a tentative agenda for the meeting on Monday. As we have done before, I would

like to have a conference line available for those to participate who cannot be there in person. I

suggest we use my conference call line: (888) 387-8686, then 4089494.

I have also pasted in below the March 1 update on the status of the THC test program.

See you on Monday,

Andy

Status of THC Test Program as of March L,zOtO

Status Category Number of Kilns

Kiln Operating; Data Gathering Underway (have

less than 60 days of data)

5

Kiln Shutdown; Data Gathering Started (have less

than 60 days of data)

3

Data Gathered for 30 Days; No Further Monitoring

Plan ned

L

Kiln Operating; Data Gathering Underway (have

less than 30 days of data)

1.2

Kiln Shutdown; Data Gathering Started (have less

than 30 days of data)

6

Kiln Shutdown; CEMS lnstalled; Data Gathering Not

Begun

0

Kiln Operating, CEMS lnstalled; Data Gathering Not

Begun

L

Kiln Shutdown; CEMS Order Placed 2

Kiln Operating; CEMS Order Placed 3

unit out of Study - shutting Down 1

Unit Out of Study - Not Operating 1

Unit Out of Study - Technical Problems L

36 total

file://C:\Documents and Settings\kbamett\Local Settings\Temp\notesFCBCEE\-web 1980.htm 8l1lZ0l0
Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

500 New Jersey, Avenue, NW

Washington, DC 20001

Phone: (202) 408-9494

Fax (202) 408-0877

Cell: (202) 270-0094

e-mail : aohare@cement.org

file://C:\Documents and Settings\kbarnett\Local Settings\Temp\notesFCBCEE\-web1980,htm Slll¡0l0
II.

EPA - PCA Meeting

Technical Rulemaking Issues

March 15,2010

RTP, I\C

12:00 - 2:30 p.m.

Tentative Agenda

(Draft, 3-10-2010)

(888) 387-8686, then 4089494

Introductions

Discussion of PCA comments

A. Mercury

1. Kiln Surveys and Variability Analysis

a. Brief review of survey and findings

b. EPA reactions, thoughts, and next steps

2. Statistical Review of Variability in Mercury Data

a. Brief review of PCA's technical comments and statistical

methodologies

b. EPA reactions, thoughts, and next steps

3. Subcategories

a. Brief review of PCA's technical comments and statistics

showing need for subcategories

b. EPA reactions, thoughts, and next steps

Brief review of PCA's technical comments

PCA review of status THC testing program

EPA reactions, thoughts and next steps

1. HCI Technology issues

a. Brief review of PCA technical comments

b. EPA reactions, thoughts and next steps

Ongoing HCI Testing Program

a. Brief review of PCA's data collection efforts

1.

2.

3.

C. HCI

2.
b.

c.

d.

PM

I. Brief review of PCA technical comments

2. Issues with use af 9.9Y¡ and possible violations

3. EPA reactions, thoughts and next steps

Other Business

A. EPA's current thinking on and schedule fo-r NSpS B. Next Steps

Adjourn

EPA's current thinking on how it might use data

EPA's thoughts on the Rfd threshold approach and the

112(dX4) alternative

EPA's timing of final rule given new HCI testing program;

need to incorporate data into rulemaking; OMB review; and

possible notice and public comment on the new HCI (and.

perhaps THC) data

D.

ru,
THC data

Keith Barnett to: Andrew O'Hare

Cc: Peter Tsirigotis, Steve Fruh, Nizich.Sharon, Steven Silverman

4410112010 09:57 PM

Dear Andy:

We need the THC data collected to date now. Otherwise we may have to go with the data we got during

the comment period. Call me.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-02

Research Triangle Park, NC 27711

919-541-5605

ba rnett. keith@epa. gov
Page 7 of2

THC Test Program Update

O'Hare, Andrew

to:

Keith Barnett

0411312010 08:01 AM

Show Details

Keith,

Pasted in below is a the status of the THC test program as of April 1,2010. Please call with any

questions.

Regards,

Andy

PCA THC Data Gathering Project

Kiln Status Categories as of April lst

Status Category Number of Kílns

90 days of Data Gathering Completed 2

Kiln Operating; Data Gathering Underway; (have more

than 60 and less than 90 days of data) 8

Kiln Operating; Data Gathering Underway (have more

than 30 but less than 60 davs of data) 4

Kiln Shutdown; Data Gathering Started (have more than

30 but less than 60 days of data) 5

Data Gathered for 30 Days; No Further Monitoring

Plan ned

L

Kiln Operating; Data Gathering Underway (have less than

30 days of data) 7

Kiln Shutdown; Data Gathering Started (have less than 30

days of data) 2

Kiln Shutdown; CEMS on Site 2

Kiln Operatine; CEMS on Site L

Kiln Operating; CEMS Order Placed 1.

Unit Out of Study - Shut Down 1

Unit Out of Study - Not Operating 1

Unit Out of Studv - Technical Problems I

36 total

Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

500 New Jersey, Avenue, NW

Washington, DC 20001

Phone: (202) 408-9494

Fax. (202) 408-0877

Cell (202) 270-0094

file://C:\Documents and Settings\kbarnett\Local Settings\Temp\notesFCBCEE\-web1506.htm 8lll20l0
Page 2 of 2

e-mail : aohare@cement.org

From: O'Hare, Andrew

Sent: Tuesday, April 13, 2010 7:33 AM

To:'barnett. keith@epa.gov'

Subject: Update

Keith,

I have a conference call with my members this a.m. to discuss the state of the data collection efforts,

etc. I was hoping to also share with them the latest thinking from the Agency on the timing for the final

rule. Any word on moving the June date?

Thanks,

Andy

Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

500 New Jersey, Avenue, NW

Washington, DC 20001

Phone: (202) 408-9494

Fax: (202) 408-0877

Celt: (202) 270-0094

e-mail : aohare@cement.org

file://C:\Documents and Settings\kbarnett\Local Settings\Temp\notesFCBCEE\-web1506.htm 8lIl2O10
Response to your Voice Mail Messages

Keith Barnett to: Andrew O'Hare

Cc: Peter Tsirigotis, Steven Silverman, Nizich.Sharon, Steve Fruh

04 I 1 4 I 20 1 0 04 :2-7 Plttl

Dear Andy:

Peter asked me to respond to your messages and I left you a voice mail - but in case you check mail first -

Peter is tied up and won't be able to get back to you until Friday at the earliest.

lf you are calling about the extension, we have reached out to Earthjustice. They haven't said no - they

are considering our request - but they have not given any indication they will agree either.

I appreciate the THC status update - but we would like to see some on the data collected to date by next

week so we can get an idea of what the data may show.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

Mail Code D243-02

Research Triangle Park, NC 27711

919-541-5605

ba rnett. keith@epa. gov
. É RE: Response to your Voice Mail Messages "s 

O'Hare, Andrew to: Ke¡ttr Barnett O4l15l2o1o 10:01 AM

Keith,

Thank you very much for the update. Reqarding the THC data, we are planning

to share some preliminary resuÌts very soon.

Regards,

Andy

Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portfand Cement Assoc-iation

500 New Jersey, Avenue, NW

Washington, DC 20001

Phone: (202) 408-9494

Fax: (202\ 408-0877 CelÌ: (202) 210-0094

e-maiI : aohareGcement. org

-----Original Message-----

From: Barnett.KeithGepamail.epa.gov lmalfto:Barnett.KelthGepamail.epa.gov]

Sent: tr{ednesday, ApriJ- 14, 2010 4:21 PM

To: O'Hare, Andrew

Cc: Tsirigotis . PeterGepamail . epa . gov; sifverman. stevenGepamail . epa. gov;

Nrzich. SharonGepamail. epa. gov; Fruh. Steve@epamaif . epa. gov

Subject: Response to your Voice Mail Messages

Dear Andy:

Peter asked me to respond to your messages and I left you a voice mail -

but in case you check maif first - Peter is tied up and won't be able to

get back to you untif Frì-day at the earliest.

If you are calling about the extension, we have reached out to

Earthjustice. They haven't said no - they are consldering our request -

but they have not glven any indlcation they will agree either.

I appreciate the THC status update - but we woul-d like to see some on

the data collected to date by next week so we can get an ldea of what

the data may show.

Ke i Lh W. BarneLL

USEPA/OAQPS/SPPD/MMG

Mall Code D243-02

Research Triangle Park, NC 21117

9t 9-54 1-5 605

barnett . keithG epa . gov
CONTACT REPORT

Person Calling: Keith Barnett

U.S. Environmental

OAQPS/ESD/OCG

9t9-54t-560s

Protection Agency

Person Called: Andy O'Hare

Portland Cement Association

Date of Contact: 5nr/20t0

Contact Summary:

I called Andy to discuss the status of the THC testing effort. I told Andy we needed to see the

data collected to date as soon as possible. I was going t have to start briefing senior managers on

the final rule very soon.

Andy stated that he thought he could supply the data to date this week or next. He was waiting

for member review.
Page 1 of I

THC Test Plan Update

O'Hare, Andrew

to:

Keith Barnett

0511212010 05:04 PM

Show Details

History: This message has been forwarded.

Keith,

Pastedinbelowisanupdateonthestatusof theTHCtestplanasof May 1,2010. pleaseletmeknowif you have any questions.

Regards,

Andy

Kiln Status Categories as of May 1st

Status Category Number

90 days of Data Gathering Completed 4

Kiln Operating; have 60 days or more but less than 90 days

of data

3

Kiln Shutdown; have 60 days or more but less than 90 days

of data

2

Data Gathered for 60 days; No Further Data Gathering

Pla nned

4

Kiln Operating; have 30 days or more but less than 60 days of

data

10

Kiln Shutdown; have 30 days or more but less than 60 days of

data

t

Data Gathered for 30 Days; No Further Data Gathering

Planned

1

Kiln Operatingj have less than 30 days of data. 6

Kiln Shutdown; have less than 30 days of data) 0

Kiln Shutdown; CEMS on Site L

Kiln Operating; CEMS on Site 0

Kiln Operating; CEMS Order placed t

unit out of study - shut Down t

Unit out of study - Not operating t

Unit Out of Study - Technical problems t

36 total

Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

500 New Jersey, Avenue, NW

Washington, DC 20001

Phone: (202) 408-9494

Fax: (202) 408-0877

Cell: (202) 270-0094

e-mail: aohare@cement.org

frle://C:\Documents and Settings\kbarnett\Local Settings\Temp\notesFCBCEE\-web293 7 .htm glll20l0
THC Data from PCA's Voluntary Data Gathering Effort

Keith Barnett to: Andrew O'Hare

Cc: Peter Tsirigotis, Steven Silverman, Susan Fairchild, Steve Fruh

0512812010 04:44 PM

TO: Andy O'Hare of the Poftland Cement Association and the Portland Cement NESHAP Docket

Dear Andy:

Our Office of General Counsel, the Department of Justice, and I had a call with Rich Alonso today. ln that

callwe communicated to him that PCA must send to us by COB June 3, 2010, all avaílable THC

emissions data in their possession that was generated as part of PCA's voluntary THC data gathering

effort. I repeat that same statement to you here: if EPA has not received the data by that time we cannot

guarantee that we will be able to consider the data in making our decisions regarding standards for THC in

the final Portland Cement NESHAP.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

Mail Code D243-02

Research Triangle Park, NC 27711

91 9-541 -5605

barnett. keith@epa.gov
RE: THC Data from PCA's Voluntary Data Gathering Effort

O'Hare, Andrew to: Keith Barnett

^^. 

Peter Tsirigotis, Steven Silverman, Susan Fairchild, Steve Fruh, ""' "Alonso, Richard"

05t2812010 04:54 PM

IZa i I l-r

Thanks for your note. As you know, PCA has been working diligentÌy over the past six months to collect THC, and more recently HCI data. The recess-ion and associated state of the industry has severely hampered our data coflectlon efforts and resuÌted in unfortunate delay in the data collection timeframe we had origina-lly envisioned. Nevertheless, as r have indicated to you previous-ly, we plan to transmit to you a partial set of the THC data, representing approximately 2/3 of the data that we had orlginally hoped to collect, by Monday, June 7. I appreciate your patience and understandlng for what has been a very challenging period for the u.S. cement industry.

Regards,

Andy O'Hare

Andrew T. O'Hare/ CAE

Vlce Presrdent, Regulatory Affairs

Portland Cement Association

500 New Jersey, Avenue, NW

Washlngton, DC 20001

Phone: (202) 408-9494

Fax: (202) 408-081-l

Cefl: (202) 210-0094

e-maif : aohareGcement.org

-----Originaf Message-----

From: Barnett . KelthGepamail . epa . gov fmailto : Barnett . Kelth@epamaiÌ . epa . gov] Sent: Friday, May 28, 2OI0 4:45 pM

To: O'Hare, Andrew

Cc: Tsirigotis . PeterGepamail . epa . gov; siÌverman. stevenGepamalf . epa. qov,.

F alrchild. SusanG epama_if . epa . gov; Fruh . Steve@epamail . epa . go-, subject: THC Data from PCA's Voluntary Data Gathering Effort

TO: Andy O'Hare of the Portland Cement Associatlon and the portland

Cement NtrSHAP Docket

Dear Andy:

our office of General counsel, the Department of Justice, and r had a

call wrth Rlch Alonso today. In that calÌ we cornmunicated to hlm that

PCA must send to us by coB June 3, 2070, afl avalfabÌe THC emissions data in their possession that was generated as part of PCA's voluntary

THC data qathering effort. r repeat that same statement to you here: i

EPA has not received the data by that tlme we cannot guarantee that we wifl be ab-re to consider the data in making our decislons reqarding standards for THC in the flnaf Port_land Cement NESHAP.

Kerth !r/. Barnett

USEPA/OAQPS /SPPD/MMG Maif Code D243-02

Research Trlangle Park, NC 2'1177
919-541-5605

barnett. keithGepa. gov
Page 1 of 1

THC Data

O'Hare, Andrew

to:

Keith Bamett

06/0812010 02:14Pl¡4

Show Details

Keith,

My apologies for not being able to transmit it to your attention yesterday. We have encountered some

difficulties with some of the test reports in terms of QA/QC which should be resolved shortly. I will be

transmitting to you the raw data as well as a summary of what we believe it indicates.

Regards,

Andy

Andrew T, O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

500 New Jersey, Avenue, NW

Washington, DC 20001

Phone: (202) 408-9494

Fax: (202| 408-0877

Cell: (202) 270-0094

e-mail : aohare@cement.org

fîle://C:lDocuments and Settings\kbarnett\Local Settings\Temp\notesFCBCEE\-web8166.htm 8|112010
Is

New PCA employee and was the data sent?

Keith Barnett to: Andrew O'Hare

to send the THC data?

0611412010 09:34 PM

Does this mean any changes as far as NESHAp and NSpS rulemakings?

PCA named Bryan Brendle its director of environmental and energy policy. He will focus on

regulatory issues of concern to the U.S. cement industry such as air quality, climate change,

and other matters related to the environment and health and safety, including acting as a

liaison between the cement industry and the U.S. federal govemment on appropriate issues.

Brendle brings a wealth of experience developing environmental strategies and policies. He

most recently served as director of energy and resources policies for the National Association

of Manufacturers where he was responsible for the successful lobby of inclusion of energy

and manufacturing provisions in the American Recovery and Reinvestment Act.

Previously, Brendle worked with Baise & Miller PC, a Washington, D.C. based lobbying

firm, and the Water Environment Federation.

Brendle received his Bachelor of Arts degree from Hampden-Sydney Collegg

Hampden-Sydney, Va., and received his Juris Dqctor from Mercer Law School, Mercer

University in Macon, Ga.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-02

Research Triangle Park, NC 27711

91 9-541 -5605

ba rnett. keith @epa. gov
RE: New PCA employee and was the data sent?

O'Hare, Andrew to: Keith Barnett

It is comlng,

On a reÌated

rev1ew.

PCA named Bryan Brend-le its director of environmenta_L He wilf focus on regulatory issues of concern to the U

such as air quality, cfimate change, and other matters environment and health and safety, including acting as the cement industry and the u.s. federal qoíernment on

Previously, Brendfe worked with Baise & MiÌler pC, a

lobbying firm, and the !ûater Environment Federation.

06/15/2010 'l 

1 :07 AM

I promise.

note, wlll send you a draft agenda for the meeting on Monday to

-----Orrgina_I Message----

F rom: Barnett . KelthGepamall . epa . gov [mailto : Barnett Sent: Monday, June 14, 2OIO 9:35 pM

To: O'Hare, Andrew

Subject: New PCA employee and was the data sent?

KeithGepamai_l . epa. govl

Is there a date to send the THC data?

Does this mean any changes as far as NESHAp and NSps ruremakinqs?

Brendfe brings a wealth of experience _deveÌoping environmentaf strategies and policles ' He most recentÌy served as diiecior of energy and resources policies for the NationaÌ assoclation of Manufacturers where he was

manufacturing 

responsible for the successfuf robby of incfusion of energy and provisions 1n the American Recovery and Reinvestment Act.

and energy poÌlcy.

. S. cement lndustry,

related to the

a fiaison between

appropriate issues.

l{ashington, D. C. based

Brendle received his

Hampden-Sydney, Va.,

Mercer University in

Bachefor of Arts degree from Hampden-Sydney ColÌege, and received his Jurls Doctor from Mercer Law schooÌ, Macon, Ga.
Keith W. Barnett

USEPA/OAQPS / S PPD/MMG

Maif Code D243-02

Research TriangÌe park,

9r9-541-5605

barnett . kelthGepa. gov

NC 2117I
Re: THC Data li

Keith Barnett to: O'Hare, Andrew

Yes I got it.

Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

MailCode D243-02

Research Triangle Park, NC 27711

91 9-541 -5605

ba rnett. keith@epa. gov

O'Hare, Andrew Keith, Did you receive the THC data I sent on W

06118t2010 08:31 AM

0611812010 0B:13:28 AM

From:

To:

Date:

Subject:

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

Keith BarneIURTP/USEPA/US@EPA

0611812010 08:13 AM

THC Data

Keith,

Did you receive the THC data I sent on Wednesday? Also, will send a tentative agenda for the

meeting on Monday later today.

Regards,

Andy

Andrew T. O'Hare, CAE

Vice President, Regulatory Affairs

Portland Cement Association

500 New Jersey, Avenue, NW

Washington, DC 20001

Phone: (202) 408-9494

Fax: (202) 408-0877

Cell: (202) 270-0094

e-mail: aohare@cement.org