From:   Chuck French/RTP/USEPA/US  

To:   "King, Heidi R." <Heidi_R._King@omb.eop.gov>

Cc:   Amy Branning/DC/USEPA/US@EPA, Paula VanLare/DC/USEPA/US@EPA, Sharon

Nizich/RTP/USEPA/US@EPA, Steve Fruh/RTP/USEPA/US@EPA, Wendy Blake/

DC/USEPA/US@EPA

Date:   04/13/2010 12:29 PM  

Subject: RE: Interagency comments under EO 12866 on the Gold Ore Processing

NESHAP Draft NPRM

Hi Heidi,

With regard to mercury CEMS at other types of facilities, in the MACT proposal

for cement we mentioned that there were 34 cement plants in Germany that

currently use Hg CEMs and a brief description.The page from that proposal is

attached below. The CEMs text is near the bottom of the middle column.

Let me know if you have questions.

Thanks.

Chuck

(See attached file: Hg CEMS Pages from cement FR proposal.pdf)
21156 Federal Register / Vol. 74, No. 86 / Wednesday, May 6, 2009 / Proposed Rules 

36 Information related to the development of 

Performance Specifications 12A and 12B can be 

found in dockets EPA–HQ–OAR–2002–0056 and 

EPA–HQ–OAR–2007–0164. 

37E-mail and attachment. M. Bernicke, Federal 

Environment Agency to A. Linero, Florida 

Department of Environmental Protection. February 

8, 2009. 

38Notwithstanding the connections between the 

performance specifications and this proposal, the 

mercury monitoring performance specifications 

remain technically independent from the proposed 

standards, as they exist independent of the 

proposed standard (see following paragraph in text 

above). Furthermore, EPA has adopted, and would 

continue to adopt such specifications and protocols, 

whether or not it were amending the NESHAP for 

portland cement kilns. 

exhaust. However, there need to be 

different conversion factors from 

concentration to mass per unit clinker. 

In the case where clinker cooler gas is 

combined with the kiln exhaust the 

standard would need to be adjusted to 

allow for the increased gas flow. If this 

allowance is not made, then the 

effective level of the PM standard would 

be reduced (the result being that the 

proposed standard would not properly 

reflect best performing kilns’ 

performance, and also discouraging use 

of a desirable energy efficiency 

measure). See 73 FR at 64090–91 (Oct. 

28, 2008). Therefore, we are proposing 

that facilities that combine the kiln and 

clinker cooler gas flows prior to the PM 

control would be allowed to convert the 

equivalent concentration standards 

(which are 0.0067 or 0.0063 lb/ton 

clinker for new and existing sources, 

respectively) to a lb/ton clinker standard 

using their combined gas flows (dry 

standard cubit feet per ton of feed). It 

should be noted that this provision will 

not result in any additional PM 

emissions to the atmosphere compared 

to the same kiln if it did not combine 

the clinker cooler and kiln exhaust, and 

may actually decrease emissions slightly 

due to improvements in overall process 

efficiency. 

In addition to proposing to amend the 

PM standard for kilns we are proposing 

to similarly amend the PM emissions 

limit for clinker coolers. Fabric filters 

are the usual control for both cement 

kilns and clinker coolers. As EPA noted 

in our proposed revision to Standards of 

Performance for Portland Cement Plants 

(73 FR 34078, June 16, 2008) we believe 

that the current clinker cooler controls 

can meet the same level of PM control 

that can be met by the cement kiln. 

Therefore, we are proposing as MACT 

the same PM emissions limits for both 

clinker coolers and kilns. 

In sum, because we believe that the 

costs of a beyond-the-floor standard for 

PM are not justified, we are proposing 

a PM standard for existing kilns and 

clinker coolers of 0.085 lb/ton of 

clinker, and for new kilns and clinker 

coolers of 0.080 lb/ton of clinker. 

F. Selection of Compliance Provisions 

For compliance with the mercury 

emissions standards we are proposing to 

require continuous or integrated 

monitoring (either instrument based or 

sorbent trap based). As explained earlier 

in this preamble, we do not believe that 

short term emission tests provide a good 

indication of long term mercury 

emissions from cement kilns. We 

considered the option of requiring 

cement kilns to measure and analyze 

mercury content of all inputs to the kiln, 

as was done to gather the data used to 

develop the proposed standards. 

However, that data gathering was done 

based on a daily analysis of all inputs 

to the kiln. If we were to make that the 

compliance option and require daily 

analyses, the cost would be comparable 

to the cost of a mercury monitoring 

system. If we were to allow less frequent 

analyses to reduce costs, then we are 

concerned that the accuracy may be 

reduced (and the standard would no 

longer be implemented in the same 

manner as it was developed). In 

addition, in order to meet the proposed 

mercury emission limits, we anticipate 

that many facilities will install add-on 

controls, which will create another 

variable that would make the 

measurement of mercury content of 

inputs (instead of continuous or 

integrated stack measurement) 

significantly less accurate. In order to 

determine an outlet emissions rate 

based on input measurements, the 

control device would have to be tested 

under various operating conditions to 

insure that the removal efficiency could 

be accurately calculated, and 

continuous monitoring of control device 

parameters (i.e. parametric monitoring) 

would be necessary. Given issues 

related to input monitoring, and the cost 

associated with control device 

monitoring, plus a desire to implement 

the standard in a manner consistent 

with its means of development, we 

believe that a continuous or integrated 

mercury measure at the stack is the 

preferred option, and are proposing that 

sources demonstrate compliance with 

mercury monitoring systems that meet 

either the requirements of PS–12A or 

PS–12B.36

We are not aware of any cement kilns 

in the U.S. that have continuous 

mercury monitoring systems. However, 

there are numerous utility boilers that 

have installed and certified mercury 

CEMS. We see no technical basis to say 

that these continuous mercury 

monitoring systems will not work as 

well on a cement kiln as they do on a 

utility boiler. In addition, we are aware 

that there are 34 cement kilns that have 

operating continuous mercury monitors 

in Germany.37 There were problems in 

the application of continuous mercury 

monitoring systems when they were 

first installed on these German cement 

kilns, but their performance has been 

improved so they now provide 

acceptable performance. We are 

requesting comment on the feasibility of 

applying mercury continuous 

monitoring systems to cement kilns in 

the United States. 

Generally, we propose and 

promulgate monitoring system 

performance specifications and 

performance test methods in accordance 

with their development, independent of 

publication of source category emissions 

control regulations. There are 

circumstances dictating that we publish 

such measurement procedures and 

requirements simultaneously with an 

emissions regulation because of integral 

technical relationships between the 

standard and the monitoring 

performance specifications and test 

methods and because such a 

combination is convenient and costeffective. Such combined publication 

also allows commenters to prepare 

comprehensive comments on not only 

the performance specifications or test 

methods but also on their specific 

applications. In today’s notice, we are 

reproposing to amend 40 CFR part 60, 

appendix B by adding Performance 

Specification 12A—Specifications and 

Test Procedures For Total Vapor Phase 

Mercury Continuous Emission 

Monitoring Systems in Stationary 

Sources. We are also proposing to 

amend 40 CFR part 60, appendix B by 

adding Performance Specification 12B— 

Specifications and Test Procedures For 

Monitoring Total Vapor Phase Mercury 

Emissions from Stationary Sources 

Using a Sorbent Trap Monitoring 

System, and proposing to amend 40 CFR 

part 60 Appendix F by adding 

Procedure 5—Quality Assurance 

Requirements for Vapor Phase Mercury 

Continuous Monitoring Systems Used at 

Stationary Sources for Compliance 

Determination.38

We previously promulgated versions 

of these performance specifications with 

the Clean Air Mercury Rule (CAMR). On 

March 14, 2008, the Court of Appeals 

for the District of Columbia Circuit 

issued its mandate vacating CAMR on 

other grounds not related to these 

performance specifications. We are 

reproposing these performance 

specifications today. We also want to 

make clear that these performance 

specifications are generally applicable, 


rwilkins on PROD1PC63 with PROPOSALS3