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.

37 E-mail and attachment. M. Bernicke, Federal Environment Agency to A. Linero, Florida Department of Environmental Protection. February

8, 2009. 38 Notwithstanding 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,