Memorandum

TO: Portland Cement Project Team

FROM: Keith Barnett, US EPA

SUBJECT: Revised Floors without Kilns that Would have been CISWI Kilns Had the Solid 

Waste Definition Applied

DATE: April 25, 2011 

Revision of Emission data base to remove possible CISWI kilns

The following table lists kilns that had been identified as potential CISWI kilns in the proposal of 

the CISWI rule. This list was compiled based on responses to an EPA survey and was based on 

the proposed definition of non-hazardous solid waste. 

Table 1. List of CISWI Cement 

Kilns at Proposal of the CISWI 

Rule

ALCemexDemopolis

ALLafargeRobertaPlant

ALLehighCementCoLeeds

CACAPortlandCementColton

CALehighSouthwestReddingPlant

CAMitsubishiCement

CANationalCementofCA

FLCemexBrooksville

FLCemexMiami

FLFloridaRock

FLRinkerBrooksville

GACemexClinchfield

IALafargeBuffalo

IALehighCementMasonCity

IDAshGroveInkom

ILBuzziUnicemOglesby

ILLafargeJoppaPlant

KSMonarchCementCoHumboldt

MDESSROCFrederickPlant

OKLafargeTulsaPlant

OKLoneStarPryor

ORAshGroveDurkee

PAEssrocItalcementiGroupBessemer
PALafargeWhitehallPlant

PALehighCementEvansville

PALehighCementYork

SCLafargeHarleyville

TNCemexKnoxville

TXAshGroveMidlothian

TXCemexBalconesPlant

TXHolcimMidlothianPlant

TXLoneStarMaryneal

UTAshGroveLeamington

UTHolcimDevilsSlide

WAAshGroveSeattle

WALafargeSeattle

Follow up questions were sent by EPA to these facilities to gain additional information on some

of their fuels, specifically used oil, tires, wood waste and spent seed corn. These responses were 

then reviewed based on the final solid waste definition rule signed on February 21, 2011. The 

final solid waste rule states that tires that come from an established tire collection program, clean 

wood, clean biomass, and used oil that is on spec are not solid waste. We eliminated the kilns 

that burned only these alternative fuels from the CISWI list. The remaining CISWI kilns are 

shown below in Table 2. 

Table 2. CISWI Cement Kilns

FacilityID UnitID

Lehigh Southwest, Redding CA In-Line Kiln/Raw Mill (S260)

Cemex, Miami FL Cement Kiln

Lafarge, Buffalo IA Kiln 1

Lehigh Cement, Mason City IA 302.203

Lafarge, Whitehall PA Kiln 2

Lafarge, Whitehall PA Kiln 3

Lehigh Cement, Evansville PA 122

Lehigh Cement, Evansville PA 121

Lehigh Cement, York PA 200

Holcim, Midlothian TX Kiln 2

Holcim, Midlothian TX Kiln 1

Holcim, Devils Slide UT Kiln 1

Ash Grove Cement, Midlothian TX Kilns 1 through 3

California Portland Cement, Colton 

CA

Kilns 1 and 2
In addition to the kilns above, the recent ICR follow up on alternative fuels indicates the 

following kilns in Table 3 would also be CISWI kilns (though they were not in the CISWI data 

base). 

Table 3. Additional Kilns identified as CISWI Units (but are not in CISWI data base)

Location Number of Kilns Why is it CISWI?

Lehigh, Union Bridge MD 1 Burns dried biosolids as a fuel

Lafarge, Alpena MI 5 Burns Plastics

Note that it is EPA’s position that combustion does not occur in the cold end of a cement kiln. 

Materials that enter the cold end of the kiln are gradually heated until they reach the temperature 

where clinker formation takes place. This is in contrast to combustion where fuel is introduced 

into the kiln at a location where the temperature is sufficient to immediately commence the 

process of combusting the fuel. (Fuels are never burned in the cold end of a cement kiln, and 

our interpretation reflects that understanding.) This means that cement kilns’ practices of using 

non-hazardous secondary materials in the cold end of the cement kiln would not make the kilns

“solid waste incineration unit[s]” within the meaning of section 129 (g)(1) of the CAA since

kilns would not “combus[t]” those materials. Consequently, we do not include any cement kiln 

in this analysis based on utilization of non-hazardous secondary materials in the cold end of the 

cement kiln.

For purposes of this analysis, all of the kilns shown in Tables 2 and 3 were taken out of the 

Portland cement emissions data base and the floors recalculated as shown below. That is, we 

recalculated the floors as if the recently promulgated definition of non-hazardous secondary

materials which are solid wastes had been in place at the time of the cement kiln NESHAP 

rulemaking. 

Mercury Floor

The mercury floor was calculated based on a data base of 89 kilns where we had approximately

30 days of data on all mercury inputs. Twenty-two of the 23 CISWI kilns shown above were 

part of the mercury data base. Removing the 22 CISWI kilns leaves 67 kilns. The best 

performing 12 percent would be 9 kilns.

Of the best performing 11 kilns that were used in the previous floor calculation, two would have 

been CIWSI, 1589, and 1248. Removing these kilns from the MACT floor pool leaves the 9 best 

performing kilns. The single best performing kiln now becomes kiln 1650.

The floors were recalculated (See attachment 1) based on the best performing 9 kilns and the 

new source floor was recalculated based on kiln 1650. The results were as follows:

Existing Source floor: 58 lb/MM tons clinker (versus 55 in the current rule)

New Source Floor: 24 lb/M tons clinker (versus 21 in the current rule)
THC Floor

The THC Floor was re-estimated using the THC data set used in the final rule. This data set 

(shown in Attachment 2) consisted of 15 kilns where we had continuous monitoring data. Of 

these 15 kilns, four would have been CISWI kilns (including Union Bridge, the best performer

on average). This leaves 9 kilns (see attachment 3), and the best 12 percent would be two. The 

best performing kilns on average become Suwannee, Branford and Holcim Trident. The resulting

floor based on the 99th percentile of the data of the two floor kilns is 15 ppmvd and the new 

source floor would be 11 ppmvd (see attachment 4). The corresponding organic HAP limits 

(under the alternative standard) would be 6 and 4 ppmvd respectively.

PM Floor

There were 45 kilns in the PM data set used in the final rule (see attachment 5). Removing the 

CISWI kilns left 28 kilns (see attachment 6). The best performing kilns would be the top 4. 

New source MACT does not change; it is still the Mitsubishi kiln.

The existing source MACT floor using the four best performing kilns is 0.05 lb/ton clinker (See 

Attachment 7). 

HCl Floor

There were HCl test data for 20 major source kilns used in the final rule (see attachment 8). 

Four of the 20 were CSWI kilns, leaving 16 NESHAP kilns (see attachment 9). The best 

performing 12 percent would be 2. Recalculation of the floor based on the two best performing 

kilns results in a floor of 1 ppmvd (see attachment 10), which is still below the minimum

quantification limit of 3 ppmvd. This standard thus would remain at 3 ppmvd for new and 

existing sources.