1 September 7 , 2011



### Clinker Piles

What Has PCA Proposed to EPA ? PCA has proposed that in lieu of design and management standards for clinker piles contained in recent changes to the portland cement NESHAP, that cement plant operators be obliged to employ a ppropriate management practices to minimize fugitive emissions from these facilities , pursuant to the NESHAP general duty clause found at Section 63.1348(d).

What Types of Provisions are Contained in Existing Title V Operating Permits to Address
Emission from Fugitive Sources like Clinker Piles ? Virtually all Title V permits oblige cement plant operators to minimize fugitive emissions. Some permits establish an opacity limit not to be exceeded in conjunction with materials management. Others contain a “no visible emissions” limitation imposed at the fence line of the facility. An example permit provision is
as follows:

“Good housekeeping shall be observed throughout the facility to minimize fugitive emissions. All material spills shall be cleaned up a s soon as practicable and in such manner as to minimize fugitive dust emission losses.”

What Practices are Currently Employed at Cement Plants to Minimize Fugitive Emissions from
these Facilities ? As indicated above, virtually all cement plants have an o bligation to minimize fugitive emissions from the plant site. To accomplish this, plants employ a number of practices to minimize emissions from piles of clinker stored outdoors. The most common practices are to use water sprays to form a concrete like c rust on the exposed surface of the clinker pile. Clinker has cement like properties and when exposed to water will hydrate and harden. The crust formed by this practice is very effective at reducing fugitive emissions as long as the pile is
not disturbed . The other most common practice is to cover these piles with tarps. The tarps are held down with tires in some instances, and effectively minimize fugitive emissions. Some plants also use foam sprays on the exposed surface of the pile, forming a coatin g which prevents fugitive emissions.

What Would Implementation of the Clinker Design and Management Standards Cost a Typical
Cement Plant ? The capital and operating for storing 50,000 tons of clinker are summarized below, broken down by facilities less than 1000 feet from the property line and those greater than 1000 feet from the property line. It is estimated that more than 30 of the roughly 100 plants in the U.S. would be required to make these plant investments.2 50,000 Ton Clinker Pile Facility Cos t: <1000’ and >1000’ from the Property Line Distance from Property Line Capital Costs Annual Operating Costs < 1000 feet (fully enclosed structure) $10

- 25 million $400,000

- 500,000

>1000 feet (three sided structure with tarps) $550,000

- 1.5 million $50

- 15 0,000

When Would Cement Plants Need to Begin the Process of Designing a Clinker Storage Facility to Comply by September 2013 ? When Would the Majority of the Capital Cost be Incurred ? Facilities that need to construct a fully enclosed structure (<1000 fe et) have already developed initial designs and have initiated the construction and operating permit process. To facilitate compliance by September 2013, the designs will have to be completed by the end of 2011 so that the appropriate permits may be secure d in time to begin construction in the second quarter of 2012 to ensure completion by the second quarter of 2013 to then allow time to develop and test new clinker management procedures and the air pollution control equipment associated with the new storag e facilities. The most significant capital expenditures will occur before the fourth quarter of 2012.

Plants focused on structures greater than 1000 feet from the facility will not require the same length of time to construct the facilities, though the permitting and testing of new clinker management procedures and timing of significant capital expenditures will be very similar.

Attached pleased find a series of schedules for the construction of various types of clinker storage facilities. The schedules outline timeframes for doing engineering, permitting, procurement, construction and commissioning. It is worth noting, that in regards to permitting, this phase may take much longer than reflected on the charts, owing to processes addressing
land use dec isions contained in laws such as , for example, the California Environmental Quality
Act.