1 **What is in the Portland Cement Reconsideration Package** Background In May 2011 we published our list of reconsidered items from the 2010 promulgated rule, which we were petitioned on, both by industry and environmental groups. I n December 2011, we received a remand from the courts that required us to also reconsider the MACT floors since the Nonhazardous Secondary Materials (NHSM) rule had promulgated, and now CI SWIkilns that were in our original floor, were no longer part of the PC package. In April 2012, a consent agreement was reached with the PCA that requires us to consider proposing an extended compliance date and consider the im pact of a petition from Holcim C ement regarding adequacy

of the UPLequation. This package addresses these topics.

 New source standards are unchanged except for PM

– the court opinion d id not affect the floor calculation for new sources

.

 Floors for PM, THC, mercury and HCl for existing sources were recalculated with all CI SWIkilns removed.

 We are proposing to remove the requirement that the PM CEMS meet the requirements of PS

- 11. I nst ead kilns and clinker coolers must install a PM CEMS that will be used as a continuous parameter monitoring s ys tem (the same as was done in the MATS rule)

 Compliance dates

o Extended to September 9, 2015 for PM, THC, mercury , and HCl limits and associated monitoring
o Shortened to 6 months from promulgation for open clinker storage requirements and startup/shutdown recordkeeping requirements.

 Kilns with HCl controls would have the option t o use an SO2 monitor to demons trate that the HCl control device is operating properly rather than monitoring control device parameters.

 Coal mills which are heated by cement kiln exhaust (which are currentl y unregulated b y any rule) are regulated as follows:

o If the coal mill has a separate stack it is b y the Coal Prepar ation NSPS. Mercury , THC, and HCl testing is required to demonstrate that the appropriate kiln emission limits are not circumvented.

o If the coal mill exhaust is recombined with the cement kiln exhaust, the coal mill is treated an integral part of the cement kiln.

 We corrected other testing and monitoring issues raised by industry

.  Changes to monitoring and emissions limits are shown in the attached table.2

**Pollutant /Source**  **Limit in 2010 rule Proposed Limit in**  **Reconsideration Comments**  Mercury 55 lb/MM tons clinker 55 lb/MM tons clinker This is now a bey ond

- the

- floor standard THC 24 ppmv d 24 ppmv d We incorporated additional variability

from the best performing source (on average) which raised the limit from 15 to 24

. The best performing source is a CISWI kiln Alternative Organic HAP 9 ppmvd 12 ppmvd This limit was raised due to a recalculation of the lowest limit that can be reliabl y measured. PM

– Existing Sources 0.04 lb/ton clinker based on a 30 day average 0.07 lb/ton clinker

based o n a 3 run stack test Most of the increase is due to changing the PM CEMS requirement to a PM CPMS and a stack test PM

– New sources, NSPS and NESHAP 0.01 lb/ton clinker based on a 30 day average 0.02 lb/ton clinker

based o n a 3 run stack test Change is solel y due to the changes in compliance averaging time NSPS PM limit for Modified kilns 0.01 lb/ton clinker based on a 30 day average 0.07 lb/ton clinker

based o n a 3 run stack test HCl 3 ppmvd 3 ppmvd Startup/shutdown Same as stead y state operation except that all lb/ton production limits are change d to an equivalent concentration limit No change3

**Pollutant /Source**  **Limit in 2010 rule Proposed Limit in**  **Reconsideration Comments**  Monitoring during startup/shutdown Required with a 7

- day averaging period Monitoring not

required . Facility would be required to keep records of fuel and raw materials use and estimate emissions HCl Monitoring by CEM Required for all kilns that do not have a wet scrubber Only required for kiln that have no add

- on HCl controls

Outdoor Clinker Storage piles Partial or total e nclosures based on requirements developed b y SCAQMD Work practice

standards that codify current industry practice