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OAR Box 1110 

Prepped by Ryan Dugan 

Document Number: 

4) IV-E-1 

Docket Number: 

A-82-39 

Printed 4/14/2008 1:23:55 PM Sheet 4 of 156 
^~* V UNITED STATES ENVIRONMENTAL PROTECTION AGENCY #" 0 U'O/ 

Office of Air Quality Planning and Standards -TCT. 

Research Triangle Park, North Carolina 27711 ~\tZ? 

!H> r*v 

2 0 APR 1988 

MEMORANDUM 

SUBJECT: Meeting wit h Representatives of Carolina Stalite-Company 

FROM: William Harnett$ • fcuWlM 

Standards Development Branch, ESED (MD-13) 

TO: Files 

Background 

On September 22, 1986, a meeting was held between representatives 

of Carolina Stalite Company and EPA personnel to discuss the proposed 

Calciners and Dryers NSPS. 

Attending the meeting were: 

EPA Carolina Stalite Company 

Bob Ajax, SDB Bill Hendrick 

Doug Bell, SDB Charles B. Newsome 

Bill Harnett, SDB 

Ken Durkee, ISB PSI 

Bill Neuffer, ISB 

George Walsh, EMB Ed Picklesimer 

Ed McCarley, EMB 

Lori Tussey, EMB 

Peter West lin,* EMB 

Discussion 

Mr. Charles Newsome opened the meeting by stating that they had two 

basic concerns about the proposed calciners and dryers NSPS. The first 

concern was with the requirement in the standards that a continuous 

opacity monitor must be installed on all dry control devices. Their 

second concern was with a diagram of a typical lightweight aggregate 

(LWA) plant which appears on page 3-70 of the background information 

document (BID). This diagram shows a pollution control device on a 

clinker cooler. Mr. Newsome was concerned that the standards require 

a control device on the cooler as well as on the calciners and dryers. 
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ENVIRONMENTAL PROTECTIOM 

AGEWCY 

APR 25 J988 

CENTRAL DOCKET 

SECTION 
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Mr. Neuffer explained that only calciners and dryers are covered by the 

standards and no device was required on the cooler. Mr. Durkee stated 

that the diagram was presented for informational purposes and did not 

reflect the control required by the proposed standards. 

The remainder of the meeting was about the concerns of the Carolina 

Stalite Company related to the requirement for continuous opacity monitors on dry control devices. Mr. Picklesimer and Mr. Newsome stated that 

they felt the requirements were developed on the basis of regulating 

multiple industries and processes. They stated that if we were to look 

at only the LWA industry we would not see the need for this requirement. 

It was pointed out that the majority of the LWA industry uses wet 

scrubbers to control their particulate emissions. They were only aware 

of two LWA plants beside Carolina Stalite's plant that use dry control 

devices. While they agreed that opacity monitors were inappropriate 

for wet scrubbers, they felt that it was unfair to require these devices 

on dry devices when those facilities with wet scrubbers would only have 

to monitor the pressure drop and the liquid flow rate. Because opacity 

monitors are much more costly to purchase and operate than pressure 

drop and flowrate monitors, they felt that this gave a cost advantage to 

Carolina Stalite's competitors. Mr. Newsome stated that it would cost 

$500,000 to purchase, install, and operate opacity monitors on six stacks 

at their plant. No breakdown of this cost estimate was supplied to EPA. 

He felt that if they went ahead with plans to add two new kilns to the 

four kilns currently at the plant, the State would require opacity monitors 

on all six stacks. 

He stated that the State would require these monitors because of the 

proposed standards. Mr. Ajax stated that only new, modified, or reconstructed sources are covered and existing facilities are unaffected by 

the NSPS. Mr. Newsen stated that baghouse performance and problems can 

be judged and identified much easier than by requiring opacity monitors. 

He stated that if the bags were broken either the opacity will increase 

greatly or the pressure drop across the baghouse will increase as a 

result of the nonbroken bags clogging up. If the latter situation occurs, 

he stated the cost of operating the baghouse will increase and this creates 

an incentive for proper operation of the baghouse. Mr. Ajax stated opacity 

monitors are a tool to tell whether the baghouse is operating properly 

and being maintained well. He also stated that EPA's experience has 

shown that this requirement is necessary because monitors are the only 

way for an operator or EPA to know if the operation and maintenance of 

the device is proper. Finally, he stated that EPA management strongly 

supports the use of continuous monitors and for example, the Agency has 

recently proposed that monitors be installed retroactively on all portland 

cement plants covered by the NSPS promulgated for that industry in 1971. 

Mr. Newsome stated that the Carolina Stalite Company also manufactures 

baghouses and are concerned that the monitoring requirements give an 

unfair advantage to their competitors who sell wet scrubbers. He further 

stated that because baghouses capture a product and do not have the 

waste disposal problems associated with wet scrubbers, it is inappropriate 

for EPA to be discouraging the use of baghouses by requiring continous 

opacity monitors. Mr. Ajax stated that EPA cannot really deal with this 
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issue related to baghouse vendors. Mr. Newsome felt that the reporting 

and recordkeeping requirements associated with opacity monitors would 

call for an additional person at their plant. Mr. Ajax stated that with 

most opacity monitors the recordkeeping and reporting requirements would 

be minimal but this was considered in EPA's cost analysis. Mr. Newsome 

suggested that the LWA industry be given the same alternative to opacity 

monitors that was given to the gypsum and perlite industries in the proposed standards. This alternative was to have a certified observer make, 

opacity readings once a week. Mr. Neuffer and Mr. Bell explained that 

the alternative was given because it was not cost effective for those 

industries to use opacity monitors and this situation did not apply for 

the LWA industry. Mr. Newsome was asked if an alternative of daily 

opacity readings was included in the standards, would he choose to do 

daily readings at his plant or use a continuous opacity monitor. 

Mr. Newsome stated that the cost of the two alternatives would have to 

be evaluated and he was uncertain which option he would choose. 

Mr. Newsome stated that the LWA industry (approximately 25 plants) 

should be separated out and covered under a standard just for them. He 

pointed out that they have very little in common with the rest of the 

industries covered; their product sells for $25 per ton (LWA industry 

average is $20 per ton) which is much lower than the selling price the 

other industries get for their products; and the LWA industry is facing 

stiff competition from imported pumice. In addition, the LWA industry 

generally has a lower profit margin than the portland cement industry 

and their vent streams hae flowrates of 35,000 scfm compared with average 

flowrates of 500,000 scfm for other industries such as the cement industry. 

He also stated that a baghouse represents approximately 10 percent of the 

cost of a LWA plant. For all these reasons, he felt the LWA industry 

should be covered by a separate standard. Of the three LWA plants that 

currently use dry control systems, he stated that two of these plants 

would have to close if, as a result of being covered by the standards, 

opacity monitors needed to be installed. Mr. Picklesimer stated that the 

proposed standards requirements are fine and would not be weakened by the 

deletion of the continous opacity monitor requirements. EPA personnel 

agreed to consider carefully the comments of the Carolina Stalite 

repre sentatives before promulgating the final standards.