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MEMO to Docket

DATE: January 30, 2015

SUBJECT: Telephone conversation on Portland Cement Subp art LLL

In attendance: Keith Barnett, US EPA

Carrie Yonley, P.E., Vice President, Schreiber, Yonley & Associates/A Trinity Consultants Company

Ms. Yonley asked some clarifying questions on the regulatory text for subject rule. T hese questions (some of which were also asked by other commenters) produced cl arifications that were added to the amendments, to be promulgated in April 2015. These issu es are as follows:

1. 63.1348(a) NOTE: Ms. Yonley asked if this note implied that you must complete the performance test prior to o r on the compliance date. We received this question via telephone as well from another requestor. The answer is in the Respo nse to Comment document, number 23, and is copied here:

“ Several commenters through telephone communications (as recorded in the final docket) have requested clarification on the Note for Paragraph (a) of Section 63.1348 relative to whether you must compl ete the performance test prior to or on the compliance date. Also the commenters seek clarification on the actual compliance date, since the general provisions under 63. 7 allows 180 days after the compliance date to show compliance.

RESPONSE: The sou rce must perform Relative Accuracy Test Audits (RATA) for the CPMS or CEMS before the compliance dat e, since according to 63.1351 (c), the compliance date for existing sources for all the requirements that become effective on February 12, 2013 (except for t he open clinker pile requirements) will be September 9, 2015. The Note to paragraph (a) was to provide clarification that a source’s 30 day operating day performance test could start the day after the effective date, so that the rolling averages would beg in to be developed following the first monitoring day after the compliance date . 40 CFR 63.7 does give the source 180 days to demonstrate compliance, however existing sources are expected to be operating in compliance on the effective date of the rule. It is expected that existing sources have procured their monitoring equipment and done their RATA for each emission source and is confident that they are in compliance on the compliance date. ”

2. 63.1348 (b)(iii). This section did not make it clear that sta rtup and shutdown was not to be included in data recorded and calculations used to report emissions. Startup and shutdown exemption was inadvertently omitted from this section, from the 2013 rule, and thus has been
added.2

3. Does the dioxin temperature limit during startup/shutdown still apply because we no longer require monitoring during startup and shutdown? This question is also covered in the Response to Comment document, number 24:

“ Dioxin Testing Temperature Limit D uring Startup/Shutdown

One commenter as listed in the docket, requested clarification that the temperature limit as listed in Section 63.1343(a), footnote (2), still applies during startup/shutdown situations.

RESPONSE: The temperature shown in footnot e (2) to Table 1 under Section 63.1343(a) is a decision point and ultimately a parametric limit measured during the performance test, whereby if the average temperature at the first PM control device inlet during the performance test is 400 degrees F or le ss, the limit is 0.40 ng/dscm (TEQ), but if it is greater than 400 degrees F, the limit is 0.20 ng/dscm (TEQ). The source must then comply with the limit recorded during that performance test. Once the limits are set during the dioxin compliance test, th ey apply at all times, and thus, to assure compliance, the temperature operating limit is to be continually monitored during startup and shutdown. ”

4. Does the cement kiln dust annual records requirement (Section 63.1355(d)) still apply?

No, we are removing this requirement. This is covered in the Response to Comment document,
number 10:

“ Out of date regulation under 40 CFR 63.1355(d)

Commenter 0861 stated that the rule contains an out of date requirement to keep annual records of the
amount of cement kiln d ust (CKD) removed from the system. This requirement is no longer valid since the new rule utilizes mercury controls and compliance demonstrations for meeting the new mercury limit, and thus the CKD records are not relevant.

RESPONSE: The EPA agrees that 40 CFR 63.1355(d) is no longer relevant since the final rule utilizes mercury controls and the CKD records are not needed when compliance entails the procedures required in 63.1350, and thus is removing this requirement from the final rule. ”