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February 22, 2013
PM changes key in cement NESHAP

Existing sources in the Portland cement industry will have until September 9, 2015, and possibly 1 additional year to achieve compliance with EPA’s recent amendments to the Agency’s 2010 NESHAP for the sector.  The amendments are extensive, resulting from petitions for reconsideration from the industry and environmental groups, as well as a remand from the U.S. Court of Appeals for the D.C. Circuit. 

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The Agency has also issued NSPS for new Portland cement facilities or those for which construction or reconstruction commenced after May 6, 2009.  Compliance is required by February 12, 2013, or upon start-up, whichever is later.

Monitoring

According to the EPA, the most significant amendment to the 2010 rule concerns monitoring of particulate matter (PM).  In the amendments, PM serves as a surrogate for toxic metals other than mercury.  The Agency states that these changes were necessary because PM emissions could not be reliably measured using the monitoring requirements in the 2010 rule.  Specifically, the amendments:

  • Change the compliance basis for the PM standards from continuous monitoring with a PM CEMS to a manual three-run stack test.
  • Amend the level and averaging time.
  • Require site-specific continuous parametric monitoring using a continuous parametric monitoring system (CPMS).

Emissions limits

As a result of the revised monitoring requirements, the amendments also:

  • Change the NESHAP PM emissions limit for existing sources to 0.07 pounds (lb)/ton clinker and 0.02 lb/ton clinker for new and reconstructed sources.
  • Change the NSPS PM standards for modified sources to 0.07 lb/ton clinker and 0.02 lb/ton clinker for new and reconstructed sources.
  • Require that sources retest once a year to reset the PM CPMS operating limit.
  • Add a provision that if a source exceeds its site-specific parametric operating limit, it must conduct corrective action within 45 days.  Also, if the source exceeds that parametric limit four times in a calendar year, the source is presumed to be in violation of the PM emissions standard itself, subject to rebuttal by the source.

Other actions

The Agency is retaining the stack emissions standards established in the 2010 rule for mercury, hydrogen chloride (HCl), and total hydrocarbons.  In addition, the amendments include provisions that account for commingled hazardous air pollutant (HAP) emissions from coal mills that are an integral part of the kiln.

Other actions:

  • Remove all cement kilns that combust nonhazardous solid waste from the NESHAP database.  As directed by the court, these units are incinerators and are regulated under the federal emissions standards for commercial/industrial solid waste incinerators. 
  • Revise provisions that specify the elements necessary to establish an affirmative defense to respond to emissions exceedances during malfunction. 
  • Added work practice requirements for open clinker storage piles to reduce fugitive dust emissions.  Compliance with this provision is required by February 12, 2014.

Compliance date

The revised compliance dates caused dismay among environmental groups that have argued that emissions from cement plants have serious health consequences for disadvantaged communities.  But the EPA notes that the revisions provide sources with new options for PM control, including retaining electrostatic precipitators rather than replacing them with baghouses.  Plants may also size baghouses differently.

 

Moreover, the various types of sorbent injection strategies to control organics, mercury, and HCl are affected by the PM limits (and vice versa), states the EPA.  In addition, the amended alternative standard for nondioxin organic HAPs affords additional compliance alternatives.

“Determining, developing, installing, testing, and otherwise implementing a different comprehensive HAP control regime takes time,” states the EPA.  “Specifically, plants will need to conduct engineering studies, determine the most cost-effective control strategy, seek contract bids, purchase equipment, install and test the new equipment.”

The final amendments to the Portland cement NESHAP were published in the February 12, 2013, FR.

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