On December 20, 2012, the U.S. Environmental Protection Agency (EPA) finalized amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) and New Source Performance Standards (NSPS) for Portland cement plants. As previously reported in the July 25, 2012, HGS Environmental Update, EPA proposed the amendments in response to a federal court decision, industry comments and petitions for reconsideration, and technical information received after the final rules were issued in 2010. In comparison to the 2010 rule, EPA estimates cement kilns will have to spend $52 million less to implement the amended rule. EPA also acknowledged that cement kilns that burn non-hazardous solid waste will be subject to emission standards for Commercial/Industrial Solid Waste Incinerators (CISWI), not the Portland cement plant NESHAP and NSPS.
As amended, the rules maintain stack emission standards for mercury, hydrogen chloride (HCl), and total hydrocarbons under the NESHAP. For particulate matter (PM), however, NESHAP amendments require manual stack testing in lieu of continuous emission monitoring systems (CEMS) and require establishing site-specific parametric operating levels using a PM continuous parametric monitoring system. Consequently under the NESHAP, PM standards are revised to 0.07 pounds per ton (lb/ton) clinker (from 0.04 lb/ton on a 30-day average with a PM CEMS) and 0.02 lb/ton clinker for new and reconstructed sources (from 0.01 lb/ton on a 30-day average with PM CEMS). Under the NSPS, PM standards are revised to 0.07 lb/ton clinker (from 0.01 lb/ton on a 30-day average with a PM CEMS) and 0.02 lb/ton clinker for new and reconstructed sources (from 0.01 lb/ton on a 30-day average with PM CEMS). The amendments also ease the emission limit for organic air toxics, an alternative that kilns may meet in lieu of the emission limit for total hydrocarbons. In lieu of numeric limits, work practice standards are set for demonstrating compliance with startup and shutdown requirements.
In addition, for coal mills that use kiln exhaust as part of the cement kiln, coal mill emissions are included when determining whether the kiln complies with emission limits. For any open clinker pile, facilities may choose from a list of work practices to control fugitive emissions.
For existing sources, the compliance date for meeting PM, mercury, HCl, and total hydrocarbon limits is September 9, 2015. However, existing kilns may request an additional year. The compliance date for existing open clinker storage piles is one year from the date of publication in the Federal Register.
A copy of the rule to be published in the Federal Register is available here.
For additional information, contact Jon Harris Maurer.