EPA Proposes Revisions to its NESHAP for the Portland Cement Manufacturing Industry
In the September 21, 2017 Federal Register, EPA proposed amendments to correct and clarify the NESHAP’s requirements. The proposed rule is part of EPA’s residual risk and technology review. During the review, EPA found risks due to the emissions of air toxics to be acceptable, and did not identify new cost-effective controls. Therefore, EPA proposed no revisions to the numerical emission limits. Public comments will be accepted through November 6, 2017.
EPA proposed revising the reporting paragraph to remove a reference that required sources to report their 30-operating day rolling average temperature requirements pertaining to D/F in the rule. The rule does not contain 30-day operating day rolling average temperature requirements pertaining to D/F in the rule. EPA also proposed correcting a provision that requires owners or operators to keep records of both daily clinker production and kiln feed rates. Section 63.1350(d)(1)(ii) only requires daily kiln feed rates if the facility derives their clinker production rates from the measured feed rate. The Submittal dates for the semiannual summary reports are 60 days after the end of the reporting period. Additional revisions resolve the conflict between provisions that apply when an So2 continuous parametric monitoring system is used to monitor HCl compliance. Section 63.1349(b)(1)(vi) only applies to kilns with inline raw mills, and does not apply to kilns that do not have inline raw mills or to a clinker cooler (unless the clinker cooler gases are combined with kiln exhaust and sent through an inline mill). EPA also proposed that the 1989 TEFs be incorporated into the rule to clarify that they are the appropriate factors for calculating TEQ. Finally, EPA proposed a clarification regarding the performance test requirements for sources that have been idle for one or more periods that required a performance test to demonstrate compliance. Affected sources unable to demonstrate compliance before the compliance date due to being idled, or that had demonstrated compliance, but was idled during the normal window for the next compliance test, must demonstrate compliance with the emissions standards and operating limits using the test methods and procedures in 40 CFR 63.1349 and 63.7.
EPA, Proposed Rule, National Emission Standards for Hazardous Air Pollutants From the Portland Cement Manufacturing Industry Residual Risk and Technology Review, 82 FR 44254, September 21, 2017
