GCI TECH NOTES©

Volume 16, Number 3 A Gossman Consulting, Inc. Publication March, 2011

Portland Cement 2010 NESHAP Final Rule - Particulate

by

David Gossman

Introduction
On September 9, 2010, EPA published in the Federal Register new PC MACT regulations. Of the standards, the new particulate emission limits and monitoring requirements will be one of the most difficult to comply with.

2010 NESHAP Portland Cement final Particulate Limits - Kilns and clinker coolers

40 CFR 63.1343(b)(1)

Source	Operating Mode	Particulate Limit	Units
Existing	Normal	0.04	lb/ ton clinker
Existing	Startup & Shutdown	0.004	gr/dscf
New	Normal	0.01	lb/ ton clinker
New	Startup & Shutdown	0.0008	gr/dscf

Particulate Compliance

40 CFR 60.1348(a)(1)

Particulate CEMS
First 30 days data determine initial compliance
Hourly production rate of clinker to be determined 63.1350(d)

Particulate Compliance

40CFR 60.1348(b)(2)

Normal operation - Continuous compliance documented based on 30 day rolling average
Startup/shutdown - Continuous compliance documented based on 7 day rolling average

Particulate Emission Tests

40 CFR 63.1349(b)(1)

Hourly particulate emissions and stack gas flow rate data must be obtained.
Stack gas flow rate monitored in accordance with 40 CFR 63.1350(k)(4)
Note: Reporting units are specified in the rule as lb/ton of clinker

Particulate Monitoring Reporting

40 CFR 63.1350(6)

Performance Specification 11 (PS 11) of Appendix B to Part 60 is specified for CEMS.

Method 5 or Method 5i are required to be used for the correlation test method even though those methods may not be accurate at the new lower emission limits/rates based on these rules.

Site Specific Monitoring Plans

40 CFR 63.1350(p)

The New SSMP!
Different one required for each Continuous Monitoring System (CMS)
Must be available for submission at least 60 days prior to initial performance evaluation.

Particulate CEMS Regulations

Special Notes on PS 11.

Requires a particulate CEMS to be calibrated against manual stack test methods
A minimum of 15 runs must be performed to calibrate the CEMS
Duplicate trains are recommended for the manual correlation runs
Runs of less than 1 hour each may be used but with the low emission limits established in this rule that is not likely to be a viable option
PS 11 is a particularly complex standard – because it has the force of regulation an independent audit to verify compliance may be needed to avoid the EPA “gotcha”.

Interesting Items from Preamble - Particulate

While the language in the regulation might suggest that both a particulate CEMS and BLDS (bag lack detector system) are required, the preamble and correspondence with EPA make it clear that only the PM CEMS is required on the kiln and clinker cooler stacks.

Particulate CEMS – Times Have Changed

Two primary methods – light scatter and beta radiation attenuation plus others that include light extinction, probe electrification, and optical scintillation.

Numerous manufacturers – some include:

EcoChem Analytics
Altech Environmental
Sick Sensor Intelligence
Thermo Scientific
Durag Group
PCME Ltd

Conclusion: A compliance strategy is clearly needed.

Step 1:

Start early – get particulate CEMS now!
Gain particulate CEMS operating experience.
Check for compliance status over different operating conditions as well as during start-up and shut-down.

Step 2:

If out of compliance, how far?
If in compliance, how close?
Evaluate need for operating flexibility.
Can change in bypass / CED researching be used to central emissles rate?
Can small changes in raw feed/fuel impact compliance?

Step 3:

Investigate hour control strategies for other pollutants might impact particulate emissions.
Determine what design changes, including ID for upgrade, will be needed to use higher efficiency numbers logs.

by

David Gossman

Particulate Compliance

40 CFR 60.1348(a)(1)

Particulate CEMS

First 30 days data determine initial compliance

Hourly production rate of clinker to be determined 63.1350(d)

Particulate Compliance

40CFR 60.1348(b)(2)

Normal operation - Continuous compliance documented based on 30 day rolling average

Startup/shutdown - Continuous compliance documented based on 7 day rolling average

Particulate Emission Tests

40 CFR 63.1349(b)(1)

Hourly particulate emissions and stack gas flow rate data must be obtained.

Stack gas flow rate monitored in accordance with 40 CFR 63.1350(k)(4)

Note: Reporting units are specified in the rule as lb/ton of clinker

Particulate Monitoring Reporting

40 CFR 63.1350(6)

Performance Specification 11 (PS 11) of Appendix B to Part 60 is specified for CEMS.

Site Specific Monitoring Plans

40 CFR 63.1350(p)

The New SSMP!

Different one required for each Continuous Monitoring System (CMS)

Must be available for submission at least 60 days prior to initial performance evaluation.

Particulate CEMS Regulations

Special Notes on PS 11.

Interesting Items from Preamble - Particulate

While the language in the regulation might suggest that both a particulate CEMS and BLDS (bag lack detector system) are required, the preamble and correspondence with EPA make it clear that only the PM CEMS is required on the kiln and clinker cooler stacks.

Particulate CEMS – Times Have Changed

Two primary methods – light scatter and beta radiation attenuation plus others that include light extinction, probe electrification, and optical scintillation.