Portland Cement
Trinity Consultants has a long history of assisting cement facilities with their regulatory compliance and environmental management needs. With a track record that includes several hundred projects for cement clients, Trinity has the expertise to help your facility meet its environmental requirements. In addition, our active participation in associations like the Portland Cement Association (PCA) demonstrates our commitment to staying informed about the regulatory concerns your facility faces.
Regulatory Round Up
The portland cement industry is facing several new significant air quality regulations under consideration by U.S. EPA. These include updates to: New Source Performance Standard for Portland Cement Plants (NSPS Subpart F) and National Emission Standards for Hazardous Air Pollutants for Portland Cement Plants (NESHAP Subpart LLL, aka PC MACT). Additionally, portland cement plants are also being affected by recent and proposed revisions to the NSPS for Nonmetallic Mineral Processing Plants (Subpart OOO) and NSPS for Coal Preparation Plants (Subpart Y).
Subpart F requirements will, for the first time, regulate NOx and SO2 from new and modified cement kilns. In addition to the proposed limits for NOx and SO2, the NSPS will incorporate more stringent PM requirements. The proposed PC MACT revisions, if finalized as proposed, will dramatically revamp the limits and monitoring for cement kilns. Among the potential PC MACT rule revisions would be limitations on kilns for THC, HCl (for all kilns at major sources), and significantly more stringent limits of PM.
Another recently proposed regulation that will impact the portland cement industry is EPA’s mandatory greenhouse gas (GHG) reporting rule. Cement production is a source category subject to the proposed GHG Reporting rule. This rule will require emission calculations for CO2 and other GHGs and may require facilities to review and update monitoring equipment and recordkeeping practices. As proposed, reporting would be required annually, with the first reports due March 31, 2011 for calendar year 2010 emissions. This will require data collection and monitoring to begin by January 1, 2010.
Collectively, these regulatory changes mean that cement plant operators must be prepared to manage air quality issues with increasing awareness and understanding. Trinity can help cement plant operators in a variety of ways to manage these issues.
Project Profiles:
- An international cement manufacturing company had a facility that qualified as a major source for the Portland Cement NESHAP. Trinity helped the facility develop a program for compliance that included operations and maintenance plans and procedures, SSM plans, continuous monitoring system plans, and data management specifications and procedures. As a result, the facility met its Portland Cement NESHAP requirements and streamlined its compliance management activities.
- For a major national cement manufacturing organization, Trinity conducted multimedia compliance auditing for all of its facilities. Trinity visited the company's sites to review plant compliance records and practices for adequacy, gaps, and current status. Following a report of the findings, Trinity developed a site-specific environmental compliance management system for each plant. This effort allowed the client to achieve and manage compliance at a variety of facilities with different regulatory challenges
- For a cement kiln seeking to increase alternative fuel and raw material flexibility, Trinity evaluated and prepared permit applications to obtain the appropriate air permits. The assessment included the evaluation of potential air toxic releases, application of NSR Reform principles, and public meeting support.