EHS Regulatory Compliance Support for Portland Cement
Trinity Consultants has a long history of assisting cement facilities with their regulatory compliance and environmental management needs and our engineers are well known across the U.S. industry. With a track record of three decades working for many 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) and Cement Kiln Recycling Coalition (CKRC) demonstrates our commitment to staying informed about your regulatory concerns. In 2014, Trinity acquired Schreiber, Yonley and Associates (SYA) and in 2015, Smith Aldridge, resulting in the assembling of the nation’s top cement industry experts to work together on behalf of the industry.
Environmental Regulatory Round Up for Portland Cement
The portland cement industry continually faces significant new environmental regulations that affect plant operations. Recent examples 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), and the NSPS CCCC and DDDD for Commercial and Industrial Solid Waste Incineration Units (CISWI) and the associated revisions to the definition of Non-hazardous Secondary Materials (NHSM) rules affecting the use of alternative fuels. Additionally, portland cement plants are being affected by revisions to the NSPS for Nonmetallic Mineral Processing Plants (Subpart OOO) and NSPS for Coal Preparation Plants (Subpart Y).
Subpart F requirements, for the first time, regulate NOx and SO2 from new and modified cement kilns. In addition to the NOx and SO2 limits, the NSPS incorporates more stringent PM requirements. The PC MACT revisions dramatically revamped the limits and monitoring for cement kilns requiring updated documentation, testing, instrumentation, reporting and more to address the new mercury, THC and HCl emission limitations and the significantly more stringent PM limits.
With the recent CISWI/NHSM rules, cement kilns that utilize alternative fuels now have to pay close attention to the waste versus non-waste status of the fuel, as defined by the NHSM definition rule. Plants using non-hazardous solid waste are subject to CISWI in place of PC MACT or NSPS Subpart F for the kiln system. In order to use non-hazardous alternative fuels without triggering CISWI rules, records must be developed and retained documenting that alternative fuels are sufficiently processed and that certain legitimacy criteria are met. Meanwhile, for plants using hazardous waste-derived fuel, the complicated web of RCRA permitting and the hazardous waste combustor (HWC) MACT remain in place governing kiln operations, fuels management, and the plant-wide RCRA requirements.
Collectively, the enhanced regulatory framework means that cement plant operators must be prepared to manage air quality and the broader range of environmental regulations with increasing awareness and understanding. Trinity’s engineers can support cement plant operators in a variety of ways to manage these multi-media issues from permitting, modeling and day-to-day compliance support, to emissions studies, plans, procedures and more.
Project Profiles - Portland Cement
- 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.
- For a cement company seeking to modify facility operations to use hazardous waste-derived fuel, and at similar kilns across the country, Trinity/SYA has been an instrumental partner through conducting detailed CAA and RCRA permitting, planning and overseeing complex stack testing, addressing risk assessments, preparing plans and procedures, working with the agency and public, and training plant’ staff.
- For a new greenfield Portland Cement plant, Trinity developed a Prevention of Significant Deterioration (PSD) / Nonattainment New Source Review (NNSR) permit application. This application included a top-down Best Available Control Technology (BACT) analysis for GHG emissions from the new plant. The GHG BACT analysis addressed both control measures and work practices, including measures to improve the energy efficiency of clinker production, heat recovery measures (on-site cogeneration), fuel substitution measures (including an analysis of “clean fuels”), product composition changes (considering the impacts of supplemental raw materials and cement additives), and various carbon capture and sequestration technologies (the Calera process, oxy-combustion, post-combustion solvent capture and stripping, post-combustion membranes, and superheated lime). The GHG BACT analysis, as developed by Trinity for the proposed facility, withstood the scrutiny of US EPA Region V and numerous commenters during the public notice / public hearing process and a final PSD / NNSR permit was issued. Eighteen months later, Trinity assisted this same facility with receiving a PSD / NNSR permit extension. For this effort, Trinity justified an extension of the original PSD / NNSR permit (with no changes to the original GHG BACT determination) through a review of recent permits and technology advancements.