THE EFFECTS OF ENVIRONMENTAL
REGULATIONS ON CEMENT PRODUCTION
AND EXPANSION IN EPA REGION V
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THE EFFECTS OF ENVIRONMENTAL
REGULATIONS ON CEMENT PRODUCTION
AND EXPANSION IN EPA REGION V
by
Michael Szabo
Vijay Patel
Richard Gerstle
PEDCo Environmental, Inc.
11499 Chester Road
Cincinnati, Ohio 45246
Contract No. 68-01-4147
Task No. 80
EPA Task Managers: David Kee/David Ullrich
Air Enforcement Branch
U.S. EPA Region V
230 S. Dearborn Street
Chicago, Illinois 60604
Prepared for
U.S. Environmental Protection Agency
Division of Stationary Source Enforcement
Washington, D.C. 20460
June 1979
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DISCLAIMER
This report was prepared for the United States Environmental
Protection Agency, Region V, by PEDCo Environmental, Inc., in
fulfillment of contract No. 68-01-4147, Task Order No. 80. The
contents of this report are reproduced herein, as received from
the contractor. The opinions, findings, and conclusions ex-
pressed are those of the authors, and not necessarily those of
the Environmental Protection Agency.
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ABSTRACT
This report presents the results of a study to evaluate the
effect of environmental regulations on present production and
future expansion capabilities of the 24 active cement plants in
U.S. EPA Region V. This study was done in response to allega-
tions that environmental regulations are a significant factor in
the present Midwest cement shortage. The results of a survey of
these 24 plants show that environmental regulations are not
significantly affecting overall cement production in Region V.
However, retirement of 13 percent of present cement capacity in
Region V without replacement, from 1975 to 1978, has probably
aggravated the shortage situation. Environmental regulations are
apparently a major factor in the reluctance of cement companies
to expand capacities. This situation may change in the near
future as rising cement prices improve the return on investment
from plant expansion, and as acquisitions of smaller cement com-
panies by larger corporations increase the financial capability
to expand.
111
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CONTENTS
Figures vi
Tables vii
Acknowledgment viii
1. Summary and Conclusions 1-1
1.1 Background Information 1-2
1.2 Results of Plant Survey 1-2
2. Introduction 2-1
2.1 Purpose of Study 2-1
2.2 Background of Cement Shortage in the Midwest 2-2
2.3 Outlook for Future Cement Supplies 2-4
3. Review of Portland Cement Process and Environmental
Controls/Regulations 3-1
3.1 Process Description 3-1
3.2 Major Emission Points 3-5
3.3 Applicable Control Equipment 3-7
3.4 Review of Environmental Regulations 3-9
3.5 Water Pollution Control Regulations
Applicable to Cement Manufacturing Plants 3-11
3.6 Solid Waste Regulations 3-14
4. Survey of Cement Plants in U.S. EPA Region V 4-1
4.1 Review of Plants Surveyed 4-1
4.2 Description of Data Requested 4-5
4.3 Analysis of Reported Impacts on Production
and Expansion 4-5
5. Case Histories 5-1
5.1 Case History No. 1 5-1
5.2 Case History No. 2 5-5
5.3 Case History No. 3 5-10
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CONTENTS (continued)
Page
Appendices
A. New Source Performance Standards Cement Plants A-l
B. State Implementation Plan Regulations U.S.
EPA Region V B-l
C. Environmental Protection Agency Effluent
Guidelines and Standards for Cement
Manufacturing C-l
D. Survey Form for Cement Plants in U.S. EPA
Region V D-l
E. Summary of Responses to PEDCo Survey of Cement
Plants in U.S. EPA Region V E-l
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FIGURES
Number Page
1-1 Production Trends for Cement Plants in
Region V, 1972-1978 1-4
3-1 Process Flow Diagram for Portland Cement
Production 3-2
3-2 Schematic of a Rotary Kiln 3-4
4-1 Locations and Capacities of Cement Plants
Located in U.S. EPA Region V 4-4
4-2 Level of Production for Cement Plants in
U.S. EPA Region V 4-8
4-3 Permit Process for State of Ohio 4-18
VI
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TABLES
Number Page
3-1 Emission Factors for Cement Manufacturing
Without Controls 3-6
3-2 Summary of Control Equipment on Major
Emission Points 3-10
3-3 Emission Regulations for States in U.S. EPA
Region V 3-12
4-1 Review of Cement Plants Surveyed 4-2
4-2 Factors Reported as Impacting on Current
Production and Expansion of Cement Plants
in Region V 4-6
4-3 Cement Production Trends in U.S. EPA
Region V, 1972-1978 4-10
4-4 Cement Plants Closed Without Replacement in
U.S. EPA Region V, 1975 Through 1978 4-21
vn
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ACKNOWLEDGMENT
This report was prepared for the U.S. Environmental Protec-
tion Agency, Region V, Chicago, Illinois, by PEDCo Environmental,
Inc., Cincinnati, Ohio.
The project was directed by Mr. Richard W. Gerstle, and
managed by Mr. Michael F. Szabo. Principal authors were Mr.
Szabo and Mr. Vijay P. Patel.
Mr. David Kee was the task manager for U.S. EPA Region V,
and we appreciate his direction and cooperation.
We also thank the cement companies in Region V, who partici-
pated in our survey, and were very cooperative in providing
information for this report.
The Portland Cement Association and the Bureau of Mines also
provided valuable input for this report.
Vlll
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SECTION 1
SUMMARY AND CONCLUSIONS
This report evaluates the effects of environmental regula-
tions on current production and potential expansion of the 24
*
cement plants in U.S. EPA Region V. One additional plant in
Ohio, which was closed in 1976 but is being reopened by another
company, was not included in the survey because it was in opera-
tion only part of 1978 and was only grinding clinker. The report
was written in response to allegations that environmental regula-
tions are contributing to a cement shortage in the Midwest, which
has slowed construction activity and raised public concern about
the causes of the shortage.
In early 1979, PEDCo surveyed each of the 24 plants in
operation in Region V. The information in this report is based
on that survey, on subsequent contacts with personnel in several
of the plants, on information obtained from U.S. EPA Region V and
from state environmental control agencies, and on a literature
review.
EPA Region V consists of the States of Illinois, Indiana,
Michigan, Minnesota, Ohio, and Wisconsin.
1-1
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1.1 BACKGROUND INFORMATION
Many reasons have been cited for the Midwest cement short-
age, which started in the West in 1977 and spread eastward to the
Midwest by 1978. The major reasons mentioned in the literature
include unusually high demand, caused by increased construction;
lower production, caused by such short-term factors as bad weath-
er, the 1978 coal strike, transportation bottlenecks and strikes,
and shipments of cement from the Midwest to other states; and the
effect of environmental regulations on production and expansion
capabilities, including some plant closings. Shortages were
predicted again for the 1979 building season.
1.2 RESULTS OF PLANT SURVEY
Of the 24 cement plants in Region V, 10 are dry process, and
3 of these 10 plants have preheater kilns, the most energy effi-
cient means of producing cement. Ten plants are wet process,
which consumes more energy than the dry process. The remaining
four plants have clinker grinding facilities only.
Fifteen of the 24 plants use coal exclusively for normal
operation, two use coal and natural gas, two use coal and oil,
and one uses oil and gas. The four grinding plants use elec-
tricity for grinding.
1.2.1. Effect of Environmental Regulations on Current Production
Only 2 of the 24 active plants reported a serious loss in
production (about 50 percent) for 1978; both of these plants,
which have preheater kilns, were visited. In one of them, start-
up coincided with the severe winter of 1978. This circumstance
1-2
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and two catastrophic process failures in the spring of 1978 were
responsible for most of the production loss. At the other se-
verely affected plant, nearly all the production loss stemmed
from a continuing process problem that caused opacity violations
during roller mill startup and when changing from the mill oper-
ating mode to a bypass mode utilizing flue gas conditioning
towers.
Twelve other plants indicated that environmental regulations
are reducing the amount of cement they can manufacture by an
average of 2 to 5 percent. The reduction is caused by state
regulations that require cement plants to slow or stop kiln
rotation when control equipment malfunctions occur, when the
control system is shut down during transitions, or when exhaust
gas conditions are too unstable for adequate particulate collec-
tion. The last circumstance applies particularly to kilns
equipped with electrostatic precipitators for particulate con-
trol.
Overall production for a normal year with no severe prob-
lems, as reported by the 24 plants in operation in Region V, is
approximately 94 percent of the design capacity given in the 1977
annual yearbook of the Portland Cement Association. Cement
producers generally cite 80 percent of design capacity as repre-
senting normal production. Environmental regulations do not,
therefore, appear to have a significant effect overall, on pro-
duction levels in these plants. Figure 1-1 presents the produc-
tion trend for the plants from 1972 through 1978 and shows that
1-3
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16
14 -
12
10
METRIC CONVERSION^ TONS X 0.9071= Mg
c
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Z
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BUREAU OF MINES DATA, MODIFIED BY PEDCO
V BUREAU OF MINES, PRELIMINARY 1978 DATA ON
SHIPMENTS OF CEMENT FROM PLANTS IN REGION V
1972 1973 1974 1975 1976
YEAR
1977
1978
Figure 1-1,
Production trends for cement plants
in Region V, 1972-1978.
1-4
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production peaked in 1973, reached a low point in 1975, and has
increased each year since, except for 1978. Preliminary figures
from the Bureau of Mines on shipment of finished cement from
plants in Region V (shipments should be close to production) show
that approximately 11,452,000 Mg (12,625,000 tons) were shipped
in 1978. This is a slight reduction in production as compared to
1977, and may reflect the short term problems such as extremely
bad weather, strikes, and transportation difficulties that occur-
red in Region V during 1978. This production level is still
approximately 80 percent of design capacity for all 24 active
plants in the region.
1.2.2 Effect of Environmental Regulations on Expansion of
Capacity
Most of the comments elicited by the survey concerned the
effect of environmental regulations on expansion of capacity.
Only seven plants (two of which are grinding plants) indicated
that they could expand capacity; only one plant is actually doing
so. Plant personnel cited several deterrents to expansion: the
high cost of meeting environmental regulations; low return on
investment; and the delay in obtaining permits, which increases
the lead time for constructing new plants.
We have analyzed these factors and arrived at several con-
clusions, which are summarized in the following paragraphs:
The cost of meeting environmental regulations increases the
threshold for an adequate return on investment. The contribution
of pollution control equipment to the capital investment of a new
1-5
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cement plant in Region V appears to be about 15 percent. (10
percent for air pollution equipment only, according to a recent
Portland Cement Association survey of its members). Retrofit
costs of pollution control equipment may exceed 25 percent of the
net worth of an existing plant in some cases. Operating costs
attributable to pollution control equipment for cement plants are
scarce because no recent economic studies have been done and only
one plant in Region V provided a cost estimate. Maintenance of
air pollution control equipment at this plant is estimated to
account for 2 percent of the price of cement.
In the future, new regulations to control fugitive dust and
hazardous waste will add to plant capital and operating costs.
The cement industry, however, is one of many industries facing
this problem. The increased cost is passed along to the consumer
as higher prices for cement.
The acquisition of small cement companies by larger com-
panies is a continuing trend; since the large companies have
greater financial capabilities, they should be better able to
invest in expansion. Cement prices may need to be significantly
higher in the future to provide the return on investment needed
for cement companies to undertake expansion.
Current permit procedures for new plants add substantially
to the lead time required for construction and restrict the
ability of the cement industry to respond rapidly to a shortage.
Under normal conditions, state preconstruction permits, Federal
permits [Prevention of Significant Deterioration (PSD) and Best
1-6
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Available Control Technology (BACT)] should take less than 1 year
to review. Plants in a nonattainment area, however, may need
additional time for approval or may not be able to be built
because of other emission sources. Approval of water and solid
waste permits does not usually bring delays, because they are
reviewed at the same time as the air permits. Most delays in
permit approval occur because the company does not submit ade-
quate information, the review staff at state or Federal agencies
is limited, or public hearings lead to objections to the plant
that result in the filing of lawsuits.
Permit procedures should be streamlined so that cement
companies can build new plants in the shortest possible time with
the confidence that control regulations will not be changed part
way through the project. U.S. EPA is changing the reporting
requirements so that a single application can be used to submit
information relating to air, water, and solid waste.
The responses to the survey about cement plants in Region V,
plus information in the literature, support the conclusion that--
justifiably or notenvironmental regulations are playing a role
in the reluctance of cement companies to invest in new capacity.
The ability to meet increasing demand is the key to a long-term
solution to the present shortage and to the prevention of future
shortages.
1-7
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1.2.3 Other Factors Affecting the Midwest Cement Shortage
Several other factors were mentioned by cement companies as
contributing to the Midwest cement shortage: unusually high
demand, plant closings, and unavailability of equipment.
In 1975 through 1978, about 13 percent of the capacity in
Region V was retired without replacement. The retirements in-
volved six plants with a combined annual capacity of 1,890,000 Mg
(2,084,000 tons). In conjunction with other, short term problems
that occurred in late 1977 and early 1978, these plant closings
probably aggravated the cement shortage in the Midwest. At two
of the plants, the cost of raw materials was the main reason for
closing. At the other four plants, the high cost of complying
with environmental regulations was cited as the main reason for
closing, although the increased cost of a raw material additive
was also a problem at one of these plants. Thus environmental
regulations appear to have had an indirect effect on production
in Region V by becoming a factor in the decision to close down
older plants with marginal control equipment. In most cases, the
regulations do not give control agencies the flexibility to adapt
requirements to an older plant (for example) that is only mar-
ginally out of compliance and could continue to operate profit-
ably for several more years. The cost of an additional envi-
ronmental control could force such a plant to close. At one
plant in Region V, however, a misunderstanding between the cement
1-8
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company and enforcement officials resulted in the plant being
closed when it could have remained open for 3 more years under a
variance.
The reluctance of cement companies to expand capacity is a
serious concern when plants are being closed without replacement.
Expansion of capacity to meet demand is of critical importance
and overexpansion is unlikely to occur at a time when cement
companies are predicting future plant closings.
The question of the cost-effectiveness of the EPA environ-
mental regulations for cement plants is beyond the scope of this
report. It is, however, a controversial issue, and further study
would be valuable in light of the new regulations that are pro-
posed for fugitive dust and hazardous wastes.
1-9
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SECTION 2
INTRODUCTION
2.1 PURPOSE OF STUDY
The purpose of this report is to investigate allegations
that environmental regulations are a significant cause of the
present cement shortage in the Midwest. The study area is Region
V (Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin)
of the U.S. Environmental Protection Agency (EPA). A survey of
each cement plant in Region V provided the basic information in
this study about limitations on production and expansion. Sec-
tion 1 has already summarized the results and conclusions of this
study. The remainder of Section 2 discusses background informa-
tion relevant to the cement shortage, and the outlook for future
supplies.
Section 3 provides a brief description of the portland
cement process, the major emission points, and applicable control
equipment used. A review of Federal and state environmental
regulations is also provided.
Section 4 presents the results of the survey of the 24
active cement plants in Region V. This includes a description of
the data requested and the reported impacts of environmental
regulations on present production and future expansion capabili-
ties.
2-1
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Section 5 presents case histories from two plants that
reported substantial curtailment of production because of envi-
ronmental regulations. Included in each case history are a
description of the specific problem(s) causing production cur-
tailment, company efforts to solve the problem(s), and the out-
look for increased production at these plants. A third case
history on the events surrounding the closing of a Region V
cement plant is also presented.
2.2 BACKGROUND OF CEMENT SHORTAGE IN THE MIDWEST
The shortage of cement now plaguing the Midwest began in
California in late 1977 and spread eastward to other parts of the
country. Cement prices have escalated because of the shortage,
and there have been costly delays in construction projects and
disruption of employment patterns.
2.2.1 Causes
Different sources have suggested various causes of the
present shortage in general and applied specifically to the
1234
Midwest. ' ' ' The major causes cited from these sources are
summarized below.
2.2.1.1 High Levels of Construction
The Portland Cement Association (PCA) projected that rising
interest rates and scarcity of credit would cause house construc-
tion to peak in early 1978 and then decline to a sustainable
level. This projection, however, proved wrong. Construction
began on more houses during the first 7 months of 1978 than
2-2
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during the same period in 1977, and total construction value was
3 percent higher in the first half of 1978 than in the first half
of 1977.
2.2.1.2 Lower Production Levels--
There are a number of reasons cited for the failure to meet
demand. One is the lack of capital investment earlier in this
decade. During the early months of 1978, inclement weather, fuel
supply problems attributed to the coal strike, and energy con-
versions from petroleum to coal firing kilns reduced the normal
buildup of product inventories. Because many plants delayed
their usual maintenance shutdowns to make up lost production,
extended downtime occurred during the building season.
Aggravating the shortage in the Chicago area was the 2-month
2
closing of locks on the Illinois Waterway. Three producers that
together supply one-third of the area's cement use the Waterway.
Also, strikes at some remaining plants reduced overall supplies.
2.2.1.3 Shipments to Areas of Earlier Shortages--
The shortage that started in the West in late 1977 resulted
in higher prices for cement and drew supplies from plants in the
Midwest, which would normally stockpile cement during the winter.
Shipments to areas of earlier shortages thus reduced supplies in
the Midwest.
2.2.1.4 Environmental Regulations--
There are allegations that stringent environmental regula-
tions implemented since the passage of the Clean Air Act of 1970
caused several older plants to close prematurely in the early
2-3
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1970's. In addition, the large capital expenditures required to
achieve compliance have reportedly prevented other plants from
implementing energy conservation programs, plant modernizations,
and capacity expansions. Expansion takes from 3 to 4 years,
which includes time to get necessary environmental permits.
2.2.1.5 Price Fixing
Some building and labor leaders have alleged that the
cement manufacturers have created a false shortage to force up
the price of cement. California, Kansas, and Oregon have filed
suits charging several companies with conspiring illegally to fix
or maintain prices for cement and allocate territories.
2.3 OUTLOOK FOR FUTURE CEMENT SUPPLIES
According to the PCA, it seems that only reduced demand from
the home building industry would bring about significant relief
in 1979. Although supplies appear adequate to meet national de-
mand, regional shortages will probably occur through 1980. About
4.5 million tons of new capacity is scheduled for operation
nationwide between 1978 and 1980, but the closing of older plants
and kilns will somewhat offset these additions.
Most experts believe that the long-term outlook for adequate
supplies depends on the cement industry's ability to expand ca-
pacity and obtain the necessary environmental approvals to con-
125
struct new plants. ' ' The PCA predicts a growing market for
cement. Some problems, however, could affect the cement in-
dustry. These problems include the cost of new plants ($90 to
2-4
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$110/ton of annual capacity), the implementation of wage and
price guidelines, and the overexpansion that might result from
the cyclical nature of the construction industry.
2-5
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REFERENCES
SECTION 2
1. Goldfarb, Jonathan, and Jeanne Gallagher. Building Industry
Commentary - The Cement Industry. Merrill, Lynch, Pierce,
Fenner & Smith, Inc. Securities Research Division. October
1978.
2. Builder's Association of Chicago. The Cement Shortage - Its
Causes, Impact, and the Outlook for the Future. November
1978.
3. Grancher, Roy A. The Cement Shortage Condition. Rock
Products. November 1978.
4. U.S. Department of Commerce. Situation Report - Portland
Cement Supply and Demand. September 1978.
5. Thelin, Ronald. The Public Forum - Southtown Economist,
Autumn 1978.
2-6
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SECTION 3
REVIEW OF PORTLAND CEMENT PROCESS
AND ENVIRONMENTAL CONTROLS/REGULATIONS
3.1 PROCESS DESCRIPTION1'2'3
Portland cement is a powdered material which, with water,
forms a paste that hardens slowly, bonding rock, gravel, and sand
into concrete. Portland cement production involves quarrying,
crushing, grinding, blending, clinker production, finish grind-
ing, and packaging. Figure 3-1 depicts a typical process flow
diagram for portland cement production.
Limestone and shale are blasted from quarries, usually close
to the cement facility. The raw materials are transported to the
primary crusher by truck, railroad car, or conveyor belt.
The primary crusher (gyratory, jaw or roll) reduces the size
of rocks to between 15 and 25 cm (6 and 10 in.) across. After
the rocks are broken, they are carried by conveyors to the sec-
ondary crushers, usually of the "hammer mill" type, which crushes
them to less than 2 cm (3/4 in.) across.
The crushed raw materials then undergo a fine grinding
process, which further reduces their size. The fine grinding can
be done by the wet or dry process. In the wet process, raw feed
is combined with water to form a slurry consisting of more than
one-third water. This slurry is discharged from the mill and
3-1
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stored in huge open tanks, where additional homogenization takes
place. The slurry is then pumped into the kiln. In some in-
stances, moisture is removed by vacuum filters, thickeners, or
hot kiln exhaust gases. In the dry process, the raw materials
may be dried separately before grinding, but more commonly,
grinding and drying are done simultaneously. Exhaust from the
rotary kiln that follows this step supplies hot gases for drying.
The wet slurry or the dry mix is fed into a rotary kiln
(Figure 3-2) to form cement clinker. The kiln is fired with oil,
gas, or coal. As the feed travels through the kiln, it is dried,
calcined, and partly fired at a temperature of about 1600°C
(2900°F). Newer fuel saving techniques for clinker production
include longer kilns, and suspension and traveling grate pre-
heaters.
In a suspension preheater, dry raw feed is fed downward
through a series of cyclones against an upward hot gas flow,
resulting in an effective countercurrent heat exchange. The hot
gas from the kiln exhaust does not require any additional heat
input, although some flash preheating systems are now being
introduced.
In a traveling grate preheater system, 'ground raw feed is
palletized and discharged to a hopper at the feed end of the
traveling grate. A uniform bed of pellets is spread across the
full width of the traveling grate. The pellets are heated and
partially calcined before entering the rotary kiln.
3-3
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For all kiln types the clinker drops from the lower end of
the kiln into some form of cooler where its temperature is
quickly reduced. New or modified designs carry the clinker on a
perforated grate through which air is forced. A portion of hot
overgrate air is used as combustion air for the kiln. The amount
of overgrate air is governed by the kiln excess air.
Clinker is mixed with about 5 percent gypsum (to regulate
the concrete's setting time), then ground and mixed in a grinding
mill. Milled cement is classified by a cyclone separator, and
the oversize material is returned to the mill. The cement is
conveyed to silos and then bagged or shipped in bulk by truck,
rail, or barge.
3.2 MAJOR EMISSION POINTS1'2'3
Particulate matter is the primary pollutant from the manu-
facture of cement. The potential sources of emissions from
Portland cement plants are illustrated in Figure 3-1. Kilns,
clinker coolers, and dry milling operations constitute the main
sources of particulate emissions. Sources of fugitive emissions
include quarry sites, transfer points, storage piles, and loading
area.
Small amounts of nitrogen and sulfur oxides may be emitted
from kilns and driers because of the fuels fired to supply heat.
Table 3-1 summarizes emission factors for cement manufacturing,
from AP-42, reference 5.
3-5
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TABLE 3-1.
EMISSION FACTORS FOR CEMENT MANUFACTURING
WITHOUT CONTROLS3
Pollutant
Particulate
Ib/ton
kg/MT
Sulfur dioxide0 ,
Mineral source
Ib/ton
kg/MT
Gas combustion
Ib/ton
kg/MT
Oil combustion
Ib/ton
kg/MT
Coal combustion
Ib/ton
kg/MT
Nitrogen oxides
Ib/ton
kg/MT
Dry process
Kilns
245.0
122.0
10.2
5.0
Dryers,
grinders, etc.
96. 0
48.0
Negligible
Negligible
4.2Sf
2. IS
6.8S
3.4S
2.6
1.3
Wet process
Kilns
228.0
114. 0
10.2
5.0
Negligible
Negligible
4.2S
2. IS
6.8S
3.4S
2.6
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Dryers ,
grinders, etc.
32.0
16.0
These emission factors which are taken from Reference 5, include emissions
from fuel combustion, which should not be calculated separately.
Typical collection efficiencies for kilns, dryers, grinders, etc., are:
multicyclones, 80 percent; electrostatic precipitators, 95 percent;
electrostatic precipitators with multicyclones, 97.5 percent; and fabric
filter units, 99.8 percent.
The sulfur dioxide (S02> factors presented take into account the reactions
with the alkaline dusts when no baghouses are used. With baghouses,
approximately 50 percent more SO2 is removed because of reactions with
the alkaline particulate filter cake. Also note that the total SO2
from the kiln is determined by summing emission contributions from the
mineral source and the appropriate fuel.
These emissions are the result of sulfur being present in the raw materials
and are thus dependent upon source of the raw materials used. The 10.2
Ib/ton (5.1 kg/MT) factors account for part of the available sulfur
remaining behind in the product because of its alkaline nature and
affinity for SO,-
S is the percent sulfur in fuel.
3-6
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3.3 APPLICABLE CONTROL EQUIPMENT
The main pollution control devices in the portland cement
industry are mechanical collectors, electrostatic precipitators
(ESP's), gravel beds, and fabric filters (baghouses). Combina-
tions of these devices are sometimes used depending upon the
operation and exhaust gas temperature. Only a few plants use
high-energy venturi scrubbers.
The kiln is the largest emission source in a cement plant,
the most difficult to control properly, and thus the most likely
to be controlled inadequately. A fabric filter or an ESP is
usually installed on the kiln. Wet scrubbers have proved to be
impractical for this application. Many kilns are also equipped
with mechanical collectors to remove coarse particles from the
dust.
Kiln exhaust gases are cooled in spray-towers by bleed air
or a combination of the two to a temperature of 232° to 288°C
(450° to 550°F) before entering fabric filters. These filters
are usually made of glass or Nomex fabrics, which can withstand
temperatures as high as 290°C and 230°C (550°F and 450°F), re-
spectively. Higher temperatures accelerate the aging of bag
fabrics. Thus, when fabric filters 'are used on dry process
kilns, gas temperatures are of primary concern.
Conversely, fabric filters used on wet process kilns must be
protected from gases reaching the dewpoint [usually in the range
of 130° to 150°C (270° to 300°F)]. This is achieved by providing
3-7
-------
an outer layer of insulation on precleaning cyclones, ductwork,
and hoppers.
When ESP's are used on dry kilns, water cooling and condi-
tioning exhaust gases can overcome problems of resistivity and
sulfate buildup. Wet process kilns have the proper moisture and
temperature characteristics for effective electrostatic precipi-
tation. As with fabric filters, extensive thermal insulation
must be provided on wet process kilns to prevent condensation of
water vapor within ESP's or fabric filters. Several installa-
tions with preheaters utilize exhaust gases from the kiln to dry
the raw material. This increases the moisture content and re-
duces the temperature of the gases entering the ESP.
All or a portion of the dust collected in ESP's or fabric
filters may be recycled to the process. This depends on the
alkaline content of the dust. Use of a cyclone as a precleaner
usually reduces the alkaline content of the dust passing through
to the secondary collector, from which it is recycled to the
process. If dust from the kiln has low alkalinity, a cyclone may
not be used and all of the dust collected in the ESP or fabric
filter will be recycled.
Clinker cooler dust requires a high-efficiency control
device. ESP's are not generally used for clinker cooler control,
but have been successfully applied at several installations.
Gravel bed filters are achieving some popularity for control of
clinker cooler emissions. The filter medium consists of silica
3-8
-------
gravel, which is insensitive to temperature. Gravel bed filters
can handle gases as hot as 540°C (1,000°F) with no cooling or
conditioning required.
Raw and finish milling processes are best controlled by
fabric filters, although ESP's can effectively clean exhaust
streams from finish mills. The control devices, connected in a
closed loop with air separators, transport the collected material
back to the process for cement production.
At the numerous transfer points in a cement plant, cloth
filters are often used to recover dust. Properly designed hoods,
used with 0.5 - 2 m /s (1,000 - 4,000 cfm) fans, can effectively
control emissions. At some plants, water sprays are used to
minimize emissions from transfer points.
Table 3-2 summarizes the types of control equipment used by
cement plants in Region V.
3.4 REVIEW OF ENVIRONMENTAL REGULATIONS
3.4.1 New Source Performance Standards
Pursuant to Section III of the Clean Air Act, the Adminis-
trator of the U.S. Environmental Protection Agency promulgated
standards of performance for new and modified portland cement
plants on December 23, 1971 (35 FR 15704). These standards are
applicable to portland cement plants whose construction or modi-
fied was commenced after August 17, 1971. The standards limit
particulate emissions from the kiln to 0.15 kg/metric ton (0.30
Ib per ton) of feed (dry basis) to the kiln and from the clinker
3-9
-------
TABLE 3-2. SUMMARY OF CONTROL EQUIPMENT
ON MAJOR EMISSION POINTS^
Emission
point
Kiln
Clinker cooler
Grinding mill
Number of plants reporting
ESP
12
Fabric filter
5
9
21
Other
6C
I6
Combination
3b
3d
The total number of plants reporting was 24.
One multicyclone and ESP, one multicyclone and fabric filter,
and one ESP and fabric filter.
c Two multicyclone, three gravel bed filters, and one planetary
cooler.
One multicyclone and ESP and two combinations of one gravel bed
filter and fabric filter.
Q
One Norblo dust collector.
3-10
-------
cooler to 0.05 kg/metric ton (0.10 Ib per ton) of feed (dry
basis) to the kiln. The opacity limits are 20 percent for emis-
sions from the kiln; 10 percent for emissions from the clinker
cooler, and 10 percent for emissions from other equipment.
Appendix A fully delineates the New Source Performance Standards
(NSPS) pertinent to the portland cement industry.
Federal regulations allow each state to develop a program
for enforcing NSPS within its boundaries. Thus, many states and
local regulations allow particulate emissions to vary with the
rate of input of raw materials.
3.4.2 State Emission Regulations
Applicable particulate emission regulations for each of the
six states within U.S. EPA Region V are presented in detail in
Appendix B. For existing sources, Minnesota, Michigan, and
Wisconsin have specific regulations for cement plants. For new
sources, all of the states except Indiana have specific regula-
tions for cement plants. Of the five states having specific
regulations for new sources, all but Wisconsin have regulations
identical to the Federal NSPS. Table 3-3 compares particulate
emission regulations for existing and new sources in the six
states of U.S. EPA Region V.
3.5 WATER POLLUTION CONTROL REGULATIONS APPLICABLE TO CEMENT
MANUFACTURING PLANTS
Cement manufacturing plants may be subject to Federal,
state, or local water pollution control regulations.
3-11
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3.5.1 Federal Regulations
Facilities which discharge their effluent via a point source
into surface water of the United States are subject to Effluent
Limitations Guidelines. The limits are set out in an NPDES
(National Pollution Discharge Elimination System) permit. The
permit is obtained either from the Regional Administrator or the
state (where the state is authorized by the Regional Administra-
tor to issue NPDES permits). A copy of the effluent limitations
guidelines as set out in 42 FR 10681, February 23, 1977 is shown
in Appendix C.
3.5.2 State Regulations
In many instances a state's water quality standards are more
stringent than the Federal regulations. Thus, a state may set
out discharge limitations based on the location of the plant,
type of receiving stream, flow and other characteristics. The
limitations are highly variable and too numerous to mention.
However, copies of the individual regulations may be obtained
from the state environmental protection agency (or department of
natural resources).
3.5.3 Local Regulations
When a facility discharges its effluent into a local pub-
licly owned treatment works (POTW) it is subject to pretreatment
standards set out by the local POTW. These standards may limit
discharges of heavy metals, biological oxygen demand, total
suspended solids, pH, etc. Most POTW's also place a surcharge on
3-13
-------
the effluent; the surcharge is usually based on a formula which
relates the quality of wastewater, BOD and suspended solids in
excess of a specified value to the surcharge.
3.6 SOLID WASTE REGULATIONS
Solid waste regulations do not impact cement plants as much
as the air and water pollution regulations. Most of the process
related solid water in cement plants is in the form of dust and
this is recycled; the small qualities that remain are disposed of
in impoundments or sanitary landfills.
The Resource Conservation and Recovery Act (RCRA) of 1976
which will be implemented in 1980 will put strict controls on
impoundments and sanitary landfills, and may impact cement plants
to some extent.
3-14
-------
REFERENCES
SECTION 3
1.
2.
3.
PEDCo Environmental, Inc. Compendium for Portland Cement
Manufacturing. U.S. Environmental Protection Agency, Re-
search Triangle Park, North Carolina. Contract No.
68-02-2585, Assignment No. 7. May 15, 1978.
Kulujian, N.J. Inspection Manual for the Enforcement of New
Source Performance Standards: Portland Cement Plants.
PEDCo Environmental Specialists. EPA Contract No.
68-02-1355, Task No. 4. January 1975.
PEDCo Environmental, Inc. Preparation of Process Descrip-
tion for Engineering Manual - Cement Plants. Preliminary
Draft. EPA Contract No. 68-01-4147, Task No. 49. December
1978.
4.
5.
Pit and Quarry Publications, Inc.
and Buyers Guide, 1975/76.
Pit and Quarry Handbook
Compilation of Air Pollutant Emission Factors, 2nd Edition.
U.S. Environmental Protection Agency Publication AP-42.
April 1973.
3-15
-------
SECTION 4
SURVEY OF CEMENT PLANTS IN
U.S. EPA REGION V
4.1 REVIEW OF PLANTS SURVEYED
PEDCo surveyed and received responses from all 24 active
cement plants in EPA Region V. A breakdown of plants surveyed,
by state, along with design production, capacity, and type of
fuel used, is shown in Table 4-1; Figure 4-1 shows the distribu-
tion of the plants within the six states of Region V.
4.1.1 Fuel Use Data
Fifteen plants use coal exclusively, two use coal or natural
gas, two use coal or fuel oil, one uses fuel oil or natural gas
for kiln operation. Four plants grind clinker only.
The overwhelming use of coal in these plants is a result of
the current energy situation, in which coal is cheaper and in
more adequate supply than oil and natural gas and less subject to
interruption in supply (especially than natural gas). The coal,
however, causes higher rates of particulate emissions during
transitional periods and equipment malfunctions.
4.1.2 Type of Process
Ten plants in Region V are dry process, and three of these
have preheater kilns. The other 10 plants with operating kilns
are wet process, which consumes more energy than the dry process.
4-1
-------
TABLE 4-1. REVIEW OF CEMENT PLANTS SURVEYED
Facility
Michiqan
Aetna Cement Corporation,
Essexville
Dundee Cement Company,
Dundee
Medusa Cement Company,
Charlevoix
National Gypsum Company,
Alpena
Peerless Cement Company,
Detroit
Penn - Dixie Industries, Inc.,
Petoskey
Wyandotte Cement,
Wyandotte
Total state
production^
x 10 6 Mg/yr
(106 tons/yr)
5.71
(6.29)
Type of
process
Grinding
Wet
Wet
Dry
Wet
Wet
(Grinding)
Type of
fuel
N/A
Coal
Coal
Coal
Coal
Coal
N/A
Ohiob
Columbia Cement Corporation,
Zanesville
General Portland, Inc.,
Paulding
Marquette Company,
Pedro
Medusa Cement Company,
Toledo
Southwestern Portland Cement
Company, Fairborn
2. 12
(2.34)
Wet
Wet
Dry
Dry
wet
Coal
Coal
Coal
Coal
Coal/oil
Normal production 106 mg/yr
(106 tons/yr)
Indiana
Lehigh Portland Cement
Company, Mitchell
2.91
(3.21)
Dry
Coal
4-2
-------
TABLE 4-1 (continued)
Facility
Indiana (cont'd.)
Lone Star Industries, Inc.,
Greencastle
Louisville Cement Company,
Speed
Louisville Cement Company,
Logansport
Universal Atlas, Buffington
Total state
production3
x 106 Mg/yr
(106 tons/yr)
Type of
process
Wet
Dry
Wet
Dryd
Type of
fuel
Coal
Coal/oil
Coal
Coal/gas
Illinois
Illinois Cement Company,
La Salle
Medusa Cement Company,
Dixon
Marquette Company, Oglesby
Missouri Portland Cement
Company , Joppa
2.55
(2.81)
Dry
Dry
Dry-
Dry
Coal
Coal/gas
Coal
Coal
Wisconsin
Medusa Cement Company,
Manitowoc
National Gypsum Company,
Superior
Universal Atlas Cement,
Division of U.S. Steel
Corporation, Milwaukee
0.34
(0.38)
Wet
(Grinding)
(Grinding)
Oil/gas
N/A
N/A
TOTAL EPA Region V Production (is'rm
Reported by each plant, and summarized by state.
it does meet environmental regulations; plant has adequate
supply of clinker from another Aetna Company plant.
SME Cement, Inc. plant in Middlebranch, Ohio not included in
survey, since plant is being refurbished after beina closed in
1976, and only operated during a portion of 1978 for grinding
of cement clinker only.
Equipped with a preheater kiln.
N/A - Not applicable.
4-3
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4-4
-------
4.2 DESCRIPTION OF DATA REQUESTED
The survey form first requested general information about
the plant: location, type of process, capacity, normal annual
operating hours, type of fuel used, major emission points, and
associated control equipment. Next, the survey asked whether the
plant could meet its present design capacity and whether it could
expand production. Finally, the survey asked about the effect of
environmental regulations on current production and on future
expansion.
A sample survey form is shown in Appendix D.
4.3 ANALYSIS OF REPORTED IMPACTS ON PRODUCTION AND EXPANSION
Appendix E paraphrases the responses of each cement plant in
the U.S. EPA Region V to our survey. The plants are not identi-
fied by name or segregated by state. Table 4-2 summarizes the
factors cited by each cement plant in Region V as affecting
production, expansion, and the cement shortage in general. The
following sections present a discussion of these factors.
4.3.1 Production
Only 2 of the 24 plants reported a severe loss in production
from their design capacities. Most of the production loss at one
plant stems from continuing problems with start up of a new
preheater kiln. Most of the loss at the other severely affected
plant, stems from problems in starting a roller mill and the
attendant opacity violations. Both plants are producing about 50
percent of their design capacity. Details of these operating
problems are discussed in Section 5.
4-5
-------
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4-6
-------
PEDCo did not obtain actual production totals for each plant
in Region V, although the numbers reported by some plants were
indicated as being 1978 totals. Rather, the data reported were
taken as being indicative of what a plant could produce in a
normal year with no severe problems, unless the plant indicated
differently on the survey form. Figure 4-2 shows the number of
plants reporting achievable production under, at, or over design
capacity. Of the 24 plants, 11 are between 80 and 100 percent of
design capacity (7 of these 11 are 90 percent or greater); this
represents a total production of 6,058,000 Mg (6,678,000 tons).
Seven plants representing 5,025,000 Mg (5,540,000 tons) of pro-
duction are right at 100 percent design capacity. Five plants
representing 2,277,000 Mg (2,510,000 tons) report achievable
production that is slightly over design capacity. Only one plant
[263,000 Mg (290,000 tons)] reported normal production of less
than 80 percent of design capacity, which cement producers say
2
represents normal production.
Twelve other plants stated that environmental regulations
were reducing production at their plant, typically by 2 to 5
percent. The loss was ascribed to the startup and malfunction of
control devices (5 plants) or process equipment (9 plants),
causing either a reduction or stoppage of production. During
startup, most conventional coal-fired kilns equipped with ESP' s
operate without controls for several hours. Until the operating
temperature is attained in the kiln, there is a risk of explosion
4-7
-------
18
16
14
12
10
O
CtL
263,000 M.9
(290,000 tons)
6,058,000 Mg
(6,678,000 tons)
5,025,000 Mg
(5,540,000 tons)
2,277,000 Mg~
(2,510,000 tons)
<80% DESIGN >80%<100% 100% DESIGN
CAPACITY DESIGN CAPACITY
CAPACITY
NORMAL LEVEL OF PRODUCTION REPORTED
>100% DESIGN
CAPACITY
Figure 4-2. Level of production for
cement plants in U.S. EPA Region V.
4-8
-------
of combustibles in the ESP. The feed rate of raw materials is
also reduced. Plants with preheater kilns experience periods of
high opacity at several stages: during startup of roller mills,
when switching from mill and kiln to kiln only, or vice versa.
Two companies that operate plants under a process weight
regulation said that their cement production was limited to that
feed rate at which the compliance emission test was performed.
One company estimated that this limitation leads to another 5
percent loss in production: the plant could operate at a higher
level, but with marginal control device performance.
Six plants reported that environmental regulations have no
effect on production rates, and five plants reported achievable
production numbers that are somewhat over design capacity (103 to
111%).
>
All but one of the plants (a white cement plant) indicated
that demand in their areas is presently outstripping supply.
Production trends from Bureau of Mines' data spanning 1972
through 1978 are shown in Table 4-3. These data show that pro-
duction in Region V peaked in 1973, reached a low point in 1975,
and has been increasing each year until 1978. Preliminary data
from the Bureau of Mines on finished cement shipments from plants
in Region V show that approximately 11,452,000 Mg (12,625,000
tons) were shipped in 1978. This figure should be close to
production levels of finished cement, and indicate that produc-
tion declined slightly from 1977 to 1978, perhaps reflecting the
4-9
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short term problems such as extremely bad weather, strikes,
transportation problems and unexpectedly high demand that oc-
curred in 1978. The lower production level for 1978 still rep-
resents approximately 80 percent of the design capacity of the 24
active plants in Region V.
In summary, the 24 cement plants in Region V reported that
production could be approximately 13,634,000 Mg (15,030,000 tons)
during a normal year without major problems, or about 94 percent
of the design production 14,524,000 Mg (16,011,000 tons). This
figure is far better than the 80 percent production rate that
occurred in 1978 and is considered normal, and indicates that
environmental regulations are not significantly affecting produc-
tion rates at cement plants in Region V, although some problems
at these plants are control equipment oriented. The decrease in
production attributed by some plants to environmental regulations
would be substantial if regained but would still not be enough to
meet demand such as that experienced in 1978.
4.3.2 Expansion
The survey elicited many more comments about the effect of
environmental regulations on expansion than on production. Only
7 plants (2 of them grinding plants) indicated that they could
expand capacity. Only 1 plant is presently in the process of
expansion. This section discusses each of the factors reported
as affecting expansion potential for cement plants in Region V.
4-11
-------
4.3.2.1 High Cost of Meeting Environmental Regulations--
Twelve plants cited the high cost of complying with environ-
mental regulations as one factor deterring cement companies from
expanding production. The implication is that funds that could
be used for expansion are being diverted to pollution control.
These are also cited as playing a major role in the premature
closings of several cement plants in recent years. (These clo-
sures are discussed in Section 4.3.3).
Stringent environmental regulations and the effects of
inflation have made the purchase of pollution control equipment a
major expenditure for cement plants and for other industries as
well. To remain in compliance, plant personnel must perform
regular preventive maintenance on control equipment. When mal-
functions do occur, the cost of production is increased. The
added costs are especially noticeable at plants where less main-
tenance was performed in earlier years when regulations were not
as strict. The end result is higher prices for cement.
Proposed new regulations for fugitive dust and hazardous
wastes may also increase capital and operating costs for cement
plants. In fact, three cement companies in Michigan and one in
Illinois have mentioned these proposed state fugitive dust regu-
lations as being too restrictive and costly. One company indi-
cated that if the regulations go into effect, the grinding of
cement clinker at its plant might become unfeasible. A second
company indicated that the fugitive dust regulations would sub-
stantially reduce its ability to store the product in preparation
4-12
-------
for the peak shipping season. A third company indicated that the
main source of fugitive dust in the vicinity of the plant was an
interstate highway to which little or no control was applied,
while plant procedures included daily sweeping or watering of
streets.
In summary, the companies did not indicate that production
would be directly affected by the proposed fugitive dust regula-
tions, but they believe that the expense of the regulations does
not justify the intended result.
Allegations have been made that EPA did not perform an
adequate economic impact analysis when the New Source Performance
4
Standards (NSPS) for cement plants were promulgated. The EPA
has also been criticized for its policy of treating regulations
in the "aggregate" (rather than studying their application to
each specific industry) in an effort to eliminate unnecessary
costs. The issue behind these allegations, howeverthe cost-
effectiveness of the environmental regulations for the cement
industryis complex and cannot be discussed within the scope of
this report.
It is true that environmental regulations are raising the
threshold for an adequate return on investment (ROI) for a new
cement plant (see Section 4.3.2.2), and that operating and main-
tenance costs for control equipment are increasing. These fac-
tors are apparently influencing the decision of cement companies
in Region V not to expand production capabilities, as evidenced
by the 12 plants in this survey that cited the high costs of
4-13
-------
pollution control. Only one plant however gave any estimate of
annual cost, and stated that maintenance of cyclones, ESP's and
fabric filters, accounted for 2 percent of the price of cement.
The prospect of even stricter control requirements in the in-
dustry raises the concern that the costs will be increased fur-
ther for new plants.
The problem increased cost of building and maintaining
pollution control devices in the cement industry is one shared by
other industries, and these additional costs are passed along to
the consumer in the form of higher cement prices. These prices
will probably need to be significantly higher in future years to
return the investment that the companies will make to expand
their capacity.
4.3.2.2 Low Return on Investment--
Eleven plants cited a low return on investment as one of the
reasons for not expanding production. This item is related to
the high cost of complying with emission regulations, mostly for
air.
The economic outlook for building new cement plants is not
encouraging. A recent report by Merrill Lynch, Pierce, Fenner
and Smith Inc. estimates from industry sources that the capital
spending requirement for new cement plant is $110 to $132/Mg
($100 to $120/ton) of clinker. At a selling price of $55 to
$66/Mg ($50 to $60/ton), this translates into a capital turnover
of 0.5 and, therefore, an average net margin of 20 percent to
4-14
-------
generate an ROI of 10 percent. Historically, the cement industry
has not seen 20 percent net margins even during cyclical peaks.
The minimum plant size for economical operation is believed
to be 544,260 to 725,080 Mg (600,000 to 800,000 tons/yr). At a
capital cost of 60 to 80 million dollars, this scale is report-
edly beyond the financial capability of all but the largest
producers. This situation may change in coming years as cement
prices rise. However, a number of small cement companies have
already been acquired by larger companies with much greater
financial capability to invest in expansion when conditions are
appropriate.
Some cement companies have expressed the fear that expansion
will produce an oversupply, but this seem unlikely in view of the
plant closings projected for the next few years.
Dust collection is estimated to account for 18.75 percent of
an 80 million dollar investment for a new 827,000 Mg (750,000
ton) plant. The figure is misleading, however, because many of
the collectors recovery product from exhaust streams, and as a
result, increase product yields. This recovery balances some of
the capital investment and operating costs for dust control.
Two companies in Region V indicated that pollution control
accounts for 15 percent of their capital investment in a new
plant, and a third company stated that in general, the cost of
pollution control equipment could be as high as 25 percent of the
capital investment for a new plant. Another company stated that
the cost of retrofitting pollution control equipment could exceed
4-15
-------
25 percent of the value of an existing plant in some cases. The
Portland Cement Association conducted an informal survey among
its member in 1978 and found that air pollution control only is
estimated to account for 10 percent of the capital cost of a new
plant. No additional recent data on the economics of pollution
control in the cement industry were located in the literature.
Most of the increased capacity of recent years is from
expansion of existing plants (in Region V, the only company
presently expanding is increasing existing plant capacity). This
form of expansion is more readily justified than the building of
new plants, especially if it is part of a modernization program
that can significantly reduce fuel consumption. The reduction in
direct costs results in returns on incremental spending of 15 to
20 percent.
In summary although inadequate return on investment is often
cited as a deterrent against expansion in the cement industry,
the situation is likely to improve as cement prices rise.
Acquisition of small plants by larger companies may also provide
relief by bringing greater financial capabilities. Additional
incentives may also be needed to stimulate expansion, depending
on the growth of demand.
4.3.2.3 Delays in Obtaining Permits/Increase in Construction
Lead Time--
Delays in obtaining permits were cited by 10 plants in
Region V as having an effect on expansion capability. The cur-
rent regulations and procedures are believed to add significantly
4-16
-------
to the lead time for expansion, especially in a nonattainment
area, where control considerations for a new plant are complex
and costly. The regulations are viewed by the cement industry as
a deterrent to expansion.
Some of the cement companies in Region V stated that it
would take up to 2 years to obtain all of the necessary permits
for a new plant. This increases construction lead time to about
4 years, and prevents the industry from reporting quickly to
shortages. In addition, some companies expressed the concern
that they cannot predict what the future definition and scope of
environmental regulations will be. The rules keep changing and
getting stricter.
Companies must receive approval from the state environmental
control agency and from U.S. EPA to modify, reconstruct, or build
new facilities. Figure 4-3 shows the permit procedure for Ohio,
which usually takes about 3 months. The EPA Best Available
Control Technology (BACT) and Prevention of Significant Deterior-
ation (PSD) reviews cannot take more than 12 months, according to
law. The National Pollutant Discharge Elimination System (NPDES)
water permit is usually reviewed at the same time and may take up
to 3 months. Likewise, delays are not usually encountered in
obtaining solid waste permits for new cement plants. Lead times
for obtaining a permit in a nonattainment area may be longer
because of the presence of emission offsets rules with other
industries. In some cases, the construction of a new cement
plant may not be possible (mentioned by 5 plants).
4-17
-------
PERMIT TO INSTALL
SUBMITTED TO
OEPA DISTRICT OFFICE
(AIR/WASTEWATER/SOLID WASTE)
3 WEEKS
CONTROL OFFICE
OEPA (AIR)
MODELING
PSD/NEW SOURCE REVIEW
ONE OF FIVE DISTRICT
OFFICES
WASTEWATER/SOLID WASTE
LOCAL AIR
AGENCY
45 DAYS
I
ADVERTISED
NEWSPAPER AD IN COUNTY
OF PLANT SITE
OF LOCATION (SOURCE)
45 DAYS
30 DAYS
(IF NO PUBLIC
HEARING)
ISSUANCE BY
DIRECTOR OEPA
Figure 4-3. Permit process for state
Ohio.
4-18
-------
We reviewed a list of the times it took for various entities
(including cement plants) to obtain Federal EPA approval
(PSD/BACT). These PSD/BACT determinations were made before the
more restrictive PSD regulations took effect in June 1978. For
cement plants we found no elapsed times greater than 8 months,
but we were not able to determine whether the approval was for a
portion of a cement plant or for an entirely new facility.
Indications are, however, that time for review of PSD/BACT per-
mits does not vary significanly whether a single process or an
entire plant is involved.
Delays in permit approval are usually caused by incomplete
information on the applications that are submitted, or by insuf-
ficient personnel in the state and Federal agencies responsible
for processing them. Another cause may be public hearings, which
may result in objections from environmental groups, for example,
to building a plant as proposed. They may consequently file a
lawsuit. The number of steps involved in permit approval, com-
bined with the delays that can occur at various stages, may
increase lead time to 2 years in some cases, however, the norm is
1 year or less.
In any event, the streamlining and clarification of cement
plant regulations and permit procedures shorten the lead time for
new plant construction. These measures would also allow the
cement industry to respond more rapidly to changing demands, with
the confidence that the environmental regulations will not change
midstream through the project.
4-19
-------
4.3.3 Other Factors Affecting the Cement Shortage In General
The survey elicited comments about two other factors that
have affected the cement shortage: excessive demand for cement
and the retirement of plants without replacement; which is dis-
cussed in the following section.
4.3.3.1 Retirement of Cement Plants--
The closing number of cement plants is one factor cited by
five of the companies surveyed in Region V as contributing to the
present cement shortage. Those plants that were closed in the
last 3 or 4 years and not replaced by new capacity can be assumed
to have had the greatest effect on the cement shortage. Table
4-4 lists the plants in Region V that were closed since 1975 and
their capacities.
Although environmental regulations were not given as the
only reason for the plant closings, many companies believe that
the regulations accelerate the retirement of older, obsolete
plants. No problem arises when the loss in production is com-
pensated for by the building of new plants. In the last 4 years,
however, four plants and parts of two others have been closed in
Region V and not replaced. Similar closures have occurred
throughout the nation during this time.
The combined capacity of the six plants was about 1,890,400
Mg (2,084,000 tons). This lost production represents 13 percent
of the total current capacity. The effect of these closures on
the shortage in Region V is difficult to assess, because some of
the cement produced in the last 2 years was shipped out of the
4-20
-------
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region to areas of earlier shortages. It is clear, however, that
the production from these six plants could have eased the present
shortage.
The owners of the plants cited the difficulties to comply
with environmental regulations as having an influence on the
decision to close the plants; for four plants, it was given as
the main reason. The regulations have apparently had an effect
on cement production in Region V by causing these four older
plants, with marginal control equipment, to close prematurely.
According to the owners, the cost of compliance could not be
justified.
Control agencies are not allowed sufficient flexibility in
most cases, to adapt regulations to older plants that may be
marginally out of compliance but could continue to operate prof-
itably for several more years. An example is given in Section 5,
however, of a plant that could have been granted a variance by
control agencies and remained in operation.
Personnel at EPA in Region V surveyed the six state environ-
mental control agencies about cement plant shutdowns in their
jurisdictions. Agencies in Illinois, Indiana, and Michigan
reported that their regulations had not caused any plants to shut
down in the last 4 or 5 years. The Michigan agency reported two
shutdowns early in the 1970's that involved noncompliance with
air pollution regulations. It did not report the shutdown of 12
kilns at National Gypsum Company in Alpena in 1976 (capacity of
4-22
-------
500,000 tons/yr). The company reported that these kilns were
retired because it was not economical to equip them with the
required control equipment.
The Ohio agency reported three shutdowns in the past 4 years
but did not comment about their effect on the present shortage.
Problems with raw materials were the main reason for closing two
of these plants, but companies cited environmental regulations as
contributing factors. The third plant was closed because of the
expense of complying with air pollution regulations, but another
company is reopening two-thirds of the capacity of the old plant.
Grinding of some clinker began in July 1978, and 1 kiln was on
line during the first quarter of 1979.
The Wisconsin control agency reported one plant shutdown in
1975. Because this happened 4 years ago, it is not believed to
have had an impact on the present shortage.
The Minnesota agency reported that the only plant in that
state closed in 1975 because it could not meet environmental
regulations. An attempt by another company to reopen the plant
in 1977 was denied because the State decided that the company
could not comply, technically or economically, with environmental
regulations.
In general, the state environmental agencies indicated their
belief that state regulations have not had a significant impact
on the cement shortage.
4-23
-------
REFERENCES FOR SECTION 4
Portland Cement Association. Economic Research Department.
U.S. Portland Cement Industry: Plant Information Summary.
December 1977.
Builders Association of Chicago. The Cement Shortage: Its
Causes, Impacts, and Outlook for the Future. November 13,
1978.
U.S. Department of the Interior. Bureau of Mines Mineral
Yearbooks - Cement - 1972-1977.
Dvorak, Donald W. Builders Association of Chicago. Letter
to Congressman Henry J. Hyde. December 13, 1978.
Finn, F., and James Morriss. Attorney and Counselors,
Dallas, Texas. The Impact of Environmental Regulation on
Inflation.
Goldfarb, Jonathan, and Jeanne Gallagher. Building Industry
Commentary: The Cement Industry. Merrill Lynch, Pierce,
Fenner & Smith, Inc. Securities Research Division. October
1978.
4-24
-------
SECTION 5
CASE HISTORIES
This section presents brief case histories of the two plants
in Region V that experienced a significant loss in cement produc-
tion during 1978. Each case history focuses on the causes for
the loss, on company efforts to remedy the problems, and on the
outlook for increased production in the future.
A third case history is presented on the events surrounding
the decision of a company to close its cement plant in Region V.
5.1 CASE HISTORY NO. 1
This company manufactures portland and brixment cement.
Portland cement is produced by kilns No. 1 and 2, and a third
kiln is used for brixment cement. In 1977 the company shut down
three kilns, which were built in the 1950's, in response to a
state compliance order. These kilns became uneconomical to
operate with the required controls.
The No. 1 kiln is a 152 m (500-ft) conventional unit that
began operating in 1973 . Main exhaust is controlled by a Fuller-
Draco baghouse and clinker cooler exhaust is controlled by an
American Air Filter baghouse. The No. 2 kiln is equipped with a
four-stage preheater for drying and preheating the raw feed
before firing in the kiln. A water spray conditioning tower is
5-1
-------
used on the main kiln exhaust during kiln-only operation. Par-
ticulate emissions from this kiln and from the raw mill are
controlled by an eight-section Koppers electrostatic precipitator
(ESP). A portion of the No. 2 kiln exhaust gas is ducted to a
separate Koppers ESP to control alkali buildup in the final
product. Dust from this second ESP is discarded, while the dust
from the other control devices is recycled to the process.
Clinker cooler exhaust is controlled by a Rexnard gravel-bed
filter.
The company produces a proprietary masonry cement (contain-
ing no additives) from natural limestone rock in the brixment
cement kiln. The main exhaust of the brixment kiln is controlled
by a Lurgi ESP, and exhaust from the clinker cooler is controlled
by a baghouse.
5.1.1 Operating Problems
The most recent problem occurred when the ESP on No. 2 kiln
main exhaust malfunctioned, causing both portland cement kilns to
shut down. Examination of the interior of the ESP showed that a
number of plates had been warped. There was no evidence of heat
damage, and the operators suspect that an explosion occurred.
The malfunction was sudden, happening right after a shutdown of
the raw mill. The kiln discharge is equipped with an O2 and CO
monitor; the 0 monitor was not operating when the malfunction
occurred, and it is not known whether the CO monitor was operat-
ing.
5-2
-------
The company expects replacement plates to be delivered
quickly, but the two portland cement kilns will be shut down
completely for at least 3 weeks while the ESP is rebuilt. The
plant is now operating the raw mill at one-third capacity to
provide feed for kiln No. 1. Four of the eight ESP sections are
able to operate partially, but opacity is very high. A variance
has been obtained from the state to allow operations to continue
in this manner until the shut down for repair.
The total loss in production from this incident will prob-
ably approach 90,710 Mg (100,000 tons) of clinker, which is about
8 percent of the annual design capacity of the plant.
Before this incident, production loss from malfunction of
control equipment had been insignificant. Other problems which
resulted in a 50 percent loss in production in 1978, are sum-
marized below.
5.1.1.1 Materials Handling--
During the winter of 1977-78, problems arose when the lime-
stone pile froze over the feeders and the clay pile turned to mud
when it rained. Materials that could be extracted also froze in
the flap gates of the roller mill. The company spent 5100,000
for an extra feeder outside the limestone pile, and also built a
roof over part of the clay pile, covering 13,610 Mg (15,000 tons)
to make handling easier during inclement weather.
Another problem in materials handling occurred this past
winter when two of the four rolls used in the grinding mill
developed cracks. Two new ones were flown in from West Germany,
5-3
-------
but one of the new rolls recently broke apart. The plant is now
operating on only two rolls; however only one kiln is being used.
Four new rolls are on order.
5.1.1.2 Coal Silo Failure/Fan Problems--
The severe weather problems of the winter of 1977-78 were
followed by two major catastrophes in the spring of 1978. First,
the bottom cone of the coal silo fell out and crushed electrical
and other equipment under it. Second, the fluid drives for the
preheater and mill vent fans failed because operators did not
restart the cooling water system when other equipment was re-
started after a power failure.
The combination of the severe winter and these two process
malfunctions prevented the company from building up a product
inventory and kept production behind for the rest of 1978.
Control equipment malfunctions did not affect production signifi-
cantly in 1978.
5.1.2 Environmental Regulatigjis
Company officials say that they feel overwhelmed with the
multitude of environmental regu]ations and the rate at which they
are changing: they have trouble keeping up and are experiencing
a significant increase in operating costs. For example, the U.S.
EPA recently asked the company to install a continuous opacity
monitor on the stack of the No. 2 kiln exhaust. The company is
spending $40,000 to install the necessary equipment. The monitor
is required because excessive emissions occur during transition
from mill-plus-kiln to kiln-only operating modes, and vice versa.
5-4
-------
The company says that the automatic controls for the system make
these excessive emissions unavoidable, and that they are kept as
short as possible.
Another example the company cites is efforts by the state to
impose stricter regulations on the No. 1 kiln and clinker cooler
because the plant is in a nonattainme.nl area.
New fugitive dust regulations are being proposed by the
state. If implemented, they v/ill require the company to spend
considerable capital for compliance.
Water pollution regulations have not had as much impact as
those for air pollution, but they have increased operating costs.
5.2 CASE HISTORY NO. 2
This company manufactures portland and masonry cement. Two
conventional kilns, built in 1957, were extensively modernized in
1975 and converted to preheater kilns measuring 3.4 m by 55 m (11
ft by 190 ft). The preheater kilns were intended to offset the
loss of capacity that occurred when 14 older kilns were shut down
in the early 1970's. The capacity of the two conventional kilns
was increased 15 percent when the preheaters were installed.
Raw materials (limestone, clay, and boiler slag) are fed
into a roller mill for crushing and drying; they are them con-
veyed and classified and put into storage silos. When the mate-
rial leaves the silos it is weighed and discharged into a four-
stage preheater kiln, where it is heated to 760°C (1400°F) by
5-!
-------
direct contact with kiln gases. The partially calcined feed then
enters the sloping kilns.
The two kiln main exhausts are controlled by Koppers ESP's.
In the normal mode, exhaust gases from the kilns pass through the
preheaters and the roller mill before entering the ESP's. In the
bypass mode (roller mill shutdown), the exhaust gases first go
through a conditioning tower with water sprays where the tempera-
ture is reduced from 316° to 149°C (600° to 300°F). They then
enter the ESP' s at about 104°C (220°F). A portion of kiln off-
gases (alkali bypass) are withdrawn continuously and exhausted
through a separate Swindel-Dresser ESP. The clinker coolers are
controlled with a Rexnard gravel-bed filter.
The design capacity of this plant is 540,632 Mg (596,000
tons) of cement. In 1978, however, production was about 50
percent of design, or 263,4.72 Mg (290,400 tons). The problems
causing the loss in production, efforts to remedy them, and the
outlook for increased production in the future are discussed in
the following sections.
5.2.1 Operating Problems
5.2.1.1 Bypass Mode (Kiln Only)--
Exhaust gas from each kiln is passed through a conditioning
tower with water sprays. Each tower has three 0.6 1/s (9
gal/min) sprays for a total of 0.2 1/s (27 gal/min). Problems
with the conditioning towers account for about 75 percent of the
loss of production. The main problem is plugging, caused either
by loss of air pressure, misdirection of water spray, or plugging
of spray nozzles.
5-6
-------
A misdirected spray, for example, will cause water to run
down the side of the tower and will eventually plug or partially
plug the bottom discharge duct of the tower. When it is a par-
tial plug, operators can either shut down or reduce gas flow
(and, consequently, kiln production). A complete plug of the
tower discharge requires a shutdown and a crew of 10 people
working 8 to 10 hours to dig out the plug. The situation has
improved somewhat in the last 3 months after positive shutoff
dampers were installed downstream of each conditioning tower,
thus allowing operators to isolate each tower separately. Before
the dampers were installed, a problem with one tower would cause
both towers to be shutdown.
The other problem with the conditioning towers is plugging
of spray nozzles, which causes a reduction in waterflow. This
increases the gas temperature at the inlet to the ESP' s and
degrades their performance. Operators must then cut back gas
flow and, as a result, production. Optimum temperature range for
the ESP's is 82° to 104°C (180° to 220°F). Operators have de-
veloped a decompression chamber with a slide gate, into which
they can pull the spray nozzles for repair during operation of
the conditioning towers. The slide gates, however, will not work
well after the spray nozzles are removed five or eight times, and
the tower must be shut down periodically to clean the slide
gates.
5-7
-------
5.2.1.2 Normal Mode--
When the plant is operating in the bypass mode and the
roller mill is activated, the mill fan picks up deposited dust
and purges it from the system. This causes a temporary increase
in grain loading to the ESP's. As the system stabilizes, the
stack temperature drops from around 104°C (220°F) to about 82°C
(180°F), and moisture increases. Depending on the initial stack
temperature, however, it may take five or more starts of the mill
to stay within the 40 percent opacity regulation for the first 6
minutes. If the initial stack temperature is 93°C (200°F) or
less, it may only take one or two starts; at temperatures over
93°C, it takes progressively more starts. If the initial temper-
ature is over 104°C, the operators may elect not to start the
mill until the system has been inspected.
Operators have sometimes spent as long as 8 hours trying to
start the mill without exceeding the 40 percent opacity regula-
tion. If they cannot achieve clear stacks after repeated mill
starts, they begin looking for problems in the conditioning
towers or ESP's. About 95 percent of the opacity violations come
from mill starts, and the company says that many of the viola-
tions are for opacities that exceed the limit by only a few
percentage points. Malfunctions of the roller mill itself,
however, are estimated to account for about 70 percent of lost.
production; malfunctions of the ESP contribute only about 5
percent.
5-f
-------
5.2.2 Environmental Regulations
Production is severely affected by attempts to comply with
the 40 percent opacity regulation. Company officials say that
they have changed their philosophy--from the goal of production
to that of meeting the opacity regulation. Examination of the
problem reveals that most of the trouble stems from the condi-
tioning towers. According to the company, if the towers had been
sized larger many of the problems could have been averted.
Evidence also suggests that officials at EPA Region V recommended
that fabric filters be used instead of the conditioning towers
and ESP's. The company responds that it had no idea so many
problems would arise with the existing system, and that recent
modifications have not been successful. The company believes,
however, that EPA has been reasonable in its enforcement efforts.
In light of these problems, the company is naturally con-
cerned about changes in state regulations that will lower the
limit for opacity to 20 percent over a 6~minute period. Offi-
cials say they could never meet a 20 percent opacity regulation,
and would be forced to close. They hope to be exempted from this
regulation.
5.2.2.1 Future Outlook--
Several improvements have been added to the system in the
last 9 months. The ESP for the alkali bypass system has been
rebuilt. About 18 months ago, this ESP was not working properly.
A number of modifications (most involving gas flow distribution)
markedly improved the performance of the ESP, which is now in
5-9
-------
compliance. A $200,000 fine was levied against the company
because of opacity violations from this source.
Maintenance of the entire system has been improved. Ten
people (four full time) now maintain the conditioning towers and
ESP' s; they keep records on their maintenance tasks, and a quar-
terly report is sent to EPA. Level alarms have been installed on
the ESP hoppers for the kiln main exhaust. The company reports a
reduction in the time it takes to clean out a conditioning tower.
The company hopes to move production closer to rated capa-
city, but it does not believe that the plant can reach full
production with present operating procedures.
5.3 CASE HISTORY NO. 3
The following is a brief account of the series of events
that led to the decision of a cement company in Region V to close
its facility. The information was provided by the company and is
based on correspondence and meetings between company officials
and state and county pollution control officials.
In the early 1970's, with the advent of new, stricter air
pollution laws, the ESP on the rotary kiln at this plant was no
longer adequate. The precipitator had a design efficiency of 98
percent and fully met this operating efficiency. In an effort to
comply with the stricter regulations, the company modified a
dehumidifier chamber into a wet scrubber to be used for particu-
late removal after the precipitator. This combination of con-
trols enabled kiln operation to meet the county air pollution
5-10
-------
code of 0.2 Kg/1000 Kg (0.2 lb/1000 Ib) of gas. The scrubber
used water from an adjacent canal, and the scrubber effluent was
discharged back into the canal.
The use of canal water, however, created a conflict with
U.S. EPA regulations. The suspended solids content of the dis-
charge water was in excess of state National Pollutant Discharge
Elimination System (NPDES) requirements that limited solids in
wastewater to a maximum of 50 ppm. The company complained that,
in many instances, the water from the canal already had a content
of 180 ppm suspended solids before being used for particulate
removal.
To avoid this problem with the scrubber water, the company
undertook in 1973 an extensive ESP modification and rebuilding
program at a cost of $500,000. Despite these efforts to increase
efficiency from 98 percent to over 99 percent, the ESP was still
unable to meet the air emission codes alone. The scrubber was
reactivated in October 1974, with the hopes that an agreement
could be reached with control agencies to solve the water pollu-
tion problem. In January 1975, the company applied for a vari-
ance to its water discharge permit, including a request that the
limitation on the suspended solids consent of the discharged
scrubber effluent be changed to 200 ppm (maximum of 250 ppm per
day). In response, agency personnel requested that the company-
build a settling pond. The company, however, had no available
land site.
5-11
-------
The company concluded that the only way to solve the water
pollution dilemma was to grant the variance or install other air
pollution control equipment, at a cost of $700,000, that would
eliminate the need tor the wet scrubber. During those years,
however, the cement industry was suffering from an economic
depression, and the company believed that spending another
$700,000 with no guarantee that the plant would then be in com-
pliance was totally impractical. The company notified the pol-
.lution control agencies that it would be forced to close the
plant if the requested variance was not granted. The plant
continued to be under daily scrutiny by enforcement officials,
and the company said that since there was no sign, that a vari-
ance would be granted the production of cement ceased in April
1975. More than 70 employees were laid off, and a yearly supply
of 200,000 tons of cement was lost. The company stated that
after the plant had closed it was notified that the variance for
the suspended solids content in the discharge permit would be
granted until July 30, 1978.
The annual production rate at this plant was 274,160 Mg
(192,000 tons) of cement for 1974, and a projected 207,725 Mg
(229,000 tons) for 1975.
The misunderstanding between the company and enforcement-
officials should not have happened. A substantial amount of
cement production was lost as a result. The fact remains, how-
ever, that a compromise can be reached between a company and
enforcement officials if emissions at a plant are not too far in
5-12
-------
excess of the limits. In this case, the plant v/as in compliance
with the air pollution regulations. The levels of suspended
solids discharged from the scrubber were only slightly higher
than in the water taken from the source.
5-13
-------
APPENDIX A
NEW SOURCE PERE'ORMANCE STANDARDS
CEMENT PLANTS
A-l
-------
Subpart FStandards of Performance
for Portland Cement Plants
§ 60.60 Applicability and designation of
affected facility.
[42 FR 37936, July 25, 1977)
(a) The provisions of this subpart are
applicable to the following affected fa-
cilities in Portland cement plants: kiln,
clinker cooler, raw mill system, finish
mill system, raw mill dryer, raw material
storage, clinker storage, finished product
storage, conveyor transfer points, bag-
ging and bulk loading and unloading sys-
tems.
(b) Any facility under paragraph (a)
of this section that commences construc-
tion or modification after August 17,
1971, is subject to the requirements of
this subpart.
§ 00.61 Definition*.
As used in this subpait, a1.! terms not
defined herein slip 11 have the meaning
given them in the Act and in Subpart A
.of this part.
(a) "Portland cement plant" means
any facility manufacturing Portland ce-
ment by either the wet or dry process.
§ 60.62 Standard for p/irticnlate matter.
(a) On and after the date on which
the performance test required to be con-
ducted by §-60.8 is completed, no owner
or operator subject to the provisions of
this subpart shall cause to be discharged
into the atmosphere from any kiln any
gases which:
(1) Contain pariiculate matter in ex-
cess of 0.15 kg rx;r metric ton of feed
(dry basis) to the kiln (0.30 Ib per ton).
(.1) Exmbit greater than 20 percent
opacity.
[39 FR 39872. November 12, 1974]
(b) On and after the date on which
the performance test required to ~e con-
ducted by | 60.8 Is completed, no owner
or operator subject to the provisions of
this subpart shall cause to be discharged
into the atmosphere from any clinker
cooler any gases which:
U) Contain participate matter in ex-
cess of 0 050 kg per metric ton of feed
(dry basis] jo [«e kiln (010 Ib oer tonU
(2) Exhibit 10 percent opacity,' or
greater.
(c) On and after the date on which
the performance test required to be con-
ducted by § 60 8 is completed, no owner
or operator subject to the provisions of
this subpart shall cause to be discharged
into the atmosphere from any affected
facility other than the kiln and clinker
cooler any gases which exhibit 10 percent
opacity, or greater.
(d) [Deleted;.
|39 FR 20790, June !4. 1974- 40 FR
36250, October 6, \:jlS\
§ 60.63 Monitoring of operations.
(a) The owner or operator of an:;
poi tland cement plant subject to the pro-
visions of this part shall record the daily-
production rates and kiln feed rates.
[39 FR 20790., June 14, 1974]
(Sec. 114 of the Clean Mi Act as amended
(42 U.S.C. 7414).)
§ 60.61 Test methods and procedures.
(a) The reference methods in Appen-
dix A to this part, except as provided for
in § 60.8'b), shall be used to determine
compliance with the standards pre-
scribed in § 60.62 as follows:
Q) Method 5 for the concentration
of participate matter and the associated
moisture content;
J2) Method 1 for sample and velocity
traverses;
(3) Me shod 2 for velocity and volu-
metric flow rate; and
(4) Method 3 for gas analysis.
(b) For Method 5, the minimum sam-
pling time and minimum sample volume
for each run, except when process varia-
bles or other factors justify otheiwiie to
the satisfaction of the Administrator,
shall be as follows;
(1) 60 minutes and 0.85 dscm (30,-V
dscf) for the HIa.
(2) 60 minutes and 1.15 dscm (40.6
dscf) for the clinker caoier.
(c) Total kiln feed rate (except fuels),
expressed in metnc tons per hour or a
dry basis, shall be determined during,'
each testing period by suitable methods;
and shall be confirmed by a material bal-
ance over the production system.
(d) For each ru'i, participate matter
emissions, expressed in g''metric ton of
kiln feed, shall be determined by divid-
ing the emission rite J.i g/hr bj^the kiln
feed rate. The emission rate Jhall be
determined by the'equation, g/hr=Qsx
c, where Q. volumetric flow rate of the
total effluent in dscr.w'hr as determined
in accordance with paragraph "£a>.(3) of
this section, and cparticipate concen-
tration in g/dscm as determined-in ac-
cordance with paragraph (a)(l) of this
section.
[39 FR 2'j790, June 14, 1974J
(Sec. 114 of the dean Air Act as amended
(42 U.S.C. 7414))
-------
ID
13
o
CD
OO
O
I
O
o
U_
UJ
Q.
O
'.n
D;
Q
0
u -i
?. Q 'fl ^
O 4-
*J U
Oi C
> 0
-H -^1
«
« c-
A-3
-------
APPENDIX B
S TATE I !-TP LEI'IENTAT I (
U.S. EPA
B-l
-------
i']' Portland Cement Manufacturing Proeo->-,es. Rule- 203>a> and 20,!>c .-hail not appl;, to tlv.
kiln> and Cfulei- of port la nd cement in a;ui;act u; ' IIL; piuce--e-
Rule 203: Particulate Emission Standards arid Limitations.
'a1 Particulate Emission Standards and Limitations for Now Process Emission Sources.
Except, as further provided in this Rule 203. no person c-hal! cause or allow the em;--P'n of partioulate
mailer into the atmosphere in any one hour period from any ne\v pioees- emission .source which, either
alone 01 in combin.tt'on with the emission uf participate matter from all other similar new prncess.
eini^.-ion sources at a plant or premises, exceeds the allowable emission rates specified in Table 2 1
'Table II-A i and in Fufure 2 1 < Figure Ii-B">
(b1 Particulato Emission Standards and Limitations for Existing Process Emission Sources.
Except as further provided in th.H Kuie 203. no person shall cause or allow the emission of paniculate
matter mtn ti'.e atnio-,]:Kere in any one hour period irom any existing 'precess enut-'.ii1!! source V.T.Ich,
either aione or in con,bin ition v,i:h toe (.Miiissioii of pai ticultito matter from all orh.er s.imilar ivss or
existir.fi n:'t>a-^ e'ni^'on SOUITC? r.t a plant or premise.-, e:;ceed? the allowable e!ni.-..->;e,n rates 'pcvifvd
in Table 2 '.'. 'Table 1[ C" , and in Fi^Liie 2.2 if i-ine 11-D ''.
i c') ('onipliance b v Existing Process Emission Sources. Except as oth^rwi^e provided in thi^- Rule 20.'!
c\rery ex is tin.:; process emission .source that i.-i not in compliance with paragraph b) of this Rule 200 as of
the effect've date of Part 2 of this Chapter, -hall comply with paragraph 'a; of this Rule 203, unit-..- b'.th
the f'.)l!u-.\ i-ijr co'iihtiens are met.
i I> The source is in compliance, as of the effective date of Part 2 of this Chapter, with the teirn and
condition- of a variance granted by the Pollution Control Ro.ird, or, within sixty iGO) davs uf t'ne
effect!\r date of thib Cr.apter, the source is the subject of a '.ariance petition filed uich tl:e
Pollution Control Board, v.hich variance :s subsequently granted bv the Board, and,
R-2
-------
TABLE 2.2 (II-C')
STANDARDS FOR EXISTING PROCESS EMISSION SOURCES
Process Weight Kate
Pounds Per Hour
Process Weight Rate
Tons Per Hour
Allowable
Emission Rate
Pounds Per Hour
3-3
-------
V
B-4
-------
-------
No person shall operate any process so as to produce, cause, suffer or allow
e amount shown in the following
particulate matter to be emitted in excess or th
table. Exceptions are combustion for indirect heating, incinerators, open burning,
Process
Weight
Rate
Lbs/Kr
1
1
~>
2
5
_}
4
i>
6
/
S
9
10
12
100
200
400
600
SCO
,000
,500
,000
,500
,000
,500
,000
,000
,000
,000
,000
,000
,000
,000
Tons/IIr
0
0
0
0
0
0
0
1
1
1
1
-1
z
3
3
^
^\
5
6
.05
.10
.20
.30
. 40
.50
. 75
.00
. 25
.50
. 75
.00
.50
.00
.50
.00
.50
.00
.00
Rate of
Emission
Lbs/Hr
0.
0.
1.
1.
2 .
2
3.
4.
4.
5 .
5 .
6 .
"7
8.
<}.
10 .
11,
12.
15.
551
877
40
33
22
58
38
10
76
58
96
52
58
56
49
40
20
00
50
Lbs/Hr
16,
18,
20,
30,
40,
50,
60,
70,
80,
90,
100,
120,
140,
160,
200,
1,000,
2,000,
6,000,
Process
'.Veight
Rate
Tons/Hr
OOC
COO
000
000
000
000
000
000
000
000
000
000
000
000
000
000
coo
000
S.
9.
10.
15.
20.
25.
30.
OD .
40.
45.
50.
60.
70.
80.
100.
500.
1,000.
3,000.
00
00
00
00
CO
00
00
00
00
00
00
00
00
00
00
00
00
00
Rate of
Emission
Lbs/rlr
16.
17.
19.
25.
30.
35 .
40.
41.
42.
43.
44.
46.
47.
49.
51.
69.
/ / .
92.
r~
3
9
2
2
5
4
0
3
5
6
6
3
8
0
">
t
0
6
7
When the process weight exceeds 200 tons/hour, the maximum allowable emission
may exceed that shown in the table, pL-oviaed the concentration of particulate
matter in the discharge gases to the acmosphere is less than 0.10 pounds per 1,000
pounds of gases at standard conditions.
!§ * b.a§ filtcr£,_or _e.Jya he n t__gas_-^Jj^rninp J^y_ijy_£_s_ sh_riJJ__b_s a_l 1 owed to dis c 11ar s^e
concentrations of particulate n'.-iiter ije accordance with E"=--=8.6 P^.^"7 below 30 tons
per hour or p roc e j_s VT e i cdn - snd E=~15.0 P'-1-- over 30 tons per hour of process weight.
Existing petroleum catalytic cracking units equipped with cyclone separators,
electrostatic p recipitators, or ocher gas-cleaning systems shall recover 99.97°6 or
i'ore of the circulating catalyst or total gas-borne particulate
" "nterpolation of the data in this tab-e for process weight rates up to 60,000 Ibs/h.r
jiialJ be accomplished by use of the equation .""-4.10 p0.67_ r:nci interpolation and
extrapolation of the d.?ta for process weight rates in excess o.t 60,000 Ibs/hr shall
be accomplished by use of the equation E---55.0 P^-^-^'O, '.-/here £ = rate of emission in
Ibs/hr and P=process weight in tens/hr.
B-6
-------
R 336.44. Emission cf particulcite mu'fer.
Rule -1-1 It is l.'ih.UHl! I1""' a pel -0:1 to ta'ee fir ailov. the e'
p irtienl.i'e in i''ei H'Mii ,iii\ vn.i'f e ::i ; \ee-.s '.1 ,
. a r I!:i' !:i,i\iniirii a llov, a'nle oi'ib- r>n >a'.e lote;! i'i "K:l ie 1
on its v. ,Ji tli.1 application o! i'.c In^t
tccbiiic ills' It.'isiljic, prictical t"iuiji,i"icnt a\ailu!iu' I !;;s a.ppiies oii\ to
souict's not assigned t; s!>'0:(ii- i-i'.iissi'.n \"->it 1:1 T !>!<' 1
permit to install or a pt-rn:t to opciat''
( tl ) The maxnnuci ailo'/.^ble eniissioii rate spi'c:fi;\l in a \olun!ar\
agreement, pe; lorinance ci>!i!,aet, '.'tipnlatii'ii. 01 an onloi ot the C'onvni-sii^i;
( t' '; The md\!irm:n ailei\\ahlc cniissifn iatr as clct-. i nu'ied 1>\ Table 2 ! >r
sources not to'.tie'J in si;b,ii\ isions , a ' t(i d .
TABLE ].
PARTICULATE MATTER EMISSION SCHEDULE
-------
\i, ,, u .; ii,- : ,, -. .,
-- 7~ cl l'>; '.I I., ,r ,11;- t
Ai1" n'V 1 '.nil,.I >:,.'!! lilt!
ti.'.- !v.-U
10
E-8
-------
MINNESOTA
APC 5 Standards of Performance for Industrial Process hquipuu-nt
(a) Definitions As used in this regulation, the following words sha-' have
the meanings defined herein
(!) 'Collection efficiencj" [iu,^$ the percent of the toial amount of
participate matter entering the control equpmj.it which is removed tro'n
the exhaust stream bv the control equipment and .s ^a!cula:ed bv the toHo'.^-
,rg equation'
collection erf.ciencv --
10Q(A 3)
A
Whore
A -- tne 'iivcant (eram-j or counts) or the coiccrUrati^t. 2,- SCH of
particular matter entering tre ^l',t.et'oa e^o ~m::u
B = the amount (grams or pounds Of the Concentration (gr SCF) . f
parrcul.ite matter leaving the control equipment
(2) "Itiuustml process equipment" me^ns any equ'prnent, ip":ar.i'Ui,
or device embracs"]^ chemical, icoii-'triai or n,iinL:laetunr>-; tociliiics :,uch as
ovens, mixing kettles, heating arti r:htatmf, furnircj;, kJn\ sti'U, covers,
roasters, and eouipment uced ,n connection :he;<~witn, 3rd a'l otV:r rruthods
or forms of ma.uiractumjj or procevvig ti.at mav e.pjt any air .ont^rmr,.nt
such as smoke, odor, part icu late matter, or gaseous m /.te1" Ir.((dst"irti
process equiomeru is an \J7ecte\J 'ac.tity " An e'i.;sjion fac.l.ri mav coo^iit
of more tnan one unit of inansinoi process equipm.'it
(3) "Process weigh:" mean,-, -_"o total ve':,n i>i a .v.en tine p-::icd OL
any emission ot panicuhte ma.t^r So/d fi-1-. ch^r.t'il or-: corsiJercd as p'.rt
of :he fr^.^-s "we1^?! ci'.t I'C'Jid a"d g'l^eo.'^ fut li ?.ni .xrnnL^X" ai; ire
not >"cr ,. ^;J^A\ cr K,it:h ope'ii.oa irt rroc:-s wei^'it per h1'^ is derived
b .' dividii^L.1 :he :JM! r-roc--"s v,e'^;:r b;, ;;ic n^rriicr ,-t \cuii T cue corr:V'-
operation rrorn t'le hj: rning of a " si\s^ proc-ss ;o :ne co^'ikr or. "-'::;:OT
exciuJ.ng anv :!iie Jur.: z, h.ch the .\upr-.ei: 's ;d'e F. a a coi::inoou,
opciatic.i, the 0:0:0^ v-,eI-:nt per roar ib L'^;,'^'! by di-'.o.Tg the rroc-^i
weuht for a ivr. ic-:! pe"o ! of '(rue
(.b) Arp'ic ;* Lity This rj?ui;.;;o;i -ii.'1!1 a- fly to ;nJust:,aI rrocess e'lu.i -
ment foi which a ^Mndard ot perform in- e his no; been ;:r,>rrul:;,u;jd ip j.
(tb) Exhibit greater than 20 percent opacity, except that a maximum
of 60 percent opacity shall be ptrmi^jbie for 4 rn'niHes in anv 60 minute
period and a maximum of 40 percent opac.ty shill be permissible for 4
additional rnmutes in any 60 minute penod.
(2) The owner or operator of any -ncustnal pro:e>s equlpnieni v,h*"h
v-as m operation before July 9, 1969, nn-ch has control equipment \\itl a
collection efncienc;, of not less 'ban 99 rerccnt bv wc'gnt .hall be cons.cered
in corcpl ance with the requirerre^ts of subsection Tc^'lKaa) of '-his re^i'U-
tion
{31 The o*Arcr or operator of an1, no ^MM! prore^? eqj'prnr.it 'A'rrch
was m operation before Juh 9, 1969, vn:ch is located outside the Nf.nne-
.--pohs-^t. PcJ Air Quality Cor.:.-?! Region ;nd the Ci:> of Dji--th, v.h:cb ib
located not 'ess than one-fourth nils from ^r.y r^s,cj.en.e *-: ouMic ro?d'^av,
and v\h;ci: has ccn'rol equ'pment with a collection efpc ency of rot less
than S5 percent b> weight, and the operation of the entire envision faci'.iiy
does not ca,:sc a \:o':fon of the anbi-jnt air cuaUty standees, b^all be con-
s der?d ir. cc.ODl-ance v, :& Lre requuemenrs of b-bscction f^Jilnaa1- ot this
reg jlation
(d) Standards of Perf^rmai-ce for Post 1969 Irdu;t: ^hdi! ca^se to be dischir^-:a T-'O :ie it-
mj_phere frcrr". the :r:d'.;stri,-[ pr.,c-:^s enL,pn:ent i.iv .^a^es v>n;^n
fa a) In ar\> one hour con 'am paniculate rru.ter i:\ c. \cn^s :t the
amount peim'tted :n Tar'e i ;oi the allocated proce5i 'weight, proMi':d (pap
the o^ner Oi opera'cr ih^ll i oc be recuire^ ~o ret uce the par"icL.!a;e .r.^trer
err.i;s!3n be^ov the co.ice.icr^: on per^ucea u: Taole 2 tor the appr^jri^'o
source ^ris vu!i:n^e, orovided further Tnt le^arc'e-^s of L.ne mass emission
permitted by TaNe 1. the o^ner or orerator ;'^all nof ^e peniitted to em*:
part.culatc matter in a concer.r. Men m exres-, ot 0 liQ T-lv-.rts p^r ^rncara
cubic foot of 5'-h,iLisi j.ti, or
rafer -n a ',on1,eTtro.,OT n stc:si o: ',' ?'_" 5-ai-r.; pel ,\tiv ard ru'''.1 f,.,1' of
^-r,'1,: : .'":, or
(2) !>,: owner or operator cf -my ':xu^t;:al pro,^^, !;-- M'ncn; v, h-.h
Aas not m opera' o*-, bcfort J.:'\ 9 1969 wh'c'-, has v.oi.;c' -.r. --u enr wi:h
a LC'I'tct'cr: e'^.c-e :cv of :iOt !e:s "ran. 99 7 re-.ei*. JY -^i^nf "h I'l ' e co^-
s ^e'ed m compliance with tb.s ;eqi iremerirs o: jubv^rtau (d\ -V ia) o: tbi's
(5) T'^e o'.'.ner cr oucr:tor of a,v. ,'sd.^trial iv:
v^as in cptrr./.iOr. after Jul'- 9, 1'-JD9, \<.'',--h ,\ locr e,i o^^.J^ *^e V^M:-
-uohs-riT P.-.'J! A.r Q*_ >!!i\ Conlro! Re,: or; and -Vie Cir- cf D^luth, '^h :h is
Iccare'.! not le^s than o-jo-'ourth, ir|Te frrm a;i/ residence or p>:^!:c roadv-i-av,
.'\1 '.ncn nas co'i;":*' equipment -Aith a co'lection Ci'^cier.cv cf ^ot less than
S5 ^-e'cent bv h.e,Jnt, cf.d the o'jsr:.tioj of fhe eijt"e c.ri^s.or tv.T'tv does
'
B
-Q
-------
(1) Method 1 for sample and velocity traverses,
(2) Method - for velocity and volumetric How rate.
(3) Method 3 for gas analysis,
(4) Method 5 for trie concentration cf particular- matter and asscc ct^d
moisture content,
(51 Method 9 for visual determ rat on of the op:citv of ernis-ior.s fro.1
stationary sources
(f) Performance Test Procedures In the event that emission? from, at,;.
industrial process ecMrmem contain organic vapors wh.ch crndct.^ c.t :;;.;;-
dard conditions oi temperature ard pressure, the following chances in
Method 5 for determining paniculate erni ^ions shall be made
II) Paragraph 42 (S-rnple- Recover,) in Metr.od 5 is amended -o iv:J.
as follow^
4 2 Sample Recover. Exercise care in movir.g the collection tram
from the test sue to the sample recover} area sc a^ to ir.imm ze the io..s ::
collected sample or the gain of extraneous paniculate iratter Set a«ide r.
portion of the acetone and water used in the s^inple recover;, as a blank for
analysis Place the samples L\ containers a-> folIoAs
Container "1 Remove the filtei from its holder, place in this con-
tainer, and seal
Container ~2 Place loose paniculate matter aid water and acetone
washings from all samole-c^tposed surfaces preceding the filter paper IP thi-
container and seal. The probe and nozzle should be scrubbed wi>h a sti:t
brush and dis'uled water, followed bv an acetone rinse If these solvents co
not do a rood cleaning jcb, an adequate solvent must be found and used Use
3. razor blade or rubber poiicenan (o loosen adhenng p?'t c;e> :f neces;;!^,
Container -3 Measure the volume, of water from 'he first three .m-
pingers and phce the water 'n this container Pkce v,c.tci r.rsir^s cf : h
sample-exposed surfaces between t^e Liter ?nd fourth Lnpirger in tins con-
tainer prior to seeling
Container ~4 Transfer the sine;; gel from the fourth inpingtr to tl,e
original conta'ncr and seal Use a rubber policernaT as an aid in rerro* n»:
silica gel from the ircpipger
Container -5 ThoroughK nrse a!i sample-exposed surfaces between
the filter pare' and fourth irnLnneer with acetjre, place the washings m th.s
container and seal
(2) Paragraph 4 3 ^Anai.si-1 in Method 5 is r-rpended to read as follows
43 Anaivsn Record 'he data requ.ied on the exanp'e sheet sra.v n
in ^ijure 5-3 Handle each sample container as follows
Containe 1 Tran^fc' the filter and ar". loo,,e rart'C^'atv nuittei-
from the samt'le c^ntuner to a ;a~eu glass v-ei^hin^ U'sh, cts.ccat. an.' dr.-
to a constant weight K:-ort resclti to the nearest 0 5 rig
Container ~2 Transfer 'die va^hi ,gs to a t.iref' beaver and ev-.:>^rvc
todr.ness at "rr'H" lent 'ernperature and pressure De-iceate ^nd c;r to < c^'i-
sta.nt weu-V ^A e ^b to the rearer 0 ^ rn^'
Container "^ Extraci ory?.n,c p.ut'ei.'ate from the i:n.ir.."er s^ L t. ..
with three 2* "-.' portions of ch'croforn. Ccnplet-' tnc ec-~.cc n -v ;, three
25 ml pr.riions of etl;l e'he~ C'emr.Lie trie etr-.r ar.d ch'r'roror-' e^t~...cts
transfer to a i re.l "tike' ana e'.aporate at TOT until no snNerr rei.-,.-ifs
Desiccate or. tt. a rcrisiJLt wfjfct,' ;,\) rep >,-t :ve resui;., to t^e ueare.. U 5
rag
C.7ntamer --4 Weiih tr.e sp.'.-t sillea gel and iepc.rt to the r,..-est
TABU. 2
Process V/;,eht Rat.
('bs 'r.r )
50
ICO
500
1,000
5,000
10,003
20,000
60 000
60,000
120,000
160,000
200 000
400,000
1,000 000
TABLE 1
634
9 73
14 99
2960
31 19
33 23
34 85
36.11
40 35
46 72
P ~ ;,0 tons'lir
and interp-o.'atiOn ^:]d exfapolattcc of the data for process weight rates in
excess cf oO.OOj 1?- 'hr soal! oe accompl sbec by ure of the equjlion:
E~ 17.31P;is
P > 30 toQ5;hr.
Voere E - E.r.issions .n pounds per hour
P -- Process we: nt r?.:e in to is per boc'
B-10
-------
APC 22 iU'uijrds oi Pc'-tonuaiuc for J'ortlar'd Cn.vrt l'!>nLs
(Kb L\Nbi; ^rca cr :! '" -^ .vc.'nt ooac.r., escort th-i a maxinur.i
of 40 percw^t ep.i-'C> V-^'l ;v p.n^y bie for no; r.io:e th.i:i 4 minuiss in
an-. 3!1 " r'L'ro-, r-"iu' .in^' -j. ni.iii,i i-n of hO percent C;MCI:> sh.ul L'C p^r-
niivsil?;j TLT nu: n^- ^ t; ^ i ^ m.n^^-- i:- an. oO minute pcr;o '
(21 "I if rcn :rcrrcn^ c* t'vs J..T'^-r .'.re :.[ p!.c:bk to t^e k'in, the
cl-nker or-o'.1: rV * i^ ;r, ' v-- - i; l',.. -./,\ mil d;>cr, r:r^ mater,al s'-orare,
tne finish m '! s'.^-.1!1 Ci.'ie: <, ,^, ^-: hr.^hcd prooivt sr.T-^e. con%e>or
transfer pc "i^ ar.J b,,i:^ir _; :^tj '-'_:,. irar rg a^J unioncine sv^'irns
anJ un'or.'r^ ;^ t;"i- .r\ g ,^ \\u oh e\nr;t ?^l;e: t: ^n 10 re-cj;^
Op.'C'i
fj) M.---0 --r.; -r 0"-?r't.O' . \ t.' ;-n;r cr ere-,-""'' r.f ar\ pcrt'-:?ur b. 'r-,1 -,.!n !~"tl ra'.c ;r: e^^ssjo'i ;,'e ^a.' n^ ct'..Tni nt-'O
bv ihe '-OL,,-'-JP jn-hr - Q, x c v>.;re Q. \cLirreLr - fl-.n* r it: ->f tv'?
io'a! C;:;UL\I: -i ^vc! hr as d-?':r''- ' e ' ;n occrrJince ,>. ;'-, M '^Si'.i^'T; 'eV^!,
5-11
-------
OHIO
AP-3-07. Contio) of »iMhu; air coi'Wi.mnnts from
stationary sources.
(A) Emission lir.iuaticn.
( 1) No person snail discharge into the atmosphere
from any single source of'emission v, hatso-=ver any
air contaminant of a shade or density equal to or
darker than that designated as No. 1 on the Ringel-
rr.ann Chart or 20 percent opacity, except as set forth
in subsection (A) (2) and i?ction (E) of this rt6vUi-
tion.
( 2) A person may discharge into the atr.-iosphere
from any single source of emission for a period cr
periods aggregating no; more than three r'inuto.i in
any sixty irurmtss or for a period of urr.; deer.id
necessary by the Bo^rd, rat co.itami.'iar.'-s or a shade
cr density not disks: than No. 3 on the ninjelranr
Chart cr 60 percent op'-cio,
(B) Uncombined v.ater.
It sha.ll be deemed not to he a violation o' this
regulation v/l.ere the presence of uncornbined v.'atsf is
the only reason for failure of an emission t'J r.,eet the
requirements of this reb"jiacicn.
(Adopted January 23, 1372; effective February 13,
1872.)
its ,i."piirtor.ances or a road to be used, co"istr;;cr-'d,
alrered, repaired, or demolished v',nh;ut ipkir..^ reas-'n-
ab' > precautions to prevent part.o-jlt-.te r.atter from
b-:corr.i;.i alraorne. Such reasonable precautions shall
(1) Use, where posbiols, wr.rcr or cherracaLi for
co.ilrol of dust :;i the denalitio.- of exi.,tins btii'Jir1,^
or structures, construciion opei^tions, the 7rad:n'j of
roads cr tne cJcanrg of land,
(2) Anolicatiun of a;,pra;t, oil, v.atcr, or suitable
cf-.'-rriicais c;i dirt roads, catena.' s'ochoileb, ar.d
other surracus -.\hich con. create auocrne dusts,
, 3) Ir.staiJdtion arid use or" hoodi,, fans, anJ
cor'trol e_iuipr;ent to enclose, conn.ri, ca;;ti:re a-'d
vent the har.dlin.; of du^ty materials Adecuate f jn-
ta.nner.t methods shall be employed uan.ig sand-
bi'-.stin;: or other Similar op-'rat^ons,
(4; Covering, at all tiuies '.vhen in not:o-:, c;-M
oci.ed vehicles transporting materials ii.tely to be-
to' C' -:duct of agricultural practices .,uch as
B-I:
-------
AP-3-12. Restriction of emission of participate
matter from industrial processes.
(A) General provisions.
( 1) This regulation applies to any operation
process, or activity from wr.ich participate matter is
emitted except (a) the burning of fuel for the primary
purpose of producing heat or power by indirect heating
in which the products of combustion do not come i:'tc
direct contact with process materials, (b) the burning
of refuse, and (c) the processing of salvageable
material by burning.
( 2) Emission restriction requirements for sources
not exempted under subsection (A) (11 above are
specified in Figure II and in Table I. Figure II relates
maximum allowable mass rate of emission (ordu.ate).
Table J relates process weight of tr.ate.nals introduced
into any specific process tacit rni'.y cause any emission
of paniculate matter to maximum allowable mass r.:te
of emission. Table I s.'.all apply in Priority I Reg::>r.i-
where tht- Uncontrolled Masr, Rate of Emission car.nct
be ascertained ana where an emission factor charac-
terization for the process is unknown. Curve P-l of
Figure II shall apply in Priority I Reg.ons where the
Process Weight Rate cannot be ascertained. In 311
cases, the more stringor.t of the two riq.iirei/.ents
shall apply wheje both are termed appiic.ible
(3) Compliance with the limits sp°om?d lu sec-
tion (3) of this regulation snaU be determined b<-'
sampling ar.il other rneasar" mon/s inodj nt the air
cont£.rrv.n&t!on source or sources p.icr 10 t'.ie p;mt ,1:
which air contaminants at- emitU'1 to the atmosphere.
The uncoati oiled mass "te of e:ri:-sijn may be deter-
mined by sampling in the stack up.v.tea.rs from t*v.- nil-H
cf the control eQUiprer.t. Es'.irnitir.g '.echruius.s
approved by the ooara m?y &-:
above reiuutd source teslir.;.
(4) Emission tests relating to this regulat,o:t
shall be :na,ie follow nit- the sti'.nJ.ards in the Ar-.erican
Scc;ety of .Mechanical Engineers Po.ver Test Codes u
PTC-27 dated 1957 and entitled, "Oete::;,ining Dast
Concentrations in a Gas Sirs?..in", or as -uxiificJ by th^
Hoard to s^it specific sampling needs or cor.clitic.i5,.
(5) For purposes of Figure II, the tctal uncon-
trolled mass rate of emissi-jp. iron all similar p^cvess
units at a plant, such units bains united either pn; si-
cally or operationally, or other-vise located in clo.js
proxii;:ity to each other, shall be usad for d-.ttrmin:)-^
the. maximum allowable laass rate of emission of
particular macier that pas3es through a strcX or
stacks
(6) For purposes of Table I, process v.eignt per
hour is the total weight of all materials ir.'rcdaced
into any sir si-:, specific process that may cause any
emission of paniculate matter. Solid fuels charged
will be considered as part of the process wei,,v.>., bt't
h.'juid and gaseous fuels and combustion sir '.\ ill not.
For a cyclical cr batch opeiafion, the process weight
per hour will be derived by dividing the total process
weight by the numcer of hours in one complete opera-
from the beginning of any given process to the com-
pletion thereof, excluding any time during "hich the
equipment is idle. For a continuous operation, the
process weight per hour will te derived b\ dividing
the process weight for a typical period of time.
E-14
-------
emission in Ib. hr and P Proces.s \ve;sht rate in
TABLE I
ton/hi.
ALLOWABLE RATE OF EMISSION SASeD OH ( 4) A11 persona ideated within air quality control
PROCESS WEIGHT RATE regions cias.s^ed as Priority III Regions shall attain
or exce«d, as sonn as practicable, but no later than
July 1, 1975, that desr-J1? of emission reduction speci-
fied by Curve P-3 of Figure II.
(5) AH persons located vathir. air quality cor'rol
regions classified as Priority II or III Regions shall
attain or exceed, no later than July \: 1978, that
degree nf enissicr; reduction specified by Curv t- P-l
of Fi;j.*a II or U Table I.
(Adopted January 28, 1972, efteo'.ive February 15 _
1972.)
(3) Frr.i£:j;cr. linuatiurs
( 1> No person shall ca';.-e, cufter, allow, ci per.,it
the eni-osior tf parriCvilate ratter in a:r, one h">ur u> ;.i
any sc ITi j i; e,\7os^ cf tht^ cxrr.Gunt shov.'ri in "ee
foi .o.vjr.s; Figure II.
(21 All persons located ,sith.n ai; ;;uaU'y c>. r.Lrni
r^;:;ops classified as Priority I Regior.s shall attain
erf exceed, as scor. a^> ptactitabl-3, bat no late- lhan
J'i'.y 1, 1075, t!:.u degree of enassion r^duclun jp^oi-
ficd by Cur\e P-l of Fj..;w:c II cr by Table I v lucr-
e'.or u applicable under sub..eclinn (A) (2).
(Si All persons located within ai: duality c-.itr:,i
rer.iors classified as Priorit;. II Regions srall attain
or e.xceed, as soon as practicable, but no l?u-- t'n.'.n
July 1, lP7f>, that decree of e'nission redacfic i
s;---cific-d by Curve P-2 of Figure II.
I:;terpolarion of the data " thi;3 tulle for process
v,t;~h: rates up to 60,000 lb,'rr :,'.T.!\ be accomplished
bj use cf ;>u: eQuation E = 1.10 P°'f ', and inteipola-
-------
NR f54.ll C'ontiol of patiienbip eniissior.s. (!)
GENERAL. LIMITATION'S. No peison shall cause,
suffer, allow, or permit partieu.Lite matter to be emitted
into the ambient an vri'cn substantial!) contributes to
exceeding of an air standard, or creates air pollution.
(2) FUG I FIVE DUST. N-> person shall cause, suffer,
aliov/, o! permit any materials to be handled,
transposed, or stored without taking precautions to pre-
vent part'culate matter from booming a'u-borne. Not
shall a person allow a structure, a parking lot or a road
to be used, constructed, aHued, repaired, -.and blasted or
demolished without taking such precautions. Such
precautions shall include, buf not be limited to.
(uj Use, w here possible, of u ator or chemical , for con-
trol of dust in the demolition of existing building < o:
structures, or construction operations,
fh) Application of asphalt, oil, water, suitable
chemicals, or plastic coveimg °n dirt roads, material
stockpiles, and other surfaces. which can create airborne
dust, pio'-ided such application does not create a
hydrocarbon, odor, or water po'luiiur problem.
(c) Installation and use of hood-:, fdi>^. acJ a;r c'eam:";:'
devices to enclose and '.en*, the areas where cJUv.y
matenuls are handled
airborne while beins/ nu\ed on public i^adi. lailroaxis, o'
navigable u ;i'eis.
(e) Conduc; of aencuhuia! p.a^iu;.^ -.11 '" ,:, tilli'iy of
land or applicaiion of fertilise! : in su'.h ma;. a :
create air pollution
(0 The na\ini! or maintenance of vadv ./.
ing lots so a* not to create air po'luti^n.
(3) PARTICI'LATH t MISS I ON LlAil f.S P-O^
PROClISStS. No person shall cause, suffer, allow, or
permit the emi.j-.ijn of paniculate ma:ter to i'~e ambient
air from a direct or portable source imolv;nj a proce >s in
excess of one of the following limitation7
(a) All direct and portable sources, on which construc-
tion or modification is commenced afUr Ap,:l 1, ](J72
shall meet the emission limits of this paragraph.
1 Director portable soarcc-; otrit-r thi'.'i those .,'Hcified
in (2) (a) 2. of this section, emission- in excess of-
a. An\ process rot otherwise cci'-eied b\ p-'agrap'h (3:
(a) of this section emissions calculated b\ the use of the
equation, E == 3.59 p'1 "; for process weight ra.ies up to
60,00"') pounds per hour; b> use o!"ihe equation F, ~ 17.31
p1'" for proces.) .'eight rates oi (v'i.O'JO poi:nrls per hour
or more; (F. is the allowable e. illusions in pounds per
hour and F is the process ue ght rate in tons per hcmr,) or
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in concentrations greater than tbo^e listed m section NR
154 11 (3) (h), wmchever is more restncti\e Some ex-
amples of these calculations are gi"en in the following
table.
h Cement kiln.v 0.30 pounds of partieulate per ton of
iced to the k:ln.
c. Cement clinker coolers' 0 10 pounds of part.cnlate
per ton of feed tn the kiln
2 Direct or portable sources specified here'in^er on
which construction or "'e'dificat'on is commenced after
Februai} 1. 1975, emissions in excess of.
a. -\sphalt concrete plants (an\ combination ot thr
following' dr;,ers. svs'cms for screen-rig, handing, stor-
ing, and weigh'ng hot aggregate; sxstems. for loadi-ig,
transfe;ring, and storing mineral fil'er; systems for rr.iv
jng a.M'hnli Concrete: .-r:d Me loidi.ig, transfer. a;,d
storage s\ .terns associated with emission cot's-o!
svnenr>) 0 04 Bait's ;;er dr\ ctibic foot at st:;nda(d vS
n In tho^e instances ir. '\hich au\i!:ar\ liquid or soi;>.;
TOSMI fuels are bur-led '"\ the rliiKJ caialvtic cracking an,;
incinerator-'.'. acte hont boiler, participate matter in e\cc\s
of that penr.'tted o;. paragra.ph \A) fa) Led. i.f this stvon
max ^e emi'ted to the a.imosphere, except 'bat the m-
eicmentnl rat.: of particub'tc eTi ctibic foot at
standard conditions (50 m:ihg!<;.r!< per dr. cubic metei -it
standard condition;}.
e Iron and steel plants (ba^rc o\\r,en process f;ir-
n:es) 0022 grains per dr. cubic foot at s andarri COFI-
diiions (50 milligrams per dr\ cubic meter at stand.;rd
condition-.)
(b) -\H direct and portable sources on which construe-
ii'ui or modification as commenced on or before Apr;)
1, 19"2 shall meet the emission limits of this paragraph
I. Direct 01 portable souices specified hcreunder.
cj'ii'Ssions 'n excess of
i< Cupolas- (U5 pounds of partieulatc nu.tter per 1,000
pounds ol gas.
b. Piectnc aic or induction furnaces 0 1 pounds of
paniculate matter per 1,000 pounds of gas
c Open hearth furnaces- 0 2 pounds of paniculate
mauei pen 1,000 pounds of gas
d Basic o\\gen fi.inaeey 0 ' pounds of pa>-!iculate
matte; per l.O.'/O pounds of ga5.
e Sintering plants 0 2 pound;, of particulate mauei
per 1,000 pounds of uas.
f. Air melting furnaces: 03 pounds of paniculate
matter per 1,0-nO pounds of gas
g Heating or preheating frniaces 0 3 pnunds of par-
ticulate matter per 1,000 pounds of gas.
h. Blast furnace; 0.2 pounds of particulate matte; per
1,000 pounds of gas
i Asphalt, concrete, or ag.giegate mix plants' 0.3
pounds ol paiticulate irattei per 1,000 pounds of gas.
I Cernen; kilns- 0.2 pound; of pr/rt'Ctilate matter pei
1.000 pounds of gas.
k. Lime kiln;, 0 2 pounds of particulate matter per
1,000 pounds of gas
1 Cement cimker coolers' 0.3 pound;. ( f particulate
matter per 1,000 pound-, of ga^
m Grinding, dr\mg, mixing, corne>mg, sizing, or
blending' 02 pounds of paniculate matter per 1,000
r.ounus or ^as.
n Grain processing or handing 0.'- pounds ol |/ar-
tbulate matter per 1.000 puird, of g;.>.
o. A TV other p/oees'-, not cnum; rated 04 poum'.s of
part.culute matter per 1.000 pounds of ::us.
B-17
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r ? c'" ' M r
c-i
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ErsTAL PROTCO 10\' AGLA'CY
Cl FLUL.NT C.UlDhLlNhS AN!) SIAMJAUPS I'OR CLM'iM' M VNLTACIURIM,
(-10 CFR 411, 39 I'-R 6590. R'!iru:(i\ ;0, 1V74, Amended In 40 I }\ 6432, Pebrunty
1 !. 19/5; 42 }-R 106S1, Tcbruary 23, 1977)
T,t|j 40Protection of the Fnvircnment a.aikblf into: mation. the r?>> :<>j...! \u-
CHAPTER 1-ENVinONMENTAL m^ti-UPr .or the Srrne' -Mil mahe o '
PROTECTION ACtfJCV ;uahe;i nam^ tnai ^en tact^, a-e o ;,; ,
mo not funoament.un d'.itereiu lul tna* l '. I >'--" . >..<'-. . :'>MI n>,
SUUCHAf'TER NEFFLUENT CUIOF.LINFS AND .-,,>... r.-,-,,,,«-.,.,-,,, t-, ri.,,<:f, ..-><-. .'r f -M MM,| . r ,111,-.-
STANDARDS l.w.Uk. l l, Jjl.a u, (._.,>. t ,, ..i ,,];__ __ _ _ \\,,.,.,, ,, , r .,,,,..-, ,1 ;, ;, ,-,
the T>jyeh-,r,ineru DC cr.'r.ept. it MKH
PART 4U-- CEMENT f.lANUTAC fL'fliNG lu,ic;-(1,lr,-t-;iv fi".p'e>h fvioi, ,'ie ~ ~~ '
POINT SOURCE CAIhGORY fmmd t-,"n t f -P p..,,, A .; \r'7n,,,,--. ,, , , , , , ,, . , ,
lOUiin ii> o.'.i ; u.r t,>j'uMai v, in,Mi.- .a- i, ;!j.!l 5 i-ftii-ritnu'ti; -;,ir,,,,,-i! - in- x-
Ef'luent 1 innUtioiT? Guiclelinrs tor cjr the S'.iUe .shall c^iall'.-h for tic
The pro-.-.-'on-' of ;ii:'., Mibpert air ap- ;n";11ir Ao''^rniW be vi:v"r,,^' h- "h '"-'id- nu:u v-r'!'-;s ''nc> ?- major ci'-a1; ibaUn;; iu-
aenls 'hn^tore 01 other neural l^'V^^
,oa:ces of calcium c,Mbon,-ie. Mlip;,, .^caf^ n;h .r ImnV.dioi., or mihate pic - i-t veie to a-,5e-ia^ POM,;;,:,v to^be
ah;rriin:i, ana 1:011 n/pj'her v-.:th s:;,;1- cr«ahr --, "-^ rp'-\tp ti>'" e T ' it-n1 - r;e. ija.'j.o ivote:.s >, :./:eji .;e t;io .- TIT. :\i
.s'-.mi ere i;.-od in i!'c mannfacti.rine f'f "ri'hr'7oUri'':m<'' ]rn''t ii lorr^e-'riV1""',}! :;-r seL 1"c'tt^! ':l ''"'-1 (-/'1' '"- i"lart- :-3, n" E'.euPt .-% p.oviihil br'.--v, t,..: _ " ~ "~ " ~ sublet to the: rr j1.1.;:,-;;;, of f 11., "'; ;rl nt.
nfhod-i of ,;r. "'..-; ,Si ; fer:h ir h) C1 71 -- - f p-;;>ertv' i!".-!.! _.rd.
' --- -- -----1 - -'- rVc--".if,; e' :o ( r.--i', no.
f, ilhh^ M.|.|.-nt liiMll.ilioi.^ u"i''!'H.u--, I - - .... .--. ''< TS-;' DO
,-,.,,.-PM-.UIM:: ii- il.-ioi- of .-IHa...! " "'" "ll'J" "'"'-- :>",',''."" ',",";'' r''"'" -'
K-dncli-in ,-H.i,n;,hh- ',)\ ili<- ,i|>j,Ki - ,P.. v, '',': ;'..'. r'-.ii'f o ',- . i '(1 I R 6J h:, I e;a u.,, > li.l'T'jj
lion of lii.' ln-"t }i.,i. ti.-.diii icHiUnl -
I,-, liiii'loi;-. iirii-nlK as.ih.h..-. Eix-l;.!, r.i,..; 1 i ;, . .1 PI . :
I'tvl'.o § I!].!" S|.ii..!.iru- cf i),.'P.... '..r
r-jinv-. nun- t!u- u,-:.'..-- of cl!li:-iu '-'ha'ard Ir. a nt-.v .-on: * e .^:b .-a to tile
r.-iliKiii.n all .in.ihl,- t.. :hr ::i>;,li,-.i. n'>-, is.cn.- ot thu abparl
..
iM.-r.Nor. mav ;bnut, ^-, uk-rcc to rhp achiovabl';:
i;er;:;ial Aaa; r t:.i;or":; tu ih.? Ptato,
if t];? State h.~i tlio a;,'haii:t v U; is.-!--
NPDFS |vi:n/. :a,t fr,.:,-(1 ^plating to
the ':',':ip;np r or fr.ci':. .: , irv-i. r\l tr-^
]%!C'C -, ai-'ph--1. or or'rt." -pch fe/'to;1. : L-
lai ?
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y.i'hin t!-e nonlcnf hir.!,' suboatesory, compared to those -.ocifioci m tj.c DC- forth in 40 CJVR Pert 12fi, except th,"t,
which is a usei of a p'ibhcly ov/ned tic;'t- velopmcnt Iijctirr.ert If such fup.da- for the purpose of this section, 40 C'f/R
meat v.o:k iar,d winch ''.oiik; be a p.e'.v i.iont.'Hv different fa -r,oi.i are found to 123321, 128122, ll'fl 132, and 123 n,3
source subject to section 3C6 of the Act, if eyiM, the l!errioral -'.drum: tratir o*. tre shall not apply. 1h? foilo-.ving prctrcat-
it -.vere u> di^ohaiTO poUutprits to the Staff sbal' c-1 Vt'1'.-h for th" <:; ,chn. ~cr incnt .itTidpid e.'.-tnoh -lies ths rauintity
navigable - a*_:£> , shall b>- the 'tanak id efh.eiu hnutciicna in ' lie N; PFo p?r>i.it or quality of rcK'U'Ant; or pollutant
set foi th in JO CT'K Part 123, cxc >pt ih:>;, ei"ier more or 'o^o r.t:;p£,vit ihiu the properties c:ntro">d by fn:-, section
for th- ;>i;ipo:c of i!...- section * 128 l^ lun.it'- L'or., , ;,iabl' hod h:;;:.i, to '.h..- e-;- 7,hich m^y b? c:::chni?cd to f. ^ubhcly
of th..-. title shxli or anier/'ed to i^r.ci as tcn- du-'.,icii '»' c-acn f',ari 'ni'.-nui'lj d;f- o'vn-rd tic a tnier.c v.oilis hy a pcur.t rourcc-
' "' "" ' ferent factr-i.s f-\:ch hivi1-U.>."<, MUM b? iu'j'ect to tbe pro', .siorj, of thi, tv.l/pair.
ci.sr of btanuarijs p!o-, irh-y; foi no (! --h.->. ( bu;.;'/:-[' artcr f pph:P ti.vn of the bf'cZ auce e^t'ibh'h [ !v o U in tit;.' o: (!iK.htyof
of poi;>.tiii.i3, bt; eon?--p--.?i'?:iir.fi.7 re-; ; -iboar a e ap-
plicable to d:--t?:iri'-j,p.- -,'.v;'l:r. o ',,. ~'!'' J_1-' ' _ """_' *L"' : _1" _ ' , ' jt",;' -?,;,'^',: I'',1", ,'f l '° ;'" -'''--""' ' -i :' -
v inch taa uf"r_'t T:ie vou r.-v sub",'i' - ; 1.1.. i !,''. i - v ' ' i -i|(i. " """ '--'--!il;'A ""'.-''""'1- ' '-IL-°-'- ' i 'L ' ''
,--,,.,,., ,, ,.,----,,,,,,, ,....,.". , - . '....-. a ;iuo ic,-- . <,:;,,: :i . ,1:,, r.t n _,[ ,; :,;:> a oo
'.0.1,., ,.'-.! .i.i.U cr..u 'i, ! I.'K- f'-, ,1 jij,- i . ,, , _ __ .... n :.!.!.!> -- ! "' t:i" V o.cl ;:! o- -.--:'- .u.-" ijr 'j,. -, -irc-
L; i'>,_hc.y cvt;r, , o-^.i-i t.rit d :,' -' -h "r~7";,": inc-aa ,i r, t.) cr': i! ' >,-.,", . t; -it. -i
'i ,- . . ,.. . M
c.-;.ib':,j, ,.,>pt of ;;.-> <-" '--,>- O> ;»-- ' /o-:., a.v; ,^ :1- ,r -:-.r.' i r.:r ;:^ in ;us- ""; "-.'"'-!- :-'"^c j.l-> v ,,,..ii
i, - . - , . ' - " , , " . ,.,,.-, , . ^ , ,--^-, ,. , ,'-*,,-.< -nil. ;di ::< .%,
>-.'- i . CH .;.'.! -IV:C-T,CC o; o' i'p' ?', a^'c,0.3 i.; r .- >n.ii ,: ».i 'JK <-r -. i . . i. i..j i i-. '.
ior tli^ Ktp.tcji 'AVI i;:ji!:.-' a wi'.it.", .'"-A- io -r:t !o sf>" ". ''"] c; t>.~ ,vt, it it plicaule 11 dischai k'ef, ir-suKiii:' liO'.-i Hie
ir.r; that rucii fac'.i'i,-.- ar- or'crt ;.ot :vi- ^.''i " 'o dn.h ,r;:c pc.I'iL c;, '.-. u,? na11!- i-:"r r of ra'-ifnl; ",hich den\'cs from the
da.riHn:,x',;y dnf';ic"t for "hat f cilit.' y,'.>>le va'cio), s:ia!i 'us H.t. , ,'.i-."jrt: <:-';'> ;>'--' "c/c c/." !:rar--ir:n>:. iiic.udin.'; ro ..' ma-
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i.-ri >!' intei rra'diatc prra'a;rd.s, fira-aied .such hmrattoa , ?p».._ify other Invra- !"*<, r"i, 1S8.1'.'-', 12o 13'',
s^ad in o; f:e::v^ f;>>-n th" niantuacb!: Q ta-a-e rcr.daia and 1:'8.133 f-hr!! rot npyly The foHo-v-
1 I I > 1, li t i ', i. t . t I ' » > L L C 1 - I I 11 i [ i i I i I ~"
Ml event," ,-h'U m. an a rairfall cv.n'-, control ttchrolo.,:. cu> lertly available,
\.:th a piuba:aa i . ur'1a';c'j h/or.,a., aa defined bv the Nf,-
tior.al \Ve:u'-.". Gjivicf ai Tcchraa al .. v- - - - -,-,r^, -
Papa;' No 40, ">y.in(aH Fri queacy a'ta s ,':'"' -'''-", ".Xlt"1-',-'.'' ,",-'".' t '.a ?1!1.T> M:uu'. i Js of ,)-. r', m .r.ancr I'm-
In eatablislii i.a t :in lirn;i a,ti':):v,s ^ c r f Jr'h '. S ] 1..'? 1 i1 li'Mf^! !mu;..f>->!i >
in ciri iCciion, Li'A f',H:'-c into <]<:ccH.r t aU ri "">' cti'in^ !:ic Tib10 tri cn'l"H'r d'".i'jlr!;3 i.fia.lirn ,u),i ;iaj,i,^ '?'. ti
ana solicit"-'i'h expert \o f-if.-,i* '<
as :r/e and ,-; i' o; i^an:,, aa-,-.- :i,r.e::.i:-, '" ''""11'< -''I1 ; ''"' '|l1'
in 'iiufacta: ir:" ;-ior"-'' "% \ r ,s' i:,;*, p:.j- >;~ i Cab <:L" to llir ,;;-":
c> '1:i;v rerun' :
'''",'" " " ' " ' t'11"-1 -"' -'»-«-- Uuj {,-,_,,,_o! _,_,..- ,;a.'..niiv .",,,1; \';.::
c, . ja ' ;er >..r < ' n- : r-r-::, --1.1 ,j-:.-n
!",'. ' tb.ar fji ',>' r ub'':i j :o '.no ec;'!:,i- ijf{ ' '"" f1-'.- : .:,!-: -. . " '
in "a or :aa." :a_t , T.-.O!' :
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Teleohone No.
Contract
b. Initial star tut"1 c'a;:e
Plant Data
b. Capacity, tons or bbl/i'i:'
c. Normal yearly OTt-
Major F:r:i ;; ;;:,on r'oin-is
X i 1 n
Can your planl
Y23 NO
7. £ n o '-?. .-co j. ?, i:
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b. Csn von expand plant capacity?
Yes No
cost of coi: r.^ol
egui p~ien c. , -^tc.
production, (2)
t5Xt>~:/ic iov; of ex
ec-i :.p ..: n c , ria] funct. ' on oc coriLrj.
i'lpcic. tiing o"i (1) cunent ce:nent
"ir:;\:-~. lla tion oi new pla:ihs or
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APPE:-;:
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Plant No. 1: Enviroiinentai rsgulntia \a orr.se a -iu;ch longer lag
time i:; plant construct] oa bacaaaa c: bb,? del ays in obtain-
ing perinitc .
0 Plant cannoa axpcmb b ~a:aaa ; it ia a nca ?.t tain.aont ,:re
fugitive uuat, frc;;, a ccaapx .b-.'3 ::ji:l loads.
Plant No. 2: Plant Ccipac:1:*/ caa^ct b^ exp'ancle.d; hov/ovar, uo
e:\p3 auj'tion is cl-/an , C^har c, aiaaarb ^' aia tb;: sjiv."' as ttoa
for Plant >;o . 12 .
Plant No. 2- ba.brraaii
caused [> ")a aa '; 1
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Pi art Mo. 5: Duririg the 1 ac'i; 10 v'ea?:o, five pl.-v.it 3 (othar COT;-
panies) have boen chut djvp bocauoo of vno high ooot of
eqi.ii;>i!^,nt. needed to bring c1.cir.-\s intc, co'.;p 1 i.rince ','_'_ oh e:i-
vi.c01:11:'?;atc11 ooqiila r.iono .
PlanL !:::>, '/: Ibieo hiln.f
shuc dov/n > r: Jf;7'7 bocause of
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Complex per:nit pioooduroo rro ^.quiiod toforo cctir-3 c r:i.i'
t,ion of ct now pl-orit e,n be t-^arLod. This grao.tly
extands the tiinj J'roai -;ia tho vizaoiori of funds to piano
corrrol o o ; on ,
ify. dour of tho five n-:i!r-i 0-010 shoo ."!..;>,i\ in J'3io dooauo
of tho. cc s Ls of mosoiny oit quf.litv re._;;il,-; f Lono . The ro.-
riairMxj ki Ir. IG not prt.;oo".llv ro^O'd, o' Lhoooh it jr.oe'ts euv i
rcui -.i-'U'i ol i o.iMlo f j ono .
^ ad c I' ,1:00 in:; pncooo
,^r!^rl
-------
ardot.j,. h v--.>ve c , b^ror " rnir
_or cernenc jo.
:; M ] t \i r a 1 , ~r o a d b a s e -7 ^ ~L b:
:i, and oi:lfur scrubbing,
r.nrifieo by ri\\ ~" nor:b; .
.o~o car; D;= da'/ eloioed .
ji-.iy rar-eLci: ir ves Liiici',.:;
DC! Ii, t'i on r.arivi bs b^-/:;
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Plan:; No . !£' : a en pe;
Of COTtLrol SCfUl":
olnnt , Och^r c -,:
' '... err ,_,;-;, aj.;,; f,,; o
C! ' : ' .1 ".
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