Josef Waltisberg Eichhaldenweg 23 CH-5113 Holderbank / Switzerland josef@waltisberg.com

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USA – Limits Conversion to European Standard

Comments

Report: JW-10-07a Date: 31.01.2010

Information about New Limits in USA By mid of April 2009, USEPA has issued a proposal to amend the National Emission Standard for Hazardous Air Pollutants (NESHAP) applicable to the cement industry. The proposal includes the following emission limits:

Mercury: 43 lb/mio t cli for existing sources, and 14 lb/mio t cli for new sources (monthly average), based on continuous monitoring (CEMs). THC: 7 ppmv for existing sources, and 6 ppmv for new sources (dry, propane, 7%O2) (monthly average), based on continuous monitoring (CEMs). HCl: 2 ppmv for existing sources and 0.1 ppmv for new sources (monthly aver-age), based on continuous monitoring (CEMs). PM: 0.085 lb/t cli for existing sources, and 0.080 lb/t cli for new sources, based on either CEMs or predictive modelling (for ESPs), including mandatory installation of bag leak detectors after bagfilters. Opacity: Opacity standards to be eliminated for kilns and clinker coolers.

Further information from Holcim US:

o Rolling 30 day averages if ppm o Definition at 0 [°C], 1013 [mbar] o Tons are short tons

EPA is taking public comments on the proposal for 60 days after publication in the Federal Register. PCA has already appealed the proposal. The new rule - if agreed - would be implemented in 2013.

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1. Conversion to [mg/m3] (1013 [mbar], 0 [°C], dry) at 10 [%] Oxygen

Calculation for a modern kiln (heat consumption: 3.0 to 3.2 [MJ/kg cli]) with a specific exhaust volume of 2.0 [m3/kg cli] corresponding approximately 10 [%] oxygen. Remark: European Waste Incineration Directive (WID) 1013 [mbar], 0 [°C], dry, oxygen reference at 10 [vol%]

Limits USA Converted

to European Stan-dard

Hg 14 [lb/Mio t cli] 43 [lb/Mio t cli]

3.5 [µg/m3]

10.8 [µg/m3] THC 6 [ppm] (C3H8, 7 [%] O2)

7 [ppm] (C3H8, 7 [%] O2) 7.6 [mgC/m3] 8.9 [mgC/m3]

HCl 2 [ppmv] at 7 [%] O2 0.1 [ppm v] at 7 [%] O2

2.6 [mg/m3] 0.1(3) [mg/m3]

PM 0.085 [lb/t cli] 0.080 [lb/t cli]

21.2 [mg/m3] 20.0 [mg/m3]

2. Comments from JW 2.1 Hg

o Limit WID (European Waste Incineration Directive): 50 [µg/m3] (1013 [mbar], 0 [°C], dry, 10 [%] oxygen)

o Detection limit for Hg measurement (extractive): 3 to 6 [µg/m3] (according JW and VDZ)

o Continuous measurement: In approximately the 30 to 50 [%] of the cement plants in Europe the continuous measurement fails. Reason: Gas matrix!

2.2 THC

o VOC limit WID: 10 [mgC/m3] (Exemptions may be authorized by the com-petent authority in cases where VOC do not result from the incineration of waste)

o Detection limit for VOC measurement around 2 [mgC/m3] o More than 50 [%] of the cement kilns would exceed these proposed limits o The main source for this emission is the raw material. There is no suitable

reduction possibility for emissions between 20 and 50 [mgC/m3].

2.3 HCl o Limit WID: 10 [mg/m3] o Detection limit for hydrogen chloride (HCl) measurement (extractive):

1.5 to 2.1 [mg/m3] (according JW and VDZ) o The limits are below a realistic detection limit of an extractive standard ref-

erence method. Assuming that the continuous measurement would have a lower detection limit, the values could not be controlled.

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2.4 PM o Limit WID: 30 [mg/m3] o The problem will be the calibration of the CEMs. The USEPA methods (5,

5i) are outdated and no more suitable for such low emission levels. o The new European standard (EN-13284-1) would be suitable for measur-

ing such low concentrations but below 10 [mg/m3] the uncertainty is too great and the calibration fails, that means the calibration of the CEM can not fulfill the requirements of EN-14181 respectively the requirements of the WID.

2.5 Opacity

o It is time that the USA replaces the opacity readings in favor of a concen-tration measurement.