Comments Come in for Portland Cement NESHAP
In response to the U.S. Environmental Protection Agency's proposed amendments to the national emission standard for hazardous air pollutants (NESHAP) for the portland cement manufacturing industry, the Portland Cement Association (PCA) and the League of Women Voters (LWV) in Texas had a few things to say.
Such a regulation, which requires new emission standards for mercury, total hydrocarbons, hydrochloric acid, and particulate matter, undermines the balance between environmental protection and economic viability, according to PCA statements.
"Pushing cement production to other countries would 'OPEC' the industry and make the U.S. dependent on cement imports," says Andy O'Hare, PCA vice president for regulatory affairs. "In addition, because these countries have fewer regulations global emissions of mercury and carbon dioxide could actually increase."
U.S. cement production and its related industries employ tens of thousands of Americans and produce an essential part of infrastructure construction projects identified by the Obama administration and Congress. To meet expected demand, the United States will need to produce 30 percent more cement by 2020.
"If this rule is adopted, domestic cement supply will be constrained and investments in cement capacity expansion avoided, causing the stimulus package to advance fewer projects with less jobs created," O'Hare said. "A reasonable rule—building on the good record of current regulatory programs and setting achievable standards based on demonstrated achieved emissions control strategies—would not act at cross-purposes to economic recovery."
"The cement industry takes its environmental performance seriously," O'Hare said. "During the last decade, cement plants have successful addressed the rising demand for portland cement while developing and implementing environmentally and socially responsible business practices. The industry has invested in technology to reduce air emissions, minimize waste production, recycle and recover inputs, enhance energy efficiency, and conserve natural resources—all the while producing a reliable and affordable supply of building materials to support our economy."
Mary G. Wilson, president of the LWV of the United States, and Karen Nicholson, president of the LWV of Texas, submitted comments in support of proposed regulations to limit cement kiln air emissions.
According to LWV, 11 of the 93 cement manufacturing facilities in the United States. are located in Texas, and the Texas facilities are some of the nation's largest. Eight are arrayed along the limestone deposits of the Interstate 35 corridor, which extends north-to-south between Midlothian and San Antonio. Estimated 2008 population in the area impacted by the 11 kilns was almost 11 million, nearly 44 percent of the Texas populace.
"Midlothian, Texas, in the Dallas-Fort Worth Consolidated Metropolitan Area, has the largest concentration of cement plants in the United States. The Midlothian cement kilns are also the largest stationary source of air pollution in the Dallas-Fort Worth area," said Nicholson. She added, "Thus, the proposed emission standards would greatly enhance the region's ability to meet air quality standards."
"The proposals appear to treat the industry reasonably since they do not require pollution limits below what some plants already meet and don't go into effect until 2013," Wilson said.
LWV supports the following:
- continuous emissions monitors (CEMS) for mercury emissions,
- emission standards for startup, shutdown, and malfunction equal to normal operating conditions,
- monitoring and capping mercury pollution at 43 pounds per million tons of clinker for existing plants and 14 pounds per million for new plants,
- limits of 0.085 pounds of particulate matter per ton of clinker for existing sources and 0.080 lb/ton clinker for new sources for cement kilns or cement kilns/in-line raw mills,
- limits of 2 ppmv of hydrochloric acid for existing sources and 0.1 ppmv for new sources for cement kilns or cement kilns/inline raw mills,
- limits of 7 ppmv of total hydrocarbons for existing sources and 6 ppmv for new sources for raw material driers.
LWV noted that in 2007 Texas cement kilns reported emitting 446 pounds of mercury, 313 pounds of which were emitted by the two facilities in New Braunfels. The Texas Commission on Environmental Quality recently approved permits that would allow these two plants to double their capacity.