CEMS Strategy for Portland Cement Maximum Achievable Control Technology (PCMACT)

This paper will discuss the strategy taken by our Company in response to the ever-changing Portland Cement National Emission Standards for Hazardous Air Pollutants (PC NESHAP), also known as the Portland Cement Maximum Achievable Control Technology (PC MACT), requirements and compliance dates. The new regulations called for continuous monitoring for mercury, particulate matter, total hydrocarbon emissions, and hydrochloric acid. The company took the strategy to install equipment in anticipation of a September 2013 compliance date and use any additional time that might become available to refine techniques. These installations were being commissioned in the fall of 2012 and early in 2013. This paper discusses the process utilized to design and install various continuous emissions monitoring systems (CEMS), lessons learned since the installations, and developments in how industry is attempting to comply with regulations where the Performance Specifications still are not fully developed, or the technology is not commercially available to demonstrate compliance