Cement Industry Readiness Check for Upgraded Environmental Regulations: Final Actions to Implement the Latest MACT, NSPS, and Alternative Fuel Requirements

As the rulemaking compliance dates come further into effect in 2015, U.S. cement plants will take final actions to upgrade compliance programs for the National Emission Standards for Portland Cement Manufacturing [also known as the Portland Cement Maximum Achievable Control Technology (PC MACT)]. For those facilities using alternative fuels and possibly raw materials, past practices will also require altering to address the non-hazardous secondary material (NHSM) and Commercial and Industrial Solid Waste Incineration (CISWI) rules. Meanwhile, there is continued work by the industry and the U.S. Environmental Protection Agency (EPA) to decipher and clarify final implementation steps of each rule and, in particular, to address the question of “what is a waste,” which drives facility implementation strategies. The Portland cement industry has a long and proven track record in historically implementing the PC MACT rules and in using alternative fuels and raw materials (AFR) for a variety of environmentally and economically beneficial reasons. As the final compliance steps are put in place, there are continuing questions on how the new rules will be successfully implemented, while optimizing plant operations and continuing to grow the important AFR programs. Given that this suite of regulations will forever change the playing field on day-to-day operations, and the historic use of AFR in cement plants in the U.S., there will be critical compliance and financial risk implications on how to best manage final decisions. This paper reviews final approaches for cement plant operators to maximize opportunities and reduce unintentional risks posed by the new rules, by exploring the lessons learned on implementing PC MACT, CISWI, and NHSM rules based on the authors' work with the Portland Cement Association, individual facilities, and general industry/EPA discussions.