Portland cement MACT - adopting a holistic culture of compliance

The year is 2001 and a state of the art precacliner cement kiln is commissioned. Particulate Matter (PM) stack tests from 2002 and 2007 where used as part of the EPA's PM emissions inventory in setting new regulations under the clean air act. Not only were the stack tests used, the PM results placed the plant as one of the best performing 12% ultimately used to calculate the September 2015 NESHAP standard. With new PC MACT regulations promulgated and three years to comply, the plant found itself in a situation with greater frequency of maintenance in the kiln baghouse, frequent filter bag changes and emissions which would place the plant at risk of not being compliant with the new regulations under the now stricter CPMS regime. This paper presents the case study of the plant's focus on the baghouse, including modifications to the baghouse, installation of key baghouse monitoring parameters including leak detection systems as well as the integration of this monitoring to the plant's data acquisition systems. Today the plant has significantly reduced maintenance in the baghouse, implemented a new system which allows it to efficiently and accurately pin point emissions concerns and the plant remains confidently compliant.