Cement industry readiness check for upgraded environmental regulations: final actions to implement the latest MACT, NSPS, and alternative fuels requirements

摘要

U.S. cement plants will take final actions in 2015 to upgrade compliance programs for the PC MACT rules and address the new CISWI and NHSM rules applicable to alternative fuels and raw materials (AFR). Meanwhile, there is continued work by industry and EPA to decipher and clarify final portions of each rule in order to finalize facility implementation strategies. The portland cement industry has a long and proven track record in implementing the PC MACT rules, and in using AFR for environmentally and economically beneficial reasons. As the final compliance steps are put in place, there are continuing questions on how to implement the rules while optimizing plant operations and continuing to grow AFR programs. Given that the newest regulations will change the playing field on day-to-day U.S. cement plant operations and on AFR use, there will be critical compliance and financial risk implications when making final decisions at each plant. This paper reviews final approaches for cement plant operators to consider while maximizing opportunities and reducing unintentional risks posed by the new rules. Lessons learned will be explored based on the authors' work with the PCA, individual facilities and general industry/EPA discussions.