In most areas of the U.S., it appears that the recession is a bad memory and the signs of recovery are all around us. As described by the Portland Cement Association (PCA) on its website, “following the strongest cement consumption gains in seven (7) years in 2012, cement consumption growth will continue in 2013 with a 6.2% increase.” PCA continues to explain that “the accelerated consumption predicted during the second half of 2013 should carry into the following year, with an increase of 9.2% for 2014.” PCA also upwardly revised its long-range projections for 2015-2017, with annual growth during that period expected to be as high as 11.1%. PCA predicts cement consumption levels will reach 120 million metric tons by 2017.
With this good news for U.S. cement plants, as well as similar projects across key construction sectors, the cement industry will need to balance this growth with challenging air quality requirements. A given cement manufacturing process can simultaneously be subject to multiple air quality regulations with varying requirements and compliance deadlines. Specifically, these requirements include the National Emission Standards for Hazardous Air Pollutants (NESHAPs) for the Portland Cement Manufacturing Industry (40 CFR Part 63, Subpart LLL; “PC MACT”); the Commercial and Industrial Solid waste Incinerator (CISWI) Rule (40 CFR Parts 60, Subparts CCCC or DDDD), the NESHAP for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR Part 63, Subpart DDDDD, “Boiler MACT”), and New Source Performance Standards (NSPS) for Portland Cement Plants (40 CFR Part 60, Subpart F). Since both CISWI and Boiler MACT have been given an enormous amount of attention in 2013, in this article we will explore PC MACT in some more detail and then discuss the relationship between these separate but inexorably connected rules.