Tracking Three New Compounds in Cement Plants

After expanding the pending reconsideration of the Portland Cement (PC) NESHAP Risk and Technology Review (RTR), the EPA is working with the environmental testing industry to develop a test plan to collect emissions data for three pollutants:

• Hydrogen fluoride (HF)
• Hydrogen cyanide (HCN)
• Chlorine gas (Cl2)

The goal is to have an agreed-upon test plan by the end of 2021, and to begin submitting data requests to companies under Section 114 of the Clean Air Act by early 2022. This means companies have 6-12 months to collect and submit their data.

Soon, you may have to provide emission information for HF, HCN, and Cl2.

HCN and HF concentrations can be measured using Fourier transform infrared (FTIR) technology. While Montrose routinely performs FTIR testing at cement plants, these compounds are not often targeted. Chlorine can be measured with multiple test methods that generally collect an integrated sample in an alkaline solution which is sent to a laboratory and analyzed by ion chromatography.

While Cl2 cannot be detected with FTIR testing, it can be measured with several other methods including:

• EPA Method 26, Hydrogen Halide and Halogen
• EPA Method 26A, Hydrogen Halide and Halogen – Isokinetic Method
• CARB Method 434, Determination of Chlorine in Unheated Air
• EPA Method SW-846 #0050, Isokinetic HCl/Cl2 Emission Sampling Train
• EPA Method SW-846 #0051, Midget Impinger HCl/Cl2 Emission Sampling Train

For years, experts at Montrose Environmental have collected in-depth and meaningful data from cement plants across the country. With these previously performed relative accuracy test audits (RATA), we can extract HF and HCN data for these new compliance reports.

We can also perform the additional testing necessary to track Cl2, and help you reconfigure your current FTIR instrumentation. Our experts are prepared to keep you up-to-date and continuously measuring HF and HCN levels.

Learn more about the Montrose Environmental FTIR offerings and other ways our experts can help you stay compliant and sustainable by contacting us today.