280. Can some equipment used in the production processes of cement kiln manufacturers (e.g., grinding balls, hammers, kiln chains, mill liners and lining bars, and cooler grates and side wall liners) qualify for the structural component exemption or the article exemption?
The structural exemption does not apply to these uses of toxic chemicals. EPA believes that grinding balls, hammers, kiln chains, mill liners and lining bars, and cooler grates and side wall liners are all integral components of the process activities at the facility. Therefore, these items would not be eligible for the structural component exemption.
The article exemption may apply to these items. The article exemption is meant for the processing or otherwise use of manufactured items that: are formed to a specific shape or design during manufacture; have end use functions dependent in whole or in part upon its shape or design and do not release a toxic chemical under normal conditions of processing or use of that item at the facility (February 16, 1988; 53 FR 4507). The grinding balls, hammers, kiln chains, mill liners and lifting bars, and cooler grates and side wall liners are being otherwise used by the facility. Therefore, if these pieces of equipment meet the three criteria above throughout their use during the calendar year, the exemption may be taken.