KA 860_19_01 October 7, 2019
Via email and hardcopy
Mailing: Post Office Box 5127 Gainesville, FL 32627-5127 Physical: 4014 NW 13th Street Gainesville, FL 32609-1923 www.kooglerassociates.com 352.377.5822
Eric Cornwell Manager, Stationary Source Permitting Program Air Protection Branch, Georgia EPD 4244 International Parkway Suite 120 Atlanta 30354 [email protected]
Subject: Submittal for Air Permit Application US Cement, LLC Proposed new cement facility at Houston County, Georgia
Dear Mr. Cornwell,
US Cement, LLC (US Cement) is proposing to construct a new Portland cement facility in Houston County, Georgia. Attached to this letter is the air permit application report prepared by Koogler and Associates, Inc. (Koogler) on behalf of US Cement.
In addition to an electronic copy of the report in pdf and its excel spreadsheet attachments, we are submitting two hardcopies of the same to the address below:
Stationary Source Permitting Program 4244 International Parkway, Suite 120 Atlanta, Georgia 30354
On behalf of US Cement, I sincerely appreciate your attention to this project. Please contact me at (352) 377-5822 or [email protected] if you have any questions regarding this project.
Regards,
Max Lee, PhD., P.E. KOOGLER AND ASSOCIATES, INC.
cc: Cary Cohrs, US Cement, LLC, [email protected] Byeong Kim, Georgia EPD, [email protected] James Boylan, Georgia EPD, [email protected] John Koogler, Koogler & Associates, Inc., [email protected] Upasna Rai, Koogler & Associates, Inc., [email protected]
Enc: Application Report (pdf) Electronic file to Report - Attachment F: Facility Modeling Inventory (Excel) Electronic file to Report - Attachment G: Facility Emissions Summary (Excel) REPORT IN SUPPORT OF AN APPLICATION FOR A PSD CONSTRUCTION PERMIT REVIEW
U. S. CEMENT COMPANY Cement Plant Perry, Houston County, Georgia
October 7, 2019
Prepared by Koogler and Associates, Inc. 4014 NW 13th St Gainesville, FL 32609 www.kooglerassociates.com 860_19_01
TABLE OF CONTENTS 1. INTRODUCTION ...... 1
1.1 APPLICANT ...... 2 1.2 AREA MAP SHOWING FACILITY LOCATION ...... 2 2. DESCRIPTION OF PROPOSED CONSTRUCTION ...... 4
2.1 PROPOSED EMISSIONS UNITS ...... 4 2.1.1 Raw Material Quarrying, Crushing and Storage (emission unit K101) ...... 4 2.1.2 Raw Materials Conveying, Storage and Processing (K102) ...... 5 2.1.3 Pyroprocessing System (K103) ...... 6 2.1.4 Clinker and Additives Storage and Handling (K104) ...... 10 2.1.5 Cement Finish Mill (K105) ...... 11 2.1.6 Cement Handling, Storage, Packing and Loadout (K106) ...... 11 2.1.7 Coal and Petroleum Coke Grinding System (K107) ...... 12 2.1.8 Stationary Emergency Generators CI RICE (K108) ...... 12 2.2 FUGITIVE EMISSIONS ...... 12 2.3 PRECAUTIONS TO PREVENT EMISSIONS OF UNCONFINED PARTICULATE MATTER ...... 13 2.4 FACILITY PLOT PLAN ...... 14 2.5 PROCESS FLOW DIAGRAM ...... 14 2.6 FUEL ANALYSIS OR SPECIFICATION ...... 17 2.7 DESCRIPTION OF CONTROL EQUIPMENT ...... 17 2.7.1 PM/PM10 ...... 17 2.7.2 NOx ...... 17 2.7.3 Dioxin/furan ...... 17 2.7.4 Mercury ...... 17 2.7.5 SO2, CO, VOC/THC and HCl ...... 18 2.7.6 Pollution Control Equipment – Ad Valorem ...... 18 2.8 DESCRIPTION OF STACK SAMPLING FACILITIES ...... 18 3. RULE APPLICABILITY ANALYSIS ...... 18
3.1 APPLICABLE FEDERAL AND STATE REQUIREMENTS ...... 19 3.2 RULE 391-3-1-.03 – PERMITS ...... 20 3.2.1 Rule 391-3-1-.03(1) – Construction (SIP) Permit ...... 20 3.2.2 Rule 391-3-1-.03(8) – Permit Requirements ...... 21 3.3 RULE 391-3-1-.02(7) – PREVENTION OF SIGNIFICANT DETERIORATION ...... 21 3.3.1 Rule 391-3-1-.02(7)(b) – PSD Standards ...... 21 3.3.2 Rule 391-3-1-.03(6) – Exemptions ...... 24 3.3.3 Rule 391-3-1-.02(7)(a)4.(viii) – Federal Land Manager ...... 25 3.3.4 Rule 391-3-1-.02(7)(b)7. – Best Available Control Technology ...... 27 4. AMBIENT IMPACT ANALYSIS ...... 28 5. ADDITIONAL IMPACT ANALYSES ...... 29 6. BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS ...... 30
6.1 INTRODUCTION ...... 30 6.2 PARTICULATE MATTER (PM10/PM2.5) ...... 32 6.2.1. Proposed BACT ...... 33 6.2.2. Federal Regulations Limiting PM/PM10/PM2.5 Emission Rates and Recent BACT Determinations .... 34
i 6.2.3. Particulate Matter Sources ...... 38 6.2.4. Description of Particulate Matter Control Technologies ...... 38 6.2.5. Particulate Matter BACT Selection ...... 41 6.2.6. Summary ...... 43 6.3 SULFUR DIOXIDE ...... 43 6.3.1. Proposed BACT ...... 44 6.3.2. Federal Regulations Limiting SO2 Emission Rates and Recent BACT Determinations ...... 45 6.3.3. Sulfur Behavior in Dry-process Pyroprocessing Systems ...... 47 6.3.4. Description of SO2 Control Technologies ...... 51 6.3.5. SO2 Control ...... 53 6.3.6. Summary ...... 59 6.4 NITROGEN OXIDES ...... 59 6.4.1. Proposed BACT ...... 60 6.4.2. Federal Regulations Limiting NOx Emission Rates and Recent BACT Determinations ...... 60 6.4.3. Sources of NOx in Portland Cement Plants ...... 62 6.4.4. Description of NOx Control Technologies ...... 64 6.4.5. NOx BACT Selection ...... 80 6.5 CARBON MONOXIDE ...... 81 6.5.1 Proposed BACT ...... 81 6.5.2 Federal Regulations Limiting CO Emission Rates and Recent BACT Determinations ...... 81 6.5.3 Sources of CO in Portland Cement Plants ...... 84 6.5.4 Description of CO Control Technologies ...... 87 6.5.5 CO BACT Selection ...... 88 6.6 VOLATILE ORGANIC COMPOUNDS ...... 89 6.6.1 Proposed BACT ...... 89 6.6.2 Federal Regulations Limiting THC/VOC Emission Rates and Recent BACT Determinations ...... 90 6.6.3 Sources of THC/VOC in Portland Cement Plants ...... 92 6.6.4 Description of THC/VOC Control Technologies ...... 93 6.6.5 THC/VOC BACT Selection ...... 94 6.7 GREENHOUSE GASES...... 94 6.7.1 Description of Greenhouse Gases Control Technologies ...... 96 6.7.2 Recent BACT Determinations ...... 97 6.7.3 Proposed BACT ...... 99 6.8 MERCURY ...... 99 7. CONCLUSIONS ...... 100
ii TABLE OF TABLES TABLE 1. REGULATED AIR POLLUTANT SIGNIFICANT EMISSION RATES ...... 23 TABLE 2. PROPOSED REGULATED POLLUTANTS KILN SYSTEM LIMITS ...... 32 TABLE 3. FEDERAL PARTICULATE MATTER EMISSION LIMITING STANDARDS POTENTIALLY APPLICABLE TO US CEMENT ...... 35 TABLE 4. SUMMARY OF AVAILABLE PARTICULATE MATTER CONTROL TECHNOLOGIES AND ASSOCIATED CONTROL EFFICIENCY AND TECHNICAL FEASIBILITY ...... 39 TABLE 5. KILN SPECIFIC PM EMISSION LIMIT FROM 40 CFR 63, SUBPART LLL ...... 41 TABLE 6. EMISSION POINT PARAMETERS FOR PM CONTROL BY FABRIC FILTER DUST COLLECTORS ...... 42 TABLE 7. FEDERAL SO2 EMISSION LIMITING STANDARDS POTENTIALLY APPLICABLE TO US CEMENT ...... 45 TABLE 8. CAPTURE EFFICIENCY OF FUEL SO2 IN DRY PROCESS FLORIDA PORTLAND CEMENT PLANTS ...... 49 TABLE 9. SUMMARY OF AVAILABLE SO2 CONTROL TECHNOLOGIES AND ASSOCIATED CONTROL EFFICIENCY AND TECHNICAL FEASIBILITY ...... 51 TABLE 10. EXPECTED MAGNITUDE AND RANGE OF SO2 EMISSIONS FROM US CEMENT KILN ...... 53 TABLE 11. SUMMARY OF SO2 CONTROL EFFECTIVENESS AND COST ...... 58 TABLE 12. FEDERAL NOX EMISSION LIMITING STANDARDS POTENTIALLY APPLICABLE TO US CEMENT ...... 60 TABLE 13. SUMMARY OF AVAILABLE NOX CONTROL TECHNOLOGIES AND ASSOCIATED CONTROL EFFICIENCY AND TECHNICAL FEASIBILITY ...... 64 TABLE 14. FEDERAL REGULATIONS REGULATING CO EMISSIONS FROM PORTLAND CEMENT PLANTS ...... 82 TABLE 15. FEDERAL REGULATIONS REGULATING THC/VOC EMISSIONS FROM PORTLAND CEMENT PLANTS 90
TABLE OF FIGURES FIGURE 1. SITE LOCATION MAP ...... 3 FIGURE 2. CEMENT PLANT GENERAL LAYOUT AND PROPERTY BOUNDARY ...... 3 FIGURE 3. FACILITY PLOT PLAN ...... 14 FIGURE 4. PROCESS FLOW DIAGRAM FOR PORTLAND CEMENT MANUFACTURING ...... 16 FIGURE 5. SO2 CONTROL EFFICIENCIES FOR VARIOUS CONTROL TECHNOLOGIES ...... 56 FIGURE 6. CONCEPTUAL DESIGN OF PROPOSED US CEMENT CALCINER ...... 67 FIGURE 7. EFFECT OF TEMPERATURE ON NOX REDUCTION FOR AMMONIA AND UREA ...... 73 FIGURE 8. EFFECT OF TEMPERATURE ON EFFECTIVENESS OF SNCR AMMONIA INJECTION ...... 74 FIGURE 9. TYPICAL RANGES OF NOX REDUCTION WITH SNCR ...... 76
TABLE OF ATTACHMENTS Attachment A: SIP Forms Attachment B: Process Flow Diagrams Attachment C: Federal Rule Analysis Tables Attachment D: List of Permits Attachment E: Title V Permit Example Attachment F: Facility Modeling Inventory Attachment G: Facility Emissions Summary Attachment H: EPA White Paper on GHG BACT
iii 1. Introduction This report is in support of an application for an air construction permit. US Cement is proposing to construct a modern grass-roots dry-process Portland cement plant at a site northeast of Clinchfield, Houston County, Georgia. The plant will be rated at 1.1 million tons per year of clinker. The proposed facility will be located approximately one mile east of State Road 247 at a point approximately 0.7 miles northeasterly of the intersection of State Road 247 and US Highway 341. The UTM coordinates of the Main Stack are zone 17 N, 253.498 kilometers East and 3591.602 kilometers North.
The cement plant property consists of approximately 120 acres of which 70 acres of the property are used for cement plant operations. The adjacent quarry occupies approximately 1946 acres. These two parcels will be connected by a swath of land approximately 200 feet wide and 4100 feet long connecting the cement plant and quarry. The connecting parcel will allow for a conveyor system to transport material from the quarry to the cement plant. The quarry will be mined in accordance with a mining plan that will have only a portion of the quarry property being actively mined at any one time. The cement plant will have a dry process preheater/precalciner kiln system and will produce various types and grades of Portland cement and masonry cement. The cement will be stored in silos, will be shipped in bulk by rail and trucks, and will be bagged and palletized for shipping by trucks.
U.S. Cement is asserting that the kiln will be subject to EPA rules for cement plants under National Emissions Standards for Hazardous Air Pollutants (NESHAP), Subpart LLL (LLL). Because of this overarching rule on the cement plant, many of the definitions that US Cement will adhere to in this permitting are requested to be as stated in LLL rule and apply for a broader scope of application, including BACT applicable requirements. For example, the definition of the clinker production limit established through BACT, would apply for the short-term limit the definition of a 30-day rolling average, where 30 day rolling average, operating day and rolling average are defined in 40 CFR 63.1341. This consistency of definition streamlines the plant operations for air permitting compliance and minimizes misunderstandings of applicable terms in the permits.
Attachments to this report include the GaEPD SIP Forms in Attachment A, completed and signed by the applicant. The process flow diagrams of the operations at current level of design are provided and marked to show the breakdown of each emissions unit on the diagrams with stack and air pollution control devices identified in Attachment B. Attachment C includes tables of each applicable Federal rule analyzed for each emissions unit. For example, a portion of the kiln gas (approximately three percent) sweeps the coal mill, and therefore the coal mill emissions are subject not only to NSPS, Subpart Y, but also NSPS, Subpart F and NESHAP, Subpart LLL. Attachment D includes a list of permits (as required on SIPform100) expected to be obtained for the US Cement facility. Attachment E includes an example of a desired Title V permit for a similar facility, Suwannee American Cement company, Sumterville, Florida. Notably the format has an
1 effective layout for the cement plant to be subject to either NESHAP Subpart LLL or NSPS Subpart CCCC. US Cement desires to have the air construction permit and the TV permit in a similar format to allow the functional permitting to address both of these rules as they may apply to US Cement in the future. Attachment F includes the facility modeling sources and buildings as expected to apply for PSD modeling. As discussed with GaEPD staff, PSD modeling has been internally conducted based on proposed pollutant limits. However, US Cement desires to come to agreement with GaEPD permitting on pollutant limits through this application prior to submittal of the formal PSD modeling results. Attachment G includes the facility emissions summary for pollutants based on BACT and rule analysis, including proposed GaEPD toxic air pollutants to be applied for TAP modeling. Attachment H includes the EPA white paper for GHG BACT on Portland cement plants to accompany the GHG BACT analysis provided herein.
1.1 Applicant Cary Cohrs, President U.S. Cement, LLC PO Box 673541 Marietta, GA. 30006 [email protected]
1.2 Area Map Showing Facility Location This report provides the topographic map showing the boundaries of the properties and location of the proposed facility in relation to residences, commercial/industrial activities roads, and other features of the surrounding area.
The cement plant will be located about 1.5 miles northeast of Clinchfield, GA and south of A.E. Harris Road (Figure 1). The UTM coordinates of the northwest corner of the cement plant property are Zone 17, 253.45 km East and 3591.2 km North. A property boundary drawing follows the site location map (Figure 2).
2 Figure 1. Site Location Map
PROPOSED PLANT LOCATION
Figure 2. Cement Plant general layout and Property Boundary
3 2. Description of Proposed Construction This section of the report provides a detailed description of the proposed construction project. Each emissions unit and pertinent equipment is reviewed for applicable Federal and State rules in Section 3.
2.1 Proposed Emissions Units This section includes a description of the nature, location, design capacity, and projected operations of each proposed emissions unit. US Cement proposes to have eight emission units. This is a similar number of emissions units as many recently permitted similar cement plants (e.g., Sumterville, Florida).
Each emission unit is described below for functional purpose and significant equipment related to this permit.
The facility is proposed to have a permitted limit on clinker production of 1.1 mmton/yr (12-month rolling total) and 140 tph (30 day rolling average, where 30 day rolling average, operating day and rolling average are defined in LLL rule, 40 CFR 63.1341). Due to the fact that all operations upstream and downstream of the kiln are constrained by the kiln’s clinker production, it is proposed that the clinker production limits will ensure adequate reasonable constrained production/processing limits upstream and downstream of the kiln producing clinker. Note that the design operations rates are not all proposed to be permitted limits as certain production limits are redundant given the clinker production constraint. All proposed design operating rates discussed below are related to the proposed permit limit on clinker production of 140 tph (30 day rolling average) and 1.1 mmton/yr. All emissions units are requested to have unlimited hours of operation per year (8760 hr/yr) and all process/production rates are expressed in units of short times per unit of time.
For a detailed understanding of the emission units described in this section, and the interaction of emission units with one another, referred to the Process Flow Diagrams included as Attachment B of this application report.
2.1.1 Raw Material Quarrying, Crushing and Storage (emission unit K101) This emission unit includes raw material (limestone and overburden) processing from the quarry up to raw material storage. This emissions unit also addresses raw material additives handling and storage, from the point of delivery at the property entrance to storage. FThe additives include, but are not limited to, iron oxide components (e.g., mill scale), and flyash. Dozens of suitable materials are available as suitable additives for cement manufacturing and could be used by US Cement. The use of alternative additive raw materials will have no effect on fugitive emissions associated with the delivery and storage of the materials or on emissions from the pyroprocessing system as a result of using alternative materials. The quarry includes blasting operations, truck upload of
4 mined material to a primary crusher with a design rate of 2000 tph. The crusher will crush material to a desired size of 3-inch minus. The crushed material will travel by conveyor from the crusher on three sets of conveyors to the raw material storage building.
All of the emissions from this emission unit are fugitive emissions; fugitive PM10 and PM2.5 emissions. The emission points include the loading and unloading of off-road haul trucks transporting the mined limestone and overburden from the active quarry area to the primary crusher located in the quarry; off-road truck travel within the quarry; the primary crushing of limestone (to minus 3 inch); and the conveying of the crushed limestone from the crusher to the raw material storage area at the plant site. The fugitive emissions from this emission unit also include truck travel within the plant site associated with the delivery of the additive raw materials.
Equipment includes a primary crusher at the quarry, and two raw materials storage buildings (RMS) at the cement plant. Belt conveyors (Belts BC-1, BC-2, and BC-3) convey the crushed limestone between the quarry crusher and the RMS. Raw material piles created via a Tripper Belt and stored inside of the RMS include limestone, alumina sources (e.g., bauxite, clay and coal ash), iron oxide components (e.g., mill scale and iron ore), silica sources (e.g., sand), and additives. Other materials handling equipment includes harrow and portal reclaimers, stackers, hoppers, belt conveyors, a conveyor from the RMS to the raw mill, and quality a control system/analyzer.
2.1.2 Raw Materials Conveying, Storage and Processing (K102) This emissions unit includes activities between raw material and additive storage up to, but not including the preheater (including conveyance of raw materials and raw meal to the raw mill, and the conveyance of the raw meal to the homogenizing silo). Equipment includes the raw mill with a raw material grinding rate of 300 tons per hour, the homogenizing silo (nominal 10,000 ton capacity) and the associated transport system.
The raw mill receives raw material and additives from the raw materials storage building where they are ground to a cut size of approximately 100 micrometers and combined with the dust blown back from the preheater (approximately 10 percent of the preheater feed). The dust blown back from the preheater consists of both raw meal and partially calcined materials from the kiln, calciner and lower sections of the preheater. The product of the raw mill is referred to as raw meal; the kiln feed.
Heat for raw material drying will be provided by the preheater exhaust gases and as necessary, by a natural gas fired hot gas generator with a design heat input rate of 43 MMBtu per hour. Propane and low-sulfur distillate fuel oil will be alternative fuels for the hot gas generator.
The hot gas generator included in this emission unit is for use when additional raw material drying capacity is required. Emissions from the hot gas generator and raw mill are addressed with the
5 Pyroprocessing System emissions unit (K103) as all emissions from the raw mill and hot gas generator discharge through the main kiln stack.
The majority of the raw meal leaving the raw mill (90+ percent) will be recovered in high efficiency cyclones following the raw mill and pneumatically transferred to a 10,000 ton homogenizing silo. The residual raw meal (<10 percent) will be recovered in the main kiln baghouse and transferred to a Filter Dust Surge Bin. From the surge bin, the filter dust will either be transferred to the homogenizing silo to be recycled back to the preheater, or it will be transferred to the cement finish mill in a process referred to as “Dust Shuttling”.
The purpose of dust shuttling is to control mercury emissions from the pyroprocessing system. The principle behind dust shuttling is the removal of filter dust (dust from the main kiln baghouse), which has relatively high concentrations of mercury, from the pyroprocessing system and the delivery of the dust to the cement finish mill where it will become a component of the finished cement product. As the cement is used for its intended purpose, the mercury will be sequestered and effectively removed from the environment. This dust shuttling breaks the mercury cycle within the pyroprocessing system by removing mercury that would otherwise continue to recycle within the system.
There are four baghouses that vent from this emissions unit. These baghouses are listed in the SIP form300 as, CD01-CD04. While this system includes a 43 MMBtu/hour, natural gas fired hot gas generator air heater for use when additional raw material drying capacity is required, emissions from the hot gas generator are vented to the main Kiln/Clinker Cooler baghouse. The raw mill will also exhaust through this baghouse. Therefore, the raw mill hot gas generator emissions and the raw mill material grinding emissions are addressed within the pyroprocessing system emission unit (K103).
This emissions unit will be located between the raw materials storage area and the preheater of the pyroprocessing system. The design operating rate of the raw material to the raw mill is 300 tons per hour, with a design maximum operating schedule of 8760 hours/year. The design rate of 300 tons per hour will allow for raw mill down time with continued kiln operation. Raw mills typically experience 10 to 15 percent down time annually for general maintenance and repair.
2.1.3 Pyroprocessing System (K103) This emissions unit is the defining section of the cement plant. The unit includes, the Preheater, Calciner Kiln and Clinker Cooler; i.e., equipment from the preheater through the clinker cooler discharge. The purpose of the pyroprocessing system is to convert raw material into clinker, and it is the clinker production capacity that defines the cement plant. All raw material and additive handling and processing upstream of the pyroprocessing system; the heat input rate (fuel consumption) to the kiln and calciner burners; and all cement production, cement handling,
6 packing and shipping downstream of the pyroprocessing system is dependent upon the clinker production rate.
The emissions from the Pyroprocessing System exhaust through the main kiln baghouse and stack. These emissions include the following: • All combustion related emissions from the kiln and calciner burners, • Calcined and partially calcined particulate matter from the pyroprocessing system, • Approximately 10 percent of the raw meal fed to the preheater that is blown back, • Particulate matter emissions from the clinker cooler, • Combustion emissions from the raw mill hot gas generator, and • Particulate matter emissions from the raw mill.
The relationship between these gas streams is summarized here and discussed in detail in the following paragraphs. The gases exiting the kiln pass through the calciner where a fraction of the clinker cooler exhaust is introduced as hot combustion air. These gases continue through the four stages of the preheater where the raw meal is heated prior to entering the calciner. The gas stream exiting the preheater is at a temperature of approximately 400C and contains 2-3 percent oxygen.
This gas stream continues through the downcomer which includes a gas conditioning tower (with water sprays) to the kiln ID fan. On the exhaust side of the ID fan approximately three percent of this gas stream is extracted and ducted to the coal mill to dry the coal (or petroleum coke) during grinding. Because of the use of kiln exhaust gas in the coal mill, the coal mill exhaust gas is subject to the requirements of NESHAP or CISWI rules as well as to the rules of 40 CFR 60, Subpart Y.
The major remaining fraction of the kiln exhaust gas continues onto the raw mill where it is used to heat and dry the raw materials during grinding. If additional drying capacity is required, the raw mill hot gas generator is used and emissions from this unit are combined with the kiln exhaust gas. The clinker cooler exhaust gas is also introduced to this exhaust system upstream of the raw mill.
When the raw mill is operating, the hot gases from the kiln, clinker cooler and hot gas generator pass through the raw mill, through product recovery cyclones, through the main kiln baghouse, and are discharged to the atmosphere through the main stack. In passing through the raw mill, the hot gases are quenched quickly and efficiently through the approximate temperature window 400C - 230C. As a result of this, the formation of dioxins and furans is essentially eliminated.
When the raw mill is not operating, the hot gases from the kiln/calciner leaving the preheater (at approximately 400C) pass through the gas conditioning tower in the downcomer and are quenched by water spray through the approximate temperature window 400C - 230C to prevent the formation of dioxins and furans. From this point, the kiln/calciner exhaust gases bypass the
7 raw mill, combine with the clinker cooler exhaust gas which also bypasses the raw mill, and discharge through the main kiln baghouse and main stack.
The details of the pyroprocessing system responsible for generating the gas streams just discussed are described in the following paragraphs.
The raw meal from the homogenizing silo is pneumatically conveyed to the four-stage preheater. As the raw meal passes through the preheater it will be preheated and partially calcined prior to entering the calciner. In the in-line calciner, calcination of the raw meal will be completed at temperatures between 950-1100C, and the raw meal will discharge into the kiln. In the kiln, the raw meal will be converted to clinker (gray, glass-hard, spherically shaped nodules) at material temperatures between 1450-1550C (gas temperature of approximately 1700C). Upon discharge from the kiln, the clinker will be quenched in a reciprocating grate cooler with flow control grates and conveyed to the next emission unit; clinker storage silos. The hot air discharge from the clinker cooler is split with fractions used as hot combustion air for the main kiln burner and the calciner burner system and the remaining fraction combining with the kiln/calciner exhaust gas upstream of the raw mill.
The design capacity of the pyroprocessing system is 1.1 million tons (mmton) per year of clinker and a design peak production rate of 140 tons per hour of clinker (30-kiln operating day rolling average). The design operating schedule is 8760 hours/year. These design rates are requested to be enforceable permit limits. The peak design rate of 140 ton/hr (30-kiln operating day rolling average) is 12 percent greater than the annual limit to allow periods of operational downtime, but still allow the kiln system to achieve its 12-month rolling production rate of 1.1 mmton/yr.
Fuels will be burned in the calciner burner system and at the main burner at the discharge end of the kiln. For the purpose of energy efficiency, hot combustion air for the calciner burner system will be provided through a tertiary air (TA) duct from the clinker cooler. The design heat input rate to the kiln/calciner system is 400 million Btu/hr; with nominally 45 percent of the heat input provided at the main kiln burner and 55 percent of the heat input provided through the calciner burner. This heat input rate should not be a permit limit however, because heat input is a dominant cost of cement production. As such, the heat input rate (fuel usage) will inherently be minimized which ensures maximizing while minimizing fuel usage.
The efficiency of this new modern kiln is measured by the amount of heat required to produce a ton of clinker; nominally 2.6-2.8 million BTU per ton clinker. Furthermore, unlike a typical combustor, the fuel composition does not correlate directly with pollutant emissions, but instead is dependent on the kiln operation and design. For example, and as discussed in the BACT analysis of Section 6, sulfur in fuel does not correlate to SO2 emissions due to the thermochemistry of fuel combustion required for the clinkering process. Instead, SO2 correlates to raw material sulfites (see
8 SO2 BACT analysis for more details). For these reasons, it is requested that neither the heat input rate nor the fuel feed rate be limited, as the clinker production limits will adequately limit heat input and fuel use.
Proposed fuels in the kiln/calciner system include the following: a. coal b. petroleum coke c. natural gas d. propane e. virgin fuel oil (No. 2 and No. 4) f. on-specification used fuel oil g. off-specification used fuel oil h. tire-derived fuel i. plastics j. roofing materials k. agricultural biogenic materials l. cellulosic biomass m. carpet-derived fuel n. alternative fuel mix o. biosolids; and/or p. engineered fuel
It should be noted that emissions from the pyroprocessing system are independent of the type of fuel used in the main burner and the calciner burner.
In addition to fuels fired to the kiln and calciner burners, up to 43 million BTU per hour of fuel will be fired, as needed, in the raw mill hot gas generator when additional material drying capacity is necessary. This is as discussed in Section 2.1.2, above. During normal operation of the kiln system, with expected moisture conditions of raw materials, the hot gas generator should not be required. Proposed fuels in the raw mill hot gas generator include the following: a. natural gas b. propane c. virgin fuel oil (No. 2 and No. 4) d. on-specification used fuel oil
Another air pollutant associated with the pyroprocessing system that requires attention is mercury. Mercury is input to the pyroprocessing system as a minor component of raw materials and fuels (primarily coal). Because of the thermochemistry of the pyroprocessing system, essentially no mercury leaves the system in clinker. The mercury in fuels fired to the pyroprocessing system are
9 volatilized and exit the system through the gases exhausted from the preheater. Mercury introduced in raw materials is likewise volatilized in the preheater and is exhausted.
When the volatilized mercury reaches the raw mill, and gas and material temperatures drop below approximately 150C, the mercury will condense on available particulate matter; or on activated carbon if activated carbon is injected for purposes of mercury control. If the gas/material temperatures at the raw mill and in the main kiln baghouse rise sufficiently above 150C, a fraction of the mercury will remain in a volatile form and will be discharged to the atmosphere.
On the other hand, if temperatures remain below approximately 150C, the mercury will remain adsorbed in the raw meal and main baghouse filter dust and recirculated through the homogenizing silo back to the preheater where it will continue to recycle within the pyroprocessing system.
This mercury recycle loop can be broken by removing a fraction of the filter dust (most effectively and efficiently when the raw mill is not operating) and transferring this filter dust to the cement finish mill where it can become part of the finished cement product and sequestered when the cement is used for its intended final purpose. This is the process referred to as “dust shuttling” as discussed previously in this report.
2.1.4 Clinker and Additives Storage and Handling (K104) This emissions unit includes clinker transport from the clinker cooler to the clinker silos, the discharge of clinker into the two clinker silos and the extraction of clinker from the clinker silos for delivery to the cement finish mill. This emissions unit also includes the transport of additives from storage to the cement finish mill.
The clinker discharged from the clinker cooler will be transported via bucket elevator to one of two 25,000 ton clinker storage silos. Particulate matter emissions generated during clinker transport and the discharge of clinker into the silos will be controlled with fabric filter dust collectors. The clinker will be extracted from the clinker storage silos through flow control gates and discharged onto the finish mill feed conveyor. Particulate matter emissions generated during the extraction of the clinker will be controlled by fabric filter dust collectors. The mill feed conveyor will be a covered conveyor.
Gypsum, limestone, and other additives, as necessary, will be received by truck and stored under cover. These additives will be recovered and discharged onto the finish mill feed conveyor for delivery to the cement finish mill. Emissions from the handling of additives will be controlled by best management practices; including the inherent moisture of the additive materials.
This emissions unit will be located between the clinker cooler and the cement finish mill. The design operating rate is 140 tons per hour of clinker from the clinker cooler to the clinker silos and
10 20 to 40 tons of additives. A maximum operating schedule of 8760 hours/year is requested. Because market demands may be for higher fractions of additives per ton of cement, US Cement requests that the additives to the finish mill be up to 40 tph additives. At this time, US Cement expects additives to be 20 tons per hour at design operations. Thus, project design operations will be 180 tph and normal operations will be 160 tph.
2.1.5 Cement Finish Mill (K105) Clinker from the silos and additives will be transferred to the finish mill feed conveyor. The gypsum and limestone, grinding aids and other mineral additives will be ground with the clinker in the cement finish mill. Also, as discussed in Section 2.1.2, filter dust from the main kiln baghouse will be shuttled to the cement finish mill for purposes of mercury emission control. This filter dust will be pneumatically transferred to the cement finish mill as an additional additive.
The cement finish mill will be in a closed circuit with a high efficiency air separator and cyclones. The mill will be vented by a fabric filter. A fabric filter will vent all the conveying equipment. The finished cement will be conveyed pneumatically to the cement storage silos.
This emissions unit will be located between the clinker silos and the cement silos. The projected design operations are 180 tons per hour of cement to the cement silos with a 30-kiln operating day average, and with a requested maximum operating schedule of 8760 hours/year. Normal operations will be at 160 tons per hour.
2.1.6 Cement Handling, Storage, Packing and Loadout (K106) This emissions unit includes cement pneumatically conveyed from the cement finish mill into cement silos (35,400 tons total capacity), bulk cement loadout from the silos to trucks and railcar and bagging. Cement extraction from the silos will occur through rotary shut-off valves and airslides to vented retractable loading spouts, or to the packing plant. The loading spouts and the packing plant will all be equipped with fabric filters for particulate matter emissions control.
The cement bagging operation will consist of a screen, a surge hopper, a bucket elevator and a packer. The bags will be palletized after being air cleaned. A fabric filter will vent all equipment, including the air cleaning device. The pallets will be moved by forklift to storage, where they will be loaded on trucks.
The projected design operations are 500 tons per hour and normal operations will be 250 tons per hour of cement to trucks, railcar or the packing plant; with a maximum operating schedule of 8760 hours/year.
11 2.1.7 Coal and Petroleum Coke Grinding System (K107) This emissions unit includes coal/coke handling from railcar unloading through the fine coal/coke bin. Coal and/or petroleum coke will be received by rail and stored under cover. The storage area can also be used for storage of alternative fuel materials. The coal/coke will be reclaimed from storage and transported to the coal/petcoke grinding mill by covered conveyor and bucket elevator. The bucket elevator will discharge into a coal/petcoke surge bin that will feed the coal mill.
The coal/petcoke will be conveyed from the surge bin to a vertical mill. The coal/coke will be dried in the mill with hot air drawn from the pyroprocessing system preheater exhaust. The milled coal/coke will be recovered in a product fabric filter and stored in a fine coal/petcoke bin. The bin will be vented through a fabric filter. The milled coal/coke will be pneumatically conveyed to the main burner and precalciner burner.
This emissions unit will be located adjacent to the discharge end of the kiln. The design grinding rate of the coal mill is 20 tons per hour, with a requested maximum operating schedule of 8760 hours per year. The mill design rate allows for downtime of the coal/petcoke mill when fuel is needed for the kiln.
2.1.8 Stationary Emergency Generators CI RICE (K108) This emissions unit will include at least one emergency generator; a 1000 kW, 480v, 60Hz, 3 phase emergency electric power generator. The generator will be powered by a 2000 horsepower high- efficiency diesel engine. Emergency electric power is required to provide electricity to rotate the kiln, and for other emergency purposes in case of electric power outage. The kiln must continue to rotate while cooling to prevent thermal stress on the kiln and related equipment system. Other generators may be needed for other operations, and this emission unit will comprise those generators. All emergency electric power generating systems will operate less than 100 hours per year for non-emergency purposes.
2.2 Fugitive Emissions This section identifies fugitive PM10 and PM2.5 emissions generated by truck travel at the plant site, by off road truck travel in the quarry, by the primary crushing of limestone in the quarry and by the handling and conveying of limestone and overburden from the quarry to the plant site. These emissions are also addressed and quantified on Form 6.00.
The truck travel at the plant site will be associated with the shipping of cement (22,500 trucks per year), the receipt of cement finish mill additives (48 trucks per year) and the receipt of raw material additives (7500 trucks per year). The combined travel distance for all of these trucks is estimated at 18,250 miles per year on paved roads. These roads will be vacuum swept on a regular basis for fugitive particulate matter control.
12 The off-road truck travel in the quarry will be associated with the transport of mined limestone from the quarry to the primary crusher. It is estimated that there will be a maximum of 29,040 truck trips per year totaling 22,650 vehicle miles traveled.
The primary crusher in the quarry will be rated at 2000 tons per hour. This crusher will process approximately 1,452,000 tons per year of limestone. This crushing will generate fugitive PM10 and PM2.5 emissions that will be controlled by best management practices.
Additionally, fugitive PM10 and PM2.5 emissions will be generated during the loading and unloading of the haul trucks in the quarry and during the transfer of the crushed limestone from the primary crusher to the raw material storage building at the plant site. These emissions will also be controlled by best management practices.
2.3 Precautions to Prevent Emissions of Unconfined Particulate Matter The proposed precautions that will be applicable to the proposed new emissions units are listed below. The material handling activities at the plant include loading and unloading, storage and conveying of, but not limited to the following:
• Limestone and overburden • Iron oxide source (coal ash, iron ore or other) • Silica (sand or other) • Alumina (coal ash, bauxite or other) • Gypsum • Coal/coke/and other fuels
Reasonable precautions include the following: • Paving and maintenance of roads, parking areas and yards within the plant site. • Application of water or chemicals to control emissions from such activities as grading roads, construction, and land clearing. Vacuum sweeping will be applied as needed. • Application of asphalt, water, chemicals or other dust suppressants to unpaved roads, yards, open stock piles and similar activities. • Removal of particulate matter from roads and other paved areas under the control of the owner or operator of the facility by vacuum sweeping to prevent re-entrainment, and from buildings or work areas to prevent particulate from becoming airborne. • Landscaping or planting of vegetation. • Use of hoods, fans, filters and similar equipment to contain, capture and/or vent particulate matter. • Confining abrasive blasting where possible.
13 • Enclosure or covering of conveyor systems.
2.4 Facility Plot Plan This report provides a plot plan of the facility showing the general location of proposed manufacturing processes, control equipment, stacks, vents. The plot plan below is drawn to scale and shows the location of the new emissions units. These dimensions were used for air quality modeling studies performed by the applicant in support of the air construction permit application. Attachment F includes details of all emission points (stacks and fugitives) and buildings as used in the modeling inventory.
Figure 3. Facility Plot Plan
2.5 Process Flow Diagram A general process flow diagram for cement manufacturing, from AP-42 section 11.6 is reproduced below for convenience of this process. A detailed set of process flow drawings specific to this new
14 facility are provided in Attachment B. Those drawings detail each emission unit, the emissions points, and pertinent equipment. The facility modeling inventory in Attachment F includes details of the emission points.
15 Figure 4. Process Flow Diagram for Portland Cement Manufacturing
= Processes not applicable
16 2.6 Fuel Analysis or Specification K103 emissions unit includes two fuel combustion devices and the application SIP form 201 provides typical fuel specifications for these fuels. The raw mill system includes a hot gas generator, with natural gas, propane, and distillate oil (No. 2 and No. 4) as proposed fuels. The kiln system includes coal, natural gas, distillate oil (No. 2 and No. 4), petroleum coke, tires, used oil and alternative fuels as proposed fuels. The typical fuel specification gives the density, heat value and percent content by weight of sulfur, nitrogen, and ash; determined based on reasonably available information.
Note, sulfur fuel content is not indicative of the amount of SO2 generated from fuel combustion and release to the atmosphere. See discussion in Section 6 for SO2 BACT analysis.
2.7 Description of Control Equipment As discussed in the BACT analysis sections below, pollution control equipment that is proposed is summarized below.
2.7.1 PM/PM10 A baghouse is proposed for the raw mill/kiln/clinker cooler. Baghouses are proposed for other material handling operations. Many raw material handling operations involve material with sufficiently high moisture contents to preclude the need for add-on fugitive dust controls. The PM pollution control device includes the baghouse housing, all ductwork leading into the baghouse, and pressure guage monitoring systems, all software and hardware related to proper operation of the baghouse.
2.7.2 NOx Selective non-catalytic reduction (SNCR) using ammonia, low-NOx burners, and staged combustion are proposed to achieve the BACT emissions limit for NOx. An ammonia tank and injection system are needed for SNCR control. And ancillary hardware and software used in the production monitoring for NOx is pollution control equipment.
2.7.3 Dioxin/furan Water spray injection in the gas conditioning tower will be used to control emissions of dioxin/furan. The water quality monitoring and control, and the water holding tanks and pumping systems are pollution control equipment.
2.7.4 Mercury Activated carbon injection along with shuttling of baghouse dust from the kiln baghouse to the finish mill are proposed to achieve the NESHAP Subpart LLL emissions limit for mercury. Any and all dust shuttling equipment is solely for pollution control. It includes the hopper system used to collect and store dust. The transportation system of the dust and the injection system in the finish mill and related monitoring and controls of the system are pollution control equipment. 17
2.7.5 SO2, CO, VOC/THC and HCl Plant operating practices, plant design and materials management are proposed as BACT for SO2, CO, VOC/THC and HCl.
2.7.6 Pollution Control Equipment – Ad Valorem All of the above referenced equipment should be included in the Georgia State tax exemption allowances for the US Cement industrial complex. Other equipment that qualifies for the exemption includes, but is not limited to the following. The portion of the kiln that is primarily for pollution control includes the calciner loop extension. That loop extension (as discussed in the BACT analysis below) provides burnout/reduction of NOx, VOC and CO and reduces GHG emissions. All exhaust stacks and pollution monitoring systems (includes monitoring of clinker production required for reporting in lb/ton clinker) are pollution control equipment. Sulfur and nitrogen monitoring equipment used in the quality assurance laboratory are pollution control. This list of tax exempt equipment will be addressed in other documents. However, the pollution control equipment addressed herein, at a minimum should be included.
2.8 Description of Stack Sampling Facilities For those proposed emissions units subject to a stack sampling requirement, the applicant will provide a description of the stack sampling facilities including sampling ports, work platforms, means of access and equipment support structures, if required by the Department. This information, if required, will be provided after plant construction, but prior to initial compliance testing as part of the proposed test plan.
3. Rule Applicability Analysis This section identifies state, federal and local air pollution control rules applicable to the facility and to the emissions units, based on the nature, location, design capacity, operating schedule, emissions and other relevant information.
Section 3.1 addresses Federal and State rules that apply in detail to each emissions unit. Attachment C includes tables showing the applicable Federal rules for each emission unit.
Section 3.2 provides the provisions of Chapter 391-3-1-.03 to address the proposed construction of the emissions units described in the application for an air construction permit, pursuant to Rule 391-3-1-.03.
Section 3.3 provides a detailed analysis of how the various provisions of Chapter 391-3-1 (Air Quality Control), apply on a pollutant-by-pollutant basis, including general preconstruction review requirements, and prevention of significant deterioration (PSD) review.
18 The facility is located in an area designated as attainment for criteria air pollutants, therefore nonattainment area (NAA) new source review does not apply. The project does not include a netting analysis to avoid PSD or NAA review for one or more pollutants.
If any exemptions or special provisions of Chapter 391-3-1 apply, this section provides all information necessary for the Georgia Environmental Protection Division (GaEPD) to verify applicability of each such exemption or special provision.
The project does not involve relaxation of a federally enforceable limitation on the pollutant emitting capacity of the facility and does not trigger retroactive application of PSD or NAA NSR.
3.1 Applicable Federal and State Requirements Regarding Federal Rules, each emission unit will be subject to certain applicable provisions of three New Source Performance Standards (NSPS) and applicable provisions of one National Emission Standards for Hazardous Air Pollutants (NESHAP). Regarding GaEPD rules, the emission units will have applicable requirements focused in 391-3-1-.03. Details of each rule are provided below in tabular form and explained in narrative as well for each emissions unit and, if needed, specific equipment within each emission unit.
The Federal Rules that apply to certain emissions units are outlined below. Of these rules the NESHAP Subpart LLL and NSPS Subpart F are the most significant rules
National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart LLL: Standards of Performance for Portland Cement Plants (40 CFR 63.1340) • Subject as a Brownfield source NOTE: The facility is a new source and presumed major for HAPs. This NESHAP supersedes the applicable NSPS – 40 CFR 60.60: Subpart F: Standards of Performance for Portland Cement Plants.
See Attachment C for a detailed analysis of the applicability of these rules.
New Source Performance Standards (NSPS) Subpart Y: Standards of Performance for Coal Preparation Plants (40 CFR 60.250) • For coal handling and coal mills. The new or existing status of equipment will depend on the date of equipment manufacture. The exact equipment has not been selected but US Cement will notify GaEPD when the equipment is acquired and the date of manufacture so that the applicable Subpart Y requirements will be imposed.
See Attachment C for a detailed analysis of the applicability of this rule.
Subpart OOO: Standards of Performance for Nonmetallic Mineral Processing Plants (40CFR60.670)
19 • For raw material processing in the quarry and prior to raw material storage. The new or existing status of equipment will depend on the date of equipment manufacture. The exact equipment has not been selected but US Cement will notify GaEPD when the equipment is acquired and the date of manufacture so that the applicable Subpart OOO requirements will be imposed.
See Attachment C for a detailed analysis of the applicability of this rule.
Subpart CCCC: Standards of Performance for Commercial and Industrial Solid Waste Incineration Units (40 CFR 60.) At this time and expectedly, US Cement does not foresee to assert that kiln unit to be subject to Subpart CCCC. Analysis of this rule is not provided at this time.
3.2 Rule 391-3-1-.03 – Permits This section discusses the requirements of Rule 391-3-1-.03. This rule applies to the proposed construction of the emissions units described in the application for an air construction permit, pursuant to Rule 391-3-1-.03.
3.2.1 Rule 391-3-1-.03(1) – Construction (SIP) Permit (a) Air Construction (SIP) Permit Required No emissions unit or facility that will result in air pollution that is subject to this rule will be constructed or modified without obtaining an air construction permit from the GaEPD in accordance with the requirements of Rule 391-3-1-.03. This report accompanies an application for an air construction permit.
In this report and accompanying application, the applicant for an air construction permit is providing the GaEPD with the following required information: • Process flow diagrams; • Plot plans; • Description of control devices; • Description of proposed new or modified operations; • Type of operation; • Raw materials to be used; • The finished product; • Type and quantity of fuels to be used; and • Characteristics and amounts of emissions. This information is included in the application and in this report.
(b) Ambient Air Quality Standards and PSD Increments The proposed construction of the emissions units at the facility will not cause or contribute to a failure to attain or maintain any ambient air quality standard (AAQS) or result in a significant deterioration of air quality. The ambient impact analysis section of this report (Section 4) will
20 provide all required documentation, when completed. The facility is not located in a nonattainment area or area of influence.
3.2.2 Rule 391-3-1-.03(8) – Permit Requirements (a) Preconstruction Requirements The requirements of Rule 391-3-1-.03(8), apply to the proposed project in addition to other permitting requirements under Rule 391-3-1-.03(1), as described above. Each application for a permit to construct or modify a stationary source is subject to preconstruction review. The application must demonstrate that the proposed project will not cause or contribute to a failure to attain or maintain any AAQS, result in a significant deterioration of air quality, or result in a violation of any applicable emission limit or standard of performance. In addition, no permit shall be issued to any source that does not meet the emission standards for HAPs.
(b) Information Required by 40 CFR 63.43(e) This project does not include emissions units subject to 40 CFR 63.43(e), Application Requirements for a Case-by-case MACT Determination. NESHAP Subpart LLL is applicable, and obviates the need for a case-by-case determination.
3.3 Rule 391-3-1-.02(7) – Prevention of Significant Deterioration This section discusses the requirements of Rule 391-3-1-.02(7)(b) – PSD Standards. The provisions of this rule generally apply to the construction of air pollutant emitting facilities in those parts of the state in which the state ambient air quality standards are being met. The provisions of this rule incorporate the Federal PSD rule (40 CFR Part 52.21) with some exceptions.
3.3.1 Rule 391-3-1-.02(7)(b) – PSD Standards (a) Ambient Air Increments This provision incorporates 40 CFR Part 52.21(c) by reference. The proposed construction of the emissions units at the facility will not cause or contribute to a violation of any ambient air increment. The ambient impact analysis section of this report (Section 4) will provide all required documentation, when completed. The facility is not located in a nonattainment area or area of influence.
(b) Control Technology Review The application addresses best available control technology (BACT) for each regulated NSR pollutant where there is a significant net emissions increase due to the proposed project. The BACT analysis in Section 6.0 of this report addresses the control technology review.
(c) Air Quality Analysis The proposed project, in conjunction with all other applicable emissions increases or reductions (including secondary emissions), will not cause or contribute to air pollution in violation of: 1. Any national AAQS; or 2. Any applicable maximum allowable increase over the baseline concentration in any area.
21 The ambient impact analysis in Section 4 of this report will provide all required documentation, when completed.
(d) Additional Impact Analyses The owner or operator of the proposed facility is providing the GaEPD with the required additional impact analyses. The analyses were carried out using EPA-approved methods.
(e) Preconstruction Air Quality Monitoring and Analysis This requirement will be addressed in Section 4 of this application report, when completed.
(f) Postconstruction Monitoring The applicant is requesting that GaEPD waive the discretionary requirement for postconstruction air quality monitoring.
(g) Permit Application Information Required The applicant is submitting this report and a completed application form to the GaEPD. These documents provide the following information to the GaEPD:
1. A description of the nature, location, design capacity and typical operating schedule of the facility, including specifications and drawings showing its design and plant layout;
2. A detailed schedule for construction (this will be provided prior to the initiation of construction);
3. A detailed description of the system of continuous emissions reduction proposed as BACT, emissions estimates and any other information as necessary to determine that BACT would be applied;
4. Information relating to the air quality impact of the facility, including meteorological and topographical data necessary to estimate such impact;
5. Information relating to the air quality impacts of, and the nature and extent of, all general commercial, residential, industrial and other growth which has occurred since August 7, 1977, in the area the facility would affect; and
6. A good-engineering-practice stack height, or other dispersion techniques, analysis to demonstrate compliance with applicable rules.
(h) Source Applicability and General Exemptions This section adopts the federal rule (40 CFR Part 52.21(i)) by reference and it establishes that the proposed project is subject to the PSD preconstruction review requirements of this rule. As detailed below, the proposed project does not qualify for any of the exemptions of 40 CFR Part 52.21(i):
22 • The modified facility will not be a nonprofit health or nonprofit educational institution; • The source or modification will not be a major stationary source or major modification only if fugitive emissions, to the extent quantifiable, are considered in calculating the potential to emit of the stationary source or modification and the source does not belong to any of the Major Facility categories. The US Cement facility does belong to one of the Major Facility Categories (Portland Cement Plants).
(i) New and Modified Facilities The project is not a proposed new minor facility. The proposed project is a major modification to a major facility. The proposed project is not exempted under 40 CFR 52.21 and is subject to the PSD preconstruction review requirements of 40 CFR 52.21. The project will result in a significant net emissions increase (as set forth in 40 CFR 52.21(a)(23)(i)) of certain pollutants regulated under the Act, as shown below.
Table 1. Regulated Air Pollutant Significant Emission Rates
Significant Emission Rate Project Emission Rate Pollutant (Tons/Year) (Tons/Year) PSD ? Carbon monoxide 100 1,595 YES
Nitrogen oxides 40 825 YES
Sulfur dioxide 40 220 YES
Ozone 40 VOC/40 NOx 80/825 YES
PM10 15 76.6 YES
PM2.5 10 direct PM2.5/40 NOx/40 SO2 18.5/825/220 YES
Carbon Dioxide 750,000 1,045,000 YES
Sulfuric acid mist 7 4.4 NO
Fluorides 3 0.55 NO
Lead 0.6 0.046 NO
The facility to be modified is not located within 10 kilometers of a Class I area. Ambient impacts to Class I areas will be addressed in Section 4 of this report, when completed.
(j) Emissions Increases The proposed project results in net emissions increases for pollutants regulated under the Act. No contemporaneous creditable decreases in actual emissions are requested for this project. Creditable increases from the project itself and increases in quantifiable fugitive emissions are greater than zero.
23
The proposed project results in significant net emissions increases for certain pollutants regulated under the Act. The net emissions increases are greater than the applicable significant emission rate listed in 40 CFR 52.21(a)(23)(i) – Significant Emission Rates, for the following pollutants: • Carbon Monoxide • Nitrogen Oxides • Sulfur Dioxide • Ozone (as VOC) • Particulate Matter (<10 microns) • Particulate Matter (<2.5 microns)
The date on which any increase in the actual emissions or in the quantifiable fugitive emissions of the facility occurs is the date on which the owner or operator of the facility begins, or projects to begin, operation of the emissions units resulting in the increase.
(k) Pollutants Subject to PSD Preconstruction Review The preconstruction review requirements of Rule 391-3-1-.03 apply to all pollutants regulated under the Act for which the sum of the potential emissions and the quantifiable fugitive emissions of the facility would be equal to or greater than the significant emission rates listed in 40 CFR 52.21(a)(23)(i) – Significant Emission Rates, as shown in the preceding section.
The facility is not located within 10 kilometers of a Class I area. The facility is not located in an area designated as nonattainment for any pollutant.
(l) Relaxations of Restrictions on Pollutant Emitting Capacity The proposed project is not subject to the preconstruction review requirements of this rule solely by virtue of a relaxation in any federally enforceable limitation on the capacity of the facility to emit a pollutant (such as a restriction on hours of operation).
3.3.2 Rule 391-3-1-.03(6) – Exemptions The provisions of Rule 391-3-1-.03(6) establish exemptions and exclusions from certain of the General Provisions of Rule 391-3-1-.03, and PSD Review Requirements of Rule 391-3-1-.02(7).
(a) Combustion Equipment The proposed project includes combustion equipment greater than 10 MMBtu/hr for natural gas or fuel oil and 2.5 MMBtu/hr for other fuels.
(b) Pollution Control Projects The proposed project does not qualify as a pollution control project.
(c) Modifications Under Certain Size The net emissions increases are greater than:
24 • CO: 50 TPY;
• PM, PM10, SO2, NOx, and VOC: 20 TPY; • HAPs: individual – 2 TPY, total – 5 TPY.
3.3.3 Rule 391-3-1-.02(7)(a)4.(viii) – Federal Land Manager (a) Sources Impacting Federal Class I Areas – Notice to Federal Land Managers The GaEPD shall comply with the additional notification requirements of 40 CFR 52.21(p) incorporated by reference in Rule 391-3-1-.02(7)(a)4.(viii), for a proposed new facility that would be located within 100 kilometers (km) of, or whose emissions may affect, any Federal Class I area.
The Federal Land Manager (FLM) of any lands contained in a Class I area which may be affected by emissions from a proposed facility may demonstrate to the GaEPD that the emissions from the proposed facility would have an adverse impact on the air quality-related values (AQRV) (including visibility) of the Federal Class I area, notwithstanding that the change in air quality resulting from emissions from such facility would not cause or contribute to concentrations which would exceed any maximum allowable increase for a Class I area.
If this demonstration is received by the GaEPD within thirty (30) days after the GaEPD has mailed or transmitted to the FLM a complete application pursuant to 40 CFR 52.21(p), it shall be considered in the GaEPD's preliminary determination and proposed agency action on the permit application. If this demonstration is received within the public comment period on the GaEPD's proposed agency action, it shall be considered in the GaEPD's final determination and final agency action on the permit application.
If the GaEPD finds that the FLM’s analysis does not demonstrate to the GaEPD's satisfaction that an adverse impact on the AQRVs (including visibility) of a Class I area would occur, a written explanation of the reasons for such finding shall be included in the GaEPD's preliminary or final determination as provided in 40 CFR 52.21(p). If the GaEPD is satisfied that the FLM has demonstrated an adverse impact on the AQRV (including visibility) of a Class I area, the GaEPD shall not issue the permit.
(b) Redesignation Provisions The establishment of a minor source baseline date for a pollutant establishes the baseline area for that pollutant based on the designations of individual PSD areas under 40 CFR 52.21(g), incorporated by reference in Rule 391-3-1-.02(7)4.(vi). The boundary of the baseline area may be changed only by redesignating the boundaries of the affected PSD areas in accordance with the redesignation provisions of 40 CFR 52.21(g). The minor source baseline date for an area may be disestablished or changed as the result of such redesignation of PSD areas.
The establishment of a baseline area requires the determination of the baseline emissions that affect the baseline area. The baseline emissions are determined for each pollutant for which maximum allowable increases are established under 40 CFR 52.21(2)(b)(13) and are used to compute the
25 baseline concentration levels for each point within the baseline area. The baseline concentration is the ambient concentration value to which the applicable maximum allowable increase is added to determine the maximum allowable ambient concentration for each point within the area.
(c) Ambient Monitoring Quality Assurance Requirements If ambient monitoring is required, the applicant for the proposed facility will meet the requirements of 40 CFR Part 58, Appendix B, during the operation of ambient air quality monitoring stations required pursuant to the provisions of Rule 391-3-1-.02(6).
Project Description The application and this report provide a description of the nature, location, design capacity and typical operating schedule of the facility, including general specifications and drawings showing proposed plant layout.
Construction Schedule When US Cement finalizes a construction schedule it will be submitted to GaEPD.
BACT Proposal The BACT section of this report (Section 6) provides a detailed description of the system of continuous emissions reduction proposed as BACT and includes emissions estimates and any other information as necessary to determine that BACT would be applied to the facility.
Ambient Impact Analysis The ambient impact analysis section of this report (Section 4) will provide information relating to the air quality impact of the facility, including meteorological and topographical data necessary to estimate such impact, when completed.
Growth since 1977 This section of the report provides information relating to the air quality impacts of, and the nature and extent of, all general commercial, residential, industrial and other growth which has occurred since August 7, 1977, in the area the facility would affect.
For the purposes of this report, the area the facility will affect is defined as the area of significant impact. For conservatism, the area of significant impact is based on high-first-high concentrations. A review of growth parameters for Houston County is provided below.
Houston County has experienced substantial growth since 1977. The population was 77,605 in 1980 and was estimated to be about 155,469 in 2018. The total housing units increased from 34,785 in 1990 to 63,958 in 2018. Employment has increased in the civilian labor force from 40,787 in 1990 to 95,000 in 2017.
26 The air impacts from this growth are addressed with the background air quality concentrations, when comparing with the ambient air quality standards.
Good Engineering Practice Stack Height Good engineering practice stack height will be addressed in the ambient impact analysis section of this report, when completed(Section 4).
3.3.4 Rule 391-3-1-.02(7)(b)7. – Best Available Control Technology (a) BACT Determination Following receipt of a complete application for a permit to construct an emissions unit or facility which requires a determination of BACT, the GaEPD shall make a determination of BACT during the permitting process.
(b) Phased Construction Projects For phased construction projects, the determination of BACT shall be reviewed and modified in accordance with 40 CFR 51.166(j)(4). The proposed facility is not presented as a phased construction project.
(c) Use of Innovative Control Technology With the consent of the Governor(s) of other affected state(s), the GaEPD shall approve, through the permitting process, the use of a system of innovative control technology if the proposed system would comply with the requirements of 40 CFR 51.166(s)(2)(i) through (v).
(d) Test Methods and Procedures All emissions tests performed pursuant to the requirements of this rule will comply with the following requirements.
Pollutants for Which a Standard has Been Established Pursuant to 40 CFR Part 60, 40 CFR Part 61, or 40 CFR Part 63 The test methods shall be as specified in 40 CFR Part 60, Appendix A, 40 CFR Part 61, Appendix B, or 40 CFR Part 63, Appendix B.
Pollutants for Which No Standard has Been Established Pursuant to 40 CFR 60, 40 CFR 61, or 40 CFR 63 The test methods shall be as specified in the BACT determination.
27 4. Ambient Impact Analysis THIS SECTION IS MODELING AND IS CONTINGENT ON PERMITTED BACT LIMITS AND IS NOT DRAFTED.
28 5. Additional Impact Analyses THIS SECTION IS MODELING AND IS CONTINGENT ON PERMITTED BACT LIMITS AND IS NOT DRAFTED.
29 6. Best Available Control Technology Analysis 6.1 Introduction Any major stationary source or major modification to a stationary source that is located in an area that is in attainment with all applicable New Source Review (NSR) air pollutants, as is the US Cement Houston County, Georgia project, is subject to PSD must conduct an analysis to ensure the application of Best Available Control Technology (BACT). BACT determinations are done on a case-by-case basis and the energy, environmental, and economic impacts of each control technology are evaluated. The BACT requirements are defined as: “an emissions limitation (including visible emission standard) based on the maximum degree of reduction for each pollutant subject to regulation under the Clean Air Act which would be emitted from any proposed major stationary source or major modification which the Administrator, on a case-by-case sbasis, taking into account energy, environmental, and economic impacts and other costs, determines is achievable for such source or modification through application of production processes or available methods, systems, and techniques, including fuel cleaning or treatment or innovative fuel combustion techniques for control of such pollutants. In no event shall application of best available control technology result in emissions of any pollutant which would exceed the emissions allowed by any applicable standard under 40 CFR Parts 60 and 61. If the Administrator determines that technological or economic limitations on the application of imposition of an emissions standard infeasible, a design, equipment, work practice, operational standard, or combination thereof, may be prescribed instead to satisfy the requirement for the application of best available control technology. Such standard shall, to the degree possible, set forth the emissions reduction achievable by implementation of such design, equipment, work practice or operation, and shall provide for compliance by means which achieve equivalent results.”
A common method for determining BACT is the “top-down” approach. The key steps in determining BACT for a project under this approach; steps that are consistent with those outlined in the EPA Draft New Source Review Workshop Manual (1990) and the Georgia EPD PSD permit application Guidance Document (September 18, 2012), include:
Step 1 – Identification of all Control Technologies, Step 2 – elimination of Technically Infeasible Control Options, Step 3 – A ranking of Remaining Technically Feasible Control Options, Step 4 – An evaluation of Remaining Control Technologies, and Step 5 – The selection of BACT.
The BACT requirement applies to each individual affected emissions unit and pollutant emitting activity at which a PSD applicable emissions increase would occur. The BACT determination must address separately, air pollution controls for each emissions unit and for each regulated pollutant 30 that has a significant emission rate increase. Therefore, in the case of the proposed new US Cement Portland cement plant, a BACT analysis will be performed for PM/PM10/PM2.5, SO2, NOX, THC/VOC, and CO. A “top-down” BACT analysis is described below for each emission unit for the applicable pollutants.
At the conclusion of the BACT assessment, the control technologies to be used and related emission limitations or work practice standards based on those technologies will be summarized. The summaries of the BACT assessments will describe:
• Proposed control technologies. The control technologies are the basis of the BACT determination. The analyses center around the selection of these control technologies and the determination of the emission limits or work practice standards.
• Emission limits. The emission limits will be based on the selected control technologies, as applied to the respective sources of air pollution. The emission limits, in most cases will be expressed in units of pounds of pollutant per ton of clinker produced or in concentration units (e.g., grains per dry standard cubic foot) in the case of dust collectors.
• Averaging times associated with the emission limits. The major factor involved in establishing averaging times associated with emission limits will be the federal regulations applicable to Portland cement plants; e.g., New Source Performance Standard (NSPS) emission limits (40 CFR 60, Subpart F), National Emission Standards for Hazardous Air Pollutants (NESHAP) emission limits (40 CFR 63, Subpart LLL) and/or emission limits for cement kilns operated as a Commercial or Industrial Solid Waste Incinerator (CISWI) as codified at 40 CFR 60, Subpart CCCC.
• Proposed testing, monitoring, reporting and recordkeeping provisions are not required components of the BACT assessment contained in a PSD permit application, but these requirements will be included in air construction and air operating permits. In order to ensure that any BACT limit is practically enforceable, the permit must include sufficient monitoring, reporting and recordkeeping provisions to allow the agency to verify compliance with each BACT emission limit (or work practice standard). To facilitate this permitting requirement, the testing, monitoring, reporting and recordkeeping provisions of the above cited federal regulations will be included in the BACT assessment conclusions.
The proposed plant’s preliminary design is presented in the application and report. The proposed control technologies are described in the following sections as a specific control technology or “equivalent”. The plant design is still in the preliminary stages. Therefore, the final plant design, including the control equipment design, may differ somewhat from the proposed design. However, the final control equipment configurations will be equivalent in performance and reliability.
The control technologies evaluated for each pollutant subject to a BACT determination are presented in the following sections. Each section includes a discussion of the factors associated 31 with the generation and behavior of the pollutant, applicable BACT determinations that have been reported in the EPA RACT/BACT/LAER Clearinghouse (RBLC) over the past 10 years, applicable federal regulations (e.g., those cited in previous paragraphs) that establish emission limits applicable to the pollutant being considered, and the BACT determination as described above.
Table 2 summarizes the proposed BACT limits for the kiln system and includes other regulated pollutants as described above. As discussed below, the BACT limits are largely based on recent stringent limits established for new kilns under Federal rules of NESHAP Subpart LLL and NSPS Subpart F.
TableTable of Proposed2. Proposed Regulated Regulated Pollutants Kiln System Pollutants limits Kiln System Limits
pollutant Rule Basis limit with unit of measure & averaging time pounds per hour tons per year
Hg LLL 21 lb/tonC (30day, CEMS) 0.0029 0.012 D/F LLL 0.4/0.2 ng/dscm 7%O2 (30month, SS) 0 0 HCl LLL 3 ppmvd 7%O2(30day, CEMS) 2.12 9.27 CO BACT 2.9 lb/tonC (30day, CEMS) 406 1595 NOx BACT/F 1.5 lb/tonC (30day, CEMS) 210 825 SO2 BACT/F 0.4 lb/tonC (30day, CEMS) 56 220 THC/OHAP LLL 24 ppmvd(30day, CEMS)/12(annual, SS) 20.5 80 VOC BACT 0.15 lb/tonC (30day, CEMS) 20.5 80 (eqn. 2 - LLL, ~0.036 lb/tonC) (30day, CPMS and PM (PM10)* LLL (BACT) 5.03 19.75 annual, SS) PM2.5* LLL (BACT) 38% 1.93 7.59 CO2e BACT 0.95 ton/tonC (12month, CEMS) 133.0 1045000 BACT = Best Available Control Technology LLL = NESHAP Subpart LLL F = NSPS Subpart F CEMS = continuous monitoring system SS = stack test CPMS = continuous parametric monitoring system * PM limit ~0.036 based on Eqn. 2 from rule to account for kiln and cooler emissions. PM10 has a BACT limit equal to PM. PM2.5 BACT limit is 38 percent of PM10 (see attachment F).
6.2 Particulate Matter (PM10/PM2.5) Particulate matter emissions (PM10/PM2.5) at Portland cement plants result from the grinding and handling of raw materials to produce the raw meal feed for the kiln system; the pyro processing of raw meal to produce clinker; the transport of clinker to the cement finish mill; clinker grinding to produce finished cement; and the transport, storage, packing, and shipping of finished cement. Additionally, particulate matter emissions are generated from the handling and grinding of solid fuels; both conventional fuels and alternative fuels. The particulate matter emissions generated from all of these activities are captured, pass through fabric filter dust collectors for particulate matter control, and discharge to the atmosphere through defined point sources (stacks).
In addition to the point source particulate matter emissions, fugitive particulate matter emissions are generated from the storage and handling of raw materials at the plant site; the mining, crushing and transport of materials in the quarry; and vehicle traffic both at the plant site and in the quarry.
32 Control of particulate matter emissions is achieved by the collection of particles from point sources and the use of dust collectors to control these emissions, and by minimizing the generation of particulate matter from fugitive sources. Historically, the common control devices for the control of particulate matter emissions from the kiln/raw mill system and the clinker cooler included fabric filters (baghouses), and electrostatic precipitators (ESP). Baghouses were, and are universally used to control particulate matter emissions from material grinding and handling operations.
With the promulgation of current federal regulations limiting particulate matter emissions from existing and new Portland cement plants, there has been a shift from ESPs to baghouses for controlling particulate matter emissions from kiln/raw mill systems and clinker coolers. In some cases, this has involved retrofitting baghouses as replacements for ESPs; e.g., the Argos cement plant in Newberry Florida. This has been determined to be necessary to meet particulate matter concentration limits in the range of 0.002-0.004 grains per dry standard cubic foot on a consistent basis. Note that for the proposed US Cement plant, the kiln/raw mill and the clinker cooler will exhaust through a common stack.
Inertial separators (cyclones), another category of PM/PM10 control devices, can have efficiencies of over 90 percent within narrow particle size ranges, but the overall efficiencies are generally less than 85 percent. As all particulate matter collected by dust collectors in cement plants is returned to the system as an intermediate product or product, inertial separators are used extensively as process devices for material recovery; but not as air pollution control devices.
6.2.1. Proposed BACT In the proposed US Cement plant, the cement kiln, the raw mill, the raw mill hot gas generator and the clinker cooler will exhaust through a common baghouse and stack, while the coal mill will exhaust through a separate baghouse and stack. It should be noted that approximately three percent of the kiln exhaust gas sweeps the coal mill during the grinding of coal (or petroleum coke). The fact that kiln exhaust gas passes through the coal mill makes the coal mill subject to the same particulate matter emission limit as the kiln system. Baghouses will also be used to control particulate matter emissions from the cement finish mill and the 19 material handling/transport emission points.
The kiln/raw mill/clinker cooler baghouse is proposed to operate at a basic PM/PM10 BACT emission rate of 0.002 grains per dry standard cubic foot expressed as a mass based limit (pounds per ton clinker) using eqn. 2 of NESHAP Subpart LLL. This equation allows for PM emissions from the kiln and clinker cooler that vent to the same stack to account for the combined stack gas PM emissions as a single emission limit. This eqn. effectively limits both the kiln/raw mill and clinker cooler, each to a limit of 0.02 lb/tonC. A limit of 0.02 lb/tonC would be the limit for each of the kiln and clinker cooler if they vented to separate stacks. However, EPA does not want to discourage energy efficient process that combine exhaust gases to conserve heat such as the clinker cooler venting its hot gas exhaust to the kiln/raw mill. The coal mill PM emissions will have to be assumed to originate from the kiln such that the cumulative PM emissions from the kiln/raw
33 mill/cooler stack and coal mill stack will need to meet the calculated PM emission limit by Eqn. 2 during the annual PM stack testing required under LLL. As noted in the attached calculations sheet, the effectively mass based limit is dependent on the kiln operation at the time of testing. However, the expected PM limit to be calculated using Eqn. 2 from LLL will be near 0.035 lb/tonC. This emission rate is equivalent to the New Source Performance Standard (NSPS) PM emission limit for plants commencing construction after June 16, 2008 (new plants) as codified at 40 CFR 60, Subpart F - Standards of Performance for Portland Cement Plants, and also equivalent to the National Emission Standard for Hazardous Air Pollutant (NESHAP) emission limit for plants that commence construction after May 6, 2009 (new plants) as codified at 40 CFR 63 , Subpart LLL - National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry.
As noted above, this production-based particulate matter emission limit is equivalent to a concentration-based emission limit in the stack gas of 0.002 grains per dry standard cubic foot. Further, as noted above, the coal mill baghouse will also be subject to the same standard as it exhausts a fraction of the kiln gas; i.e. to an equivalent dust loading of 0.002 grains per dry standard cubic foot.
The baghouses for the cement finish mill and the 19 material handling/transfer activities will operate with proposed BACT PM/PM10 stack gas concentrations of 0.004 grains per dry standard cubic foot, at stack conditions.
In addition to the point sources of particulate matter emissions, there will be fugitive particulate matter emissions associated with truck travel at the plant site and at the quarry, fugitive emissions associated with primary limestone crushing at the quarry, fugitive emissions associated with haul- truck loading and unloading at the quarry, and fugitive emissions associated with transfer points on the conveyor system transporting the primary crusher limestone from the quarry to the plant site. These fugitive particulate matter emissions will be controlled by work practice standards and by the inherent saturated moisture content of the mined limestone.
In the following sections, federal regulations applicable to PM emissions from new Portland cement plants are cited; particulate matter BACT determinations for Portland cement plants made over the past 10 years and listed in the EPA RACT/BACT/LAER Clearinghouse (RBLC) are reviewed; particulate matter sources are discussed; and applicable particulate matter emission control technologies are evaluated.
6.2.2. Federal Regulations Limiting PM/PM10/PM2.5 Emission Rates and Recent BACT Determinations (a) Federal Regulations The permitted particulate matter emission limiting standards for the US Cement plant will be based on a BACT determination. The BACT particulate matter emission standard will be at least as stringent as promulgated federal emission limiting standards for particulate matter from Portland
34 cement plants; and possibly more stringent depending upon the BACT determination. In the following paragraphs, federal regulations potentially applicable to the US Cement plant will be summarized, as will BACT determinations establishing particulate matter emission limits for Portland cement plants made over the past 10 years.
The US Cement plant will be subject to New Source Performance Standard (NSPS) emission limits for plants commencing construction after June 16, 2008 (new plants) as codified at 40 CFR 60, Subpart F - Standards of Performance for Portland Cement Plants. Additionally, depending on how US Cement plans to categorize the new plant; i.e., as a conventional fuel burning plant, or a plant operated as an commercial/industrial solid waste incinerator, the plant will be subject to either National Emission Standards for Hazardous Air Pollutants (NESHAP) rules or to Commercial and Industrial Solid Waste Incinerator (CISWI) rules. The NESHAP rules for plants that commence construction after May 6, 2009 (new plants) are codified at 40 CFR 63 , Subpart LLL - National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry and the CISWI rules for plants that commence construction after June 4, 2010 (new are codified at 40 CFR 60, Subpart CCCC - Standards of Performance for Commercial and Industrial Solid Waste Incineration Units. The PM emission limiting standards imposed by each of these three federal regulations are summarized in Table 3. While US Cement is not expected to assert that CCCC applies, this assertion is the authority of US Cement.
Table 3. Federal Particulate Matter Emission Limiting Standards Potentially Applicable to US Cement Waste Burning Kiln NESHAP Kiln NSPS All Kilns Basis of Emission Basis of Emission Basis of Emission Pollutant 40 CFR 60, Subpart CCCC Limit 40 CFR 63, Subpart LLL Limit 40 CFR 60, Subpart F Limit
4.9 mg/dscm @ 7% O2 Rule 0.02 lb/ton Clk Rule 0.02 lb/ton Clk Rule PM 0.002 gr/dscf @ 7% O2 Equivalent to Rule 6.23 mg/dscm @ 7% O2* Equivalent to Rule 0.016 lb/ton Clk* Equivalent to Rule 0.0027 gr/dscf @ 7% O2* Equivalent to Rule * - Based on a Stack Gas Flow Rate of 51,429 dscf/ton Clinker
(b) Recent BACT Determinations The EPA RACT/BACT/LAER Clearinghouse (RBLC) was reviewed for BACT determinations made over the period 2009-2019 that would limit particulate matter emissions from Portland cement plants that were subject to PSD. The following determinations were found. Note that many kilns in the review below show similar PM limits of 0.02 lb/tonC (or Eqn. 2 for combined kiln/cooler).
RBLC ID: IN-0312 Date: June 26, 2019 Company: Lehigh Cement Company, LLC Project: Add new preheater/pre-calciner cement kiln with a rated throughput of 7716 tons of clinker per day at an existing facility. The kiln system consists of 15-stage preheater, calciner and rotary kiln. Emissions are controlled by the Kiln Baghouse, low NOx burners, SNCR, and an activated carbon system. The kill uses natural gas,
35 coal, coke, fuel oils and/or non-hazardous fuels (chips and tires, whole tires, engineered fuels, dried bio-solids, high-carbon fly as you and other biomass fuels.
PM/PM10/PM2.5 Emission Limits: The PM emission limits for this project were not subject to BACT; the limits were established to avoid PSD review
RBLC ID: TX-0831 Date: December 06, 2017 Company: GCC Permian, LLC Project: New dry process Portland cement kiln added at an existing facility.
PM/PM10/PM2.5 Emission Limits: The PM emission limit for the kiln in this project was established in accordance with BACT/PSD at 0.02 pounds per ton of clinker (30-day average) and 0.01 gr/dscf. These emission limits were to be met through a baghouse. The PM10/PM2.5 emission limit for the kiln in this project was established in accordance with BACT/PSD at 0.01 gr/dscf. This emission limit was to be met through a baghouse. The PM/PM10/PM2.5 emission limit for the material handling, transport, and transfer sources in this project was established in accordance with BACT/PSD at 0.01 gr/dscf. This emission limit was to be met through a baghouse. The PM/PM10/PM2.5 emission limit for the raw material handling operations and storage piles in this project was established in accordance with BACT/PSD at no limit but controlled with the use of water sprays and full or partial enclosures (which was estimated at 70% control efficiency).
RBLC ID: TX-0828 Date: November 07, 2017 Company: TXI Operations LP Project: Increase production and bring about other as-built changes on the kiln at an existing facility.
PM/PM10/PM2.5 Emission Limits: The PM/PM10/PM2.5 emission limit for the kiln, clinker conveying and storage and material handling in this project was established in accordance with BACT/PSD at 0.01 gr/dscf. This emission limit was to be met through a baghouse. The PM/PM10/PM2.5 emission limit for the non-metallic mineral processing, raw material handling operations and storage piles in this project was established in accordance with BACT/PSD at no limit but controlled with the use of water sprays and full or partial enclosures (which was estimated at 70% control efficiency).
RBLC ID: TX-0822 Date: June 30, 2017 Company: Capitol Aggregates, Inc. Project: New dry process Portland cement kiln added at an existing facility.
PM/PM10/PM2.5 Emission Limits: The PM/PM10/PM2.5 emission limit for the kiln in this project was established in accordance with BACT/PSD at 0.02 pounds per ton of clinker and 0.01 gr/dscf. These emission limits were to be met through a baghouse. The PM/PM10/PM2.5 emission limit for the clinker cooler in this project was established in accordance with BACT/PSD at 0.01 gr/dscf. This emission limit was to be met through a baghouse. The PM/PM10/PM2.5 emission limit for the
36 raw material handling operations and storage piles in this project was established in accordance with BACT/PSD at no limit but controlled with the use of water sprays and enclosures (which was estimated at 70% control efficiency). The PM/PM10/PM2.5 emission limit for the material handling, transport, and transfer sources in this project was established in accordance with BACT/PSD at 0.01 gr/dscf. This emission limit was to be met through a baghouse (which was estimated at 99% control efficiency).
RBLC ID: TX-0821 Date: June 13, 2017 Company: Alamo Cement Company Project: New dry process Portland cement kiln added at an existing facility.
PM/PM10/PM2.5 Emission Limits: The PM emission limit for the kiln in this project was established in accordance with BACT/PSD at 0.01 gr/dscf. This emission limit was to be met through a baghouse. The PM10/PM2.5 emission limit for the kiln in this project was established in accordance with BACT/PSD at 0.02 gr/dscf. This emission limit was to be met through a baghouse. The PM emission limit for the clinker conveying and storage in this project was established in accordance with BACT/PSD at 0.01 gr/dscf. This emission limit was to be met through a baghouse. The PM10/PM2.5 emission limit for the clinker conveying and storage in this project was established in accordance with BACT/PSD at 0.02 gr/dscf. This emission limit was to be met through a baghouse. The PM/PM10/PM2.5 emission limit for the raw material handling in this project was established in accordance with BACT/PSD at no limit but controlled with the use of water sprays and full or partial enclosures (which was estimated at 70% control efficiency). The PM/PM10/PM2.5 emission limit for the finish mill heater in this project was established in accordance with BACT/PSD at 0.01 gr/dscf. This emission limit was to be met through a baghouse.
RBLC ID: CO-0074 Date: July 09, 2012 Company: GCC Rio Grande, Inc. Project: Modify process at an existing facility.
PM/PM10/PM2.5 Emission Limits: The PM10 emission limit for the kiln in this project was established in accordance with BACT/PSD at 0.58 pounds per ton of clinker (12-month rolling average). This emission limit was to be met through the use of fabric filters.
RBLC ID: IL-0111 Date: December 20, 2011 Company: Universal Cement Project: Construction of a new 1.25 mmton/yr dry process Portland cement plant.
PM/PM10/PM2.5 Emission Limits: The filterable PM emission limit for the kiln in this project was established in accordance with BACT/PSD at 0.01 pounds per ton of clinker (30-day rolling average). This emission limit was to be met with a baghouse. The total PM and PM10 emission limit for the kiln in this project was established in accordance with BACT/PSD at 0.14 pounds per ton of clinker (3-hour). This emission limit was to be met through a baghouse. The filterable PM
37 emission limit for the clinker cooler in this project was established in accordance with BACT/PSD at 0.01 pounds per ton of clinker (30-day rolling average). This emission limit was to be met through a baghouse. The total PM and PM10 emission limit for the clinker cooler in this project was established in accordance with BACT/PSD at 0.01 pounds per ton of clinker (3-hour). This emission limit was to be met through a baghouse.
RBLC ID: GA-0136 Date: January 27, 2010 Company: Cemex Southeast, LLC Project: Construction of a new preheater/pre-calciner Portland cement plant rated at 3800 tons per day clinker. The new plant was to be constructed at the existing Cemex Clinchfield, Houston County, Georgia site.
PM/PM10/PM2.5 Emission Limits: The PM emission limit for the kiln in this project was established in accordance with BACT/PSD at 0.153 pounds per ton of clinker. This emission limit was to be met through a fabric filter/baghouse. The PM10 emission limit for the kiln in this project was established in accordance with BACT/PSD at 0.129 pounds per ton of clinker. This emission limit was to be met through a fabric filter/baghouse. The PM fugitive emission limit for the finish mill in this project was established in accordance with BACT/PSD at 0.01 gr/dscf and 0.0085 gr/dscf. These emission limits were to be met through a baghouse.
6.2.3. Particulate Matter Sources There will be 22 point sources of PM/PM10/PM2.5 emissions associated with the proposed plant and several sources of fugitive particulate matter emissions. The major particulate matter emission points will be the baghouses and stacks exhausting the kiln/raw mill/clinker cooler, the finish mill and the coal mill. The remaining 19 emission points that are associated with material handling/transport equipment will have PM/PM10/PM2.5 emissions controlled by smaller baghouses.
6.2.4. Description of Particulate Matter Control Technologies A summary of available particulate matter control technologies and their associated control efficiencies are listed in Table 4. These techniques include the following:
• Precleaners (including cyclones),
• Scrubbers,
• Electrostatic Precipitators,
• Fabric Filters (Baghouses), and
• Work Practice Standards for Fugitive Particulate Matter Emissions.
38 Table 4. Summary of Available Particulate Matter Control Technologies and Associated Control Efficiency and Technical Feasibility Proven and Technically Proposed Technology for Ranking Based on Control Technology Control Efficiency Feasible? the US Cement Kiln? Efficiency (Y/N) (Y/N) Precleaners Cyclones have efficienciess up to ~90%, however in the Portland cement industry they are used only for (including cyclones) material recovery as they did not have the efficiencies required to meet today's regulatory requirements.. Scrubbers are not used for air pollution control in the cement industry as they negate the opportunity to Scrubbers return valuable product back to the production process, and they create a water management problem which is foreign to most cement plants. ESPs were previously used to control PM emissions from kilns and clinker coolers. However, with the Electrostatic promulgation of new federal PM emission standards (0.002-0.004 gr/dscf) it has been determined ESPs Precipitators (ESPs) cannot reliably provide the necessary control efficiency. Fabric Filters 99+% Y 1 Y (baghouses) Work Practices for 50-90+% Y 1 Y Fugitive Emissions
The various types of control techniques, some of which are obviously not practical for cement plant application, are described below.
(a) Precleaners This type of technology reduces the inlet loading of PM to downstream collection devices by removing larger particles. Precleaners include cyclones, mechanically-aided separators, momentum separators and settling chambers. Cyclones are widely used in the cement industry for product recovery and in some cases, to reduce the dust loading to baghouses. These devices are not, however, used for air pollution control as they lack the efficiencies to meet today’s regulatory requirements.
(b) Scrubbers Scrubbers remove PM/PM10 and various gases from a gas stream. The pollutants are removed primarily through the impaction, diffusion, interception, and/or absorption of the pollutant onto droplets of liquid. The liquid containing the pollutant is then collected for disposal.
Scrubbers are not used in the cement industry for particulate matter control however, as baghouses can provide a higher control efficiency and can operate at a lower cost and with less maintenance. Also, collecting particulate matter wet in a scrubber would negate the opportunity to return the collected particulate matter (dry) to the process. And finally, the use of scrubbers for particular matter control would create a water management/disposal problem that is foreign to a dry-process Portland cement plant.
(c) Electrostatic Precipitators Electrostatic precipitators (ESP) have been used control particulate matter emissions from kiln/raw mill and clinker cooler exhaust gas streams, however with the promulgation of current NSPS, NESHAP and CISWI particulate matter regulations, it is been found that ESPs cannot reliably and
39 routinely provide the efficiencies necessary to meet these standards. As a result, some Florida plants have removed ESPs and replace them with high efficiency baghouses.
(d) Fabric Filters In a fabric filter or baghouse, gas is passed through fabric, causing particulate matter in the gas stream to be collected on the fabric by sieving and other mechanisms. Fabric filters may be in the form of sheets, cartridges, or bags, with a number of individual fabric filter units housed together in a group. The bag configuration is most common for larger baghouses while cartridges are common in smaller baghouses; such as those used on bin vents in the cement industry.
Fabric filters can be made of many different types of materials. The most common bag material used in baghouses employed on kiln/raw mill, clinker cooler and cement finish mill gas streams is a fabric coated with a Teflon-type membrane. These membrane coated fabrics have sub-micron pore sizes making materials extremely effective for particulate matter control.
The type of fabric is based on the operating conditions. Cleaning intensity and frequency are important variables in determining removal efficiency. The dust cake created on the surface of the fabric provides a significant portion of the fine particulate removal efficiency. Therefore, cleaning that is too frequent or too intense will reduce the fine particulate removal efficiency. Also the cleaning cannot be too infrequent or too ineffective because this will increase the pressure drop.
Baghouses are typically categorized by their cleaning method. The different types of cleaning methods of baghouses include shaker cleaning, reverse-air, and pulse-jet.
(e) Work Practice Standards for Fugitive Particulate Matter Emissions The fugitive particulate matter emissions associated with the US Cement plant and quarry include emissions from truck travel at the plant site and in the quarry, the primary crushing of limestone in the quarry and the handling and conveying of limestone during transport from the quarry to the plant site. The document entitled Emission Inventory, US Cement, LLC, Clinchfield, Houston County, Georgia, September 18, 2019 and submitted to the Georgia EPD on September 18, 2019 as part of this permitting process describes in detail the fugitive particulate matter emission sources associated with the US Cement plant and quarry.
Work practices that will be employed to control fugitive particulate matter emissions generated by truck travel on paved roads within the plant site will include roadway sweeping on a scheduled basis. Fugitive particulate matter emissions generated by the travel of off-road haul trucks in the quarry will be control by the inherent moisture and characteristics of surface material on the haul road, and by watering by water truck as needed.
The limestone, as mined, will have a moisture content in excess of six percent based on boring data. At this moisture content, the limestone is saturated (see above referenced Emission Inventory document) and as such, the generation of fugitive particulate matter emission during the handling,
40 primary crushing and transport of the limestone will be minimized. The inherent moisture content of the limestone (resulting in the saturation of the limestone) will be the means of controlling fugitive particulate matter emissions from activities associated with limestone handling.
6.2.5. Particulate Matter BACT Selection (a) Cement Kiln, Clinker Cooler and Coal Mill The proposed BACT emissions limit for the kiln/raw mill/clinker cooler is the particulate matter emission limiting standard for new kilns of 40 CFR 63, Subpart LLL. This standard limits particulate matter emissions from the pyroprocessing system to 0.02 pounds per ton of clinker, averaged over all kiln operating hours within 30 consecutive kiln operating days, excluding periods of startup and shutdown. This production-based particulate matter emission limiting standard is equivalent to a concentration-based standard of 0.002 grains per dry standard cubic foot, at stack gas oxygen concentration.
The kiln specific particulate matter emission limit, accounting for gas flow from the clinker cooler and accounting for the fraction of kiln gas that is exhausted through the coal mill, is to be determined in accordance with Equation 2 of 40 CFR 63.1343(b) as follows:
Table 5. Kiln Specific PM Emission limit from 40 CFR 63, Subpart LLL Stack Gas Flow Stack Gas Flow P ** Unit alt (dscfm) (dscf/ton Feed)* (lb/ton Clk) Kiln/Cooler/Raw Mill 282,762 73,696 0.0347 Kiln/Raw Mill 240,348 62,641 Cooler 42,414 11,054 Coal Mill 9,727 2,535 0.0012 Total 292,489 76,231 0.0359 * - Kiln Feed at 1.1 mmtpy Clinker and a 90% operating factor = 230 tph (140 tph Clk) ** - Palt = (0.002*1.65)*(Qkiln + Qclk cooler + Qcoal mill)/7000 (40 CFR 63.1343(b))
These kiln and coal mill specific particulate matter emission limits are emission limits for particulate matter with all particulate matter presumed to be PM10. As documented in the Emission Inventory submittal referenced above, the PM2.5 fraction of the kiln/raw mill/clinker cooler particulate matter emissions is 38.4 percent and the PM2.5 fraction of the coal mill particulate matter emissions is 11.9 percent. The particulate matter emission limits from the kiln/raw mill/clinker cooler and the coal mill will be met using high efficiency fabric filters. The specifications for these systems will be provided when available. Based on operating experience at other modern cement plants, assurance can be been provided that the proposed BACT limit for PM/PM10 is achievable.
The baghouse is a top-ranked technique based on control efficiency, technical feasibility, and proven technology. The baghouse will achieve more than 99 percent control of PM/PM10 emissions from the kiln/raw mill/clinker cooler and the coal mill. The proposed emission limit is 41 reasonable based on the most recent BACT determinations listed on the Clearinghouse and the proposed control technology is reasonable based on the control technologies listed on the Clearinghouse for this type of process.
(b) Finish Mill and Material Handling Equipment The only add-on control technology that is listed on the Clearinghouse for finish mills material handling sources at cement plants is baghouses. Baghouses can achieve very high control efficiency (greater than 99%). Any additional add-on control techniques would be very costly based on the control that the baghouses alone can achieve. Therefore, as baghouses are the only proven control technology for these types of sources and since they can achieve very high control efficiencies, baghouses are justified as BACT for this source group. The proposed BACT emission limit for particular matter, with all particulate matter presumed to be PM10, is 0.004 gr/dscf. The parameters of the 20 emission points where baghouses will be used for particulate matter control are presented in Table 6. The final baghouse specifications will be provided when available.
Table 6. Emission Point Parameters for PM Control by Fabric Filter Dust Collectors Gas Flow Temperature Moisture PM10 PM2.5 No. Source Description ACFM DSCFM (⁰F) (%) (gr/dscf) (fraction) STK1 Raw Mill Bucket Elevator 8,000 6,208 200 3.0 0.004 12.1% STK2 Raw Mill Rejects Bin 6,000 4,656 200 3.0 0.004 12.1% STK3 Raw Meal Transport 1,000 776 200 3.0 0.004 12.1% STK4 Filter Dust Surge Bin 6,000 4,043 300 3.0 0.004 12.1% STK5 Raw Meal Silo 22,000 17,072 200 3.0 0.004 12.1% STK6 Raw Meal Mixing Bin 4,000 3,104 200 3.0 0.004 12.1% STK7 Kiln Feed Transport 1,000 776 200 3.0 0.004 12.1% STK8 Clinker Transport 3,000 2,022 300 3.0 0.004 1.3% STK9 Clinker Silo No. 1 6,500 4,380 300 3.0 0.004 1.3% ST10 Clinker Silo No. 2 4,000 2,696 300 3.0 0.004 1.3% ST11 Clinker Silo Extraction No. 1 600 466 200 3.0 0.004 1.3% ST12 Clinker Silo Extraction No. 2 600 466 200 3.0 0.004 1.3% ST13 Cement Mill Bucket Elevator 8,000 6,208 200 3.0 0.004 29.8% ST14 Cement Silo No. 2 12,000 9,312 200 3.0 0.004 29.8% ST15 Cement Silo No. 1 12,000 9,312 200 3.0 0.004 29.8% ST16 Cement Silo Bulk Loading No. 2 3,000 2,328 200 3.0 0.004 29.8% ST17 Cement Silo Bulk Loading No. 1 3,000 2,328 200 3.0 0.004 29.8% ST18 Fine Coal Bin 800 621 200 3.0 0.004 11.9% ST19 Packing Plant 12,000 9,312 200 3.0 0.004 29.8% S20A Finish Mill 35,098 25,983 219 4.8 0.004 29.8% S20B Sepol 129,291 107,598 144 4.8 0.004 29.8% S20C Dust Shuttle Bin 6,000 4,656 200 3.0 0.004 12.1% ST21 Coal Mill 2 11,706 9,727 170 11.0 0.0012 11.9% ST22 Kiln/Cooler/Raw Mill 3 379,052 282,762 250 12.5 0.0347 38.4%
(c) Fugitive Particulate Matter Emissions As described in a preceding section, fugitive particulate matter emissions associated with this project include emissions from truck travel at the plant site and in the quarry, the primary crushing of limestone in the quarry, and the handling and conveying of limestone during transport from the quarry to the plant site.
42 The work practices that will be employed to control fugitive particulate matter emissions generated by truck travel on paved roads within the plant site will include roadway sweeping on a scheduled basis. Fugitive particulate matter emissions generated by the travel of off-road haul trucks in the quarry will be control by the inherent moisture and characteristics of surface material on the haul road, and by the application of water as needed.
The limestone, as mined, will have a moisture content in excess of six percent based on boring data. At this moisture content, the limestone is saturated and as such, the generation of fugitive particulate matter emission during the handling, primary crushing and transport of the limestone will be minimized. The inherent moisture content of the limestone (resulting in the saturation of the limestone) will be the means of controlling fugitive particulate matter emissions from activities associated with limestone handling.
6.2.6. Summary Fabric filter dust collector (baghouses) will be used to control particular matter emissions from all point sources in the proposed US Cement plant. The baghouse is the top-ranked particulate matter control technique based on control efficiency, technical feasibility, and proven technology within the Portland cement industry. Baghouses will achieve control efficiencies of greater than 99 percent reliably and consistently on all of the sources of particulate matter within the US Cement plant. There are no other particulate matter control options comparable to baghouses.
The BACT PM10/PM2.5 emission limit proposed for the kiln/raw mill/clinker cooler and the coal mill of eqn. 2 of NESHAP Subpart LLL (equivalent to 0.02 pounds of particulate matter per ton of clinker for each kiln and cooler) for new kiln systems and is equivalent to the most stringent BACT determination imposed on kiln systems in Portland cement plants over the past 10 years.
The proposed particulate matter BACT PM10/PM2.5 limit for the emission points outside of the kiln system of 0.004 grains per dry standard cubic foot is more stringent than other BACT emission limits imposed on comparable sources at new or modified Portland cement plants over the past 10 years.
The work practices proposed to control fugitive particulate matter emissions from the plant site and quarry are consistent with work practices in other new, modern Portland cement plants and will control fugitive emissions to the degree necessary to assure compliance with applicable ambient air quality standards and to prevent nuisance conditions from affecting off-site receptors.
6.3 Sulfur Dioxide SO2 emissions from a modern, dry-process Portland cement plant result from organic or thermally unstable inorganic sulfur compounds in raw materials in the raw meal fed to the pyroprocessing system. It is pretty much universally accepted, as will be discussed in the following sections, that no significant amount of fuel sulfur is released to the atmosphere in the form of SO2. The fuel sulfur is adsorbed by raw materials in the calciner and/or lower sections of the preheater and is
43 cycled back to the kiln with the sulfur in the forms of calcium, magnesium and/or alkali compounds in the clinker.
As a result of this behavior of sulfur in the pyroprocessing system, the effective control technologies for reducing SO2 emissions to the atmosphere are add-on technologies such as wet scrubbing and dry sorbent injection used alone or in conjunction with the management of raw materials; with the latter directed toward the goal of using raw materials with acceptable levels of organic and or thermally unstable in organic sulfur compounds. For this project, material management alone is being proposed for SO2 emission control. Boring data for on-site materials showed that the organic and thermally unstable inorganic sulfur compounds in the limestone (approximately 80 percent of the raw feed to the pyroprocessing system) is that nondetectable levels. Organic and/or thermally unstable inorganic sulfur compounds do exist at variable levels (from non-detectable to three percent) in clays and/or Fullers earth that are mined on-site, however the sulfur levels in these materials can either be managed at levels consistent with the proposed Best Available Control Technology (BACT) SO2 emission limit of 0.4 pounds per ton of clinker, 30 operating day rolling average, or the on-site mined materials can be replaced with imported substitute raw materials having acceptable concentrations of organic and/or thermally unstable inorganic sulfur compounds.
In the following sections, the BACT for SO2 is stated, and then followed by the justification for the BACT emission limit and control technologies selected.
6.3.1. Proposed BACT The proposed BACT SO2 emission limit for the kiln/raw mill/cooler emission point is 0.4 pounds of SO2 per ton of clinker, 30 kiln-operating day rolling average. This proposed SO2 BACT emission limit is the emission limit established for new Portland cement plants by New Source Performance standards for Portland cement plants codified at 40 CFR 60, Subpart F. This BACT emission limit is also consistent with the most stringent BACT determinations imposed on Portland cement plants during the past 10 years.
The proposed BACT control technology proposed to achieve this SO2 emission limit is the inherent adsorption of SO2 by the limestone and alkalis in the raw material, raw material management to minimize as much as necessary the organic and or thermally unstable inorganic sulfur content of raw materials, and good kiln operating practices.
In the following sections, federal regulations applicable to SO2 emissions from new Portland cement plants are cited; SO2 BACT determinations for Portland cement plants made over the past 10 years and listed in the EPA RACT/BACT/LAER Clearinghouse (RBLC) are reviewed; the behavior of sulfur in the pyroprocessing system is discussed; and applicable SO2 emission control technologies are evaluated.
44 6.3.2. Federal Regulations Limiting SO2 Emission Rates and Recent BACT Determinations (a) Federal Regulations The permitted SO2 emission limiting standards for the US Cement plant will be based on a BACT determination. The BACT emission standard will be at least as stringent as promulgated federal emission limiting standards for SO2 from Portland cement plants; and possibly more stringent depending upon the BACT determination. In the following paragraphs, federal regulations potentially applicable to the US Cement plant will be summarized, as will BACT determinations establishing SO2 emission limits for Portland cement plants made over the past 10 years.
The US Cement plant will be subject to New Source Performance Standard (NSPS) emission limits for plants commencing construction after June 16, 2008 (new plants) as codified at 40 CFR 60, Subpart F - Standards of Performance for Portland Cement Plants. Additionally, depending on how US Cement plans to categorize the new plant; i.e., as a conventional fuel burning plant, or a plant operated as an industrial solid waste incinerator, the plant will be subject to either National Emission Standards for Hazardous Air Pollutants (NESHAP) rules or to Commercial and Industrial Solid Waste Incinerator (CISWI) rules. The NESHAP rules for plants that commence construction after May 6, 2009 (new plants) are codified at 40 CFR 63 , Subpart LLL - National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry and the CISWI rules for plants that commence construction after June 4, 2010 (new plants) are codified at 40 CFR 60, Subpart CCCC -Standards of Performance for Commercial and Industrial Solid Waste Incineration Units .
The SO2 emission limiting standards imposed by each of these three federal regulations are summarized in Table 7.
Table 7. Federal SO2 Emission Limiting Standards Potentially Applicable to US Cement Waste Burning Kiln NESHAP Kiln NSPS Kilns Basis of Emission Basis of Emission Basis of Emission Pollutant 40 CFR 60, Subpart 40 CFR 63, Subpart Limit Limit 40 CFR 60, Subpart F Limit CCCC LLL 28 ppmvd @ 7% O2 Rule 0.4 lb/ton Clk, SO2 30-day avg No Rule Limit -- Rule 30-operating day average 0.30 lb/ton Clk* Equivalent to Rule * - Based on an Estimated Stack Gas Flow Rate of 65,000 dscf/ton Clinker @ 7% O2.
(b) Recent BACT Determinations The EPA RACT/BACT/LAER Clearinghouse (RBLC) was reviewed for BACT determinations made over the period 2009-2019 that would limit SO2 emissions from Portland cement plants that were subject to PSD. The following determinations were found:
RBLC ID: IN-0312 Date: June 26, 2019 Company: Lehigh Cement Company, LLC
45 Project: Add new preheater/pre-calciner cement kiln with a rated throughput of 7716 tons of clinker per day at an existing facility. The kiln system consists of 15-stage preheater, calciner and rotary kiln. Emissions are controlled by the Kiln Baghouse, low NOx burners, SNCR, and an activated carbon system. The kill uses natural gas, coal, coke, fuel oils and/or non-hazardous fuels (chips and tires, whole tires, engineered fuels, dried bio-solids, high-carbon fly as you and other biomass fuels.
SO2 Emission Limit: The SO2 emission limits for this project was not subject to BACT; the limit was established to avoid PSD review
RBLC ID: KS-0031 Date: July 14, 2017 Company: Ash Grove Cement Company Project: Modification of an existing 4800 ton per day (clinker) dry process Portland cement Plant.
SO2 Emission Limit: The SO2 emission limit for this project was not subject to a BACT determination. The existing SO2 emission limit of 1.20 pounds per ton of clinker was retained following the modification project.
RBLC ID: TX-0822 Date: June 30, 2017 Company: Capitol Aggregates, Inc. Project: New dry process Portland cement kiln added at an existing facility.
SO2 Emission Limit: The SO2 emission limit for this project was established in accordance with BACT/PSD at 0.40 pounds per ton of clinker.
RBLC ID: TX-0639 Date: 2013 Company: Cemex Construction Materials South, LLC Project: Modification of an existing kiln resulting in a significant emission rate increase.
SO2 Emission Limit: The SO2 emission limit for this project was established in accordance with BACT/PSD at 1.0 pounds per ton of clinker.
RBLC ID: IL-0111 Date: December 20, 2011 Company: Universal Cement Project: Construction of a new 1.25 mmton/yr dry process Portland cement plant.
SO2 Emission Limit: The SO2 emission limit for this project was established in accordance with LAER requirements at 0.4 pounds per ton of clinker. This emission limit was to be met through the inherent absorption of SO2 kiln dust and an add-on circulating fluidized-bed absorber, or equivalent as the SO2 control method.
RBLC ID: GA-0136
46 Date: January 27, 2010 Company: Cemex Southeast, LLC Project: Construction of a new preheater/pre-calciner Portland cement plant rated at 3800 tons per day clinker.
SO2 Emission Limit: The SO2 emission limit for this project was established in accordance with BACT/PSD at 1.0 pounds per ton of clinker. This emission limit was to be met by the judicious selection of raw materials. A hydrated lime injection system would be used, as necessary to supplement material selection. It should be noted that this BACT determination by the Georgia EPD was identical to a determination made in 2008 or 2009 for a new, grass-roots preheater/pre- calciner Portland cement plant also proposed for a site in Houston County, Georgia
6.3.3. Sulfur Behavior in Dry-process Pyroprocessing Systems SO2 can be generated from organic or thermally unstable inorganic sulfur compounds in the raw material fed to the pyroprocessing system and from sulfur in the fuel. It is generally agreed that very little of the fuel sulfur is released from the stack as SO2. The fuel sulfur is adsorbed by raw materials in the calciner or the preheater and are cycled back to the kiln with virtually all of the fuel sulfur exiting the kiln in the clinker. Thus, virtually all of SO2 emissions from a modern preheater-calciner designed cement plant are from the sulfur compounds in the raw materials. The behavior of sulfur in the pyroprocessing system of a modern, dry process Portland cement plant is discussed in the following paragraphs. Sulfur is introduced into the pyroprocessing system with fuels and the raw materials that compose the kiln feed (raw meal). The forms of sulfur and path of introduction have an influence on the fate of the sulfur (i.e. whether it is captured and incorporated into the clinker or whether it is emitted as SO2).
The kiln feed is composed of several components. The major components are mined on-site and include limestone (nominally 80 percent of the raw meal) and sand/clays (nominally 20 percent of the raw meal). Imported raw materials include iron oxide component (e.g., mill scale or iron ore) and possibly bauxite (nominally two percent of the raw meal). The chemistry of the raw meal is determined using a continuous on-line analysis and is critical in maintaining kiln stability and clinker quality. The limestone mined at the US Cement site, and the iron oxide component and bauxite have been measured to have nondetectable levels of organic and thermally unstable inorganic sulfur.
Sulfates are stable at preheater/pre-calciner temperatures, do not result in emissions of SO2, and pass into the rotary kiln to become part of the clinker. Disulfides decomposes at lower stage preheater temperatures and form SO2 which may be captured in the upper preheater stages, in the grinding mill, or in the fabric filter. The sulfate formed is returned with the kiln feed as non-SO2 forming sulfur species. Sulfides in the raw meal behave in a similar manner to disulfides. Studies by the PCA and others have shown that 15-40 percent of the organic and thermally unstable inorganic sulfur compounds in the raw meal can produce SO2 in the preheater/pre-calciner section of a modern, dry process Portland cement plant.
47
Addition of calcium hydroxide [Ca(OH)2] into the upper stage of the preheater enhances the natural capture of SO2 released from the decomposition of sulfur compounds with calcium oxide dust recirculating from the pre-calciner to the top preheater stages. In effect, the preheater both generates SO2 from kiln feed and captures SO2 in an internal adsorption process depending on material temperature and preheater stages. Sulfur is also introduced into the pyroprocessing system through fuel in the pre-calciner (nominally 55 percent of the pyroprocessing system heat input) and main kiln burner (nominally 45 percent of the heat input). Sulfur in fuel can be present as sulfates, pyrites, and organic forms. During combustion the mineral forms decompose at flame temperature in an oxidizing atmosphere forming SO2 and a minimal amount of SO3.
Sulfur dioxide formed in the main burner is reacted with alkali (Na2O and K2O) and calcium oxides and is incorporated in the clinker or emitted as alkali sulfates (Na2 SO4 and K2 SO4). SO2 is highly soluble in the liquid phase of the clinker and converts to sulfates in the clinker product. Sulfur dioxide formed by combustion of fuel in the pre-calciner is reacted with calcium and magnesium oxides released during decarbonization. The calcined meal is in direct contact with the combustion gases at optimum reaction temperatures in an oxidizing atmosphere. This SO2 forms anhydride calcium and/or magnesium sulfate in solid form (e.g., dust) and either passes into the kiln to be incorporated into the clinker or is blown back through the raw mill system where it is reincorporated into the raw meal and reintroduced to the pyroprocessing system at the top of the preheater. The sulfide and sulphite sulfur in the raw meal decomposes as the meal is progressively heated through the four stages of the preheater and into the pre-calciner. Reactions that occur are:
Disulfide 2 FeS2 + 5 ½ O2 → FeO3 + 4 SO2
Sulphite 4 CaSO3 → CaS + 3 CaSO4 CaS + ½ O2 → CaO + SO2
Organic Sulfur S + O2 → SO2
The sulphite decomposition occurs between 370 and 4200 C and sulfides decomposition occurs between 500 and 6000 C; temperatures that occur in the upper stages of the preheater.
0 Capture of SO2 occurs above 400 C in the preheater with calcium carbonate and calcium oxide by the following reactions: CaCO3 + SO2 + 1 ½ O2 → CaSO4 + CO2 CaO + SO2 + ½ O2 → CaSO4
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SO2 not captured in the preheater is partially captured in the raw mill as the gas temperatures decreases and water in the limestone is released during drying. These reactions are: CaCO3 + 2H2O + SO2 + ½ O2 → CaSO4 -2H2O + CO2 CaO + SO2 + ½ O2 → CaSO4 Ca(OH)2 + SO2 +½ O2 → CaSO4 – ½ H2O + ½ H2O These sulfur species are returned to the raw meal as sulfates which are stable at preheater temperatures and pass through the pre-calciner into the kiln. Several papers have been published that describe the sulfur cycle in preheater/pre-calciner kilns that conclude that SO2 emissions are the result of sulfides and sulfites in raw meal and not the result of sulfur in kiln fuels.
The Portland Cement Association (PCA) published a detailed thesis on this subject entitled “Formation and Techniques for Control of Sulfur Dioxides and other Sulfur Compounds in Portland Cement Kiln Systems” (PCA R&D serial No. 2460) in 2001. This document provides a thorough literature review of articles published concerning sulfur behavior in the pyroprocessing system. A list of referenced documents is provided in the PCA publication that support the conclusion that SO2 emissions are independent of fuel sulfur.
An earlier paper was published in 1991 in Cemtech entitled “Possibilities of SO2 Reduction in the Cement Industry by Sorption Processes”. This paper describes the formation of SO2 from sulfur in raw meal and indicates that fuel sulfur is retained in the clinker. The conclusion in this paper also indicates that SO2 from fuel combustion can only occur in an upset condition when the kiln is operating in a reduced oxygen condition. This condition is not consistent with formation of clinker and is avoided in the clinker manufacturing process.
The conclusions reached in these two referenced papers are vividly demonstrated by actual SO2 emission data from modern dry process Florida kilns. In Florida, operators are fortunate to have on-site mined raw materials, and imported additives (e.g. mill scale and/or bauxite) with virtually no organic or thermally unstable inorganic sulfur compounds; e.g., virtually all of the sulfur introduced to the pyroprocessing systems is the result of fuel sulfur. Table 8 shows the calculated inherent control efficiencies for fuel generated SO2 in kilns in Florida.
Table 8. Capture Efficiency of Fuel SO2 in Dry Process Florida Portland Cement Plants
Parameters Year Kiln 1 Kiln 2 Kiln 3 Kiln 4 Kiln 5
2011 1.8 4.4 29.1 10.0 3.2
Annual SO2 2012 1.3 2.0 29.5 5.6 5.5 Emissions (TPY) 2013 0.2 4.4 19.0 7.0 6.8 2014 0.1 3.3 19.0 9.9 6.6
49 Parameters Year Kiln 1 Kiln 2 Kiln 3 Kiln 4 Kiln 5
2011 889.2 969.0 1180.8 1728.9 811.9 Potential 2012 992.9 1100.6 1215.5 1502.9 1057.5 Emissions of Fuel 2013 1076.3 1073.4 1475.5 1824.5 916.9 Sulfur as SO2 (TPY) 2014 1512.0 -- 1878.9 2872.3 1522.7 2011 99.80 99.55 97.54 99.42 99.61 2012 99.87 99.82 97.63 99.63 99.48 Fraction of Sulfur 2013 99.98 99.59 98.73 99.62 99.26 Retained in 2014 99.99 -- 99.00 99.66 99.57 Clinker (%) Avg. 99.91 99.65 98.24 99.58 99.48 Avg. 99.37
These actual data confirm the conclusions of the PCA and Chemtech papers by demonstrating that, on average well over 99 percent of the fuel sulfur is retained in the clinker product. In reviewing these data, it should be recognized that the SO2 emissions do include trace amounts of SO2 generated by raw materials; thus causing the removal of fuel generated SO2 to be conservatively understated. It should also be noted that these data represent kilns from North, Central and South Florida; the data represent kilns fired with a single fuel or a combination of fuels including petroleum coke (4-5 percent sulfur), coal (nominally one percent sulfur), alternative fuels with variable sulfur contents, and natural gas; the data represent preheater kilns and preheater/precalciner kilns of the FL Schmidt and Polysius designs; and the data represent 20 years of kiln operations. Thus, it is quite apparent from the broad range of conditions represented by this data set that the 99+ percent removal of fuel generated SO2 is a fact; not an isolated perturbation.
In reviewing the data in the first broad row of Table 8, it will be noted that all of the reported annual SO2 emission rates are less than the PSD defined Significant Emission Rate for SO2 of 40 tons per year. These annual SO2 emission rates represent a production-based SO2 emission rate in the range of 0.03 pounds of SO2 per ton of clinker. As a side note, because the SO2 emission rates from all Florida kilns have consistently been extremely low, the Florida Department of Environmental Protection (FDEP) has removed the continuous emission monitoring requirement for SO2 from all Florida cement plant permits; allowing compliance with permitted SO2 emission limits to be demonstrated by a single annual test.
The physical process of fuel sulfur generated SO2 in dry process Portland cement plants can be compared to that which occurs in a fluidized bed boiler. In a fluidized bed boiler, solid fuel containing sulfur is combusted with the addition of limestone to capture and control potential SO2 emissions. These boilers routinely demonstrate sulfur removal efficiencies of greater than 98 percent when burning hi-sulfur fuels. Combustion temperatures are typically in the range 850-9500 C and calcium to sulfur ratios typically between 3 and 3.5.
50
The conditions in the preheater section of a modern dry-process Portland cement plant include a temperature range of 400-900⁰C and a calcium/sulfur ratio of 700-800. At the high calcium/sulfur ratio in cement plants, it can be concluded that virtually no fuel generated SO2 is emitted to the atmosphere.
Based on this review of raw material sulfur and fuel sulfur behavior in the pyroprocessing system of a modern, dry-process Portland cement plant, it can be concluded that SO2 emissions can effectively be controlled by controlling the organic and thermally unstable inorganic sulfur compounds in the raw meal. Fortunately at the US Cement site, the on-site limestone which nominally constitutes 80 percent of the raw meal has non-detectable levels of these sulfur compounds. It is therefore incumbent on US Cement to judiciously select on-site mined sand and clays for use in the raw meal that are low in these types of sulfur compounds and/or to use imported substitute materials and additives that are likewise low in these types of sulfur compounds.
6.3.4. Description of SO2 Control Technologies A summary of the available SO2 control technologies are listed in Table 9, including the expected control efficiencies. These techniques include the following: • Absorption, • Adsorption, and • Low sulfur raw materials. The expected control efficiencies for each of these technologies is discussed in detail in the following sections.
Table 9. Summary of Available SO2 Control Technologies and Associated Control Efficiency and Technical Feasibility Proven and Proposed Technology Control Ranking Based Control Technology Technically for the Cement Kiln? Efficiency (%) on Efficiency Feasible? (Y/N) (Y/N) Low-Sulfur Raw 0-100 Y 1 Y Materials Absorption Wet Scrubbing 75 Y 2 N Adsorption Dry Scrubbing 45 Y 3 Y
(a) Absorption Absorption is a mass transfer operation in which one or more soluble components of a gas mixture are dissolved in a liquid with a low volatility. The pollutant diffuses out of the gas into the liquid when the liquid has less than the equilibrium concentration of the gaseous component. The driving force for absorption is this difference between actual and equilibrium concentrations. Control devices that use absorption principles include packed towers, plate or tray columns, venturi scrubbers, and spray chambers.
51
Packed towers are columns that are filled with packing material that provide a large surface area. The large surface area allows for contact between the liquid and the gas. Packed towers can achieve higher removal efficiencies, handle higher liquid rates, and have relatively lower water consumption requirements than other types of gas absorbers. However, packed towers may also have high pressure drops, high instances of clogging and fouling, and high maintenance costs because of the packing material.
Plate, or tray, tower scrubbers are vertical cylinders where the gas and liquid come in contact in steps on trays or plates. The liquid enters at the top of the column and flows across each plate and through a downspout to the plates below. The gas stream flows upward through holes in the plates, bubbles into the liquid, and passes to the plate above. Plate towers are easier to clean and can handle large temperature fluctuations better than packed towers. However, at high gas flow rates, plate towers exhibit larger pressure drops and have higher liquid holdups.
Venturi scrubbers have a “converging-diverging” flow channel. The cross-sectional area of the channel decreases then increases along the length of channel, which increases the waste stream velocity and turbulence which improves the gas-liquid contact. The liquid droplets are then separated from the gas stream in an entrainment section. A venturi scrubber control efficiency is increased by increasing the pressure drop, which leads to higher operating costs.
Spray towers use a spray distribution system to deliver liquid droplets through a countercurrent gas stream under the influence of gravity. The droplets contact the pollutants in the gas stream. The required contacting power is derived from an appropriate combination of liquid pressure and flow rate. Spray towers are easy to operate and maintain and have low energy requirements. However, they have the least effective mass transfer capability of the absorbers and have high water recirculation rate requirements.
(b) Adsorption In an adsorption control system, a dry alkaline material or an alkaline slurry is injected into the gas stream. In the case of the alkaline slurry, the water evaporates leaving the dry alkaline material. SO2 is adsorbed to the surface of the alkaline particles. A reaction occurs that forms sulfur compounds that cannot be re-entrained into the gas stream. Hydrated lime (calcium hydroxide) is a common type of alkali and can be introduced at the top of the preheater for SO2 control if necessary.
(c) Low Sulfur Fuels and/or Raw Materials As discussed in the preceding section, SO2 emissions are independent of fuel sulfur. Hence, the sulfur content of fuels in a modern, dry-process Portland cement plant is irrelevant as far as SO2 emissions are concerned.
52 As further discussed in a preceding section, SO2 emissions from a modern, dry-process Portland cement plant are a function of organic sulfur and/or thermally unstable inorganic sulfur compounds in feed materials. Thus, if a high-sulfur component of the raw meal can be replaced with a compound with a low-sulfur content or no sulfur, the effect of this change will be directly proportional to the reduction in the mass of sulfur introduced to the pyroprocessing system.
6.3.5. SO2 Control Two factors must be taken into consideration when evaluating the efficacy of controlling SO2 emissions from the proposed US Cement kiln:
• The expected variability in the uncontrolled SO2 emission rate, and
• The magnitude of the uncontrolled SO2 emissions.
These two parameters are summarized in Table 10 for the proposed US Cement plant. The magnitude and variability of SO2 emissions are based on the sulfur contents of clay and Fullers earth found on-site through soil borings and the expected use of these materials in the raw meal that will be fired to the pyroprocessing system. The proposed SO2 emission rate of 0.4 pounds per ton of clinker, 30 operating day rolling average is included as a point of reference.
Table 10. Expected Magnitude and Range of SO2 Emissions from US Cement Kiln ppmvd @ mg/m3 @ lb/hr Expected SO2 Stack Stack lb/ton Clk @ 140 tph Emission Rate Conditions Conditions Clinker Average 35 93 0.82 115 Maxiuum 75 200 1.76 247 Minimum 5 13 0.12 16
At 0.4 lb/ton Clk 17 45 0.40 56
The data show that the SO2 emission rate resulting from the use of on-site raw materials, other than limestone, will result in a SO2 emission rate that, at times will exceed the proposed SO2 emission limit. When these times occur is unpredictable in the course of mining as the geographical distributions of sulfur contents of clays and/or Fullers earth are unpredictable.
As a result of the expected variability in the emission rate of SO2, the SO2 control options for the US Cement kiln will be used as necessary to meet the proposed SO2 emission limit on a continuing basis.
The other matter to note from the data in Table 10 is the magnitude of the expected uncontrolled SO2 emissions. From the standpoint of uncontrolled emissions from cement plants in general, the expected uncontrolled SO2 emissions from the US Cement plant are quite low. Uncontrolled SO2
53 emissions in the range of 5-6 pounds per ton of clinker are not uncommon, and a Heidelberg Cement report includes uncontrolled SO2 emission rates in excess of 20 pounds per ton of clinker.
Compared to these emission rates, the uncontrolled SO2 emissions from the US Cement kiln are expected to range from approximately 0.12-1.76 pounds per ton of clinker. For the proposed kiln, this is equivalent to approximately 5 - 75 ppm (13 – 200 mg/m3) SO2 in the stack gas (at stack conditions). To put these uncontrolled SO2 emissions from US Cement into perspective, European countries impose controlled SO2 emission limits ranging from 50 - 400 milligrams per normal cubic meter. Germany has the lowest limit at 50 milligrams per normal cubic meter, with other EU countries having limits ranging from 350-400 milligrams per normal cubic meter. Switzerland and Norway have a limits of 500 milligrams per normal cubic meter while the UK has a limit of 200 milligrams per normal cubic meter. In other words, the SO2 emission limits for EU cement plants range from a limit approximately 10 percent higher than the proposed US Cement limit of 0.4 pounds per ton of clinker to a limit that is approximately nine times higher than the proposed US Cement limit.
The magnitude of the uncontrolled emissions from the US Cement kiln are emphasized as SO2 control efficiencies decrease as the uncontrolled SO2 emissions decrease. As a result, the control efficiencies of add-on control options that might be considered for US Cement are going to be toward the lower and of performance efficiencies.
The fact that the expected uncontrolled SO2 emissions from the proposed US Cement kiln (emissions between 0.12 - 1.76 pounds per ton of clinker) equate to stack gas SO2 concentrations ranging from 5 - 75 ppm makes SO2 control more difficult than if the uncontrolled SO2 emissions were at higher concentrations. Because of the low uncontrolled SO2 concentrations, it has been estimated that the SO2 control efficiency with hydrated lime injection will be approximately 45 percent and the SO2 control achievable with limestone scrubbing will be approximately 75 percent as will be discussed further on.
To establish the effectiveness of sorbent injection and wet scrubbing for cement plants, several references on SO2 control in the cement industry were reviewed as were some references related to SO2 control using sorbent injection and wet scrubbing in the electric power industry. In the IEEE paper by Miller and Hansen(5) it is stated that hydrated lime injection at a molar ratio in the range of 3.0 – 5.0 is capable of reducing SO2 emissions by 45-70 percent, depending on the amount of SO2 released by pyritic sulfur. It is further stated that the optimum injection point for the hydrated lime is in the upper stages of the preheater tower; near the point where the pyritic sulfur is converted to SO2. Regarding the application of limestone scrubbing, it is stated that SO2 emission reductions in the range of 90-95 percent are achievable. However no reference is made to the uncontrolled SO2 concentrations for which either of these levels of control might be achieved.
54 In a reference document on Best Available control Techniques (BAT) for the cement and lime manufacturing industries, the European Integrated Pollution Prevention and Control Bureau (IPPC) discussed lime injection and wet and dry scrubbing as means of controlling SO2 emissions(2) . Regarding lime injection, it is stated that hydrated lime is the most effective form of lime and it is further stated that this material can either be added to the kiln feed or introduced in the upper stages of the preheater at molar ratios between 3.0 and 6.0. The document states that with hydrated lime injection and uncontrolled SO2 emissions no higher than 150 ppm (equivalent to ~3.5 pounds per ton of clinker), it is theoretically possible to achieve a controlled SO2 emission level of approximately 40 ppm (equivalent to ~0.9 pounds per ton of clinker). The paper goes on to state that no plant in Europe had actually achieved this level of reduction. It is stated that most European plants use lime injection to reduce uncontrolled SO2 emissions from the 450 ppm range (equivalent to ~10 pounds per ton of clinker) or higher down to a controlled SO2 emission level of approximately 150 ppm (equivalent to ~3.5 pounds per ton of clinker). With both wet and dry scrubbing, the European IPPC Bureau references uncontrolled SO2 stack gas concentrations in the range of 900 to 1200 ppm (~20-30 pounds per ton of clinker). With these concentrations of uncontrolled SO2, control efficiencies in the range of 90 percent are reported to be achievable with both wet and dry scrubbing.
In a Portland Cement Association publication on the formation and control of sulfur dioxide in cement plants(3) it is again stated that hydrated lime is the most effective reagent for dry scrubbing. The PCA states that 50-70 percent SO2 removal with molar ratios ranging from 2.5 – 4.0 has been observed; however, the paper does not reference the level of uncontrolled SO2 emissions. Regarding the application of wet scrubbers, the PCA references uncontrolled SO2 concentrations in the range 400-900 ppm. At these uncontrolled SO2 concentrations, the PCA reports wet scrubbing efficiencies in the range 80-95 percent.
A paper by the Polysius Corporation(4) cites the use of hydrated lime injection into the upper stages of the preheater. This paper also reports that hydrated lime is the most effective reagent. This paper reports that molar ratios between approximately 2.0 and 10.0 will result in SO2 reductions in the range of 20-80 percent with uncontrolled SO2 emissions in the range 450 ppm (approximately six times higher than the highest uncontrolled SO2 concentration expected from the proposed US Cement kiln). This paper also cites the use of a wet scrubber on a cement plant in Switzerland. This scrubber reportedly reduced stack gas SO2 concentrations from approximately 950 ppm to approximately 150 ppm; approximately an 85 percent reduction. But here, the controlled SO2 emissions are approximately twice the highest uncontrolled SO2 emissions expected from the US Cement kiln.
Probably the most applicable reference reviewed was a presentation prepared by the Heidelberg (5) Cement Group . The Heidelberg data relates SO2 control efficiency to the concentration of uncontrolled SO2 emissions. The information from this presentation is summarized in Figure 5; a figure taken from the Heidelberg presentation. In Figure 5, uncontrolled SO2 emission rates and
55 concentrations in ranges expected from the proposed US Cement kiln are superimposed on data developed by Heidelberg.
Figure 5. SO2 Control Efficiencies for Various Control Technologies
The Heidelberg data show that dry lime injection (dry additive) is normally applied when 3 uncontrolled SO2 concentrations are in the range 400-1200 mg/m (150-450 ppm). The lower range of application reported by Heidelberg is approximately twice the upper range of uncontrolled SO2 concentrations expected from the proposed US Cement kiln. In the applicability range reported by Heidelberg Cement, the SO2 control efficiencies achieved by lime injection are in the range 60-67 percent. These efficiencies are consistent with other references cited. In the uncontrolled SO2 concentration range expected from the proposed US Cement kiln however, the SO2 control efficiencies will be lower; in the 45 percent range.
For the application of wet scrubbers, the Heidelberg data show that scrubbers are typically not 3 employed unless uncontrolled SO2 concentrations are in the range of 1750-3300 mg/m (650-1250 ppm). In this uncontrolled SO2 concentration range, Heidelberg reports limestone scrubbing efficiencies in the range of 85-90 percent; efficiencies consistent with other references cited. At the uncontrolled SO2 concentration range expected from the proposed US Cement kiln (5-75 ppm), the efficiency of limestone scrubbing is in the range of 75 percent.
Two papers prepared by F.L. Smidth(6),(7) report results of hydrated lime injection trials. Both papers report that hydrated lime is the most effective reagent and that SO2 control efficiencies in the range of 50-90 percent were achievable when lime was injected into the upper stages of the preheater at molar ratios ranging from 3.0-6.0. In these trials, uncontrolled SO2 emissions were in
56 the range 10-12 pounds per ton of clinker (equivalent to 420-500 ppm uncontrolled SO2 concentrations from the proposed US Cement kiln).
The final document reviewed was a summary document prepared by EPA(8). The information provided in this document typically applies to coal and oil fired combustion sources although other types of facilities are referenced. This paper cites SO2 removal efficiencies by wet scrubbers in the range of 90 percent and greater. These efficiencies however are achieved with uncontrolled SO2 emissions in the range of 2000 ppm. The paper also references removal efficiencies by lime injection in the range of 50-60 percent with no reference to uncontrolled SO2 emissions. When comparing SO2 control technologies for oil and coal fired combustion units with the same technologies applied to cement plants, the differences in the two applications must be taken into consideration. For limestone scrubbing, the applications are comparable if uncontrolled SO2 concentrations are comparable. With lime injection, there are differences, however. With both combustion units and cement plants, lime can be injected at a point where the temperature for SO2 adsorption is optimized. The main difference however is that the inherent dust loading in a cement plant is 3-4 times the dust loading found in combustion units. In addition to the difference in dust loadings, the characteristics of the inherent dusts must also be taken into consideration. These differences are not addressed in detail here as sufficient information on the effectiveness of SO2 control in the cement industry has been presented. The differences are mentioned only to caution the transfer of control technology from the power industry to the cement industry without considering the differences in the two types of plants.
With the background for SO2 emission control established, the use of sorbent injection and wet scrubbing for controlling SO2 emissions will be addressed. Dry scrubbing could also have been addressed in detail, but SO2 control efficiencies and control costs of dry scrubbing will be close to the costs expected with wet scrubbing and it will be shown that wet scrubbing is not cost effective.
To calculate the cost of control with the limited data available on the organic sulfur and/or thermally unstable inorganic sulfur compounds in feed materials, simplifying assumptions had to be made based upon the data summarized in Table 10. Since the average expected uncontrolled SO2 emission rate from the US Cement kiln will be approximately 0.8 pounds per ton of clinker and the proposed SO2 emission limit for the kiln is 0.4 pounds per ton of clinker, it was presumed that on average, a 50 percent SO2 control efficiency would be required. Note however that the expected control efficiency expected from dry sorbent injection is only about 45 percent. Hence, if dry sorbent injection is proposed as a control technology, additional SO2 reduction will be required through the management of the organic sulfur and/or thermally unstable inorganic sulfur compounds present in on-site-mined materials or the importation of substitute raw materials. Note also that the fractional efficiency of add-on SO2 control technologies can be reduced, and possibly even be eliminated through the management of on-site mined raw materials containing organic sulfur and/or thermally unstable inorganic sulfur compounds and/or the importation of raw materials to replace theses on-site mined materials.
57 Referring to Table 11, the effectiveness of SO2 control and the cost of SO2 control by hydrated lime injection and wet scrubbing are summarized. It will be noted that the uncontrolled SO2 emissions range from 0.12-1.76 pounds per ton of clinker. This corresponds to a stack gas SO2 concentration range of 5-75 ppm. The actual uncontrolled SO2 emissions will be about 451 tons per year.
Table 11. Summary of SO2Table Control AE - SUMMARY Effectiveness OF SO2 CONTROL and EFFECTIVENESS Cost AND COST Average Controlled SO2 Emissions Fraction of Fraction of Fraction of Range of Uncontrolled SO2 Emissions Annual SO2 Cost of SO2 Controlled SO2 Annual SO2 Time Control Time SO2 Uncontrolled Emission Limit SO2 Conc Removed Removal ($/ton Emissions Actually Emission Limit SO2 Emissions System SO2) (lb/ton Clinker) Stk Gas Conc (ppm) Controlled Exceeded (tpy) (lb/ton Clinker) (ppm) (tpy) (tpy) Operates HYDRATED LIME INJECTION FOR SO2 CONTROL 0.12 1.76 5 75 451 0.4 17 248 203 45.0%* ~50% 0.0% $3,581 LIMESTONE SCRUBBING FOR SO2 CONTROL 0.12 1.76 5 75 451 0.4 17 226 226 50.0% ~50% 0.0% $23,136 * - The maximum expected control efficiency for lime injection, at the expected uncontrolled SO2 emission rates is 45 percent
Continuing across the table, data are presented for an SO2 emission limit of 0.4 pounds per ton of clinker. This corresponds to a stack gas SO2 concentration of 17 ppm. Data in the table further show that the uncontrolled SO2 that must be removed to comply with the 0.4 pound per ton emission limit is 226 tons per year in a typical year. As previously noted, the maximum SO2 control efficiency expected from sorbent injection is about 45 percent; hence, supplemental SO2 controlled by overall raw material management will be required if sorbent injection is proposed as a control technology.
To achieve the required level of SO2 control, the sorbent injection system will have to operate about 50 percent of the time annually and the cost for controlling the 203 tons per year of SO2 removed will be about $3,581 per ton of SO2. Cost calculation summaries for dry sorbent injection are included in Table 11.
Data in Table 11 present similar analyses for controlling SO2 emissions by wet scrubbing. As stated previously, the SO2 control efficiency with wet scrubbing is expected to average no better than 75 percent because of the low concentrations of uncontrolled SO2 emissions (i.e., less than 75 ppm). The data show that even though marginally higher SO2 emission control is achievable with wet limestone scrubbing, the SO2 control costs will the about $23,136 per ton (at an SO2 emission limit of 0.4 pounds per ton of clinker). This control cost is greater than what is considered a cost effective control measure. Cost calculation summaries for wet limestone scrubbing are included in Table 11.
In summary, it can be stated that SO2 emission control by sorbent injection is cost effective and can be expected to reduce SO2 emissions by approximately 45 percent. This level of control will not be totally adequate to achieve the proposed SO2 emission limit of 0.4 pounds of SO2 per ton of clinker on a continuous basis. As a result, and as the first level of SO2 emission control, SO2 emissions will be controlled through the management of raw materials constituting the raw meal fed to the pyroprocessing system. On-site mined raw materials containing organic sulfur and/or thermally unstable inorganic sulfur compounds will be selectively used and replaced, as necessary 58 by imported raw materials and with little or no organic sulfur and/or thermally unstable inorganic sulfur compounds.
The cost-effectiveness analyses also show that controlling SO2 emissions by wet scrubbing is not cost effective. The effectiveness and the costs associated with dry scrubbing will be close to those for limestone scrubbing, and by interpolation, it can be concluded that dry scrubbing will likewise not be a cost effective control option.
6.3.6. Summary Information from several references has been provided confirming that the expected SO2 emissions from in a modern, dry-process Portland cement plant will be the result of organic and/or thermally unstable inorganic sulfur compounds in the raw materials fed to the pyroprocessing system. Sulfur introduced to the pyroprocessing system by fuels will not affect SO2 emissions to the atmosphere.
To achieve the proposed 0.4 pounds of SO2 per ton of clinker, 30 kiln-operating day rolling average SO2 emission rate, US Cement evaluated both sorbent injection and wet scrubbing as add-on SO2 control technologies and further evaluated the use of raw material management for controlling SO2 emissions. An analysis of the data available indicates that the uncontrolled SO2 concentration expected in the stack gases will range from approximately 5-75 parts per million. Because of the variable and relatively low uncontrolled stack gas SO2 concentrations, SO2 emission control will be in the range of approximately 45 percent for sorbent injection and in the range of approximately 75 percent for wet scrubbing..
Cost effectiveness analyses of SO2 control by sorbent injection was found to be a cost effective control measure; however this control technology will not be capable of totally providing the SO2 control efficiencies required. The cost of controlling SO2 emissions by wet scrubbing on the other hand, was determined not to be cost-effective. The limestone mined at the US Cement site, and the iron oxide component and bauxite have been measured to have nondetectable levels of organic and thermally unstable inorganic sulfur. As a result, US Cement is proposing to use the management of raw materials to comply with the proposed SO2 emission limit of 0.4 pounds per ton of clinker, 30 operating day rolling average. US Cement is confident that through materials management that SO2 emissions can be well controlled to the low BACT SO2 limit.
6.4 Nitrogen Oxides Nitrogen oxides (NOx) emissions from a modern dry process Portland cement plant kiln are the result of fuel combustion in the main kiln burner and the calciner burner. NOx emissions can be reduced by minimizing fuel combustion (or conversely, by increasing the thermal efficiency of the kiln system), by controlling the combustion processes and/or by add-on technology such as Selective Non-catalytic Reduction (SNCR). All of these approaches will be discussed in this Section. In the following sections, the BACT for NOx is presented, and then followed by the justification for the BACT emission limit and control technologies selected.
59 6.4.1. Proposed BACT The proposed BACT for NOx from the US Cement kiln is 1.5 lb/ton clinker, 30 kiln-operating day rolling average which will be met using Selective Non-Catalytic Reduction (SNCR), low-NOx burners and kiln/calciner design. The kiln and calciner burners will all be multi-channel, low-NOx burners. There have been no operating kilns at any U.S. Portland cement plant that have demonstrated a lower NOx limit is achievable long-term. In the following sections, federal regulations applicable to NOx emissions from new Portland cement plants are cited; NOx BACT determinations for Portland cement plants made over the past 10 years and listed in the EPA RACT/BACT/LAER Clearinghouse (RBLC) are reviewed; NOx sources in the pyroprocessing system are discussed; and applicable NOx emission control technologies are evaluated.
6.4.2. Federal Regulations Limiting NOx Emission Rates and Recent BACT Determinations (a) Federal Regulations The permitted NOx emission limiting standards for the US Cement plant will be based on a BACT determination. The BACT emission standard will be at least as stringent as promulgated federal emission limiting standards for NOx from new Portland cement plants; and possibly more stringent depending upon the BACT determination. In the following paragraphs, federal regulations potentially applicable to the US Cement plant will be summarized, as will BACT determinations establishing NOx emission limits for Portland cement plants made over the past 10 years. The US Cement plant will be subject to New Source Performance Standard (NSPS) emission limits for plants commencing construction after June 16, 2008 (new plants) as codified at 40 CFR 60, Subpart F - Standards of Performance for Portland Cement Plants. Additionally, depending on how US Cement plans to categorize the new plant; i.e., as a conventional fuel burning plant, or a plant operated as an industrial solid waste incinerator, the plant will be subject to either National Emission Standards for Hazardous Air Pollutants (NESHAP) rules or to Commercial and Industrial Solid Waste Incinerator (CISWI) rules. The NESHAP rules for plants that commence construction after May 6, 2009 (new plants) are codified at 40 CFR 63 , Subpart LLL - National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry and the CISWI rules for plants that commence construction after June 4, 2010 (new plants) are codified at 40 CFR 60, Subpart CCCC - Standards of Performance for Commercial and Industrial Solid Waste Incineration Units. The NOx emission limiting standards imposed by each of these three federal regulations are summarized in Table 12.
Table 12. Federal NOx Emission Limiting Standards Potentially Applicable to US Cement Waste Burning Kiln NESHAP Kiln NSPS Kilns Pollutant 40 CFR 60, Subpart Basis of Emission Limit 40 CFR 63, Subpart Basis of Emission Limit Basis of Emission Limit 40 CFR 60, Subpart F CCCC LLL 200 ppmvd @ 7% O2 Rule 1.5 lb/ton Clk, NOx 30-day avg No Rule Limit -- Rule 30-operating day avg 1.55 lb/ton Clk* Equivalent to Rule
60 (b) Recent BACT Determinations The EPA RACT/BACT/LAER Clearinghouse (RBLC) was reviewed for BACT determinations made over the period 2009-2019 that would limit NOx emissions from Portland cement plants that were subject to PSD. The following determinations were found:
RBLC ID: IN-0312 Date: June 26, 2019 Company: Lehigh Cement Company, LLC Project: Add new preheater/pre-calciner cement kiln with a rated throughput of 7716 tons of clinker per day at an existing facility. The kiln system consists of 15-stage preheater, calciner and rotary kiln. Emissions are controlled by the Kiln Baghouse, low NOx burners, SNCR, and an activated carbon system. The kill uses natural gas, coal, coke, fuel oils and/or non-hazardous fuels (chips and tires, whole tires, engineered fuels, dried bio-solids, high-carbon fly as you and other biomass fuels. NOx Emission Limit: 1.50 pounds per ton of clinker, 30-day average. This limit is to be met by staged combustion, low-NOx burners and SNCR
RBLC ID: KS-0031 Date: July 14, 2017 Company: Ash Grove Cement Company Project: Modification of an existing 4800 ton per day (clinker) dry process Portland cement Plant. NOx Emission Limit: The NOx emission limit for this project was not subject to a BACT determination. The existing NOx emission limit of 3.0 pounds per ton of clinker was retained following the modification project. This emission limit was to be met through good combustion practices.
RBLC ID: TX-0822 Date: June 30, 2017 Company: Capitol Aggregates, Inc. Project: New dry process Portland cement kiln added at an existing facility. NOx Emission Limit: The NOx emission limit for this project was established in accordance with BACT/PSD at 1.5 pounds per ton of clinker. This emission limit was to be met through good combustion practices and SNCR.
RBLC ID: IL-0111 Date: December 20, 2011 Company: Universal Cement Project: Construction of a new 1.25 mmton/yr dry process Portland cement plant. NOx Emission Limit: The NOx emission limit for this project was established in accordance with LAER requirements at 1.2 pounds per ton of clinker. This emission limit was to be met through staged combustion and SNCR.
61
RBLC ID: GA-0136 Date: January 27, 2010 Company: Cemex Southeast, LLC Project: Construction of a new preheater/pre-calciner Portland cement plant rated at 3800 tons per day clinker. The new plant was to be constructed at the existing Cemex Clinchfield, Houston County, Georgia site. NOx Emission Limit: The NOx emission limit for this project was established in accordance with BACT/PSD at 1.95 pounds per ton of clinker. This emission limit was to be met by using Staged and Controlled Combustion (SCC), SNCR, low NOx burner and indirect firing. It should be noted that this BACT determination by the Georgia EPD was identical to a determination made in 2008 or 2009 for a new, grass-roots preheater/pre-calciner Portland cement plant also proposed for a site in Houston County, Georgia.
6.4.3. Sources of NOx in Portland Cement Plants The kiln/raw mill system is the only source of NOx in the proposed US Cement plant. The NOx results from fuel combustion in the kiln and calciner burners and from fuel combustion in the auxiliary heater in the raw mill. All NOx will be discharged through the kiln/raw mill/cooler stack. The US Cement plant will be a dry-process plant with a calciner and preheater. This is the most fuel-efficient Portland cement plant design currently available. Approximately 45 percent of the fuel utilized in these plants is fired in the kiln to create a clinkering condition while the remainder is fired in the calciner to preheat the raw meal as it passes through the preheater and to calcine the limestone in the raw meal prior to entry into the kiln.
There are three mechanisms involved in the formation of NOx; “prompt” NOx, “fuel” NOx, and “thermal” NOx. “Prompt” NOx is NOx formed instantaneously at the flame surface during luminous oxidation. This NOx is independent of flame temperature and excess air. The formation of this NOx and the resulting concentration in the gases exhausted from the kiln can be considered as the baseline NOx emissions resulting from the two combustion processes. In cement plants, prompt NOx is not significant. The “fuel” NOx is the NOx formed by the oxidation of nitrogen in solid fuels. Approximately 60 percent of the fuel nitrogen can be converted to NOx; depending upon available oxygen in the flame and the temperature profile of the flame. The “thermal” NOx is the most significant source of NOx in cement kilns. This NOx is formed through a reaction between atmospheric nitrogen and oxygen. The rate of formation is a function of both available oxygen in the flame and the temperature of the flame.
The combustion characteristics of various fuels affect the formation of both fuel NOx and thermal NOx. Additionally, the firing location (the main kiln burner or the calciner burner) affects NOx formation as a result of differing heat release requirements. And finally, the burner design plays a very important role in NOx formation.
62 The US Cement plant will be permitted to fire natural gas, coal, petroleum coke, various grades of fuel oil, and alternative fuels. Historically, natural gas was thought to generate more NOx per ton of clinker than coal or oil; however, with the advent of precessing jet burners which greatly improved the radiant heat transfer from the natural gas flame, natural gas firing generates NOx levels equivalent to coal and oil firing. The levels of NOx resulting from coal and oil firing are the result of these fuels having a higher fuel nitrogen content and the fuels being fired with a higher volume of combustion air which increases the availability of oxygen, and hence the potential for NOx formation. There are other factors associated with coal and oil burning, however, that more than offset the factors that would indicate higher NOx formation with these fuels. These factors include the flame shape, the luminescence of the flame, higher levels of carbon monoxide (CO), and various radicals that tend to counter the formation of NOx. The use of petroleum coke in either the kiln burner or calciner also appears to increase NOx emissions even though the nitrogen content of petroleum coke can be lower than that of coal and it burns with a lower flame temperature.
In the North American energy market, natural gas prices have been decreasing during the past several years, primarily due to advances in shale gas extraction techniques. The availability of cheaper natural gas is viewed with caution by some in the cement industry due to long-term procurement concerns. Advantages of natural gas include the fact that there is no need to stockpile this fuel, there is no need for blending or grinding, carbon emissions are lower, and it has sharper burning characteristics than coal. Also, a natural gas flame ignites earlier, releases intense heat, and with the advent of precessing burners, natural gas has radiative heat transfer characteristics similar to solid fuel flames. Based on results from recent natural gas firing trials at selected cement plants, along with mineral interactive computational fluid dynamics (MI-CFD) predictions, subsequent to validation from the plant data, natural gas firing has been optimized by taking combustion and mineral interactions into consideration (A).
The location at which fuel is introduced and the combustion requirements also affect the potential for NOx formation. At the main kiln burner, the purpose of combustion is to create a high temperature (1450-1550°C) burning zone for clinker production. The associated gas temperature is in the range of 1700°C. This combustion must be carried out with sufficient oxygen to produce an intense, high temperature flame under oxidizing conditions and to result in a 2-3 percent oxygen concentration in the gas stream exiting the kiln. Both of these conditions contribute to the formation of thermal NOx. The burner design, as it affects flame shape, and the fuel to air ratio, can mitigate NOx formation, however. In most modern dry process cement plants, low-NOx burners are used. These burners have multiple channels through which the fuel, primary combustion air and secondary combustion air are introduced. The introduction of secondary air, in addition to completing the combustion of the fuel, is used to shape the flame. These low-NOx burners are jet burners that come in various designs to induce air/fuel mixing and heat transfer. These burners can reduce NOx emissions when combusting both gaseous and solid fuels (e.g., see
A IEEE Transactions on Industry Applications, VOL. 52, NO. 2, March/April 2016. From Coal to Natural Gas: Its Impact on Kiln Production, Clinker Quality, and Emissions; S.S. Akhtar, E. Ervin, S. Raza, T. Abbas. 63 ATEC GRECO Flexiflame burner). Research shows that some burners can reduce NOx by up to 70 percent.B In the calciner of a preheater-calciner designed plant, the purpose of combustion is to provide the heat necessary to calcine the kiln feed prior to entering the kiln and to provide heat for the preheater tower. The calciner fuel can be fired either in a separate combustion chamber or in an in-line calciner where it is burned in contact with the raw meal. The latter design will be incorporated into the US Cement plant. In either case, the temperature required is in the range 900-950°C (the calcination temperature of calcium carbonate). This is much lower than the temperature at the kiln burner. Furthermore, the combustion in the calciner can occur with either stoichiometric or sub- stoichiometric amounts of combustion air. In the case of sub-stoichiometric combustion, reducing conditions are created that can reduce the NOx generated in the kiln. Additional combustion air is then supplied downstream to assure the complete burned-out of fuel and to oxidize hydrocarbons and carbon monoxide. This method of firing as discussed in detail in subsequent sections of this BACT report.
6.4.4. Description of NOx Control Technologies A summary of available NOx control technologies and their associated control efficiencies is presented in Table 13.
Table 13. Summary of Available NOx Control Technologies and Associated Control Efficiency and Technical Feasibility Proven and Proposed Technology Control Ranking Based Control Technology Technically Feasible? for the Cement Kiln? Efficiency (%) on Efficiency (Y/N) (Y/N) Design Features Plant/Calcined design Variable Y 1 Y Combustion control Variable Y 4 Y Low- NOx burners with Variable Y 2 Y indirect firing Fuel selection and feed Variable Y 5 Y mix Post Combustion Controls Selective non-catalytic 12-77% Y 3 Y reduction (SNCR) Selective catalytic 25-90% Y NA N reduction (SCR)
Control technologies for NOx can be divided into two categories: design features and post- combustion controls. The available types of NOx controls are: Design Features: • Kiln/calciner design; • Combustion control;
B Boateng, A.A., Rotary Kilns Transport Phenomena and Transport Processes, 2016, pg 51. 64 • Low- NOx burners • Indirect firing of solid fuels; and • Fuel selection and feed mix. Post-combustion controls: • Selective non-catalytic reduction (SNCR); and • Selective catalytic reduction (SCR).
(a) Design Considerations NOx formation in the pyroprocessing system at a Portland cement plant is a function of the energy release. Plant designs that minimize the energy release during clinker production typically reduce the formation of NOx emissions. Modern plant designs such as the preheater/calciner design have lower heat input requirements for clinker production, and therefore generate lower amounts of NOx emissions per ton of clinker.
As points of comparison, an old long wet-process cement kiln required approximately 6.0 mmBTU per ton of clinker and a long dry-process kiln required in the order of 4.5 mmBTU per ton of clinker. The more modern designed dry process plants with a preheater have a heat requirement in the range of 3.5-3.8 mmBTU per ton of clinker and dry process plants with both a calciner and preheater have heat input requirements in the range of 2.6-3.0 mmBTU per ton of clinker. The kiln system as proposed by US Cement, will typically operate at approximately 2.6-2.8 mmBTU per ton of clinker.
The control of combustion and the staging of fuel, feed and combustion air play important roles in the formation of NOx. In the modern dry process plants with preheaters and calciners (the only type of plant addressed herein) the firing of fuel is split so that approximately 45 percent of the fuel is fired at the kiln burner and 55 percent is fired at the calciner. The fuel fired in the calciner can be further staged by firing through multiple burners and/or through the addition of alternative fuels such as Tire Derived Fuel (TDF).
Kiln Design The fuel fired in the kiln is for purposes of producing cement clinker. This requires a short, intense flame capable of producing a material temperature in the range of 1450-1550°C. The corresponding gas temperature is typically greater than 1700°C. Additionally, excess oxygen is required for clinkering. It is typical to strive for oxygen levels of two-three percent at the kiln inlet (the point where raw material is fed into the kiln and the combusted gases exit the kiln) to assure oxidizing conditions in the burning zone.
With continuous oxygen (O2) and carbon monoxide (CO) monitoring at the kiln inlet and throughout the calciner and preheater, the excess air can be controlled to maintain oxygen levels that promote optimum clinkering conditions while minimizing the excess O2 available for NOx formation. Another practical benefit of reducing excess oxygen levels is a reduction in the amount of excess air drawn through the kiln. By minimizing excess air, the fuel required to heat the air is
65 minimized (also minimizing the potential for NOx formation) and the power consumption of the kiln I.D. fan is minimized.
Other factors related to fuel firing in the kiln are the method in which the fuel is delivered to the burner and the burner design. Modern Portland cement plants firing solid fuels are indirectly fired; i.e., the air that sweeps the mill in which solid fuels are ground is vented to the atmosphere through a particulate matter control device and the ground fuel is stored in a fuel storage bin. From the fuel storage bin, the ground fuel is conveyed to the burner with a controlled amount of primary combustion air. With natural gas as a fuel, indirect firing is not an issue, however the result is the same; i.e. the fuel is conveyed to the burner with a controlled amount of primary combustion air. With indirect-fired kilns, the primary combustion air is typically in the range of 6-10 percent of the total combustion air; compared with 20-30 percent in the older direct-fired kilns. This reduction in primary combustion air not only reduces the amount of oxygen available for NOx formation, but also allows a greater proportion of hot air recovered from the clinker cooler to be used as secondary combustion air. This reduces both the formation of NOx and increases the thermal efficiency of the pyroprocessing system. Various sources have reported fuel savings of 2-5 percent with indirect firing systems when compared with direct firing systems. Other advantages of indirect firing are:
• The moisture from coal drying is no longer injected into the flame, • Since the primary air flow is substantially less than with direct firing, the peak flame temperature is reduced and the potential for thermal NOx generation is reduced, • As the primary combustion air is reduced and the excess coal mill sweep air is replaced by hot clinker cooler air as secondary combustion air, the fuel consumption (mmBTU per ton of clinker) can be reduced by approximately 2-5 percent, • As the indirect firing system includes a pulverized coal storage bin, the coal mill can be taken down for maintenance without shutting the kiln down, • NOx emissions can be reduced as much as 30-35 percent over emissions from a typical direct fired, mono-channel burner, • The indirect firing system coupled with a multi-channel burner can be adjusted to accommodate fuels of varying characteristics; i.e., coal and petroleum coke as well as supplemental alternative fuels, • The flame shaping with the multi-channel burner improves combustion efficiency and eliminates flame impingement on refractory.
Calciner Design The other location of firing fuel in a preheater-calciner cement plant is in the calciner. This fuel preheats the raw meal as it passes through the preheater and calcines the limestone prior to the raw meal entering the kiln. These two processes require a large amount of heat, however the temperature required for calcination is in the range 900°C. This is much lower than the temperature required in the kiln for clinkering and as a result, NOx formation is minimized. Figure 6 shows the conceptual design of the calciner system that will be employed at the US Cement plant. 66
The concept of staged combustion can be employed in calciner. The staging can involve the staging of fuel combustion, the staging of combustion air and/or the staging (splitting) of kiln feed. The basic staged combustion system operating under oxidizing conditions throughout will result in NOx emissions of about 3.5-4.0 pounds per ton of clinker. Compared to this, a dry process plant with a preheater only (all fuel fired at the kiln burner) will have NOx emissions in the range of 5.0-6.0 pounds per ton of clinker. The reduction in NOx emissions achieved with the preheater- calciner kilns is a result of burning approximately 55 percent of the fuel at lower temperatures in the calciner.
Figure 6. Conceptual Design of Proposed US Cement Calciner
In the calciner of the proposed US Cement plant, NOx reduction is achieved by operating the calciner zone between the tertiary air inlet (Point 5) and the top air inlet (Point 6) in a reducing mode at high temperatures. Under these conditions the NOx from the kiln and the calciner burners is converted to elemental nitrogen due to the reducing atmosphere. Complementing the NOx reduction created by the reducing atmosphere are unburned hydrocarbons from the calciner fuel that also exerted a reducing effect on the NOx
The temperature in the reducing zone can be set by means of splitting the feed from the Stage II preheater cyclone (Point 7). The target temperature in this stage of the calciner is between 950 ⁰C and 1100 ⁰C. By introducing less feed at the bottom steed-point, less meal is calcined in the lower part of the calciner and hence, the temperature is higher. The temperature is set depending upon the NOx reduction requirements.
The tertiary air damper (Point 5) and the top-air damper (Point 6) regulate the distribution of combustion air going to the calciner firing zone and the clinkering zone in the calciner. This 67 combustion air distribution, combined with the oxygen in the gas stream leaving the kiln (approximately 2-3 percent) must be balanced to ensure an oxygen content of approximately three percent at the top of the preheater.
In the downstream zone of the calciner (Point 3 and beyond) a burning zone with hyper- stoichiometric conditions is generated by the addition of top-air. This ensures that CO and hydrocarbons produced in the reducing zone of the calciner are burned out. A total gas retention time of 5-6 seconds in the calciner, coupled with sufficient oxygen introduced through the top-air damper assures the burnout of CO and hydrocarbons.
Due to the special configuration of fuel, gas and raw meal flows, the calciner that will be installed in the US Cement plant will, in addition to its primary function of raw meal de-carbonation, also is designed to reduce the NOx produced in the kiln and of minimizing the formation of NOx from the primary fuel, or alternative fuel combusted in the calciner.
NOx emissions from a preheater-calciner plant with the staged combustion system operating under reducing conditions will yield NOx emissions that are 30-35 percent lower than a plant operating with a staged combustion system under oxidizing conditions.
Low-NOx Burners with Natural Gas or Indirect Solid Fuel Firing The burner design plays a major role in the creation of an optimum burning zone and in the formation of NOx. The low-NOx burners installed on most modern cement plants have multiple channels through which fuel and combustion air are introduced. The fuel is fired with an optimum amount of primary combustion air to produce a fuel-rich combustion zone. The secondary combustion air (heated air recovered from the clinker cooler) is fired around the flame. This firing method reduces the flame turbulence, it establishes a fuel-rich zone for initial combustion, and delays the mixing of fuel with secondary combustion air. The shaped, less intense flame from a low-NOx burner results from the staging of combustion and lowers the overall flame temperature. This reduces NOx formation and shapes the flame to optimize clinkering conditions in the burner zone. It should be noted that low-NOx burners can be used only with indirect fired kilns.
Multi-channel burners were introduced approximately 40 years ago for firing pulverized coal to steam boilers. The multi-channel burners were a departure from the traditional mono-channel burner where fuel and primary air were delivered through a single channel with secondary combustion air supplied elsewhere around the burner. With the mono-channeled burners, 20-30 percent of the combustion air was delivered as primary air with the fuel. Because of the volume and momentum of the primary combustion air, fuel ignition typically took place some distance from the burner, resulting in flame instability and allowing even more combustion air to be entrained into the flame. This burner configuration resulted in relatively high thermal NOx formation and offered no opportunity for flame shaping.
68 With the multi-channel burner, the basic principles are to introduce the fuel with a small amount of primary combustion air at a low injection velocity. The remainder of the primary air is then added through two other concentric channels. One channel delivers swirl or radial air and the other channel delivers axial air. Combined, the total primary air delivered to the multi-channel burner is 6-10 percent of the stochiometric combustion air. This design allows for the initial combustion of coal to occur in an oxygen deficient environment close to the burner. The swirl air provides internal mixing of the flame, and the axial air allows for flame shaping. These factors combined to minimize the oxygen concentration at the flame root in order to lower thermal NOx emissions, and it allows for variability in fuel characteristics without sacrificing performance and efficiency.
The main kiln burner and the calciner burner for the US Cement plant kiln will be a low NOx burner and the burner will be fired with natural gas or indirectly fired with a solid fuels (e.g., coal or petroleum coke). Alternative fuels may also be fired in the kiln and/or the calciner.. The low NOx burners come in various designs to induce air/fuel mixing and heat transfer, such as the ATEC GRECO Flexiflame burner, or the FCT Combustion Turbo-Flex burner.
These burners can reduce NOx emissions when combusting gaseous and solid fuels. Research shows that some of the new low NOx burners can reduce NOx by up to 50-70 percentC and a simultaneous increase in flame luminosity; an attribute that is important in radiation heat transfer in rotary kilns. These improvements in performance are due to the large eddy created by the precessing action described in the referenced document5. During this action, natural gas can undergo cracking prior to combustion to generate soot particles which, in turn, proceed to combustion in a manner similar to pulverized solid fuel. In so doing the soot-laden flame emits radiant energy, a component of the heat transfer mechanism that is enhanced by the rotary kiln curvature. For example, it has been claimed that the first installation of a precessing action burner at the Ash Grove Cement Plant in Durkee, Oregon increased the rotary kiln product output by 11 percent, increased specific fuel efficiency by 6 percent, and reduced NOx emissions by 37 percentD. The burners in the kiln and calciner will include using a burner management system (BMS) that has automated control of fuel firing to ensure safety, maximize natural gas combustion, and minimize NOx emissions to an extent not achievable with manual systems. No NOx emissions increase is expected when firing natural gas with from the use of these low NOx burners.
In addition to improving combustion characteristics, the multi-channel burner is quite effective in reducing thermal NOx emissions. Several studies have indicated that NOx emissions can potentially be reduced 30-35 percent over emissions from a mono-channel burner. This is achieved through the reduction in primary air and by controlling combustion as previously described. It should be noted that the reduction of primary air below 6-10 percent of stochiometric combustion air is not practical as further reduction will result in kiln instability and overheating of the burner tip.
C Boateng, A.A., Rotary Kilns Transport Phenomena and Transport Processes, 2016, pg. 51. D R. Videgar. (1997). “Gyro-therm technology solves burner problems,” World Cement (November), 1997. 69
Improvements in the thermal efficiency of the multi-channel burner over a mono-channel burner result from the improved and controlled combustion process and from the fact that all secondary air is hot air from the clinker cooler. The moisture laden, relatively cool coal mill sweep air that is introduced with direct and semi-direct firing systems is no longer introduced to the kiln. Various reports have cited improvements in fuel use ranging from 2-5 percent.
Fuel Selection and Feed Mix Composition Reducing the temperature required to clinker the raw feed, changes in fuels and/or increasing additives at the finish mill (to increase the yield of cement per ton of clinker) have an effect on NOx emissions. Varying the feed mix or fuel, however, may not be practical because of the fact that most cement plants have a captive quarry and hence, are limited in the general chemistry of the mix. Additionally, the availability of suitable fuels may limit the practicality of pursuing alternative fuels. At the present time, US Cement plants to use natural gas as the primary fuel; with other conventional fuels and alternative fuels used as dictated by availability and economics.
With feed mix composition, it is known that raw materials with a higher alkali content clinker at higher temperatures and thus have the potential for generating higher NOx emissions. Measures to reduce the alkali content of raw feed are not practical. The addition of slag to the raw feed (a process known as the CemStar® process) will reduce the heat required for clinkering. This is because the slag is very similar to clinker and has a low melting temperature because many of the reactions required to convert slag to clinker have already taken place in the processes producing the slag. Because less heat is required to calcine the slag, there is a reduced heat requirement for overall clinkering and a potential for the reduction of thermal NOx emissions.
Burning fuels with the highest possible heating value and lowest possible fuel nitrogen content also has the potential for reducing NOx emissions. As the availability of is driven by economics and regional availability, fuel switching is of limited practical value.
Historically, the cement manufacturing industry has fired natural gas in cement kilns without automated controls or even much forethought into how to most efficiently use natural gas. Years ago, some cement kilns converted from natural gas to coal (primarily because coal became a less expensive fuel or provided greater fuel diversity). In doing so (converting from natural gas to coal), the companies often touted the benefits of reduced NOx when firing coal compared to natural gas. Because the NOx rates were lower when converting from natural gas to coal, and conversion to coal was the proposed project, the industry had no incentive or reason to determine whether NOx emissions formed from the combustion of natural gas in the past were being minimized. Some literature suggests that NOx emissions produced from the firing of coal can be 30 percent lower compared to NOx emissions produced from the firing of natural gas – again, without necessarily taking into account how low NOx emissions might be if combustion were optimized and efforts were made to minimize NOx emissions. NOx emission factors based on projects where kilns were converting from natural gas to coal as their primary fuel are therefore not necessarily indicative of
70 NOx emissions expected from a modern kiln that plans to add natural gas with optimized and automated burner technology.
Even the EPA AP-42 references to increases in NOx due to natural gas firing are based on data from older wet kilns prior to 1990 where the kilns were switching from natural gas to coal and touting the benefits of resulting lower NOx levels.E The burner systems and controls for natural gas combustion have markedly changed since the 1970’s, and even more so over the past 10 years when natural gas prices dropped, and it became a competitive (reaching dominant) fuel. Now, with the precessing jet natural gas burners and automated burner control systems, there is very little difference between NOx emissions when firing coal or natural gas.
(b) Proposed US Cement Kiln/Calciner Design The Polysius kiln considered by US Cement incorporates all of the latest features discussed in the preceding sections. The Polysius pyroprocessing system includes a kiln that’s will be fired with a Unitherm multi-channel kiln burner, or equivalent, followed by a PREPOL-AS-MSC calciner with a single burner and a PYROTOP calciner extension offering a 5-6 second gas retention time. The overall system offers high on-line availability, energy efficiency (approximately 2.6-2.8 mmBTU per ton of clinker), minimized NOx and CO emissions, and flexibility in raw materials and fuel selection. The kiln size is minimized due to the fact that the calcinations of the raw mill are effectively carried out in the calciner. The PYRO-JET kiln burner operates with approximately seven percent primary air and with optimized flame shaping and combustion as previously described for multi-channel precessing burners. The Polysius kilns typically operate with a kiln inlet oxygen concentration in the range of 2-3 percent.
The gas stream exiting the kiln enters the PREPOL-AS-MSC calciner; an in-line calciner designed for both the calcination of raw meal and the reduction of NOx formed in the kiln. The nitrogen oxide reduction is achieved by operating the calciner zone between tertiary air inlet and the top air inlet in a reducing mode and at high temperatures, in such a way that the NOx from the clinkering zone and the calciner burner is converted into nitrogen due to the reducing atmosphere. In addition to the lack of oxygen calciner zone, incompletely burned hydrocarbons generated in the reducing atmosphere of the calciner also exert a reducing effect on nitrogen oxides already formed in the clinkering zone.
The temperature in the reducing zone can be set by means of split feeding of the meal from the Stage II preheater cyclone to the calciner. The target temperature is between 950C to 1000C. The tertiary air and top air dampers will regulate the distribution of the combustion air going to the clinkering zone firing and the calciner firing system. The essential air for the complete combustion in these system will be monitored at the kiln inlet and at the exit of the preheater. A minimum oxygen concentration of approximately 2–3 percent in the kiln inlet is required in order to prevent reducing conditions in the kiln and the associated disadvantages such as the formation
E EPA AP-42, Chapter 11.6-6. 71 of rings. The total tertiary air fed into the calciner will be set according to the combustion air volumes required in the calciner so that a minimum oxygen concentration of approximately three percent is achieved at the exit of the preheater.
In the downstream zone of the calciner, a burning zone with hyper stoichiometric conditions will be generated by adding top air. This ensures that the CO and THC produced in the reducing combustion zone is largely burned out. The meal fed into the calciner is separated in the Stage I preheater cyclone. From there, it will flow at a temperature between 840°C and 860°C through meal ducts, and through the kiln inlet housing into the kiln. To achieve the efficient utilization of natural gas and, on an as needed basis both coal and petcoke in the calciner, the Polysius calciner is extended vertically to increase the residence time to about five to six seconds.
(c) Post-Combustion Controls The two add-on NOx control technologies that have been demonstrated by full scale application in cement plants are Selective Non-catalytic Reduction (SNCR) and Selective Catalytic Reduction (SCR). Both technologies are based on the injection of an ammonia based compound into a hot gas stream and the subsequent reduction of NOx to elemental nitrogen by the ammonia. SNCR is effective in a temperature range of 840-1100°C and operates without a catalyst. SCR on the other hand, operates in a temperature range of 300-500°C and employs a catalyst to facilitate the reaction between ammonia and NOx. Both technologies have been described in detail in several publications and reports. Therefore, only an overview of each technology will be provided herein along with an assessment of each.
SNCR Selective non-catalytic reduction (SNCR) is based on the chemical reduction of the NOx molecule into molecular nitrogen (N2) and water vapor (H2O) and in modern preheater/pre-calciner kilns, F NO typically constitutes 75-95 percent of the NOx with the remainder being NO2 . The process is considered to be a selective process because the reduction of NOx is favored over other chemical reactions during this process for a specific range of temperatures and in the presence of oxygen.
The ammonia reaction is as follows: 2NO + 2NH3 + ½ O2 → 2N2 + 3H2O (90-95 percent of NOx) 6NO2 + 8NH3 → 7N2 + 12H2O (5-10 percent of NOx)
The urea reaction is as follows: 2NO + CO(NH2)2 + ½ O2 → 2N2 + CO2 + 2H2O
The basic reactions that occur following ammonia injection begin with the decomposition of ammonia in the presence of OH* radicals to create a NH2* radical and water vapor. The NH2* radicals then react with NOx to produce elemental nitrogen and water vapor. These reactions take
F Koogler and Associates, Inc., Proprietary Test Data from Florida Portland Cement Kilns, September 2019 72 place without the aid of a catalyst and are highly temperature dependent. The other requirement for SNCR is oxygen; the source of the OH* radicals.
With the injection of aqueous ammonia, the optimum reaction temperature is approximately 950°C (1750°F) and for urea injection, the optimum temperature is about 1000°C (1830°F). It has been found that the control efficiencies of for both aqueous ammonia and urea are about the same shown in Figure 7. In the U.S. water with ammonia concentrations in excess of 20 percent is considered a “hazardous material” for transportation purposes. Therefore, the ammonia content of ammonia water in the U.S. is typically reduced to about 19 percent.
Figure 7. Effect of Temperature on NOx Reduction for Ammonia and Urea
For temperatures significantly below these optimum temperatures, some of the ammonia remains unreacted and ends up in the raw materials or as ammonia in the stack gas. At temperatures significantly above the optimum temperatures, the ammonia will react with oxygen, increasing the concentrations of NO and NO2 (referred to collectively herein as NOx). This is shown graphically in Figure 8G.
G Matz, T. L., Lehigh Hanson Inc., AAPCA 2016 Spring Meeting - NOx Controls Updates, April 2016 73 Figure 8. Effect of temperature on effectiveness of SNCR ammonia injection
In the US and elsewhere in the world, SNCR is widely used to control NOx emissions from Portland cement plants. The Portland Cement Association has reported that approximately 67 percent of the Portland cement plants in the US employee SNCR for NOx control. This compares with one existing and one expected installation of selective catalytic control (SCR) system; one retrofitted on a long wet-process kiln and one retrofitted on an older dry process kiln.
In modern preheater-calciner cement plants operating with and extended calciner such as will be employed by US Cement, the optimum location for the introduction of ammonia for SNCR is following Point 3 shown in Figure 6, but prior to the gases entering the Stage I preheater cyclone. Between these points, oxygen is available and the 900-1000°C temperature window usually occurs under normal steady-state plant operating conditions. During periods of plant startup and malfunction, the temperature window might be erratic and the effectiveness of SNCR will suffer.
Another factor to take into consideration with SNCR in a staged combustion plant system operating under reducing conditions is that the introduction of combustion air is required to complete the burnout of fuel and to oxidize CO in the gas stream. The oxidation of CO to CO2 involves the same OH* radicals that react with ammonia to produce the NH2* radicals. Thus, for SNCR to be effective without increasing CO emissions (because of the competition between CO and ammonia for the OH radicals), there must be sufficient gas residence time following the introduction of top air and the introduction of ammonia for CO oxidation to occur. With the Polysius extended calciner coupled with the PYROTOP, offering five to six seconds residence time, the burn-out of both THC and CO is assured prior to the introduction of ammonia. This being the case, there should be no competition between CO and ammonia for the OH* radicals, and CO 74 emissions will not be higher when SNCR is employed as was reported when SNCR was initially installed on some of the older preheater designed Portland cement plants.
Ammonia slip and the potential for secondary emissions is another factor to consider with SNCR. It has been found that with a molar ratio (ammonia to NOx) of 0.8 or less, ammonia slip is minimized (typically less than 5ppm in the stack gas). Above a molar ratio of 0.8, ammonia slip begins to increase. The undesirable consequence of ammonia slip is the potential for a visible plume. The formation of this plume is temperature/humidity dependent and results from reactions between ammonia, chlorides and/or SO2 in the stack gas; usually after the stack gas leaves the stack.
SNCR has been demonstrated at several installations to be effective for reducing NOx emissions from Portland cement plants. It should be noted that the efficiency of SNCR as applied at different facilities, can be quite varied. Efficiencies reported in a paper by Horton et alH ranged from as low as 20 percent to 90+ percent depending on conditions at the point of ammonia injection and the ammonia to NOx molar ratio and EPA recently reported SNCR efficiencies ranging from 12-77 percent with ammonia injection and from 25-90 percent with urea injection (e.g., see Figure 9I).
In most European Union countries NOx emissions from dry process Portland cement plants are limited to 200 mg/Nm3 (0.9 lb/ton). In other countries internationally, NOx emissions are limited to 400-500 mg/Nm3, or higherJ. To comply with requirements imposed by the Swedish government, the Slite, Sweden plant demonstrated that with careful operation of the kilns and the SNCR system, it was able to achieve NOx reductions of approximately 80-85 percent.11 Similar NOx reductions have been achieved at the Scancem Cement Plant in Skovde, Sweden using SNCR however at both locations, NH3/NOx molar ratios in the range of 1.2-1.8 were required. Ammonia slip at these high molar ratios was minimized or controlled by conditions unique to the two plants. At Slite, a scrubber for SO2 control follows the SNCR system and absorbs any slipped ammonia. At the Skovde plant, ammonia bypassing the SNCR system is absorbed in the raw mill which reportedly operates approximately 98 percent of the time.
H Use of SNCR to Control Emission of NOx from Cement Plants, paper presented at the 2006 IEEE Meeting, J. Horton, A. Linero, and F. Miller I Koogler and Associates, Inc., Data Compiled from Several Sources, Including Proprietary Data, September 2019 J Edwards, P., Global Cement Emission Standards, Global Cement Magazine, March 2014 75 Figure 9. Typical Ranges of NOx Reduction with SNCR
Swedish Plants
The SNCR performance data from the majority of tests, including the data from the two Florida preheater/calciner kilns, the two referenced Swedish plants and the average of performance data from other applicable tests fall in a reasonably consistent range. The data show NOx control efficiencies ranging from 25-35 percent at a molar ratio of 0.4, from 55-65 percent at a molar ratio of about 0.8, and efficiencies in the range of 70-80 percent at molar ratios above 1.0. As stated previously, when the molar ratio of NOx/NH3 gets much above 0.8, ammonia slip becomes an issue.
To summarize, SNCR has been demonstrated to reduce NOx emissions from Portland cement plants both in the US and Europe. The system is cost effective, it has no significant adverse effects on the operation of the plant, and NOx reductions in the range of 25-65 percent can be achieved at an ammonia to NOx molar ratio of 0.4:0.8. The efficiency of NOx control with SNCR depends on several factors including the uncontrolled NOx emission rate, the NOx/ NH3 molar ratio, the plant design (calciner design) as it relates to providing a suitable ammonia injection point, the injection of ammonia at the optimum injection point, and the required control efficiency taking into account NOx reduction resulting from staged combustion and other plant operating/design features. Regarding the optimum injection point of ammonia, a Florida plant reduced ammonia consumption of a SNCR system by approximately 50 percent by conducting computational fluid dynamic
76 modeling to determine the optimum injection point. Such technology is commonplace now and will be used in the design of the SNCR system on the US Cement plant.
Regarding the cost of an SNCR system, it has been reported that the total installed cost of an SNCR system is in the range $1.5-$2.0 million regardless of the clinker production capacity of the plant. In the same reference capital costs of SNCR systems were reported to range from $1.06-$2.54 per ton of clinker (adjusted to the value of 2019 US dollars). Based on these costs, the capital cost of a SNCR system for the proposed US Cement plant would be in the range of $1.87 million. The annual cost of installation would be $245,850; or approximately $0.23 per ton of clinker for the US Cement plant
The annual operating cost of an SNCR system, excluding capital recovery will the vary depending on the price of ammonia and the degree of NOx control required. At current (2019) prices and estimating a requirement to reduce NOx by 2.0 pounds per ton of clinker, the indirect annual operating cost of an SNCR system for the US Cement plant will be in the range $0.50 per ton of clinker.
This puts the total annual cost of an SNCR system at approximately $0.73 per ton of clinker; or to approximately $805,000 for the US Cement plant. To put this into perspective, the projected clinker production cost for US Cement is approximately $50-$55 per ton.
The other way of expressing the cost of an SNCR system is in terms of dollars per ton of NOx removed. For the 1.1 mmton per year (clinker) kiln proposed by US Cement and a NOx reduction from 3.5 pounds per ton of clinker to 1.5 pounds per ton of clinker, the cost of SNCR is on the order of $750 per ton of NOx removed.
While being effective for controlling NOx emissions and while being cost effective, it must be recognized that an SNCR system will not always be fully effective. Because the system is a mechanical system, there will be periods of downtime. In addition to this, system will not be fully effective during plant start-ups and during periods of plant upset because of the temperature dependency of the reactions associated with SNCR. During periods when SNCR is not fully effective, NOx emissions from a staged combustion plant can be controlled by using Best Operating Practices including more aggressive reducing conditions in the calciner. Also because of these periods of less than optimum SNCR system performance, the NOx emission limiting standard must be set as a 30-day average limit.
SCR Selective catalytic reduction (SCR) chemically reduces the NOx to N2 and H2O the same as SNCR, but in the presence of a catalyst and at a lower temperature. A nitrogen-based reagent such as ammonia or urea is injected upstream of a catalyst bed. The gas mixes with the reagent and then enters a reactor that contains the catalyst. As the hot gas stream and reagent diffuse through the catalyst, the reagent reacts selectively with the NOx molecules within a specific temperature range
77 and in the presence of oxygen. Theoretically, SCR systems can be designed for NOx removal efficiencies up close to 100 percent. In practice, commercial coal-, oil-, and natural gas–fired SCR systems are often designed to meet control targets of over 90%.
SCR has been used extensively worldwide to control NOx emissions from fossil fuel fired boilers. In the U.S. alone, more than 1,000 SCR systems have been installed on a wide variety of sources in many different industries, including utility and industrial boilers, process heaters, gas turbines, internal combustion engines, chemical plants, and steel millsK. In the Portland cement industry however, SCR has not gained much acceptance. The first SCR system installed on a Portland cement plant was installed on a plant in Solnhofen, Germany. This SCR system operated from 2001 until it was shut down in 2005. Currently there are SCR systems operating on six cement plants in Europe (placed online between 2006 and 2015), one SCR system operating on an old wet-process Lafarge kiln in Joppa, Illinois (placed online in 2013) and one SCR system planned for installation on an existing Holcim dry-process kiln in Midlothian Texas9.
The major obstacle to the application of SCR to Portland cement plants is the dust loading in the gas stream between the preheater and the raw mill; the only location in a dry-process plant (without gas reheating) where the gas is in the temperature range of 300-500°C (575⁰F-925⁰F). The dust loading in this gas stream is typically 35-80 grains per dry standard cubic foot (80-180 mg/Nm3). As a point of comparison, the dust loading in power plants where SCR is commonly employed is on the order of 20 mg/Nm3. In addition to the dust loading the dust encountered in a Portland cement plant is more difficult to handle because of trace element contamination with catalyst poisons (sodium, potassium, arsenic, phosphorus, lead, chromium, and zinc) and physical handling characteristics “sticky dust”. These factors result in higher capital costs for much more extensive catalyst cleaning systems, and higher operational costs associated with energy consumption for the compressed air utilized for catalyst cleaning, and additional fan capacity necessary to address the higher pressure loss across the catalyst. To find a catalyst that would operate in these conditions, Lurgi, the catalyst supplier for the Solnhofen Germany cement plant (see below), tried approximately 20 different catalyst types before coming up with a catalyst that was effective at the high dust loadings encountered in cement plants, and would not be poisoned with the high concentrations of contaminants encountered.
The first SCR system installed on a cement plant was installed at the Solnhofen Portland Cement Works GmbH & Company KG (Solnhofen) in 2001 following a lengthy pilot study. The SCR system was eventually shut down in 2005 and replaced with a SNCR system in 2005 and replaced with a SNCR system. At Solnhofen, catalyst was installed in three of the six beds with a total catalyst loading of approximately 35 cubic meters. Catalyst cleaning equipment was installed in the alternating three empty bed spaces. It was reported that while operating a low-NOx burner and
K Chapter 2 Selective Catalytic Reduction John L. Sorrels Air Economics Group Health and Environmental Impacts Division Office of Air Quality Planning and Standards U.S. Environmental Protection Agency Research Triangle Park, NC 27711 David D. Randall, Karen S. Schaffner, Carrie Richardson Fry RTI International Research Triangle Park, NC 27709 May 2016 78 firing waste fuels (60 percent oil and 40 percent auto fluff) the uncontrolled NOx emissions from the Solnhofen plant were in the range 800-1200 mg/Nm3 (3.6-5.4 lb NOx/ton clinker). With the SCR system operating the plant was able to meet the NOx emission limit of 500 milligrams per cubic meter (2.3 lb NOx/ton clinker). It is expected that a lower NOx emission rate could have been met on a continuing basis with a greater catalyst loading.
Regarding the NOx removal efficiency achieved by the Solnhofen SCR system, there were reported efficiencies as high as 80-90 percent; efficiencies achieved during short test periods with clean catalyst. But, long term operating data indicated that the system typically operated at NOx removal efficiencies in the range 35-70 percent; with the 70 percent efficiency occurring at a NH3/NOx molar ratio of 1.0. At molar ratios above 1.0, the NOx removal efficiency flattens and reaches an upper limit of approximately 75 percent at molar ratios between 1.4 and 2.0.
Considering the uncontrolled NOx emissions from the Solnhofen plant are in the range of 800- 1200 milligrams per normal cubic meter and further considering that the NOx emission limit for the plant is 500 mg/Nm3, a NOx removal efficiency of 40-60 percent would typically have been required for compliance. This means the SCR system would have typically operated at a NH3/NOx molar ratio in the range of 0.4-0.8. It is within this range that the preponderance of available data fall substantiating the fact that this was probably the typical operating range of the system.
If a SCR system were to be installed at a cement plant in the U.S., it is widely expected that pilot plant testing would be necessary to evaluate the most effective catalyst type, configuration, and loading for the physical and chemical characteristics of the dust and the gas stream at the candidate plant. The pilot study would evaluate the suitability of gas temperatures, gas bypass systems or gas blending systems to account for times when the gas temperature is outside an acceptable range, the NOx loading to the SCR system, the NOx reduction required, catalyst loading requirements, and catalyst cleaning systems. Such a study would probably require 1-3 years to be thoroughly effective.
Regarding the cost of SCR systems, the Portland Cement Association (PCA) in comments to EPA pointed out that the design of SCR systems was extremely site-specific and that as a result of this, cost data available on the few SCR systems operating worldwide was not applicable to estimating capital or operating costs of SCR systems for specific new or retrofitted Portland cement plants. The PCA stated that the best estimate of the capital cost of an installed SCR system on a new plant would be in the range of $15.50-$17.50 per ton of clinker; or approximately $18.2 million for the proposed US Cement plant. This capital cost relates to an annualized capital cost of $2.4 million per year. The best estimate of an indirect annual cost for the proposed US Cement plant is approximately $1 million per year; resulting in a total annual cost of $3.4 million per year.
If these costs are applied to the US Cement assuming an uncontrolled NOx emission rate of 3.5 pounds per ton of clinker and a permitted NOx emission rate of 1.5 pounds per ton of clinker, the cost of NOx control would be approximately $3100 per ton of NOx removed, and the system
79 would add approximately $3.10 per ton of clinker produced. To put this cost into perspective, the projected clinker production cost at the US Cement plant is in the range $50-$55 per ton of clinker.
6.4.5. NOx BACT Selection The kiln proposed by US Cement will be a modern preheater-calciner plant with staged combustion. The fuel staging will involve firing approximately 45 percent of the total pyroprocessing heat requirement at the kiln burner and approximately 55 percent of the total heat requirement in the calciner. The Polysius pyroprocessing system includes a kiln that will be fired with the Unitherm multi-channel kiln burner, or equivalent, followed by a PREPOL-AS-MSC calciner with a single burner and a PYROTOP calciner extension offering a 5-6 second gas retention time. The overall system offers high on-line availability, energy efficiency (approximately 2.6-2.8 mmBTU per ton of clinker), minimized NOx and CO emissions, and flexibility in raw materials and fuel selection. The PYRO-JET kiln burner operates with approximately seven percent primary air and with optimized flame shaping and combustion as previously described for multi-channel precessing burners. The Polysius kilns typically operate with a kiln inlet oxygen concentration in the range of 2-3 percent.
With the plant design proposed by US Cement, experience with similar plants has demonstrated that NOx emissions in the range of 2.4-2.8 pounds per ton of clinker (30-day average) can be achieved. Achieving these levels requires the following: • A preheater-calciner design plant capable of firing natural gas, coal, petcoke and supplemental fuels, • Low-NOx burners, • Process monitors for oxygen, carbon monoxide, temperature and pressure, • Raw material selection to produce a feed that is readily calcinable (i.e., limestone and other on-site derived materials) with little or no pyritic sulfur, nitrogen compounds, or organics. It is also a prerequisite that the materials from off-site suppliers have these same characteristics, and • Operating the first stage of the calciner under reducing conditions (to destroy NOx formed in the kiln).
Beyond these measures, US Cement will use SNCR to reduce NOx emissions to the degree necessary to achieve the proposed BACT limit of 1.5 pounds per ton of clinker, 30 kiln-operating day rolling average. This proposed BACT emission rate for NOx is equivalent to the emission limit imposed by 40 CFR 60, Subpart F for new Portland cement plants commencing operation after June 16, 2008 and it is also equivalent to the lowest NOx emission limit established as BACT by EPA over the past 10 years.
When establishing BACT, consideration should be given to the overall operation of a plant, the range of fuels and raw materials that might be encountered, and impacts on air quality. This proposed limit will allow US Cement to operate the plant with a range of fuels (natural gas, coal, petroleum coke, fuel oil and sustainable biomass fuels) and raw materials under reasonable
80 operating conditions and to use SNCR to achieve the NOx control necessary to achieve the proposed BACT limit of 1.5 pounds of NOx per ton of clinker. These are reasonable expectations, taking into account the mandated requirements of BACT, and the proposed NOx emission limit is consistent with the lowest established BACT limit for any Portland cement plant in the U.S.
6.5 Carbon Monoxide In modern Portland cement plants of the preheater/precalciner design, carbon monoxide emissions can result from two independent sources. The first is carbon monoxide resulting from the combustion processes in the kiln and calciner and the second is from the oxidation of carbonaceous material in the raw feed introduced to the preheater. Another potential source which is not considered significant is the reduction of carbon dioxide generated during the calcination of raw meal in the preheater tower. The CO that is generated by the combustion processes is the most complex. CO generated from the kiln feed is purely a function of the organic or elemental carbon content of the raw feed and the volatility of this carbon.
In the following sections, the BACT for CO is presented, and then followed by the justification for the BACT emission limit and control technologies selected.
6.5.1 Proposed BACT The CO emission limit proposed as BACT is 2.9 pounds per ton of clinker, 30-kiln operating day rolling average. This will be achieved by good combustion practices, plant design, and raw materials management.
In the following sections, federal regulations applicable to CO emissions from new Portland cement plants are cited; CO BACT determinations for Portland cement plants made over the past 10 years and listed in the EPA RACT/BACT/LAER Clearinghouse (RBLC) are reviewed; CO sources in the pyroprocessing system are discussed; and applicable CO emission control technologies are evaluated.
6.5.2 Federal Regulations Limiting CO Emission Rates and Recent BACT Determinations (a) Federal Regulations The permitted CO emission limiting standards for the US Cement plant will be based on a BACT determination. The BACT emission standard will be at least as stringent as promulgated federal emission limiting standards for CO from new Portland cement plants; and possibly more stringent depending upon the BACT determination. In the following paragraphs, federal regulations potentially applicable to the US Cement plant will be summarized, as will BACT determinations establishing CO emission limits for Portland cement plants made over the past 10 years.
The US Cement plant will be subject to New Source Performance Standard (NSPS) emission limits for plants commencing construction after June 16, 2008 (new plants) as codified at 40 CFR 60, Subpart F - Standards of Performance for Portland Cement Plants. Additionally, depending on
81 how US Cement plans to categorize the new plant; i.e., as a conventional fuel burning plant, or a plant operated as an industrial solid waste incinerator, the plant will be subject to either National Emission Standards for Hazardous Air Pollutants (NESHAP) rules or to Commercial and Industrial Solid Waste Incinerator (CISWI) rules. The NESHAP rules for plants that commence construction after May 6, 2009 (new plants) are codified at 40 CFR 63 , Subpart LLL - National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry and the CISWI rules for plants that commence construction after June 4, 2010 (new plants) are codified at 40 CFR 60, Subpart CCCC - Standards of Performance for Commercial and Industrial Solid Waste Incineration Units. The CO emission limiting standards imposed by each of these three federal regulations are summarized in Table 14.
Table 14. Federal Regulations Regulating CO Emissions from Portland Cement Plants Waste Burning Kiln NESHAP Kiln NSPS Kilns Pollutant 40 CFR 60, Subpart Basis of Emission Limit 40 CFR 63, Subpart Basis of Emission Limit Basis of Emission Limit 40 CFR 60, Subpart F CCCC LLL 190 ppmvd @ 7% O2 Rule CO 30-day avg No Rule Limit -- No Rule Limit -- 0.71 lb/ton Clk* Equivalent to Rule * - Based on an Estimated Stack Gas Flow Rate of 51,429 dscf/ton Clinker @ 7% O2.
(b) Recent BACT Determinations The EPA RACT/BACT/LAER Clearinghouse (RBLC) was reviewed for BACT determinations made over the period 2009-2019 that would limit CO emissions from Portland cement plants that were subject to PSD. The following determinations were found:
RBLC ID: IN-0312 Date: June 26, 2019 Company: Lehigh Cement Company, LLC Project: Add new preheater/pre-calciner cement kiln with a rated throughput of 7716 tons of clinker per day at an existing facility. The kiln system consists of 15-stage preheater, calciner and rotary kiln. Emissions are controlled by the Kiln Baghouse, low NOx burners, SNCR, and an activated carbon system. The kill uses natural gas, coal, coke, fuel oils and/or non-hazardous fuels (chips and tires, whole tires, engineered fuels, dried bio-solids, high-carbon fly as you and other biomass fuels. CO Emission Limit: 1.40 pounds per ton of clinker, 12-month rolling average. The limit is to be achieved by good combustion practices.
RBLC ID: TX-0831 Date: December 6, 2017 Company: GCC Permian, LLC Project: The addition of Kiln 3, a new cement kiln with a production capacity of 3300 tons of clinker per day. Kiln 3 will eventually replace Kiln 1, but elements of Kiln 1 process equipment will be repurposed for use with Kiln 3. Kiln 1 will remain in operation until Kiln 3 is activated. At no time will Kiln 1 and Kiln 3 operate simultaneously
82 CO Emission Limit: 1.50 pounds per ton of clinker, 30-day rolling average. The limit is to be achieved by good combustion practices.
RBLC ID: KS-0031 Date: July 14, 2017 Company: Ash Grove Cement Company Project: Modification of an existing 4800 ton per day (clinker) dry process Portland cement Plant. CO Emission Limit: Equivalent to 3.12 pounds per ton of clinker, eight-hour average. The limit is to be achieved by good combustion practices.
RBLC ID: TX-0822 Date: June 30, 2017 Company: Capitol Aggregates, Inc. Project: New dry process Portland cement kiln added at an existing facility. CO Emission Limit: The CO emission limit for this project was established in accordance with BACT/PSD at 3.0 pounds per ton of clinker, annual average. This emission limit was to be achieved through good combustion practices.
RBLC ID: TX-0822 Date: June 13, 2017 Company: Alamo Cement Company Project: The addition of a second Portland cement kiln (Kiln 3) at the existing site. The project will also include ancillary equipment CO Emission Limit: The CO emission limit for this project was established in accordance with BACT/PSD at 2.0 pounds per ton of clinker, 1-hour average and 1.67 pounds per ton of clinker, annual average. These limits were to be achieved through good combustion practices.
RBLC ID: MO-0088 Date: January 18, 2017 Company: Continental Cement Company, LLC Project: The project was the correction of a previously issued CO BACT limit for a preheater/pre-calciner kilns based upon revised data. CO Emission Limit: The CO emission limit for this project was established in accordance with BACT/PSD at 6.0 pounds per ton of clinker, 30-day rolling average. This limit is to be achieved through good combustion practices
RBLC ID: NY-0115 Date: December 9, 2014 Company: Lafarge Building Materials, Inc. Project: The replacement of two wet-process kilns with a single modern, dry-process preheater/pre-calciner kiln and clinker cooler.
83 CO Emission Limit: The CO emission limit for this project was established in accordance with BACT/PSD requirements at 2.5 pounds per ton of clinker, 30-day rolling average. There is no mention as to how they limit is to be achieved.
RBLC ID: TX-0639 Date: October 8, 2013 Company: Cemex Construction Materials South Project: Modification of an existing Portland cement plant. CO Emission Limit: The CO emission limit for this project was established in accordance with BACT/PSD requirements at 1.38 pounds per ton of clinker, 12-month rolling average. This limit is to be achieved through plant design and good combustion practices
RBLC ID: IL-0111 Date: December 20, 2011 Company: Universal Cement Project: Construction of a new 1.25 mmton/yr dry process Portland cement plant. CO Emission Limit: The CO emission limit for this project was established in accordance with BACT/PSD requirements at 1.05 pounds per ton of clinker, 30-day rolling average. This limit is to be achieved by good combustion practices.
RBLC ID: GA-0136 Date: January 27, 2010 Company: Cemex Southeast, LLC Project: Construction of a new preheater/pre-calciner Portland cement plant rated at 3800 tons per day clinker. The new plant was to be constructed at the existing Cemex Clinchfield, Houston County, Georgia site. CO Emission Limit: The CO emission limit for this project was established in accordance with BACT/PSD at 2.90 pounds per ton of clinker, 30-day rolling average. This emission limit was to be met by using good combustion practices, plant design and operating practices. It should be noted that this BACT determination by the Georgia EPD was identical to a determination made in 2008 or 2009 for a new, grass-roots preheater/pre-calciner Portland cement plant also proposed for a site in Houston County, Georgia.
6.5.3 Sources of CO in Portland Cement Plants (a) Combustion Sources In modern preheater/precalciner cement plants, approximately 40-50 percent of the fuel fired in the kiln burner and the remaining 50-60 percent is fired in the calciner. The CO generated in the kiln results from the kiln operating conditions dictated by the production of quality clinker; and more specifically by the amount of excess oxygen available at the back of the kiln (where the gases exit the kiln); typically 2-3 percent.
84 As the gases exit the kiln and enter the calciner, CO levels become a function of calciner design, operation, and the degree to which staged combustion is used to control nitrogen oxides. If staged combustion is used aggressively for nitrogen oxide control, reducing conditions are created in the lower stages of the calciner which will increase CO levels. Regardless of the CO level in the lower stages of the calciner, the CO can be oxidized by the introduction of secondary or tertiary combustion air in the upper stage of the Polysius and PREPOL-AS-MSC calciner with a single burner and a PYROTOP calciner extension offering a 5-6 second gas retention time. This gas retention time allows for the burnout of CO prior to the Stage I cyclone of the preheater. The mechanism of this oxidization is a function of calciner design which is discussed in the following paragraphs. The degree of carbon monoxide reduction prior to the Stage I cyclone becomes a function of the residence time and turbulence in the calciner following the introduction of secondary or tertiary combustion air.
The kiln proposed by US Cement utilizes an in-line calciner (ILC) burner in the riser duct leaving the kiln as shown in Figure 6. The ILC burner in this kiln is a low-NOx burner which can be operated with sub-stoichiometric combustion air to create a reducing zone that will destroy some of the NOx formed in the kiln. The severity of the reducing conditions can be controlled to minimize plugging in this section of the pyroprocessing system (see Section 6.4.4). It should be noted that the lower the degree of NOx reduction in the calciner, the greater will be the demand placed on the SNCR system for NOx control.
As discussed in Section 6.4.4, NOx reduction is achieved by operating the calciner zone between the tertiary air inlet (Point 5) and the top air inlet (Point 6) in a reducing mode at high temperatures. Under these conditions the NOx from the kiln and the calciner burners is converted to elemental nitrogen due to the reducing atmosphere.
The tertiary air damper (Point 5) and the top-air damper (Point 6) regulate the distribution of combustion air going to the calciner firing zone and the clinkering zone in the calciner. This combustion air distribution, combined with the oxygen in the gas stream leaving the kiln (approximately 2-3 percent) must be balanced to ensure an oxygen content of approximately three percent at the top of the preheater.
In the downstream zone of the calciner (Point 3 and beyond) a burning zone with hyper- stoichiometric conditions is generated by the addition of top-air. This ensures that CO and hydrocarbons produced in the kiln and reducing zone of the calciner are burned out. A total gas retention time of 5-6 seconds in the calciner, coupled with sufficient oxygen introduced through the top-air damper assures the burnout of CO and hydrocarbons.
The calciner is designed with a gas residence time on the order of 5-6 seconds to allow the burnout of hard-to-burn fuels as well as CO. At the top of the calciner loop, the kiln employs a proprietary Polysius PYROTOP that thoroughly mixes the gas stream from the calciner with tertiary air to
85 provide additional assurance of fuel and carbon monoxide burnout prior to the gas stream entering the Stage I preheater cyclone.
Regardless of the calciner design, another factor that must be taken into consideration when evaluating potential CO emissions is the use of SNCR for NOx control. The oxidation of CO to CO2 in the calciner involves the same OH* radicals that react with ammonia to produce the NH2* radicals. Thus, there will be a competition between ammonia and CO for the radicals if the CO is not burned out before the ammonia is introduced. With the Polysius calciner design and the 5-6 second gas residence time, the CO and hydrocarbons in the gas stream have adequate time for burnout between Point 3 and Point 4; allowing for SNCR ammonia injection prior to Point 4.
Summarizing the aforementioned factors, the CO at the exit of the calciner will be a function of the CO exiting the kiln, CO generated by reducing conditions in the ILC, the burn-out (oxidation) of CO in the upper stages of the calciner and the competition between CO and NH3 for the OH* radicals following the SNCR NH3 injection points. The CO exiting the kiln and the CO generated in the ILC will be dictated by plant operating conditions that will optimize clinker quality and minimize operating problems (plugging, etc.). These conditions will probably result in somewhat less CO, and somewhat more NOx entering the upper stages calciner because the plant operator will have SNCR to control the NOx.
In the upper stages of the proposed calciner, there will be adequate time (5-6 seconds total residence time) and turbulence for the CO and hydrocarbons to be oxidized prior to the SNCR system. Thus, the competing reaction between CO and NH3 will be minimized.
Taking all of these factors into consideration, a reasonable equivalent pyroprocessing system CO emission rate entering the lower stages of the preheater should be 1.0-1.5 pounds per ton of clinker.
(b) Raw Materials At the US Cement quarry, analyses have shown low levels of kerogens in some samples of the clay, Fuller’s earth and limestone. Kerogens are commonly defined as the insoluble macromolecular organic matter dispersed in sedimentary rock. The kerogens can be petroleum (CnHm) or carbonaceous (C>>H) in nature. The kerogens are carbonaceous in nature.
Another potentially significant source of carbon compounds in raw materials is the unburned carbon in power plant ash that is used in some cement plants as a source of aluminum and iron. US Cement will manage any ash in a manner that will assure an acceptable carbon level for compliance with the BACT limit.
Another factor that influences potential CO emissions from feed materials is the volatility of the carbon in the feed. It was reportedL that carbon volatilizing in the range of 450-550°C
L Shenk, R.E., F.L. Smidth, Inc., Presentation to the Florida Department of Environmental Protection. December 17, 2004. 86 (temperatures in the upper part of the preheater) will produce more CO than carbon that volatilizes in the range of 600-800°C (temperatures in the lower part of the preheater). The reason is that carbon volatilizing in the lower section of the preheater stands a better chance of being oxidized to CO2 than carbon volatilizing in the upper portions of the tower where the temperatures are much lower. It is expected that a majority of the carbon (kerogens) in the US Cement raw materials will volatilize in the 600-800°C temperature range because of their carbonaceous rather than petroleum nature.
(c) Total CO Emissions In addition to the design and material characteristics affecting CO emissions, the typical operating conditions in a well-operated cement plant create a great deal of variability in CO emissions. These operating conditions include such things as material flushes, build up, blockages, false air, poor material burnability, and changes in fuel and feed characteristics. These factors require constant adjustments in plant operations to maintain a smooth running plant and uniform clinker quality.
Based on approximately six months of operating data provided to the State of Florida by a Florida cement companyM, the CO concentrations at the exit of the preheater ranged from less than 400 ppm to over 1,200 ppm (one hour averages) under normal operating conditions. These data are referenced as an example of the variability in CO emissions from a modern Portland cement plant under normal operating conditions.
Considering that combustion related CO will be 1.0-1.5 pounds per ton of clinker; and that the carbon (kerogens) in the limestone, Fuller’s earth and clay could increase CO emissions by about 1.0-1.5 pound per ton of clinker, a CO emission rate in the range of 3.0 pounds per ton of clinker can be expected. This emission rate does not take into consideration the short term fluctuations brought on by operating fluctuations and variations in feed and fuel as previously discussed. Considering these factors and the variability in emissions due to typical plant operating issues, a CO emission rate for the proposed US Cement kiln of 2.9 pounds per ton of clinker, 30-kiln operating day rolling average is proposed.
6.5.4 Description of CO Control Technologies The control mechanisms discussed thus far are related to plant design and operating features and material selection. Further reduction in CO emissions can only be accomplished with add-on controls. Such controls would involve some type of thermal oxidation.
To date, two thermal oxidizers have been installed on cement plants in the U.S. TXI Operations, LP (TXI) installed a Regenerative Thermal Oxidizer (RTO), a wet scrubber, and a baghouse on a
M Florida Department of Environmental Protection. Technical Evaluation and Preliminary Determination – CSR Rinker Materials Corporation. Miami-Dade County, Florida. December 14, 2004. 87 kiln permitted at their Midlothian facility in November 1998. TXI elected to install this air pollution control system in order to “net-out” of a PSD review for the project.N
After operating the plant for about a year, TXI approached the Texas Commission on Environmental Quality (TCEQ) and requested that they be allowed to discontinue the operation of the RTO. The request was based on an alleged inferior design of the RTO, high operating cost due to the sharp increase in the price of natural gas used to fire the RTO and an excessively high pressure drop across the RTO. In evaluating the request, TCEQ determined that the RTO was technically feasible but economically unreasonable.18
It should be noted that the RTO was installed to control both VOC and carbon monoxide. During the consideration of the TXI request to discontinue the use of the RTO, cost analyses were performed by TCEQ and by TXI. The cost of control for carbon monoxide at the TXI plant was estimated to be approximately $1,400 per ton of CO removed. This cost was higher than what was considered BACT for CO by the TCEQ.19 Using cost figures developed by TCEQ and scaling to the US Cement plant, the estimated control cost is $6,000+ per ton of CO removed. This is for 75 percent CO control; the control proposed for TXI under their amended permit.
Even though TCEQ agreed with TXI that the RTO was not BACT, TXI agreed in a settlement with third-party interveners to continue to operate the RTO, but at a reduced operating temperature. Such operations would reduce natural gas usage, electrical consumption, and kiln limitations created by exceeding system pressure drop safety operating margins. With the RTO, the CO limit for the No. 5 Kiln at the TXI Midlothian facility is 1.56 pounds per ton of clinker.
The only other known RTO operating in the U.S. is at the Holcim Plant in Dundee, Michigan. This RTO was installed for the control of VOC’s resulting from high levels of kerogen in the limestone. Without the RTO, the VOC emissions from the two wet process kilns would be about 7,200 tons per year. The driving force for installing the RTO at the Holcim Plant was part of a consent agreement to abate odors resulting from the high VOC emissions.
It has been reported19 that the Holcim RTO has had problems with material build up, probably related to its packed bed design, and has required a large-scale rebuilding to improve performance.
6.5.5 CO BACT Selection The operation of an RTO at US Cement would increase the energy and environmental impacts as fossil fuel (natural gas) would be required to provide the thermal energy for the system operation. The use of this fuel would increase emissions of NOx and result in minor increases in other pollutants. Additionally, electrical energy would be necessary to operate the system and this would have secondary environmental impacts.
N Texas Commission on Environmental Quality. Construction Permit Amendment – Review Analysis and Technical Review, Permit No. 1360A/PSE-TX-632MI. September 9, 2005. 88 Based on the operating experience with RTOs at plants in Texas and Michigan and the cost of controlling CO with an RTO (at $6,000+ per ton of CO), the application of an RTO or other thermal oxidizers to control CO is rejected as BACT. Good combustion practices, plant design and raw material management will be used to limit carbon monoxide emissions to 2.9 pounds per ton of clinker, 30-kiln operating day rolling average. This is proposed as BACT for the US Cement project.
6.6 Volatile Organic Compounds As with CO, volatile organic compound (VOC) emissions from modern Portland cement plants of the preheater/calciner design can potentially result from two independent sources. The first is from products of incomplete combustion in the pyroprocessing system and the second is from the volatilization or oxidation of carbonaceous material in the raw feed introduced to the preheater.
The discussion of VOC emissions is confounded somewhat in that state agencies typically limit the emission rate of VOCs while the federal NESHAP standards for Portland cement plants place limits of Total Hydrocarbon (THC) emissions. Federal New Source Performance Standards (NSPS) for Portland cement plants at 40 CFR 60, Subpart F and federal standards for cement kilns operated as Commercial/Industrial Solid Waste Incinerators (CISWI) at 40 CFR 60, Subpart CCCC do not have THC/VOC limits for cement kilns. VOCs, for practical purposes, are defined as total hydrocarbons minus methane and ethane. The THC limits EPA has set for Portland cement plants are codified at 40 CFR 63, Subpart LLL at 24 ppmvd @ 7% O2.
In the following sections, the BACT for THC/VOC is presented; followed by the justification for the BACT emission limit and control technologies selected.
6.6.1 Proposed BACT The THC/VOC emission limit proposed as BACT is the 40 CFR 63, Subpart LLL THC stack gas concentration emission limit of 24 ppmvd corrected to 7 percent O2 or to 0.15 pounds of THC per ton of clinker at the design stack gas flow rate. Consistent with the NESHAP limit, it is proposed that the BACT limit be based on a 30-kiln operating day average. This limit will be achieved by plant design, good combustion practices and material management to minimize raw materials with VOC/THC precursors. It is proposed that the VOC BACT emission limit be identical to the THC BACT emission limit.
In the following sections, federal regulations applicable to THC/VOC emissions from new Portland cement plants are cited; THC/VOC BACT determinations for Portland cement plants made over the past 10 years and listed in the EPA RACT/BACT/LAER Clearinghouse (RBLC) are reviewed; THC/VOC sources in the pyroprocessing system are discussed; and applicable THC/VOC emission control technologies are evaluated.
89 6.6.2 Federal Regulations Limiting THC/VOC Emission Rates and Recent BACT Determinations (a) Federal Regulations The permitted THC/VOC emission limiting standards for the US Cement plant will be based on a BACT determination. The BACT emission standard will be at least as stringent as promulgated federal emission limiting standards for THC/VOC from new Portland cement plants; and possibly more stringent depending upon the BACT determination. In the following paragraphs, federal regulations potentially applicable to the US Cement plant will be summarized, as will BACT determinations establishing THC/VOC emission limits for Portland cement plants made over the past 10 years.
The US Cement plant will be subject to New Source Performance Standard (NSPS) emission limits for plants commencing construction after June 16, 2008 (new plants) as codified at 40 CFR 60, Subpart F - Standards of Performance for Portland Cement Plants. Additionally, depending on how US Cement plans to categorize the new plant; i.e., as a conventional fuel burning plant, or a plant operated as an industrial solid waste incinerator, the plant will be subject to either National Emission Standards for Hazardous Air Pollutants (NESHAP) rules or to Commercial and Industrial Solid Waste Incinerator (CISWI) rules. The NESHAP rules for plants that commence construction after May 6, 2009 (new plants) are codified at 40 CFR 63 , Subpart LLL - National Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry and the CISWI rules for plants that commence construction after June 4, 2010 (new plants) are codified at 40 CFR 60, Subpart CCCC - Standards of Performance for Commercial and Industrial Solid Waste Incineration Units. The CO emission limiting standards imposed by each of these three federal regulations are summarized in Table 15.
Table 15. Federal Regulations Regulating THC/VOC Emissions from Portland Cement Plants Waste Burning Kiln NESHAP Kiln NSPS Kilns Pollutant 40 CFR 60, Subpart Basis of Emission Limit 40 CFR 63, Subpart Basis of Emission Limit Basis of Emission Limit 40 CFR 60, Subpart F CCCC LLL 24 ppmvd @ 7% O2 THC No Rule Limit NESHAP THC Limit as BACT NESHAP THC Limit as BACT No Rule Limit NESHAP THC Limit as BACT 0.14 lb/ton Clk
VOC No Rule Limit NESHAP THC Limit as BACT No Rule Limit NESHAP THC Limit as BACT No Rule Limit NESHAP TRHC Limit as BACT * - Based on an Estimated Stack Gas Flow Rate of 51,429 dscf/ton Clinker @ 7% O2.
(b) Recent BACT Determinations The EPA RACT/BACT/LAER Clearinghouse (RBLC) was reviewed for BACT determinations made over the period 2009-2019 that would limit CO emissions from Portland cement plants that were subject to PSD. The following determinations were found:
RBLC ID: IN-0312 Date: June 26, 2019 Company: Lehigh Cement Company, LLC
90 Project: Add new preheater/pre-calciner cement kiln with a rated throughput of 7716 tons of clinker per day at an existing facility. The kiln system consists of a 5-stage preheater, calciner and rotary kiln. Emissions are controlled by the Kiln Baghouse, low NOx burners, SNCR, and an activated carbon system. The kill uses natural gas, coal, coke, fuel oils and/or non-hazardous fuels (chips and tires, whole tires, engineered fuels, dried bio-solids, high-carbon fly as you and other biomass fuels. VOC Emission Limit: 0.12 pounds per ton of clinker, 12-month rolling average. The limit is to be achieved by good combustion practices.
RBLC ID: TX-0822 Date: June 30, 2017 Company: Capitol Aggregates, Inc. Project: New dry process Portland cement kiln added at an existing facility. VOC Emission Limit: The VOC emission limit for this project was established in accordance with BACT/PSD at 0.50 pounds per ton of clinker, 30-day rolling average. This emission limit was to be achieved through good combustion practices.
RBLC ID: TX-0822 Date: June 13, 2017 Company: Alamo Cement Company Project: The addition of a second Portland cement kiln (Kiln 3) at the existing site. The project will also include ancillary equipment VOC Emission Limit: The VOC emission limit for this project was established in accordance with BACT/PSD at 0.10 pounds per ton of clinker, 1-hour average and 0.08 pounds per ton of clinker, annual average. These limits were to be achieved through good combustion practices.
RBLC ID: FL-0357 Date: December 1, 2015 Company: Suwannee American Cement, LLC Project: The plant has a capacity of 210 tons/hour of dry preheater feed materials, 120 tons/hour of clinker production, and 150 tons/hour of Portland cement production. Annual (12-month rolling) production is limited to 1,648,578 tons of dry preheater feed materials; 965,425 tons of clinker production; and 1,191,360 tons of Portland cement production VOC Emission Limit: The VOC emission limit for this project was established in accordance with BACT at 0.15 pounds per ton of clinker, 30-day rolling average, and a THC BACT limit was set at 24 ppmvd, 30-day rolling average corrected to seven percent oxygen. These limits are to be achieved through good combustion practices
RBLC ID: CO-0074 Date: July 09, 2012 Company: GCC Rio Grande, Inc.
91 Project: Modify process at an existing facility. VOC Emission Limit: The VOC emission limit for this project was established in accordance with BACT at 0.149 pounds per ton of clinker, 12-month rolling average. The limit was to be achieved by good combustion practices and raw material management.
RBLC ID: GA-0136 Date: January 27, 2010 Company: Cemex Southeast, LLC Project: Construction of a new preheater/pre-calciner Portland cement plant rated at 3800 tons per day clinker. The new plant was to be constructed at the existing Cemex Clinchfield, Houston County, Georgia site. VOC Emission Limit: The CO emission limit for this project was established in accordance with BACT/PSD at 0.50 pounds per ton of clinker, 30-day rolling average. This emission limit was to be met by using good combustion practices, plant design and raw material management. It should be noted that this BACT determination by the Georgia EPD was identical to a determination made in 2008 or 2009 for a new, grass-roots preheater/pre-calciner Portland cement plant also proposed for a site in Houston County, Georgia.
RBLC ID: CO-0071 Date: October 15, 2009 Company: Holcim, Inc. Project: Modify process at an existing facility. Cement clinkering system, nominal design rated at a clinker production of 5,950 tons per day, and consisting of: one Polysius Dopol 90 AS preheater with R-564 calciner, 2 strings x 5 cyclones, and one Polysius, 17 feet diameter by 256 feet long, cement clinkering rotary kiln with alkali bypass. A slipstream (10 % typical) of the gas exiting the preheater is routed to coal mill for drying the coal. The rest of the gas stream is routed to the raw mill. VOC Emission Limit: The VOC emission limit for this project was established in accordance with BACT at 0.50 pounds per ton of clinker, 12-month rolling average. The limit was to be achieved by good combustion practices and raw material management.
6.6.3 Sources of THC/VOC in Portland Cement Plants The generation and oxidation of THCs generally parallels that of carbon monoxide; i.e., the THC formed in the pyroprocessing system is effectively oxidized in a well-designed calciner and the majority of THC in the stack gas is a result of the volatilization of organic matter present in the raw feed to the preheater. For this reason, the reader is referred to the preceding section (Section 6.5 – Carbon Monoxide) for a discussion of the design and operation of the calciner.
(a) Combustion Sources Because of the temperatures encountered in the kiln and calciner and because of the temperature, residence time and turbulence in the upper stages of the calciner, the majority of the THCs generated in the kiln and calciner are effectively oxidized. Based on tests in Florida plants, the
92 THC concentration in the gas stream leaving the calciner and entering the lower stages of the preheater is approximately 10 ppm; equivalent to a THC emission rate of approximately 0.1 pounds per ton of clinker.
(b) Raw Materials As reported in Section 6.5.3, the clay, Fuller’s earth, and limestone from the Clinchfield quarry have only trace amounts of kerogens. The limestone and clays constitute approximately 83 percent of the raw meal fed to the preheater and the Fuller’s earth represents approximately 15 percent of the raw meal. The imported additives, which make up the remaining two percent of the raw feed is provided by off-site suppliers. This material can be managed to assure that it contains acceptably low levels of THC precursors.
(c) Total THC Emissions Considering the fact that combustion related THCs entering the lower stages of the preheater are equivalent to a THC emission rate of approximately 0.1 pounds per ton of clinker, the variability of the kerogen concentrations in raw materials, and normal fluctuations in plant operating conditions, US Cement is proposing a BACT limit for THC of 24 ppm by dry volume corrected to seven percent oxygen (or approximately 0.15 pounds of THC per ton of clinker). This limit is consistent with the NESHAP, Subpart LLL emission limit for new kilns, it is reasonable based on site specific data available to US Cement and it is in the range of BACT Determinations for other recently permitted Portland cement plants. US Cement also is proposing this same emission limit as the BACT emission limit for VOC.
6.6.4 Description of THC/VOC Control Technologies To further reduce this THC emission rate would require the addition of add-on control equipment such as a thermal oxidizer. To date, add-on control has not been required as BACT for any cement plant in the United States, however two regenerative thermal oxidizers (RTOs) have been installed in the U.S. for other reasons. One was to allow the applicant to “net-out” of a PSD Review and the second was installed to reduce hydrocarbon emissions that resulted in an objectionable odor. These RTOs were installed at the TXI Midlothian Texas Plant (to avoid a PSD Review) and at the Holcim Dundee, Michigan Plant (for odor control).
As previously reported in Section 6.5, both facilities have reported problems with the operation of the RTOs. TXI has approached the Texas Commission on Environmental Quality (TCEQ) and requested a permit amendment allowing the shutdown of the RTO. The TCEQ ruled that the RTO was technically feasible but economically unreasonable and therefore, would have permitted TXI to operate without the RTO. As part of an agreement with third-party interveners however, TXI agreed to continue operating the RTO, but at a lower operating temperature. The lower operating temperature resulted in an approximate 85 percent control efficiency for THC and reduced operating costs and the operating problems.
93 Using cost data developed by TCEQ and TXI during the processing of the application for the amended permit and scaling these data to the proposed US Cement Plant, a control cost of approximately $42,000 per ton of THC removed has been estimated.O This is for 85 percent THC control; the control proposed for TXI under their amended permit.
6.6.5 THC/VOC BACT Selection The BACT limit proposed by US Cement for THC/VOC emissions is 24 ppm dry volume at seven percent oxygen, 30-kiln operating day average. This emission limit is equivalent to 0.15 pounds of THC/VOC per ton of clinker at the design stack gas flow rate. This limit is consistent with the NESHAP, Subpart LLL emission limit for new Portland cement plants. This THC/VOC BACT limit will be achieved by plant design, plant operating practices and raw material management. Add-on controls are not proposed consistent with recent BACT determinations and because studies reported herein have demonstrated add-on controls for THC are not cost effective.
6.7 Greenhouse Gases EPA regulates six greenhouse gas (GHG) compounds. GHG missions from the production of cement are comprised of three of the six; carbon dioxide (CO2), methane (CH4), and nitrous oxide(N2O). EPA document “Available and Emerging Technologies for Reducing Greenhouse Gas Emissions from the Portland Cement Industry (EPA White Paper)” provides GHG BACT guidance specific to the cement industry. EPA recommends energy efficiency, fuel, raw material, and add-on control techniques as measures to be considered to reduce GHG emissions.
For Portland cement kilns, GHG emissions can result from two independent sources. The first source is from the combustion processes in the kiln and calciner resulting in emissions of CO2, CH4, and N2O and the second is from the oxidation of carbonaceous material (primarily limestone) in the raw feed introduced to the preheater that results in CO2 emissions. Reducing the fraction of carbonaceous material in fuels, e.g., through the use of alternative fuels such as biomass, can reduce GHG emissions. Even tires have up to 20 percent non-fossil fuel energy content.
Other processes in the production of cement that impact GHG emissions are related to reducing the amount of energy required to produce cement (e.g. use of high-efficiency separators in mills). The review investigates other GHG BACT determinations and the controls applied to achieve GHG BACT. Unlike other regulated pollutants, GHG pollutants are unique for high PSD threshold, no ambient standard apply (and therefore application of LAER), and intimate tie of energy efficiency to pollutant reduction.
Combustion-generated GHGs are largely fixed fractions of combustion related to type of fuel and are largely independent of the combustion process. Since 2012 EPA has required GHG mandatory Reporting where EPA established tabular composition of GHG produced from fuel type
O Texas Commission on Environmental Quality. Construction Permit Amendment – Review Analysis and Technical Review, Permit No. 1360A/PSE-TX-632MI. September 9, 2005.
94 combustion in rules developed for the GHG reporting rule, 40 CFR 98. Because of this rule, US Cement will be required to use a CO2 CEMS to monitor continuously the amount of CO2 emitted from the kiln system out of the main stack. EPA provides in 40 CFR 98, Table C-1 and C-2 the following GHG emissions factors.
Default CO2 Default high emission Fuel type heat value factor
Coal and coke mmBtu/short ton kg CO2/mmBtu Anthracite 25.09 103.69 Bituminous 24.93 93.28 Subbituminous 17.25 97.17
Natural gas mmBtu/scf kg CO2/mmBtu (Weighted U.S. Average) 1.026 × 10−3 53.06
Petroleum products—liquid mmBtu/gallon kg CO2/mmBtu Distillate Fuel Oil No. 1 0.139 73.25 Distillate Fuel Oil No. 2 0.138 73.96 Distillate Fuel Oil No. 4 0.146 75.04 Residual Fuel Oil No. 5 0.14 72.93 Residual Fuel Oil No. 6 0.15 75.1 Used Oil 0.138 74 Liquefied petroleum gases (LPG)1 0.092 61.71
Petroleum products—solid mmBtu/short ton kg CO2/mmBtu Petroleum Coke 30 102.41
Other fuels—solid mmBtu/short ton kg CO2/mmBtu Tires 28 85.97 Plastics 38 75 Wood and Wood Residuals (dry basis)5 17.48 93.8 Agricultural Byproducts 8.25 118.17 Peat 8 111.84 Solid Byproducts 10.39 105.51
Default
CH4 emission
factor (kg Default N2O emission
Fuel type CH4/mmBtu) factor (kg N2O/mmBtu) Coal and Coke (All fuel types in Table C-1) 1.1 × 10− 02 1.6 × 10− 03 Natural Gas 1.0 × 10− 03 1.0 × 10− 04 Petroleum Products (All fuel types in Table C-1) 3.0 × 10− 03 6.0 × 10− 04 Biomass Fuels—Solid (All fuel types in Table C-1, except wood and wood 3.2 × 10− 02 4.2 × 10− 03 residuals) Wood and wood residuals 7.2 × 10− 03 3.6 × 10− 03
The primary means of minimizing greenhouse gas emissions from the cement production operation are through minimizing the amount of heat input required per ton of clinker produced and minimizing the amount of clinker per ton of cement. This new kiln system is targeting 2.6 to 2.8 million BTU per ton of clinker which is extremely efficient for cement kilns and minimizes the amount of heat input required. The less fuel used per ton of clinker will result in less GHG emissions for that type of fuel. The type of fuel, as shown in the table above is a primary factor as well, to reduce GHG emissions.
The BACT review involves the five steps reviewed in the introduction of this section. Each of these steps as well as a review of recent cement plant GHG BACT determinations are discussed below.
95 6.7.1 Description of Greenhouse Gases Control Technologies STEP 1: IDENTIFY ALL AVAILABLE CONTROL TECHNOLOGIES
The EPA White Paper identifies the methods to reduce GHG emissions in Table 3 of that document, and most will be applicable to this new facility. The categories of controls are as follows: 1) Energy Efficiency Improvements in Raw Material Preparation 2) Energy Efficiency Improvements in Clinker Production 3) Energy Efficiency Improvements in Finish Grinding 4) Energy Efficiency Improvements in Facility Operations 5) Raw Material Substitution and Blended Cements
Energy Efficiency Improvements in Raw Material Preparation a) Raw material transport will use mechanical systems b) Belt Conveyor will be used instead of pneumatic systems c) The blend silo will be a gravity type homogenizing silo d) The raw mill will use high-efficiency roller mills e) All separators will be state-of-the-art high efficiency f) Coal mill will be a roller mill
Energy Efficiency Improvements in Clinker Production a) The facility will use automated process controls to maintain the kiln at optimum levels. The kiln will have automated flame adjustment and fuel rate controls with series of modern process monitors, temperature, O2, CO, pressures, etc.. b) Kiln seals will be regularly maintained through a maintenance plan with regular routine inspections on the seals and during major outages c) The combustion system will be extremely energy efficient and expected to regularly achieve 2.8 mmbtu/ton clinker produced d) Kiln preheater insulation will be installed as a requirement to achieve the extremely high energy efficiency e) Refractory material will be selected to be optimum material design for the kiln f) The clinker cooler will be a high efficiency grate cooler g) The kiln motor drive will be adjustable and high-efficiency h) The preheater will have firing in the extension loop i) The kiln will use low CO2-emitting fossil fuels, e.g., natural gas, as market available j) The kiln will use biogenic fuels to replace fossil fuels, as market available. The facility use a wide range of alternative fuels selected to be compatible with kiln operation and clinker quality requirements, as requested in the permit
Energy Efficiency Improvements in Finish Grinding a) Finish mill classifiers will be high efficiency to reduce operation per ton of cement
96 b) As the market demands, US Cement can produce cement with higher ratio of additives as requested in the permit. However, this contingent on market demands
Energy Efficiency Improvements in Facility Operations a) High efficiency motors with variable speed drives will be used b) The compressed air system will be optimized
There are other controls offered by EPA. However, the other controls are based on retrofitting older existing kilns or use of materials/fuels not available to the US Cement facility. Oxygen enrichment has been shown to be feasible, however there are no reasonable sources of oxygen in the vicinity of the US cement site and making that an infeasible option.
The other primary control that is offered by EPA but that is clearly infeasible is Carbon Capture and Sequestration (CCS). Multiple analyses have been completed since the EPA White Paper showing that the cost of CCS is well beyond a feasible control and cost. Even the feasibility of the technology remains at pilot scale studies and not operational full-scale CCS systems on cement plants.
STEP 2: ELIMINATE TECHNICALLY INFEASIBLE OPTIONS The infeasible options for the US Cement plant include CCS, oxygen enrichment and obtaining fuels or raw materials not available in the market. While fuels or materials may become available at some point in the future, the application of those options are not definitive and should not be requirements, especially given the primary focus to reduce GHG emissions will be through extremely efficient operation of this state-of-the-art plant.
STEP 3: RANK REMAINING CONTROL TECHNOLOGIES As nearly all of the energy efficiency related processes and designs discussed in Step 1 are to be implemented, a ranking of the control technologies is not needed. As discussed above, the mix of fuel will be determined by fuel cost, availability, reliability of source providers, reliability of consistent fuel product, and inherent variations in kiln operations due to raw material composition variabilities. Similarly the raw material mix will be determined based on availability, impact on kiln operations, and cement product quality demands.
STEP 4: EVALUATE MOST EFFECTIVE CONTROLS AND DOCUMENT RESULTS The itemized controls listed above are the most effective controls. The EPA lists the expected energy efficient improvements in Table 3 of the EPA White Paper. EPA White Paper is attached (Attachment H).
6.7.2 Recent BACT Determinations The EPA RACT/BACT/LAER Clearinghouse (RBLC) was reviewed for BACT determinations made over the period 2009-2019 that would limit and control CO2e emissions from Portland cement plants that were subject to PSD. The following determinations were found since 2009.
97
RBLC ID: TX-0822 Date: June 30, 2017 Company: Capitol Aggregates, Inc. Project: New dry process Portland cement kiln added at an existing facility. Greenhouse Gases Emission Limit: The CO2e emission limit for this project was established in accordance with BACT/PSD at 0.97 ton per ton of clinker, annual average applied through good combustion practices.
RBLC ID: TX-0821 Date: August 7, 2017 Company: Alamo Cement Company Project: New dry process Portland cement kiln added at an existing facility. Greenhouse Gases Emission Limit: The CO2e emission limit for this project was established in accordance with BACT/PSD at 0.961 ton per ton of clinker, annual average applied through good combustion practices.
RBLC ID: TX-0831 Date: December 6, 2017 Company: GCC Permian LLC Project: Addition of Kiln No. 3, a new cement kiln with a production capacity of 3,300 tons of clinker per day. Kiln No. 3 will eventually replace Kiln No. 1 (currently authorized under NSR Permit No. 8410), but elements of the Kiln No. 1 process equipment will be repurposed for use with Kiln No. 3. Kiln No. 1 will remain in operation until Kiln No. 3 is activated. At no time will Kiln Nos. 1 and 3 operate simultaneously. Greenhouse Gases Emission Limit: A 0.92 ton CO2e/ton clinker, annual average limit applied through good combustion practices.
RBLC ID: NY-0115 Date: December 9, 2014 Company: LaFarge Building Materials Inc. Project: New dry process Portland cement kiln added at an existing facility. Greenhouse Gases Emission Limit: The CO2e emission limit for this project was established in accordance with BACT/PSD at 0.950 ton per ton of clinker, 12-month average.
RBLC ID: CO-0074 Date: July 9, 2012 Company: GCC Rio Grande, Inc. Project: Modify process at existing facility Greenhouse Gases Emission Limit: The CO2e emission limit for this project was established in accordance with BACT/PSD at 0.950 ton per ton of clinker, 12-month average.
98
RBLC ID: IL-0111 Date: December 20, 2011 Company: Universal Cement Project: New Greenfield Facility Greenhouse Gases Emission Limit: The CO2e emission limit for this project was established in accordance with BACT/PSD at 0.930 ton per ton of clinker, 12-month average through use of a multi-stage preheater/precalciner kiln with selection of refractory and a kiln seal management program
STEP 5: SELECT THE BACT
6.7.3 Proposed BACT The US Cement CO2e emission limit proposed as BACT is 0.95 pounds per ton of clinker, 12- month rolling average. This will be achieved by good combustion practices, plant design, and raw materials management to the degree practical.
6.8 Mercury Although mercury is not a PSD pollutant, and hence not subject to BACT as the proposed emission rate is less than 200 pounds per year, potential mercury emissions are addressed herein because of the mercury emission limits contained in the NESHAP (40 CFR 63, Subpart LLL) and CISWI (40 CFR 60, Subpart CCCC). Both of these rules limit Mercury emissions from new Portland cement plants to 21 pounds per million tons of clinker; or to 23.1 pounds per hour from the proposed US Cement plant.
For the proposed plant, US Cement is proposing a mercury emission limit equivalent to the NESHAP/CISWI emission limits; i.e., a limit of 21 pounds per million tons of clinker. The limit was established by considering the total potential mercury content of all of the raw materials and fuels that will be introduced to the plant, deducting any mercury that might be withdrawn through the process of dust shuttling (with enhancements introduced by activated carbon injection if necessary), and assuming all of the remaining mercury is released to the atmosphere through the kiln/raw mill/cooler stack. The mercury transferred to the finish mill during dust shuttling will be incorporated in the cement product and will not be released to the atmosphere.
It is interesting to note that if the proposed US Cement plant operated 100 percent of the time annually at the NESHAP/CISWI compliance mercury emission rate, the annual mercury emissions would be 23.1 pounds per year. This emission rate is well below the significant emission rate of 200 pounds per year for mercury; hence mercury is not subject to PSD and a BACT analysis.
99 7. Conclusions The proposed emission limits for particulate matter (PM/PM10), sulfur dioxide (SO2), nitrogen oxides (NOx), carbon monoxide (CO), volatile organic compounds (VOC) and greenhouse gases for the proposed US Cement kiln are based on emission limits and/or the application of control technologies that have been recently accepted and permitted as BACT for Portland cement plants by various states or are limits that are lower than most if not all kilns. Based on initial modeling, the BACT emission limits proposed in this report will not cause or contribute to a violation of any air quality standard, PSD increment, or any other applicable state or federal regulation.
The proposed plant design information provided in the application and this report provides the GaEPD reasonable assurance that the construction and operation of the proposed plant will not discharge, emit, or cause pollution in contravention of any applicable standard or rule.
100 ATTACHMENT A
SIP FORMS
101
6. Reason for Application: (Check all that apply) New Facility (to be constructed) Revision of Data Submitted in an Earlier Application Existing Facility (initial or modification application) Application No.: Permit to Construct Date of Original Permit to Operate Submittal: Change of Location Permit to Modify Existing Equipment: Affected Permit No.:
7. Permitting Exemption Activities (for permitted facilities only): Have any exempt modifications based on emission level per Georgia Rule 391-3-1-.03(6)(i)(3) been performed at the facility that have not been previously incorporated in a permit? No Yes, please fill out the SIP Exemption Attachment (See Instructions for the attachment download)
8. Has assistance been provided to you for any part of this application? No Yes, SBAP Yes, a consultant has been employed or will be employed. If yes, please provide the following information: Name of Consulting Company: Koogler and Associates, Inc. Name of Contact: Dr. John Koogler and Dr. Maxwell Lee Telephone No.: (352) 377-5822 Fax No.: (352) 377-7158 Email Address: [email protected] Mailing Address: Street: 4014 NW 13TH ST City: Gainesville State: Florida Zip: 32609 Describe the Consultant’s Involvement: Application preparation, PSD Analysis, BACT determination, engineering calculations and air dispersion modeling.
9. Submitted Application Forms: Select only the necessary forms for the facility application that will be submitted. No. of Forms Form 1 2.00 Emission Unit List 1 2.01 Boilers and Fuel Burning Equipment 2.02 Storage Tank Physical Data 2.03 Printing Operations 2.04 Surface Coating Operations 2.05 Waste Incinerators (solid/liquid waste destruction) 1 2.06 Manufacturing and Operational Data 1 3.00 Air Pollution Control Devices (APCD) 3.01 Scrubbers 1 3.02 Baghouses & Other Filter Collectors 3.03 Electrostatic Precipitators 1 4.00 Emissions Data 1 5.00 Monitoring Information 1 6.00 Fugitive Emission Sources 1 7.00 Air Modeling Information
10. Construction or Modification Date
Georgia SIP Application Form 1.00, rev. February 2019 Page 2 of 5 Estimated Start Date: Construction start March 2020, Operation start March 2022
11. If confidential information is being submitted in this application, were the guidelines followed in the “Procedures for Requesting that Submitted Information be treated as Confidential”? No Yes
12. New Facility Emissions Summary New Facility Criteria Pollutant Potential (tpy) Actual (tpy) Carbon monoxide (CO) 1595 Nitrogen oxides (NOx) 825 Particulate Matter (PM) (filterable only) 76.6 PM <10 microns (PM10) 76.6 PM <2.5 microns (PM2.5) 18.5
Sulfur dioxide (SO2) 220 Volatile Organic Compounds (VOC) 80 Greenhouse Gases (GHGs) (in CO2e) 1,045,000 Total Hazardous Air Pollutants (HAPs) 25.6 Individual HAPs Listed Below: See Application Report
13. Existing Facility Emissions Summary Current Facility After Modification Criteria Pollutant Potential (tpy) Actual (tpy) Potential (tpy) Actual (tpy) Carbon monoxide (CO) NA Nitrogen oxides (NOx) Particulate Matter (PM) (filterable only) PM <10 microns (PM10) PM <2.5 microns (PM2.5)
Sulfur dioxide (SO2) Volatile Organic Compounds (VOC) Greenhouse Gases (GHGs) (in CO2e) Total Hazardous Air Pollutants (HAPs) Individual HAPs Listed Below:
Georgia SIP Application Form 1.00, rev. February 2019 Page 3 of 5
14. 4-Digit Facility Identification Code: SIC Code: 3273 SIC Description: Cement and Concrete Product Manufacturing NAICS Code: 327310 NAICS Description: Cement Manufacturing
15. Description of general production process and operation for which a permit is being requested. If necessary, attach additional sheets to give an adequate description. Include layout drawings, as necessary, to describe each process. References should be made to source codes used in the application.
Refer to attached Application Report.
16. Additional information provided in attachments as listed below: Attachment A - Application Report Attachment B - Electronic Modeling / Emissions Inventory (to be provided per approval of pollutant limits) Attachment C - Attachment D - Attachment E - Attachment F -
17. Additional Information: Unless previously submitted, include the following two items: Plot plan/map of facility location or date of previous submittal: See Application Report Flow Diagram or date of previous submittal: See Application Report
18. Other Environmental Permitting Needs: Will this facility/modification trigger the need for environmental permits/approvals (other than air) such as Hazardous Waste Generation, Solid Waste Handling, Water withdrawal, water discharge, SWPPP, mining, landfill, etc.? No Yes, please list below: See Attachment to Application Report
Georgia SIP Application Form 1.00, rev. February 2019 Page 4 of 5 19. List requested permit limits including synthetic minor (SM) limits.
NA
20. Effective March 1, 2019, permit application fees will be assessed. The fee amount varies based on type of permit application. Application acknowledgement emails will be sent to the current registered fee contact in the GECO system. If fee contacts have changed, please list that below:
Fee Contact name: Cary Cohrs, same as in Application Report Fee Contact email address: same as in Application Report Fee Contact phone number: same as in Application Report
Fee invoices will be created through the GECO system shortly after the application is received. It is the applicant’s responsibility to access the facility GECO account, generate the fee invoice, and submit payment within 10 days after notification.
Georgia SIP Application Form 1.00, rev. February 2019 Page 5 of 5 Facility Name: US Cement, LLC Date of Application: October 7, 2019
FORM 2.00 – EMISSION UNIT LIST
Emission Name Manufacturer and Model Number Description Unit ID Raw Material Quarrying, This emission unit comprises the quarry and its equipment: K101 Polysius, custom Crushing and Storage one crusher and three conveyor belts.
This emission unit comprises the following buildings/silos with their respective stacks, baghouses (see SIPform4.00 for details of Stack IDs, see SIPform3.00 for details of Baghouse IDs): Limestone Circular Blending Bed Silo (Tier_1) – no stack Raw Materials Raw Mill Additives Building (Tier_2) – no stack K102 Conveying, Storage and Polysius, custom Raw Mill Building (Tier_3) with the following stacks, baghouses: Processing - Raw Mill Bucket Elevator stack (STK1, CD01) - Raw Mill Rejects Bin stack (STK2, CD02) - Raw Meal Transport stack (STK3, CD03) Raw Meal Silo (Tier_4): - Raw Meal Silo stack (STK5, CD05) This emission unit comprises the pyroprocess system: Raw Mill, Kiln and Clinker Cooler main stack (ST22, CD22) This emission unit comprises the following buildings with their respective stacks, baghouses (see SIPform4.00 for details of Stack IDs, see SIPform3.00 for details of Baghouse IDs): Preheater Tower (Tier_5) with the following stacks, baghouses: K103 Pyroprocessing System Polysius, custom - Raw Meal Mixing Bin stack (STK6, CD06) - Kiln Feed Transport stack (STK7, CD07) Clinker Cooler (Tier_6): - Clinker Transport stack (STK8, CD08) Filter Dust Surge Bin stack (STK4, CD04) Raw Mill air heater – no stack, vents to main stack This emission unit comprises two clinker silos each having two stacks, baghouses: Clinker Silo No. 1 (Tier_7A) Clinker and Additive - Clinker Silo No. 1 stack (STK9, CD09) K104 Polysius, custom Storage and Handling - Clinker Silo Extraction No. 1 stack (ST11, CD11) Clinker Silo No. 2 (Tier_7B) - Clinker Silo No. 2 stack (ST10, CD10) - Clinker Silo Extraction No. 2 stack (ST12, CD12)
Georgia SIP Application Form 2.00, rev. June 2005 Page 1 of 3 This emission unit comprises the Finish Mill (Tier_8) with four stacks, baghouses: Finish Mill (Cement - Finish Mill stack (S20A, C20A) K105 Polysius, custom Grinding) - Sepol stack (S20B, C20B) - Dust Shuttle Bin stack (S20C, C20C) - Cement Mill Bucket Elevator stack (ST13, CD13)
This emission unit comprises the following buildings/silos with their respective stacks, baghouses (see SIPform4.00 for details of Stack IDs, see SIPform3.00 for details of Baghouse IDs): Cement Silo No. 1 (Tier_10A) - Cement Silo No. 1 stack (ST17, CD17) Cement Silo No. 2 (Tier_10B) Cement Handling, - Cement Silo No. 2 stack (ST16, CD16) K106 Storage, Packing and Polysius, custom Cement Silo No. 3 (Tier_10C) Loadout - Cement Silo Bulk Loading No. 1 stack (ST15, CD15) Cement Silo No. 4 (Tier_10D) - Cement Silo Bulk Loading No. 2 stack (ST14, CD14) Cement Packing Plant (Tier_11) - Cement Packing Plant stack (ST19, CD19) Cement Mill Additives Building (Tier_12) – no stack
This emission unit comprises the following buildings/silos with their respective stacks, baghouses (see SIPform4.00 for details of Stack IDs, see SIPform3.00 for details of Baghouse IDs): Coal and Petroleum Coke Coal Mill (Tier_9): K107 Polysius, custom Grinding System - Coal Mill stack (ST21, CD21) - Fine Coal Bin stack (ST18, CD18) Fuels (coal, coke, alternative fuels) storage building (Tier_13) – no stack
Stationary Emergency Emergency Generator to operate kiln rotation in case of loss of K108 TBD Generators CI RICE power
Georgia SIP Application Form 2.00, rev. June 2005 Page 2 of 3
Georgia SIP Application Form 2.00, rev. June 2005 Page 3 of 3 Facility Name: US Cement, LLC Date of Application: October 7, 2019
FORM 2.01 – BOILERS AND FUEL BURNING EQUIPMENT
Design Capacity Percent Dates Emission Type of Burner Type of Draft1 of Unit Excess Date & Description of Last Modification Unit ID (MMBtu/hr Input) Air Construction Installation
K103 Kiln / Raw mill air heater Induction 400/43 TBD TBD new K108 Emergency Generators new
1 This column does not have to be completed for natural gas only fired equipment.
Georgia SIP Application Form 2.01, rev. June 2005 Page 1 of 3 Facility Name: US Cement, LLC Date of Application: October 7, 2019
FUEL DATA
Hourly Heat Percent Ash in Potential Annual Consumption Percent Sulfur Consumption Content Solid Fuel Total Quantity Percent Use by Season Emission Fuel Type Ozone Unit ID Non-ozone Season Max. Avg. Min. Avg. Max. Avg. Max. Avg. Amount Units Season May 1 - Sept Oct 1 - Apr 30 30 1,050 K103 Natural gas 4075 mmscf 100 100 0.465 Neg. Neg. Btu/scf 13,000 0.6 - K103 Coal 135000 ton 0 0 15.4 4 - 20% Btu/lb 5.4% Petroleum 13,300 0.5 - 0.05 – K103 125000 ton 0 0 14 coke Btu/lb 1% 2.8% Distillate Fuel 140,000 0.2 - K103 oil (No. 2 or 28 mmgal 0 0 0.003 Neg. Btu/gal 1% No. 4) On-spec used 140,000 0.4 - K103 28 mmgal 0 0 0.003 0 - 4% oil Btu/gal 1.5% Off-spec used 140,000 0.4 - K103 28 mmgal 0 0 0.003 0 - 4% oil Btu/gal 1.5% 14,000 K103 tires 117000 ton 0 0 13 Btu/gal Alternative to be K103 ton 0 0 10 5000 10 Btu/ton 0 - 1% 1 - 25% fuels determined* Fuel oil (No. 2 140,000 0.2 - K108 0.0001 mmgal 0 0 0.0001 Neg. or No. 4) But/gal 1%
* See Application Report for list of expected alternative fuels and heat input potential
Fuel Supplier Information Supplier Location Fuel Type Name of Supplier Phone Number Address City State Zip Natural gas To be determined Coal To be determined Petroleum To be determined coke
Georgia SIP Application Form 2.01, rev. June 2005 Page 2 of 3 Distillate To be determined Fuel oil
(No. 2 or No. 4) On-spec To be determined used oil Off-spec To be determined used oil tires To be determined Alternative To be determined fuels
Georgia SIP Application Form 2.01, rev. June 2005 Page 3 of 3 Facility Name: US Cement, LLC Date of Application: October 7, 2019
FORM 2.06 – MANUFACTURING AND OPERATIONAL DATA
Normal Operating Schedule: 24 hours/day 7 days/week 52 weeks/yr Additional Data Attached? - No - Yes, please include the attachment in list on Form 1.00, Item 16.
Seasonal and/or Peak Operating N/A Periods:
Dates of Annually Occurring Shutdowns: Not defined
PRODUCTION INPUT FACTORS
Emission Const. Input Raw Hourly Process Input Rate Emission Unit Name Annual Input Unit ID Date Material(s) Design Normal Maximum Raw Material Limestone, fuller’s 3000 2000 3000 K101 Quarrying, Crushing, 9/2020 2,000,000 earth, clay tons/hr tons/hr tons/hr and Storage Limestone, fuller’s Raw Materials earth, clay, mill 300 225 300 K102 Conveying, Storage, 9/2020 2,000,000 scale, slag, coal tons/hr tons/hr tons/hr and Processing ash Limestone, fuller’s 140 Pyroprocessing earth, clay, mill 140 125 tons/hr K103 9/2020 2,000,000 System scale, slag, coal tons/hr tons/hr (30-day ash avg) Clinker and Additive Clinker and K104 9/2020 1,400,000 180 160 180 Storage and Handling Additives Finish Mill (Cement Clinker and K105 9/2020 1,400,000 180 160 180 Grinding) Additives Cement Handling, K106 Storage, Packing, and 9/2020 Cement 1,400,000 500 250 500 Loadout Coal and Petroleum K107 9/2020 Solid fuels 130,000 30 20 30 Coke Grinding System Stationary Emergency K108 9/2020 Fuel NA Generators CI RICE
PRODUCTS OF MANUFACTURING
Emission Production Schedule Hourly Production Rate Description of Product (Give units: e.g. lb/hr, ton/hr) Unit ID Tons/yr Hr/yr Design Normal Maximum Units 140 K103 Clinker 1,100,000 8760 140+ 125 (30kiln op ton/hr day avg) K106 Cement 1,400,000 8760 500 250 500 ton/hr
Georgia SIP Application Form 2.06, rev. June 2005 Page 1 of 2
Georgia SIP Application Form 2.06, rev. June 2005 Page 2 of 2 Facility Name: US Cement, LLC Date of Application: October 7, 2019
Form 3.00 – AIR POLLUTION CONTROL DEVICES - PART A: GENERAL EQUIPMENT INFORMATION
Gas Temp. F Inlet Gas APCD Emission APCD Type Date Make & Model Number Unit Modified from Mfg (Baghouse, ESP, Flow Rate Unit ID Unit ID Installed (Attach Mfg. Specifications & Literature) Specifications? Scrubber etc) Inlet Outlet (acfm) No CD01 K102 Baghouse Polysius - TBD 200 8,000 No CD02 K102 Baghouse Polysius - TBD 200 6,000 No CD03 K102 Baghouse Polysius - TBD 200 1,000 No CD04 K103 Baghouse Polysius - TBD 300 6,000 No CD05 K102 Baghouse Polysius - TBD 200 22,000 No CD06 K103 Baghouse Polysius - TBD 200 4,000 No CD07 K103 Baghouse Polysius - TBD 200 1,000 No CD08 K103 Baghouse Polysius - TBD 300 3,000 No CD09 K104 Baghouse Polysius - TBD 300 6,500 No CD10 K104 Baghouse Polysius - TBD 300 4,000 No CD11 K104 Baghouse Polysius - TBD 200 600 No CD12 K104 Baghouse Polysius - TBD 200 600 No CD13 K105 Baghouse Polysius - TBD 200 8,000 No CD14 K106 Baghouse Polysius - TBD 200 12,000 No CD15 K106 Baghouse Polysius - TBD 200 12,000 No CD16 K106 Baghouse Polysius - TBD 200 3,000 No CD17 K106 Baghouse Polysius - TBD 200 3,000 No CD18 K107 Baghouse Polysius - TBD 200 800
Georgia SIP Application Form 3.00, rev. June 2005 Page 1 of 4 No CD19 K106 Baghouse Polysius - TBD 200 12,000 No C20A K105 Baghouse Polysius - TBD 219 35,098 No C20B K105 Baghouse Polysius - TBD 144 129,291 No C20C K105 Baghouse Polysius - TBD 200 6,000 No CD21 K107 Baghouse Polysius - TBD 170 11,706 No CD22 K103 Baghouse Polysius - TBD 250 379,052 No CD23 K103 SNCR Polysius - TBD 1544 2012 NA Activated No CD24 K103 Polysius - TBD 350 300 NA Carbon Injection Water Spray No CD25 K103 Polysius - TBD 700 300 NA System
Georgia SIP Application Form 3.00, rev. June 2005 Page 2 of 4 Facility Name: US Cement, LLC Date of Application: October 7, 2019
Form 3.00 – AIR POLLUTION CONTROL DEVICES – PART B: EMISSION INFORMATION
Percent Control Inlet Stream To APCD Exit Stream From APCD Pressure Drop APCD Efficiency Pollutants Controlled Across Unit Unit ID Method of Method of Design Actual lb/hr lb/hr (Inches of water) Determination Determination CD01 99.999+ Manufacturer’s PM/PM10/PM2.5 0.21/0.21/0.03 guarantee CD02 99.999+ Manufacturer’s PM/PM10/PM2.5 0.16/0.16/0.02 guarantee CD03 99.999+ Manufacturer’s PM/PM10/PM2.5 0.03/0.03/0.003 guarantee CD04 99.999+ Manufacturer’s PM/PM10/PM2.5 0.14/0.14/0.02 guarantee CD05 99.999+ Manufacturer’s PM/PM10/PM2.5 0.59/0.59/0.07 guarantee CD06 99.999+ Manufacturer’s PM/PM10/PM2.5 0.11/0.11/0.01 guarantee CD07 99.999+ Manufacturer’s PM/PM10/PM2.5 0.03/0.03/0.003 guarantee CD08 99.999+ Manufacturer’s PM/PM10/PM2.5 0.07/0.07/0.001 guarantee CD09 99.999+ Manufacturer’s PM/PM10/PM2.5 0.15/0.15/0.002 guarantee CD10 99.999+ Manufacturer’s PM/PM10/PM2.5 0.09/0.09/0.001 guarantee CD11 99.999+ Manufacturer’s PM/PM10/PM2.5 0.02/0.02/0.0002 guarantee CD12 99.999+ Manufacturer’s PM/PM10/PM2.5 0.02/0.02/0.0002 guarantee CD13 99.999+ Manufacturer’s PM/PM10/PM2.5 0.21/0.21/0.06 guarantee CD14 99.999+ Manufacturer’s PM/PM10/PM2.5 0.32/0.32/0.1 guarantee CD15 99.999+ Manufacturer’s PM/PM10/PM2.5 0.32/0.32/0.1 guarantee CD16 99.999+ Manufacturer’s PM/PM10/PM2.5 0.08/0.08/0.02 guarantee CD17 99.999+ Manufacturer’s PM/PM10/PM2.5 0.08/0.08/0.02 guarantee CD18 99.999+ Manufacturer’s PM/PM10/PM2.5 0.02/0.02/0.003 guarantee
Georgia SIP Application Form 3.00, rev. June 2005 Page 3 of 4 CD19 99.999+ Manufacturer’s PM/PM10/PM2.5 0.32/0.32/0.1 guarantee C20A 99.999+ Manufacturer’s PM/PM10/PM2.5 0.89/0.89/0.27 guarantee C20B 99.999+ Manufacturer’s PM/PM10/PM2.5 3.69/3.69/1.10 guarantee C20C 99.999+ Manufacturer’s PM/PM10/PM2.5 0.16/0.16/0.02 guarantee CD21 99.999+ Manufacturer’s PM/PM10/PM2.5 0.17/0.17/0.02 guarantee CD22 99.999+ Manufacturer’s PM/PM10/PM2.5 4.86/4.86/1.87 guarantee Proposed BACT CD23 1.5 lb/tonC, 210 NOx 12-77% (1.5 lb NOx/ton N/A lb/hr clinker) CD24 21 lb/mmtonC, Hg 40-90% NESHAP LLL limit N/A 0.00014 lb/hr
Georgia SIP Application Form 3.00, rev. June 2005 Page 4 of 4 Facility Name: US Cement, LLC Date of Application: October 7, 2019
FORM 3.02 – BAGHOUSES & OTHER FILTER COLLECTORS
Pressure Filter Surface Inlet Gas Dew Inlet Gas APCD No. of Bag or Filter Drop Gas Cooling Leak Detection Area Point Temp. Temp. Cleaning Method ID Bags Material (inches of Method System Type (ft2) (F) (F) water) Pulse jet CD01 * * * * polyester 6 NA none
Pulse jet CD02 * * * * polyester 6 NA none
Pulse jet CD03 * * * * polyester 6 NA none
Pulse jet CD04 * * * * polyester 6 NA none
Pulse jet CD05 * * * * polyester 6 NA none
Pulse jet CD06 * * * * polyester 6 NA none
Pulse jet CD07 * * * * polyester 6 NA none
Pulse jet CD08 * * * * polyester 6 NA none
Pulse jet CD09 * * * * polyester 6 NA none
Pulse jet CD10 * * * * polyester 6 NA none
Pulse jet CD11 * * * * polyester 6 NA none
Pulse jet CD12 * * * * polyester 6 NA none
Pulse jet CD13 * * * * polyester 6 NA none
Pulse jet CD14 * * * * polyester 6 NA none
Pulse jet CD15 * * * * polyester 6 NA none
Pulse jet CD16 * * * * polyester 6 NA none
Pulse jet CD17 * * * * polyester 6 NA none
Pulse jet CD18 * * * * polyester 6 NA none
Georgia SIP Application Form 3.02, rev. June 2005 Page 1 of 2 Page 1 of Pulse jet CD19 * * * * polyester 6 NA none
Pulse jet C20A * * * * polyester 6 NA none
Pulse jet C20B * * * * polyester 6 NA none
Pulse jet C20C * * * * polyester 6 NA none
Pulse jet CD21 * * * * polyester 6 NA none
Pulse jet CD22 * * * * polyester 6 NA none
Attach a physical description, dimensions and drawings for each baghouse and any additional information available such as particle size, maintenance schedules, monitoring procedures and breakdown/by-pass procedures. Explain how collected material is disposed of or utilized. Include the attachment in the list on Form 1.00 General Information, Item 16
Georgia SIP Application Form 3.02, rev. June 2005 Page 2 of 2 Page 2 of Facility Name: US Cement, LLC Date of Application: October 7, 2019
FORM 4.00 – EMISSION INFORMATION
Emission Rates Air Pollution Emission Stack Actual Control Pollutant Emitted Hourly Actual Hourly Potential Potential Annual Unit ID ID Annual Method of Device ID Emissions Emissions Emission Emission Determination (lb/hr) (lb/hr) (tpy) (tpy)
K102 CD01 STK1 PM/PM10/PM2.5 N/A 0.21/0.21/0.03 N/A 0.84/0.84/0.1 Manuf. Guarantee
K102 CD02 STK2 PM/PM10/PM2.5 N/A 0.16/0.16/0.02 N/A 0.63/0.63/0.08 Manuf. Guarantee
K102 CD03 STK3 PM/PM10/PM2.5 N/A 0.03/0.03/0.003 N/A 0.1/0.1/0.01 Manuf. Guarantee
K102 CD05 STK5 PM/PM10/PM2.5 N/A 0.59/0.59/0.07 N/A 2.31/2.31/0.28 Manuf. Guarantee
K103 CD04 STK4 PM/PM10/PM2.5 N/A 0.14/0.14/0.02 N/A 0.55/0.55/0.07 Manuf. Guarantee
K103 CD06 STK6 PM/PM10/PM2.5 N/A 0.11/0.11/0.01 N/A 0.42/0.42/0.05 Manuf. Guarantee
K103 CD07 STK7 PM/PM10/PM2.5 N/A 0.03/0.03/0.003 N/A 0.1/0.1/0.01 Manuf. Guarantee
K103 CD08 STK8 PM/PM10/PM2.5 N/A 0.07/0.07/0.001 N/A 0.27/0.27/0.004 Manuf. Guarantee K103 (kiln CD22 ST22 PM/PM10/PM2.5 N/A 4.86/4.86/1.87 N/A 19.11/19.11/7.36 LLL rule stack)
K103 CD22 ST22 SO2 N/A 54.1 N/A 212.7 BACT
K103 CD22 ST22 NOX N/A 203.0 N/A 797.6 BACT
K103 CD22 ST22 CO N/A 392.5 N/A 1542.0 BACT
K103 CD22 ST22 VOC N/A 20.5 N/A 80 BACT
K103 CD22 ST22 CO2e N/A 133.0 N/A 1,045,000 GHG rule
K103 CD22 ST22 Hg N/A 0.0029 N/A 0.012 LLL rule
K103 CD22 ST22 HCl N/A 2.12 N/A 9.27 LLL rule
K103 CD22 ST22 DF N/A 0 N/A 0 LLL rule
Georgia SIP Application Form 4.00, rev. June 2011 Page 1 of 2 K104 CD09 STK9 PM/PM10/PM2.5 N/A 0.15/0.15/0.002 N/A 0.59/0.59/0.008 Manuf. Guarantee
K104 CD10 ST10 PM/PM10/PM2.5 N/A 0.09/0.09/0.001 N/A 0.36/0.36/0.005 Manuf. Guarantee
K104 CD11 ST11 PM/PM10/PM2.5 N/A 0.02/0.02/0.0002 N/A 0.06/0.06/0.001 Manuf. Guarantee
K104 CD12 ST12 PM/PM10/PM2.5 N/A 0.02/0.02/0.0002 N/A 0.06/0.06/0.001 Manuf. Guarantee
K105 CD13 ST13 PM/PM10/PM2.5 N/A 0.21/0.21/0.06 N/A 0.84/0.84/0.25 Manuf. Guarantee
K105 C20A S20A PM/PM10/PM2.5 N/A 0.89/0.89/0.27 N/A 3.51/3.51/1.05 Manuf. Guarantee
K105 C20B S20B PM/PM10/PM2.5 N/A 3.69/3.69/1.10 N/A 14.54/14.54/4.33 Manuf. Guarantee
K105 C20C S20C PM/PM10/PM2.5 N/A 0.16/0.16/0.02 N/A 0.63/0.63/0.08 Manuf. Guarantee
K106 CD14 ST14 PM/PM10/PM2.5 N/A 0.32/0.32/0.1 N/A 1.26/1.26/0.38 Manuf. Guarantee
K106 CD15 ST15 PM/PM10/PM2.5 N/A 0.32/0.32/0.1 N/A 1.26/1.26/0.38 Manuf. Guarantee
K106 CD16 ST16 PM/PM10/PM2.5 N/A 0.08/0.08/0.02 N/A 0.31/0.31/0.09 Manuf. Guarantee
K106 CD17 ST17 PM/PM10/PM2.5 N/A 0.08/0.08/0.02 N/A 0.31/0.31/0.09 Manuf. Guarantee
K106 CD19 ST19 PM/PM10/PM2.5 N/A 0.32/0.32/0.1 N/A 1.26/1.26/0.38 Manuf. Guarantee
K107 CD18 ST18 PM/PM10/PM2.5 N/A 0.02/0.02/0.003 N/A 0.08/0.08/0.01 Manuf. Guarantee K107(coal CD21 ST21 PM/PM10/PM2.5 N/A 0.17/0.17/0.02 N/A 0.66/0.66/0.08 LLL rule mill stack) Engineering K107 CD21 ST21 SO2 N/A 1.9 N/A 7.3 Judgement Engineering K107 CD21 ST21 NOX N/A 7.0 N/A 27.4 Judgement Engineering K107 CD21 ST21 CO N/A 13.5 N/A 53.0 Judgement Hg (combine K107 CD21 ST21 N/A N/A LLL rule emissions w ST22) THC (combine K107 CD21 ST21 N/A N/A LLL rule emissions w ST22) HCl (combine K107 CD21 ST21 N/A N/A LLL rule emissions w ST22)
Georgia SIP Application Form 4.00, rev. June 2011 Page 2 of 2 Facility Name: US Cement, LLC Date of Application: October 7, 2019
FORM 5.00 MONITORING INFORMATION
Emission Monitored Parameter Emission Unit/APCD Monitoring Unit ID/ Name Frequency APCD ID Parameter Units Temperature at inlet to K103/CD22 Pyroprocessing System degrees Continuous baghouse Particulate Matter K103/CD22 Pyroprocessing System % Continuous (parametric)
K103/CD23 Pyroprocessing System NOX CEMS ppmvd Continuous
K103/CD23 Pyroprocessing System SO2 CEMS ppmvd Continuous K103/CD23 Pyroprocessing System THC CEMS ppmvw Continuous ppmvw/ O2 CEMS (diluent ppmvd K103/CD23 Pyroprocessing System monitor to convert THC Continuous (wet and dry values to to 7% O2) determine moisture) K103/CD23 Pyroprocessing System Clinker Production Ton/hr Continuous
K103/CD23 Pyroprocessing System CO2 CEMS ppmw Continuous K103/CD23 Pyroprocessing System FLOW CMS acfm Continuous K103/CD23 Pyroprocessing System CO CEMS ppmw Continuous K103/CD23 Pyroprocessing System Hg ppmw Continuous K103/CD23 Pyroprocessing System HCl ppmw Continuous
K103/CD23 Pyroprocessing System Water spray in. H2O Continuous
Comments: Monitoring requirements are based on 40 CFR 63, Subpart LLL and BACT. Some monitoring is not required but used to monitor and control pollution
Georgia SIP Application Form 5.00, rev. June 2005 Page 1 of 1 Facility Name: US Cement, LLC Date of Application: October 7, 2019
FORM 6.00 – FUGITIVE EMISSION SOURCES
Fugitive Emission Reduction Pot. Fugitive Emissions Emission Description of Source Precautions Source ID Amount (tpy) Pollutant
FP1 Mining Truck Loading Surface treatment control 0.03/0.01/0.003 PM/PM10/PM2.5
FP2 Truck Unloading Surface treatment control 0.03/0.01/0.003 PM/PM10/PM2.5
FP3 Crusher 0.22/0.1/0.018 PM/PM10/PM2.5 Crusher to Conveyor 1 Transfer TP0 0.1/0.03/0.009 PM/PM10/PM2.5 Point Conveyor 1 to Conveyor 2 TP1 0.1/0.03/0.009 PM/PM10/PM2.5 Transfer Point Conveyor 2 to Conveyor 3 TP2 0.1/0.03/0.009 PM/PM10/PM2.5 Transfer Point Truck Travel to and from Mine & TT1 Water Truck 21.11/21.11/2.11 PM/PM10/PM2.5 Crusher Truck Travel to and from Cement TT2 Sweeper 2.170/2.170/0.533 PM/PM10/PM2.5 Packing Plant Truck Travel to and from Cement TT3 Sweeper 0.006/0.006/0.001 PM/PM10/PM2.5 Mill Additives Truck Travel to and from Raw TT4 Sweeper 1.252/1.252/0.307 PM/PM10/PM2.5 Mill Additives
Georgia SIP Application Form 6.00, rev. June 2005 Page 1 of 1 Facility Name: US Cement, LLC Date of Application: October 7, 2019
FORM 7.00 – AIR MODELING INFORMATION: Stack Data
Dimensions of largest Stack Information Exit Gas Conditions at Maximum Emission Rate Structure Near Stack Stack Emission Height Inside ID Unit ID(s) Exhaust Height Longest Velocity Temperature Flow Rate (acfm) Above Diameter Direction (ft) Side (ft) (ft/sec) (F) Grade (ft) (ft) Average Maximum STK1 K102 122 2.0 Vertical 112 63 42 200 8,000 8,000 STK2 K102 40 1.5 Vertical 112 63 57 200 6,000 6,000 STK3 K102 51 1.0 Vertical 112 63 21 200 1,000 1,000 STK4 K103 91 1.5 Vertical 57 300 6,000 6,000 STK5 K103 261 3.0 Vertical 225 48.5 52 200 22,000 22,000 STK6 K103 64 1.2 Vertical 315 95 54 200 4,000 4,000 STK7 K103 49 1.0 Vertical 315 95 21 200 1,000 1,000 STK8 K103 45 1.0 Vertical 67 100 64 300 3,000 3,000 STK9 K104 199 1.5 Vertical 189 76 61 300 6,500 6,500 ST10 K104 199 1.2 Vertical 189 76 54 300 4,000 4,000 ST11 K104 10 1.0 Vertical 189 76 13 200 600 600 ST12 K104 10 1.0 Vertical 189 76 13 200 600 600 ST13 K105 77 1.7 Vertical 112 105 55 200 8,000 8,000 ST14 K106 196 1.0 Vertical 186 48 64 200 12,000 12,000 ST15 K106 196 2.0 Vertical 186 48 64 200 12,000 12,000 ST16 K106 29 1.0 Vertical 186 48 64 200 3,000 3,000 ST17 K106 29 1.0 Vertical 186 48 64 200 3,000 3,000 ST18 K107 87 1.0 Vertical 135 70 17 200 800 800 ST19 K106 33 2.0 Vertical 92 140 64 200 12,000 12,000 S20A K105 138 4.0 Vertical 112 105 47 219 35,098 35,098 S20B K105 138 7.0 Vertical 112 105 56 144 129,291 129,291
Georgia SIP Application Form 7.00, rev. June 2005 Page 1 of 3 S20C K105 70 1.5 Vertical 112 105 57 200 6,000 6,000 ST21 K107 53 2.0 Vertical 135 70 62 170 11,706 11,706 ST22 K103 350 12.0 Vertical 56 250 379,052 379,052
NOTE: If emissions are not vented through a stack, describe point of discharge below and, if necessary, include an attachment. List the attachment in Form 1.00 General Information, Item 16. For fugitive volume and line volume sources refer to emission inventory tables.
Georgia SIP Application Form 7.00, rev. June 2005 Page 2 of 3 Facility Name: US Cement, LLC Date of Application: October 7, 2019
FORM 7.00 AIR MODELING INFORMATION: Chemicals Data
Potential MSDS Chemical Emission Rate Toxicity Reference Attached (lb/hr) Refer to attached Application Report for TAPS data
Georgia SIP Application Form 7.00, rev. June 2005 Page 3 of 3 ATTACHMENT B
PROCESS FLOW DIAGRAMS
102 8 I 7 I 6 I 5 .. 4 I 3 I 2 I 1
D D
REFo DRAWING TITLE
- 0001 INDE - 0002 RAW MATERIAL CRUSHING 0003 RAW MATERIAL STORAGE 0004 RAW GRINDING FEED BINS 0005 RAW GRINDING SYSTEM 0006 MAIN BAG HOUSE AND DUST TRANSPORT 0007 RAW MEAL BLENDING c 0008 KILN FEED c 0009 PREHEATER AND CALCINER 0010 KILN AND TERTIARY AIR DUCT 0011 CLINKER COOLER 0012 CLINKER AND ADDITIVE STORAGE PLANT ELEVATION: 0013 CLINKER AND ADDITIVE TRANSPORT EI ABQ~E SEA LE~EL 0014 CEMENT GRINDING SYSTEM ---. 0015 GRINDING AID SYSTEM .- LEGEND 0016 CEMENT TRANSPORT B LB/H COMBUSTIBLE FLOW 0017 CEMENT STORAGE AND TRUCK LOADING D FT DIAMETER 0018 COAL GRINDING VERTICAL MILL G ST/H MATERIAL FLOW 0019 COAL GRINDING AND CONVEYING SYSTEM H % MATERIAL MOISTURE 0020 PLANT COMPRESSED AIR SYSTEM HU BTU/LB NET CALOR VALUE B 0021 NOX REDUCTION SYSTEM SNCR B K IN GRAIN SIZE PACKING PLANT KB CM 2/G BLAINE 0022
KR % RESIDUAL 200 MESH
M HP MOTOR POWER
N RPM SPEED
P INWG STAT PRESSURE
Q MBTU!H HEAT qUANTITY - as BTU/LB HEAT QUANTITY 3 S G/FT DUST CONTENT 3 SG LB/FT BULK DENSITY T OF TEMPERATURE
TP OF DEW POINT Go"",' To'"""•• to ISO "5BmK US CEMENT LLC "0'0" ",sting' to ISO MGO. Oro," UT OF AMBIENT TEMPERATURE: HOUSTON, GA "rio", fln"h to ISO 130' oaF MIN '""' ,eok to "''''''I he;,ot R, ~m) Th.ln'orrnotio",on','nodh",'nr.,"n"'""tiolon.tho Woldod ""o,,,,.. ,ijon to ISO '''20 110'F MAX proportyofTh,,,.nKnJpplnoyotrioISolyijon,(USA),lno,lt r"oll,'.nded 'oc "bI;,,"o",Th.;"'orrn,';o" ";"',,. g~:: - ~~ ~;I:~' A w,'h tho ,n'o"",""", tho' "" port th",of 'h,II b. A comm,nlcotad to 0 thkd po,,>, .fthout w,ltl.n "tho""tlo, Th'" "",I. () = BY OTHERS 'com Th"" ••"K""p In,,,tool >Ol,tloo. (u>.0. 100, P"J",,"on
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T OF TEMPERATURE
TP OF DEW POINT G"",,,' Tol"""",,, to ISO 27""mK US CEMENT LLC """0" Coot'o,. to ISO ""62, Om"p UT OF AMBIENT TEMPERATURE: HOUSTON, GA S,rio", flo"h to ISO ,'", O°F MIN """ ""ok to ""II", he;,ht Ro ~m) Tho "foemotlon ,o,t","" h.,.I, 10 ,0,fldo,tI.1 on" tho Wold.d <'on"",.. ,t;on to '''''' ''''0 110'F MAX pr.",,~ of Th)',enKnJpp Ind"o\~.1 Solu~o", (USA). Inc, It ,. no' ,,'.nd.d foc "bI"otIon, Th.;nforrnotlon ,,;"'.. g~:: t~ ~;I:~' A w,th tho "doeoten",n, th.t "" po" th.,.of .h,II b. A commonlco,"d to , thl," ,ort> .Ith"" written oothorl"Uo, Th,,",,,,,I. () = 8Y OTHERS 'com ."",. D D FROM 201.8C02 I SHT -002 I , - TO t:a-I 2Ll.TPOl r---- I SHT-004 I ~'m 2L1.BCOl ~ 2G1.8G01 C ~ C ~"IV'/'/~~/ / \ .., ~ @ ... ffra ...1\ ST PLANT ELEVATION: L ~:\ <,'< ~ ~- EI ABQ~E SEA LE~EL 2Gl.C~~ ~ --- LEGEND OPERATING DESIGN l G I - I - B LB/H COMBUSTIBLE FLOW I H I - , 0 FT DIAMETER TO 301.AWOl G ST/H MATERIAL FLOW ~ I SHT 004 I H % MATERIAL MOISTURE HU BTU/LB NET CALOR VALUE B B K IN GRAIN SIZE KB CM 2/G BLAINE 3C1.BCOl KR % RESIDUAL 200 MESH M HP MOTOR POWER N RPM SPEED P INWG STAT PRESSURE Q MBTU!H HEAT qUANTITY - QS BTU/LB HEAT QUANTITY 3 S G/FT DUST CONTENT 3 SG LB/FT BULK DENSITY T of TEMPERATURE Preliminary TP OF DEW POINT ".,"", To'"",,", to ISO '76BmK Date: 08/1412019 US CEMENT LLC "O'9h C"tln,. to Isa aG62, Oro," UT OF AMBIENT TEMPERATURE: HOUSTON, GA Sort,,,,, "";,h to ISD 13Q2 oaF MIN 1101 JAA '""' ,eo, to ","ey he;,ht R, ",m) Th.lofo,,"otro" '"0"'0"" h".,o loooo"'ootiol 0"tho W.Id"" C","'"",O", '" ISO ',.,20 110'F MAX property of Th,,,.nKrupp In.",Uiol SolllUon, (USA),_ lno, It ;"otl,'ood""'''p,bI'oo',",.Th,,",,,,,,,,,",,,,.,,.d g~t - i~~ ~;1:~' A w;th tho ,ndo"","d,", thot '0 port tho,,'" 'holl b, A comm"',,,,"d to 0 thkd po"" wrtho,' w,ltt,n "tho,1"tlon Th,"'''''". () = BY OTHERS '"m Th,.... ,K"". 'ndy"',"' So"tlo", (USA). 'no_ p"J",,"on V % VOLATILE MATTER ~ Co,troot Nom. USC9512 ()ontrootN. *82200 9512 VB ACFM GAS FLOW thyssenkrupp MECHANICAL PROCESS FLOW SHEET ~pl_SakJllDnl(USA),Inc. RAW MATERIAL STORAGE SCFM GAS FLOW VN A_.~" 3000 STPD CLINKER vs seF/LB GAS FLOW '"" NER 6 JUN 2016 51'"'00 o. D"ooptlo, 00" Dot. Chkd 00. ,"' 00. 00" 1134406 1- 3 VY FT /S GAS FLOW Revisions ,"' .. 1"00'. NONE -.l.:h.'t 0030' 022 8 I 7 I 6 I 5 i" 4 I 3 2 I 1 8 I 7 I 6 I 5 .. 4 I 3 I 2 I 1 D D FROM 2L1.BCOl I SHT-003 I 1 OVERBURDEN ASH MILL SCALE/ (CLAY) IRON ORE TO+ 3Fl.BCOl FROM 3C1.8C02 I SHT-005 I - I SHT -003 I - ~~.3,000 ~T.. "" ~ ~~<- 1;q.D? :sT.. 0 0 A~~2Ll.TPOl 2L 1.TP02 2L 1.TP03 , \301.FH011 '\OLFH021 '\01.FH031 ~q:::J g:J g:J <> <> <> ci2 <> <> <> <> <> 3Dl.AWOl 3D1.AW02 301.AW03 3Dl.AW04 I G I- I G I- G I I I I I 3E1.MSOl C I H I- I I H I- I I H I- I 3El.ANOl C [L]] ~ 3El.BWOl ~ 3E1.8C01 [L]] OPERATING DESIGN G I - I - I ~ etLJ PLANT ELEVATION: EI ABQ~E SEA LE~EL ~ --- LEGEND S LS/H COMBUSTIBLE FLOW ° FT DIAMETER G ST/H MATERIAL FLOW H % MATERIAL MOISTURE HU BTU/LB NET CALOR VALUE B B K IN GRAIN SIZE KS CM 2/G BLAINE KR % RESIDUAL 200 MESH M HP MOTOR POWER N RPM SPEED P INWG STAT PRESSURE Q MBTU!H HEAT qUANTITY QS STU/LS HEAT QUANTITY f- 3 S G/FT DUST CONTENT 3 SG LB/FT BULK DENSITY T 'F TEMPERATURE Preliminary TP 'F DEW POINT Date: 08/1412019 Go,,",' To'"""•• to ISO "5BmK US CEMENT LLC "o'Oh "osting' to ISO MGO. Oro," UT 'F AMBIENT TEMPERATURE: 1101 HOUSTON, GA "rio", fl,;,h to ISO 130' oaF MIN JAA -'" ,eok to ",11"'1 he;,h' Ro ~m) Th.',forrnotio"o,to',odh""""o'"'""tlolo,dtho Wold .. """,,,.. ,ij,n to ISO '''20 110'F MAX propertyofTh,,,.nKnJppl,dyotrioISol\l\;on,(USA).lno.lt ;"ot','.nd.. foc"bI,,,ijo,.Th.,,forrn,tro,,,;,,,,," g~:: - ~~ ~;I:~' A w,'h tho ,n'o"","d", tho' '0 port th",of 'holl b. A comm,nlcotad to 0 thkd ,0"," wltho", w,ltl.n "tho""tlo, Th'" "",I. et = BY OTHERS from Th,.,' ~pl_SakJllDnl(USA),Inc. RAW GRINDING FEED BINS SCFM GAS FLOW VN A_.~" 3000 STPD CLINKER NER 6 JUN 2018 VS SCF /LS GAS FLOW '"" 1 0" 0" o ..o"tlo, 00. Chkd O~ ,"' O~ DI'"' " 1134406 3 VY FT /S GAS FLOW '"" '"" Revisions ,"' - 1',01. NONE ISho.t 004 of 022 8 T 7 I 6 I 5 I"- 4 T 3 2 I 1 8 7 6 5 4 3 2 I I I I I I ,,------, 3Fl.BFOl*t:r=7 3F1.BF01. IIIIIII1 FNJOl I '" I IIIIIII1 IIIIIII1 3Fl.FN01.FLJ~\ 3Fl.~2 3Fl~GOl 3E1.8C01FROM Ill,fq :----- /~ .--l:I F 3Fl.GP04 TO L 3Fl.BF01. 4El.PBOl D I SHT-004 I I ;J: FVJOl D ([~~~~~~~~- . ~ &!f3F 1.FNOl I SHT-006 I r * , 3Ft;]"" * 3Fl.FNO~02 ® a:::k==",Q",: 3F 1 .BCDl :0 3Fl.GP03 3F1.CF;J-E:! ~1.FL03 3Fl.BEOl - - RECYCLE. BYPASS f 3Fl.RFOl ®--4V ,------"~~3Dl~.""3Fl.BF01. '?l"~ ------;:!ij...., FROM 3Jl.BFOl FNJOl 3Fl.BFOl 3Jl.ALOl 4El.PDOl ~*EJC73J1.BF01. VI SHT -006 I 3Fl.GP06 mnnn FNJOl ~= / 13". 3F1.FA02 ~ I------I~ ~"- ~~ 3Jl RVOl :l!t1I. c rVI .i!~3J1.BF01. c I I ~f R_V_D_'_--\_ FROM cgJ ~~:7;~:;-~;;;;;;;;;;;;;;;;;;;;;J~;;;;;;"e~~;;;;;;;;;;;;~3:F~'3J1.TC01.FNJOl :.G:P:DS~;;;;;;]:I!": .3Fl.FLOl 3J1.BF02 Et3Fl.BF01.RVJOl ~ 3J1.TCOl : 'I-:SCc HT::"_'::oCC07o--,l 3Fl.FBOl REJECTS I 150 *T TO 3Fl.MT02 3Fl.GP02 A 1--\ 3J 1 .BF02 3Fl.NGOl SHT 007 I I 3Fl.BW02 cgJ 3J 1.TC02 I I PLANT ELEVATION: 3Fl.SEOl ~ ET ABOVE SEA LEVEL 3Fl.ZDOl .ORVOl 3Jl.TC02. FNJOl ~r------A LEGEND cgJ 3Jl.TC03-:r: 3J 1.TC03. j B LB/H COMBUSTIBLE FLOW ~~ I 3Fl.SEOl I FNJOl o FT DIAMETER 3Fl .CP071 r=1C=~""'.::''''\:,:\S:;E~P;;O;O:L:..c;1o::M!:.R::.;3:S:';D_:W FROM TO G ST/H MATERIAL FLOW '\<'" /) _ 4S1.FNOl 3J1.QSOl H % MATERIAL MOISTURE HU BTU/LB NET CALOR VALUE l!:;j-;===~ \'\'~QMO~/ /'I===~~~~~~:::>-:?!::::==3:F~1.=F=AO=1=3=F=1.=G=PD='======ir==~::::l3~k~=·S=G=O=2=:::::!.===1 =S3=HFT~1-~GO=p~=1,=I==1=S=HT=-=O=0::l7 ~ 4g~~01 B~~--~--~------~ K IN GRAIN SIZE QUAOROPOL I SHT -009 I B QMR2 )8/19 () BLAINE ----&O---DIi-i ~ _BY CUSTOMER 3Fl.HGOl KR % RESIDUAL 200 MESH 3F1.WJ01 G I 10 I WATER INJECTION ~rr:<':;-~$I!"lu:t$l!"=::::;J;"~--,:llr-'G"'A~S ~BY CUSTOMER M HP MOTOR POWER N RPM SPEED . FAN DESIGN 1 0 1 - 1 FROM P - 1 HEIGHT 1 - 1 3F1.GP04 T SHT-005 I I va 4El.SKOl o I 4EHN01~ II- o 4El.GPOl // Z ur.;:::I==;.J~-~.J:;=~II~==;;;::::::==;;;===;;;======""'"",,«~~ ~ )2' 4EI.GP02 .....!!!. - - .Jll .Jll .Jll ~ ~ 4EI.FN01 4E1.FN01.FLJ02 1111111111 111111111111 1111111111 IIIIIIII11 IIIIIIII1111 IIIIIIII11 1111111111 4E1.PBOl 1111111111 IIIIIIII11 4El.PB01 IIIIIIII11 PULSE 1111111111 1111111111 IIIIIIII11 IIIIIIII11 JET 1111111111 SOUTH 1111111111 IIIIIIII11 NORTH IIIIIIII11 1111111111 1111111111 IIIIIIII11 IIIIIIII11 FILTER M 1- 1 1111111111 '" R~,'«, 1111111111 IIIIIIII11 '" R~,'«, IIII111111 1111111111 111111111111 1111111111 1111111111 111111111111 1111111111 N 1 1 1111111111 111111111111 1111111111 1111111111 111111111111 1111111111 - uuuuu uuuuu uuuuu uuuuu uuuuu uuuuu - 1'"'0 '"' '0' ,",'0 '0' '"' '0' 1'"' '0' '"' 4E1 paOHVJOI =-i~ r =-! 4E1 paOHVJO?=-! =-i =-! 4ELPaOLFVJll 4E1 PBOl FVJ02c::m-1?/~ CD{ ~\ 4E1 PBOl FVJ08CD{ c::m-I~~~CD{ 4E1.PB01.FVJ12 4E1 PB01.FVJ03J I / \\E1 PB01.FVJ05 ~~- -4E1 PB01.FVJ09 1 G 1 - 4E1.PB01.FVJ04J 4E1 PBOl FVJ06 4E1 PB01.FVJ10 ~ 4E1.BFOI.FVJ01 c c 4E1 1 HI- T- PLANT ELEVATION: TO FILTER DUST 3J1.ALOl -- SURGE BIN EI AIlQllE SEA LEllEL 4E1.FB01 ---. I SHT -005 I LEGEND a LajH COMBUSTIBLE FLOW ~ 7 __ 4_E_1~BN01 ~~_~ 4E1.FGOl _ '\. ' D FT DIAMETER C T l ~, '~G~-~ ______~r~'@~ ~ G ST/H MATERIAL FLOW 4E1.RF01 VFD I H % MATERIAL MOISTURE ([) HU BTU/LB NET CALOR VALUE 4El.SCOl B 4E1.RB03 B K IN GRAIN SIZE 2 Ka CM !G BLAINE KR % RESIDUAL 2DD MESH rTO M HP MOTOR POWER 4Cl.TC02 N RPM SPEED I SHT -008 I P INWG STAT PRESSURE 0 MBTU/H HEAT qUANTITY - OS BTUjLa HEAT QUANTITY 3 S G!FT DUST CONTENT SG LB/FT :3 BULK DENSITY T of TEMPERATURE TP 'F DEW POINT US CEMENT LLC "o'Oh Coot;n,. to ISO ""62. Gro,p_ UT of AMBIENT TEMPERATURE: HOUSTON, GA S,rio", fI";,h to ISO ,"", O"F MIN """" ""ok to ",II.,. he;,h' Ro ~m) 110"F MAX A () = BY OTHERS v % VOLATILE MATTER USC9512 2200 9512 va ACFM GAS FLOW Preliminary thyssenkrupp MECHANICAL PROCESS FLOW SHEET Date: 08/1412019 _"__ ,"",'~ MAIN BAGHOUSE AND DUST TRANSPORT VN SCFM GAS FLOW '-._' 3000 STPD CLINKER VS seF jLa GAS FLOW 110/ JAA ,", NER 6 JUN 2018 D,m'pllo" ,~ 0'" ,~ ." ,~ DI'"" 1134406 I"" 3 GAS '"" vv FT /S FLOW Revisions ." ~ NONE ISh •• t 006 of 022 8 I 7 I 6 I 5 4 I 3 2 8 6 5 3 I 7 I I 4 I I 2 I =.~i1i1lii 3Kl.BF02.FNJOl IIIIIII1 IIIIIII1 3JUl02 t'CC~ Ivai I o [------i \,::~:,":," L-'-'--__~ o .---- ___~F(1.BFa2 .FNJOl 3Jl.TC04 ---, , 3Jl.BF02 ~I I 3J l.TC04.FNJOl :: I:: I:: I VB I - I c9J I ./------l I I 3J1.BF02.FVJOl- ~ - 3Kl.BLOl : - ~-- ~"'~'"1-..I~_i'-- :I TO+ 3K1.BLOl I-a= I 3J1.TC03 ;::;:: .FNJOl SHT-005 FROM I I HOIST aEAM ~'JU~ ___ .LU~L~.LL*~ __l. n~------\c_ 4C1.VP01 2 ST I SHT -008 I TANGENTIAL HOMOGENIZING c SILO c 10,000 ST FROM OPERATING DESIGN 14m~ (46'-0"rll) 3Jl.TC03 -\-----, I G I - 1- I SHT -005 Ival- I I 3Kl.BLOl I Ival- I I j3K1.BL01 0071 FROM I 3J1.VP01() I~Kl.BLOl 3J1.TC03 3Kl.BL01.PPAOl I .0072 I I SHT -005 I PLANT ELEVATION: -~~+=d,=='7~ BIN MOUNTED II V81- I EI AIlQllE SEA LEllEL I / 3Kl.BFOl 3Kl.BF01.FNJOl \ ./ ~-IlI- 3K1.al01.PPA02 ~ 3J1.QS01 ~~/~=t!;V» \ IIIIIII1 ---- LEGEND ,-- /~ IIIIIII1 \ , a lajH COMBUSTIBLE FLOW \ ~ \ -, D FT DIAMETER ~~jk- : , , , G ST/H MATERIAL FLOW \~ : ~bb.., I -, , , H % MATERIAL MOISTURE , SAMPLE f>"- 3J 1.ACO 1 ~ , HU BTU/LB NET CALOR VALUE , B [i~i B K IN GRAIN SIZE t t 2 L_ P INWG STAT PRESSURE 0 MBTU/H HEAT QUANTITY 3K1.RB03 I-- OS aTUjla HEAT QUANTITY 3 S G/FT DUST CONTENT SG LB/FT 3 BULK DENSITY 4C1.TC01.FNJ01 T OF TEMPERATURE TP 'F DEW POINT TO 4C1.TC02 US CEMENT LLC "o'Oh Coot;n,. to ISO ""62. Oro,p UT OF AMBIENT TEMPERATURE: I SHT -008 I HOUSTON, GA S,rio", fI";,h to ISO ,"", O"F MIN ""'" ""ok to ",II.,. he;,h' Ro ~m) 110"F MAX A () = BY OTHERS v % VOLATILE MATTER USC9512 2200 9512 va ACFM GAS FLOW Preliminary thyssenkrupp MECHANICAL PROCESS FLOW SHEET Date: 08/1412019 RAW MEAL BLENDING VN SCFM GAS FLOW 3000 STPD CLINKER , VS seF jla GAS FLOW 110/ JAA .. NER 6 JUN 2018 D,m'pllo" .~ 0," .~ ." .~ ,," D1"" 1134406 I'· 3 GAS FLOW vv FT /S Revisions ." ~ NONE ISh •• t 007 of 022 8 7 6 5 4 3 2 T I I T 8 7 6 5 4 3 2 I I I I I I TO KILN SYSTEM D D TO 3Kl.BLOl -l,------_. 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B K IN GRAIN SIZE 4C1.ACOl BLAINE KR % RESIDUAL 200 MESH M HP MOTOR POWER N RPM SPEED P INWG STAT PRESSURE 4C1.RBOl 4C1.RB02 Q MBTU!H HEAT qUANTITY QS BTU/LB HEAT QUANTITY 3 S G/FT DUST CONTENT 3 SG LB/FT BULK DENSITY T OF TEMPERATURE TP OF DEW POINT US CEMENT LLC "o'OhO"';",.'oIS"""62.Gro,p UT OF AMBIENT TEMPERATURE: HOUSTON, GA "rio", "";,h '0 ISD 130' oaF MIN "" peok '0 "''''''I he;,h' R, ~m) 110'F MAX A () = BY OTHERS V % VOLATILE MATTER USC9512 2200 9512 VB ACFM GAS FLOW Preliminary thyssenkrupp MECHANICAL PROCESS FLOW SHEET Date: 08/1412019 KILN FEED VN SCFM GAS FLOW 3000 STPD CLINKER 1101 JAA NER 6 JUN 2018 VS SCF ILB GAS FLOW '"0 D1'0' 00 o ..ooptlo" 00. Chkd 00. ,"' ,~ 00" 1134406 Ie., GAS FLOW Revisions ,"' NONE ISh •• , 008 of 022 7 6 5 4 3 2 - T I I T 8 6 3 I 7 I I 5 4 I I 2 I 4Gl.EDOl 4G1.EVOl ct 4Gl.TVOl ~ ~ I 4Gl.PTOl 4G1.FAO~ iJi D ~ D CAPACITY 5,280 LBS. 5.000 GAL WATER I ~ WATER PU MP If------olt----, TANK SKID 1 rrn1~ 4GI.PS02V~ FROM '-- UA4.CP02 ---- \------SHT-020 - I I '" - 4G1.ET01 -jL , ~G1.PSOI P - !to T - = VB - ~ VN - 3Fl.GPOl 'y~~'.GPO' 3Fl.QMOlTO ___ t :::::~~~~::::::::::~~~~~~~~::~ f-" c 4Gl.FNOl "V" c I SHT -005 I ~~ <-----i FROM Gl.ET01.SCJOl t7\ ~ I- SNeR 4Gl.AJOl I M I SHT-021 N - 4Gl.PJOl 'I" I I 4El.ET01.FVJ01®i '!f®4El.ET01.FVJ02 TO+ '"* *"' CR1.RMOl I SHT -018 I PLANT ELEVATION: EI ABQ~E SEA LE~EL I4El.SC02 4El.SC03 ---- LEGEND + G I - I TO TRUCK TO B LB/H COMBUSTIBLE FLOW 4Cl.TC02 I SHT-008 I 0 FT DIAMETER G ST/H MATERIAL FLOW H % MATERIAL MOISTURE HU BTU/LB NET CALOR VALUE f------~ 4Gl.TD01.FNCOl B 4G l.TOO I B K IN GRAIN SIZE ~~ KB CM 2/G BLAINE FROM KR % RESIDUAL 200 MESH CW1.DGOl 4GI.B~ pv t M HP MOTOR POWER I SHT 019 FROM 4Kl.KHOl I RPM ~)J-~.eAOI N SPEED SHT -010 I P INWG STAT PRESSURE 4Gl KJOl ----- 4K1~~P01 Q MBTU!H HEAT qUANTITY (§I/!:J I SHT-OIO I QS BTU/LB HEAT QUANTITY 3 S G/FT DUST CONTENT SG 3 BULK DENSITY LB/FT CLEANING SYSTEM FOR PREHEATER T of TEMPERATURE 4G1.CG01 TP OF DEW POINT US CEMENT LLC "o'OhO"';",.'oIS"""62.Gro,p UT of AMBIENT TEMPERATURE: HOUSTON, GA "rio", "";,h '0 ISD 130' oaF MIN '""' pook '0 "''''''I he;,h' R, ~m) 110'F MAX A () = BY OTHERS V % VOLATILE MATTER USC9512 2200 9512 VB ACFM GAS FLOW Preliminary thyssenkrupp MECHANICAL PROCESS FLOW SHEET Date: 08/1412019 PREHEATER AND CALCINER VN SCFM GAS FLOW 3000 STPD CLINKER 1101 JAA NER 6 JUN 2018 VS SeF/LB GAS FLOW '"0 D1'0' 0o O"ooptlO" Chkd ,"' ,~ 00" 1134406 3 ". ". 1°" VY FT /S GAS FLOW Revisions ,"' NONE ISh •• , 009 of 022 8 7 6 5 4 3 2 - T I I T 8 I 7 I 6 I 5 .. 4 I 3 I 2 I 1 D D - - FROM CW2.DGOl I SHT -021 I C I c , TO 4Gl.TDOl I SHT -009 I ~ M ,h 4Kl.BUOl FROM 0 0 PLANT ELEVATION: 4G1.KJOl (13.78 x 196.85 'EET) SHT -009 - 4.2mx60m 4K1.KPOl EI ABQ~E SEA LE~EL I I III B!= \'- $" Q IVBI I ---. .'Q' .- ~ ''':T 4Kl.BU01.'NPOl LEGEND iK 'FDD 4Kl.KHOl 4Kl.KC02 4Kl.KCOl B COMBUSTIBLE FLOW LB/H IVBI I / ~ $ fcii) 4K1.BU01.'NeOl a 'T DIAMETER ~J<~ 1 VB G ST/H MATERIAL FLOW IVBI· I r.. 4Rl.PQOl SHT all H % MATERIAL MOISTURE 4Kl.KC02.FNCOl 4Kl.KC01.FNCOl,~ I I HU BTU/LB NET CALOR VALUE CMJ:=:::::: B 4Kl.KP01.FNCOl @.~ B K IN GRAIN SIZE ~ 4Kl.KP01.FNC02 KB CM 2/G BLAINE KR % RESIDUAL 200 MESH M HP MOTOR POWER N RPM SPEED P INWG STAT PRESSURE Q MBTU!H HEAT qUANTITY - QS BTU/LB HEAT QUANTITY 3 S G/FT DUST CONTENT 3 SG LB/FT BULK DENSITY T ., TEMPERATURE TP ., DEW POINT ".,,,,,, To'"",,", to ISO '7SBmK US CEMENT LLC "0'0" 0",;",. t. IS" ""62. G"," UT ., AMBIENT TEMPERATURE: HOUSTON, GA "rio", "";,h to ISD 130' oaF MIN '""' peok to ",11"'1 he;,ot Ro ~m) Th.1,'orrnotio"o,t,',odh""".,o,",gotlolo,dtho W.ldod "",,,,,.. ,Oon to ISO '''20 110'F MAX propertyofTh,,,enKrupplndyotrioISol\l\;on,(US/,),lno,lt ;, ,"','.ndod ,,, "bI'""o,,Th,',',rrn,',o, ,,;"',," g~~: - t~ ~;I:~' A wlth tho ,n'o"",""". thot '" port th",of 'holl b. A comm,nl,atad to 0 thkd po"" wltho,' w,1tl.n "tho""tlo, Th," "",I. () = BY OTHERS '"m Th"". M I- I N I - I TO 4S1.GP03 q 3Fl.QMOl p~ I SHT-Q05 I - \ c<~.:;/ 0- 0 ~ 4S1.GP02 0 P T - va - r D T 1 D - I ~ '------H -;u::::::r 1 -V4S1'CND1 - V - ~ j.. ~ j.. (ABOVE BURNER FLOOR) (BELOW BURNER FLOOR) 451.5C01 4T1.BFOl 1DT 'O\)--s- rmmfl FROM5T FROM 4Tl.BFOl IIIIIII1 UA1.CP02 UA1.CPOl .FNJOl ~I SHT-D22 SHT -022 C I II I r------l C k FROM I ..,-I 4K1.KHOl , G I - I ~ 4TI.aFOI. SHT-Ol0 , FVJOl I I I , , FROM 0 , 4Tl.AYOl , I ~ , SHT -012 Vi , I I , 451.5C02 DESIGN ~" ______J 4Rl.PQ01.FNJOl 4S1.GPOl PLANT ELEVATION: H2O , FT ABOVE SEA LEVEL i~ ~ I ---- LEGEND ." ." 4Rl.PQOl a LB/H COMBUSTIBLE FLOW :t:t:tn ____ ~2~y!~!'i.".. ..._,_~;;'_~_~;;':!' ____ •______I D FT DIAMETER i \ ( \~( \ ( \ 4R1.RROl TO '-1'-/ ,_J ,_/ 4T1.AYOl G ST/H MATERIAL FLOW ...... ~ ...... ! ! ! ! ! , , I SHT-012 I , , , , , , H % MATERIAL MOISTURE , , , , , , , , , ! ! , , , , HU BTU/LB NET CALOR VALUE , , , o 0 0 0 0 , B ' ' , , , 1 B K IN GRAIN SIZE O~' O~' 4RI.FN01 4RI.FN02 4RI.FN03 4RI.FN041"' 'INO~ 2 @)~ @) @) I Ka CM /G BLAINE IMI-I MI-I M- 4Rl.RR01.FNCOl 4Rl.FN06 4Rl.FN07 TO 4R1.RR01.F KR % RESIDUAL 200 MESH I M I- 1M 1- 4T1.AY01 M - SHT -012 M HP MOTOR POWER d b I I N RPM SPEED 4Rl.PQ01.HYSOl 4R1.CGOl HYDRAULIC UNIT P INWG STAT PRESSURE STATIC GRATE FOR POLYTRACK CLEANING AND ROLL a MaTU/H HEAT QUANTITY SYSTEM CRUSHER I-- aS BTU/LB HEAT QUANTITY 3 S G/FT DUST CONTENT 3 SG LB/FT BULK DENSITY T "F TEMPERATURE TP 'F DEW POINT G",,,,I Tol""""", to ISO 27""mK US CEMENT LLC "ooOh Coot"" to ISO ""62. Gmop UT 'F AMBIENT TEMPERATURE; HOUSTON, GA S,rio" fI",h to ISO ,'", O'F MIN """ ""ok to ""II", h,;,ht Ro ~m) Tho "foemotlon ,o,to',"" h"'" I. ,0,fI,,,tI.1 ood tho Wold.d <'on""""';on to '''''' ''''0 110"F MAX propert' of Th)",nKnJPP Ind"o\~ol Solu~o", (USA). Inc, It r.no';n'.nd.dfoc"bI;,otIon,Th.;nforrnotlon" r",od g~:: - t~ ~;I:~' A w,th tho "doe""nd,n, th.t "" port th",of .holl b. A commonlco,"d to , thlm port> .Ith"" written oothorl"Uo, Th,,,,,,,,,I. () = BY OTHERS 'com """"" 7.5S~ o o iiilJrJ 4Tl.BF03 -S-~ 4Tl.BF02.FNJOl rnnn,= .FNJOl 4Tl.BF02 uu..u..u VB I - I 4T1.BF03 FROM =-*IIIIIII I VB 14,000 4Rl.SC02 UUUU I SHT-Ql1 I \L---I----' ,----~~ ::r 4T1.BF03.FVJOl FROM FROM 4T1.BF02.FVJ01 =r I : 4Rl.PQOl I 4Tl.8FOl r A I M 1- II t SHT -011 SHT -all - I I I I 1 ST I - I I 1:1 ST I I 'V: I 4Tl.AYOl l I I 4T1.CFOl I CAPACITY: 900 Ibs I ~;It;H"" I A 1------j OPER. DESIGN I I G I - I- 4T1.BWOl I G I - I c I *f-=-L--~- * c OPERATING DESIGN rGT - 1- = FVFD f PLANT ELEVATION: j EI AIlQllE SEA LEllEL TO 5E2.BWOl 5El.AYOl 5E2.8C01 --- LEGEND I SHT-013 I B LBjH COMBUSTIBLE FLOW I G I - CLINKER CLINKER D FT DIAMETER 4Vl.KLOl 4Vl.KL02 G ST/H MATERIAL FLOW 25,000 STONS 25,000 STONS H % MATERIAL MOISTURE HU BTU/LB NET CALOR VALUE B B K IN GRAIN SIZE 2 KB CM !G BLAINE KR % RESIDUAL 200 MESH M HP MOTOR POWER N RPM SPEED P INWG STAT PRESSURE 0 MBTU/H HEAT qUANTITY I-- OS BTUjLB HEAT QUANTITY 3 S G!FT DUST CONTENT SG LB/FT :3 BULK DENSITY TO CLINKER AND TO CLINKER AND ADDITIVE ADDITIVE T of TEMPERATURE TRANSPORT TRANSPORT TP 'F DEW POINT I SHT-013 I I SHT-013 I US CEMENT LLC "0'0" Cootln,. to ISO ""62. Oro"P UT of AMBIENT TEMPERATURE: HOUSTON, GA S'rio", fl",h to ISO ,"", O"F MIN ""'" ",,'k to ",II.,. he;,h' R, ~m) 110"F MAX A () = BY OTHERS v % VOLATILE MATTER USC9512 2200 9512 VB ACFM GAS FLOW Preliminary thyssenkrupp MECHANICAL PROCESS FLOW SHEET Date: 08/1412019 CLINKER AND ADDITIVE STORAGE VN SCFM GAS FLOW 3000 STPD CLINKER VS seF JLB GAS FLOW 110/ JAA '"" NER 6 JUN 2018 ,~ ,~ ,~ 1'"0" D''"''ptlo" ." D 1134406 1"00 3 0'" CO" vv FT /S GAS FLOW Revisions ." ~ NONE ISh •• t 012 of 022 8 7 6 5 4 3 2 T I I T 8 I 7 I 6 I 5 .. 4 I 3 I 2 I 1 D D FROM FROM 4Vl.KLOl 4Vl.KL02 I SHT -012 I I SHT 012 I - 5El.5Y02 SE1.SV03 5El.SVD4 SE1.SV05 SE1.SV06 - 5E1S~ ~/~/ ~~/~/ - ~ ~ ~ WINTER SUMMER M I- I G 1- - VFD T 1- - -- FROM -%clj-%GrP -%elj-%GYP ~9 5E2.8C01 C I SHT -012 I C lJ;o1FNJ01 J;02.FNJ01 I VB I - I VB I - I --- I --- r------l;:------l ~III IIII ~III IIII 5El.BWOl ~ 5El.BFOl / 5El.AYOl 5El.BF02/ I I G 1 - G 1 - , , PLANT ELEVATION: 1 1 , , TO EI ABQ~E SEA LE~EL 5Fl.TMOl 1 1 I SHT -014 I ~ --- LEGEND FROM FROM 5Fl.GBOl 5Fl.GB02 B LB/H COMBUSTIBLE FLOW I SHT-017 I I SHT -017 I ° FT DIAMETER G ST/H MATERIAL FLOW H % MATERIAL MOISTURE HU BTU/LB NET CALOR VALUE B B K IN GRAIN SIZE KB CM 2/G BLAINE KR % RESIDUAL 200 MESH M HP MOTOR POWER N RPM SPEED P INWG STAT PRESSURE Q MBTU!H HEAT qUANTITY C- as BTU/LB HEAT QUANTITY 3 S G/FT DUST CONTENT 3 SG LB/FT BULK DENSITY T of TEMPERATURE TP OF DEW POINT ".,"", To'"",,", to ISO '76BmK US CEMENT LLC "O'9h C"tln,. to Isa aG62, Oro," UT OF AMBIENT TEMPERATURE: HOUSTON, GA Sort,,,,, ",;,h to ISD 13Q2 oaF MIN '""' ,eo, t, ","ey he;,", R, ",m) Th."""",tro"o,t",""h,,.','ooo,",""tlo'o,.th. W.ldod Co,ol",,,"o, '0 ISO ',.,20 110'F MAX propertyofTh,,,enKruppl,.,ot/ioISolllUon,(USA),I",,lt ",ol,,',"dod '"p,bI,,,tro,,Th. """""'0'",.. ,," g~t - i~~ ~;1:~' A wlth tho ,n'o"","'". thot '" port th."of 'h,II b. A comm"',,,,"d to ° thkd p,ely wrtho,t w,ltt.n "tho""tlo, Th,"'''''.'. () = BY OTHERS '"m Th"".,K""p 'ndy"'oo' So"tl,", (USA). 'no, p"J"""o' V % VOLATILE MATTER ~ Co,t",ot N,m. USC9512 ""t",ot"o *82200 9512 VB ACFM GAS FLOW Preliminary thyssenkrupp MECHANICAL PROCESS FLOW SHEET ~pl_SakJllDnl(USA),Inc. CLINKER AND ADDITIVE TRANSPORT SCFM GAS FLOW Date: 08/1412019 VN A_.~" 3000 STPD CLINKER 1101 JAA NER 6 JUN 2016 vs seF/LB GAS FLOW '"" Dr"' ., o. D.. ooptlo, 00" Dot. Chkd 00. ,"' 00. 00" 1134406 1- 3 VY FT /S GAS FLOW Revisions ,"' .. I"",· NONE ISh •• t 013,'022 8 T 7 I 6 I 5 I"- 4 T 3 2 I 1 8 7 6 5 4 3 2 I I I I I I M DESIGN - 7ST T - VB - ~----i 10 STC) Preliminary ~ 5Fl.PB02 o SF1. Te02 Date: 08/1412019 o 5Fl.GP05 =~~iiiiiiiiiiiiiif111f T 110/ JAA ~: 111111111111111111111)Hfillll IIIIIIII1111111 HH"f""""" ~:::Ol===::::;;-J g I rSF1.FN02 iii iii U~~t~ Iii iii iii iii iii" i I)J-r-lilllllllllllllllllllllill 4\ l¥' uuuuuuuuuuuuuu SEPOl SF1.DS01 NSV-290 I I I: ;;;;;;;;;;;;;;;;;;~~r;;;;~1-\/ ~<§JSF1.TC02.FNJOl M I I / 5Fl.GP04 , 5Fl.TC02.FNJ02@f---~ I SF1.BF01 SF1.BF01.FNJOl J 5Fl.TC02.RVJOl ~~ I 5F1.TC02.RVJ02~~ I - i -~_+_~S:F~1~P~B:0~2L- ~~ SF1.RF02 """" -a-~ DESIGN - r \" DESIGN I :::::::: ~- 0---: \..f I I 5Fl.PB02.RBOlt ____'~F, ----;;;;;oJ.~ I ~ I I ~5F1.BF01.FVJOl I SF1.RF03 ~~ I L __ FROM 5J1.SP01 I 1 I SHT-018 c ___ •• I c ~l.reO'FN~~,~~~----~S~J~l~J~e:O~l;;;;;;;;;;~~-- ~~;;;;;;;;;;Jr·······t··v·:·~5:U:;:M:E:R··W:'~:T:ER~····D·E·S·IG·N···5·Fl·=·SK,o,,1 ~. I VN P FROM T 5El.AYOl -" 1 SHT-013 1 VB - 'IMPACT If ~BOX ~;;;;;;;;;;;;;;;;~5~F~1.~Te~0~3;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;~~~~' ::S~F~1~.P~B:0:'::~~~S~F:2~.G~P~0:2==rt~:; - 5F1.TC03.FNJ01 I [~~~~AAAfifi~ ~ PLANT ELEVATION: 5F1.FW01~n 11111111111111111111 (0SF1.FN01 11111111111111111111 ----. IT ABOVE SEA LEVEL 11111111111111111111 WINTER SUMMER .Iii;; 11111111111111111111 11111111111111111111 I G I - ~r------UUUUUUUUUU I M I SJ1.05Dl I I LEGEND r I T I - I I 5F2.GP01 " B LBjH COMBUSTIBLE FLOW , SF1.DBDl ;7(~ o FT DIAMETER .@> ~t SF1.RF01 G MATERIAL FLOW , ST/H , , /i H % MATERIAL MOISTURE , I HU BTU/LB NET CALOR VALUE L{;;) I CEMENT B~~--~--~------~ 5Fl.PB01 I COOLER B K IN GRAIN SIZE 5Fl.TMOl .RBOl I r- KB BLAINE r-!"'" - r- I--rr------i.----r- ::. I .. '- I S.4m DIA X 14.Sm % RESIDUAL 200 MESH I KR SPRA1Y""1LA~N~e;!:E__ ~~'~~~~~ I 17.72' DIA X 47.57' ~ ~~ _____~ v I M HP MOTOR POWER /"------I ____ -.l N RPM SPEED ~ _ Ir-,-,---"c~,"",'"-___rr_--l,-- _ r- ~ SF 1. w1 .FN J02 SF1.WJ01.FNJOl L...... - - BLOWER / P INWG STAT PRESSURE o MBTU/H HEAT qUANTITY L- I / TO L - os BTUjLB HEAT QUANTITY 5J1.SPOl SF1.TM01.DRVDl ;':'0 1 SHT-018 1 S DUST CONTENT ~------,---j~M . :-r~*~u~SF1.TC01 I ~ I = I 5Fl.TC01.FNJOl SG LB/FT :3 BULK DENSITY f"'I .::: T OF TEMPERATURE . r-LIM"'..LI --=-_--"1 .9. .9. ~ Y TP 'F DEW POINT - US CEMENT LLC """Oh Coot'o" to ISO ""62. Om"p UT OF AMBIENT TEMPERATURE: HOUSTON, GA S,rio", fI",h to ISO ,'", O"F MIN ctL!J """ ""ok '0 ""II", he;,h' Ro ~m) 110"F MAX IWATER SPRAY TANKI BIN A _~~~~~ ~~~~:=r=~~::'-F-"'BUy~eO~N~T~R~A&e~TO~R A '- DESIGN __ SUMMER () = BY OTHERS v % VOLATILE MATTER G (H20) I L BY OWNER VB ACFM GAS FLOW thyssenkrupp MECHANICAL PROCESS FLOW SHEET ,",-,Krupp ndu_ Solutio .. (USA), Inc. CEMENT GRINDING SYSTEM SCFM GAS FLOW I VN A_.~" FIXED BEARING LUBE SYSTEM WATER FLOATING BEARING LUBE SYSTEM I 3000 STPD CLINKER SUPPLY 0., NER 6 JUN 2018 VS seF JLB GAS FLOW I SF2.TM01.FXBOl SF2.TM01.FTBOl I I D.. oel,tlo, 3 ct 1134406 FT /S GAS FLOW vv Revisions NONE I""'" 014 of 022 8 I 7 1 6 I 5 4 I 3 2 8 I 7 I 6 I 5 .. 4 I 3 I 2 I 1 1" GRINDING AID PIPING ~~ Ji TO PAN LNVEYOR l.()J 5El.AYOl SHT -014 I 0 ·SI 0 1" GRINDING AID PIPING VEil M~AY '/2" 2" OVER-FLOW n wj BIRD SCREEN ., . 1/2 HP , HP '/2" GRINDING AID TANK 7 ,000 GALLON ," ," RETURN STORAGE TANK WI .. .. LADDER, FRAME & TIE-DOWNS LOW POINT ~ ~ 2" TANK FILL VENT! 30 GALLON DRAIN - wi CHECK VALVE 1·r. PLANT WATER .. PLANT ~ DAY TANK - WATER - . r. SAMPLE .r. '/2" .r. 2" X 1" RED. GRINDING AID _UNION INSERTED ~ ../ ~r , '- , FROM METERING CHECK VALVE DRAIN ~ SKID 2" 1/2" , J.r. . (). ~ '/2" .(). ~ ~ DRAIN .~ DRAIN .~. CLEAN-OUT ·V ..L • V 2" GRINDING AID PIPING 1" DUPLEX METERING 1" DUPLEX METERING STRAINER PUMP STRAINER PUMP r- r- 5Fl.GB01.PMPOl 5Fl.GB01.PMP02 C C BALL MILL BALL MILL GRINDING AID METERING SKID GRINDING AID METERING SKID CLEAN-OUT CONTAINMENT DIKE GRINDING AID SYSTEM 5Fl.GB01 V03 TO PAN JONVEYOR ~ 5E1.AYOl P .... ISHT -014 I VENT i 30 GALLON '"' 1- «l'o MASONRY ADDITIVE 1" ADDITIVE PIPING ~~lm r DAY TANK I'" '/2" .r. SAMPLE 1/2 HP '/2" ," f. I Vi" M~AY 2" OVER-FLOW ~ W/ BIRD SCREEN .,. ~ B CLEAN-OUT f'I .~ B MASONRY ADDITIVE '/2"Y 1" ADDITIVE PIPING DRAIN 'U' TANK 7,000 GALLON STORAGE ," RETURN DUPLEX LOW POINT ~ TANK W/ LADDER, ," METERING DRAIN FRAME & TIE-DOWNS STRAINER PUMP .. 5Fl.GB02.PMP03 GRINDING AID METERING SKID 2" X 1" RED. ~ 2" TANK FILL - W/ CHECK VALVE ~ ~ Preliminary - "- - DRAIN .; Date: 08/1412019 2" 1101 JAA .r. ! ., () 2" ADDITIVE PIPING , U CENTRIF~ PUMP CLEAN-OUT~ NOTE; 2.5 GPM 2" DUPLEX AERATION ADDITIVES 5Fl.GB02.PMPOl STRAINER MAY SEPARATE AT ".,,,,,1 Tol"",,", to ISO '7SBmK US CEMENT LLC "o'Oh ""tin,. to Isa ""G2. G,",p_ (CONTINUOUS DUTY) TEMPERATURES LESS "rio", ",;,h to ISD 130' 2" 2" ADDITIVE PUMP SKID THAN 50"F AND MUST HOUSTON, GA -'" peok to ",11"'1 he;,h' Ro ~m) BE KEPT IN MOTION. Th.1,'o""otio,,o,t,',odh""""o'"'""tlolo,dtho W.ldod "",,,,,.. ,ijon to ISO '''20 propertyofTh,,,.nKruppl,dyotrioISol\l\;on,(USI\).lno.lt - - ",ot','.ndod,,,,,bI'ootro,.Th.','o,,"o',o,,,,,,,,,d g~~: - t~ ~;I:~' A .r. wlth tho ,n'o"","d"O tho' '" port th",of 'holl b. A comm,nl,otad to 0 thkd po"" with"" w,1tl.n "tho""tI", Th'" "",I. BY OTHERS P"J",,"on -...;;;T () = '"m Th,.., TO 5F1.BFOl I SHT -015 I ! 0 I 0 I 5Fl.DPOl I \ \ FROM \ 5J1.TCOl \ \ I SHT-016 I \ I - 5J 1 .P002 - 5J1.SP!-~ CJ CJ I " I I " i I N I- I I 5Jl.PD03 5Jl.PD04 I *I --"-+-GI __- ---jl TYP E I & " _~G1 __- ~I MASONRY C 0 CJ CJ CJ CJ CJ c I" I- I 5Jl.CPOl TO TO TO TO TO PLANT ELEVATION: 5Kl.SLOl SK1.SL02 5Kl.SL03 5Kl.SL04 5Kl.SLOS SHT-019 SHT-019 SHT-019 SHT 019 I SHT -019 I ---. EI AIlQllE SEA LEllEL I I I I I I I I +-- LEGEND a LajH COMBUSTIBLE FLOW D FT DIAMETER G ST/H MATERIAL FLOW H % MATERIAL MOISTURE HU BTU/LB NET CALOR VALUE B B K IN GRAIN SIZE 2 Ka CM !G BLAINE KR % RESIDUAL 200 MESH M HP MOTOR POWER N RPM SPEED P INWG STAT PRESSURE 0 MBTU/H HEAT qUANTITY - OS aTUjLa HEAT QUANTITY 3 S G!FT DUST CONTENT SG LB/FT :3 BULK DENSITY T of TEMPERATURE TP 'F DEW POINT US CEMENT LLC "0'0" Cootln,. to ISO ""62. Oro"P UT of AMBIENT TEMPERATURE: HOUSTON, GA S'rio", flo"h to ISO ,"", O"F MIN ""'" ",,'k to ",II.,. he;,h' R, ~m) 110"F MAX A CJ = BY OTHERS v % VOLATILE MATTER USC9512 2200 9512 va ACFM GAS FLOW Preliminary thyssenkrupp MECHANICAL PROCESS FLOW SHEET Date: 08/1412019 CEMENT TRANSPORT VN SCFM GAS FLOW 3000 STPD CLINKER VS seF jLa GAS FLOW 110/ JAA .. , NER 6 JUN 2018 1 eo D',",lptlo" ,", .~ 0," .~ ." .~ 3 ,," DI"" 1134406 vv FT /S GAS FLOW ~ - Revisions .. ' 1"001. NONE ISh •• t 0160'022 8 I 7 1 6 I 5 4 I 3 2 1 1 8 7 6 5 4 3 2 I I I I I I B- 5Kl.BF02 5K1.8FOl ~ -If- 5K1.BF02.FNJOl -Il-~5Kl.BF01.FNJOl IIIIIII1 ~ IIIIIII1 IIIIIII1 IIIIIII1 ~~~~ ~~~~ 1--- I FROM FROM ~ 5Kl.BF01.FVJOl FROM 5J~~g~03 ~5Kl.BF02.FVNOl I 0 o SJ1.CFOl SJ1.CF04 5J 1.CFOZ 'I C:SCCH';cT"'O"OC', ;C8 'I T I 1 SHT 0018 1 1 1 SHT-Q018 SHT 0018 FROM 1 1 5Jl.CF04 I I 1 SHT-OOIB 1 T I I ; [pi A HOIST BEAM 2 ST SK1.EVOl () - - QCapa,,'y, 900 Ib,. TYPE II TYPE I TYPE I TYPE I MASONRY CEMENT CEMENT CEMENT CEMENT CEMENT NW SW INTER SE NE SILO SILO STICE SILO SILO SILO #1 #2 #3 #4 #5 8,000 STONS 8,000 STONS 2,500 8,000 STONS 8,000 SIGNS STONS 5K1.SL02 5Kl.SL04 c 5Kl.SLOl 5Kl.SL03 5K1.SL05 c , \ I \ I \ , \ I \ I ,, 5Kl.RBOl \ I \ I " SK1.RB05 \ / 5K1.R804 \ / 5Kl.RB02 \ / ~\ L PLANT ELEVATION: C}-- C}-- 'Ii II --{;) , , --{;) EI AIlQllE SEA LEllEL ~/If i\/If ---. 602.D~ [ .tli~DDOl [ .tli~'.0D02 602.Te02 LEGEND n I 602.0002 I I B LBjH COMBUSTIBLE FLOW L______J ~ t J,L------J-J 6Dl.DD0!J 602.0001 D FT DIAMETER 6Dl.TC01.FJN01(g1 6~2.TC01.FNJ01 VB 1 1 ./': ~ VB 1- 1 G ST/H MATERIAL FLOW = /j6Dl.DPOl @ j\!P 602.0POI H % MATERIAL MOISTURE I~\~ 60l.BFOl ~ l..J I ~1'" 6.QL§£Ol 601.TC03 I, ~1a- ~ HU BTU/LB NET CALOR VALUE 601 BFO~ ~ II I Ifill .FNJOl 6D2.BF01.FNJOl I::::::: B ',' I::::::: IIIIIII1 B K IN GRAIN SIZE 'l' U U U l~uU j 2 j--, KB CM !G BLAINE '--l ~ 6D2.B7,·FYJOl KR % RESIDUAL 200 MESH 6°i·BF01.FVJ01~ ~ M HP MOTOR POWER b- :f I ~1 6D2.TCOI 601.TCO'- ""'601.TC03 N RPM SPEED I..., I 602.TCO'- P INWG STAT PRESSURE I -= -= I 601.Te02 0 MBTU/H HEAT QUANTITY 602.TC03 ) ) - OS BTUjLB HEAT QUANTITY t 602.0POl Preliminary 3 S G!FT DUST CONTENT --r Date: 08/1412019 6D1.LDOI 1 G 1 - 1 6D2.LDOl 'IGT=I SG LB!FT 3 BULK DENSITY 110/ JAA T OF TEMPERATURE TP 'F DEW POINT US CEMENT LLC """Oh Coot,",. to ISO ""62. Om"p UT OF AMBIENT TEMPERATURE: HOUSTON, GA S,rio", fI""h to ISO ,'", O"F MIN """ ""ok '0 ""II.". he;,h' Ro ~m) 110"F MAX 6Dl.WGOl 602.WGDl A () = BY OTHERS V % VOLATILE MATTER USC9512 leo"""" No 2200 9512 VB ACFM GAS FLOW thyssenkrupp MECHANICAL PROCESS FLOW SHEET CEMENT STORAGE AND TRUCK LOADING VN SCFM GAS FLOW r~==t======t==~=====t==t=====t==t====~~~--~~~~~~~"no~,~.~~.~~~~,~ '-._' 3000 STPD CLINKER VS SCF JLB GAS FLOW ", NER 6 JUN 2018 1eo D.. oel,tlo" Co" CO" 1'"" 1134406 3 .. "~ "~ .. "~ D vv FT !S GAS FLOW ~ Revisions ". 1",01. NONE I""'" 017"'022 8 I 7 I 6 I 5 4 I 3 2 I 1 8 7 6 5 4 3 2 I I I I I I ROTARY SCREW AIR COMPRESSOR UA1.CP02 TO ~ 1,060 GAL WATER SPRAY "-' RECEIVER ~ CLINKER _------+------l UALAV02 n--cf"~":~ - COOLER VENT ~ "" "" '"' "'-'-"c12lW-0 _ I S"T -all I g y V::::f~~ = I DESICCANT D I DRYER 890 I CFM@125 PSIG D : POST DRYER UA 1.ADO 1 J I : _ ~TER _ -==;-- COALESCING i------TO I oLo n..k ~r PREFILTER t.. I CLINKER ------t------,------j Q AUTOMATIC 1,060 GAL ~, I ROTARY SCREW _T_ T ~ _T_ ORAIN RECEIVER ! AIR COMPRESSOR COOLER EJ CP I S"T -011 I VENT TO DEW:OINT i V ~~ oX. ';J ..L UA~Ol 1~~_EX1~L~_TRJB"" : UA1. I.n _ ATMOSPHERE MONITOR : 1 900 I "" T ,., "" I ' n--cfB:e, AND/OR DRAIN ,: ,: CFM : IJ >.. I ~T~ U-r~-'------1L_ ~ OIL/WATER I I I 1 r Y AUXILIARY I Y-u-{::::E~~ -- - L__ SAR ______1______l__ ~ ______J_ i ______L ______'N~ET STU~ _____ 1 ___ 8~aJ CFM@l 2S PSIG UA1.WSOl COMPRESSOR ROOM #1 DESICCANT DRYER POST DRYER UA2.ADO 1 TO .:r:. FILTER COALESCING FINISH MILL _----oI KB CM 2/G BLAINE KR % RESIDUAL 200 MESH L:R:···T···"i~,,···JL .. I~ ... =~:\ ...... ""y,~:~; ,;., M HP MOTOR POWER UA4.WSOl : POST DRYER UA4.AD02 RPM SPEED N I FILTER COALESCING ROTARY SCREW TO ' _T. ~ _T. PREFILTER AIR COMPRESSOR P INWG STAT PRESSURE AUTOMATIC 1,060 GAL PREHEATER STANDBY _------+------,----'-1 U DRAIN RECEIVER Q MBTU/H HEAT QUANTITY AUXILIARY UA4.CP02 I S"T-009 I ~ I _T. T ~ _T. I~ ..T..,..., _T. UA~02 QS BTU/LB HEAT QUANTITY INLeE 1T STUB _T_ DEW POINT If ~E90Lo----ll-j",,>'<-fJ y----OlC,...,_T.~r 8;;[B1", - DUST CONTENT MONITOR : CFM .... _T_ ~-=-_~ - 3 , <;;;, SG LB/FT BULK DENSITY , l---(yJ----A-U~X-IL-,A-RY-lil V % VOLATILE MATTER Date: 08/1412019 ""ot""" Nom. No COAL MILL USC9512 "",In"" 2200 9512 V8 ACFM GAS FLOW MAINTENANCE 1101 JAA ~ thyssenkrupp MECHANICAL PROCESS FLOW SHEET HOIST PLANT COMPRESSED AIR SYSTEM VN SCFM GAS FLOW CR1.DMOl 3000 STPD CLINKER (95SCFM; 90 145PSI) MOBILE COMPRESSOR NER 6 JUN 2018 VS SCF /L8 GAS FLOW UA3.CPOl D"oo,tloo ,."d Dolo 3 1134406 VY FT /S GAS FLOW Revisions NONE ISh •• t 020 of 022 8 7 6 5 I'" 4 3 2 1 I I I 8 7 6 5 4 3 2 I I I I I I ... £2 VENT EMERGENY D SHOWER D RETURN TO ATMOSPHERE ./ - - 10,000 GAL TANK AQUA AMMONIA (19%) 1------. ------1 (SINGLE WALL) C C LT CONTROL , PLANT BASKET STRAINER \ I , _T. At , iLEX PLANT ELEVATION: FLEX I "\~ 4Gl.AJ01.PMPOl 1I HOSE TO PREHEATER HOSE I • T~ ~ T ~ ~ T. EI ABQ~E SEA LE~EL AND CALCINER --,-~~~~------~1 --. 1 1 SAFETY SAFETY SHT-009 PUMP ~FLANGE LEGEND SHUTOFF t SHUTOFF ~l '::::7 VALVE P VALVE B LB/H COMBUSTIBLE FLOW ft f< 0 FT DIAMETER PLANT AIR G ST/H MATERIAL FLOW WATER CLEANING INLET OUTLET CLEANING H % MATERIAL MOISTURE (CONNECTION) OUTLET HU STU/LB NET CALOR VALUE B B K IN GRAIN SIZE LEAK DETECTOR AIR 2 KB CM /G BLAINE e1 KR % RESIDUAL 200 MESH I 1 r I M HP MOTOR POWER I PUMP 1- ~ J SKID N RPM SPEED L ______ P INWG STAT PRESSURE Q MBTU!H HEAT qUANTITY - as BTU/LB HEAT QUANTITY 3 S G/FT DUST CONTENT [------[ 3 SG LB/FT BULK DENSITY CONTAINMENT DIKE (BY GC) T OF TEMPERATURE SNCR 4G 1 .AJO 1 TP OF DEW POINT US CEMENT LLC "o'Oh "ootlno, to ISO ""GO. Gro,p_ UT OF AMBIENT TEMPERATURE: HOUSTON, GA "rio", fI,;,h to ISO 130' oaF MIN -'" ,eok to "''''''I he;,h' Ro ~m) 110'F MAX A () = BY OTHERS v % VOLATILE MATTER USC9512 2200 9512 VB ACFM GAS FLOW Preliminary thyssenkrupp MECHANICAL PROCESS FLOW SHEET Date: 08/1412019 NOX REDUCTION SYSTEM SNCR VN SCFM GAS FLOW 3000 STPD CLINKER VS SCF /LB GAS FLOW 1101 JAA '"" NER 6 JUN 2018 I 0 •• O"ooptloo D1'0' '" o. 00. Chkd O~ ,"' O~ 1134406 3 VY FT /S GAS FLOW '"" '"" Revisions ,"' - 1",01, NONE ISh.,t 021 of 022 8 7 6 5 ~ 4 3 2 1 I I I I I 8 7 6 5 4 3 2 5 ST FROM 6e 1. TCOS ~------, I T 6Gl.BF01.EXJOl I 1------1 (LAT) I ,- I o 6Gl.BF01.FNJOl 6Gl.BFOl I I 6Gl.CH02 o 6G 1. OPO l'''':::~oIl1~;;;! I I I I I ,-, I I _jJ_,- Tr L -, I I I I I I FROM I I I 6el.TC05 \------j I I I 6Gl.CH03 I I I FROM 6Gl'CI H04 I 6el.TC05 \------J I ~ FB02.ATS01 PACKER I I I I I FEED / I I l!IN 1 802 / I ______DD02.ATSOl I I :6G1~' 6~ 6C1.8E01- /: 1 I I ______REJECT HOPPER -I ~II~ (s) ~-i FB01.ATS01- 1- L~ _~ I'~I 1 DD01.ATS01- - -I-I -- -: LJ I -RB01.JSTOl I ', 6Gl.DD02 I,'~ ~ I c I I c L ______L_' ______I ___ -{) 6G1.CH10 l.~======-- -, ,------j 6Gl.R801 I I '--I .c:=~A I I I ROTO-PACKER6-SPOUT i I I I I I I I I I I I RADIMAT • I I I o I 6Gl.LGOl PALLETIZER I 6G1.PLOl I I I B 6Gl.CH09 l 6Gl.FVJOl 6Cl.TC05.EXJ02 (FLS) FROM CEMENT STORAGE S'LOSL 6G1.CH11 BROKEN BAG CHUTE "";;;;;;;; 6Gl.SCOl 6el.TC05 6e 1. TC05.EXJ03 (FLS) US CEMENT LLC tr tr ~' ~~;:----:=--1 A () BY OTHERS 1 --~~!!~~."H1°iUS1TiOiN!,~G!A!i~j!!!!!!j~!!~;!~i"~~ 8 7 6 5 4 3 2 ATTACHMENT C FEDERAL RULE ANALYSIS TABLES 103 Emissions Unit K101: Raw Material K102: Raw Materials K104: Clinker and K106: Cement Handling, K108: Stationary Rules from 40 CFR 63 Subpart LLL K103: Pyroprocessing K105: Finish Mill K107: Coal and Petroleum Coke Quarrying, Crushing and Conveying, Storage and Additive Storage and Storage, Packing and Emergency Generators System (Cement Grinding) Grinding System Storage Processing Handling Loadout CI RICE §63.1340 What parts of my plant does this subpart cover? NO YES YES YES YES YES NO (but receives kiln gas) NO §63.1341 Definitions. §63.1342 Standards: General. What standards apply to my kilns, clinker coolers, raw material §63.1343 NO NO YES NO NO NO NO (but receives kiln gas) NO dryers, and open clinker storage piles? §63.1343 (a) General. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1343 (b) Kilns, clinker coolers, raw material dryers, raw mills, and finish mills. NO YES YES NO YES NO NO (but receives kiln gas) NO §63.1343 (c) Open clinker storage piles. NO NO NO YES NO NO NO (but receives kiln gas) NO §63.1344 [Reserved] Emissions limits for affected sources other than kilns; clinker coolers; §63.1345 NO YES NO YES YES YES NO (but receives kiln gas) NO new and reconstructed raw material dryers. §63.1346 Operating limits for kilns. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1347 Operation and maintenance plan requirements. NO YES YES YES YES YES NO (but receives kiln gas) NO §63.1348 Compliance requirements. NO YES YES YES YES YES NO (but receives kiln gas) NO §63.1348 (a) Initial performance test requirements. NO YES YES YES YES YES NO (but receives kiln gas) NO §63.1348 (a)(1) PM compliance. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1348 (a)(2) Opacity compliance. NO YES NO YES YES YES NO (but receives kiln gas) NO §63.1348 (a)(3), (4), (5), (6) D/F compliance, THC compliance, Mercury compliance, HCl compliance. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1348 (a)(7) Commingled exhaust requirements. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1348 (b) Continuous monitoring requirements. NO YES YES YES YES YES NO (but receives kiln gas) NO §63.1348 (b)(1) General requirements. NO YES YES YES YES YES NO (but receives kiln gas) NO §63.1348 (b)(1)(iv) Clinker Production. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1348 (b)(2) PM compliance. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1348 (b)(3) Opacity compliance. NO YES NO YES YES YES NO (but receives kiln gas) NO §63.1348 (b)(4), (6), (7), (8) D/F compliance, THC compliance, Mercury compliance, HCl compliance. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1348 (b)(5) Activated carbon injection compliance. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1348 (b)(9) Startup and Shutdown compliance. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1348 (c) Changes in operations. NO YES YES YES YES YES NO (but receives kiln gas) NO §63.1348 (d) General duty to minimize emissions. NO YES YES YES YES YES NO (but receives kiln gas) NO §63.1349 or §63.1349 (a) Performance testing requirements. NO YES YES YES YES YES NO (but receives kiln gas) NO §63.1349 (b)(1) PM emission tests. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1349 (b)(2) Opacity tests. NO YES NO YES YES YES NO (but receives kiln gas) NO D/F emission tests, THC emission tests, Mercury emission tests, HCl §63.1349 (b)(3), (4), (5), (6) NO NO YES NO NO NO NO (but receives kiln gas) NO emission tests. §63.1349 (b)(7) Total o‐HAP emission tests. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1349 (b)(8) HCl emission tests with SO 2 monitoring. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1349 (c) Performance test frequency. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1349 (d) Performance test reporting requirements. NO initial VE only YES initial VE only initial VE only initial VE only NO (but receives kiln gas) NO §63.1349 (e) Conditions of performance tests. NO YES YES YES YES YES NO (but receives kiln gas) NO Emissions Unit K101: Raw Material K102: Raw Materials K104: Clinker and K106: Cement Handling, K108: Stationary Rules from 40 CFR 63 Subpart LLL K103: Pyroprocessing K105: Finish Mill K107: Coal and Petroleum Coke Quarrying, Crushing and Conveying, Storage and Additive Storage and Storage, Packing and Emergency Generators System (Cement Grinding) Grinding System Storage Processing Handling Loadout CI RICE §63.1350 or §63.1350 (a) Monitoring requirements. NO YES YES YES YES YES NO (but receives kiln gas) NO §63.1350 (b) PM monitoring requirements. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1350 (c) [Reserved] §63.1350 (d) Clinker production monitoring requirements. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1350 (e) [Reserved] §63.1350 (f)(1) Opacity monitoring requirements. NO YES NO YES YES YES NO (but receives kiln gas) NO §63.1350 (f)(2) Opacity monitoring requirements. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1350 (f)(3) Opacity monitoring requirements. NO NO NO NO YES NO NO (but receives kiln gas) NO §63.1350 (f)(4) Opacity monitoring requirements. NO NO NO NO NO NO NO (but receives kiln gas) NO D/F monitoring requirements, THC monitoring requirements, Mercury §63.1350 (g), (i), (k), (l) NO NO YES NO NO NO NO (but receives kiln gas) NO monitoring requirements, HCl monitoring requirements. §63.1350 (h) Monitoring requirements for sources using sorbent injection. NO NO NO NO NO NO NO (but receives kiln gas) NO §63.1350 (j) Total o‐HAP monitoring requirements. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1350 (m) Parameter monitoring requirements. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1350 (n) Continuous flow rate monitoring system. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1350 (o) Alternate monitoring requirements approval. NO YES YES YES YES YES NO (but receives kiln gas) NO §63.1350 (p) Development and submittal (upon request) of monitoring plans. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1351 Compliance dates. NO YES YES YES YES YES NO (but receives kiln gas) NO §63.1352 Additional test methods. NO NO YES NO NO NO NO (but receives kiln gas) NO §63.1353 Notification requirements. NO YES YES YES YES YES NO (but receives kiln gas) NO §63.1354 Reporting requirements. NO YES YES YES YES YES NO (but receives kiln gas) NO §63.1355 Recordkeeping requirements. NO YES YES YES YES YES NO (but receives kiln gas) NO §63.1356 Sources with multiple emissions limit or monitoring requirements. NO YES YES YES YES YES NO (but receives kiln gas) NO §63.1357 [Reserved] §63.1358 Implementation and enforcement. NO YES YES YES YES YES NO (but receives kiln gas) NO §63.1359 [Reserved] Table 1 to Subpart LLL of Part 63 ‐ Applicability of General Provisions NO YES YES YES YES YES NO (but receives kiln gas) NO Emissions Unit K101: Raw Material K102: Raw Materials K104: Clinker and K106: Cement Handling, K108: Stationary Rules from 40 CFR 63 Subpart A K103: Pyroprocessing K105: Finish Mill K107: Coal and Petroleum Coke Quarrying, Crushing and Conveying, Storage and Additive Storage and Storage, Packing and Emergency Generators System (Cement Grinding) Grinding System Storage Processing Handling Loadout CI RICE §63.1 Applicability. NO YES YES YES YES YES NO (but receives kiln gas) YES §63.2 Definitions. §63.3 Units and abbreviations. §63.4 Prohibited activities and circumvention. NO YES YES YES YES YES NO (but receives kiln gas) YES §63.5 Preconstruction review and notification requirements. NO YES YES YES YES YES NO (but receives kiln gas) YES §63.6 Compliance with standards and maintenance requirements. NO YES YES YES YES YES NO (but receives kiln gas) YES §63.7 Performance testing requirements. NO YES YES YES YES YES NO (but receives kiln gas) YES §63.8 Monitoring requirements. NO YES YES YES YES YES NO (but receives kiln gas) YES §63.9 Notification requirements. NO YES YES YES YES YES NO (but receives kiln gas) YES §63.10 Recordkeeping and reporting requirements. NO YES YES YES YES YES NO (but receives kiln gas) YES §63.11 Control device and work practice requirements. NO YES YES YES YES YES NO (but receives kiln gas) YES §63.12 State authority and delegations. NO YES YES YES YES YES NO (but receives kiln gas) YES §63.13 Addresses of State air pollution control agencies and EPA Regional Offices. NO YES YES YES YES YES NO (but receives kiln gas) YES §63.14 Incorporations by reference. NO YES YES YES YES YES NO (but receives kiln gas) YES §63.15 Availability of information and confidentiality. NO YES YES YES YES YES NO (but receives kiln gas) YES §63.16 Performance Track Provisions. NO YES YES YES YES YES NO (but receives kiln gas) YES Appendix Table 1 to Subpart A of Part 63 ‐ Detection Sensitivity Levels (grams per hour) NO YES YES YES YES YES NO (but receives kiln gas) YES Emissions Unit K101: Raw Material K102: Raw Materials K104: Clinker and K106: Cement Handling, K107: Coal and K108: Stationary Rules from 40 CFR 60 Subpart F K103: Pyroprocessing K105: Finish Mill Quarrying, Crushing and Conveying, Storage and Additive Storage and Storage, Packing and Petroleum Coke Emergency Generators System (Cement Grinding) Storage Processing Handling Loadout Grinding System CI RICE NO (but receives kiln §60.60 Applicability and designation of affected facility. NO YES YES YES YES YES NO gas) §60.61 Definitions. NO (but receives kiln §60.62 Standards. NO YES YES YES YES YES NO gas) NO (but receives kiln §60.62 (a) kiln NO NO YES NO NO NO NO gas) NO (but receives kiln §60.62 (b) clinker cooler NO NO NO YES NO NO NO gas) NO (but receives kiln §60.62 (c) other than kiln and clinker cooler NO YES NO NO YES YES NO gas) affected source subject to this subpart with a different emissions limit or NO (but receives kiln §60.62 (d) requirement for the same pollutant under another regulation in title 40 of this NO YES YES YES YES YES NO gas) chapter. NO (but receives kiln §60.62 (e) compliance date NO YES YES YES YES YES NO gas) NO (but receives kiln §60.63 Monitoring of operations. NO YES YES YES YES YES NO gas) §60.63 (a) [Reserved] NO (but receives kiln §60.63 (b) Clinker production monitoring requirements. NO NO YES NO NO NO NO gas) NO (but receives kiln §60.63 (c) PM Emissions Monitoring Requirements. NO NO YES NO NO NO NO gas) NO (but receives kiln §60.63 (d) CEMS monitoring and recording the concentration by volume of NOX emissions NO NO YES NO NO NO NO gas) NO (but receives kiln §60.63 (e) CEMS monitoring and recording the concentration by volume of SO2 emissions NO NO YES NO NO NO NO gas) NO (but receives kiln §60.63 (f) NOX and SO2 CEMS NO NO YES NO NO NO NO gas) NO (but receives kiln §60.63 (g) For each CPMS or CEMS NO NO YES NO NO NO NO gas) NO (but receives kiln §60.63 (h) stack gas flow rate NO NO YES NO NO NO NO gas) NO (but receives kiln §60.63 (i) Development and Submittal (Upon Request) of Monitoring Plans. NO YES YES YES YES YES NO gas) NO (but receives kiln §60.64 Test methods and procedures. NO YES YES YES YES YES NO gas) NO (but receives kiln §60.64 (a) performance tests and relative accuracy tests NO YES YES YES YES YES NO gas) demonstrate compliance with the PM standards in §60.62 using EPA method 5 or NO (but receives kiln §60.64 (b) NO YES YES YES YES YES NO method 5I gas) Calculate and record the rolling 30 kiln operating day average emission rate daily NO (but receives kiln §60.64 (c) NO NO YES NO NO NO NO of NOX and SO2 gas) NO (but receives kiln §60.64 (d) submit the results of the performance tests conducted NO YES YES YES YES YES NO gas) NO (but receives kiln §60.65 Recordkeeping and reporting requirements. NO YES YES YES YES YES NO gas) NO (but receives kiln §60.65 (a) submit reports of excess emissions NO NO YES NO NO NO NO gas) NO (but receives kiln §60.65 (b) submit semiannual reports of the malfunction information NO NO YES NO NO NO NO gas) NO (but receives kiln §60.65 (c) requirements of this section NO YES YES YES YES YES NO gas) NO (but receives kiln §60.66 Delegation of authority. NO YES YES YES YES YES NO gas) Emission Unit K107: Coal and Rules from 40 CFR 60 Subpart Y Petroleum Coke Grinding System §60.250 Applicability and designation of affected facility. YES commenced construction, reconstruction or modification after October 27, 1974, and on or §60.250 (b) NO before April 28, 2008 commenced construction, reconstruction or modification after April 28, 2008, and on or §60.250 (c) NO before May 27, 2009 §60.250 (d) commenced construction, reconstruction or modification after May 27, 2009 YES §60.251 Definitions. §60.252 Standards for thermal dryers. YES §60.252 (a) constructed, reconstructed, or modified on or before April 28, 2008 NO §60.252 (b) constructed, reconstructed, or modified after April 28, 2008 YES §60.252 (c) thermal input from an affected facility covered under another 40 CFR Part 60 subpart YES §60.253 Standards for pneumatic coal‐cleaning equipment. YES §60.253 (a) constructed, reconstructed, or modified on or before April 28, 2008 NO §60.253 (b) constructed, reconstructed, or modified after April 28, 2008 YES Standards for coal processing and conveying equipment, coal storage systems, transfer and §60.254 NO loading systems, and open storage piles. §60.254 (a) constructed, reconstructed, or modified on or before April 28, 2008 NO §60.254 (b) constructed, reconstructed, or modified after April 28, 2008 YES §60.254 (c) constructed, reconstructed, or modified after May 27, 2009 YES §60.255 Performance tests and other compliance requirements. YES §60.255 (a) commenced construction, reconstruction, or modification on or before April 28, 2008 NO §60.255 (b) commenced construction, reconstruction, or modification after April 28, 2008 YES If any affected coal processing and conveying equipment (e.g., breakers, crushers, screens, conveying systems), coal storage systems, or coal transfer and loading systems that §60.255 (c) YES commenced construction, reconstruction, or modification after April 28, 2008, are enclosed in a building An owner or operator of an affected facility (other than a thermal dryer) that commenced §60.255 (d) YES construction, reconstruction, or modification after April 28, 2008 For an owner or operator of a group of up to five of the same type of affected facilities that §60.255 (e) YES commenced construction, reconstruction, or modification after April 28, 2008 As an alternative to meeting the requirements in paragraph (b)(2) of this section, an owner §60.255 (f) or operator of an affected facility that commenced construction, reconstruction, or YES modification after April 28, 2008 As an alternative to meeting the requirements in paragraph (b)(2) of this section, an owner §60.255 (g) or operator of an affected facility that commenced construction, reconstruction, or YES modification after April 28, 2008 The owner or operator of each affected coal truck dump operation that commenced §60.255 (h) YES construction, reconstruction, or modification after April 28, 2008 §60.256 Continuous monitoring requirements. YES §60.256 (a) constructed, reconstructed, or modified on or before April 28, 2008 NO §60.256 (b) constructed, reconstructed, or modified after April 28, 2008 YES §60.256 (c) Each bag leak detection system YES §60.257 Test methods and procedures. YES §60.258 Reporting and recordkeeping. YES Emissions Unit K101: Raw Material Rules from 40 CFR 60 Subpart OOO Quarrying, Crushing and Storage §60.670 Applicability and designation of affected facility. YES §60.671 Definitions. §60.672 Standard for particulate matter (PM). YES §60.673 Reconstruction. YES §60.674 Monitoring of operations. YES §60.674 (a) uses a wet scrubber to control emissions NO The owner or operator of any affected facility for which construction, modification, or §60.674 (b) reconstruction commenced on or after April 22, 2008, that uses wet suppression to control YES emissions the owner or operator of any affected facility for which construction, modification, or §60.674 (c) reconstruction commenced on or after April 22, 2008, that uses a baghouse to control NO emissions the owner or operator of any affected facility for which construction, modification, or §60.674 (d) reconstruction commenced on or after April 22, 2008, that uses a baghouse to control NO emissions may use a bag leak detection system the owner or operator of any affected facility that is subject to the requirements for §60.674 (e) processed stone handling operations in the Lime Manufacturing NESHAP (40 CFR part 63, NO subpart AAAAA) §60.675 Test methods and procedures. YES §60.676 Reporting and recordkeeping. YES §60.676 (a) existing facility being replaced and the replacement piece of equipment NO §60.676 (b) construction, modification, or reconstruction commenced on or after April 22, 2008 YES §60.676 (c) During the initial performance test of a wet scrubber, and daily thereafter NO §60.676 (d) After the initial performance test of a wet scrubber NO §60.676 (e) The reports required under paragraph (d) of this section NO §60.676 (f) The owner or operator of any affected facility shall submit written reports of the results YES The owner or operator of any wet material processing operation that processes saturated §60.676 (g) NO and subsequently processes unsaturated materials The subpart A requirement under §60.7(a)(1) for notification of the date construction or §60.676 (h) NO reconstruction commenced is waived for affected facilities under this subpart. A notification of the actual date of initial startup of each affected facility shall be submitted §60.676 (i) YES to the Administrator. §60.676 (j) The requirements of this section remain in force YES §60.676 (k) Notifications and reports required under this subpart and under subpart A of this part YES Table 1 to Subpart OOO of Part 60—Exceptions to Applicability of Subpart A to Subpart OOO NO Table 2 to Subpart OOO of Part 60—Stack Emission Limits for Affected Facilities With Capture Systems NO Table 3 to Subpart OOO of Part 60—Fugitive Emission Limits YES ATTACHMENT D LIST OF PERMITS 104 PERMITTING SCHEDULE/US CEMENT, LLC Haynesville, Georgia Prior/During Anticipated Date of Permit Governing Body Construction Issue Notes Georgia Environmental Protection Department (Review by Federal Stationary Source, Title V, Air Quality Environmental Protection Agency) Prior February 1, 2020 Koogler & Associates in Process Permit has been issued and is Georgia Environmental Protection valid. Underwater mining is being Surface Mining Department Completed explored National Pollution Discharge Elimination System Houston County, Georgia Prior November 1, 2019 Bryant Engineering in Process (Stormwater, Erosion Control, Spill Containment) Georgia Environmental Protection Solid Waste and Recovered Materials Department Prior February 1, 2020 Wetlands Army Corp of Engineers Modify November 1, 2019 Site Plan Houston County, Georgia Prior December 1, 2019 Bryant Engineering in Process Georgia Environmental Protection Water Consumption/Withdrawl Department During October 1, 2020 Deep well permits Georgia Environmental Protection Sanitary, Leach Field Department During January 1, 2021 Georgia Environmental Protection Radiation Department During January 1, 2021 ATTACHMENT E TITLE V PERMIT EXAMPLE 105 American Cement Company, LLC Sumterville Cement Plant Facility ID No. 1190042 Sumter County Title V Air Operation Permit Revision Permit No. 1190042-016-AV (Revision to Title V Air Operation Permit No. 1190042-013-AV) Permitting Authority: State of Florida Department of Environmental Protection Division of Air Resource Management Office of Permitting and Compliance 2600 Blair Stone Road Mail Station #5505 Tallahassee, Florida 32399-2400 Telephone: (850) 717-9000 Email: [email protected] Compliance Authority: State of Florida Department of Environmental Protection Compliance Assurance Program, Central District 3319 Maguire Boulevard, Suite 232 Orlando, Florida 32803-3767 Telephone: (407) 897-4100 E-mail: [email protected] American Cement Company, LLC Sumterville Cement Plant Title V Air Operation Permit Revision Permit No. 1190042-016-AV Table of Contents Section Page Number Placard Page ...... 1 I. Facility Information. A. Facility Description...... 2 B. Summary of Emissions Units...... 3 C. Applicable Regulations...... 3 II. Facility-wide Conditions...... 5 III. Emissions Units and Conditions. A. EU001 Raw Material Quarrying, Crushing, and Storage...... 9 B. EU002 Raw Materials Conveying, Storage, and Processing ...... 12 C. EU003 Pyroprocessing System...... 15 D. EU004 Clinker and Additive Storage and Handling...... 42 E. EU005 Finish Mill (Cement Grinding)...... 45 F. EU006 Cement Handling, Storage, Packing, and Loadout...... 48 G. EU007 Coal and Petroleum Coke Grinding System...... 51 H. EU010 Alternative Fuels Processing System...... 56 I. EU009 Stationary Emergency Generator CI RICE...... 62 IV. Appendices...... Separate Document Appendix A, Glossary. Appendix I, List of Insignificant Emissions Units and/or Activities. Appendix RR, Facility-wide Reporting Requirements. Appendix TR, Facility-wide Testing Requirements. Appendix TV, Title V General Conditions. Appendix BD, Final BACT Determination and Emission Standards, 1190042-001-AC (PSD-361) February 13, 2006 Appendix U, List of Unregulated Emissions Units and/or Activities. Appendix NESHAP 40 CFR 63 Subpart A – General Provisions Appendix NESHAP 40 CFR 63 Subpart LLL - National Emissions Standards for Hazardous Air Pollutants for the Portland Cement Manufacturing Industry Appendix NSPS 40 CFR 60 Subpart A – General Provisions. NSPS 40 CFR 60 Subpart OOO Standards of Performance for Non-Metallic Mineral Processing Plants Appendix NSPS 40 CFR 60 Subpart F Standards of Performance for Portland Cement Plants Appendix NSPS 40 CFR 60 Subpart Y Standards of Performance for Coal Preparation Plants Appendix NSPS, Subpart DDDD – Emissions Guidelines and Compliance Times for Commercial and Industrial Solid Waste Incineration Units, referenced in Rule 62-204.800(9)(f), F.A.C. Rule 62-204.800(9)(f), F.A.C. Appendix NSPS 40 CFR 60 Subpart IIII, Stationary Combustion Ignition (CI) Internal Combustion Engines Appendix OM – Operation and Maintenance Plan Appendix CEMS – CEMS Contingency Plan Appendix MM - Material Management Plan Referenced Attachments...... At End Table H, Permit History. www.dep.state.fl.us Rick Scott Florida Department of Governor Environmental Protection Carlos Lopez-Cantera Bob Martinez Center Lt. Governor 2600 Blair Stone Road Tallahassee, Florida 32399-2400 Noah Valenstein Secretary PERMITTEE: Permit No. 1190042-016-AV American Cement Company, LLC Sumterville Cement Plant 4750 E. C. R. 470, Post Office Box 445 Facility ID No. 1190042 Sumterville, Florida 33585 Title V Air Operation Permit Revision The purpose of this permit is to revise the Title V air operation permit for the above referenced facility to incorporate the applicable provisions of Rule 62-204.800(9)(f), F.A.C.; 40 CFR 60, Subpart DDDD; and Permit No. 1190042-017-AC into the kiln and coal mill sections of the permit. The existing Sumterville Cement Plant is located in Sumter County at 4750 E County Road 470, Post Office Box 445, Florida. UTM coordinates are: Zone 17, 399.8 km East, and 3181.9 km North. Latitude 28° 45’ 38” North and Longitude is 82° 01’ 35” West. The Title V air operation permit is issued under the provisions of Chapter 403, Florida Statutes (F.S.), and Florida Administrative Code (F.A.C.) Chapters 62-4, 62-210, and 62-213. The above named permittee is hereby authorized to operate the facility in accordance with the terms and conditions of this permit. Executed in Tallahassee, Florida. 1190042-013-AV Effective Date: December 23, 2016 1190042-016-AV Effective Date: November 29,2017 Renewal Application Due Date: March 26, 2021 Expiration Date: November 8, 2021 For: Syed Arif, P.E., Program Administrator Office of Permitting and Compliance Division of Air Resource Management SA/dlr/pks www.dep.state.fl.us SECTION I. FACILITY INFORMATION. Subsection A. Facility Description. The American Cement, LLC Sumterville cement plant is a Portland cement manufacturing plant. The facility is a nominal 1,186,250 tons per year (TPY) clinker dry process Portland cement plant incorporating a dry process kiln with a preheater and calciner (PH/C). The facility includes a surface limestone mine. The manufacture of Portland cement primarily involves the crushing, grinding, and blending of limestone, clays, and other raw materials into a chemically proportioned mixture which is heated in a rotary kiln to extremely high temperature to produce clinker nodules. The clinkers are cooled and ground with a small quantity of additives to produce finished cement. Major equipment associated with the main components of the plant includes the following: • A raw materials storage building (RMS); • A primary crusher at the quarry and belt conveyors to RMS; • Raw material piles stored inside of the RMS. The piles include but are not limited to limestone, alumina sources (e.g., bauxite, clay, and coal ash), iron sources (e.g., mill scale, coal ash and iron ore), silica sources (e.g., sand), and additives (e.g., feldspar); • Materials handling equipment associated with the RMS which includes: harrow and portal reclaimers, stackers, belt conveyors, conveyor from the RMS to the raw mill, and control system/analyzer; • An in-line raw mill that simultaneously dries and grinds raw materials using the exhaust gas from the kiln, preheater/calciner (PH/C), and clinker cooler; • Mechanical and pneumatic handling and feed systems designed to handle alternative fuels at a nominal rate of 32 tons of alternative fuel per hour; • Kiln and calciner burners alternative fuel handling and firing systems; • Fuel preparation equipment for grinding, shredding, screening, and sizing equipment to prepare alternative fuels; • A preheater/calciner capable of burning coal, petroleum coke, new No. 2 oil, on-specification used oil, certain categories of alternative fuels, and natural gas; it has staged combustion and selective non-catalytic reduction (SNCR) system; • An air heater, capable of firing No. 2 or No. 4 fuel oil, on-specification used fuel oil, and natural gas, for use when additional drying capacity is required; • A nominal 10,000 ton homogenizing (blending) silo; • A nominal 18 TPH coal and petroleum coke grinding system with associated mill, storage facility, conveyors, including a fabric filter baghouse; • A dry process preheater/calciner kiln capable of producing 3,250 short tons per day of clinker; • An indirect-firing system with a low-NOX main kiln burner capable of burning coal, petroleum coke, new No. 2 fuel oil, on-specification used oil, certain categories of alternative fuels, and natural gas; • A whole tire kiln feeder system; • A clinker cooler with reciprocating grates, cooling air fans, and hot air ducting to the kiln and PH/C; • Clinker storage and grinding including a finish mill with air separator, clinker silos with metering device, additive storage (including but not limited to limestone and gypsum), and associated conveyors; and • A cement transfer and storage facility including truck loadout and packhouse. Nitrogen oxides (NOx) emissions are minimized by indirect firing in a low-NOx main kiln burner, and staged combustion with a selective non-catalytic reduction (SNCR) ammonia injection system in the preheater/calciner. Sulfur dioxide (SO2) emissions are controlled by the use of inherently low sulfur raw materials and scrubbing by finely divided lime in the calciner. Carbon monoxide (CO) and volatile organic compound (VOC) emissions are controlled by promoting complete combustion in the kiln and calciner, and minimizing carbon and oily content of raw materials. Particulate matter (PM/PM10) from the PH/C, kiln, in-line raw mill, and clinker cooler are American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 2 of 64 SECTION I. FACILITY INFORMATION. controlled by a single large fabric filter main baghouse. Numerous other baghouses control PM/PM10 emissions from materials conveyance, transfer, grinding, and handling. Fugitive PM/PM10 emissions from raw material piles, loading operations, transportation, etc. are controlled by reasonable precautions including paving, road sweeping, watering, planting grass, etc. Subsection B. Summary of Emissions Units. EU No. Brief Description Regulated Emissions Units 001 Raw Material Quarrying, Crushing, and Storage (includes raw material processing from quarry up to raw material storage, and additives handling from delivery to storage) 002 Raw Materials Conveying, Storage, and Processing (from raw material and additive storage to preheater - includes conveyance of raw materials and raw meal to and from raw mill, and homogenizing (blending) silo) 003 Pyroprocessing System (includes kiln, preheater/calciner, raw mill, air heater, and clinker cooler) 004 Clinker and Additives Storage and Handling (includes clinker handling from clinker cooler to clinker silo discharge, and clinker and additive handling from storage to the finish mill) 005 Finish Mill (Clinker Grinding) 006 Cement Handling, Storage, Packing, and Loadout (includes cement conveyance to silos, cement silos, loadout to trucks from silos, and cement bagging operations) 007 Coal and Petroleum Coke Grinding System (includes coal/petroleum coke handling from truck and railcar unloading to the pulverized fuel bin) 009 Stationary Emergency Generator Compression Ignition (CI) Reciprocating Internal Combustion Engine (RICE) 010 Alternative Fuels Processing System Unregulated Emissions Units and Activities 008 Fugitive Dust From Storage Piles, Paved Roads, and Unpaved Roads Also included in this permit are miscellaneous insignificant emissions units and/or activities (see Appendix I, List of Insignificant Emissions Units and/or Activities). Subsection C. Applicable Regulations. Based on the Title V air operation permit renewal application received on March 28, 2016, this facility is a major source of hazardous air pollutants (HAP). The existing facility is a PSD major source of air pollutants in accordance with Rule 62-212.400, F.A.C. The cement plant portion of the facility is subject to the maximum achievable control technology (MACT) requirements in 40 CFR 63 Subpart LLL – National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Portland Cement Manufacturing Industry. The plant is also subject to 40 CFR 60, Subpart F – Standards of Performance for Portland Cement Plants, although many sections of this rule have been superseded by 40 CFR 63, Subpart LLL. In addition, the plant is subject to various state Rules and the Department’s determination of best available control technology (BACT) for NOx, CO, SO2, VOC, and PM/PM10 and the associated BACT emission limitations for each of these air pollutants. (See Appendix BD - Final BACT Determination and Emission Standards.) The limestone mine quarry is subject to 40 CFR 60, Subpart OOO - Standards of Performance for Non-metallic Mineral Processing Plants; the coal mill is subject to both 40 CFR 60, Subpart Y - Standards of Performance for Coal Preparation Plants and either Rule 62-204.800(9)(f) which incorporates the requirements of 40 CFR 60, American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 3 of 64 SECTION I. FACILITY INFORMATION. Subpart DDDD – Emissions Guidelines and Compliance Times for Commercial and Industrial Solid Waste Incineration Units (DDDD) when the kiln is subject to DDDD or 40 CFR 63 Subpart LLL (LLL) (because the coal mill receives exhaust gas from the kiln which is subject to either of the two regulations), and the emergency engine is subject to 40 CFR 60 Subpart IIII - Standards of Performance for Stationary Compression Ignition Internal Combustion Engines. The kiln (EU 003) can be subject to either DDDD or LLL standards. This permit is written to allow the kiln to switch between the two regulations. This facility includes continuous emissions monitoring systems (CEMS) for NOx, CO, total hydrocarbons (THC, both as a monitor for THC emissions (as regulated under LLL) and as a surrogate monitor for VOC emissions), mercury (Hg) and hydrogen chloride (HCl) on the common PH/C kiln, in- line raw mill, and clinker cooler fabric filter baghouse exhaust stack. A PM continuous parameter monitoring system (CPMS) was installed on this stack prior to February 25, 2015 to meet the requirements of Consent Order 13-1128 and the compliance requirements 40 CFR 63, NESHAP Subpart LLL. Since the coal mill (EU 007) stack (S-22) emits exhaust gas vented from the kiln into the coal mill, this coal mill stack (S-22) is required to meet the more stringent emission limits of DDDD or LLL as applicable to the kiln, rather than NSPS, Subpart Y A summary of applicable regulations is shown in the following table. Regulation EU No(s). 40 CFR 60, NSPS Subpart A - General Provisions for 40 CFR 60 001 through 007, 009 40 CFR 60, NSPS Subpart F - Standards of Performance for Portland 002 through 006 Cement Plants 40 CFR 60, NSPS Subpart Y - Standards of Performance for Coal 007 Preparation Plants 40 CFR 60, NSPS Subpart OOO - Standards of Performance for Non- 001 Metallic Mineral Processing Plants 40 CFR 60, NSPS Subpart IIII - Standards of Performance for Stationary 009 Compression Ignition Internal Combustion Engines 40 CFR 63, NESHAP Subpart A - General Provisions for 40 CFR 63 002 through 007 40 CFR 63, NESHAP Subpart LLL - National Emissions Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing Industry 002 through 007 - Major Sources State Regulations EU Nos. Chapters 62-4, 62-204, 62-210, 62-212, 62-213, 62-296, and 62-297, F.A.C. All Rule 62-204.800(9)(f), F.A.C.* 003, 007 * At the time of issuance of this permit, the kiln (EU 003) and coal mill (EU 007) are subject to Rule 62- 204.800(9)(f), F.A.C., which incorporates the requirements of DDDD, and not subject to LLL. If the permittee certifies that the kiln has not used any waste material for a period of six months and provides the appropriate advance notice to the Department, the permittee may revert back to compliance with LLL rather than DDDD, including performing all required initial compliance testing. If any material constituting waste were to be used, however, the kiln and coal mill would immediately be subject to the DDDD requirements. {Permitting Note (for informational purposes only): The facility is subject to the federal requirements of the Greenhouse Gas Reporting Program codified at 40 CFR 98. This reporting rule is not a requirement of the State of Florida. American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 4 of 64 SECTION II. FACILITY-WIDE CONDITIONS. The following conditions apply facility-wide to all emission units and activities: FW1. Appendices. The permittee shall comply with all documents identified in Section IV, Appendices, listed in the Table of Contents. Each document is an enforceable part of this permit unless otherwise indicated. [Rule 62-213.440, F.A.C.] Emissions and Controls FW2. Not Federally Enforceable. Objectionable Odor Prohibited. No person shall cause, suffer, allow or permit the discharge of air pollutants, which cause or contribute to an objectionable odor. An “objectionable odor” means any odor present in the outdoor atmosphere which by itself or in combination with other odors, is or may be harmful or injurious to human health or welfare, which unreasonably interferes with the comfortable use and enjoyment of life or property, or which creates a nuisance. [Rule 62-296.320(2) and 62- 210.200(Definitions), F.A.C.] FW3. General Volatile Organic Compounds (VOC) Emissions or Organic Solvents (OS) Emissions. The permittee shall allow no person to store, pump, handle, process, load, unload or use in any process or installation, volatile organic compounds or organic solvents without applying known and existing vapor emission control devices or systems deemed necessary and ordered by the Department. [Rule 62-296.320(1), F.A.C.] {Permitting Note: Nothing is deemed necessary and ordered at this time.} FW4. General Visible Emissions. No person shall cause, let, permit, suffer or allow to be discharged into the atmosphere the emissions of air pollutants from any activity equal to or greater than 20% opacity. EPA Method 9 is the method of compliance pursuant to Chapter 62-297, F.A.C. This regulation does not impose a specific testing requirement for general visible emissions. [Rule 62-296.320(4)(b)1. and 4., F.A.C.] FW5. Unconfined Particulate Matter. No person shall cause, let, permit, suffer or allow the emissions of unconfined particulate matter from any activity, including vehicular movement; transportation of materials; construction; alteration; demolition or wrecking; or industrially related activities such as loading, unloading, storing or handling; without taking reasonable precautions to prevent such emissions. Reasonable precautions shall include the following: a. Landscaping and planting of vegetation; b. Application of water to control fugitive dust from activities such as demolition of buildings, grading roads, construction, and land clearing; c. Water supply lines, hoses and sprinklers, or other sources of water shall be located near all stockpiles of raw materials, coal, and petroleum coke; d. All plant operators shall be trained in basic environmental compliance and shall perform visual inspections of raw materials, coal and petroleum coke periodically and before handling. If the visual inspections indicate a lack of surface moisture, such materials shall be wetted with sprinklers. Wetting shall continue until the potential for unconfined particulate matter emissions are minimized; e. Water spray shall be used to wet the materials and fuel if inherent moisture and moisture from wetting the storage piles are not sufficient to prevent unconfined particulate matter emissions; f. As necessary, applications of asphalt, water, or dust suppressants to unpaved roads, yards, open stockpiles and similar activities; g. Paving of access roadways, parking areas, manufacture area, and fuel storage yard; h. Removal of dust from buildings, roads, and other paved areas under the control of the owner or operator of the facility to prevent particulate matter from becoming airborne; i. A vacuum sweeper shall be used to remove dust from paved roads, parking, and other work area; j. Enclosure or covering of conveyor systems where practicably feasible; k. All materials on plant property shall be stored under roof. Materials, other than quarried materials, shall be stored on compacted clay or concrete, or in enclosed vessels; l. Use of hoods, fans, filters, and similar equipment to contain, capture and/or vent particulate matter; and, American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 5 of 64 SECTION II. FACILITY-WIDE CONDITIONS. m. Confining abrasive blasting where possible. In determining what constitutes reasonable precautions for a particular source, the Department shall consider the cost of the control technique or work practice, the environmental impacts of the technique or practice, and the degree of reduction of emissions expected from a particular technique or practice. [Rules 62-212.400 (Best Available Control Technology), and 62-296.320(4)(c), F.A.C.; Appendix BD - Final BACT Determination and Emission Standards; Permit 1190042-001-AC (PSD-FL-361) [Rule 62-296.320(4)(c), F.A.C., Permit Renewal Application dated March 28, 2016] Annual Reports and Fees See Appendix RR, Facility-wide Reporting Requirements for additional details. FW6. Electronic Annual Operating Report and Title V Annual Emissions Fees. The information required by the Annual Operating Report for Air Pollutant Emitting Facility [Including Title V Source Emissions Fee Calculation] (DEP Form No. 62-210.900(5)) shall be submitted by April 1 of each year, for the previous calendar year, to the Department of Environmental Protection’s Division of Air Resource Management. Each Title V source shall submit the annual operating report using the DEP’s Electronic Annual Operating Report (EAOR) software, unless the Title V source claims a technical or financial hardship by submitting DEP Form No. 62-210.900(5) to the DEP Division of Air Resource Management instead of using the reporting software. Emissions shall be computed in accordance with the provisions of subsection 62-210.370(2), F.A.C. Each Title V source must pay between January 15 and April 1 of each year an annual emissions fee in an amount determined as set forth in subsection 62-213.205(1), F.A.C. The annual fee shall only apply to those regulated pollutants, except carbon monoxide and greenhouse gases, for which an allowable numeric emission-limiting standard is specified in the source’s most recent construction permit or operation permit. Upon completing the required EAOR entries, the EAOR Title V Fee Invoice can be printed by the source showing which of the reported emissions are subject to the fee and the total Title V Annual Emissions Fee that is due. The submission of the annual Title V emissions fee payment is also due (postmarked) by April 1st of each year. A copy of the system-generated EAOR Title V Annual Emissions Fee Invoice and the indicated total fee shall be submitted to: Major Air Pollution Source Annual Emissions Fee, P.O. Box 3070, Tallahassee, Florida 32315-3070. Additional information is available by accessing the Title V Annual Emissions Fee On-line Information Center at the following Internet web site: http://www.dep.state.fl.us/air/emission/tvfee.htm. [Rules 62-210.370(3), 62-210.900 & 62-213.205, F.A.C.; and, §403.0872(11), Florida Statutes (2013)] {Permitting Note: Resources to help the permittee complete the AOR are available on the electronic AOR (EAOR) website at: http://www.dep.state.fl.us/air/emission/eaor. If the permittee has questions or need assistance after reviewing the information posted on the EAOR website, please contact the Department by phone at (850) 717-9000 or email at [email protected].} FW7. Annual Statement of Compliance. The permittee shall submit an annual statement of compliance to the compliance authority at the address shown on the cover of this permit within 60 days after the end of each calendar year during which the Title V permit was effective. The submittal may be made electronically to [email protected]. (See also Appendix RR, Conditions RR1 and RR7.) [Rules 62-213.440(3)(a)2. & 3. and (3)(b), F.A.C.] FW8. Prevention of Accidental Releases (Section 112(r) of CAA). If, and when, the facility becomes subject to 112(r), the permittee shall: a. Submit its Risk Management Plan (RMP) to the Chemical Emergency Preparedness and Prevention Office (CEPPO) RMP Reporting Center. Any Risk Management Plans, original submittals, revisions or updates to submittals, should be sent electronically through EPA’s Central Data Exchange system at the following address: https://cdx.epa.gov. Information on electronically submitting risk management plans using the Central Data Exchange system is available at: http://www2.epa.gov/rmp. The RMP Reporting Center can be contacted at: RMP Reporting Center, Post Office Box 10162, Fairfax, VA 22038, Telephone: (703) 227-7650. American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 6 of 64 SECTION II. FACILITY-WIDE CONDITIONS. b. Submit to the permitting authority Title V certification forms or a compliance schedule in accordance with Rule 62-213.440(2), F.A.C. [40 CFR 68] FW9. Semi-Annual Monitoring Reports. The permittee shall monitor compliance with the terms and conditions of this permit and shall submit reports of any deviations from the requirements of these conditions at least every six (6) months. All instances of deviations from permit requirements must be clearly identified in such reports, including reference to the specific requirement and the duration of such deviation. All reports shall be accompanied by a certification by a responsible official, pursuant to subsection 62-213.420(4), F.A.C. (See also Conditions RR2. – RR4. of Appendix RR, Facility-wide Reporting Requirements, for additional reporting requirements related to deviations.) [Rule 62-213.440(1)(b)3.a., F.A.C.] {Permitting Note: EPA has clarified that, pursuant to 40 CFR 70.6(a)(3), the word “monitoring” is used in a broad sense and means monitoring (i.e., paying attention to) the compliance of the source with all emissions limitations, standards, and work practices specified in the permit.} Additional Operational Requirements FW10. Used Oil Notification: a. Identification numbers. Used oil burners which have not previously complied with the notification requirements of RCRA section 3010 must comply with these requirements and obtain an EPA identification number. b. Mechanics of notification. A used oil burner who has not received an EPA identification number may obtain one by notifying the Regional Administrator of their used oil activity by submitting either: (1) A completed EPA Form 8700-12 (To obtain EPA Form 8700-12 call RCRA/Superfund Hotline at 1- 800-424-9346 or 703-920-9810); or (2) A letter requesting an EPA identification number. Call the RCRA/Superfund Hotline to determine where to send a letter requesting an EPA identification number. The letter should include the following information: (i). Burner company name; (ii). Owner of the burner company; (iii). Mailing address for the burner; (iv). Name and telephone number for the burner point of contact; (v). Type of used oil activity; and (vi). Location of the burner facility. [40 CFR 279.62] FW11. Used Oil Storage: Used oil burners are subject to all applicable Spill Prevention, Control and Countermeasures (40 CFR part 112) in addition to the requirements of this subpart. Used oil burners are also subject to the Underground Storage Tank (40 CFR part 280) standards for used oil stored in underground tanks whether or not the used oil exhibits any characteristics of hazardous waste, in addition to the requirements of this subpart. a. Storage units. Used oil burners may not store used oil in units other than tanks, containers, or units subject to regulation under parts 264 or 265 of this chapter. b. Condition of units. Containers and aboveground tanks used to store oil at burner facilities must be: (1) In good condition (no severe rusting, apparent structural defects or deterioration); and (2) Not leaking (no visible leaks). c. Secondary containment for containers. Containers used to store used oil at burner facilities must be equipped with a secondary containment system. (1) The secondary containment system must consist of, at a minimum: (i). Dikes, berms or retaining walls; and (ii). A floor. The floor must cover the entire area within the dike, berm, or retaining wall. (2) The entire containment system, including walls and floor, must be sufficiently impervious to used oil to prevent any used oil released into the containment system from migrating out of the system to the soil, groundwater, or surface water. American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 7 of 64 SECTION II. FACILITY-WIDE CONDITIONS. d. Secondary containment for existing aboveground tanks. Existing aboveground tanks used to store used oil at burner facilities must be equipped with a secondary containment system. (1) The secondary containment system must consist of, at a minimum: (i). Dikes, berms or retaining walls; and (ii). A floor. The floor must cover the entire area within the dike, berm, or retaining wall except areas where existing portions of the tank meet the ground; or (iii). An equivalent secondary containment system. (2) The entire containment system, including walls and floor, must be sufficiently impervious to used oil to prevent any used oil released into the containment system from migrating out of the system to the soil, groundwater, or surface water. e. Secondary containment for new aboveground tanks. New aboveground tanks used to store used oil at burner facilities must be equipped with a secondary containment system. (1) The secondary containment system must consist of, at a minimum: (i). Dikes, berms or retaining walls; and (ii). A floor. The floor must cover the entire area within the dike, berm, or retaining wall; or (iii). An equivalent secondary containment system. (2) The entire containment system, including walls and floor, must be sufficiently impervious to used oil to prevent any used oil released into the containment system from migrating out of the system to the soil, groundwater, or surface water. [40 CFR 279.64] FW12. On Specification Used Oil Fuel Requirements - “On-Specification” used oil fuel shall meet the following specifications: a. Arsenic shall not exceed 5.0 ppm; b. Cadmium shall not exceed 2.0 ppm; c. Chromium shall not exceed 10.0 ppm; d. Lead shall not exceed 100.0 ppm; e. Total halogens shall not exceed 1000 ppm; and f. Flash point shall not be less than 100° F Used oil fired as a fuel may be generated from on-site sources or purchased from a vendor. Used oil shall not contain any PCB’s per 40 CFR 761.20(e). [Permit 1190042-001-AC (PSD-FL-361), 40 CFR 279.61; 40 CFR 761.20(e)] Table of Contents American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 8 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection A. Emissions Unit No. 001, Raw Material Quarrying, Crushing, and Storage The specific conditions in this section apply to the following emission unit: EU No. Brief Description 001 Raw Material Quarrying, Crushing, and Storage This emissions unit consists of raw material processing from quarry up to raw material storage, and additives handling from delivery to storage. Equipment includes a primary crusher at the quarry, and two raw materials storage buildings (RMS). Belt conveyors (Belts BO-3, BO-2, and BO-1) convey the crushed limestone between the crusher and the RMS. Raw material piles created via a Tripper Belt and stored inside of the RMS include limestone, alumina sources (e.g., bauxite, clay and coal ash), iron sources (e.g., mill scale and iron ore), silica sources (e.g., sand), and additives (e.g., feldspar). Other materials handling equipment includes harrow and portal reclaimers, stackers, hoppers, belt conveyors, a conveyor from the RMS to the raw mill, and a control system/analyzer. Raw material quarrying, crushing, and storage contains the following emissions points: • Primary crusher and all belt conveyors (Belts BO-3, BO-2, and BO-1) • Belt conveyor transfer points to raw material storage building [Crusher to Belt BO-3; Belt BO-3 to Belt BO-2; Belt BO-2 to Belt BO-1; Belt BO-1 to Tripper Belt; and Tripper Belt to Limestone Pile (located inside RMS)]. • All conveyors and hoppers associated with additives handling and storage.) {Permitting Note: This emissions unit is regulated under 40 CFR 60, Subpart A (General Provisions) and 40 CFR 60, Subpart OOO (Standards of Performance for Nonmetallic Mineral Processing Plants) adopted by reference in Rule 62-204.800(8)(b), F.A.C. For the purposes of Subpart OOO emission limits, this facility is considered an affected facility (as defined in §§60.670 and 60.671) which commenced construction, modification, or reconstruction after August 31, 1983 but before April 22, 2008 (construction of components of this emission unit were commenced on or before October 18, 2007). As indicated in the Title V renewal application received March 28, 2016, this emission unit conducts wet material mining operations and wet material processing operation (wet screening) as defined in §60.671 of Subpart OOO. As such, only the crusher operations are subject to the visible emission limits of Subpart OOO. Any changes in operations or modifications of equipment may change the applicable provisions of Subpart OOO. PSD BACT Determinations - A determination of the Best Available Control Technology (BACT) was made for particulate matter (PM/PM10). To satisfy the BACT requirements for this emission unit the visible emissions limits act as surrogate standards for PM. (Appendix BD – Final BACT Determination and Emission Standards)} Essential Potential to Emit (PTE) Parameters A.1. Hours of Operation - This emissions unit is permitted to operate continuously (i.e., 8,760 hours per year). [Rule 62-210. 200 (Definition of Potential to Emit), F.A.C.; Construction Permit 1190042-001-AC (PSD-FL- 361)] A.2. Process Rate Limitations - The crusher may process up to 540,000 tons (dry basis) per month of raw materials on monthly average basis. No more than 1,482,000 tons (dry basis) of raw materials shall be processed during any consecutive 12-month period. (See Specific Condition No. A.8. for recordkeeping requirements associated with these process rate limitations and related testing provisions in Appendix TR, Facility-wide Testing Requirements for operating rate limitation after testing.) [Rule 62-210200 (Definition of Potential to Emit), F.A.C.; Permit No. 1190042-001-AC (PSD-FL-361)] American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 9 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection A. Emissions Unit No. 001, Raw Material Quarrying, Crushing, and Storage Emission Limitations and Standards A.3. Visible Emission Standards - Visible emissions (VE) shall not exceed the following limits. a. Fugitive emissions from the crusher shall not exceed 15% opacity b. The following equipment up to the first crusher and in the production line after the first crusher, grinding mill or storage bin are exempt from the requirements of NSPS Subpart OOO. However, visible emissions from these operations shall not exceed 20% opacity. This facility-wide opacity limit of 20% per 62-296.320(4)(b)1. F.A.C. does not require VE testing. a. Screening operations, b. bucket elevators, c. belt conveyors, d. bagging operations, e. storage bins, f. enclosed truck or railcar loading stations, and g. any other affected facility (as defined in 40 CFR 60.670 and 40 CFR 60.671). [40 CFR 60.670-671 Rule 62-296.320(4)(b)1. F.A.C.] Test Methods and Procedures A.4. Visible Emissions Test Required. Within 180 days prior to this permit’s renewal application due date, the permittee shall determine compliance with the visible emissions limits for the crusher contained in Specific Condition A.3.a. {Permitting Note: Tests which are only required once during the term of a permit prior to obtaining a renewed permit should be performed roughly five years from the previous test.} A.5. Test Methods. Tests shall be performed in accordance with the following reference methods: Method Description of Method and Comments 9 Visual Determination of the Opacity of Emissions from Stationary Sources The above methods are described in 40 CFR 60, Appendix A, and adopted by reference in Rule 62-204.800, F.A.C. No other methods may be used unless prior written approval is received from the Department. [Rule 62-204.800(8) F.A.C.; NSPS Subpart OOO 40 CFR 60.675; Permit No. 1190042-001-AC (PSD-FL-361)] A.6. Common Testing Requirements. Unless otherwise specified, tests shall be conducted in accordance with the requirements and procedures specified in Appendix TR, Facility-Wide Testing Requirements, of this permit, as well as the applicable provisions of NSPS Subpart OOO 40 CFR 60.675 (for crusher only). [Rule 62-297.310, F.A.C., Permit No. 1190042-001-AC (PSD-FL-361)] Recordkeeping and Reporting Requirements A.7. Compliance Test Reports - For each compliance test conducted, the permittee shall file a test report including the information specified in Rule 62-297.310(10)(c), F.A.C. with the compliance authority no later than 45 days after the last run of each test is completed. (See Condition TR8. in Appendix TR, Facility-Wide Testing Requirements for additional test report requirements.) [Rule 62-297.310(8), F.A.C.; Permit No. 1190042-001-AC (PSD-FL-361)] A.8. Crusher Process Rate Records - In order to document compliance with the crusher process rate limitations of Specific Condition No. A.2., the permittee shall maintain the following records of the monthly crusher processing rate: a. the month of the record; b. the crusher processing rate (tons dry basis) for each month; and American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 10 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection A. Emissions Unit No. 001, Raw Material Quarrying, Crushing, and Storage c. the total tons (dry basis) processed through the crusher in the most recent 12 consecutive month period (stated as tons (dry basis) per 12 consecutive month period). The above information shall be recorded no later than 10 days following the end of the month. It shall be available to the Department when requested. [Rule 62-213.440(1)(b), F.A.C., Permit No. 1190042-001-AC (PSD-FL-361)] A.9. Other Reporting Requirements - See Appendix RR, Facility-Wide Reporting Requirements, for additional reporting requirements. [Rule 62-213.440(1)(b), F.A.C.] Table of Contents American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 11 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection B. Emissions Unit No. 002, Raw Materials Conveying, Storage, and Processing The specific conditions in this section apply to the following emissions unit: EU No. Brief Description 002 Raw Materials Conveying, Storage, and Processing This emissions unit consists of raw material and additive storage to preheater (includes conveyance of raw materials and raw meal to and from raw mill, and homogenizing silo. Equipment includes one homogenizing silo (nominal 10,000 ton capacity) and the associated transport system. The following emissions points (EP) in the raw materials conveying, storage, and processing system are controlled by fabric filter baghouses: Baghouse Emissions Point (EP) Description Baghouse Description /EP ID Raw meal transfer at air lift to CAMCORP Model 4TR8x16 baghouse with design F-10 homogenizing silo exhaust air flow rate of 1,000 acfm CAMCORP Model 15TR12x225 baghouse with Raw meal transfer to homogenizing silo G-07 design exhaust air flow rate of 22,000 acfm CAMCORP Model 7TR12x49 baghouse with Homogenizing silo bin vent G-10 design exhaust air flow rate of 3,000 acfm CAMCORP Model 8TR12x64 baghouse with Filter dust surge bin E-38 design exhaust air flow rate of 6,000 acfm CAMCORP Model 4TR8x16 baghouse with design Raw meal transfer from homogenizing silo H-08 exhaust air flow rate of 1,000 acfm Dust transfer from main baghouse to finish CAMCORP Model 8TR12x64 baghouse with mill, including a 200-ton silo and dust TBD design exhaust air flow rate of 6,000 acfm collector {Permitting Note: The emission points tabulated above do not vent to the kiln (EU 003). This emissions unit is regulated under 40 CFR 63, Subpart A (General Provisions) and 40 CFR 63, Subpart LLL (National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Portland Cement Manufacturing Industry) adopted by reference in Rule 62-204.800(8)(b), F.A.C. For the purposes of Subpart LLL emission limits, this facility is considered an “existing” source (built prior to May 6, 2009). Although the baghouse for dust transfer from the main baghouse to the finish mill is considered “new” for purposes of NESHAP LLL; the monitoring recordkeeping requirements are the same .} Essential Potential to Emit (PTE) Parameters B.1. Hours of Operation - This emissions unit is permitted to operate continuously (i.e., 8,760 hours per year). [Rule 62-210. 200 (Definition of Potential to Emit), F.A.C.] Control Technology B.2. Baghouse Controls - Each emissions point (EP) identified above for the raw material conveying, storage and processing operations shall be controlled by a baghouse system. Each required baghouse shall be designed, operated, and maintained to achieve a PM design specification of 0.01 grains/dscf and a PM10 design specification of 0.007 grains/dscf. [Rules 62-212.400 (Best Available Control Technology), F.A.C.; Appendix BD - Final BACT Determination and Emission Standards; Permit Nos. 1190042-001-AC (PSD-FL- 361) and1190042-015-AC] Emissions Limitations and Standards American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 12 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection B. Emissions Unit No. 002, Raw Materials Conveying, Storage, and Processing B.3. Visible Emissions (VE) Limitations - Visible emissions (VE) shall not exceed the following limits. a. Visible emissions are limited to 5% opacity from each of the emissions points (EP) shown in the EP table above and controlled by a baghouse. b. Visible emissions are limited to 10% opacity from any other emissions point associated with this emissions unit and not controlled by a baghouse. {Permitting Note - The baghouses are designed to control PM emissions to 0.01 grains/dry standard cubic foot (gr/dscf) and PM10 emissions to 0.007 gr/dscf. The 5% opacity limitation is consistent with this design and provides reasonable assurance that annual emissions of PM/PM10 for all emission points in this emission unit system will be less than 10.5 TPY. Exceedance of the 5% opacity limit shall be deemed an exceedance of this permit condition and not necessarily an exceedance of the 10% opacity VE limitations given in NSPS 40 CFR 60 Subpart F or NESHAP 40 CFR 63 Subpart LLL § 63.1345.} [Rules 62-204.800(8) and (11), and 62-212.400 (Best Available Control Technology), F.A.C.; Appendix BD - Final BACT Determination and Emission Standards; NSPS Subpart F 40 CFR 60.62(c); NESHAP Subpart LLL 40 CFR 63.1345; Permit Nos 1190042-001-AC (PSD-FL-361) and1190042-015-AC.] Monitoring Requirements B.4. Opacity Monitoring Requirements - Each affected emissions point (EP) subject to an opacity standard shall be periodically monitored using the procedures described in paragraphs “a” through “e” of this section to ensure compliance with the requirements of Specific Condition No B.3.b a. You must conduct a monthly 10-minute visible emissions test of each affected source in accordance with Method 22 of 40 CFR 60, Appendix A. The performance test must be conducted while the affected source is in operation. b. If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner or operator may decrease the frequency of performance testing from monthly to semi- annually for that affected source. If visible emissions are observed during any semi-annual test, you must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. You must also meet the requirements of B.4.d below. c. If no visible emissions are observed during the semi-annual test for any affected source, you may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner or operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. You must also meet the requirements of B.4.d below. d. If visible emissions are observed during any Method 22 performance test, you must conduct five 6- minute averages of opacity in accordance with Method 9 in accordance with 40 CFR 60, Appendix A. The Method 9 performance test must begin within 1 hour of any observation of visible emissions. e. The requirement to conduct Method 22 visible emissions monitoring under this paragraph do not apply to any totally enclosed conveying system transfer point, regardless of the location of the transfer point. “Totally enclosed conveying system transfer point” means a conveying system transfer point that is enclosed on all sides, as well as, top and bottom. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. [40 CFR 63.1350(f)] American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 13 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection B. Emissions Unit No. 002, Raw Materials Conveying, Storage, and Processing Test Methods and Procedures B.5. Initial Compliance Test: The new dust shuttling system baghouse exhaust vent shall be tested to demonstrate initial compliance with the visible emission standard in condition B.3.a. The initial test shall be conducted within 60 days after achieving permitted capacity, but not later than 180 days after initial operation of the unit. [Rules 62-4.070(3), 62-297.310(8)(b)1, F.A.C. and Permit No. 1190042-015-AC] B.6. Annual Compliance Tests Required. During each calendar year (January 1st to December 31st), the baghouse exhaust vents for the emission points (EP) shown in the EP table above shall each be tested for visible emissions. [Rule 62-297.310(8), F.A.C.] {Permitting Note – The new dust shuttling baghouse shall be tested each calendar year after its initial compliance test as required by Condition B.4} B.7. Test Methods. When required, tests shall be performed in accordance with the following reference methods: Method Description of Method and Comments 9 Visual Determination of the Opacity of Emissions from Stationary Sources Visual Determination of Fugitive Emissions From Material Sources (for opacity periodic 22 monitoring) The above methods are described in 40 CFR 60, Appendix A, and adopted by reference in Rule 62-204.800, F.A.C. No other methods may be used unless prior written approval is received from the Department. [Rule 62-297.401, F.A.C.] B.8. Common Testing Requirements. Unless otherwise specified, tests shall be conducted in accordance with the requirements and procedures specified in Appendix TR, Facility-Wide Testing Requirements, of this permit. [Rule 62-297.310, F.A.C.] Records and Reports B.9. NESHAP 40 CFR 63 Subpart LLL Requirements. The permittee shall meet the applicable notification, recordkeeping, and reporting requirements in §63.1353, §63.1354 and §63.1355. The permittee shall maintain files of all information (including all reports and notifications) required by 40 CFR 63.1355 recorded in a form suitable and readily available for inspection and review as required by 40 CFR 63.10(b)(1). The files shall be retained for at least five years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. At a minimum, the most recent two years of data shall be retained on site. The remaining three years of data may be retained off site. The files may be maintained in electronic format. [40 CFR 63.1353, 1354 and 1355] B.10. NSPS 40 CFR 60 Subpart F Requirements. The permittee shall meet the applicable recordkeeping and reporting requirements in §60.65. [40 CFR 60.65] B.11. Other Reporting Requirements. See Appendix RR, Facility-Wide Reporting Requirements, for additional reporting requirements. [Rule 62-213.440(1)(b), F.A.C.] Table of Contents American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 14 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System The specific conditions in this section apply to the following emissions unit: EU No. Brief Description 003 Pyroprocessing System The Pyroprocessing System includes the kiln, preheater/calciner (PH/C), raw mill, raw mill air heater, and clinker cooler. It consists of a dry process preheater/calciner rotary kiln with in-line raw mill that simultaneously dries and grinds raw materials using the exhaust gas from the kiln, preheater/calciner, and/or clinker cooler. The preheater includes a staged combustion calciner. The indirect-fired kiln, designed to process a nominal 220 tons per hour of dry preheater feed material (including baghouse dust recirculation), is equipped with a low-NOX main kiln burner. The calciner burners and main kiln burner are capable of burning pulverized coal (primary fuel), petroleum coke, natural gas, on-specification used oil, No. 2 fuel oil, and certain categories of alternative fuel materials. The alternative fuels include, but are not limited to, tire-derived fuel (TDF), plastics, roofing materials, agricultural biogenic materials, untreated and treated cellulosic biomass, carpet-derived fuel, alternative fuel mix, biosolids, and engineered fuel (EF). A kiln tire feed mechanism with an airlock/gate system is capable of feeding TDF into the kiln system at the transition section between the base of the calciner and the point where gases exit the kiln. Other equipment includes a raw mill air heater (with a design maximum heat input rate of 36 MMBtu per hour) for use when additional material drying capacity is required, and a clinker cooler with reciprocating grates, cooling air fans, and hot air ducting to the kiln, preheater/calciner, or in-line raw mill. The raw mill air heater is capable of firing natural gas, virgin fuel oil, and on-specification used oil. Emissions from the pyroprocessing system are directed to a single 12.8 foot diameter main exhaust stack with a stack height of 349 feet. The kiln vents partially to the coal mill (EU 007). PM/PM10 emissions from the pyroprocessing system are controlled by the following fabric filter main baghouse. Baghouse/ Emissions Point (EP) Description Baghouse Description EP ID E-19 Pyroprocessing System high temperature Main Baghouse with design exhaust (Main (Preheater/calciner, kiln, clinker air flow rate of 409,650 acfm exhausting out the 349 Baghouse) cooler, raw mill, air heater) foot tall Main Stack Nitrogen Oxides (NOX) emissions from the pyroprocessing system are controlled by the following: • Low-NOX Burners and Indirect Firing - The main kiln is equipped with a low NOX burner that creates distinct combustion zones within the flame. An indirect firing system is used to reduce the amount of primary air injected with the fuel used in the main kiln burner. The tire injection system reduces NOx emissions. • Staged Combustion in the Calciner (SCC) - The preheater/calciner (PH/C) system is designed such that the introduction of fuel, air, and meal to the calciner are staged or sequenced for the reduction of NOX emissions. • SNCR in the Calciner - A selective non-catalytic reduction (SNCR) system is operated to achieve the permitted levels for NOX emissions from the pyroprocessing system. The SNCR system consists of an aqueous ammonia tank, pumps, piping, compressed air delivery, injectors, control system, and other ancillary equipment. Aqueous ammonia is injected at locations in the calciner with an appropriate temperature profile to support the SNCR process. Sulfur Dioxide (SO2) emissions from the pyroprocessing system are controlled by the use of low-sulfur raw materials which keep SO2 emissions from the pyroprocessing system below permitted levels, and scrubbing by finely divided lime in the preheater, calciner, and kiln American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 15 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System The kiln exhaust stack includes CEMS for NOx, CO, THC, Hg, & HCl; and a CPMS for PM. {Permitting Notes: The permittee notified the Department by letter dated December 22, 2016, that the cement plant kiln unit is subject to the requirements for waste burning kilns under Rule 62-204.800(9)(f), F.A.C., which incorporates the requirements of DDDD, rather than being regulated under LLL. At the time of issuance of this permit, the kiln remains subject to DDDD and not LLL. If the permittee certifies that the kiln has not used any waste material for a period of six months and provides the appropriate advance notice to the Department, this permit authorizes the permittee to revert back to compliance with LLL rather than DDDD. If any material constituting waste were to be used, however, the kiln would immediately be subject to the DDDD requirements. This subsection of the permit therefore includes three sets of conditions to address the separate requirements. Conditions C.4 through C.34 apply regardless of applicability of DDDD or LLL; Conditions C.35 through C.57. apply only when the kiln is subject to DDDD; and C.58 through C.71. apply only when the kiln is subject to LLL. This emissions unit may be regulated under 40 CFR 63, Subpart A (General Provisions) and 40 CFR 63, Subpart LLL, adopted by reference in Rule 62-204.800(8)(b), F.A.C. For the purposes of Subpart LLL emission limits, this facility is considered an “existing” source (built prior to May 6, 2009) This emissions unit is subject to 40 CFR 60 Subpart A (General Provisions) and 40 CFR 60 Subpart F - Standards of Performance for Portland Cement Plants. Construction of the components of this Portland cement manufacturing plant was commenced on or before July 9, 2007, which is before the June 16, 2008 trigger date contained in Subpart F for the applicability of some requirements and is therefore “existing” equipment for the purposes of NSPS. If the unit is subject to DDDD, the unit is also considered “existing” based on the date of commencement of construction. The Department determined that the Best Available Control Technology (BACT) emissions performance requirements of this permit are as stringent as or more stringent than the requirements imposed by the applicable 40 CFR 60 Subpart F (NSPS) provisions. Some separate reporting and monitoring may be required by the individual subpart. PSD BACT Determinations - A determination of the BACT was made for particulate matter (PM/PM10), CO, NOX, SO2 and VOC for this emissions unit (Permit No. 1190042-001-AC (PSD-FL-361).} C.1. NESHAP Applicability. a. Subpart LLL. Subpart LLL and Conditions C.58 through C.71 apply to this emissions unit (EU) if the permittee were to switch to all non-waste fuels and meet the requirements of Condition C.3 below, then Subpart LLL would apply instead of the CISWI requirements. [40 CFR 63.1348(a)] b. Subpart A. If this EU becomes subject to NESHAP Subpart LLL, 40 CFR 63 Subpart A –General Provisions, would also apply. [40 CFR 63.1] C.2. NSPS Applicability. a. Subpart A. This emissions unit shall comply with all the applicable standards contained in 40 CFR 60 Subpart A – General Provisions, regardless of the EU being subject to DDDD or LLL. [40 CFR 60.1] b. Subpart F. This emissions unit shall comply with all the applicable standards contained in 40 CFR 60 Subpart F – Standards of Performance for Portland Cement Plants, regardless of the EU being subject to DDDD or LLL. [40 CFR 60.60] c. Subpart DDDD. This EU shall comply with all applicable standards under Rule 62-204.800(9)(f), F.A.C., which implements the emission guidelines of 40 CFR 60 Subpart DDDD - Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units that Commenced Construction On or Before November 30, 1999, unless the operator switches to non-waste fuels as provided under Condition C.3 below. [Rule 62-204.800(9)(f), F.A.C.] {Permitting Note: The compliance date for this subpart is February 7, 2018. Rule 62-204.800(9)(f), F.A.C. and NSPS Subpart DDDD are included in the appendices document.} C.3. Change of NSPS/NESHAP Applicability Status. American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 16 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System a. Waste-to-Fuel Switch. If the permittee combusts solid waste in the kiln, the kiln is subject to NSPS Subpart DDDD. If the permittee ceases to combust solid waste in the kiln, the permittee has the option of switching from compliance with Subpart DDDD to compliance with NESHAP Subpart LLL. If the permittee makes this election, the permittee shall meet the following conditions. (1) The permittee shall first establish an “effective date” for the waste-to-fuel switch, which shall be at least six (6) months after the date that the permittee ceased combusting solid waste in the kiln, consistent with 40 CFR 60.2710(a)(2), referenced in Rule 62-204.800(9)(f), F.A.C. (2) The kiln shall remain in compliance with DDDD, set forth in Conditions C.35 through C.57, until the “effective date” of the waste-to-fuel switch. (3) The permittee shall provide the Department with 30 days’ advance notice prior to the “effective date” of the waste-to-fuel switch. (4) The permittee shall be in compliance with NESHAP Subpart LLL on the “effective date” of the waste-to-fuel switch. b. Notification of Waste-to-Fuel Switch. The permittee’s 30-day advance notification to the Department regarding the effective date of a waste-to-fuel-switch required Specific Condition C.3a(3) above, shall include: (1) The date of the notice; (2) The name of the owner or operator and the location of the DDDD kiln that will cease burning solid waste; (3) The kiln is currently a DDDD unit, and Subpart LLL will become applicable as of the effective date of the waste-to-fuel switch; (4) The fuel(s), non-waste material(s), and solid waste(s) the kiln is currently combusting and has combusted over the past 6 months, and the fuel(s) or non-waste materials the kiln will commence combusting; (5) The date on which the kiln became subject to the currently applicable Subpart DDDD emission limits; (6) The date the permittee ceased combusting solid waste in the kiln; and (7) The effective date of the waste-to-fuel switch, consistent with Specific Condition C.3a(1) above. c. If the permittee meets these conditions, the kiln will become subject to the applicable requirements of NESHAP Subpart LLL on the effective date of the waste-to-fuel switch and Conditions C.58 through C.71, reflecting the Subpart LLL requirements will apply to the kiln, instead of the Subpart DDDD requirements reflected in Conditions C.35 through C.57. d. Re-firing Solid Waste – Compliance Requirements. Following a waste-to-fuel switch and the applicability of LLL, if the permittee begins using materials identified as a solid waste in the kiln, the kiln will again be subject to the DDDD requirements in Rule 62-204.800(9)(f), F.A.C. The “effective date” of the fuel-to-waste switch is the first day that the permittee introduces (or re-introduces) solid waste into the kiln. The permittee shall complete all initial compliance demonstrations for any LLL standards that are applicable to the kiln before the permittee commences or recommences combustion of solid waste. In addition, the permittee must provide 30 days’ prior notice of the fuel-to-waste switch “effective date.” After the completion of any required testing and the thirty-day notice, Subpart LLL requirements will no longer apply. e. All air pollution control equipment necessary for compliance with any newly applicable emissions limits which apply as a result of the cessation or commencement or recommencement of combusting solid waste shall be installed and operational as of the effective date of the waste-to-fuel or fuel-to-waste switch. f. All monitoring systems necessary for compliance with any newly applicable monitoring requirements which apply as a result of the cessation or commencement or recommencement of combusting solid waste shall be installed and operational as of the effective date of the waste-to-fuel, or fuel-to-waste switch. All calibration and drift checks shall be performed as of the effective date of the waste-to-fuel, or fuel-to- waste switch. Relative accuracy testing for DDDD CEMS need not be repeated if that testing was previously performed consistent with section 112 monitoring requirements or monitoring requirements. [Rule 62-204.800(9)(f), F.A.C. and 40 CFR 60.2710(a)] American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 17 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System Specific Conditions C.4– C.34 apply to this EU always, regardless of whether the EU is regulated under DDDD or LLL. Essential Potential to Emit (PTE) Parameters C.4. Hours of Operation - This emissions unit is permitted to operate continuously (i.e., 8,760 hours per year). [Rule 62-210. 200 (Definition of Potential to Emit), F.A.C.; Permit No. 1190042-001-AC (PSD-FL-361)] C.5. Process Rate Limitations - The clinker production rate of the kiln shall not exceed 135.42 tons per hour (30-kiln operating day rolling average) and 1,186,250 tons during any consecutive 12-month period. Kiln preheater feed rate shall be monitored and recorded for purposes of determining clinker production. The clinker production rate shall be determined using a factor based on reconciled clinker production, determined for accounting purposes in accordance with 40 CFR 63.1350(d)(1)(ii) and as specified in Condition C.62. [Rule 62-210. 200 (Definition of Potential to Emit), F.A.C.; Permit No. 1190042-001-AC (PSD-FL-361), 1190042-009-AC (PSD-FL-361F), and 1190042-015-AC] C.6. Authorized Fuels Categories for Pyroprocessing System Kiln and Calciner - Only the following authorized fuels shall be fired in the pyroprocessing system kiln and calciner. (See specific Condition H.4 for a description of each fuel category.) a. coal b. petroleum coke c. natural gas d. virgin fuel oil e. on-specification used fuel oil f. tire-derived fuel (TDF) (The kiln is currently permitted to use both whole tires using the existing tire injection mechanism system and chipped tires.) g. plastics h. roofing materials i. agricultural biogenic materials j. cellulosic biomass – untreated k. cellulosic biomass – treated (The permittee shall not fire more than 1,000 lb/hour averaged on a 7-day block average basis of segregated streams of wood treated with copper-chromium-arsenic (CCA) compounds.) l. carpet-derived fuel m. alternative fuel mix n. biosolids; and/or o. engineered fuel (EF) [Rule 62-210. 200 (Definition of Potential to Emit), F.A.C.; Permit No.1190042-001-AC (PSD-FL-361) and 1190042-009-AC (PSD-FL-361F] C.7. Authorized Fuels for Pyroprocessing System Air Heater - The raw mill air heater shall fire only the following fuels: a. natural gas; b. on-specification used oil; or c. No. 2 or No. 4 fuel oil. [Rule 62-210. 200 (Definition of Potential to Emit), F.A.C.; Permit No.1190042-001-AC (PSD-FL-361), as amended by Construction Permit 1190042-003-AC (PSD-FL-361B)] C.8. Prohibited Fuels and Materials - The owner or operator shall not introduce into any part of the process any of the following fuels and materials: a. hazardous wastes as defined in 40 CFR 261; b. petroleum contaminated soil or materials; c. off-specification used oil; American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 18 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System d. solid fuels other than those allowed by this permit; e. nuclear waste, and radioactive waste; f. biomedical waste; g. asbestos-containing materials per 40 CFR 61 Subpart M; h. whole batteries; i. solid wastes, other than those allowed by this permit, or j. Coal ash which has not been determined to be acceptable for initial or continued use to control emissions of Total Hydrocarbon (THC) and Volatile Organic Compound (VOC) by initial, trial, or periodic sampling protocols and test results specified in the facility Material Management Plan for THC/VOC emissions control (Appendix MM - Material Management Plan). These prohibited materials shall not be used to manufacture engineered fuels. If the permittee identifies delivered material that falls under this specific condition, the supplier shall be contacted and the material shall be returned, disposed, or any other appropriate legal method of handling the material shall be employed. The permittee shall maintain records of delivery, sampling and analysis, and actions taken to correct abnormalities. Such records shall be stored onsite for at least five years and available for inspection upon request. [Rule 62-210. 200 (Definition of Potential to Emit), F.A.C.; Permit No.1190042-001-AC (PSD-FL-361), 1190042-009-AC (PSD-FL-361F), and 1190042-017-AC; 30-Day Response letter to Consent Order OGC 15- 0398, dated September 17, 2015, specifically Appendix 1 Material Management Plan] C.9. Maximum Heat Input Rate to Pyroprocessing System - Kiln and Calciner - The design heat input rate to the pyroprocessing system kiln and calciner (combined) is 9,600 MMBtu per day (based on a nominal rate of 400 MMBtu/hr). [Rule 62-210. 200 (Definition of Potential to Emit), F.A.C.; Permit No.1190042-001-AC (PSD-FL-361)] C.10. Tire Derived Fuel (TDF) Usage Limitations and Requirements - The use of whole or chipped tire derived fuel (TDF) in the pyroprocessing system is limited by the following requirements a. The maximum heat input rate from firing TDF shall not exceed 60 MMBtu per hour and/or 15% of the total pyroprocessing system kiln and calciner heat input rate (the remaining 85% of the total pyroprocessing heat input rate shall be from the firing of other authorized fuels); b. TDF shall be directly fed into the kiln system at the transition section between the base of the calciner and the point where gases exit the kiln. The tire feed mechanism shall be operated with an airlock/gate system; c. Tires shall be stored, handled and managed in accordance with the provisions of Chapter 62-711, F.A.C., and the permittee’s current Solid Waste Operation Permit for a waste tire processing facility. (The current permit is 0297136-002-WT-02.) (See Specific Condition C.32 for recordkeeping requirements associated with the limitations of a. and b. above.) [Rule 62-210. 200 (Definition of Potential to Emit), F.A.C.; Permit No.1190042-001-AC (PSD-FL-361)] C.11. On Specification Used Oil Fuel Usage Limitations - The firing of “on-specification” used oil fuel shall not exceed the following: a. 1,000 gallons per hour (kiln and calciner combined); and b. 1,500,000 gallons during any consecutive 12-month period (kiln, calciner, and raw mill air heater combined). (See Specific Condition C.30 for recordkeeping requirements associated with the limitations of a. and b. above.) [Rule 62-210. 200 (Definition of Potential to Emit), F.A.C.; Permit No.1190042-001-AC (PSD-FL-361)] C.12. Standards for Used Oil Burners. American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 19 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System a. To ensure that used oil managed at a used oil burner facility is not hazardous waste under the rebuttable presumption of 40 CFR 279.10(b)(1)(ii), a used oil burner must determine whether the total halogen content of used oil managed at the facility is above or below 1,000 ppm. b. The used oil burner must determine if the used oil contains above or below 1,000 ppm total halogens by: (1) Testing the used oil; (2) Applying knowledge of the halogen content of the used oil in light of the materials or processes used; or (3) If the used oil has been received from a processor/re-finer subject to regulation under Subpart F of 40 CFR, Part 279, using information provided by the processor/re-finer. c. If the used oil contains greater than or equal to 1,000 ppm total halogens, it is presumed to be a hazardous waste because it has been mixed with halogenated hazardous waste listed in Subpart D of 40 CFR, Part 261. The owner or operator may rebut the presumption by demonstrating that the used oil does not contain hazardous waste (for example, by showing that the used oil does not contain significant concentrations of halogenated hazardous constituents listed in Appendix VIII of 40 CFR, Part 261). (1) The rebuttable presumption does not apply to metalworking oils/fluids containing chlorinated paraffins, if they are processed, through a tolling arrangement as described in 40 CFR 279.24(c), to reclaim metalworking oils/fluids. The presumption does apply to metalworking oils/fluids if such oils/fluids are recycled in any other manner, or disposed. (2) The rebuttable presumption does not apply to used oils contaminated with chlorofluorocarbons (CFCs) removed from refrigeration units where the CFCs are destined for reclamation. The rebuttable presumption does apply to used oils contaminated with CFCs that have been mixed with used oil from sources other than refrigeration units. d. Records of analyses conducted or information used to comply with paragraphs a., b., and c. of this condition shall be maintained by the burner for at least 3 years. [40 CFR 279.63, Rebuttable Presumption for Used Oil] C.13. Cement Kiln Dust Handling Requirements - Cement kiln dust shall be re-circulated in the process and shall not be directly discharged from process. This in-process recirculation includes the transfer of baghouse dust from the baghouse or dust bin to the finish mill, or elsewhere, for the purpose of controlling mercury emissions. Cement kiln dust removed from process equipment during maintenance and repair shall be confined and controlled at all times and shall be managed in accordance with the applicable provisions of 40 CFR 261. [Rule 62-210. 200 (Definition of Potential to Emit), F.A.C.; Permit No.1190042-001-AC (PSD-FL- 361)] C.14. SNCR System - A selective non-catalytic reduction (SNCR) system shall be operated to achieve the permitted levels for NOX emissions from the pyroprocessing system. The SNCR system will consist of an aqueous ammonia tank, pumps, piping, compressed air delivery, injectors, control system, and other ancillary equipment. Aqueous ammonia will be injected at a location(s) in the preheater/calciner with an appropriate temperature profile to support the SNCR process. [Rule 62-212.400 (Best Available Control Technology), F.A.C.; Appendix BD - Final BACT Determination and Emission Standards; Permit No.1190042-001-AC (PSD-FL-361)] Excess Emissions {Permitting Note - The following conditions C.16 through C.19 apply only to the emissions standards specified in Condition No. C.35. of this section that have “BACT” as the basis for the standard. Rule 62-210-700, F.A.C., (Excess Emissions) cannot vary or supersede any federal provision of the NSPS or the NESHAP programs.} C.15. Operating Procedures - The Best Available Control Technology (BACT) determinations established by this permit rely on “good operating practices” to reduce emissions. Therefore, all operators and supervisors shall be properly trained to operate and maintain the kiln and calciner, and pollution control systems in accordance with the guidelines and procedures established by each manufacturer. The training shall include good operating practices as well as methods for minimizing excess emissions. [Rule 62-212.400 (Best American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 20 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System Available Control Technology), F.A.C.; Appendix BD - Final BACT Determination and Emission Standards; Permit No.1190042-001-AC (PSD-FL-361)] C.16. Excess Emissions Prohibited - Excess emissions caused entirely or in part by poor maintenance, poor operation, or any other equipment or process failure that may reasonably be prevented during startup, shutdown, or malfunction shall be prohibited. All such preventable emissions shall be included in any compliance determinations based on CEMS data. [Rule 62-210.700(4), F.A.C.; Permit No.1190042-001-AC (PSD-FL-361)] C.17. Allowable Data Exclusions (BACT Limits only)- Continuous monitoring data collected during periods of startup, shutdown, and malfunction may be excluded from the compliance demonstrations only in accordance with the following requirements, provided that best operational practices to minimize emissions are adhered to and the duration of excess emissions are minimized. As provided by the authority in Rule 62-210.700(5), F.A.C., the following conditions replace the provisions in Rule 62-210.700(1), F.A.C. a. CO Data: Each 30-day rolling average shall include all periods of operation (including startup, shutdown, and malfunction), but may exclude limited periods due to equipment malfunctions. No more than 30 hours in any calendar month shall be excluded from the compliance determinations due to equipment malfunctions. Malfunctions do not include process upsets that occur as a normal part of cement production. b. NOX Data: Each 30-day rolling average shall include all periods of operation (including startup, shutdown, and malfunction), but may exclude limited periods due to malfunctions of the Selective Non- Catalytic Reduction (SNCR) system. “Malfunctions of the SNCR system” are defined as any unavoidable mechanical and/or electrical failure that prevents introduction of ammonia-based solutions into the kiln system. No more than 30 hours in any calendar month shall be excluded from the compliance determinations due to malfunctions of the SNCR system. c. Other Data: All valid data shall be included in the compliance determination. If the mercury CEMS is used as the method for demonstrating compliance, all valid data shall be included in the compliance determination. d. The following definitions apply to the above provisions: i. Startup (BACT) is defined as the commencement of operation of any emissions unit which has shut down or ceased operation for a period of time sufficient to cause temperature, pressure, chemical, or pollution control device imbalances, which might result in excess emissions. Startup is the time from when a shutdown kiln first begins firing fuel until it begins producing clinker. Startup begins when a shutdown kiln turns on the induced draft fan and begins firing fuel in the main burner. Startup ends when feed is being continuously introduced into the kiln for at least 120 minutes or when the feed rate exceeds 60 percent of the kiln design limitation rate, whichever occurs first. ii. Shutdown (BACT) means the cessation of the operation of an emissions unit for any purpose. Shutdown begins when feed to the kiln is halted and ends when continuous kiln rotation ceases. iii. Malfunction (BACT) means any unavoidable mechanical and/or electrical failure of air pollution control equipment or process equipment or of a process resulting in operation in an abnormal or unusual manner. Within one working day of any BACT only startup, shutdown, or malfunction of the system for which an exclusion of data occurred, the permittee shall notify the Department’s Central District Compliance Assurance Program ([email protected]). [Rule 62-210. 200 (159, 230, and 245), F.A.C.; Permit No.1190042-001-AC (PSD-FL-361)] C.18. Malfunction Notifications - If temporarily unable to comply with any condition of the permit due to breakdown of equipment (malfunction) or destruction by hazard of fire, wind, or by other cause, the permittee shall immediately (within one working day) notify the Compliance Authority. Notification shall include pertinent information as to the cause of the problem, and what steps are being taken to correct the problem American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 21 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System and to prevent its recurrence, and where applicable, the owner’s intent toward reconstruction of destroyed facilities. Such notification does not release the permittee from any liability for failure to comply with Department rules. If requested by the Compliance Authority, the owner or operator shall submit a quarterly written report describing the progress being made to correct the problem and prevent its recurrence. [Rules 62-210.700(6) and 62-4.130, F.A.C.; Permit No.1190042-001-AC (PSD-FL-361)] Monitoring Requirements C.19. Aqueous Ammonia Injection - A monitoring system to continuously monitor and record the aqueous ammonia injection rate of the SNCR system (1-hour block averages) shall be calibrated, operated, and maintained in accordance with the manufacturer’s recommendations. [Rule 62-212.400 (Best Available Control Technology), F.A.C.; Permit No.1190042-001-AC (PSD-FL-361)] C.20. Required Continuous Emission Monitoring Systems (CEMS) - The permittee shall calibrate, operate and maintain CEMS to measure and record concentrations of the following pollutants in the pyroprocessing system main exhaust stack (Baghouse/EP ID E-19) in a manner sufficient to demonstrate continuous compliance with the emissions standards specified in this subsection for the pyroprocessing system. a. carbon monoxide (CO); b. nitrogen oxides (NOX); c. mercury (Hg) d. volatile organic compounds/total hydrocarbons (VOC/THC)* and, e. hydrogen chloride (HCl ) *A continuous oxygen diluent monitor shall be calibrated, operated, and maintained at the THC monitor location to correct measured THC emissions to the required oxygen concentration. In the event the oxygen monitor is not operating, a default stack gas oxygen concentration of 16 percent will be applied. [Rules 62-4.070(3), 62-204.800(11), 62-212.400 (Best Available Control Technology (BACT)), and 62- 297.520, F.A.C.; Appendix BD - Final BACT Determination and Emission Standards; Permit No. 1190042- 001-AC (PSD-FL-361)] C.21. CEMS Certification Requirements a. CO CEMS (BACT) - The carbon monoxide continuous emissions monitoring system (CO CEMS) shall be certified pursuant to 40 CFR 60, Appendix B, Performance Specification 4 or 4A. Quality assurance procedures shall conform to the requirements of 40 CFR 60, Appendix F. The required Relative Accuracy Test Audit (RATA) tests shall be performed using EPA Method 10 in Appendix A of 40 CFR 60 and shall be based on a continuous sampling train. The CO CEMS span values shall be set appropriately, considering the expected range of emissions and corresponding emission standards. b. NOX CEMS (BACT) - The nitrogen oxides continuous emissions monitoring system (NOx CEMS) shall be certified pursuant to 40 CFR 60, Appendix B, Performance Specification 2. Quality assurance procedures shall conform to the requirements of 40 CFR 60, Appendix F. The required RATA tests shall be performed using EPA Method 7E in Appendix A of 40 CFR 60. The NOX CEMS span values shall be set appropriately, considering the expected range of emissions and corresponding emission standards. [Rules 62-204.800(8) & 62-212.400 (Best Available Control Technology), F.A.C.; Appendix BD - Final BACT Determination and Emission Standards; 40 CFR 60 Appendices A, B and F; Permit No.1190042-001- AC (PSD-FL-361)] C.22. CEMS Data Requirements (BACT only CO, VOC and NOx) The CEMS shall be calibrated, maintained, and operated in the in-line kiln/raw mill stack to measure and record the emissions of CO, NOX, and THC/VOC in a manner sufficient to demonstrate compliance with the emission limits of this permit. The CEMS shall express the results in units of pounds per ton of clinker produced, and pounds per hour. Emissions of VOC shall be reported in units of the standards (lb/hr, lb/ton of clinker) for BACT monitoring a. Valid Hourly Averages (applies to all CEMS (BACT) hourly data used for longer averaging times) Each CEMS shall be designed and operated to sample, analyze, and record data evenly spaced over the hour at a minimum of one measurement per minute. All valid measurements collected during an hour shall be American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 22 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System used to calculate a 1-hour block average that begins at the top of each hour. Each 1-hour block average shall be computed using at least one data point in each fifteen-minute quadrant of an hour, where the unit combusted fuel (or produced clinker) during that quadrant of an hour. Notwithstanding this requirement, a 1-hour average shall be computed from at least two data points separated by a minimum of 15 minutes (where the unit operates for more than one quadrant of an hour). If less than two such data points are available, there is insufficient data and the 1-hour block average is not valid. (1) Hours during which there is no kiln feed and no fuel fired are not valid hours. (2) Hours during which the plant is firing fuel but producing no clinker are valid, but these hours are excluded from the production-normalized emission rate computation (pounds per ton of clinker). These hours are included in any pollutant mass emission rate computation (pounds per hour). b. 30-day Rolling Averages (CO and NOx) Compliance with the emission limits for CO and NOX shall be based on a 30-day rolling average. Each 30-day rolling average shall be the arithmetic average of all valid hourly averages collected during the last 30 operating days. A new 30-day rolling average shall be recomputed after every day of operation for the new day and the preceding 29 operating days. For purposes of computing these emission limits, an operating day is any day that the kiln produces clinker or fires fuel. c. 30-day Block Average (VOC) - Compliance with the emission limits for VOC (as THC) shall be based on a 30-day block average. Each 30-day block average shall be the arithmetic average of all valid hourly averages occurring within each 30 operating-day block. d. Data Exclusion - Except for monitoring system breakdowns, repairs, calibration checks, and zero and span adjustments, each CEMS shall monitor and record emissions during all operations including episodes of startups, shutdowns, and malfunctions. Limited amounts of CEMS emissions data recorded during some of these episodes may be excluded from the corresponding compliance demonstration subject to the provisions of Condition No. C.18 in this section. The permittee shall minimize the duration of data excluded for such episodes to the extent practicable. e. Data Availability: Monitor availability for each CEMS shall be 95% or greater in any calendar quarter. Monitor availability shall be reported in the quarterly excess emissions report. In the event 95% availability is not achieved, the permittee shall provide the Department with a report identifying the problems in achieving 95% availability and a plan of corrective actions that will be taken to achieve 95% availability. The permittee shall implement the reported corrective actions within the next calendar quarter. Failure to take corrective actions or continued failure to achieve the minimum monitor availability shall be violations of this permit, except as otherwise authorized by the Compliance Authority. {Permitting Note: Not meeting 95% CEMS availability in a single calendar quarter does not constitute a violation of this permit condition so long as the corrective actions stipulated by the condition, i.e., submittal of a plan identifying the problems and taking corrective action in the next calendar quarter, are implemented by the permittee. Different problem(s) arising in subsequent calendar quarters with regard to CEMS availability also does not necessarily constitute a violation of this permit condition so long as corrective actions have been taken addressing any previous problem(s) and the new problem(s) do not arise from lack of maintenance, training of personnel or other negligence by the permittee. In addition, circumstances completely outside the control of the permittee, e.g. lightning strikes, that prevent 95% CEMS availability in a calendar quarter do not constitute a violation of this permit condition. Finally, continuing problems from calendar quarter to calendar quarter related to the same problem(s) that causes CEMS availability to not meet the 95% criteria could also constitute a violation of this permit condition.} [Permit Nos.1190042-001-AC (PSD-FL-361), 1190042-008-AC and 1190042-015-AC] C.23. Continuous Compliance: For purposes of BACT, continuous compliance with the permit standards for emissions of CO, NOX, Hg and VOC (via THC) shall be demonstrated with data collected from the required continuous emissions monitoring systems (CEMS). [Rules 62-212.400(10)(b) and 62-297.310(8)(a) & (b), F.A.C.] American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 23 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System Testing Requirements C.24. SO2 Compliance Testing – Compliance stack tests for SO2 shall be conducted prior to submittal of a Title V permit renewal application. [Permit No.1190042-015-AC] C.25. Compliance Testing Requirements - Any required compliance tests shall be conducted at, at least 90% of permitted capacity in accordance with the requirements of Rule 62-297.310(3), F.A.C. [Rules 62-204.800(8) and 62-297.310(8)(a) and (b), F.A.C.; Permit No.1190042-001-AC (PSD-FL-361)] C.26. Test Methods. When required, tests shall be performed in accordance with the following reference methods: Method Description of Method and Comments 1-4 Traverse Points, Velocity and Flow Rate, Gas Analysis, and Moisture Content 5 or 5i Method for Determining Particulate Matter Emissions (All PM is assumed to be PM10.) 6C Method for Determining SO2 Emissions (Instrumental) 7E Determination of Nitrogen Oxide Emissions from Stationary Sources Determination of Carbon Monoxide Emissions from Stationary Sources 10 {Note: The method shall be based on a continuous sampling train.} 23 Determination of Polychlorinated Dibenzo-P-Dioxins and Polychlorinated Dibenzofurans from Stationary Sources 321 Measurement of HCl by Fourier Transform Infrared (FTIR) instrumentation 25A Method for Determining Gaseous Organic Concentrations (Flame Ionization) 29 Determination of Metal Emissions from Stationary Sources 30B Determination of Mercury from Coal-Fired Combustion Sources Using Carbon Sorbent Traps The above methods are described in 40 CFR 60, Appendix A, and adopted by reference in Rule 62-204.800, F.A.C. No other methods may be used unless prior written approval is received from the Department. Tests shall be conducted in accordance with the appropriate test method and the applicable requirements specified in Appendix C of this permit, NSPS Subpart A in 40 CFR 60, and NESHAP Subparts A and LLL in 40 CFR 63. [Rules 62-204.800(8) F.A.C.; 40 CFR 60 Appendix A; 40 CFR 63 Subparts A and LLL] Records and Reports C.27. Used Oil Records - For each shipment of used oil received, the owner or operator shall maintain records from the vendor certifying that the used oil meets Specific Condition FW12. for specifications for “on- specification” used oil fuel. Records shall include the following parameters: arsenic, cadmium, chromium, lead, total halogens, flash point, PCBs, sulfur content, coal ash, and heating value. Otherwise, the owner or operator shall sample and analyze each shipment of used oil received for the above parameters. If vendor certifications are relied upon, the owner or operator shall analyze at least one sample obtained each calendar year for the above parameters. If analytical results show that the used oil does not meet the above requirements, the owner or operator shall immediately cease burning of the used oil, and notify the Compliance Authority of the analytical results. The analysis shall be performed via EPA-approved or ASTM methods. The permittee shall obtain, make, and keep the following records: a. gallons of on-specification used oil received and burned each month; b. name and address of all vendors delivering used oil to the facility; c. copies of the vendor certifications, if obtained, and any supporting information; and d. analytical results showing required parameters. The records shall be retained in a form suitable for inspection at the facility by the Department, and shall be retained permanently. [Permit No.1190042-001-AC (PSD-FL-361), 40 CFR 279.61, 40 CFR 761.20(e)] American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 24 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System C.28. Operational Records – In order to demonstrate compliance with the limitations specified in Specific Condition Nos. C.5. through C.10., and C.15., the owner or operator shall maintain the following operational records on site. For each 1-hour block of operation, continuously monitor and record the following: a. dry preheater feed rate (tons/hour); b. clinker production rate (tons/hour); c. fuel sources in use and fuel firing rate(s) for each fuel; d. heat input rate (based on the representative heating value and the hourly fuel firing rate of each fuel); and e. SNCR system NH3/NOX molar ratio or ammonia injection rate. Records shall also document the following for each 24-hour rolling period and consecutive 12-month period: f. dry preheater feed rate (tons/24 hours and tons/12 consecutive months); and g. clinker production rates (tons/24 hours and tons/12 consecutive months). [Permit No.1190042-001-AC (PSD-FL-361)] C.29. On-Specification Used Oil Usage Records - In order to demonstrate compliance with the usage limitations specified in Specific Condition No. C.11., the permittee shall keep the following records of on-specification used oil usage in the pyroprocessing system. Daily records shall consist of: a. gallons of on-specification (see Specific Condition No. FW12. for specifications) used oil used each day in the pyroprocessing system (gallons/day); b. amount of time each day that any pyroprocessing equipment was in operation firing on- specification used oil (hours/day); and c. daily average gallons/hour on-specification used oil firing rate, based on “a.” and “b.” above (divide “a” by “b”). Monthly records shall consist of: d. total pyroprocessing system on-specification used oil usage for the month (gallons/month); e. total pyroprocessing system on-specification used oil usage for the most recent 12- consecutive month period (gallons/12-consecutive months) [Permit No. 1190042-001-AC (PSD-FL-361)] C.30. Fuel Analysis Records - For each traditional fuel delivery the owner or operator shall maintain records of the quantity of fuel delivered and a representative analysis of the fuel including the sulfur content, higher and lower heating value, proximate analysis, and ultimate analyses. [Rule 62-212.400 (Best Available Control Technology), F.A.C.; Permit No.1190042-001-AC (PSD-FL-361)] C.31. Tire Derived Fuel (TDF) Heat Input Rate Records - In order to demonstrate compliance with the whole or chipped tire derived fuel (TDF) heat input rate limitations specified in Specific Condition No. C.10., the permittee shall keep the following hourly records of pyroprocessing system TDF heat input rate. a. the total pyroprocessing system TDF heat input rate (TDF MMBtu/hour); b. the total pyroprocessing system heat input rate from all fuels (Total MMBtu/hour); c. the percentage of the total pyroprocessing rate heat input rate provided by TDF, based on a. and b. above (Divide a by b then multiply by 100) [Permit No.1190042-001-AC (PSD-FL-361)] C.32. Annual Mercury (Hg) PSD Avoidance Emission Limitation Compliance Demonstration: a. Material Balance Demonstration - If not using the mercury (Hg) CEMS to demonstrate compliance with the Annual Hg BACT emission limitation (see b. below), the owner or operator shall demonstrate compliance with the Hg throughput limitation by material balance and maintaining records of the monthly and rolling 12-month mercury throughput. Samples of the raw mill feed and all fuels shall be collected each day. A single composite daily sample shall be made from all samples collected during a day. A American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 25 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System monthly composite sample shall be made from each of the daily composite samples. Each monthly composite sample shall be analyzed to determine the mercury concentration of the materials representative for the month. The analytical methods used to determine mercury concentration shall be EPA or ASTM methods such as EPA Method 7471A (Mercury in Solid or Semisolid Waste). No other methods may be used unless prior written approval is received from the Department. For each raw material and fuel, the monthly mercury throughput rate (pounds per month) shall be the product of the mercury concentration from the monthly composite sample and the mass of raw material or fuel used during the month. If the mercury concentration is below detection limit or below the limits of quantification, the detection limit will be assumed for the concentration of the raw material or fuel. The owner or operator shall have the option of collecting, composting, analyzing and calculating the Hg leaving the process via the clinker or dust permanently withdrawn from the pyroprocessing system. If the mercury concentration is below the detectable limit or limits of quantification (for the clinker or dust withdrawn), a value of zero will be assumed for the concentration in the clinker or dust. (1) For each month, the mass of mercury introduced into the pyroprocessing system (pounds per month) shall be the sum of the monthly mercury throughput rate for each raw material and fuel. (2) The consecutive 12-month mercury throughput rate shall be the sum of the individual monthly records for the current month and the preceding eleven months (pounds of mercury per consecutive 12-months). (3) Such records, including calculations and data, shall be completed no later than 25 days following the month of the records. b. Use of Mercury Continuous Emissions Monitoring System (Hg-CEMS) - The permittee may use the Hg- CEMS to demonstrate compliance with the BACT cumulative 12-month rolling Hg mass emission limitation (122 pounds per rolling 12-month period) in lieu of the procedures described in the preceding paragraph. [Permit No.1190042-001-AC (PSD-FL-361)] {Permitting Note: Demonstrating compliance with the more stringent Hg emission standard in DDDD or LLL (as applicable), assures compliance with the BACT standard.} C.33. Quarterly CEMS Report - Within 30 days following the end of each calendar quarter, the permittee shall submit a report to the Compliance Authority summarizing: equipment malfunctions resulting in excluded CEMS data and/or excess emissions; and the monitor availability of each CEMS. The report shall contain the information and follow the general format specified in Appendix TV this permit. [Rules 62-4.130 & 62- 212.400(BACT), F.A.C.; and Permit No. 1190042-001-AC (PSD-FL-361)] Conditions C.35 to C.57 apply only of the kiln is subject to DDDD Emissions Standards C.34. Emissions Standards - Emissions from the pyroprocessing system (including the air heater) main stack shall not exceed the emissions standards shown in the following table. Unless otherwise noted (refer to Condition C.18.), emission limitations apply during all periods of operation (including startup, shutdown, and malfunction) Compliance Pollutant Emission Limit1,2,6 Averaging Time Basis Method 2.67 lb/ton of clinker 30-day rolling CEMS BACT 362.5 lb/hr Carbon Monoxide 30-day rolling (CO) 790 parts per million by volume, CEMS or Annual (CEMS) or three Table 8 to dry, corrected to 7% oxygen or greater Method 1-hr runs (Method DDDD9 (ppmvd @ 7% O2) 10 10) American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 26 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System Compliance Pollutant Emission Limit1,2,6 Averaging Time Basis Method 1.8 lb/ton of clinker 30-day rolling CEMS BACT 243.8 lb/hr Nitrogen Oxides 30-day rolling (NOX) CEMS or Annual (CEMS) or three Table 8 to 630 ppmvd @ 7% O2 or greater Method 1-hr runs (Method DDDD3, 9 7 or 7E 7 or 7E) 0.185 lb/ton of clinker Method 6 or 6C Three, 1-hour runs upon permit BACT 25.0 lb/hr renewal Sulfur Dioxide (SO2) 30-day rolling CEMS or Annual (CEMS) or three Table 8 to 600 ppmvd @ 7% O2 or greater Method 1-hr runs (Method DDDD9 6 or 6C 6 or 6C) 0.11 lb/ton of clinker Volatile Organic 4 30-day block CEMS BACT Compounds (VOC) 15.0 lb/hr 0.153 lb/ton of clinker Annual Method 5, Three 1-hr runs 5 RM-up BACT 19.13 lb/hr Particulate Matter 10% Opacity 6-minute block CPMS BACT (PM/PM10) 30-day rolling CPMS or Annual 13.5 milligrams per dry standard (CPMS) or three Table 8 to or greater Method cubic meter (mg/dscm) @ 7% O2 1-hr runs (Method DDDD9 5 5) 0.075 nanograms (ng)/dscm (Toxic Equivalency Basis (TEQ)) Dioxins/ 8 Annual or greater Table 8 to @ 7% O2 or Three-run average Furans (D/F)3 Method 23 DDDD 1.3 ng/dscm (Total Mass Basis) @ 7% O2 Rule 62- 58 pounds per Million tons of CEMS or Sorbent Mercury (Hg) 30-day rolling 204.800(9)(f), clinker (lb/MM tons clinker) Trap F.A.C.7, 9 30-day rolling CEMS or Annual Hydrochloric Acid (CEMS) or Table 8 to 3 ppmvd @ 7% O2 or greater Method 8, 9 (HCl) Three-run average DDDD 321 (Method 321) Annual or greater Table 8 to Cadmium (Cd) 0.0014 mg/dscm @ 7% O2 Three-run average Method 29 DDDD8 Annual or greater Table 8 to Lead (Pb) 0.014 mg/dscm @ 7% O2 Three-run average Method 29 DDDD8 1. Oxygen monitoring is required for DDDD compliance, correction to 7% O2. DDDD pollutants, except Hg, that are measured by CMS shall not be oxygen corrected for periods of startup and shutdown pursuant to Rule 62- 204.800(9)(f), F.A.C., referencing 40 CFR 60.2875. Refer to Condition C.48 for operation requirements during periods of startup and shutdown. American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 27 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System Compliance Pollutant Emission Limit1,2,6 Averaging Time Basis Method 2. On an annual basis, no more than 12 months following the previous annual air pollution control device inspection, the permittee shall complete the air pollution control device inspection as described in 40 CFR 60. 2706. 3. All valid NOx hourly averages shall be included into the 30-day rolling average. Compliance with NOx BACT limit and monitoring requirements shall suffice for NOx DDDD limit and monitoring. 4. Compliance shall be demonstrated by THC CEMS. VOC emissions shall be measured as THC and expressed as “propane” for the mass emissions rate. The Permittee can request to demonstrate by a Method 25A test that a fraction of THC is methane if exceedance of VOC limit is indicated by THC CEMS. 5. For purposes of BACT compliance, all PM emitted from the baghouse exhaust is assumed to be PM10. a. The PM limit in DDDD is more stringent than the BACT PM/PM10 limits (DDDD Control Plan states 19.13 lb/hr is equivalent to 37.3 mg/dscm 7% O2 compared to 13.5 mg/dscm 7% O2). Therefore, compliance with the DDDD PM limit assures compliance with the BACT PM/PM10 limits. b. The BACT requirements do not waive or vary any applicable DDDD monitoring or record keeping requirements. 6. Because the kiln system exhaust gas partially vents through the coal mill (EU007) stack, compliance testing for DDDD pollutants of CO, NOx, SO2, PM, D/F, Hg, HCl, Cd and Pb requires testing of kiln and coal mill per 40 CFR 60.2710(y)(3) (The kiln partially exhausts through the coal mill stack, but the coal mill exhaust does not exhaust to the kiln stack.). For purposes of determining the combined emissions from kilns that exhaust kiln gases to a coal mill that exhausts through a separate stack, instead of installing a CEMS or PM CPMS on the alkali bypass stack or in-line coal mill stack, the results of the initial and subsequent performance test can be used to demonstrate compliance with the relevant emissions limit. A performance test shall be conducted on an annual basis (between 11 and 13 calendar months following the previous performance test). 7. Because the Hg emission limit (58 lb/MM tons clinker) is specific to the Rule 62- 204.800(9)(f), F.A.C., the procedures to demonstrate compliance on the coal mill stack follows 40 CFR 63.1348(b)(7) and 63.1350(k). 8. If conducting stack tests to demonstrate compliance and performance tests for this pollutant for at least 2 consecutive years show that emissions are at or below this limit, permittee can skip testing according to 40 CFR 60.2720 if all of the other provisions of 40 CFR 60.2720 are met. 9. 40 CFR 60.2875 defines 30-day rolling average as: “the arithmetic mean of the previous 720 hours of valid operating data. Valid data excludes periods when this unit is not operating. The 720 hours should be consecutive, but not necessarily continuous if operations are intermittent.” For Hg, the 30-day rolling average is to be calculated as specified in Rule 62-204.800(9)(f), F.A.C. {Permitting Note - In combination with the annual clinker production limitation of 1,186,250 tons per year, the above emissions standards (most stringent) effectively limit annual potential emissions from this unit to: • 1,584 tons/year of CO (BACT); • 1,068 tons/year of NOX (BACT); • 90.7 tons/year of PM/PM10 (DDDD) • 110 tons/year of SO2 (BACT); and; • 66 tons/year of VOC (BACT). The effective limits in lb/ton clinker were calculated using the annual clinker production limit of 1,186,250 TPY. A five-year average of stack testing kiln exhaust flow rate, corrected to 7% O2 of 136,660 dscfm was used to calculate DDDD emissions.} [Rules 62-204.800(9)(f), 62-210.200 (Definition of Potential to Emit), 62-212.400 (Best Available Control Technology), F.A.C.; Appendix BD - Final BACT Determination and Emission Standards; Permit No.1190042- 001-AC (PSD-FL-361) and 1190042-009-AC (PSD-FL-361F)] C.37. Applicability of Emission Limits. The emission limitations apply at all times the EU is operating including and not limited to startup, shutdown, or malfunction. [Rule 62-204.800(9)(f), F.A.C., referencing 40 CFR 60.2670(a)] American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 28 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System Performance Testing C.38. PM CPMS Requirements. If the permittee uses a PM CPMS to demonstrate compliance, the permittee shall establish the PM CPMS operating limit and determine compliance with it according to paragraphs (i)(1) through (5) of 40 CFR 60.2675. [Rule 62-204.800(9)(f), F.A.C., referencing 40 CFR 60.2675] C.39. Initial and Annual Performance Testing. a. All performance tests shall consist of a minimum of three test runs conducted under conditions representative of normal operations. b. The permittee shall document that the waste burned during the performance test is representative of the waste burned under normal operating conditions by maintaining a log of the quantity of waste burned (as required in 40 CFR 60.2740(b)(1)) and the types of waste burned during the performance test. [Rule 62-204.800(9)(f), F.A.C., referencing 40 CFR 60.2690] C.40. Initial Performance Date Deadline. The initial performance test shall be conducted no later than 180 days after the final compliance date of February 7, 2018. [Rule 62-204.800(9)(f), F.A.C., referencing 40 CFR 60.2705(a)] C.41. Initial Air Pollution Control Device Inspection. a. The initial air pollution control device inspection shall be conducted within 60 days after installation of the control device and the kiln reaches the charge rate at which it will operate, but no later than 180 days after the final compliance date for meeting the amended emission limitations. b. Within 10 operating days following an air pollution control device inspection, all necessary repairs shall be completed unless the owner or operator obtains written approval from the Department establishing a date whereby all necessary repairs of the designated facility shall be completed. [Rule 62-204.800(9)(f), F.A.C, referencing 40 CFR 60.2706] Continuous Compliance C.42. CO Compliance. For facilities using a CEMS to demonstrate compliance with the CO emission limit, compliance with the CO emission limit may be demonstrated by using the CEMS according to 40 CFR 60.2710(g) or periodic stack testing by Method 10 pursuant to 40 CFR 60.2710(b). [Rule 62-204.800(9)(f), F.A.C., referencing 40 CFR 60.2710(g)] C.43. Exemptions During Performance Testing. Operation above the established maximum, below the established minimum, or outside the allowable range of the operating limits specified in Condition C.35., constitutes a deviation from the permittee’s DDDD operating limits, except during performance tests conducted to determine compliance with the emission and operating limits or to establish new operating limits. Operating limits are confirmed or reestablished during performance tests. [Rule 62-204.800(9)(f), F.A.C, referencing 40 CFR 60.2710(c)] C.44. HCl and Hg Compliance. If the permittee does not use an acid gas wet scrubber or dry scrubber, the permittee must determine compliance with the HCl emissions limit according to the requirements in paragraph 40 CFR 60.2710 (j)(1). The permittee shall determine compliance with the mercury emissions limit using a mercury CEMS according to paragraph 40 CFR 60.2710 (j)(2). [Rule 62-204.800(9)(f), F.A.C, referencing 40 CFR 60.2710(j)] C.45. Interval of Annual Performance Tests. a. The permittee shall conduct annual performance tests between 11 and 13 months of the previous performance test. b. The permittee shall repeat the performance test if the feed stream is different than the feed streams used during any performance test used to demonstrate compliance. [Rule 62-204.800(9)(f), F.A.C., referencing 40 CFR 60.2715 and 40 CFR 60.2725] American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 29 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System C.46. Alternate Interval of Performance Testing. The permittee shall conduct annual performance tests according to the schedule specified in Condition C.45a., with the following exceptions: a. The permittee may conduct a repeat performance test at any time to establish new values for the operating limits to apply from that point forward, as specified in 40 CFR 60.2725. The Department may request a repeat performance test at any time. b. The permittee shall repeat the performance test within 60 days of a process change, as defined in 40 CFR 60.2875. Process change means any of the following physical or operational changes: (1) A physical change (maintenance activities excluded) to the DDDD unit which may increase the emission rate of any air pollutant to which a standard applies; (2) An operational change to the DDDD unit where a new type of non-hazardous secondary material is being combusted; (3) A physical change (maintenance activities excluded) to the air pollution control devices used to comply with the emission limits for the DDDD unit (e.g., replacing an electrostatic precipitator with a fabric filter); and (4) An operational change to the air pollution control devices used to comply with the emission limits for the affected DDDD unit (e.g., change in the sorbent injection rate used for activated carbon injection). c. If the initial or any subsequent performance test for any pollutant listed in Table 8 of Subpart DDDD (Condition C.35.) demonstrates that the emission level for these pollutants are equal to 75% of the applicable emission limits, the permittee is not required to conduct a performance test for the pollutant in response to a request by the Department to repeat a performance test or repeat the performance test within 60 days of a process change. The permittee may elect to skip conducting a performance test for the pollutant for the next 2-years. The permittee shall conduct a performance test for the pollutant during the third year and no more than 37-months following the previous performance test for the pollutant. For cadmium and lead, emissions shall be emitted at emission levels no greater than their respective emission levels equal to 75% of the applicable emission limit in Condition C.35. to qualify for less frequent testing under 60.2720(a)(3). {Permitting Note: The pollutants that contain a footnote “3” to Table 8 of Subpart DDDD (footnote 8 of Condition C.35) are Cd, D/F (toxic equivalency basis), HCl, and Pb. Pollutants that do not contain the footnote “3” are CO, D/F (total mass basis), Hg, NOx, PM, and SO2. The facility uses CEMS to monitor emissions of CO and NOx, and a PM CPMS to monitor emissions of PM, to demonstrate compliance with their respective BACT limits. Subpart DDDD does not require the use of CEMS to demonstrate compliance with the applicable emission limits for CO or NOx. For D/F (toxic equivalency basis), D/F (total mass basis), SO2, Hg, and HCl, performance tests for at least 2 consecutive years must show that emissions are at or below 75% of their respective emission limits in order for them to qualify for less frequent testing. For Cd and Pb, performance tests for both pollutants must show that emissions are at or below 75% of their emission limit for them to qualify for less frequent testing. Since the method of compliance for PM is PM CPMS, PM does not qualify for less frequent testing. If the facility chooses to use CEMS to demonstrate compliance with the Subpart DDDD limits for CO and NOx, performance tests required to certify the CEMS is required annually, and therefore do not qualify for less frequent testing. However, if the facility chooses to conduct stack testing to demonstrate compliance with the Subpart DDDD limits for CO and NOx, they qualify for less frequent testing as long as performance test for at least 2 years show that emissions are at or below 75% of their emission limit. Additionally, less frequent testing is not applicable if the facility wishes to establish new operating limits, or if the Department requests the facility to repeat a performance test, or if there is a process change (as defined in 40 CFR 60.2875). Finally, if conducting less frequent testing, and a subsequent performance test for the pollutant indicates emissions to be above 75% of the emission limit, the performance testing frequency changes back to annual, until that pollutant qualifies for less frequent testing again.} d. If the permittee is conducting less frequent testing for a pollutant as provided above and a subsequent performance test for the pollutant indicates that the DDDD unit does not meet the emission level specified American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 30 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System in paragraph (c) above, the permittee shall conduct annual performance tests for the pollutant according to the schedule specified in Condition C.45 a. until the permittee qualifies for less frequent testing for that pollutant. [Rule 62-204.800(9)(f), F.A.C., referencing 40 CFR 60.2720(a) and 60.2875] C.47. Required Monitoring Equipment. a. HCl. For waste-burning kilns not equipped with a wet scrubber or dry scrubber, in place of HCl testing with EPA Method 321 at 40 CFR 63, Appendix A, the permittee shall install, calibrate, maintain, and operate a CEMS for monitoring HCl emissions, as specified in 40 CFR 60.2710(j), discharged to the atmosphere and record the output of the system. b. PM. To demonstrate continuous compliance with the PM emissions limit, the facility may substitute use of either a PM CEMS or a PM CPMS for conducting the PM annual performance test and other CMS monitoring for PM compliance (e.g., bag leak detectors, ESP secondary power, PM scrubber pressure). c. NOx. To demonstrate continuous compliance with the NOx emissions limit, the facility may substitute use of a CEMS for the NOx annual performance test to demonstrate compliance with the NOx emissions limits and monitoring the charge rate, secondary chamber temperature and reagent flow for selective noncatalytic reduction, if applicable. d. Hg. Waste-burning kilns shall install, calibrate, maintain, and operate a mercury CMS as specified in rule 62-204.800(9)(f), F.A.C. [Rule 62-204.800(9)(f), F.A.C., referencing 40 CFR 60.2730(g-h) & (k) and 40 CFR 60.2710(j)] C.48. CEMS Data During Startup and Shutdown. “CEMS data during startup and shutdown”, is defined as: CEMS data collected during the periods of kiln operation that do not include normal operations. Startup means the time from when a shutdown kiln first begins firing fuel until it begins producing clinker. Startup begins when a shutdown kiln turns on the induced draft fan and begins firing fuel in the main burner. Startup ends when feed is being continuously introduced into the kiln for at least 120 minutes or when the feed rate exceeds 60 percent of the kiln design limitation rate, whichever occurs first. Shutdown means the cessation of kiln operation. Shutdown begins when feed to the kiln is halted and ends when continuous kiln rotation ceases. {Permitting Note: CEMS data during startup and shutdown, as defined above, are not corrected to 7% oxygen, and are measured at stack oxygen content. Also see Condition C.37} [Rule 62-204.800(9)(f), F.A.C., referencing 40 CFR 60.2875 and 60.2710] C.49. Control Equipment Inspections. If the permittee uses an air pollution control device to meet the emission limitations in DDDD, the permittee shall conduct an initial and annual inspection of the air pollution control device. The inspection shall include, at a minimum, the following: a. Inspect air pollution control device(s) for proper operation; and b. Develop a site-specific monitoring plan according to the requirements in Specific Condition C.50. This requirement also applies to the permittee if the permittee petitions the EPA Administrator for alternative monitoring parameters under 40 CFR 60.13(i). [Rule 62-204.800(9)(f), F.A.C., referencing 40 CFR 60.2710(k)] C.50. CMS Monitoring Plan. For each CMS required in 40 CFR 60.2710, the permittee shall develop and submit to the EPA Administrator for approval, a site-specific monitoring plan according to a.(1) through (6) of this condition: a. The permittee shall submit this site-specific monitoring plan at least 60 days before the permittee’s initial performance evaluation of the CMS: (1) Installation of the CMS sampling probe or other interface at a measurement location relative to each affected process unit such that the measurement is representative of control of the exhaust emissions (e.g., on or downstream of the last control device); American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 31 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System (2) Performance and equipment specifications for the sample interface, the pollutant concentration or parametric signal analyzer and the data collection and reduction systems; (3) Performance evaluation procedures and acceptance criteria (e.g., calibrations); (4) Ongoing operation and maintenance procedures in accordance with the general requirements of 40 CFR 60.11(d); (5) Ongoing data quality assurance procedures in accordance with the general requirements of 40 CFR 60.13; and (6) Ongoing recordkeeping and reporting procedures in accordance with the general requirements of 40 CFR 60.7(b), (c), (c)(1), (c)(4), (d), (e), (f) and (g). b. The permittee shall conduct a performance evaluation of each CMS in accordance with the site-specific monitoring plan. c. The permittee shall operate and maintain the CMS in continuous operation according to the site-specific monitoring plan. [Rule 62-204.800(9)(f), F.A.C., referencing 40 CFR 60.2710(l)] Operator Training and Qualifications C.51. Operator Training and Qualification Requirements. a. No CISWI unit can be operated unless a fully trained and qualified CISWI unit operator is accessible, either at the facility or can be at the facility within 1 hour. The trained and qualified CISWI unit operator may operate the CISWI unit directly or be the direct supervisor of one or more other plant personnel who operate the unit. If all qualified CISWI unit operators are temporarily not accessible, the permittee shall follow the procedures in §60.2665. b. Operator training and qualification must be obtained through a state-approved program or by completing the requirements included in paragraph c of this condition. c. Training must be obtained by completing an incinerator operator training course that includes, at a minimum, the three elements described below: (1) Training on the following eleven subjects: (a) Environmental concerns, including types of emissions; (b) Basic combustion principles, including products of combustion; (c) Operation of the specific type of incinerator to be used by the operator, including proper startup, waste charging, and shutdown procedures; (d) Combustion controls and monitoring; (e) Operation of air pollution control equipment and factors affecting performance (if applicable); (f) Inspection and maintenance of the incinerator and air pollution control devices; (g) Actions to prevent and correct malfunctions or to prevent conditions that may lead to malfunctions; (h) Bottom and fly ash characteristics and handling procedures; (i) Applicable federal, state, and local regulations, including Occupational Safety and Health Administration workplace standards; (j) Pollution prevention; and (k) Waste management practices. (2) An examination designed and administered by the instructor. (3) Written material covering the training course topics that can serve as reference material following completion of the course. d. The operator training course must be completed by the later of: (1) February 7, 2018; (2) Six months after CISWI unit startup; and (3) Six months after an employee assumes responsibility for operating the CISWI unit or assumes responsibility for supervising the operation of the CISWI unit. American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 32 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System e. To maintain qualification, the permittee must complete an annual review or refresher course covering, at a minimum, the following five topics: (1) Update of regulations; (2) Incinerator operation, including startup and shutdown procedures, waste charging, and ash handling; (3) Inspection and maintenance; (4) Prevention and correction of malfunctions or conditions that may lead to malfunction; and (5) Discussion of operating problems encountered by attendees. [Rule 62-204.800(9)(f), F.A.C., referencing 40 CFR 60.2635] Recordkeeping and Reporting Requirements C.52. Site-Specific Operator Training Documentation. a. Documentation shall be available at the facility and readily accessible for all CISWI unit operators that addresses the ten topics described in paragraphs a. (1) through (10) below. The permittee shall maintain this information and the training records required by paragraph c. of this condition in a manner that they can be readily accessed and are suitable for inspection upon request: (1) Summary of the applicable standards under Subpart DDDD; (2) Procedures for receiving, handling, and charging waste; (3) Incinerator startup, shutdown, and malfunction procedures; (4) Procedures for maintaining proper combustion air supply levels; (5) Procedures for operating the incinerator and associated air pollution control systems within the standards established under Subpart DDDD; (6) Monitoring procedures for demonstrating compliance with the incinerator operating limits; (7) Reporting and recordkeeping procedures; (8) The waste management plan required under 40 CFR 60.2620 through 60.2630; (9) Procedures for handling ash; and (10) A list of the wastes burned during the performance test. b. The permittee shall establish a program for reviewing the information listed in paragraph a. above, with each incinerator operator: (1) The initial review of the information listed in paragraph a. of this condition shall be conducted by the later of the following three dates: (a) February 7, 2018; (b) Six months after CISWI unit startup; and (c) Six months after being assigned to operate the CISWI unit. (2) Subsequent annual reviews of the information listed in paragraph a. above must be conducted no later than 12 months following the previous review c. The permittee shall also maintain the information specified below: (1) Records showing the names of CISWI unit operators who have completed review of the information in 40 CFR 60.2660(a) as required by 40 CFR 60.2660(b), including the date of the initial review and all subsequent annual reviews; (2) Records showing the names of the CISWI operators who have completed the operator training requirements under 40 CFR 60.2635, met the criteria for qualification under 40 CFR 60.2645, and maintained or renewed their qualification under 40 CFR 60.2650 or 60.2655. Records shall include documentation of training, the dates of the initial refresher training, and the dates of their qualification and all subsequent renewals of such qualifications; and (3) For each qualified operator, the phone and/or pager number at which they can be reached during operating hours. [Rule 62-204.800(9)(f), F.A.C., referencing 40 CFR 60.2660 and 60.2665] C.53. Records. The permittee shall maintain the items (as applicable) as specified below for a period of at least 5 years: American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 33 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System a. Calendar date of each record; b. Records of the data described below: (1) The CISWI unit charge dates, times, weights, and hourly charge rates; (2) For affected CISWI units that establish operating limits for controls other than wet scrubbers under Rule 62-204.800(9)(f), F.A.C., referencing §60.2675(d) through (g) or §60.2680, the permittee shall maintain data collected for all operating parameters used to determine compliance with the operating limits. (3) If a fabric filter is used to comply with the emission limitations, the permittee shall record the date, time, and duration of each alarm and the time corrective action was initiated and completed, and a brief description of the cause of the alarm and the corrective action taken. The permittee shall also record the percent of operating time during each 6-month period that the alarm sounds, calculated as specified in 40 CFR 60.2675(c), referenced by Rule 62-204.800(9)(f), F.A.C. c. Identification of calendar dates and times for which data show a deviation from operating limits established under 40 CFR 60.2675(d) through (g) or 40 CFR 60.2680, referenced by Rule 62- 204.800(9)(f), F.A.C., with a description of the deviations, reasons for such deviations, and a description of corrective actions taken. d. The results of the initial, annual, and any subsequent performance tests conducted to determine compliance with the emission limits and/or to establish operating limits, as applicable. Retain a copy of the complete test report including calculations. e. Records showing the names of CISWI unit operators who have completed review of the information in Condition C.52.a. as required by Condition C.52.b., including the date of the initial review and all subsequent annual reviews. f. Records showing the names of the CISWI operators who have completed the operator training requirements under 40 CFR 60.2635 (Condition C.51), met the criteria for qualification under 40 CFR 60.2645, and maintained or renewed their qualification under 40 CFR 60.2650 or 40 CFR 60.2655, all referenced by Rule 62-204.800(9)(f), F.A.C. Records must include documentation of training, the dates of the initial and refresher training, and the dates of their qualification and all subsequent renewals of such qualifications. g. For each qualified operator, the phone and/or pager number at which they can be reached during operating hours. h. Records of calibration of any monitoring devices as required under 40 CFR 60.2730, referenced by Rule 62-2024.800(9)(f), F.A.C. i. Equipment vendor specifications and related operation and maintenance requirements for the incinerator, emission controls, and monitoring equipment. j. The information listed in Condition C.52.a. k. On a daily basis, keep a log of the quantity of waste burned and the types of waste burned (always required). l. Maintain records of the annual air pollution control device inspections that are required for the kiln, any required maintenance and any repairs not completed within 10 days of an inspection or the timeframe established by the Department. m. For continuously monitored pollutants or parameters, the permittee shall document and keep a record of the following parameters measured using continuous monitoring systems: (1) All 1-hour average concentrations of SO2, NOx, CO, Hg, PM –CPMS, HCl DDDD limit emissions. The permittee shall indicate which data are CEMS data during startup and shutdown; (2) All 1-hour average percent oxygen concentrations. n. If the permittee chooses to stack test less frequently than annually, consistent with §60.2720(a) through (c), referenced by Rule 62-204.800(9)(f), F.A.C., the permittee shall keep annual records that document that the permittee’s emissions in the previous stack test(s) were less than 75 percent of the applicable American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 34 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System emission limit and document that there was no change in source operations including fuel composition and operation of air pollution control equipment that would cause emissions of the relevant pollutant to increase within the past year. o. Records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control and monitoring equipment. p. Records of all required maintenance performed on the air pollution control and monitoring equipment. q. Records of actions taken during periods of malfunction to minimize emissions in accordance with 40 CFR 60.11(d), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. r. For operating units that combust non-hazardous secondary materials that have been determined not to be solid waste pursuant to 40 CFR 241.3(b)(1), the permittee shall keep a record which documents how the secondary material meets each of the legitimacy criteria under §241.3(d)(1). If the unit combusts a fuel that has been processed from a discarded non-hazardous secondary material pursuant to §241.3(b)(4), the permittee shall keep records as to how the operations that produced the fuel satisfies the definition of processing in 40 CFR 241.2 and each of the legitimacy criteria in 40 CFR 241.3(d)(1). If the fuel received a non-waste determination pursuant to the petition process submitted under 40 CFR 241.3(c), the permittee shall keep a record that documents how the fuel satisfies the requirements of the petition process. For operating units that combust non-hazardous secondary materials as fuel pursuant to 40 CFR 241.4, the permittee shall keep records documenting that the material is a listed non-waste under 40 CFR 241.4(a). Link to 40 CFR 241. [Rule 62-204.800(9)(f), F.A.C., referencing 40 CFR 60.2740 (a), (b)(1)(5-6), (e-m), (n)(2-4)(6)(8-9), (q-u)] C.54. Initial Test Report. The initial test report shall be submitted to EPA electronically using the EPA Electronic Reporting Tool (ERT) within 60-days following the initial performance test including the information specified in Table 5 to 40 CFR 60, Subpart DDDD. [Rule 62-204.800(9)(f) referencing 40 CFR 60.2760 and Table 5 of NSPS Subpart DDDD] C.55. EPA Annual Report. The annual report shall be submitted to EPA electronically using the EPA ERT no later than 12 months following the submission of the initial test report and subsequent reports including the information specified Table 5 to 40 CFR 60, Subpart DDDD. [Rule 62-204.800(9)(f) F.A.C. referencing 40 CFR 60.2767, 60.2770 and Table 5 of NSPS Subpart DDDD] C.56. Semi-Annual Deviation Report. The emissions limitation or operating limit deviation report shall be submitted to EPA electronically using the EPA ERT by August 1st of that year for data collected during the first half of the calendar year and by February 1st of the following year for data collected during the second half of the calendar year. The deviation report shall include the information specified in Table 5 in NSPS Subpart DDDD. {Permitting Note: The information in this report shall be included in the semi-annual monitoring report required in Condition FW9. [Rule 62-204.800(9)(f), F.A.C. referencing 40 CFR 60.2775, 60.2780 and Table 5 of NSPS Subpart DDDD] C.57. Report Submittal. a. The permittee shall submit initial, annual, deviation reports, results of each performance test and CEMS performance evaluation electronically on or before the submittal due dates specified in Conditions C.54 - C.56. b. The Reports shall be submitted to the EPA via the Compliance and Emissions Data Reporting Interface (CEDRI) (CEDRI can be accessed through the EPA's Central Data Exchange (CDX) (https://cdx.epa.gov/). Use the appropriate electronic report in CEDRI for this subpart or an alternate electronic file format consistent with the extensible markup language (XML) schema listed on the CEDRI Web site (https://www.epa.gov/chief), once the XML schema is available. If the reporting form specific to Subpart DDDD, is not available in CEDRI at the time that the report is due, submit the report to EPA Region IV Director at Air, Pesticides and Toxics Management Division, U.S. Environmental Protection Agency, 61 Forsyth St. SW., Suite 9T43, Atlanta, Georgia 30303-8960. Once the form has been available American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 35 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System in CEDRI for 90 calendar days, the permittee shall begin submitting all subsequent reports via CEDRI. The reports must be submitted by the deadlines specified in Conditions C.54 - C.56, regardless of the method in which the report is submitted. c. All documents related to compliance activities such as reports, tests, and notifications (as specified in Conditions C.54 - C.56) submitted in a manner outlined in paragraph b. of this condition, shall also be submitted to the Compliance Authority listed on the cover page of this permit. [Rules 62-4.160(15)., 62-213.440(1)(b)., & 62-204.800(9)(f), F.A.C., referencing 40 CFR 60.2795] Conditions C.58 to C.71 apply only if the kiln unit is subject to LLL. Emissions Standards C.58. Emissions Standards - Emissions from the pyroprocessing system (including the air heater) main stack shall not exceed the emissions standards shown in the following table. Unless otherwise noted (refer to Condition C.18.), emission limitations apply during all periods of operation (including startup, shutdown, and malfunction) Compliance Pollutant1 Emission Limit2.4 Averaging Time Basis Method3 2.67 lb/ton of clinker CO 30-day rolling CEMS BACT 362.5 lb/hr 1.8 lb/ton of clinker NOX 30-day rolling CEMS BACT 243.8 lb/hr 0.185 lb/ton of clinker Method 6 or 6C, SO2 Three, 1-hour runs upon permit BACT 25.0 lb/hr renewal 0.11 lb/ton of clinker VOC 5 30-day block CEMS BACT 15.0 lb/hr 30-kiln operating THC 24 ppmvd (as propane) @7% O2 CEMS7 LLL 10 10 day rolling 0.153 lb/ton of clinker ST, Annual Three 1-hr runs Method 5, RM-up BACT 19.13 lb/hr 10% Opacity 6-minute block CPMS 8 BACT 8 PM/PM10 ST, Annual 30-kiln operating Method 5, Raw 9 day rolling of Equation 1 of §63.1343(b)(2) Mill-up and Raw LLL 10 CPMS Mill down & PM monitoring5 CPMS 0.20 ng/dscm (TEQ) @ 7% O2 (if ST, 30-month o T > 400 F) or Method 23 & D/F11 Three 3-hr runs LLL 11 0.40 ng/dscm (TEQ) @ 7% O2 (if Temperature T ≤ 400 oF) Monitor American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 36 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System Compliance Pollutant1 Emission Limit2.4 Averaging Time Basis Method3 55 lb/MM tons clinker (effective 30-kiln operating Hg CEMS 12 10 on and after 09/09/16)4 day rolling LLL 4 30- kiln operating HCl or SO2 HCl 3 ppmvd @ 7% O2 10 day rolling CEMS13 LLL 1. Pollutant: PM = particulate matter; PM10 = PM with a mean diameter of 10 micron or less; SO2 = sulfur dioxide; NOx = nitrogen oxides; CO = carbon monoxide; VOC = volatile organic compounds; VE = Visible Emissions; D/F = dioxin and furans; Hg = mercury; THC = total hydrocarbons; HCl = hydrogen chloride. 2. Units of emission limits: lb/ton-f = pounds per ton of preheater feed; lb/hr = pounds per hour; lb/ton-c = pounds per ton of clinker; lb/MM tons clinker = pounds per million tons of clinker; ng/dscm TEQ = nanograms per dry standard cubic meter, toxic equivalents; ppmvd = parts per million volume dry. 3. Compliance Method: ST = annual or periodic stack test; CEMS – continuous emission monitor system; SBT = sorbent trap CEMS; CPMS = continuous parameter monitoring system. Except as provided in 40 CFR 63.1348(b), performance tests are required at regular intervals for affected sources that are subject to a dioxin, organic HAP or HCl emissions limit. Performance tests required every 30 months must be completed no more than 31 calendar months after the previous performance test except where that specific pollutant is monitored using CEMS; performance tests required every 12 months must be completed no more than 13 calendar months after the previous performance test. 4. Oxygen monitoring is required for compliance, all concentration limits require correction to 7% O2. 5. Compliance shall be demonstrated by THC CEMS. VOC emissions shall be measured as total hydrocarbons (THC) and expressed as “propane” for the mass emissions rate. Permittee can request to demonstrate by a Method 25A test that a fraction of THC is methane if exceedance of VOC limit is indicated by THC CEMS. 6. See also Subsection G. (EU007) for details on required coal mill testing and monitoring. 7. THC monitoring is a combination of kiln CEMS and coal mill testing per 40 CFR 63.1348(b)(6)(ii). Permittee can alternatively comply by testing and monitoring for total organic HAP monitoring in accordance with the requirements of 40 CFR 63.1350(j). 8. For purposes of BACT compliance, all PM emitted from the baghouse exhaust is assumed to be PM10. a. The PM limit in LLL are more stringent than the BACT PM/PM10 limits. Therefore, compliance with the LLL PM limits is considered compliance with the BACT PM/PM10 limits. b. The BACT requirements do not waive or vary any applicable LLL monitoring or record keeping requirements. 9. Existing kilns that combine the clinker cooler exhaust and coal mill exhaust with the kiln exhaust, and send the combined exhaust to the PM control device (CPMS) as a single stream may meet an alternative PM emissions limit calculated using Equation 1 of §63.1343(b)(2): PMalt = (.0060 x 1.65)(Qk + Qc + Qcm)/7000 Where: PMalt = Alternative PM emission limit for commingled sources. 0.006 = The PM exhaust concentration (gr/dscf) equivalent to 0.070 lb per ton clinker where clinker cooler and kiln exhaust gas are not combined. 1.65 = The conversion factor of ton feed per ton clinker. Qk = The exhaust flow of the kiln (dscf/ton feed). Qc = The exhaust flow of the clinker cooler (dscf/ton feed). Qcm = The exhaust flow of the coal mill (dscf/ton feed). 7000 = The conversion factor for grains (gr) per lb. 10. Because the kiln system exhaust gas partially vents through the coal mill (EU007) stack, compliance testing for LLL pollutants of PM, THC, Hg, and HCl requires testing of kiln and coal mill. The combination of coal mill and kiln emissions determines compliance per 40 CFR 63.1348(a)(7)(ii). (The kiln partially exhausts through the coal mill stack, but the coal mill exhaust does not exhaust to the kiln stack.) PM emissions from the kiln and coal mill stacks must be simultaneously tested and the results are then combined using Eqn. 1 per 40 CFR 63.1343(b)(2) American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 37 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System Compliance Pollutant1 Emission Limit2.4 Averaging Time Basis Method3 (Item 9 above). PM testing may be required more frequently than annual if the PM CPMS indicates high readings. See condition G.3 [40 CFR 63.1349(a) and (b)(1), and 40 CFR 63.1350(b)(1)] for details on coal mill monitoring and PM CPMS monitoring with PM testing requirements. PM10 compliance can be demonstrated by PM testing. 11. Dioxin/furans shall not exceed 0.20 ng/dscm (TEQ) @ 7% oxygen when the average of the performance test run temperatures at the inlet to the particulate matter control device is greater than 204° C (400° F) and shall not exceed 0.40 ng/dscm (TEQ) @ 7% oxygen when the average of the performance test run temperatures at the inlet to the particulate matter control device is 204° C (400° F) or less. 12. Hg monitoring is combination of kiln CMS/sorbent trap and coal mill testing per 40 CFR 63.1348(b)(7) and 63.1350(k). 13. HCl monitoring is combination of kiln CMS and coal mill testing per 40 CFR63.1348(b)(8) and 63.1349(b)(6). 14. NESHAP pollutants compliance by CMS shall exclude all data during periods of startup and shutdown per 40 CFR 63.1343(a). Refer to Condition C.66 for operation requirements during periods of startup and shutdown {Permitting Note - In combination with the annual clinker production limitation of 1,186,250 tons per year, the above (most stringent) emissions standards effectively limit annual potential emissions from this unit to: • 1,584 tons/year of CO; • 1,068 tons/year of NOX; • 90.7 tons/year of PM/PM10 (LLL Limit is most stringent) • 110 tons/year of SO2; and; • 66 tons/year of VOC.} [Rules 62-204.800(11), 62-210. 200 (Definition of Potential to Emit), 62-212.400 (Best Available Control Technology), F.A.C.; Appendix BD - Final BACT Determination and Emission Standards; NESHAP 40 CFR 63 Subpart LLL, Permit No. 1190042-001-AC (PSD-FL-361) and 1190042-009-AC (PSD-FL-361F)] Excess Emissions C.59. LLL Allowable Data Exclusions: LLL compliance data exclusions shall only abide by the following definitions as defined in LLL: a. Startup means the time from when a shutdown kiln first begins firing fuel until it begins producing clinker. Startup begins when a shutdown kiln turns on the induced draft fan and begins firing fuel in the main burner. Startup ends when feed is being continuously introduced into the kiln for at least 120 minutes or when the feed rate exceeds 60 percent of the kiln design limitation rate, whichever occurs first. b. Shutdown means the cessation of kiln operation. Shutdown begins when feed to the kiln is halted and ends when continuous kiln rotation ceases. [40 CFR 63.1341] Monitoring Requirements C.60. Baghouse Temperature Monitor - A continuous temperature monitor shall be calibrated, operated, and maintained at the inlet to the baghouse for the kiln system exhaust in accordance with the D/F monitoring requirements of 40 CFR 63.1350(g). [Rule 62-204.800(11), F.A.C.; NESHAP 40 CFR 63 Subpart LLL 40 CFR 63.1350; Permit No.1190042-001-AC (PSD-FL-361)] C.61. Continuous Flow Rate Monitoring - The permittee shall operate, calibrate, and maintain instruments for continuously measuring and recording the pollutant per mass flow rate to the atmosphere from sources subject to an emissions limitation that have a pounds per ton of clinker basis (i.e., the pyroprocessing system). The flow monitor shall be certified pursuant to 40 CFR 60, Appendix F. [Rule 62-204.800(11), F.A.C.; 40 CFR 63.1350(n), Permit No.1190042-001-AC (PSD-FL-361)] C.62. Clinker Production Monitoring Requirements: The permittee must determine hourly clinker production by the following: American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 38 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System a. Determine hourly clinker production rate by one of two methods: i. Install, calibrate, maintain, and operate a permanent weigh scale system to measure and record weight rates in tons-mass per hour of the amount of clinker produced. The system of measuring hourly clinker production must be maintained within ±5 percent accuracy, or ii. Install, calibrate, maintain, and operate a permanent weigh scale system to measure and record weight rates in tons-mass per hour of the amount of feed to the kiln. The system of measuring feed must be maintained within ±5 percent accuracy. Calculate your hourly clinker production rate using a kiln-specific feed to clinker ratio based on reconciled clinker production determined for accounting purposes and recorded feed rates. Update this ratio monthly. Note that if this ratio changes at clinker reconciliation, the permittee must use the new ratio going forward, but the permittee does not have to retroactively change clinker production rates previously estimated. b. Determine, record, and maintain a record of the accuracy of the system of measuring hourly clinker production (or feed mass flow if applicable) before initial use (for new sources) or by the effective compliance date of LLL (for existing sources). During each quarter of source operation, the permittee must determine, record, and maintain a record of the ongoing accuracy of the system of measuring hourly clinker production (or feed mass flow). c. If the permittee measures clinker production directly, record the daily clinker production rates; if the permittee measures the kiln feed rates and calculate clinker production, record the hourly kiln feed and clinker production rates. d. Develop an emissions monitoring plan in accordance with paragraphs (p)(1) through (p)(4) of 40 CFR 63.1350. [40 CFR 63.1350(d)] C.63. Operation and Maintenance Plan Requirements: The permittee must prepare, for each affected source subject to the provisions of LLL, a written operations and maintenance plan. The plan must be submitted to the Compliance Authority and must include the following information: a. Procedures for proper operation and maintenance of the affected source and air pollution control devices in order to meet the emissions limits and operating limits, including fugitive dust control measures for open clinker piles of 40 CFR 63.1343, 63.1345, and 63.1346. The permittee’s operations and maintenance plan must address periods of startup and shutdown. b. Corrective actions to be taken when required by paragraph 40 CFR 63.1350(f)(3); c. Procedures to be used during an inspection of the components of the combustion system of each kiln and each in-line kiln raw mill located at the facility at least once per year. Failure to comply with any provision of the operations and maintenance plan developed in accordance with this section is a violation of the standard. [40 CFR 63.1347] {Permitting Note - The permittee has submitted an operation and maintenance plan in accordance with this Condition. Refer to Appendix OM - Operation and Maintenance Plan} C.64. Operation and Maintenance (O&M) and Startup, Shutdown & Malfunction (SSM) Plans - The permittee shall operate, maintain and correct any malfunctions to emission units, monitoring systems, and control equipment in accordance with the attached Operation and Maintenance (O&M) and Startup, Shutdown & Malfunction (SSM) Plans (Appendix OM - Operation and Maintenance Plan). [40 CFR 63.1347] C.65. PM CPMS Monitoring Requirements a. The permittee has conducted an initial performance test using Method 5 or Method 5I to establish the PM operating parameter limits. The permittee shall use the PM CPMS to demonstrate continuous compliance with this established operating limit. b. The permittee shall repeat the Method 5 or Method 5I performance test annually and reassess and adjust the CPMS site-specific operating limit in accordance with the results of the performance test using the procedures in 40 CFR 63.1349(b)(1) (i) through (vi) of LLL. American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 39 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System c. The permittee shall repeat the Method 5 or Method 5I test if the analytical range of the PM CPMS instrument is changed, or if the instrument itself is replaced, or any principal analytical component of the instrument that would alter the relationship of output signal to in-stack PM concentration is replaced. To determine continuous compliance, the permittee shall use the PM CPMS output data for all periods when the process is operating and the PM CPMS is not out-of-control. The permittee shall demonstrate continuous compliance by using all quality-assured hourly average data collected by the PM CPMS for all operating hours to calculate the arithmetic average operating parameter in units of the operating limit on a 30 operating day rolling average basis, updated at the end of each new kiln operating day. If the 30 operating day PM CPMS average value is higher than the established operating parameter limit, the permittee shall: d. Within 48 hours of the exceedance, visually inspect the air pollution control device; e. If inspection of the air pollution control device identifies the cause of the exceedance, take corrective action as soon as possible and return the PM CPMS measurement to within the established value; and, f. Within 30 days of the exceedance or at the time of the annual compliance test, whichever comes first, conduct a PM emissions compliance test to determine compliance with the PM emissions limit. Within 45 days verify or re-establish the PM CPMS operating limit. PM CPMS exceedances leading to more than four required performance tests in a 12-month process operating period (rolling monthly) constitute a presumptive violation of 40 CFR 63.1349 and 1350. [Rule 62-204.800(11), F.A.C., 40 CFR 63.1349 and 63.1350(b)] C.66. CEMS Certification Requirements - a. THC CEMS (also as a surrogate for VOCs monitoring required by LLL) - The total hydrocarbon continuous emissions monitoring system (THC CEMS) (which is also used for VOC BACT monitoring) as VOC is measured as total hydrocarbons) shall meet the requirements of 40 CFR 63.1349 and 63.1350. b. Hg CEMS/sorbent trap (LLL) - The mercury continuous emissions monitoring system (Hg-CEMS) shall meet the requirements in Performance Specification 12A (PS-12A) or 12B. The owner or operator shall meet the requirements of 40 CFR 63.1349 and 63.1350. c. PM CPMS (LLL) - The PM CPMS shall meet the requirements of 40 CFR 63.1350(b). d. HCl CEMS (LLL)- The HCl CEMS shall meet the requirements of 40 CFR 63.1349 and 63.1350. {Permtting Note - Upon approval from the Permitting Authority through modification of this permit, VOC monitoring can exclude methane emissions from THC CEMS data. Such exclusion is not approved at this time}. [40 CFR 63.1349 and 63.1350; Permit No. 1190042-001-AC (PSD-FL-361)] C.67. Operations During NESHAP Startup and Shutdown - During periods of startup and shutdown as defined in Condition C.59 and 40 CFR 63.1341, the permittee shall meet the following requirements: a. During startup you must use any one or combination of the following clean fuels: natural gas, synthetic natural gas, propane, distillate oil, synthesis gas (syngas), and ultra-low sulfur diesel (ULSD) until the kiln reaches a temperature of 1,200 degrees Fahrenheit. b. Combustion of the primary kiln fuel (i.e., coal), may commence once the kiln temperature reaches 1,200 degrees Fahrenheit. c. Alternative fuels shall only be fired after the kiln has achieved normal operation, temperatures and production, that is, not during startup. (See Condition H.7) d. All dry sorbent and activated carbon systems that control hazardous air pollutants must be turned on and be properly operating at the time the gas stream at the inlet to the baghouse reaches 300 degrees Fahrenheit (five-minute average) during startup. Temperature of the gas stream is to be measured at the inlet of the baghouse every minute. Such injection systems can be turned off during shutdown. American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 40 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection C. Emissions Unit No. 003, Pyroprocessing System Particulate control and all remaining devices that control hazardous air pollutants should be operational during startup and shutdown. e. Keep records of the date, time and duration of each startup or shutdown period for any affected source that is subject to a standard during startup or shutdown that differs from the standard applicable at other times, and the quantity of feed and fuel used during the startup or shutdown period. [40 CFR 63.1346(g) and Kiln Operation and Maintenance Plan (Appendix OM)] Testing and Compliance Requirements C.68. Annual PM Compliance Tests Required. During each calendar year (January 1st to December 31st), this emission unit shall be tested to demonstrate compliance with the emissions standards for PM. The permittee shall simultaneously test the kiln and coal mill stacks to determine an emissions limit per 40 CFR 63.1343(b)2 and then set the PM CPMS 30-kiln operating day limit using 63.1349(b)1. Coal Mill emissions must be accounted for by 40 CFR 63.1349(b)(1)(viii). See also Subsection G (EU-007). [Rules 62-297.310(8)(a) and (b), F.A.C.; Permit No.1190042-001-AC (PSD-FL-361); 40 CFR 63 Subpart LLL] C.69. Continuous Compliance - For purposes of Subpart LLL continuous compliance with the PM, Hg, and HCl standards of 40 CFR 63.1343 shall be demonstrated using data collected from PM, Hg, and HCl CEMS/CPMS in accordance with 40 CFR 63.1348(b), and 40 CFR 63.1350(b), (k) & (l). Coal mill emissions must be accounted for by 40 CFR 63.1349(b)(4)(iii). See also Subsection G. [40 CFR 63.1348(b), 63.1350(b), (k), (l), and 63.1349(b)(4)(iii)] C.70. D/F Compliance Testing - D/F tests shall be conducted in accordance with the provisions of 40 CFR 63.1348(a)(3) and 63.1349(b)(3). Frequency of testing shall be in accordance with the requirements of 40 CFR 63.1348(c) and 63.1349(c) (i.e., every 30 months, or upon making a change in operations that may adversely affect compliance with the standard (see Specific Condition C.71). [Rules 62-297.310(8)(a) and (b), F.A.C.; 40 CFR 60.8; 40 CFR 63.1348 and 1349(b), Permit No.1190042-001-AC (PSD-FL-361)] C.71. Supplemental Dioxin/Furan and PM/PM10 Compliance Tests - The owner or operator shall notify the Compliance Authority prior to initiating any significant change in the feed or fuel used in the most recent compliant performance test for dioxin/furan or PM/PM10. For purposes of this condition, significant means any of the following: a. a physical or chemical change in the feed or fuel; b. the use of a raw material not previously used; c. a change in the LOI of the coal ash outside the normal range of monitored parameters; d. a change between non-beneficiated coal ash and beneficiated coal ash. Based on the information provided, the Compliance Authority will determine if performance testing pursuant to 40 CFR 63.1349 will be required for the new feed or fuel. A significant change shall not include switching to a feed/fuel mix for which the permittee already tested in compliance with the dioxin/furan and PM/PM10 emission limits. [Permit No.1190042-001-AC (PSD-FL-361)] Table of Contents American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 41 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection D. Emissions Unit No. 004, Clinker and Additives Storage and Handling The specific conditions in this section apply to the following emissions unit: EU No. Brief Description 004 Clinker and Additives Storage and Handling This emissions unit consists of clinker handling from clinker cooler to clinker silo discharge, as well as, clinker and additive (limestone, gypsum and other materials) handling from storage to the finish mill. The following emissions points (EP) in the raw materials conveying, storage, and processing are controlled by fabric filter baghouses. Baghouse Emissions Point (EP) Description Baghouse Description / EP ID L-03 Clinker Cooler Discharge CAMCORP Model 15TR12x30 baghouse with design exhaust air flow rate of 3,000 acfm L-06 Clinker Transfer to Clinker Silo #1 CAMCORP Model 8TR12x64 baghouse with design exhaust air flow rate of 6,500 acfm M-08 Clinker Transfer to Clinker Silo #2 CAMCORP Model 6TR12x42 baghouse with design exhaust air flow rate of 4,000 acfm DC-1 Clinker Transfer from Clinker Silo #1 four filter baghouse with design exhaust air flow rate of 353 acfm DC-2 Clinker Transfer from Clinker Silo # 2 four filter baghouse with design exhaust air flow rate of 353 acfm D.1. Baghouse Controls - Each emissions point (EP) identified above for the clinker and additives storage and handling operations shall be controlled by a baghouse system. Each required baghouse shall be designed, operated, and maintained to achieve a PM emission limit of 0.01 grains/dscf and a PM10 emission limit of 0.007 grains/dscf. [Rule 62-212.400 (Best Available Control Technology), F.A.C.; Appendix BD - Final BACT Determination and Emission Standards; Permit No.1190042-001-AC (PSD-FL-361)] Emission Limitations and Standards D.2. Visible Emissions (VE) Limitations - Visible emissions shall not exceed the following limits. a. Visible emissions are limited to 5% opacity from each of the emissions points (EP) shown in the EP table above and controlled by a baghouse. b. Visible emissions are limited to 10% opacity from any other emissions point associated with this emissions unit and not controlled by a baghouse. {The baghouses are designed to control PM emissions to 0.01 grains/dry standard cubic foot (gr/dscf) and PM10 emissions to 0.007 gr/dscf. The 5% opacity limitation is consistent with this design and provides reasonable assurance that annual emissions of PM/PM10 for all emission points in this emission unit system will be less than 4 TPY. Exceedance of the 5% opacity limit shall be deemed an exceedance of this permit condition and not necessarily an exceedance of the 10% opacity VE limitations given in NSPS 40 CFR 60 Subpart F or NESHAP 40 CFR 63 Subpart LLL.} [Rules 62-204.800(8) and (11), and 62-212.400 (Best Available Control Technology (BACT)), F.A.C.; Appendix BD – Final BACT Determination and Emission Standards; NSPS Subpart F 40 CFR 60.62(c); NESHAP Subpart LLL 40 CFR 63.1345; Permit No. 1190042-001-AC (PSD-FL-361)] Monitoring of Operations D.3. Opacity Monitoring Requirements - Each affected emissions point (EP) subject to an opacity standard shall be periodically monitored using the procedures described in paragraphs “a” through “g” of this section to ensure compliance with the requirements of Specific Condition No. D.2.b. American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 42 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection D. Emissions Unit No. 004, Clinker and Additives Storage and Handling a. You must conduct a monthly 10-minute visible emissions test of each affected source in accordance with Method 22 of 40 CFR 60, Appendix A. The performance test must be conducted while the affected source is in operation. b. If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner or operator may decrease the frequency of performance testing from monthly to semi- annually for that affected source. If visible emissions are observed during any semi-annual test, you must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. c. If no visible emissions are observed during the semi-annual test for any affected source, you may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner or operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. d. If visible emissions are observed during any Method 22 performance test, you must conduct five 6-minute averages of opacity in accordance with Method 9 in accordance with 40 CFR 60, Appendix A. The Method 9 performance test, must begin within 1 hour of any observation of visible emissions. e. The requirement to conduct Method 22 visible emissions monitoring under this paragraph does not apply to any totally enclosed conveying system transfer point, regardless of the location of the transfer point. “Totally enclosed conveying system transfer point” must mean a conveying system transfer point that is enclosed on all sides, top, and bottom. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. f. If any partially enclosed or unenclosed conveying system transfer point is located in a building, you must conduct a Method 22, according to the requirements of paragraphs (a) through (d) of this section for each such conveying system transfer point located within the building, or for the building itself, according to 63.1350(f) (f)(1)(vii). g. If visible emissions from a building are monitored, the requirements of paragraphs (a) through (d) of this section apply to the monitoring of the building, and you must test visible emissions from each side, roof, and vent of the building for at least 10 minutes. [Rule 62-204.800(11), F.A.C., 40 CFR 63.1347, 40 CFR 63.1350(f), Permit No.1190042-001-AC (PSD-FL- 361)] Test Methods and Procedures D.4. Annual Compliance Tests Required. During each calendar year (January 1st to December 31st), the baghouse exhaust vents for the emission points (EP) shown in the EP table above shall each be tested for visible emissions. [Rule 62-297.310(8), F.A.C.] D.5. Test Methods. When required, tests shall be performed in accordance with the following reference methods Method Description of Method and Comments 9 Visual Determination of the Opacity of Emissions from Stationary Sources Visual Determination of Fugitive Emissions From Material Sources (for opacity periodic 22 monitoring) The above methods are described in 40 CFR 60, Appendix A, and adopted by reference in Rule 62-204.800, F.A.C. No other methods may be used unless prior written approval is received from the Department. The above methods are described in 40 CFR 60, Appendix A, and adopted by reference in Rule 62-204.800, F.A.C. No other methods may be used unless prior written approval is received from the Department. [Rules 62- 297.401, and 62-204.800(11) F.A.C.; 40 CFR 63.1350(f); Permit No.1190042-001-AC (PSD-FL-361)] American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 43 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection D. Emissions Unit No. 004, Clinker and Additives Storage and Handling D.6. Common Testing Requirements. Unless otherwise specified, tests shall be conducted in accordance with the requirements and procedures specified in Appendix TR, Facility-Wide Testing Requirements, of this permit. [Rule 62-297.310, F.A.C.] Table of Contents American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 44 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection E. Emissions Unit No. 005, Finish Mill The specific conditions in this section apply to the following emissions unit: EU No. Brief Description 005 Finish Mill (Cement Grinding) This emissions unit consists of a cement finish (grinding) mill in a closed circuit with a high efficiency air separator and cyclones capable of processing approximately 159 tons per hour of cement. Other equipment includes associated enclosed conveyors, bucket elevators, and belts. The following emissions points (EP) in the finish mill/cement grinding process are controlled by fabric filter baghouses. Baghouse/ Emissions Point (EP) Description Baghouse Description EP ID N-93 Finish Mill Air Separator CAMCORP Model 110TR12x1760 baghouse with design exhaust air flow rate of 150,000 acfm N-94 Finish Mill Sweep (Sepol vent) CAMCORP Model 29TR12x464 baghouse with design exhaust air flow rate of 40,000 acfm E.1. Baghouse Controls - Each emissions point (EP) identified above for the finish mill grinding operations shall be controlled by a baghouse system. Each required baghouse shall be designed, operated, and maintained to achieve a PM design specification of 0.01 grains/dscf and a PM10 design specification of 0.007 grains/dscf. [Rule 62-212.400 (Best Available Control Technology), F.A.C.; Appendix BD - Final BACT Determination and Emission Standards; Permit No.1190042-001-AC (PSD-FL-361)] Emission Limitations and Standards E.2. Particulate Matter (PM/PM10) Standard for Finish Mill Air Separator (EP ID N-93) - Particulate matter (PM/PM10) emissions from the finish mill air separator baghouse (Emission Point (EP) ID N-93) shall not exceed 0.007 grains per dscf of exhaust as determined by EPA Method 5. All PM emitted from the baghouse exhaust is assumed to be PM10. The BACT requirements do not waive or vary any applicable NESHAP monitoring or record keeping requirements. [Rules 62-212.400 (Best Available Control Technology), F.A.C.; Appendix BD – Final BACT Determination and Emission Standards; Permit No.1190042-001-AC (PSD-FL- 361) E.3. Visible Emissions (VE) Limitations - Visible emissions from the finish mill air separator baghouse (EP ID N-93) and from the finish mill sweep baghouse (EP ID N-94) are limited to 5% opacity. [Rule 62- 212.400(BACT), F.A.C.; Appendix BD – Final BACT Determination and Emission Standards; Permit No.1190042-001-AC (PSD-FL-361)] {Permitting Note: The above limits are more stringent and suffice for LLL VE limit pursuant to 40 CFR 63.1345} Monitoring of Operations E.4. Opacity Monitoring Requirements -Emissions Point (EP) ID N-93 and EP ID N-94 shall be periodically monitored using the procedures described in paragraphs “a” through “g” of this section to ensure compliance with the requirements of Specific Condition Nos. E.3. a. You must conduct a monthly 10-minute visible emissions test of each affected source in accordance with Method 22 of 40 CFR 60, Appendix A. The performance test must be conducted while the affected source is in operation. b. If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner or operator may decrease the frequency of performance testing from monthly to semi- annually for that affected source. If visible emissions are observed during any semi-annual test, American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 45 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection E. Emissions Unit No. 005, Finish Mill you must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. c. If no visible emissions are observed during the semi-annual test for any affected source, you may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner or operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. d. If visible emissions are observed during any Method 22 performance test, you must conduct five 6-minute averages of opacity in accordance with Method 9 in accordance with 40 CFR 60, Appendix A. The Method 9 performance test, must begin within 1 hour of any observation of visible emissions. e. The requirement to conduct Method 22 visible emissions monitoring under this paragraph does not apply to any totally enclosed conveying system transfer point, regardless of the location of the transfer point. “Totally enclosed conveying system transfer point” must mean a conveying system transfer point that is enclosed on all sides, top, and bottom. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. f. If any partially enclosed or unenclosed conveying system transfer point is located in a building, you must conduct a Method 22, according to the requirements of paragraphs (a) through (d) of this section for each such conveying system transfer point located within the building, or for the building itself, according 63.1350(f) (f)(1)(vii). [Rule 62-204.800(11), F.A.C., 40 CFR 63.1347, 40 CFR 63 1350(f), Permit No.1190042-001-AC (PSD-FL- 361)] Test Methods and Procedures E.5. Annual Compliance Tests Required. During each calendar year (January 1st to December 31st), the baghouse exhaust vents for the emission points (EP) shown in the EP table above shall each be tested to demonstrate compliance with the visible emissions standards of Specific Condition Nos. E.3. [Rule 62- 297.310(7), F.A.C.; Permit No.1190042-001-AC (PSD-FL-361)]. E.6. Compliance Tests Prior To Renewal. The exhaust vent for the finish mill air separator baghouse (EP ID N-93) shall be tested for particulate matter (PM) emissions to demonstrate compliance with the PM emission limitation of Specific Condition No. E.2 prior to submittal of a permit renewal application. [Rule 62- 297.310(7), F.A.C.; Permit No.1190042-001-AC (PSD-FL-361)] {Permitting Note: This test which is only required once during the term of a permit prior to obtaining a renewed permit should be performed roughly five years from the previous test.} E.7. Test Methods. When required, tests shall be performed in accordance with the following reference methods: Method Description of Method and Comments 1-4 Traverse Points, Velocity and Flow Rate, Gas Analysis, and Moisture Content Method for Determining Particulate Matter Emissions The minimum sample volume shall 5 be 30 dry standard cubic feet 9 Visual Determination of the Opacity of Emissions from Stationary Sources Visual Determination of Fugitive Emissions From Material Sources (for opacity periodic 22 monitoring) American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 46 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection E. Emissions Unit No. 005, Finish Mill The above methods are described in 40 CFR 60, Appendix A, and adopted by reference in Rule 62-204.800, F.A.C. No other methods may be used unless prior written approval is received from the Department. [Rule 62-297.401, F.A.C., 40 CFR 63.1350; Permit No.1190042-001-AC (PSD-FL-361)] E.8. Common Testing Requirements. Unless otherwise specified, tests shall be conducted in accordance with the requirements and procedures specified in Appendix TR, Facility-Wide Testing Requirements, of this permit. [Rule 62-297.310, F.A.C.] Table of Contents American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 47 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection F. Emissions Unit No. 006, Cement Handling, Storage, Packing, and Loadout The specific conditions in this section apply to the following emissions unit: EU No. Brief Description 006 Cement Handling, Storage, Packing, and Loadout This emission unit includes cement conveyance to silos, cement silos, loadout to trucks from silos, and cement bagging operations. Equipment includes two concrete cement silos with rotary shut-off valves, flow control valve, and airslides. The cement bagging operation includes a screen, surge hopper, bucket elevator and packer. Operation is estimated to be nominally 500 tons per hour of cement to truck loadout and/or bagging operation. The following emissions points (EP) in the Cement Handling, Storage, Packing, and Loadout processes are controlled by fabric filter baghouses. Baghouse/ Emissions Point (EP) Description Baghouse Description EP ID N-91 Cement Transfer from Finish Mill CAMCORP Model 9TR12x81 baghouse with design exhaust air flow rate of 8,000 acfm Q-25 Cement Silos #1, 2, 3, and 5 CAMCORP Model 11TR12x121 baghouse with design exhaust air flow rate of 12,000 acfm Q-26 Cement Silo #4 CAMCORP Model 11TR12x121 baghouse with design exhaust air flow rate of 12,000 acfm Q-14 Truck Loadout #1 CAMCORP Model 7TR8x49 baghouse with design exhaust air flow rate of 3,000 acfm Q-17 Truck Loadout #2 CAMCORP Model 7TR8x49 baghouse with design exhaust air flow rate of 3,000 acfm R-12A Packing (Bagging) Plant CAMCORP Model 11TR12x121 baghouse with design exhaust air flow rate of 12,000 acfm F.1. Baghouse Controls - Each emissions point (EP) identified above for cement handling, storage, packing and loadout operations shall be controlled by a baghouse system. Each required baghouse shall be designed, operated, and maintained to achieve a PM design specification of 0.01 grains/dscf and a PM10 design specification of 0.007 gr/dscf. [Rule 62-212.400 (Best Available Control Technology), F.A.C.; Appendix BD - Final BACT Determination and Emission Standards; Permit No.1190042-001-AC (PSD-FL-361)] Emission Limitations and Standards F.2. Visible Emissions (VE) Limitations - Visible emissions shall not exceed the following limits: a. Visible emissions are limited to 5% opacity from each of the emissions points (EP) shown in the EP table above controlled by a baghouse. b. Visible emissions are limited to 10% opacity from any other emissions point associated with this emissions unit and not controlled by a baghouse. [Rules 62-204.800(8) & (11), and 62-212.400 (Best Available Control Technology), F.A.C.; Appendix BD – Final BACT Determination and Emission Standards; 40 CFR 60.62(c); 40 CFR 63.1343; Permit No.1190042-001-AC (PSD-FL-361)] Monitoring of Operations American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 48 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection F. Emissions Unit No. 006, Cement Handling, Storage, Packing, and Loadout F.3. Opacity Monitoring Requirements - Each affected emissions point (EP) subject to an opacity standard shall be periodically monitored using the procedures described in paragraphs “a” through “g” of this section to ensure compliance with the requirements of Specific Condition No F.2.a. a. You must conduct a monthly 10-minute visible emissions test of each affected source in accordance with Method 22 of 40 CFR 60, Appendix A. The performance test must be conducted while the affected source is in operation. b. If no visible emissions are observed in six consecutive monthly tests for any affected source, the owner or operator may decrease the frequency of performance testing from monthly to semi- annually for that affected source. If visible emissions are observed during any semi-annual test, you must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. c. If no visible emissions are observed during the semi-annual test for any affected source, you may decrease the frequency of performance testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual performance test, the owner or operator must resume performance testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. d. If visible emissions are observed during any Method 22 performance test, you must conduct five 6-minute averages of opacity in accordance with Method 9 in accordance with 40 CFR 60, Appendix A. The Method 9 performance test, must begin within 1 hour of any observation of visible emissions. e. The requirement to conduct Method 22 visible emissions monitoring under this paragraph does not apply to any totally enclosed conveying system transfer point, regardless of the location of the transfer point. “Totally enclosed conveying system transfer point” must mean a conveying system transfer point that is enclosed on all sides, top, and bottom. The enclosures for these transfer points must be operated and maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. f. If any partially enclosed or unenclosed conveying system transfer point is located in a building, you must conduct a Method 22, according to the requirements of paragraphs (a) through (d) of this section for each such conveying system transfer point located within the building, or for the building itself, according to 63 1350(f) (f)(1)(vii). [Rule 62-204.800(11), F.A.C., Permit No.1190042-001-AC (PSD-FL-361), 40 CFR 63 1350(f),] Test Methods and Procedures F.4. Annual Compliance Tests Required. During each calendar year (January 1st to December 31st), the baghouse exhaust vents for the emission points (EP) shown in the EP table above shall each be tested to demonstrate compliance with the visible emissions standards of Specific Condition No. F.2. [Rule 62- 297.310(8), F.A.C.; Permit No.1190042-001-AC (PSD-FL-361)]. {Permitting Note: As of the issuance of this permit, all EPs in this EU are controlled with a baghouse.} F.5. Test Methods. When required, tests shall be performed in accordance with the following reference methods: Method Description of Method and Comments 9 Visual Determination of the Opacity of Emissions from Stationary Sources Visual Determination of Fugitive Emissions From Material Sources (for opacity periodic 22 monitoring) The above methods are described in 40 CFR 60, Appendix A, and adopted by reference in Rule 62-204.800, F.A.C. No other methods may be used unless prior written approval is received from the Department. [Rule 62-297.401, F.A.C., 40 CFR 63.1350; Permit No.1190042-001-AC (PSD-FL-361)] American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 49 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection F. Emissions Unit No. 006, Cement Handling, Storage, Packing, and Loadout F.6. Common Testing Requirements. Unless otherwise specified, tests shall be conducted in accordance with the requirements and procedures specified in Appendix TR, Facility-Wide Testing Requirements, of this permit. [Rule 62-297.310, F.A.C.] Table of Contents American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 50 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection G. Emissions Unit No. 007, Coal and Petroleum Coke Grinding System The specific conditions in this section apply to the following emissions unit: EU No. Brief Description 007 Coal and Petroleum Coke Grinding System The coal and petroleum coke grinding system includes coal/petroleum coke handling from truck and railcar unloading to the pulverized fuel bin. Equipment includes a coal/petroleum coke grinding mill with thermal dryer, storage bins, and associated conveyor systems. Clinker cooler gas is used for drying. The following emissions points (EP) in the coal and petroleum coke grinding system are controlled by fabric filter baghouses. Baghouse/ Emissions Point (EP) Description Baghouse Description EP ID Two CAMCORP Model 12PRW233 baghouse Coal/Petroleum Coke Mill (including S-22 separators, each with design exhaust air flow rate of Thermal Dryer) 17,500 acfm (combined common exhaust stack ) CAMCORP Model 8PRT19 baghouse with design S-26 Coal/Petroleum Coke Bin exhaust air flow rate of 800 acfm (ancillary de-dusting) {Permitting Note: This emissions unit (Baghouse/ EP ID S-22) is subject to 40 CFR 60 Subpart A (General Provisions) and 40 CFR 60 Subpart Y -Standards of Performance for Coal Preparation Plants. For the purposes of Subpart Y applicability, this emissions unit commenced construction on or before December 3, 2007 and is considered an “existing” source (built prior to April 28, 2009). As with the EU 003 main baghouse EP, EP S-22 is also regulated under either DDDD or LLL. For the purposes of LLL, this facility is considered an as an “existing” source (built prior to May 6, 2009). For the purposes of DDDD, the kiln and related emissions from EP S-22 are considered an “existing” source. Because the kiln EU- 003 vents partially to the coal mill (S-22), the coal mill emissions are presumptively subject to all emissions limits of DDDD or LLL, as applicable. This subsection of the permit therefore includes three sets of conditions to address the separate requirements. Conditions G.1 through G.8 apply regardless of applicability of DDDD or LLL. Conditions G.9 through G.12. apply only when the kiln is subject to DDDD. Conditions G.13 through G.17. apply only when the kiln is subject to LLL. (See condition G.3.). PSD BACT Determination - A determination of the BACT was made for particulate matter (PM/PM10). To satisfy some of the BACT requirements for this emission unit the visible emissions limits act as surrogate standards for PM. (Appendix BD – Final BACT Determination and Emission Standards)} Specific Conditions G.1 – G.8 apply to this EU at all times, regardless of whether the EU is regulated under DDDD or LLL. G.1. Process Rate Limitation - The coal/petroleum coke grinding mill may process up to 18.5 tons per hour based on a 30-day rolling average of coal/petroleum coke. No more than 134,904 tons of coal/petroleum coke shall be processed through the grinding mill during any consecutive 12-month period. [Rule 62-210. 200 (Definition of Potential to Emit), F.A.C.; Permit No.1190042-001-AC (PSD-FL-361)] Control Technology G.2. Baghouse Controls - Each emissions point identified above for the coal and petroleum coke grinding system shall be controlled by a baghouse system. Each required baghouse shall be designed, operated, and maintained to achieve a PM design specification of 0.01 grains/dscf and a PM10 design specification of 0.007 gr/dscf. [Rule 62-212.400 (Best Available Control Technology), F.A.C.; Appendix BD – Final BACT Determination and Emission Standards; Permit No.1190042-001-AC (PSD-FL-361)] American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 51 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection G. Emissions Unit No. 007, Coal and Petroleum Coke Grinding System Emission Limitations and Standards G.3. Particulate Matter (PM/PM10) Standard - PM/PM10 emissions from the thermal dryer (Emission Point (EP) ID S-22) shall not exceed 0.007 grains per dscf (gr/dscfm) of exhaust as determined by EPA Method 5. [Rules 62-204.800(8), and 62-212.400 (Best Available Control Technology), F.A.C.; Appendix BD – Final BACT Determination and Emission Standards; 40 CFR 60.252; and Permit No.1190042-001-AC (PSD-FL- 361)] {Permitting Note: –The PM limit for EP S-22 is effectively 13.5 mg/dscm corrected to 7% O2 (DDDD) or 0.006 gr/dscf (LLL) as determined by 40 CFR 63.1343(b)(2), Equation 1. As such, compliance with these limits provide assurance of compliance with the PM limit of 40 CFR 60, Subpart Y and the BACT PM emission limit. The BACT determination PM limit (0.007 gr/dscf) is more stringent than the applicable NSPS Subpart Y 40 CFR 60.252(a)(1) PM limit of 0.031 gr/dscfm. Compliance with DDDD or LLL (as applicable) PM standard will ensure compliance with both of these limits. (See condition G.16.)} G.4. Visible Emissions (VE) Limitations - Visible emissions shall not exceed the following limits. a. Visible emissions from emissions point (EP S-26) controlled by a baghouse shall not exceed 5% opacity. b. Visible emissions from all coal/petcoke processing and conveying equipment, coal/petcoke storage systems, or coal/petcoke transfer and loading systems not controlled by a baghouse, shall not exceed 10% opacity. [Rules 62-204.800(8), and 62-212.400 (Best Available Control Technology), F.A.C.; Appendix BD – Final BACT Determination and Emission Standards; 40 CFR 60.252; and Permit No.1190042-001-AC (PSD-FL- 361)] {Permitting Note – These BACT determination VE opacity limits are more stringent than the applicable NSPS Subpart Y 40 CFR 60.252(a)(2) and 60.254(a) VE limits of 20% opacity. Demonstration of compliance with the BACT VE limitations will also be considered as demonstration of compliance with NSPS 40 CFR 60 Subpart Y limit.) Continuous Monitoring Requirements G.5. Thermal Dryer Exit Temperature - A monitoring device for the continuous measurement of the temperature of the gas stream at the exit of the thermal dryer shall be installed, calibrated, maintained, and continuously operated to measure the temperature of the gas stream in accordance with the requirements of 40 CFR 60 Subpart Y. [Rule 62-204.800(8), F.A.C.; NSPS Subpart Y 40 CFR 60.256(a)] Testing Requirements G.6. Annual Compliance Tests Required. During each calendar year (January 1st to December 31st), the baghouse exhaust vents for emission point S-26 shall be tested for visible emissions. [Rule 62-297.310(8)(a), F.A.C.] G.7. Common Testing Requirements. Unless otherwise specified, tests shall be conducted in accordance with the requirements and procedures specified in Appendix TR, Facility-Wide Testing Requirements, of this permit. [Rule 62-297.310, F.A.C.] Recordkeeping and Reporting Requirements G.8. Coal/Petroleum Coke Grinding Mill Process Rate Records - In order to document compliance with the coal/petroleum coke grinding mill process rate limitations of Condition No. G.1, the permittee shall maintain the following records of the monthly grinding mill processing rate: a. the month of the record; b. the total quantity of coal and petroleum coke processed through the grinding mill for the month (tons coal/petroleum coke per month); American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 52 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection G. Emissions Unit No. 007, Coal and Petroleum Coke Grinding System c. the total hours of operation of the grinding mill for the month (hours/month) (operation of the grinding mill is defined as periods of operation when coal or petroleum coke is being processed (ground) by the mill); d. the average grinding mill coal/petroleum coke processing rate (tons/hour) for the month (based on b. and c. above); and e. the total tons of coal and petroleum processed through the grinding mill in the most recent 12 consecutive month period (tons coal/petroleum coke per 12 consecutive month period). The above reports shall be recorded and available for inspection no later than 10 days following the end of the month. [Rule 62-213.440(1)(b), F.A.C.] Specific Conditions G.9 – G.12 apply to this EU only when the Kiln is regulated under DDDD. G.9. Emissions from Coal/Petroleum Coke Mill (S-22). When there is an in-line coal mill that exhausts emissions through a separate stack, the combined emissions are subject to the emission limits applicable to the waste-burning kilns. To determine the kiln-specific emission limit for demonstrating compliance, the permittee shall: a. Calculate the kiln-specific emission limit using equation 7 of 40 CFR 60.2710(y)(1): Cks = [{(emission limit) * (Qab + Qcm + Qks)} – (Qab * Cab) – (Qcm * Ccm)] / Qks Where, Cks = Kiln stack concentration (ppmvd, mg/dscm, ng/dscm, depending on pollutant. Each corrected to 7% O2.) Qab = Alkali bypass flow rate (volume/hr) Cab = Alkali bypass concentration (ppmvd, mg/dscm, ng/dscm, depending on pollutant. Each corrected to 7% O2.) Qcm = In-line coal mill flow rate (volume/hr) Ccm = In-line coal mill concentration (ppmvd, mg/dscm, ng/dscm, depending on pollutant. Each corrected to 7% O2.) Qks = Kiln stack flow rate (volume/hr) b. PM concentrations shall be measured downstream of the in-line coal mill. All other pollutant concentrations shall be measured either upstream or downstream of the in-line coal mill. [Rule 62-204.800(9)(f), F.A.C., referencing 40 CFR 60.210(y)] G.10. Hg Emissions. When there is an in-line coal mill that exhausts emissions through a separate stack, the combined emissions are subject to the emission limits applicable to the waste-burning kilns. For Hg, the unit may comply with the alternative production-based Hg emission limit of 58 lb/MMton clinker as specified in Rule 62-204.800(9)(f)5., F.A.C. [Rule 62-204.800(9)(f)5., F.A.C.] Compliance Testing G.11. Compliance Testing. Because the kiln system exhaust gas partially vents through the coal mill stack, compliance testing for DDDD pollutants of CO, NOx, SO2, PM, Hg, HCl, D/F, Cd, and Pb requires testing of kiln and coal mill. For purposes of determining the combined emissions from kilns that exhaust kiln gases to the coal mill, that exhausts through a separate stack, instead of installing a CEMS or PM CPMS on the in-line coal mill, the results of the initial and subsequent performance test can be used to demonstrate compliance with the relevant emissions limit. A performance test shall be conducted on an annual basis between 11 and 13 months following the previous performance test. [Rule 62-204.800(9)(f), F.A.C., referencing 40 CFR 60.210(y)(3)] G.12. Hg Compliance Testing. Because the Hg emission limit of 58 lb/MM ton clinker is specific to Rule 62- 204.800(9)(f), F.A.C., the procedure to demonstrate compliance on the coal mill stack shall follow procedures outlined in 40 CFR 63 1348(b)(7) and 40 CFR 63.1349(b)(5). [Rule 62-204.800(9)(f)8., F.A.C.] American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 53 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection G. Emissions Unit No. 007, Coal and Petroleum Coke Grinding System Specific Conditions G.13 – G.17 apply to this EU only when the Kiln is regulated under LLL. G.13. THC Emissions: Because the kiln (which is subject to NESHAP 40 CFR 63 Subpart LLL) vents partially to the coal mill, the coal mill emissions are presumptively subject to the THC emissions limits of NESHAP Subpart LLL. Coal mill emissions must be accounted for in accordance with 40 CFR 63.1348(b)(6)(ii). Because the kiln uses a THC CEMS for monitoring, the THC CEMS data is combined with the coal mill THC testing results to determine an effective compliance limit using Equation 9, below. For the purposes of conducting the accuracy and quality assurance evaluations for CEMS, the THC span value (as propane) is 50 ppmvd and the reference method (RM) is Method 25A of 40 CFR 60, Appendix A. THC must be measured either upstream of the coal mill or the coal mill stack. Where: Cks = Kiln stack concentration (ppmvd). Qab = Alkali bypass flow rate (volume/hr). Cab = Alkali bypass concentration (ppmvd). Qcm = Coal mill flow rate (volume/hr). Ccm = Coal mill concentration (ppmvd). Qks = Kiln stack flow rate (volume/hr). [40 CFR 63.1349(b)(4)] G.14. Hg Emissions: Because the kiln vents partially to the coal mill, the coal mill emissions are presumptively subject to the Hg emissions limits of NESHAP 40 CFR 63 Subpart LLL. Coal mill emissions must be accounted for by 40 CFR 63.1349(b)5. Because the kiln uses a Hg CEMS or sorbent trap system for monitoring, the Hg CEMS/sorbent trap data is combined with coal mill Hg testing results to determine an effective compliance limit using Equation 10, below. Where: E30D = 30-day rolling emission rate of mercury, lb/MM tons clinker. Ci = Concentration of mercury for operating hour i, µg/scm. Qi = Volumetric flow rate of effluent gas for operating hour i, where Ci and Qi are on the same basis (either wet or dry), scm/hr. k = Conversion factor, 1 lb/454,000,000 µg. n = Number of kiln operating hours in a 30 kiln operating day period. P = 30 days of clinker production during the same time period as the mercury emissions measured, million tons. [40 CFR 63.1349(b)(5)] G.15. HCl Emissions: Because the kiln vents partially to the coal mill, the coal mill emissions are presumptively subject to the HCl emissions limits of NESHAP 40 CFR 63 Subpart LLL. Coal mill emissions must be accounted for by 40 CFR 63.1349(b)(6). Because the kiln uses either an HCl CEMS or surrogate monitoring by SO2 CEMS or by minimal sorbent injection rate (See 40 CFR 63.1349(b)(6)) for monitoring, the CEMS data is combined with coal mill HCl testing results to determine an effective compliance limit using Equation 11, below. Where: American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 54 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection G. Emissions Unit No. 007, Coal and Petroleum Coke Grinding System Cks = Kiln stack concentration (ppmvd). Qab = Alkali bypass flow rate (volume/hr). Cab = Alkali bypass concentration (ppmvd). Qcm = Coal mill flow rate (volume/hr). Ccm = Coal mill concentration (ppmvd). Qks = Kiln stack flow rate (volume/hr). [40 CFR 63.1349(b)(6)] Compliance Test Methods and Procedures G.16. Annual PM Compliance Tests Required. Since the kiln (which is subject NESHAP 40 CFR 63 Subpart LLL) vents partially to the coal mill (S-22), the coal mill emissions are presumptively subject to the PM emissions limits of NESHAP 40 CFR 63 Subpart LLL. During each calendar year (January 1st to December 31st), coal mill emission point S-22 shall be tested to demonstrate compliance with the emissions standards for PM. The permittee shall simultaneously test the kiln and coal mill to determine an emissions limit per 40 CFR 63.1343(b)2 and then set the PM CPMS 30-kiln operating day limit using 63.1349(b)1. Coal Mill emission must be accounted for by 40 CFR 63.1349(b)(1)(viii). Equation 8 below. Where: EC = Combined hourly emission rate of PM from the kiln and bypass stack and/or inline coal mill, lb/ton of kiln clinker production. EK = Hourly emissions of PM emissions from the kiln, lb. EB = Hourly PM emissions from the alkali bypass stack, lb. EC = Hourly PM emissions from the inline coal mill stack, lb. P = Hourly clinker production, tons. The permittee shall demonstrate initial compliance by conducting separate performance tests while the raw mill is under normal operating conditions and while the raw mill is not operating. [Rules 62-297.310(8)(a) and (b), F.A.C.; Permit No.1190042-001-AC (PSD-FL-361) and 40 CFR 63.1349] G.17. Test Methods. When required, tests shall be performed in accordance with the following reference methods: Method Description of Method and Comments 1-4 Traverse Points, Velocity and Flow Rate, Gas Analysis, and Moisture Content 5/5I Method for Determining Particulate Matter Emissions (All PM is assumed to be PM10.) 25A Measurement of Gaseous Organic Concentrations (Flame Ionization – Instrumental) 29 Determination of Metal Emissions from Stationary Sources 321 Measurement of Gaseous Hydrogen Chloride Emissions At Portland Cement Kilns by Fourier Transform Infrared (FTIR) Spectroscopy The above methods are described in 40 CFR 60, Appendix A, and adopted by reference in Rule 62-204.800, F.A.C. No other methods may be used unless prior written approval is received from the Department. Tests shall be conducted in accordance with the appropriate test method and the applicable requirements specified in Appendix TV of this permit, NSPS Subpart A in 40 CFR 60, and NESHAP Subparts A and LLL in 40 CFR 63. [Rules 62-204.800(8) & (11), F.A.C.; 40 CFR 60 Appendix A; 40 CFR 63 Subparts A and LLL] Table of Contents American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 55 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection H. Emissions Unit No. 010, Alternative Fuels Processing System The specific conditions in this section apply to the following emissions unit: EU No. Brief Description 010 Alternative Fuels Processing System Essential Potential to Emit (PTE) Parameters H.1. Hours of Operation – The activities included in this emissions unit are permitted to operate continuously (i.e., 8,760 hours per year). [Rule 62-210.200 (Potential to Emit), F.A.C.; Permit No.1190042-009-AC (PSD- FL-361F)] Performance Requirements H.2. The permittee is authorized to operate the following permanent equipment for firing alternative fuels (AF) in the pyroprocessing kiln system. The permittee shall submit details of the final design once complete (e.g., design heat input rates and schematics). a. Mechanical and Pneumatic Handling and Feed Systems. Each feed system is designed to handle alternative fuels with multiple points of injection to accommodate various AF particle size, density, and heating value. The nominal feed rate of the total feed system is 32 tons of AF per hour. i. The mechanical feed system(s) for the calciner and kiln burners consists of mechanical feeder(s), weighing mechanism(s), load hopper(s) with required conveyors, storage bins, and other associated equipment. ii. The pneumatic feed systems for the calciner and kiln burners consists of a system of mechanical feeder(s) and associated system of air movement equipment and related ductwork, weighing mechanism(s), loading hopper(s) with required conveyors, storage bins, and other associated equipment. b. Kiln and Calciner Burner, AF Handling and Firing Systems. The permittee is can operate the current kiln and/or calciner burner system with a multi-channel fuel burner(s) and/or other related feed equipment specifically designed for co-firing AF with authorized fuels in the kiln. c. Feed Systems. To the extent practicable, components of the feed systems shall be substantially enclosed or covered to prevent the loss of any AF and fugitive dust emissions. Each feed system shall be integrated into the existing kiln data system. The AF feed rate shall be recorded along with the other fuel feed rates. d. Fuel Preparation Equipment. The permittee is authorized to install grinding, shredding, screening, and sizing equipment to prepare the AF. This equipment will be powered by electric motors or diesel engines. In addition, the diesel engines shall comply with any applicable NSPS or NESHAP standards. [Permit No.1190042-009-AC (PSD-FL-361F); Rule 62-210.225, PTE, F.A.C.; Rule 62-296.320] H.3. Prohibited Materials: The owner or operator shall not introduce into any part of the process any of the following fuels and materials: a. hazardous wastes as defined in 40 CFR 261; b. petroleum contaminated soil or materials; c. off-specification used oil; d. nuclear waste, and radioactive waste; e. biomedical waste; f. asbestos-containing materials per 40 CFR 61 Subpart M; g. whole batteries; h. solid wastes, other than tires as allowed by this permit, or i. Coal ash which has not been determined to be acceptable for initial or continued use to control emissions of Total Hydrocarbon (THC) and Volatile Organic Compound (VOC) by initial, trial, or periodic sampling protocols and test results specified in the facility Material Management Plan for THC/VOC emissions control (Appendix MM - Material Management Plan). American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 56 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection H. Emissions Unit No. 010, Alternative Fuels Processing System If the permittee identifies delivered material that falls under the above paragraph, the supplier shall be contacted and the material shall be returned, disposed, or any other appropriate legal method of handling the material shall be employed. The permittee shall maintain records of delivery, sampling and analysis, and actions taken to correct abnormalities. Such records shall be stored onsite for at least five years and available for inspection upon request. [Rule 62-210. 200 (Potential to Emit), F.A.C.; Permit No.1190042-009-AC (PSD-FL-361F)] H.4. Alternative Fuels (AF): Subject to the AF Acceptance Criteria, the permittee is authorized to accept authorized fuels within any of the following AF categories. a. Tire-Derived Fuel (TDF), which includes whole and shredded tires with or without steel belt material including portions of tires such as tire fluff. The kiln is currently permitted to use both whole tires using the existing tire injection mechanism system and chipped tires. b. Plastics, which includes materials such as polyethylene plastic used in agricultural and silvicultural operations. This may include incidental amounts of chlorinated plastics. c. Roofing Materials, which consists of roofing shingles and related roofing materials with the bulk of the incombustible grit material separated and which is not subject to regulations as an asbestos- containing material per 40 CFR 61, Subpart M. d. Agricultural Biogenic Materials, which includes materials such as peanut hulls, rice hulls, corn husks, citrus peels, cotton gin byproducts, animal bedding and other similar types of materials. e. Cellulosic Biomass - Untreated, which includes materials such as untreated lumber, tree stumps, tree limbs, slash, bark, sawdust, sander dust, wood chips scraps, wood scraps, wood slabs, wood millings, wood shavings and processed pellets made from wood or other forest residues. f. Cellulosic Biomass - Treated, which includes preservative-treated wood that may contain treatments such as creosote, copper-chromium-arsenic (CCA), or alkaline copper quaternary (ACQ), painted wood, or resinated woods (plywood, particle board, medium density fiberboard, oriented strand board, laminated beams, finger-jointed trim and other sheet goods). The permittee shall not fire more than 1,000 lb/hour averaged on a 7-day block average basis of segregated streams of wood treated with copper-chromium-arsenic (CCA) compounds. g. Carpet-Derived Fuel, which includes shredded new, reject or used carpet materials. This material may contain incidental related materials (e.g., tack-down strips, nails, etc.). h. Alternative Fuel Mix, which includes a blended combination of two or more of any of the above materials. i. Biosolids, which includes organic materials sanitized to meet EPA Class A sanitization standards and is derived from treatment processes of public treatment water systems. j. Engineered Fuel (EF) is engineered to have targeted, consistent fuel properties such as: calorific value, moisture, particle size, ash content, and volatility. The specific targeted properties are established based on available alternative fuel material supply and are carefully controlled through blending of non-hazardous combustible materials or through separation of non-hazardous incombustible materials from combustible materials (mixes of any alternative fuels where the blending and processing may also include the addition of on-specification used oils or other non- hazardous liquids to ensure consistent and predictable fuel properties). EF is engineered largely from the above materials and could include, but not be limited to materials such as animal meal, automotive manufacturing byproducts, clean-up debris from natural disasters, processed municipal solid waste, dried/sanitized biosolids, paint filter cake, hospital materials (non-infectious), pharmaceuticals (expired prescriptions), cosmetics, and confiscated narcotics that are not a hazardous waste (40 CFR 261). [Rule 62-210. 200 (Potential to Emit), F.A.C.; Permit No.1190042-009-AC (PSD-FL-361F)] H.5. Receiving AF: For AF received at the plant, the permittee shall comply with the following requirements: a. All AF materials received at the plant shall be in covered trucks and/or enclosed containers as needed to prevent fugitive emissions. When unloading and handling AF, the permittee shall take reasonable precautions to prevent fugitive dust emissions. American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 57 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection H. Emissions Unit No. 010, Alternative Fuels Processing System b. The permittee shall record the category/type and the amount of each AF received. c. Each AF category received shall be sampled and analyzed in a manner consistent with industry standards for quality assurance and quality control to ensure that representative data is collected. The permittee shall obtain the analytical results of a representative sample of the AF category prior to the initial delivery, quarterly for the first year, and if the analysis meets permit requirements the frequency of sampling and analysis shall be annual every January thereafter, if that material is present. All records and results of the analysis will be maintained at the facility as required for currently permitted fuels. d. Fuel Analyses Parameters: i. The following information shall be included when reporting the analytical results for an AF: heating value (Btu/lb) of AF; moisture, ash, sulfur and chlorine content (percent by weight); chromium, lead, and mercury contents (ppm). All concentrations are on a dry basis. ii. Reject roofing shingles, either separately as item H.4.c. (Roofing Materials) or if knowingly included in item H.4.j. (Engineered Fuel), shall include a certification from the manufacturer that they were made without asbestos or analytical testing results. [Permit No.1190042-009-AC (PSD-FL-361F)] H.6. Processed/Prepared AF: The AF shall be stored: a. Under cover or in covered trailers, containers, or buildings as needed to prevent fugitive emissions; b. On top of a paved or compacted clay surface; and, b. By Best Management Practices to promote containment and prevent contamination of air, water, and soil. The permittee identified Best Management Practices in the air permit application for 1190042- 009-AC [Permit No.1190042-009-AC (PSD-FL-361F)] H.7. Operation: Alternative fuels (AF) shall only be fired after the kiln has achieved normal operation, temperatures and production (i.e., when raw materials are introduced). a. AF shall be introduced only in the high-temperature combustion zones of the main kiln burner, the precalciner burner or appropriate secondary firing points in the precalciner/preheater. b. The permittee shall make every effort during the shakedown and assessment periods to promote efficient combustion and minimize emissions impacts. c. Operators shall discontinue firing AF if one of the CEMS, CPMS, or other continuous monitors indicates a non-compliance issue related to alternative fuels. Use of AF may start again after the issue is corrected. [Permit No.1190042-009-AC (PSD-FL-361F)] H.8. Biosolids - NESHAP 40 CFR 61 Requirements - Subpart A: When combusting biosolids the permittee shall comply with all applicable requirements of 40 CFR 61, Subpart A, General Provisions, which have been adopted by reference in Rule 62-204.800(10)(d), F.A.C., except for 40 CFR 61.08 and except that the Secretary of the Department is not the Administrator for the purposes of 40 CFR 61.04, 40 CFR 61.11, and 40 CFR 61.18. In lieu of the process set forth in 40 CFR 61.08, the Department will follow the permit processing procedures of Rule 62-4.055, F.A.C. [Rule 62-204.800(10)(d), F.A.C., and Permit No.1190042-009-AC (PSD-FL-361F)] H.9. Mercury Emissions from Biosolids: The permitted maximum allowable emission rate for mercury is 7.1 pounds per 24-hour period. This condition is met by compliance with the NESHAP 40 CFR 63 Subpart LLL Hg limit 55 lb/MM tons clinker. [Rule 62-204.800(10)(d), F.A.C., and 40 CFR 61.52 and Permit No.1190042- 009-AC (PSD-FL-361F)] Monitoring Requirements H.10. Sampling Criteria: Each AF material received shall be sampled and analyzed in a manner consistent with industry standards for quality assurance and quality control to ensure that representative data is collected. At a minimum, the frequency of sampling and analysis shall be consistent with the frequency of sampling and American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 58 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection H. Emissions Unit No. 010, Alternative Fuels Processing System analysis of coal. (See Condition H.5.d.) All records and results of the analysis shall be maintained at the facility as required for currently permitted fuels. [Permit No.1190042-009-AC (PSD-FL-361F)] H.11. AF Assessment and Analytical Methods: The permittee shall use the following analytical methods to determine the composition of the AF. Parameter Analytical Methods Moisture, Volatiles, Ash and Fixed Carbon Proximate Analysis appropriate for given fuel Carbon, Hydrogen, Nitrogen Sulfur and Ultimate Analysis appropriate for given fuel Oxygen Heating Value ASTM E711 - 87(2004) Standard Test Method for Gross Calorific Value of Refuse-Derived Fuel by the Bomb Calorimeter, or ASTM D5468 - 02(2007) Standard Test Method for Gross Calorific and Ash Value of Waste Materials, or Proximate Analysis appropriate for given fuel Chlorine EPA SW-846 or EPA Method 9056 Mercury EPA 7470A/7471A Other Metals EPA SW-846 or EPA Method 6010B Other equivalent methods may be used with prior written approval of the Compliance Authority [Permit No.1190042-009-AC (PSD-FL-361F)] H.12. Sampling/Analysis by Permittee: For each AF category assessment, the permittee shall obtain analytical results of the AF as required in Condition H.5. The operator shall take a representative as-fired sample of the AF and have it analyzed for the parameters listed in specific condition H.5.d. [Permit No.1190042-009-AC (PSD-FL-361F)] H.13. Testing of Biosolids for Mercury: The permittee shall test biosolids unless a waiver of emission testing is obtained under 40 CFR 61.13 from the Department. Such tests shall be conducted in accordance with the procedures set forth in 40 CFR 61 Subpart E as follows. a. The emission or sampling test shall be performed within 90 days of startup of firing biosolids per Method 101A or 105 in Appendix B to 40 CFR 61 Subpart E. A total of three composite samples or as necessary shall be obtained within an operating period of 24 hours. When the 24-hour operating period is not continuous, the total sampling period shall not exceed 72 hours after the first grab sample is obtained. Samples shall not be exposed to any condition that may result in mercury contamination or loss. b. The Compliance Authority ([email protected]) shall be notified at least 30 days prior to an emission or sampling test. c. The permittee shall take samples over such a period or periods as are necessary to determine accurately the maximum emissions which will occur in a 24-hour period. No changes shall be made in the operation which would potentially increase emissions above the level determined by the most recent stack test, until the new emission level has been estimated by calculation and the results reported to the Department. d. All samples shall be analyzed and mercury emissions shall be determined within 30 days after the stack or sampling test. Each determination shall be reported to the Compliance Authority ([email protected]) within 15 calendar days following the date such determination is completed. Records of emission test results and other data needed to determine total emissions shall be retained at the source and shall be made available, for inspection by the Compliance Authority, for a minimum of 5 years. e. The maximum 24-hour period biosolids firing rate shall be determined by use of a flow rate measurement device that can measure the mass rate of biosolids charged to the incinerator or dryer American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 59 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection H. Emissions Unit No. 010, Alternative Fuels Processing System with an accuracy of ±5 percent over its operating range. Other methods of measuring biosolids mass charging rates may be used if they have received prior approval by the Department. f. If sampling is used, mercury emissions shall be determined by use of the following equation. where: EHg = Mercury emissions, g/day. M = Mercury concentration of biosolids on a dry solids basis, µg/g. Q = Biosolids changing rate, kg/day. Fsm = Weight fraction of solids in the collected biosolids after mixing. 1000 = Conversion factor, kg µg/g2. g. No changes in the operation of a plant shall be made after a biosolids test has been conducted which would potentially increase emissions above the level determined by the most recent biosolids test, until the new emission level has been estimated by calculation and the results reported to the Compliance Authority ([email protected]). h. If mercury emissions exceed 3.5 pound per 24-hour period, demonstrated either by stack sampling according to 40 CFR 61.53 or biosolids sampling, the permittee shall monitor mercury emissions at intervals of at least once per year. The results of monitoring shall be reported and retained as indicated in Specific Condition H.13.d. [Rule 62-204.800(10)(d), F.A.C., 40 CFR 61.53, 53, 54, and 55, and Permit No.1190042-009-AC (PSD-FL- 361F)] {Permiting Note: Compliance with the mercury limitation of this condition is demonstrated by the monitoring of mercury emissions in accordance with NESHAP LLL and Condition C.21.} H.14. AF Target Levels: Targets levels are the desired AF properties for as-fired fuel in the system. Target Levels are not enforceable. Parameter Target Levelsa Higher Heating Value > 5,000 Btu/lb Arsenic < 2,000 ppm by weight Beryllium < 20 ppm by weight Cadmium < 200 ppm by weight Chromium < 200 ppmw (mg/kg) Lead < 1,000 ppmw (mg/kg) Mercury < 0.3 ppm by weight a - Heating value is on dry basis. All concentrations are dry basis. Target levels are based on USGS data of coal samples, (http://pubs.usgs.gov/of/2010/11961). [Permit No.1190042-009-AC (PSD-FL-361F)] Notification Requirements H.15. Shakedown Notifications: Within 15 (fifteen) days of completing construction, the permittee shall notify the Compliance Authority and provide a schedule for shakedown and the initial AF category assessment. The Compliance Authority may waive this deadline. [Permit No.1190042-009-AC (PSD-FL-361F)] H.16. AF Assessment Notifications: At least five days prior to firing each new category of AF material listed in Specific Condition H.4., the permittee shall notify the Compliance Authority with a proposed schedule of when the specific new category of AF will be fired. The Compliance Authority may waive this deadline. [Permit No.1190042-009-AC (PSD-FL-361F)] American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 60 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection H. Emissions Unit No. 010, Alternative Fuels Processing System Recordkeeping and Reporting Requirements H.17. Records of Fuels and Heat Input: The permittee shall record the fuel-firing rate continuously. The permittee shall maintain records of the quantity and representative analysis of fuels purchased, and such records shall include the parameters listed in Specific Condition H.5.d. The permittee shall make and maintain records of heat input to the pyroprocessing system on a block-hour basis, starting at the beginning of each hour, by multiplying the hourly average fuel-firing rate by the heating value representative of that fuel from the records of fuel analysis. Such records shall be completed for each block-hour by the end of the day following the day the fuel was fired. [Permit No.1190042-009-AC (PSD-FL-361F)] H.18. Reports for Shakedown and AF Assessments: During periods of authorized shakedowns and AF category assessments, the permittee shall document the shakedown and/or AF category assessment period. These periods may end early when the operator is confident that good operating practices have been defined for the AF category that results in steady kiln system operation. Within 90 days of completing a shakedown and/or assessment of each AF category listed in Specific Condition H.4., the permittee shall provide a written report summarizing the following information collected from the shakedown and/or AF category assessment period shall be submitted to the Compliance Authority ([email protected]). a. For a 24-hour period representing good operating practices and steady kiln operation, the report shall include: the representative analysis of the AF fired; hourly AF and fossil fuel firing rates; hourly clinker production; hourly CO, NOx, and THC emissions data from the CEMS; the hourly averages from the CPMS; and the inlet temperature to main kiln baghouse (3-hour average). Identify the good operating practices resulting in steady kiln operation. b. The AF category assessments may occur over several years. Emissions from the initial AF category assessment of a new fuel may be excluded from the report requiring a comparison of actual-to-baseline emissions (Rules 62-212.300(1)(e) and 62-210.370, F.A.C.) since operators are still establishing good operating practices and the AF will not have been available for the full calendar year. To exclude emissions data collected during an authorized shakedown and/or AF category assessment period from this report, the permittee shall submit the following information: total clinker production; fossil fuel fired; AF fired; total CO, NOx,, and THC emissions (tons). Excluded data shall be replaced with data estimated from: the actual clinker production rate; and an emissions factor based on the average emission rates from the rest of the year (i.e., all periods except the shakedown and/or AF assessment periods). [Permit No.1190042-009-AC (PSD-FL-361F)] H.19. Test Reports: The permittee shall prepare and submit reports for all required tests in accordance with the requirements specified in Appendix TR - Facility-Wide Testing Requirements of this permit. The permittee shall use the most accurate of the approaches below to compute the emissions of a pollutant. a. If the emissions unit is equipped with a CEMS meeting the requirements of Rule 62-210.370(2)(b), F.A.C., the permittee shall use the CEMS to compute the emissions of the pollutant. b. If a CEMS is not available or does not meet the requirements of Rule 62-210.370(2)(b), F.A.C, but emissions of the pollutant can be calculated using the mass balance methodology of Rule 62- 210.370(2)(c), F.A.C., the permittee shall use that methodology, unless the permittee demonstrates to the Department that an alternative approach is more accurate. c. If a CEMS is not available or does not meet the requirements of Rule 62-210.370(2)(b), F.A.C., and emissions cannot be computed pursuant to the mass balance methodology, the permittee shall use an emission factor meeting the requirements of Rule 62-210.370(2)(d), F.A.C., unless the permittee demonstrates to the Department that an alternative approach is more accurate. [Permit No.1190042-009-AC (PSD-FL-361F)] H.20. Records Availability: All records shall be made available to the Department upon request. [Permit No.1190042-009-AC (PSD-FL-361F) and Rule 62-4.070(1) & (3), F.A.C.] Table of Contents American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 61 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection I. Emissions Unit No. 009, Stationary Emergency Generator The specific conditions in this section apply to the following emissions unit: EU No. Brief Description Stationary Emergency Generator CI RICE. This emissions unit consists of one Manufacturer- certified Compression Ignition Reciprocating Internal Combustion Engine (CI RICE) used to drive 009 an emergency generator at the facility. The CI RICE is a Caterpillar Diesel Engine Model No. C32, rated at 1.12 megawatts and 1050 horsepower, with a manufacture date of 2007. {Permitting Notes: This emergency-use reciprocating internal combustion engines (RICE) is regulated under 40 CFR 63, Subpart ZZZZ, NESHAP for Stationary RICE and 40 CFR 60, Subpart IIII, NSPS for Stationary Compression Ignition RICE, adopted in Rules 62.204.800(11)(b) & (8)(b), F.A.C., respectively. This CI RICE is considered “new” with a displacement of less than 30 liters per cylinder, located at a major source of HAP, that has been modified, reconstructed, or commenced construction on or after 6/12/2006, and that have a post-2007 model year. In accordance with provisions of 40 CFR 63.6590(b)(i), this emergency RICE is subject to only the limited requirements (notification only) of Subpart ZZZZ.} Essential Potential to Emit (PTE) Parameters I.1. Authorized Fuel. This Stationary Reciprocating Internal Combustion Engines (RICE) must use diesel fuel that meets the following requirements for non-road diesel fuel: a. Sulfur Content. The sulfur content shall not exceed 15 ppm (0.0015%) by weight (ultra low sulfur) for non-road fuel. b. Cetane and Aromatic. The fuel must have a minimum cetane index of 40 or must have a maximum aromatic content of 35 volume percent. [40 CFR 60.4207(b), 80.510(b) I.2. Restricted Hours of Operation. The following limitations apply to the CI RICE operations: a. Emergency Situations. There is no time limit on the use of emergency stationary RICE in emergency situations. [40 CFR 60.4211(f)(1)] b. Other Situations. You may operate these emergency stationary RICE for any combination of maintenance and readiness testing for a maximum of 100 hours per calendar year. Operation for the purpose of maintenance checks and testing is allowed provided that the tests are recommended by federal, state or local government, the manufacturer, the vendor, or the insurance company associated with the engine. The owner or operator may petition the Compliance Authority for approval of additional hours to be used for maintenance checks and readiness testing, but a petition is not required if the owner or operator maintains records indicating that Federal, State, or local standards require maintenance and testing of emergency RICE beyond 100 hours per year. Any operation for non-emergency situations as allowed by paragraph I.2.c. count as part of the 100 hours per calendar year allowed by this paragraph [40 CFR 60.4211(f)(2)(i)] c. Non-emergency Situations. These engines may be operated for up to 50 hours per calendar year in non- emergency situations. The 50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year for maintenance and testing and emergency demand response provided in paragraph b., above. The 50 hours per year for non-emergency situations cannot be used for peak shaving or non-emergency demand response, or to generate income for a facility to supply power to an electric grid or otherwise supply power as part of a financial arrangement with another entity. [40 CFR 60.4211(f)(3)]. Emissions Standards I.3. NMHC + NOX Emissions. Emissions of non-methane hydrocarbons plus nitrogen oxide shall not exceed 6.4 grams per kilowatt-hour (g/KW-hr). [40 CFR 60.4202 and 40 CFR 89.112- Table 1] American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 62 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection I. Emissions Unit No. 009, Stationary Emergency Generator I.4. CO Emissions. Emissions of carbon monoxide shall not exceed 3.5 g/KW-hr. [40 CFR 60.4202 and 40 CFR 89.112- Table 1] I.5. PM emissions. Emissions of particulate matter shall not exceed 0.20 g/KW-hr. [40 CFR 60.4202 and 40 CFR 89.112- Table 1] Monitoring Requirements I.6. Hour Meter. The owner or operator must install a non-resettable hour meter on the CI RICE if one is not already installed. [40 CFR 60.4209(a)] Testing and Compliance Requirements I.7. Operation and Maintenance. The owner or operator must operate and maintain the CI RICE according to the manufacturer's written instructions. In addition, owners and operators may only change those settings that are permitted by the manufacturer. These RICE must be maintained and operated to meet the emissions limits in Specific Conditions I.3. through I.5. over the entire life of the engine. [40 CFR 60.4206 & 4211(a)] I.8. Compliance Requirements Due to Loss of Certification. If you do not install, configure, operate, and maintain your engine and control device according to the manufacturer's emission-related written instructions, or you change emission-related settings in a way that is not permitted by the manufacturer, you must keep a maintenance plan and records of conducted maintenance and must, to the extent practicable, maintain and operate the engine in a manner consistent with good air pollution control practice for minimizing emissions. In addition, if you do not install and configure the engine and control device according to the manufacturer's emission-related written instructions, or you change the emission-related settings in a way that is not permitted by the manufacturer, you must conduct an initial performance test to demonstrate compliance with the applicable emission standards within 1 year of such action. I.9. Testing Requirements. In the event performance tests are required pursuant to Specific Condition I.8., the following requirements shall be met: a. Testing Procedures. The performance test must be conducted according to the in-use testing procedures in 40 CFR Part 1039, Subpart F. b. NTE Standards. Exhaust emissions from these engines must not exceed the not-to-exceed (NTE) numerical requirements, rounded to the same number of decimal places as the applicable standard (STD) in Specific Conditions I.3 through I.5, determined from the following equation: NTE Requirement For Each Pollutant = (1.25) x (STD) (Eq. 1) [40 CFR 60.4212(a) & (c) I.10. Common Testing Requirements. Unless otherwise specified, tests shall be conducted in accordance with the requirements and procedures specified in Appendix TR, Facility-Wide Testing Requirements, of this permit. [Rule 62-297.310, F.A.C.] Records and Reports I.11. Testing Notification. At such time that the requirements of Specific Conditions I.8 and I.9. become applicable, the owner or operator shall notify the compliance authority of the date by which the initial compliance test must be performed. [Rule 62-213.440(1), F.A.C] I.12. Hours of Operation Records. The owner or operator must keep records of the operation of the engine in emergency and non-emergency service that are recorded through the non-resettable hour meter. The owner or operator must record the time of operation of the engine and the reason the engine was in operation during that time. [40 CFR 60.4214(b)] I.13. Maintenance Records. To demonstrate conformance with the manufacturer’s written instructions for maintaining the certified engine and to document when compliance testing must be performed pursuant to Specific Condition I.8., the owner or operator must keep the following records: a. Engine manufacturer data indicating compliance with the standards. American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 63 of 64 SECTION III. EMISSION UNITS AND SPECIFIC CONDITIONS. Subsection I. Emissions Unit No. 009, Stationary Emergency Generator b. A copy of the manufacturer’s written instructions for operation and maintenance of the certified engine. c. A written maintenance log detailing the date and type of maintenance performed on the engine, as well as, any deviations from the manufacturer’s written instructions. [Rule 62-213.440(1), F.A.C.; and, 40 CFR 60.4211(c) & (g)] Table of Contents American Cement Company, LLC Permit No. 1190042-016-AV Sumterville Cement Plant Title V Air Operation Permit Revision Page 64 of 64 ATTACHMENT F FACILITY MODELING INVENTORY (electronic excel spreadsheet) 106 ATTACHMENT G FACILITY EMISSIONS SUMMARY (electronic excel spreadsheet) 107 ATTACHMENT H EPA WHITE PAPER ON GHG BACT 108 Office of Air and Radiation October 2010 ______ AVAILABLE AND EMERGING TECHNOLOGIES FOR REDUCING GREENHOUSE GAS EMISSIONS FROM THE PORTLAND CEMENT INDUSTRY Available and Emerging Technologies for Reducing Greenhouse Gas Emissions from the Portland Cement Industry Prepared by the Sector Policies and Programs Division Office of Air Quality Planning and Standards U.S. Environmental Protection Agency Research Triangle Park, North Carolina 27711 October 2010 Table of Contents I. Introduction...... 3 II. Purpose of This Document...... 3 III. Description of the Cement Manufacturing Process ...... 3 IV. Summary of Control Measures ...... 7 V. Energy Efficiency Improvements to Reduce GHG Emissions...... 16 A. Energy Efficiency Improvements in Raw Material Preparation...... 17 B. Energy Efficiency Improvements in Clinker Production...... 19 C. Energy Efficiency Improvements in Finish Grinding...... 27 D. Energy Efficiency Improvements in Facility Operations ...... 28 VI. Raw Material Substitution to Reduce GHG Emissions ...... 30 VII. Blended Cements to Reduce GHG Emissions...... 32 VIII. Carbon Capture and Storage ...... 34 IX. Other Measures to Reduce GHG Emissions...... 39 X. EPA Contacts...... 41 XI. References...... 41 Appendix A...... 44 2 Abbreviations and Acronyms € euro °C degrees Celsius °F degrees Fahrenheit AC alternating current ANSI American National Standards Institute ASTM American Society for Testing and Materials ASU Air Separation Unit BACT best available control technology Btu British thermal unit C3S tricalcium silicate CaO calcium oxide CH4 methane CO carbon monoxide CO2 carbon dioxide De-NOx a NOx removal process DOE U.S. Department of Energy EnMS Energy Management Systems EPA U.S. Environmental Protection Agency EPI Energy Performance Indicator ft feet ft3 cubic foot GHG greenhouse gas GJ gigaJoule Hr hour ISO International Standards Organization Kcal kilocalories Kg kilogram Kt kilotonnes kWh kilowatt hour LD Long dry M meter(s) MMBtu million British thermal units 2 Abbreviations and Acronyms (continued) MEA Monoethanolamine MJ megaJoule MW megawatts Nm3 normal cubic meter NO2 nitrogen dioxide NOx nitrogen oxides ORC organic Rankin cycle PH preheater PH/PC preheater/precalciner PM particulate matter PSD prevention of significant deterioration scf standard cubic feet SO2 sulfur dioxide TBD To be determined tpy tons per year UK United Kingdom yr year 2 I. Introduction This document is one of several white papers that summarize readily available information on control techniques and measures to mitigate greenhouse gas (GHG) emissions from specific industrial sectors. These white papers are solely intended to provide basic information on GHG control technologies and reduction measures in order to assist States and local air pollution control agencies, tribal authorities, and regulated entities in implementing technologies or measures to reduce GHGs under the Clean Air Act, particularly in permitting under the prevention of significant deterioration (PSD) program and the assessment of best available control technology (BACT). These white papers do not set policy, standards or otherwise establish any binding requirements; such requirements are contained in the applicable EPA regulations and approved state implementation plans. II. Purpose of this Document This document provides information on control techniques and measures that are available to mitigate greenhouse gas (GHG) emissions from the cement manufacturing sector at this time. Because the primary GHG emitted by the cement industry is carbon dioxide (CO2), the control technologies and measures presented in this document focus on this pollutant. While a large number of available technologies are discussed here, this paper does not necessarily represent all potentially available technologies or measures that that may be considered for any given source for the purposes of reducing its GHG emissions. For example, controls that are applied to other industrial source categories with exhaust streams similar to the cement manufacturing sector may be available through “technology transfer” or new technologies may be developed for use in this sector. The information presented in this document does not represent U.S. EPA endorsement of any particular control strategy. As such, it should not be construed as EPA approval of a particular control technology or measure, or of the emissions reductions that could be achieved by a particular unit or source under review. III. Description of the Cement Manufacturing Process Cement is a finely ground powder which, when mixed with water, forms a hardening paste of calcium silicate hydrates and calcium aluminate hydrates. Cement is used in mortar (to bind together bricks or stones) and concrete (bulk rock-like building material made from cement, aggregate, sand, and water). By modifying the raw material mix and the temperatures utilized in manufacturing, compositional variations can be achieved to produce cements with different properties. In the U.S., the different varieties of cement are denoted per the American Society for Testing and Materials (ASTM) Specification C-150. Cement is produced from raw materials such as limestone, chalk, shale, clay, and sand. These raw materials are quarried, crushed, finely ground, and blended to the correct chemical composition. Small quantities of iron ore, alumina, and other minerals may be added to adjust the raw material composition. The fine raw material is fed into a large rotary kiln (cylindrical 3 furnace) which rotates while the contents are heated to extremely high temperatures. The high temperature causes the raw material to react and form a hard nodular material called “clinker”. Clinker is cooled and ground with approximately 5 percent gypsum and other minor additives to produce Portland cement. The heart of clinker production is the rotary kiln where the pyroprocessing stage occurs. The rotary kiln is approximately 20 to 25 feet (ft) in diameter and from 150 ft to well over 300 ft long; the kiln is set at a slight incline and rotates one to three times per minute. The kiln is most often fired at the lower end (sometimes, mid-kiln firing is used and new units incorporate preheating as well as precalcining), and the raw materials are loaded at the upper end and move toward the flame as the kiln rotates. The materials reach temperatures of 2500°F to well above 3000°F in the kiln. Rotary kilns are divided into two groups, dry-process and wet-process, depending on how the raw materials are prepared. In wet-process kilns, raw materials are fed into the kiln as a slurry with a moisture content of 30 to 40 percent. To evaporate the water contained in the feedstock, a wet-process kiln requires additional length (in comparison to a dry kiln). Additionally, to evaporate the water contained in the slurry, a wet kiln consumes nearly 33 percent more kiln energy when compared to a dry kiln. Wet-process kilns tend to be older operations as compared to dry-processes where raw materials are fed into the process as a dry powder. There are three major variations of dry- process kilns in operation in the U.S.: long dry (LD) kilns, preheater (PH) kilns, and preheater/precalciner (PH/PC) kilns. In PH kilns and PH/PC kilns, the early stages of pyroprocessing occur before the materials enter the rotary kiln. PH and PH/PC kilns tend to have higher production capacities and greater fuel efficiency compared to other types of cement kilns. Table 1 shows typical average required heat input by cement kiln type. Table 1. Typical Average Heat Input by Cement Kiln Type Heat Input, Kiln Type MMBtu/ton of cement Wet 5.5 Long Dry 4.1 Preheater 3.5 Preheater/Precalciner 3.1 Source: EPA, 2007a (Table 3-3) Three important processes occur with the raw material mixture during pyroprocessing. First, all moisture is driven from the materials. Second, the calcium carbonate in limestone dissociates into CO2 and calcium oxide (free lime); this process is called calcination. Third, the lime and other minerals in the raw materials react to form calcium silicates and calcium aluminates, which are the main components of clinker. This third step is known as clinkering or sintering. The formation of clinker concludes the pyroprocessing stage. Once the clinker is formed in the rotary kiln, it is cooled rapidly to minimize the formation of a glass phase and ensure the maximum yield of alite (tricalcium silicate) formation, 4 an important component for the hardening properties of cement. The main cooling technologies are either the grate cooler or the tube or planetary cooler. In the grate cooler, the clinker is transported over a reciprocating grate through which air flows perpendicular to the flow of clinker. In the planetary cooler (a series of tubes surrounding the discharge end of the rotary kiln), the clinker is cooled in a counter-current air stream. Reciprocating type grate coolers can also be used to cool the clinker. The cooling air is used as secondary combustion air for the kiln to improve efficiency since the cooling air has been preheated during the process of cooling the clinker. After cooling, the clinker can be stored in the clinker dome, silos, bins, or outside in storage piles. The material handling equipment used to transport clinker from the clinker coolers to storage and then to the finish mill is similar to that used to transport raw materials (e.g. belt conveyors, deep bucket conveyors, and bucket elevators). To produce powdered cement, the nodules of clinker are ground to the consistency of powder. Grinding of clinker, together with additions of approximately 5 percent gypsum to control the setting properties of the cement can be done in ball mills, ball mills in combination with roller presses, roller mills, or roller presses. While vertical roller mills are feasible, they have not found wide acceptance in the U.S. Coarse material is separated in a classifier that is re-circulated and returned to the mill for additional grinding to ensure a uniform surface area of the final product. (Coito et al., 2005, and others.) Figure 1 presents a diagram of the cement manufacturing process using a rotary kiln and cyclone preheater configuration. The schematic for a rotary kiln and precalciner configuration is very similar to that shown in Figure 1, with a calciner vessel located between the rotary kiln and cyclone preheater. Combustion for heat generation may occur in the riser to the preheater, in the calciner and/or in the kiln. These combustion processes are one of two primary sources of GHG emissions, the second being the calcinations reaction that occurs in the kiln. These GHG sources are the focus of the control measures presented in the remainder of this document. Total combustion and process-related GHG emissions from 2006 cement production, including methane (CH4)and nitrous oxide (N2O) emissions from fossil fuel combustion based on plant-specific characteristics were estimated to be 95.5 tons (86.8 million metric tons) of CO2 equivalents (MTonne CO2e). (EPA, 2007b) This is equivalent to 0.98 tons of CO2e per ton of clinker, of which 0.46 tons are attributable to fuel combustion. Combustion emissions include CO2, N2O and CH4 emissions that result from the combustion of carbon-based fuels in the cement kiln and other onsite combustion equipment. The cement kiln is the most significant of these combustion units and typically is fueled with coal. Other fossil fuels are generally too expensive to be used for kiln fuel; however carbon-based waste materials (e.g., solvents, oils, and waste tires) are commonly combusted in the kilns to dispose of the waste, and make use of their energy content. The other sources of CO2 emissions stemming from cement manufacturing operations include transportation equipment used in the mining and transport of raw and finished materials and the fuels required for operating the process. The direct CO2 emission intensity of fuels depends on the carbon content of the fuel which varies by type of fuel and further may vary within a given fuel type. The emission intensity of coals, for example, will vary depending on its geologic source. Table 2 shows the CO2 emission intensity in pounds per million British Thermal Units (lb/MMBtu) for fuels combusted at cement kilns in the United States. 5 Figure 1. Diagram for Cement Manufacturing Preheater Process Source: CEMBUREAU, 1999 6 Table 2. CO2 Emission Intensity (lb CO2/MMBtu) for Fuels Combusted at Cement Kilns CO2 Emission Intensity (lb/MMBtu) Natural Western Sub- Eastern Bituminous Heavy Fuel Oil Tires Petroleum Coke Gas bituminous Coal1 Coal2 105.02 169.32 186.83 187.44 199.52 212.56 1 Origin - Rosemont Powder River Basin 2 Origin - Logan, West Virginia Source: Staudt, 2008a Process-related CO2 emissions from cement production are the second largest source of industrial CO2 emissions in the United States. (EPA, 2008) The cement production process comprises the following two steps: (i) clinker production and (ii) finish grinding. Essentially all GHG emissions from cement manufacturing are CO2 emissions from clinker production. There are no CO2 emissions from the finish grinding process, during which clinker is ground finely with gypsum and other materials to produce cement. However, CO2 emissions are associated with the electric power consumed by plant equipment such as the grinders. IV. Summary of Control Measures This document addresses the cement manufacturing sector and summarizes readily available information on control techniques and measures to mitigate greenhouse gas emissions from this sector. Because the primary GHG emitted by the cement industry is CO2, the control technologies and measures presented here focus on this pollutant. In general, emissions of CO2 from the cement manufacturing sector can be reduced by: • Improving the energy efficiency of the process, • Shifting to a more energy efficient process (e.g. from wet and long dry to preheater/precalciner process), • Replacing high carbon fuels with low carbon fuels, • Applying lower clinker/cement ratio (increasing the ratio additives/cement): blended cements, and/or • Removing CO2 from the flue gases. These options will be discussed in the remainder of this document. Much of the original data used in this document were in different units. . To facilitate comparisons of costs and efficiencies for the various control measures, units were converted to English or International System of Units (SI_ units when possible. Also, many measures were expressed in units per ton of raw feed to the kiln, clinker production or cement production. Again for the sake of comparison, values were converted to values per short ton of cement. Conversions used in this process were as follows: 1.65 tons of raw feed/ton of clinker, 0.92 tons of clinker/ton of cement, and 1.52 tons of raw feed/ton of cement. Costs of control measures expressed in euros (€) were converted to dollars ($) assuming $1.50/€. Table 3 summarizes the CO2 control measures presented in this document. Where available, the table includes the emission reduction potential, energy savings, costs, and feasibility of each measure. 7 Table 3. Portland Cement Manufacturing Sector– Summary of Greenhouse Gas Control Measuresa, b Control Emission Energy Operating Demonstrated Technology Reduction Savings Capital Costs Costs Applicability in Practice? Other factors Energy Efficiency Improvements in Raw Material Preparation Switch from Calculated from 2.9 kWh/ton $4.1/annual ton NA New and Existing Yes pneumatic to energy savings cement cement capacity Facilities with mechanical raw LD, PH, PH/PC material transport kilns Use of belt Calculated from 2.5 kWh/ton $3.43/ton cement Reduction of New and Existing Yes conveyors and energy savings cement capacity $0.17/ton Facilities bucket elevators cement instead of pneumatics Convert raw meal Calculated from 1.4-3.5 $5.0/ton cement NA New and Existing Yes blending silo to energy savings kWh/ton Capacity (silo Facilities gravity-type cement retrofit) homogenizing Improvements in Calculated from 1.0 kWh/ton $2.5/ton cement Increase of New and Existing Yes May increase raw material energy savings cement capacity $0.02/ton Facilities with production by up blending cement LD, PH, PH/PC to 5% kilns Replace ball mills Calculated from 9-11 kWh/ton $7.6/ton cement NA New and Existing Yes with high energy savings cement capacity Facilities efficiency roller mills Replace ball mills 14-22 lb CO2/ton 11-15 kWh/ton $33/ton cement Reduction of New and Existing Yes with vertical roller cement cement capacity $0.17/ton Facilities mills cement High Efficiency 4-6 lb CO2/ton 3.8-5.2 $3/annual ton NA New and Existing Yes May increase Classifiers cement kWh/ton cement capacity Facilities grinding mill cement capacity 8 Control Emission Energy Operating Demonstrated Technology Reduction Savings Capital Costs Costs Applicability in Practice? Other factors Roller mill for fuel Calculated from 7-10 kWh/ton Cost of roller Reduction of as New and Existing Yes (coal) preparation energy savings coal mill is higher much as 20- Facilities instead of impact than impact or 50% or tube mill tube mill Energy Efficiency Improvements in Clinker Production Process control 7-33 lb CO2/ton 2.5-5% or $0.3/annual ton NA New and Existing Yes and management cement and 1.3 lb 42-167 MJ/ton cement capacity Facilities. All systems CO2/ton cement cement and kilns. from electricity electricity usage reduction savings of 1 kWh/ton cement Replacement of Calculated from 0.4% or 0.01 NA NA New and Existing Yes kiln seals energy savings MMBtu/ton Facilities. All cement kilns. Kiln combustion Calculated from 2-10% $0.8/annual ton NA New and Existing Yes May result in up system energy savings reduction in cement capacity Facilities. All to 10% increase improvements fuel usage kilns. in kiln output Fluxes and 9-30 lb CO2/ton 42-150 MJ/ton NA Fuel savings New and Existing Yes mineralizers to cement and 0-2 cement may be offset Facilities. All reduce energy lb/ton cement by cost of kilns. demand from electricity fluxes and usage reduction mineralizers Kiln/preheater Calculated from 0.1-0.31 $0.21/annual ton NA New and Existing Yes insulation energy savings MMBtu/ton cement capacity PH and PH/PC (internal) cement kilns Kiln/preheater Calculated from 17 Btu/ton $0.25/ton cement NA New and Existing Yes insulation energy savings cement capacity PH and PH/PC (external) kilns Refractory Calculated from 49,800 Btu/ton $0.50/ton cement NA All kilns Yes material selection energy savings cement capacity 9 Control Emission Energy Operating Demonstrated Technology Reduction Savings Capital Costs Costs Applicability in Practice? Other factors Replacement of Reduction of17- Reduce energy NA NA New and Existing Yes planetary and 52 lbCO2/ton consumption by kilns with travelling grate cement, but 8% or 84-251 capacity > 500 cooler with increase of 2-6 MJ/ton cement; tonnes/day reciprocating grate lb/ton cement increase cooler from increased electricity use electricity use by 1-5 kWh/ton cement Heat recovery for Calculated from Produce 7-20 $2-4/annual ton $0.2-0.3/annual LD kilns Yes power – energy savings kWh/ton cement capacity ton cement cogeneration cement capacity Suspension Up to 2 lb 0.5-0.6 $2.5-2.9/annual NA New and Yes May result in up preheater low CO2/ton cement kWh/ton ton cement retrofitting PH to 3% production pressure drop cement per 50 capacity and PH/PC kilns increase cyclones mm water column pressure reduction Multistage Calculated from 0.4 MMBtu/ton $12.8-34/annual NA New and Yes May increase preheater energy savings cement ton cement retrofitting PH kiln capacity by capacity and PH/PC kilns up to 50% Conversion from 50-460 lb 1.1 MMBtu/ton $7.9-96/ annual Decrease by LD kilns Yes Actual values are long dry kiln to CO2/ton cement cement ton cement $0.08/ton highly site preheater/ capacity cement specific precalciner kiln Kiln drive Calculated from 0.5 kWh/ton Increased by Reduced power New and Existing Yes efficiency energy savings cement about 6% cost for kiln Facilities. improvements drive by 2-8% Adjustable speed Calculated from 5 kWh/ton NA NA New and Existing Yes drive for kiln fan energy savings cement Facilities. 10 Control Emission Energy Operating Demonstrated Technology Reduction Savings Capital Costs Costs Applicability in Practice? Other factors Oxygen 18-37 lb CO2/ton NA NA NA All Kilns Yes May increase enrichment cement; however, production by 3- this may be 7%. May completely offset increase NOx by increased emissions. electricity consumption Mid kiln firing Calculated from NA NA NA Existing Wet, LD Yes Burning tires the emission kilns may result in factor of tires lower NOx compared to fuel emissions being replaced Air mixing Calculated from Improves $520,000 Increases TBD Yes Likely reduces technology fuel reduction combustion electricity usage CO, NOx, and efficiency by 0.23 SO2 emissions reducing fuel kWh/ton use cement Preheater riser Ph and PH/PC duct firing kilns Energy Efficiency Improvements in Finish Grinding Improved ball Calculated from 6-25 kWh/ton $2.3-7.3/annual May reduce by Existing and New Yes mills energy savings cement ton cement 30-40%, but Facilities. All capacity; or vertical roller kilns. $35/ton cement mill may capacity for a increase costs vertical roller by $0.17/ton mill cement 11 Control Emission Energy Operating Demonstrated Technology Reduction Savings Capital Costs Costs Applicability in Practice? Other factors High efficiency Calculated from 1.7-2.3 $2/annual ton $0.045/ton Existing and New Yes May increase classifiers energy savings kWh/ton cement cement Facilities. All production by up cement, but kilns. to 25% could be as high as 6 kWh/ton cement Energy Efficiency Improvements in Facility Operations High efficiency Calculated from 5%, or about 5 $0.67/ton cement No change Existing and New Yes motors energy savings kWh/ton clinker Facilities. All kilns. Variable speed 3-10 lb CO2/ton 3-8 kWh/ton NA NA Existing and New Yes Capital and drives cement cement Facilities. All operating cost kilns. savings are highly site specific High efficiency Calculated from 0.9 kWh/ton $0.46/ton cement NA Existing and New Yes fans energy savings cement Facilities. All kilns. Optimization of Calculated from Up to 20% NA NA Existing and New Yes compressed air energy savings Facilities. All systems kilns. Lighting system Calculated from 12-50% NA NA Existing and New Yes efficiency energy savings depending on Facilities. All improvements specific kilns. changes made 12 Control Emission Energy Operating Demonstrated Technology Reduction Savings Capital Costs Costs Applicability in Practice? Other factors Raw Material Substitution Decarbonated 0.02-0.51 ton 1.12 $0.75/ton cement Increased by All Facilities Yes Energy savings feedstocks (steel CO2/ton material MMBtu/ton for steel slag fed $0.08/ton may be offset by slag or fly ash) cement; or into kiln without cement for steel 0.08 MBtu/ton to 0.07-1.59 grinding slag fed into dry feedstock MMBtu/ton kiln without material grinding Calcereous oil 0.009 lb CO2/ton 0.07 $1/ton cement Increase by All Facilities Yes shale cement MMBtu/ton when replacing $0.08/ton cement 8% of raw meal cement when replacing 8% of raw meal Blended Cements Cementitious 200-860 lb 380- NA NA All Facilities Yes In general, the materials CO2/ton cement 1710MJ/ton use of 1 ton of for cement with cement for material reduces 30-70% blast cement with 30- emissions by the furnace slag 70% blast amount furnace slag generated to produce 1 ton clinker Pozzolanic 100-280 lb 200-500 MJ/ton NA NA All Facilities Yes Cost savings of materials CO2/ton cement cement cement replaced must be balanced against the cost of the material Carbon Capture Calera process 90%, but varies Parasitic load of $950/kW for NA TBD Pilot testing Pilot testing is with specific 10-20 of the coal-fired power on power plants application power plant plant 13 Control Emission Energy Operating Demonstrated Technology Reduction Savings Capital Costs Costs Applicability in Practice? Other factors Oxy-combustion 1000-1600 lb Overall energy NA NA TBD No No installations CO2/ton cement, requirements at cement plants; but increased decrease by 75- many technical electricity usage 84 MJ/ton issues to could generate cement, but overcome 110-150 CO2/ton electricity cement requirements increase by 92- 96 kWh/ton cement Post-combustion Up to 95% NA NA NA TBD Yes, but not at solvent capture cement plants and stripping Post-combustion Up to 80% NA NA NA TBD No, currently membranes in research stage Superheated CaO Up to 43% NA NA NA TBD No, currently in research stage Other Control Measures Fuel switching 18% for NA NA NA All Facilities Yes Does not affect switching from emissions from coal to heavy oil; calcination 40% for reaction switching from coal to natural gas Alternative fuels – Depends on NA NA NA All Facilities Certain biomass emission factor biomass of biomass materials have compared to fuel been used being replaced 14 Control Emission Energy Operating Demonstrated Technology Reduction Savings Capital Costs Costs Applicability in Practice? Other factors Hybrid solar plants Equivalent to NA NA NA TBD No, currently emissions that in research would have been stage generated by fuel replaced Syngas co- Up to 650 lb NA NA NA TBD No, but has production CO2/ton cement been applied to smaller streams Power 830-1300 lb NA NA NA TBD No, currently plant/cement plant CO2/ton cement in research carbonate looping stage a References for the information in this table are contained in the subsequent discussions of control measures. b TBD = to be determined; NA = data not available at this time 15 V. Energy Efficiency Improvements to Reduce GHG Emissions The cement manufacturing process is highly energy intensive. Thus, a primary option to reduce GHG emissions is to improve energy efficiency. Industrial energy efficiency can be greatly enhanced by effective management of the energy used by operations and processes. U.S. EPA’s ENERGY STAR Program works with hundreds of U.S. manufacturers and has seen that companies and sites with stronger energy management programs gain greater improvements in energy efficiency than those that lack procedures and management practices focused on continuous improvement of energy performance. Energy Management Systems (EMSs) provide a framework to manage energy and promote continuous improvement. The EMSs provides structure for an energy program. EMSs establish assessment, planning, and evaluation procedures which are critical for actually realizing and sustaining the potential energy efficiency gains of new technologies or operational changes. Approaches to implementing EnMS vary. EPA’s ENERGY STAR Guidelines for Energy Management are available for public use on the web and provide extensive guidance (see: www.energystar.gov/guidelines). Alternatively, energy management standards are available for purchase from ANSI (ANSI MSE 2001:200) and in the future from ISO (ISO 50001). For nearly 10 years, the U.S. EPA’s ENERGY STAR Program has promoted an energy management system approach. The U.S. EPA’s ENERGY STAR Program (www.energystar.gov/industry) and U.S. Department of Energy’s (DOE’s) Industrial Technology Program (www.energy.gov/energyefficiency) have led industry specific energy efficiency initiatives over the years. These programs have helped to create guidebooks of energy efficient technologies, profiles of industry energy use, and studies of future technology. Resources from these programs can help to identify technology that may help reduce GHG emissions generated by the cement manufacturing sector. Cement plants can measure their improvements in energy efficiency either against themselves or against the performance of the entire industry. This type of plant energy benchmarking is typically done at a whole-facility, or site, level in order to capture the synergies of different technologies, operating practices, and operating conditions. Benchmarking enables companies to set informed and competitive goals for plant energy improvement and also helps companies prioritize investment to improve the performance of lowest performing processes while learning from the approaches used by the best performing processes. When benchmarking is conducted across an industrial sector, a benchmark can be established that defines best-in-class energy performance. The U.S. EPA’s ENERGY STAR Program has developed benchmarking tools that establish best in class for specific industrial sectors. These tools, known as Plant Energy Performance Indicators (EPI) are established for specific industrial sectors and are available for free at www.energystar.gov/industrybenchmarkingtools. Using several basic plant specific inputs, the EPIs calculate a plant’s energy performance providing a score from 0-100. EPA defines the average plant within the industry nationally at the score of 50; energy-efficient plants score 75 or better. ENERGY STAR offers recognition for sites that score in the top quartile of energy efficiency for their sector using the EPI. 16 The remainder of this section summarizes available and emerging CO2 control technologies and/or measures for the cement sector. For many of the control technologies and/or measures listed in this section, CO2 emission reductions are not explicitly provided. Energy efficiency improvements lead to reduced fuel consumption in the kiln system, and/or reduce electricity demand. Thus, where CO2 emission reductions are not provided, these reductions can be calculated from the reduction of fuel used by the kiln system. For facilities that produce their own electricity, emission reductions that result from reduced electricity usage can be calculated from the reduced amount of fuel consumed at their power plant (if fuel combustion rather than waste heat is used for this purpose). The Portland Cement Association (PCA, 2008) provides a discussion on most of the efficiency measures presented in this section, particularly addressing technical feasibility. Staudt (2009) provides a means of estimating the capital costs for the energy efficiency measures using the following equation: Capital Costs ($2008) = Scale-Up Factor x (tons/yr cement capacity)0.6 The scale-up factors are provided in Table 1 of Staudt (2009) and cover a variety of different kiln types (see Appendix A). A. Energy Efficiency Improvements in Raw Material Preparation Transport System Efficiency Improvements Pneumatic and mechanical conveyor systems are used throughout cement plants to convey kiln feed, kiln dust, finished cement, and fuel. Mechanical systems typically use less energy than pneumatic systems, and switching to mechanical conveyor systems can save 2.9 kWh/ton of cement. Installation costs for the mechanical conveyor systems are estimated to be $4.1/ton of cement. (Worrell and Galitsky, 2008) Installation of belt conveyors and bucket elevators may result in investment costs of $3.43/ton cement and reduce operating costs by $0.17/ton cement. Additionally, power consumption may decrease by 2.5 kWh/ton cement. (Hollingshead and Venta, 2009) New facilities should be able to use mechanical conveyors unless there is a design consideration that precludes their use or makes pneumatic systems a more viable choice. For existing facilities, the conversion from pneumatic systems to mechanical systems may be cost- effective due to increased reliability and reduced downtime. (Worrell and Galitsky, 2008) 17 Raw Meal Blending The raw meal, or kiln feed material, is comprised of a number of ingredients. To optimize the clinker production process in the kiln, the raw meal must be mixed thoroughly to form a homogenous mixture. The mixing may occur in an air fluidized silo or a mechanical system that simultaneously withdraws material from several storage silos. Alternatively, gravity- type homogenizing silos may be used to reduce energy consumption. The gravity-type silos may reduce energy consumption by 1.4 – 3.5 kWh/ton cement. Silo retrofit costs have been estimated to be $5.0/ton cement. This estimate assumed a capital cost of $550,000 per silo having a capacity of 165,000 tons/yr. (Worrell and Galitsky, 2008) Improvements in blending of raw materials may reduce energy requirements by16,700 Btu/ton cement and reduce power consumption by 1.0 kWh/ton cement. Production may increase by about 5 percent. Investment costs were estimated to be $2.50/ton cement and operating cost may increase by $0.02/ton cement. (Hollingshead and Venta, 2009) Gravity-type silos appear to be most commonly used in new construction. Rather than constructing entirely new silos systems, modifications at existing facilities may be cost effective when the silo can be partitioned with air slides and divided into compartments which are sequentially agitated. (Worrell and Galitsky, 2008) High Efficiency Roller Mills Older facilities may use ball mills for grinding raw materials. Higher efficiency options for ball mills include high efficiency roller mills, ball mills combined with high pressure roller presses, or horizontal roller mills. The use of the more efficient grinding methods may reduce energy consumption by 9 – 11 kWh/ton cement. Retrofit costs are estimated to be $7.6/ton cement. (Worrell and Galitsky, 2008) Replacing older ball mills with vertical roller mills or high pressure grinding rolls can reduce the electricity demand of the grinding operation from 11 – 15 kWh/ton cement, which may reduce CO2 emissions related to the electricity generation from 14 – 22 lb/ton cement. (ECRA, 2009) Another study (Hollingshead and Venta, 2009) found that this option resulted in a power savings of 8.3 kWh/ton cement and reduced operating costs by $0.17/ton cement. Capital investment costs were estimated to be $33/ton cement capacity. Additional energy savings can be realized by combining a raw material drying step with vertical roller mills by utilizing waste heat from kilns or clinker coolers. (Worrell and Galitsky, 2008) High Efficiency Classifiers After grinding, classifiers and separators are used to separate particles by size, with the larger particles being returned to the grinder for further processing. Classifiers that have lower efficiencies return an excess of smaller particles back to the grinder that should have been allowed to pass to the next operation. This extra load on the grinder results in an increase in 18 energy consumption. Energy savings for using high efficiency classifiers is estimated to be 8 percent of the electricity usage of the grinder. (Worrell and Galitsky, 2008) Case studies have shown that operations modified to include a high efficiency classifier realized an energy savings of 3.8 – 5.2 kWh/ton cement. The modification may also lead to increased grinding mill capacity and improved product quality. Modification costs are estimated to be $3/ton cement production. (Worrell and Galitsky, 2008) Another study estimates the decrease in electricity demand as a result of installing high efficiency separators to be 4 kWh/ton cement, which may lead to CO2 emission reductions of 4 – 6 lb/ton cement. The investment costs of installing high efficiency separators at a new facility or retrofitting an existing facility are about $3.75 million, with an operating cost decrease (excluding depreciation, interest, and inflation) of about $0.38/ton cement. (ECRA, 2009) Fuel Preparation (Coal) – Roller Mills Facilities that use coal as a fuel typically include fuel preparation steps to crush, grind, and dry the coal. As discussed above, roller mills are typically more efficient than other grinding methods. For coal operations, roller mills consume about 16-18 kWh/short ton coal processed, compared to 45-60 kWh/short ton for an impact mill and 25-26 kWh/short ton for a tube mill. Thus, a roller mill may save 7-10 kWh/short ton coal over the use of a tube mill and save 27 – 44 kWh/ton coal over the use of an impact mill. Although capital costs are higher for a roller mill, the operating costs may be as much as 20 percent lower than tube mill and 50 percent lower than an impact mill. (Worrell and Galitsky, 2008) B. Energy Efficiency Improvements in Clinker Production Process Control and Management Systems Automated control systems can be used to maintain operating conditions in the kiln at optimum levels. Maintaining optimum kiln conditions leads to more efficient operation throughout the cement manufacturing process. Reported energy savings after installing such automated controls range from 2.5-10 percent, with typical results in the range of 2.5-5 percent. The cost to install an automated control system and to train operators at one facility was reported to be $0.3/annual ton cement. Payback periods are typically 2 years or less. (Worrell and Galitsky, 2008) ECRA (2009) reported that energy savings related to control systems compared to a kiln without a control system may range from 42-167 megajoules (MJ)/ton cement, and reduce electricity consumption up to 1 kWh/ton cement. The kiln energy savings may reduce CO2 emissions from 7 – 33 lb/CO2/ton cement, with an additional 1.3 lb CO2/ton cement coming from the decrease in electricity usage. There should be no barriers to installing control systems on new construction. Most existing facilities should be able to retrofit the clinker production operations to accommodate control systems. 19 Replacement of Kiln Seals Kiln seals are used at the inlet and outlet of the kiln to reduce heat loss and air penetration. Leaking seals can result in increased heat loss which increases fuel use. Replacement of kiln seals has been reported to reduce fuel consumption by 0.4 percent (0.01 MMBtu/ton cement) at one facility. The payback period for improved kiln seal maintenance is estimated to be 6 months or less. (Worrell and Galitsky, 2008) Improved kiln seal maintenance is generally applicable to existing facilities; however, the design of new facilities should consider the effectiveness and longevity of available kiln seals. All facilities should have a regular maintenance plan for the kiln seals. Kiln Combustion System Improvements As with any combustion system, inefficiencies may occur in the fuel combustion operation. Incomplete fuel burning, poor mixing of fuel with combustion air, and poorly adjusted firing can lead to increased fuel usage (as well as increased NOx and CO emissions). Reported fuel savings of 2-10 percent have been reported at cement plants that have instituted combustion optimization methods. (Worrell and Galitsky, 2008) A proprietary system called Gyro-Therm has been demonstrated at several cement plants to improve combustion and reduce fuel usage. The system is applicable to gas-fired and gas/coal-fired kilns and reportedly results in a 2.7-10 percent reduction in fuel usage and up to 10 percent increase in output of the kiln. Average costs of the system based on demonstration projects is $0.8/annual ton cement capacity (Worrell and Galitsky, 2008), and payback time is estimated to be less than one year. (FTC, 2009) New construction should consider available technologies to optimize kiln combustion. Existing systems can typically be retrofitted to incorporate optimization techniques. Use of Fluxes and Mineralizers to Reduce Energy Demand The use of fluxes and mineralizers can reduce the temperature at which the clinker melt begins to form in the kiln, promote formation of clinker compounds, and reduce the lower temperature limit of the tricalcium silicate stability range. All of these factors can reduce the fuel energy demand of the kiln. (ECRA, 2009) Fluorides are often used as a mineralizer and can reduce the sintering temperature by 190°F. Although there is a fuel savings, that savings may be offset by the high cost of the fluxing agent or mineralizer. (ECRA, 2009) Fluxing agents and mineralizers can reduce energy consumption by 42-150 MJ/ton cement. Additional electricity requirements, if any, may be up to 1 kWh/ton cement. Potential reductions in CO2 emissions range from 9-30 lb CO2/ton cement at the kiln and increases due to increased electricity usage range from 0-2 lb CO2/ton cement. (ECRA, 2009) 20 Kiln/Preheater Insulation Due to the large size of cement kilns, the amount of outer surface area of the kiln is very high, and significant heat loss can occur through the kiln shell. Proper insulation is important to keep these losses to a minimum. The refractory material lining the kiln is the primary insulating material. High temperature insulating linings for the kiln may reduce fuel usage by 0.1-0.31 MMBtu/ton cement. Costs of the refractory material have been estimated to be $0.21/ton cement capacity. (Worrell and Galitsky, 2008) The investment costs for external insulation on upper preheater vessels and on the cooler housing were estimated to be $0.25/ton cement and provide an energy savings of 17 Btu/ton cement. (Hollingshead and Venta, 2009) When replacing refractory materials at existing plants, structural considerations must be taken into account to assure that the kiln can support the weight of the new refractory material. New construction can account for the weight of the refractory material in the kiln design. Refractory Material Selection The refractory bricks lining the combustion zone of the kiln protect the outer shell from the high combustion temperatures, as well as chemical and mechanical stresses. Although the choice of refractory materials is highly dependent on fuels, raw materials, and operating conditions, consideration should be given to refractory materials that provide the highest insulating capacity and have the longest life. Although energy savings are difficult to quantify due to the unique conditions at each facility, some benefit will be realized from higher quality refractory materials. (Worrell and Galitsky, 2008) Investment costs of $0.50/ton cement for improved refractory materials in the kiln and preheater may reduce energy consumption by 49,800 Btu/ton cement. (Hollingshead and Venta, 2009) Grate Cooler Conversion Grate coolers are used to cool the clinker immediately after it exits the kiln. The grate cooler is integral to heat recovery from the clinker, so grate coolers that operate with higher efficiencies will lead to less wasted heat and reduce fuel usage elsewhere in the process. Both planetary and travelling grate coolers can be replaced with reciprocating grate coolers. (Worrell and Galitsky, 2008) Replacement of a planetary cooler with a reciprocating grate cooler can reduce kiln fuel consumption by as much as 8 percent, even though the reciprocating grate cooler has an increased power consumption of about 2.5 kWh/ton cement. However, the cost of the reciprocating cooler may be prohibitive for facilities with a capacity less than 550 tons/day. Planetary coolers do not allow tertiary heat recovery, which is required if a precalciner is used. 21 The conversion to a reciprocating grate cooler may be more economical for units that have or will have a precalciner installed as well. (Worrell and Galitsky, 2008) Another study also estimated the energy savings at the kiln to be about 8 percent, or 84 – 251 MJ/ton cement. The grate coolers, however, require an increase in electrical consumption of about 1 – 5 kWh/ton cement. The cost for conversion from a planetary cooler to a reciprocating grate cooler with a capacity of 6,600 tons/day is estimated to be $22.5-30 million. The actual costs can vary significantly based on site specific conditions. Retrofitting an older grate cooler to a modern reciprocating grate cooler is estimated to be $1.5-4.5 million. (ECRA, 2009) Hollingshead and Venta (2009) estimated that installing a complete new grate cooler would have an investment cost of $8/ton cement and reduce energy consumption by 0.22 MMBtu/ton cement. Power consumption would increase by 3 kWh/ton cement and operating costs would increase by $0.17/ton/cement. Production would increase by about 20 percent. Emission reductions of CO2 due to the lower kiln fuel requirements may range from 17 – 52 lb/CO2/ton cement. The increase in electrical power usage could result in an increase in CO2 emissions from power generation operations. The associated increase due to electrical usage may range from 2 – 6 lb CO2/ton cement. (ECRA, 2009) Heat Recovery for Power – Cogeneration There are several exhaust streams in the cement manufacturing operation that contain significant amounts of heat energy, including the kiln exhaust, clinker cooler, and kiln preheater and precalciner. In certain cases, it may be cost effective to recover a portion of the heat in these exhaust streams for power generation. Power generation can be based on a steam cycle or an organic Rankin cycle (i.e., the conversion of heat into work). In each case, a pressurized working fluid (water for the steam cycle or an organic compound for the organic Rankin cycle) is vaporized by the hot exhaust gases in a heat recovery boiler, or heater, and then expanded through a turbine that drives a generator. Based on the heat recovery system and the kiln technology, 7-8 kWh/ton cement can be produced from hot air from the clinker cooler, and 8- 10kWh/ton cement from the kiln exhaust. (ECRA, 2009) Total power generation can range from 7-20 kWh/ton cement. Steam turbine heat recovery systems were developed and first implemented in Japan and are being widely adopted in Europe and China. Installation costs for steam systems range from $2-4/annual ton cement capacity with operating costs ranging from $0.2-0.3/annual ton cement capacity. (Worrell and Galitsky, 2008; ECRA, 2009) Generally, only long dry kilns produce exhaust gases with temperatures high enough to make heat recovery for power economical. Heat recovery installations in Europe and China have included long dry kilns with preheaters. Heat recovery for power may not be possible at facilities with in-line raw mills where the waste heat is used to extensively dry the raw materials; it is usually more economic and efficient to use the exhaust heat to reduce the moisture content of raw materials with very high moisture. (Worrell and Galitsky, 2008) It is possible to meet 25-30 percent of the plants total electrical needs through this type of cogeneration. As an example, a 4,100 ton/day cement plant in India, installed a waste heat 22 recovery power plant using the exhaust from the preheaters and clinker cooler. The power plant was rated at 8 megawatts (MW). Capital investment was $18.7 million, and CO2 emission reductions were reported to be 49,000/yr. (PCA, 2008) Suspension Preheater Low Pressure Drop Cyclones Cyclones are used to preheat the raw meal prior to the kiln. Exhaust gases from the kiln or clinker cooler are routed to the cyclone and provide the heat to preheat the raw meal suspended or residing in the cyclone. The larger the pressure drop losses in the cyclone, the greater the energy requirements for the kiln or clinker cooler exhaust fan. One study estimated that the energy savings resulting from installing low pressure drop cyclones is 0.5 – 0.6 kWh/ton cement for each 50 mm water column the pressure drop is reduced. One facility realized a savings of 4 kWh/ton cement, but a total savings of 0.6 – 0.9 kWh/ton cement may be more typical. (Worrell and Galitsky, 2008) At existing facilities, retrofit to include the cyclones may also require rebuilding of the preheater tower, which may significantly increases the cost of the project. Additionally, new cyclones may increase overall dust loading and increase dust carryover from the preheater tower. Capital costs have been estimated to be $2.50/annual ton cement capacity. There should be no barriers to installing low pressure drop cyclones at new facilities. (Worrell and Galitsky, 2008) One study (Hollingshead and Venta, 2009) estimated the investment cost for this option to be $2.90/ton cement based on replacing the inlet and outlet cyclone ducting. Electricity requirements may decrease by 3 kWh/ton cement and production increase by 3 percent. Another study (ECRA, 2009) stated that retrofitting the preheat system with low pressure drop cyclones may be economically reasonable when the foundation and tower of the preheater can be reused without rebuilding. The reduced power consumption of the fan system may range from 0.5 – 1.3 kWh/ton cement. The reduced electricity generation may reduce CO2 emissions by up to 2 lb CO2/ton cement. Conversion to Multistage Preheater Modern cement manufacturing facilities incorporate multi-stage preheaters (four- or five- stage) prior to the kiln. (These preheater cyclones may or may not be low pressure drop cyclones as discussed above.) However, older kilns may preheat only prior to the combustion zone of the kiln or employ single- or two-stage preheaters. Some older kilns may not preheat at all. Multi- stage preheaters allow higher energy transfer efficiency and lower fuel requirements. Improved preheating may increase productivity of the kiln as a result of a higher degree of precalcination. Although the energy savings are highly site-specific, one retrofit project at an older kiln resulted in a decrease in energy usage of 0.4 MMBtu/ton cement, while increasing capacity by over 50 percent. The capital cost of the conversion was $33-34/annual ton cement capacity. Another study estimated the cost of installing suspension preheaters to be $23/ton cement capacity. (Worrell and Galitsky, 2008) 23 Adding a preheater stage will lead to additional heat capture from the exit gases. These savings were estimated to be 108,200 Btu/ton cement with a 3 percent production increase for adding one preheater stage. Electricity usage will increase by 1 kWh/ton cement. Investment costs were estimated to be $12.80/ton cement, which includes exit duct modifications and structural improvements to handle the additional stage. (Hollingshead and Venta, 2009) New construction typically employs multistage preheaters. Retrofit of existing facilities may be cost effective when the kiln needs to be replaced. (Worrell and Galitsky, 2008) In order to demonstrate the energy efficiency obtained with multistage preheaters, one study (ECRA, 2009) investigated the theoretical yearly average fuel energy requirements for cement kilns using multistage preheat systems and reported the following data: • 3 cyclone stages: 2,800 to 3,200 MJ/ton cement • 4 cyclone stages: 2,700 to 3,000 MJ/ton cement • 5 cyclone stages: 2,600 to 2,900 MJ/ton cement • 6 cyclone stages: 2,500 to 2,800 MJ/ton cement Conversion of Long Dry Kiln to Preheater/Precalciner Kiln Long dry kilns without preheater capacity or with only a single-stage preheater can be upgraded to a multi-stage PH/PC kiln. The conversion can reduce energy consumption by 1.1 MMBtu/ton cement based on studies done in Canada and the conversion of an Italian facility. While one study estimated the capital cost of such a conversion to be $7.9/ton cement capacity, another estimated the cost to be $19 – 24/ton cement. (Worrell and Galitsky, 2008) According to another study, the cost of upgrading a long dry kiln to a multistage preheater kiln is about $33 – 34/ton cement (in 1993 dollars). Capital costs can also be estimated using the following equation (Staudt, 2008b): Capital Costs (2005$) = $6545 x (tons/yr cement)0.6 The conversion of a long dry kiln to a preheater/precalciner kiln can be estimated using the following equation (Staudt, 2008b): Capital Costs (2005$) = $8084 x (tons/yr cement)0.6 Fixed costs for either conversion are estimated to be 4 percent of capital costs. Variable costs are primarily related to fuel usage and will be reduced according to the specific fuel reduction at each facility. (Staudt, 2008b) Converting to a PH will require a new pyro line (except perhaps for half the kiln) and minor improvements for raw grinding equipment. Production may increase by 25 percent with a reduction in energy consumption of 1.2MM Btu/ton cement and no net increase in electricity consumption. Investment costs were estimated to be $88/annual ton cement capacity, and 24 operating and maintenance costs were projected to decrease by $0.08/ton cement. (Hollingshead and Venta, 2009) Converting to a PH/PC kiln may increase production by 40 percent and may require more extensive upgrades in the raw grinding and clinker cooling areas to handle the increased production. The PH/PC kiln may reduce energy consumption by 0.7 MMBtu/ton cement and require no net increase in electricity consumption. Investment costs were estimated to be $96/annual ton of cement capacity, and operating and maintenance costs were projected to decease by $0.08/ton cement. (Hollingshead and Venta, 2009) One report (ECRA, 2009) stated that the energy savings realized for a retrofit depend highly on the process being replaced. Energy savings range from 800 MJ/ton cement when converting a long dry kiln to as much as 2,300 MJ/ton cement when converting a long wet kiln with a modern preheater/precalciner kiln and a modern clinker cooler. Electricity consumption in either case may be reduced up to 4kWh/ton cement. Emission reduction potential for CO2 ranges from 150-460 lb CO2/ton cement for direct emissions from the cement plant, and indirect reductions due to reduced consumption of electricity range from 0-6.5 lb CO2/ton cement. Kiln Drive Efficiency Improvement Due to the large size of the kiln, a substantial amount of power is required to rotate the kiln. When direct current motors are used, the efficiency of the motors is maximized by using a single pinion drive with an air clutch and a synchronous motor. This combination may reduce kiln drive electricity requirements by 2-3 percent, which equates to about 0.5 kWh/ton cement. However, the higher efficiency system increases capital costs by about 6 percent. (Worrell and Galitsky, 2008) The use of alternating current motors may result in slightly higher efficiencies than direct current motors. Alternating current motors may achieve a 0.5-1 percent reduction in electricity usage over direct current motors and also have a lower capital cost. New construction should consider high efficiency motors as part of an overall energy efficiency strategy. Existing facilities should consider replacing older motors with either alternating current or direct current high efficiency motors rather than re-winding the old motors, which could reduce power costs for the kiln drive by 2-8 percent. (Worrell and Galitsky, 2008) Adjustable Speed Drive for Kiln Fan Replacing the damper on the kiln fan system can reduce energy consumption of the kiln fan. One cement facility realized a nearly 40 percent reduction in electricity usage after making this modification on a 1,000 hp fan motor. Another facility that installed adjustable speed drives saw a reduction in electricity use of 5 kWh/ton cement. Installing adjustable speed drives for the kiln fan is applicable to both new and existing facilities. 25 Oxygen Enrichment Oxygen enrichment is the process of injecting oxygen (as opposed to air) directly into the combustion zone (or as an adjunct to the combustion air stream) to increase combustion efficiency, reduce exhaust gas volume, and reduce the available nitrogen that may form NOx pollutants. One study (Staudt, 2009) reported on four US cement plants that installed oxygen enrichment systems. These plants experience an increase in clinker production between 3.1 percent and 10 percent. One of the facilities reported a 3-5 percent decrease in fuel usage. If the oxygen enrichment process is not carefully managed, increased thermal NOx emissions can occur due to increased flame temperatures associated with highly efficient oxygen combustion. (Worrell and Galitsky, 2008) Staudt (2009) reported that the capital cost of an oxygen enrichment system can be estimated using the following equation: Capital Costs ($2009) = $1511 x (tons/yr cement capacity)0.6 This same report estimated fixed operating costs to be 4 percent of capital costs and variable operating costs to be 40 kWh/short ton of additional clinker times the cost of power, since electricity accounts for virtually all of the variable costs. ECRA (2009) reported that some experimentation showed that an increase of 25-50 percent in kiln capacity was possible with oxygen enrichment of 30-35 percent by volume of the combustion air. The thermal efficiency increase can reduce kiln energy requirements from 84- 167 MJ/ton cement. The increase in kiln production may lead to an increased electricity demand of 8-29 kWh/ton cement. While the reduced fuel usage in the kiln may reduce CO2 emissions by 18-37 lb CO2/ton cement, the increased electricity consumption could increase CO2 emissions by 28-46 lb CO2/ton cement. Oxygen enrichment is applicable to both new and existing facilities. However, a source of oxygen is required. Mid Kiln Firing Mid kiln firing, which is the practice of adding fuel (often scrap tires) at a point near the middle of the kiln, can result in reduced fuel usage thereby potentially reducing overall CO2 emissions. This practice is most often used with long wet or long dry kilns. The burning of tires emits slightly less CO2 per MMBtu than bituminous coal, but more CO2 per MMBtu than natural gas. Burning tires may also result in lower NOx emissions. Air Mixing Technology Mixing air is the practice of injecting a high pressure air stream into a kiln to break up and mix stratified layers of gases within the kiln. Mixing the air improves the combustion efficiency. Due to the increased efficiency, less fuel is required, leading to lower CO2 emissions. (Staudt, 2008b) 26 Capital costs of an air mixing system are approximately $520,000. Staudt (2008b) provides an equation to estimate capital costs based on tons per year (tpy) of clinker. Fixed annual costs are expected to be similar to that of a low NOx burner. Variable costs will be incurred by an air mixing system for electricity usage and is estimated to be 0.23 kWh/ton cement. Air mixing technology will likely reduce CO, NOx, and SO2 emissions. Staudt (2008b) reports that the concentration of CO in the kiln exhaust stream is reduced from 228 ppm down to 121 ppm, while SO2 was reduced from 359 ppm down to 10 ppm and NOx was reduced from 599 ppm down to 313 ppm. Preheater Riser Duct Firing The operation of cement manufacturing operations that include a preheater prior to the kiln can be improved by firing a portion of the fuel in the riser duct to increase the degree of calcination in the preheater. When tires are used as the fuel, CO2 emissions may be reduced because the burning of tires emits slightly less CO2 per MMBtu than bituminous coal, but more CO2 per MMBtu than natural gas. C. Energy Efficiency Improvements in Finish Grinding Improved Ball Mills Several technologies exist that reduce the power consumption of the finish grinding operation, such as roller presses, roller mills, and roller presses used for pre-grinding in combination with a ball mill. The electricity savings when replacing an older ball mill with a new finish grinding mill may be 25 kWh/ton cement. The addition of a pre-grinding system to an existing ball mill can reduce electricity consumption by 6-22 kWh/ton cement. Capital cost estimates for installing a new roller press vary widely, from a low of $2.3/annual ton cement capacity to a high of $7.3/annual ton cement capacity. Additionally, new grinding technologies may reduce operating costs by as much as 30-40 percent. (Worrell and Galitsky, 2008) Replacing ball mills with vertical roller mills is estimated to require an investment cost of $35/ton cement capacity and increase operating costs by $0.17/ton cement to account for more frequent maintenance. Power savings were estimated to be 9 kWh/ton cement. (Hollingshead and Venta, 2009) Retrofitting of existing facilities most often involves the use of high-pressure roller presses. All types of finish grinding systems applicable to the specific facility should be evaluated for new construction. High Efficiency Classifiers Classifiers are used to separate fine particles from coarse particles in the grinding operation. Low efficiency classifiers do a poorer job of separating out the fine particles and send 27 an excess of fine particles back to the grinder. This increases the load on the grinder and increases energy usage. High efficiency classifiers reduce the amount of fine particles returned to the grinder. In one study, the installation of high efficiency classifiers reduced electricity use by 6 kWh/ton cement and increased production by 25 percent. Other studies have shown the reduction in electricity use to be 1.7-2.3 kWh/ton cement. Capital costs were $2/annual ton finished material. (Worrell and Galitsky, 2008) Another study (Hollingshead and Venta, 2009) assumed that this conversion would require, in addition to the high efficiency classifier, a product dust collector and a new fan. Investment costs were estimated to be $2/ton cement with operating costs increasing by $0.04/ton cement. However, production may increase by 10 percent and power consumption may decrease by 2.1 kWh/ton cement. Retrofitting existing facilities with high efficiency classifiers should be considered where the physical layout of the finish grinding system allows it. New construction should consider the most efficient classifiers. D. Energy Efficiency Improvements in Facility Operations High Efficiency Motors Due to the high number of motors at a cement manufacturing facility, a systems approach to energy efficiency may be considered. Such an approach would look for energy efficiency opportunities for all motor systems (motors, drives, pumps, fans, compressors, controls). An evaluation of energy supply and energy demand would be performed to optimize overall performance. A systems approach includes a motor management plan that considers at least the following factors (Worrell and Galitsky, 2008): • Strategic motor selection • Maintenance • Proper size • Adjustable speed drives • Power factor correction • Minimize voltage unbalances One cement facility recently retrofitted the motors on the blowers and pumping systems as part of a motor system improvement project. Replacing older, less efficient motors with new, high efficiency motors reduced electricity use by about 2.1 million kWh/yr and saved about $168,000/yr in energy costs and $30,000/yr in maintenance costs. (PCA, 2008) The cost of replacing all older motors with high efficiency motors was estimated to be $0.67/ton cement with no increase in operating costs. Power consumption may decrease by about 5 percent, or 4 kWh/ton cement. (Hollingshead and Venta, 2009) Motor management plans and other efficiency improvements can be implemented at existing facilities and should be considered in the design of new construction. 28 Variable Speed Drives A typical cement plant may include 500-700 motors, most of which are fixed speed AC models. Since load conditions vary during production, decreasing throttling using variable speed drives can reduce energy consumption by 3-8 kWh/ton cement. This may lead to a reduction of CO2 emissions of 3-10 CO2/ton cement. The cost of retrofitting is highly site specific, but may range from $0.38-0.53 million. Operational savings from reduced electricity usage may range from $0.41-0.96/ton cement. (ECRA, 2009) High Efficiency Fans Fan technology has improved greatly since many older plants were constructed. If older fans are still in use, upgrading them to modern high efficiency fans may reduce power consumption by 0.9 kWh/ton cement with an investment cost of $0.46/ton cement. (Hollingshead and Venta, 2009) Optimization of Compressed Air Systems Compressed air systems provide compressed air that is used throughout the plant. Although the total energy used by compressed air systems is small compared to the facility as a whole, there are opportunities for efficiency improvements that will save energy. Efficiency improvements are primarily obtained by implementing a comprehensive maintenance plan for the compressed air systems. Worrell and Galitsky (2008) listed the following elements of a proper maintenance plan: • Keep the surfaces of the compressor and intercooling surfaces clean • Keep motors properly lubricated and cleaned • Inspect drain traps • Maintain the coolers • Check belts for wear • Replace air lubricant separators as recommended • Check water cooling systems In addition to the maintenance plan, reducing leaks in the system can reduce energy consumption by 20 percent. Reducing the air inlet temperature will reduce energy usage. The most effective means of reducing inlet air temperatures is by routing the air intake to a location that is outside and does not draw plant heat into the inlet air. Rerouting the inlet air can have a payback period as little as 2-5 years. Control systems can reduce energy consumption by as much as 12 percent. Properly sized pipes can reduce energy consumption by 3 percent. Since as much as 93 percent of the electrical energy used by air compressor systems is lost as heat, recovery of this heat can be used for space heating, water heating, and similar applications. (Worrell and Galitsky, 2008) Air compressor system maintenance plans and other efficiency improvements can be implemented at existing facilities and should be considered in the design of new construction. 29 Lighting System Efficiency Improvements Similar to air compressor systems, the energy used for lighting at cement manufacturing facilities represent a small portion of the overall energy usage. However, there are opportunities for cost effective energy efficiency improvements. Automated lighting controls that shut off lights when not needed may have payback periods of less than 2 years. Replacing T-12 lights with T-8 lights can reduce energy use by half, as can replacing mercury lights with metal halide or high pressure sodium lights. Substituting electronic ballasts for magnetic ballasts can reduce energy consumption by12-25 percent as well as reducing noise and heat from the ballasts. Lighting system improvements can be implemented at existing facilities and should be considered in the design of new construction. VI. Raw Material Substitution to Reduce GHG Emissions Decarbonated Feedstocks (Steel Slag or Fly Ash) Certain steel slag and fly ash materials may be introduced into the raw material feed or the clinker grinding process (see Blended Cements below) to reduce the amount of raw material needed to produce a given amount of clinker. Reduction in the amount of raw feed materials needed for clinker production can result in energy savings of 1.12 MMBtu/ton cement. This is slightly offset by the need to dry the slag or fly ash, which may consume 0.07 MMBtu/ton cement. However, where a low alkali cement product is desired, the use of steel slag or fly ash reduces the alkali content of the finished product. This may save 0.16 MMBtu/ton cement for reducing the need to bypass kiln exit gases to remove alkali-rich dust. (Worrell and Galitsky, 2008) Another study estimated that when the steel slag is used to increase production (rather than simply reduce raw material usage); the increased load on the finish grinders is 2.0 kW/ton cement. (Staudt, 2008b) Another study quantified the CO2 emission reduction as approximately the same on a ton CO2/ton clinker basis as the percent of slag added. Thus, if slag is substituted for 5 percent of the clinker output, then the CO2 emissions on a ton CO2/ton clinker basis will be reduced by about the same percentage. (Staudt, 2008b) In a separate report, Staudt (2009) reported the following values for estimating the CO2 emissions avoided and heat input reduced by using decarbonated kiln feedstocks (see Table 4). 30 Table 4. CO2 Emissions Avoided and Heat Input Reduced by Using Decarbonated Kiln Feedstocks Decarbonated CO2 Avoided Heat Input Reduced Feedstock Material (tons calcined CO2/ton material) (MMBtu/short ton material) Blast Furnace Slag 0.35 1.10 Steel Slag 0.51 1.59 Class C Fly Ash 0.20 0.61 Class F Fly Ash 0.02 0.07 One study (ECRA, 2009) reported that for a 15 percent replacement of raw materials by granulated blast furnace slag the decrease in kiln energy consumption may range from 84- 335MJ/ton cement, but that electricity consumption may increase by as much as 2 kWh/ton cement. The potential CO2 emission reductions from reduced fuel consumption may range from 0-216 lb CO2/ton cement and 0-4 lb CO2/ton cement emissions increase may occur due to the increased electricity requirements. The study cautioned that the high CO2 reduction potential may be very site specific and may not represent overall emission reduction potentials for the industry. Another study reported that 172 lb of steel slag used as a raw material feed could provide as much calcium as 200 lb of limestone, which reduced CO2 emissions by 88 lb. Thus, each ton of steel slag used to replace an equivalent amount of limestone reduced CO2 emissions by 0.466 tons. (PCA, 2008) According to Hollingshead and Venta (2009), steel slag can be fed directly into the kiln without grinding. In this case, the only equipment upgrades are a slag hopper with a regulated withdrawal system and conveyors to the feed point of the kiln. Investment costs were estimated to be $0.75/ton cement and operating costs were estimated to increase by $0.08/ton cement. Production may increase by 5 percent with a corresponding energy savings of 15 kcal/kg clinker 54,100 Btu/ton cement and power savings of 3 kWh/ton cement. (Hollingshead and Venta, 2009) The costs associated with implementing feedstock substitutions will vary at each location because of specific equipment modifications needed at each site. Primary capital costs are related to storage and handling systems for the materials. When the materials must first be dried, the kiln exhaust can generally be used to provide the necessary energy. Capital costs have been estimated to be $0.65/short ton cement capacity. Operating costs will depend on the costs of the substitute materials compared to the original raw materials, including transportation and mining, increased energy usage for grinding, and reduced electricity and fuel usage for the kiln. (Worrell and Galitsky, 2008) Cemstar, a proprietary slag injection process, has a total capital investment of about $1.5 million (as expressed in 2005 dollars) for a 45 ton/hr wet kiln. Fixed annual costs are expected to be low and one estimate put them at 4 percent of capital costs. Variable costs will depend on 31 how the kiln is operated after the modification. First there will be a cost reduction because steel slag ($5-15/ton) costs less than clinker ($73/ton). Second, there may be a reduction in cost due to less limestone used as raw material if the kiln output remains the same. If the kiln output is simply increased, then there will be no net savings in the limestone cost. (Staudt, 2008b) The use of steel slag or fly ash can be considered for existing facilities due to the relatively minor modification required, and should be considered in the design of new construction when sources of steel slag or fly ash are located close enough to the plant site to make their use feasible. Calcereous Oil Shale Calcerous oil shale has been used in cement plants in Germany and Russia as an alternate feed stock. Oil shale can also be used as a fuel substitute, and one facility uses the resulting ash as an additive in the finish grinding operation. (PCA, 2008) Some oil shale deposits may be partially decarbonated and their use would lead to reduced CO2 emissions from the calcination process. Additionally, they may have a caloric value that will contribute to the energy requirements of the preheater and kiln. If the shale is burned separately, the ash may be used as a raw material. Assuming that 8 percent of the raw meal is replaced with oil shale, an investment of $1/ton cement would be required for installation of a feed system, and operating costs would increase by $0.08/ton cement (assuming that the source of the shale is close to the facility). This modification could reduce energy requirements by 0.07 MMBtu/ton cement and reduce CO2 emissions by 0.009 lb/ton cement. (Hollingshead and Venta, 2009) Reductions in CO2 emissions will be directly related to the amount of limestone feed stock replaced. However, processing of the oil shale may result in some CO2 emissions that would have to be taken into account and are not estimated here. VII. Blended Cements to Reduce GHG Emissions Blended cements contain supplementary cementitious materials that replace a portion of the clinker used to make Portland cement. These materials are broadly divided into cementitious materials and pozzolans. Cementitious materials exhibit characteristics of cement. Granulated blast furnace slag is a commonly used cementitious material in cement manufacturing. A pozzolan is a material that when mixed with calcium hydroxide will exhibit cementitious properties. Example pozzolans used in cement manufacture include diatomite, calcined clay, calcined shale, metakaolin, silica fume, and fly ash from coal combustion. (Staudt, 2009) Whether supplementary cementitious materials can be used in cement depends on a number of factors including availability, properties of the material, price, intended application of the cement, quality and elemental constituents of the pozzolans, national standards, and market acceptance. (ECRA, 2009) Primary among these is availability, as the cement kiln must be located near the source of the material. The use of blast furnace slag requires the location of a blast furnace for pig-iron production near the kiln, as well as availability of the slag from that 32 facility. Deposits of natural pozzolans suitable for cement production are located in very limited areas. In general, investment costs for the equipment needed to receive, store, and meter supplementary materials to the cement product were estimated to be $3.40/ton cement. Operating costs and power consumption will decrease in proportion to the replacement rate of the clinker. (Hollingshead and Venta, 2009) Cementitious Materials Granulated blast furnace slag will offset emissions from the cement manufacturing process on a one-for-one basis. In other words, the use of one ton of slag will reduce all emissions from the cement manufacturing process by the amount of emissions that would be generated to produce one ton of clinker. (Staudt, 2009) The cost of granulated slag averages about $80/ton (in 2006 dollars). This may not include shipping costs, which may drive up the final cost to prohibitive levels if the source of the slag is not close to the cement facility. (Staudt, 2008b) The reduction in kiln energy requirements will be directly related to the reduced amount of clinker production resulting from blending another material in the finish grinding process. For a cement product with 30-70 percent by mass of granulated blast furnace slag, the reduced energy requirements will range from 380-1710 MJ/ton cement. The resulting CO2 emission reductions may range from 200-860 lb CO2/ton cement. Retrofitting a facility to allow blending in the finish grinding process may require investment costs ranging from about $7.5-15 million. (ECRA, 2009) Pozzolanic Materials Fly ash from coal combustion is the most widely used pozzolanic material for blended cement use. However, the use of fly ash may be limited by quality and consistency. Fly ash used for concrete blending must meet stringent quality specifications and have a good consistency. Local market factors may also play a part in the use of fly ash, as shipping costs are high due to fly ash weight. (Staudt, 2009) Natural pozzolans are available in limited areas. Facilities using natural pozzolans must be located in proximity to the source of the pozzolans. Fly ash of sufficient quality for cement blending costs $25-$30 per ton while displacing an equivalent weight of cement at about $70-$80/ton (in 1997 dollars). These prices do not include transportation costs, which may range from $0.10-$0.13/ton-mile (in 1997 dollars). Diatomite, one of the more widely used natural pozzolans in blended cements, cost $9.00 per ton (FOB plant) (in 2009 dollars). Clay and shale cost about $11/ton (FOB plant) (in 2009 dollars). (Staudt, 2009) 33 The use of fly ash as a blending material may reduce the energy requirements of the kiln by 200-500 MJ/ton cement for a cement with a fly ash content of 25-35 percent by mass. The resulting CO2 emission reductions may range from 100-280 lb CO2/ton cement. Retrofitting a facility to allow blending in the finish grinding process may require investment costs ranging from$12-18 million. (ECRA, 2009) Natural pozzolans may require additional drying, crushing and grinding prior to use. Depending on the extent of drying necessary, the energy requirements of the kiln may be reduced by 0-500 MJ/ton cement for a cement with a natural pozzolan content of 15-35 percent by mass. The resulting CO2 emission reductions may range from 0-280 lb CO2/ton cement. Retrofitting a facility to allow blending in the finish grinding process may require investment costs ranging from $12-18 million. (ECRA, 2009) VIII. Carbon Capture and Storage Carbon capture and storage (CCS) involves separation and capture of CO2 from the flue gas, pressurization of the captured CO2, transportation of the CO2 via pipeline, and finally injection and long-term geologic storage of the captured CO2. Several different technologies, at varying stages of development, have the potential to separate and capture CO2. Some have been demonstrated at the slip-stream or pilot-scale, while many others are still at the bench-top or laboratory stage of development. In 2010, an Interagency Task Force on Carbon Capture and Storage was established to develop a comprehensive and coordinated Federal strategy to speed the commercial development and deployment of clean coal technologies. The Task Force was specifically charged with proposing a plan to overcome the barriers to the widespread, cost-effective deployment of CCS within 10 years, with a goal of bringing 5 to 10 commercial demonstration projects online by 2016. As part of its work, the Task Force prepared a report that summarizes the state of CCS and identified technical and non-technical barriers to implementation. The development status of CCS technologies is thoroughly discussed in the Task Force report. For additional information on the Task Force and its findings on CCS as a CO2 control technology, go to: http://www.epa.gov/climatechange/policy/ccs_task_force.html. The post-combustion technologies listed below are generally end-of-pipe measures and would not require fundamental changes in the clinker burning process. Calera Process Calera has recently developed a process to capture CO2 emissions and chemically convert the captured CO2 to carbonates. The process employs a scrubber with high pH water containing calcium, magnesium, sodium, and chloride as the scrubbing liquid. The CO2 is absorbed by the water, converting it to a dissolved carbonic acid species. At higher pH values, the carbonic acid 2- 2- 2+ 2+ dissociates and produces bicarbonate and CO3 ions. The CO3 then reacts with Ca and Mg to form carbonate minerals. These minerals can then be precipitated from the solution and dried, and then used to make blended cement or other building materials. The remaining water can then be further treated to remove sodium chloride to produce potable water. Thus, the process 34 can take seawater or brackish natural water from wells and produce potable water as a byproduct. Further, the process can be expanded using a low voltage chemical process to convert the removed sodium chloride to produce sodium hydroxide or sodium bicarbonate. The sodium hydroxide can then be used to raise the pH of the scrubber water. The process can be configured such that no industrial waste is discharged into the environment. Results at a pilot plant installed at a 10MW coal-fired power plant have shown capture efficiency greater than 90 percent for CO2. When the carbonate materials are used in blended cements, the overall carbon footprint can be negative. This is because the carbon emissions avoided from the cement manufacturing process may be greater than those of the baseline CO2 emissions from the power plant. (Calera, 2009) This process is still being researched for its use in the cement industry. Oxy-combustion Some researchers have reported that oxy-combustion may be feasible for cement plants, although no systems have been installed. Oxy-combustion is the process of burning a fuel in the presence of pure or nearly pure oxygen instead of air. (Oxygen enrichment, as discussed earlier, differs from oxy-combustion in that oxygen enrichment does not replace air but injects oxygen into the combustion zone along with combustion air.) Fuel requirements for oxy-combustion are reduced because there is no nitrogen component to be heated, and the resulting flue gas volumes are significantly reduced. (Barker et al., 2009) The process uses an air separation unit to remove the nitrogen component from air. The oxygen-rich stream is then fed to the kiln, and the resulting kiln exhaust gas contains a higher concentration of CO2, as much as 80 percent. A portion of the exhaust stream is discharged to a CO2 separation, purification, and compression facility. This technology is still in the research stage for the cement industry. (ECRA, 2009) Technical issues related to using oxy-combustion at a cement plant identified by Barker et al. (2009) include: • Flame Temperatures and Dilution. Flame temperatures in excess of 3500°C can be achieved using oxy-combustion, which is too hot for proper operation of a cement kiln. Therefore, a portion of the flue gases are recycled back to the combustion zone to provide the necessary dilution. • Heat Transfer Characteristics. Changing the atmosphere within the combustion chamber will have a significant effect on the heat transfer characteristics. • Feed Lifting. Nitrogen ballast in the exhaust gases from the kiln plays an important role in lifting the feed between the cyclone stages in the suspension preheater. CO2 is a denser gas than nitrogen and should be more effective in this feed lifting role. • Wear and Tear. Due to higher temperatures, kiln wall deterioration may increase at higher oxygen concentrations, leading to more frequent replacement of the kiln lining. • Process Chemistry. Research is still on-going to determine whether the clinker formation in a different atmosphere will still generate a useful product. 35 • Air Dilution. Excessive air in-leaks will result in contamination of the CO2-rich exhaust gas. These contaminates will require removal which will increase costs. • Flue Gas Cleanup. Depending on the final storage location of the CO2, the gas will require some clean-up to remove water vapor, nitrogen, argon, NOx, and SOx. • Air Separation Unit (ASU). An ASU will be required to deliver oxygen to the process, which will increased electricity demand. • Reducing Conditions. The oxygen concentration in the clinker production process should be maintained >2 percent (w/w). The ECRA (2009) study indicated that the overall energy requirements would decrease by 75-84MJ/ton cement. Electricity requirements would increase by 92-96 kWh/ton cement, primarily to operate the CO2 separation, purification, and compression facility. Potential CO2 emission reductions would range from1000-1600 lb CO2/ton cement as a result of reduced fuel combustion, but increase by 110-150 lb CO2/ton cement as a result of the increased electricity demand. The ECRA (2009) study estimated that additional investment costs for a new facility would range from $495-540 million, and operational costs would increase by $10-13/ton cement based on a 2.2 million ton /yr facility. Costs related to transport and storage of CO2 were not included. The study cautioned that these costs are highly uncertain because the technology has not yet been developed, and that the initial facilities employing the technology would likely incur much higher costs. IEA GHG performed a study in 2008 that involved a very extensive analysis of the technical, economic, and retrofitting issues related to oxy-combustion. The analysis was performed based on a new cement plant located in the United Kingdom (UK) producing 1.1 million tons/year of cement, using a dry feed process with a five stage preheater. Additionally, the analysis focused on a plant configuration where oxy-combustion was used for the precalciner, but air combustion was used for kiln. This configuration minimized the possible impact of a high CO2 atmosphere on the clinker production process. This was compared to a base case of the same plant without oxy-combustion. Total energy consumed from fuel, assuming coal as the fuel, was an increase of 1.0 MW. Net power consumption increased by 11.8 MW. (IEA GHG, 2008) CO2 emissions avoided at the cement plant were 490,200 tons/yr, or 436,500 tons/yr when taking into account the import and export of electricity, which equated to 61 and 52 percent reductions, respectively. (IEA GHG, 2008) Capital costs were an increase of $96 M over the base case. Total operating costs, taking into account the import of electricity, was an increase of $24 M/y. (IEA GHG, 2008) Post-Combustion Solvent Capture and Stripping Post-combustion capture using solvent scrubbing, typically using monoethanolamine (MEA) as the solvent, is a commercially mature technology. Solvent scrubbing has been used in chemical industry for separation of CO2 in exhaust streams. (Bosoaga et al., 2009) 36 While post-combustion capture of CO2 has been studied extensively for combustion sources at gas-fired power stations, there has been little work to address feasibility at cement plants. One study (Barker et al., 2009) performed an initial evaluation of solvent capture for new cement plants. This study evaluated post-combustion amine scrubbing using MEA. The following technical issues were raised in this study: • Sulfur Dioxide (SO2). The concentration of SO2 in the flue gas from the cement process is important for post-combustion capture with amines because amines react with acidic compounds to form salts that will not dissociate in the amine stripping system. • Nitrogen Dioxide (NO2). NOx within the flue gas is problematic for MEA absorption as this result in solvent degradation. • Dust. The presence of dust reduces the efficiency of the amine absorption process. The dust level must be kept below 15 mg/Nm3. • Additional Steam Requirements. One of the major issues with using MEA CO2 capture is the large steam requirement for solvent regeneration. • Reducing Conditions. The clinker must not be generated in reducing conditions and an excess of oxygen must be maintained in the process. • Heat Reduction for MEA Absorption. The flue gas must be cooled from about 110°C to about 50°C to meet the ideal temperature for CO2 absorption with MEA. • Other Gases. The presence of any acidic components will reduce the efficiency of the MEA absorption process. ECRA (2009) estimated that 95 percent of the CO2 in the exhaust stream could be captured using MEA absorption. Similar to Barker et al. (2009), this study stated that absorption technologies are only in the pilot stage in the energy sector and actual demonstration facilities are many years in the future. Initial cost estimates place the investment costs at $130-380 million and operating costs at $13-63/ton cement. These are rough estimates only and exclude CO2 transport and storage costs. However, Bosoaga et al. (2009) pointed out that an advantage of cement plants over power plants is the higher concentration of CO2 in the flue gas. This directly impacts absorber unit size, and the power requirements for CO2 compression will be lower compared to the power demand for a power plant. One study that performed a very extensive analysis of the technical, economic, and retrofitting issues related to post-combustion solvent capture was completed by IEA GHG (2008). Based on this analysis, the major additions to a cement plant to incorporate this technology include: • A CO2 capture plant which includes a solvent scrubber and regenerator • A compressor to increase the pressure of the CO2 product for transport by pipeline • High efficiency flue gas desulfurization and De-NOx (a NOx removal process) to satisfy the flue gas purity requirements of the CO2 capture process • A plant to provide the steam required for regeneration of the CO2 capture solvent. The technical and cost analysis was performed based on a new cement plant located in the UK producing 1.1 million tons/year of cement, using a dry feed process with a five stage preheater. This was compared to a base case of the same plant without the post-combustion 37 control. Total energy consumed from fuel, assuming coal as the fuel, increased by 207.2 MW. Net power consumption decreased by 13.1 MW, including excess electricity generation of 2.9 MW. (IEA GHG, 2008) CO2 emissions avoided at the cement plant were 594,000 tons/yr, or 653,200 tons/yr when taking into account the import and export of electricity, which equated to 74 and 77 percent reductions, respectively. (IEA GHG, 2008) Capital costs were an increase of $443 M over the base case. Total operating costs, taking into account the export of excess electricity generation for the steam plant, was an increase of $95.7 M/y. (IEA GHG, 2008) Post-Combustion Membranes Membrane technology may be used to separate or adsorb CO2 in the kiln exhaust. It has been estimated that 80 percent of the CO2 could be captured using this technology. The captured CO2 would then be purified and compressed for transport. This technology is still primarily in the research stage, with industrial application at least 10 years away. There are significant problems to overcome designing membrane reactors large enough to handle the kiln exhaust. Positive aspects of membrane systems include ability to be positioned either horizontally or vertically and very low maintenance since regeneration is not required). Although the technology is too immature to estimate energy requirements, potential CO2 emission reductions are at least 1300 lb CO2/ton cement. (ECRA, 2009) Superheated Calcium Oxide (CaO) A typical modern cement plant operates by feeding limestone (primarily CaCO3) to a precalciner that dissociates CO2 from the CaCO3 to produce CaO. Fuel is burned in the precalciner to provide the heat necessary to drive this reaction. Thus, the exhaust stream contains CO2 from the calcination of CaCO3 and combustion of the fuel, as well as other products of combustion and excess combustion air. As a result, the total CO2 produced in the precalciner is diluted by a larger exhaust steam, making capture of the CO2 more difficult. The superheated CaO process separates the calcination and combustion reactions into independent chambers. The heat necessary to run the calciner is provided by circulating a stream of superheated CaO particles between a fluidized bed combustor and a fluidized bed calciner. Thus, the exhaust stream from the calciner consists primarily of CO2. The CO2 can then be collected and compressed in preparation for disposal. Theoretically, up to 53 percent of the CO2 released in the cement manufacturing process could be captured, avoiding 43 percent of the CO2 emitted by the traditional cement plant. (Rodriguez et al., 2009) Although simulations using Aspen Hysys have shown that the superheated CaO process is theoretically feasible, the system remains theoretical with no systems yet built. New construction is most amenable to this system, although retrofitting existing facilities is possible. Retrofits would involve removal of existing preheaters and precalciners (if present) and 38 construction of the fluidized beds, cyclones, heat exchangers, and compressors associated with the process. Rodriguez et al. (2009) did not provide cost information. IX. Other Measures to Reduce GHG Emissions Fuel Switching Switching from coal as the primary fuel to oil or gas will reduce the fuel combustion portion of overall CO2 emissions, but will not affect the emissions from the calcination reaction. The CO2 reduction potential of switching from coal to heavy oil is about 18 percent (210 lb CO2/gigajoule (GJ) versus 170 lb CO2/GJ). Switching to natural gas will reduce fuel combustion CO2 emissions by about 40 percent (210 lb CO2/GJ versus 124 lb CO2/GJ). However, any fuel switching scenario will have to consider whether other pollutants, such as NOx increase as a result of the switch. (ECRA, 2009) The investment cost to retrofit a cement plant to switch from coal to oil fuel has been estimated to range from $7.5-22.5 million, with an increase in operating costs (excluding depreciation, interest, and inflation) ranging from $10-20/ton cement. (ECRA, 2009) Alternative Fuels – Biomass The potential on site reduction in CO2 emissions that may be realized by switching from a traditional fossil fuel to a biomass fuel is based on the specific emission factor for the fuel as related to its caloric value. Pure biomass fuels include animal meal, waste wood products and sawdust, and sewage sludge. It may also be possible to use biomass materials that are specifically cultivated for fuel use, such as wood, grasses, green algae, and other quick growing species. (ECRA, 2009) ECRA (2009) identified a number of issues related to the use of biomass fuels: • Caloric Value. Although cement kilns can theoretically use 100 percent biomass fuels, the caloric content must be taken into consideration. Most organic materials have a caloric content of 9-16 GJ/ton cement, while the main firing of a cement kiln requires at least 18-20 GJ/ton cement. Thus, biomass would have to blend with other fuels if used in the kiln. The lower process temperatures in the precalciner allow the use of lower caloric value fuels. Up to 60 percent of the precalciner fuel can be biomass. • Trace Compounds. The biomass fuel, particularly waste products, may contain trace elements such as heavy metals or may contain compounds that are detrimental such as chlorine. These substances could result in other air emission issues or produce compounds in the combustion process that may be detrimental to equipment or clinker quality. • Technical Experience. Because cement kilns operate differently when alternate fuels are used, technical expertise to operate the process when using the alternate fuels is required. • Waste Regulations. The regulation of wastes that may be used for fuel affects the use of those wastes as fuel. For example, if there are no impediments to land filling the waste, then there may be little of the waste available for fuel use. 39 • Social Acceptance. The use of waste fuels in a given area may be driven by social acceptance of burning the fuel in the community. • Agricultural Areas. For crops grown for biomass purposes, sufficient agricultural areas in proximity to the cement kiln are required. Hybrid Solar Plants and Wind Turbines Initial research is being performed on a system that uses sunlight collected by heliostat mirrors and focused by a parabolic reflector into the kiln as an energy source. Such a system may be feasible in generally sunny areas where small cement plants could be constructed to meet local needs. Due to the immaturity of this technology, no cost information is available. Emission reductions of CO2 are equivalent to the emissions that would be generated by fuel combustion, since the solar system would replace fuel in the clinker forming process. However, CO2 emissions from the calcination process would be unaffected. (PCA, 2008) At least one cement plant has installed wind turbines capable of meeting one-third of their plant electric demand. No cost information is available. Emission reductions of CO2 are equivalent to the emissions that would be produced by the fuel being replaced. Emissions of CO2 from calcinations would not be affected. Syngas Co-Production Pre-combustion technologies such as reforming or gasification/partial oxidation can be used to produce fuels (mainly hydrogen) that are mostly carbon-free, or to reduce the carbon content of hydrocarbon fuels. Syngas is a mixture of predominantly H2, CO, and CO2 that is generated as an intermediate step from fossil fuels such as coal or gas. The CO is then oxidized to CO2 in a shift reactor. The subsequent separation of the CO2 from the H2 is the primary function of pre-combustion capture. The resulting H2 is too explosive to use directly in the kiln, but may be diluted with other gaseous fuels or inert gas such as nitrogen or steam. Even when diluted, the combustion and radiation properties of hydrogen differ significantly from traditional fuels, requiring extensive modifications to the kiln and perhaps new developments in burner technology. The potential CO2 emission reductions are up to 650 lb CO2/ton cement depending on how much of the carbon in the fuel can be removed. Since this technology has been applied only to much smaller streams than required for a cement kiln, estimates of investment and operating costs for a system sized for a cement kiln have not yet been developed. Power Plant/Cement Plant Carbonate Looping (Solid Sorbent Process) Carbonate looping is a subset of mineral carbonation based on the equilibrium of calcium carbonate to calcium oxide and CO2 at various temperatures and pressures. The combustion gases are placed in contact with calcium oxide, forming calcium carbonate from the CO2. The sorbent is sent to a calciner for regeneration. The gas stream exiting the calciner has an 40 increased CO2 concentration and is suitable for subsequent processing for transport and storage. (ECRA, 2009) Due to the immaturity of this technology, energy requirements and costs have not been estimated. Potential CO2 emission reductions range from about 830-1300 lb CO2/ton cement. (ECRA, 2009) Chemical Looping Chemical looping is a combustion technology with inherent separation of CO2. A metal oxide is used as an oxygen carrier which transfers oxygen from combustion air to the fuel. Direct contact between air and fuel is avoided, and a concentrated stream of CO2 is generated. Although direct application to clinker production appears unlikely, the technology may be applicable to H2 production that can subsequently be used as fuel. (PCA, 2008) X. EPA Contacts Keith W. Barnett U.S. EPA Office of Air Quality Planning and Standards/Sector Policies and Programs Division Mail Code D243-02 109 T.W. Alexander Dr. Research Triangle Park, NC 27711 Phone: 919-541-5605 Fax: 919-541-5600 [email protected] Elineth Torres U.S. EPA Office of Air Quality Planning and Standards/Sector Policies and Programs Division Mail Code D205-02 109 T.W. Alexander Dr. Research Triangle Park, NC 27711 Phone: 919-541-4347 Fax: 919-541-5600 [email protected] XI. References Barker, D.J., S.A. Turner, P.A. Napier-Moore, M. Clark, and J.E. Davison, 2009. “CO2 Capture in the Cement Industry,” Energy Procedia, Vol. 1, pp. 87-94. http://www.sciencedirect.com/science?_ob=MImg&_imagekey=B984K-4W0SFYG-F- 1&_cdi=59073&_user=10&_orig=browse&_coverDate=02%2F28%2F2009&_sk=999989998& view=c&wchp=dGLbVlz- zSkWA&md5=12853bece66323782f9a46335b4b213c&ie=/sdarticle.pdf Bosoago, Adina, Ondrej Masek, and John E. Oakey, 2009. “CO2 Capture Technologies for Cement Industry,” Energy Procedia, Vol. 1, pp. 133-140. 41 http://www.sciencedirect.com/science?_ob=MImg&_imagekey=B984K-4W0SFYG-N- 1&_cdi=59073&_user=10&_orig=browse&_coverDate=02%2F28%2F2009&_sk=999989998& view=c&wchp=dGLzVlz- zSkWA&md5=b9ba07fff56e3ad43069658cb689db9e&ie=/sdarticle.pdf Calera, Inc., 2009. “Notes on Sustainability and Potential Market,” October 2009. CEMBUREAU, 1999. Best Available Techniques for the Cement Industry, CEMBUREAU Report, The European Cement Association, December 1999. D/1999/5457/December, Brussels. http://www.cembureau.be Coito, Fred, Frank Powell, Ernst Worrell, Lynn Price, and Rafael Friedmann, 2005. “Case Study of the California Cement Industry” (Report No. LBNL-59938), Proceedings of the 2000 ACEEE Summer Series on Energy Efficiency in Industry, Ernest Orlando Lawrence Berkeley National Laboratory, Berkeley, CA. http://ies.lbl.gov/iespubs/59938.pdf EPA, 2007a. Alternative Control Techniques Document Update – NOX Emissions from New Cement Kilns. EPA-453/R-07-006, November 2007. http://www.epa.gov/ttn/catc/dir1/cement_updt_1107.pdf, accessed October 21, 2008. EPA, 2007b. “Plant-level Cement GHG Database: Revised Draft,” prepared by ICF for the Program Integration Branch, Climate Change Division, U.S. Environmental Protection Agency, May 2007. EPA, 2008. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006, Final. U.S. Environmental Protection Agency, Washington, DC. April 15. http://www.epa.gov/climatechange/emissions/usinventoryreport.html# European Cement Research Academy (ECRA), Cement Sustainability Initiative, 2009. “Development of State of the Art – Techniques in Cement Manufacturing: Trying to Look Ahead,” June 4, 2009, Duesseldorf, Germany. http://www.wbcsdcement.org/pdf/technology/Technology%20papers.pdf FTC International, 2009. “Gyro-Therm Burners – Revolutionary Low NOx High Efficiency Gas Burners,” December 2009. http://www.fctinternational.com/splash/about_fct/fct_combustion/products_fct_combustion/gyro therm/body.htm Hollingshead, Andrew and George Venta, 2009. “Carbon Dioxide Reduction Technology Effectiveness Assessment – Initial Evaluation,” PCA R&D Series No. SN3125, Portland Cement Association, Skokie, IL. http://www.cement.org/bookstore/profile.asp?store=&pagenum=&pos=0&catID=&id=16964 ICF International, 2010. CHP Installation Database, maintained for U.S. DOE and Oak Ridge National Laboratory. 42 International Energy Agency Greenhouse Gas R&D Programme (IEA GHG), 2008. “CO2 Capture in the Cement Industry,” Report No. 2008/3, July 2008. Portland Cement Association (PCA), 2008. “Carbon Dioxide Control Technology Review,” Report No. PCA R&D SN3001, Portland Cement Association, Skokie, IL. http://www.cement.org/bookstore/profile.asp?store=&pagenum=&pos=0&catID=&id=16705 Rodriguez, N., M. Alonso, J.C. Abanades, G. Grasa, and R. Murillo, 2009. “Analysis of a Process to Capture the CO2 Resulting from the Pre-Calcination of the Limestone Feed to a Cement Plant,” Energy Procedia, Vol. 1, pp. 141-148. http://www.sciencedirect.com/science?_ob=MImg&_imagekey=B984K-4W0SFYG-P- 1&_cdi=59073&_user=10&_orig=browse&_coverDate=02%2F28%2F2009&_sk=999989998& view=c&wchp=dGLbVzW- zSkWb&md5=3ad2bd75e1a9d6e56d407a31bb4e6fc3&ie=/sdarticle.pdf Staudt, Jim, 2008a. Memorandum to Ravi Srivastava, Samudra Vijay, and Elineth Torres, “NOx, SO2 and CO2 emissions from Cement Kilns (Emissions Memo)” Andover Technology Partners, September 23, 2008. Staudt, Jim, 2008b. Memorandum to Ravi Srivastava, Samudra Vijay, and Elineth Torres, “Costs and Performance of Controls,” Andover Technology Partners, September 25, 2008. Staudt, Jim, 2009. Memorandum to Ravi Srivastava, Nick Hutson, Samudra Vijay, and Elineth Torres, “GHG Mitigation Methods for Cement,” Andover Technology Partners, July 10, 2009. United States (US) DOE, 2009. “An Assessment of the Commercial Availability of Carbon Dioxide Capture and Storage Technologies as of June 2009,” Washington, D.C. US DOE, Office of Scientific and Technical Information. June 2009. http://www.pnl.gov/science/pdf/PNNL-18520_Status_of_CCS_062009.pdf Worrell, Ernst and Galitsky, Christina, 2008. “Energy Efficiency Improvement and Cost Saving Opportunities for Cement Making” (Report No. LBNL-54036-Revision), Ernest Orlando Lawrence Berkeley National Laboratory, Berkeley, CA. March 2008. http://www.energystar.gov/ia/business/industry/LBNL-54036.pdf 43 Appendix A Scale-up Factors for Use with Equation 1 of Staudt (2009) From Payback Calculation From Reported Capital Costs Capital Energy Saving Method Wet Cost Wet Long Pre- Precal- Long Pre- Precal Pro- Process Dry heater ciner Dry heater -ciner cess Raw Material Preparation Efficient Transport Min 392 392 392 787 787 System 787 Raw Material Blending Avg 1181 1181 1181 1181 1181 1181 Process Control Vertical Avg 19 19 19 Mill High Efficiency Roller Mill Min 1352 1352 1352 1458 1458 1458 Slurry Blending and Max 1546 Homogenization Wash Mills w/Closed Min 1136 Circuit Classifier High Efficiency Min 553 714 714 714 451 584 584 583 Classifiers Clinker Making Energy Management and Avg-wet 207 220 220 220 Control System Max-dry Seal Replacement Max 6 8 8 8 Combustion System Avg 370 334 334 334 188 244 244 Improvement 243 Indirect Firing Avg 1986 1986 1986 1394 1802 1802 1802 Shell Heat Loss Avg 66 88 88 88 47 60 61 60 Reduction Optimize Grate Cooler Avg 48 78 78 78 Conversion to Grate Avg 83 101 101 101 38 50 50 49 Cooler Heat Recovery for Power Avg 604 Generation Conversion to Semi-Dry Min 2455 Process Kiln Efficient Mill Drives Avg 194 30 30 30 Finish Grinding Energy Management and Max 16 20 20 20 Process Control Improved Grinding Media Avg 178 230 230 230 in Ball Mills 44 From Payback Calculation From Reported Capital Costs Capital Energy Saving Method Wet Cost Wet Long Pre- Precal- Long Pre- Precal Pro- Process Dry heater ciner Dry heater -ciner cess High Pressure Roller Min 1515 1958 1958 1958 903 1166 1166 Press 1166 High Efficiency Min 389 545 545 545 451 584 584 Classifiers 583 Plant-Wide Measures Preventative Max 40 51 51 51 Maintenance High Efficiency Motors Max 29 37 37 37 Adjustable Speed Drives Avg 158 213 213 213 70 91 91 90 Optimization of Max 86 44 44 44 Compressed Air Systems Product Changes Blended Cement Max 294 294 294 294 Limestone Portland Max 153 153 153 153 Cement 45