(f>GCC Dacotah

January 16, 2002

Mr. Brian Gustafson

Department of Environment and

Natural Resources - Air Quality Program

Joe Foss Building

523 East Capitol

Pierre, SD 57501-3182

Dear Mr. Gustafson:

In accordance with the Amended Compliance Plan, GCe Dacotah submits the following

documents to the South Dakota Department of Environment and Natural Resources

("Department") for the Rapid City portland cement manufacturing facility.

1. Application for a "Prevention of Significant Deterioration" ("PSD") permit for

N02 and CO emissions;

2. PSD Air Quality Dispersion Modeling Analysis for N02and CO emissions; and

3. A proposed Implementation Schedule for Achieving the Emissions Levels

Proposed in the PSD Permit Applications for N02, CO, and Particulate Matter.

We understand that the Department would like to meet on January 31, 2002 to discuss the

PSD permit application for PM emissions, submitted previously on November 15,2001.

In addition, and after the Department has had an opportunity to review the enclosed, we

would like to schedule a meeting with the Department to review all of our submittals.

Specifically, we request that the Department determine the "completeness" of the PSD

permit applications as soon as possible. We appreciate the Department working with us

in these efforts.

Sincerely,

GCCDacotah

AdoC'-#!.. 7f:r', ... H r

Dave Rydquist

VP Operations

DRlpv

Building Together'· Mailing Address:

P.O. Box 360

Rapid Oty, SD 57709

Street Address:

501 North Saint Onge SI.

Rapid Oty, SD 57702

Telephone: 605·721·7100

Fax: 605-721-7012

www.gcc.com
<,GCC Dacotah

PROPOSED SCHEDULE FOR IMPLEMENTING EMISSIONS

LIMITATIONS CONTAINED IN GCC DACOTAH PSD PERMIT APPLICATION

A. INTRODUCTION

During the course of developing the PSD pennit applications submitted under separate

cover to the Department on November 15,2001 and January 17, 2002, respectively, GCC

Dacotah has investigated the lead time necessary for the completion ofthe proposed PSDrelated physical and operational upgrades to the Rapid City facility. As such, Gee Dacotah

submits this proposed schedule and time line for completing the achievement ofthe projects

proposed in the PSD pennit applications with respect to PM, N02 and CO emissions.

B. PROPOSED PSD PROJECT-RELATED TIME LINES AND CRITICAL

CONSIDERATIONS

Gee Dacotah is aware that South Dakota regulations do not provide a specific set of

procedural requirements for PSD pennits. PSD pennit applications are instead governed by

South Dakota regulatory provisions for the separate and distinct Operating Permit program.

In developing both PSD pennit applications, Gee Dacotah believes that it has closely

followed the South Dakota requirements for assembling a complete permit application and

requests that the Department make a detennination to that effect as soon as possible.

While the South Dakota regulations allow a potentially long period oftime for a

pennit application to be processed, following a completeness determination, GCe Dacotah

requests an expedited pennit review from the Department in order that the related processes

for design, engineering and construction may proceed as expeditiously as possible. At this

time, Gee Dacotah anticipates that total project design, engineering, contracting, and

construction processes will likely take up to 18 months to complete from the date ofreceipt of

the PSD pennit.

Below is a listing ofthe major individual project complements, and their anticipated

duration within the estimated 18-month period:

ANTICIPATED TASK ANTICIPATED

DURATION

Total anticipated PSD pennit-related program 18 months

Expansion of quarry reclamation areas and associated 12 - 13 months

reduction of quarry disturbance areas

Main road strip paving proiect (200 meters) 2 months

Seal clinker storage sheds 2- 3 months

Upgrade ofindividual dust collectors units 12 months

Process engineering 2 months

B 'Id' ..{.7565~]jDGr;:I} UI mg mgerl er

Maling Jldctess:

Po. Box 360

R<pid Gly, so 51700

Strrel A:ldress:

501 f\brth 53nt Olge St.

RqXd Oly, so fJ17a2.

Telepl-one 605-721-7100

R:oc 605-721-7012

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,

<,GCC Dacotah

ANTICIPATED TASK ANTICIPATED

DURATION

Plant design and en.gineering 2 -3 months

Auxiliary equipment engineering 2-3 months

Equipment and materials procurement 10 months

Civil works 4 months

Equipment installation 4 months

Duct work fabrication and installation 5 months

Electrical works 2 - 3 months

Pre-commissioning commissioning and start up/shakedown 1-2 months

Because ofthe need to coordinate this multifaceted project with weather conditions,

seasonal market conditions, specialized contractor availability, and scheduled maintenance

outages, GCC Dacotah requests that the Department issue a PSD permit by no later than May

31, 2002. GCC Dacotah believes that working closely with the Department over the next four

to five months is critical in order to avoid otherwise costly and duplicative design and

engineering efforts and equipment purchases. Based upon the above-described project

schedule, GCC Dacotah is committed to working closely with the Department and other

interested parties to obtain a complete PSD permit as soon as possible, within the South

Dakota and federal PSD process requirements. GCC Dacotah requests theDepartment's

concurrence with our assessment and proposed schedule.

8 'Id' ..P565,1.00M::I} UI mg JOgerner Maling Jldci'ess:

P.O Box 360

R<:pid Oly, so 57700

Strea Pddress:

501 f\brth sant 01geSt.

RcPd Oly, so 577CJ2

Teeph:Jne 605-721-7100

Fa><: 605-721-7012

WNW.gcc.cx:m
PREVENTION OF SIGNIFICANT DETERIORATION PERMIT APPLICATION

GCC DACOTAH • RAPID CITY, SOUTH DAKOTA

NOx AND CO EMISSIONS FROM KILN No.6 PROCESS LINE MODIFICATIONS

Prepared by:

Arun Kanchan • Senior Project Manager

Walter Greer· Senior Technical Associate

Mike Remsberg· Project Manager

Stacy Carr • Project Supervisor

Erick Mertooetomo • Project Consultant

TRINITY CONSULTANTS

12801 N. Central Expressway

Suite 1200

Dallas, Texas 75243

(972) 661-8100

January 16, 2002

Project 014401.0088

TrioityA CQnsultahts
REVISED DECEMBER 12, 2002

TABLE OF CONTENTS

TABLE OF CONTENTS I

1. INTRODUCTION 1-1

2. PROJECT BACKGROUND AND OVERVIE\V 2-1

2.1 LOCATION OF FACILITY 2-1

2.2 PROCESS DESCRIPTION 2-1

2.2.1 KILN FEED PREPARATION 2-4

2.2.2 CLINKER PRODUCTION 2-6

2.2.3 FINISHED CEMENT GRINDING 2-6

2.3 1996 KILN NO.6 MODIFICATION PROJECT 2-7

2.4 PROPOSED BACT RELATED MODIFICATIO:\S 2-7

3. PSD ApPLICABILITY, EMISSIONS STANDARDS, A:\ll REQUIRDIENTS 3-1

3.1 PSD APPLICABILITY 3-1

3.1.1 EMISSION NETTING RESULTS 3-2

3.2 SD DENR PERMIT APPLICATION REQUIRE~IENTS 3-4

3.3 APPLICABLE FEDERAL EMISSIONS STANDARDS 3-8

4. BEST AVAILABLE CONTROL TECHNOLOGY ANALySES 4-1

4.1 ANALYSIS PROCEDURE 4-1

4.2 BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS FOR OXIDES

OF NITROGEN 4-2

4.2.1 GENERATION OF OXIDES OF NITROGEN 4-2

4.2.2 STEP 1 - IDENTlFICATlON OF POTENTIAL CONTROL TECHNOLOGIES 4-4

4.2.3 STEP 2 - ELIMINATE TECHNICALLY I~'FEASIBLE OPTIONS 4-5

4.2.4 STEP 3 - RANK THE REMAINING CONTROL TECHNOLOGIES BY

CONTROL EFFECTIVENESS 4-6

4.2.5 STEP 4 - EVALUATE THE MOST EFFECTIVE CONTROLS AND DOCUMENT

THE RESULTS 4-7

4.2.6 COMPARISON OF NOx EMISSION RATES 4-13

4.2.7 EVALUATlON OF TECHNOLOGY COMBINATlONS 4-14

4.2.8 STEP 5 - SELECT BACT 4-16

4.3 BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS FOR

CARBON MONOXIDE 4-18

4.3.1 STEP 1 - IDENTIFICATION OF POTENTIAL CONTROL TECHNOLOGIES 4-18

4.3.2 STEP 2 - ELIMINATE TECHNICALLY INFEASIBLE OPTIONS 4-21

4.3.3 STEP 3 - RANK THE REMAINING CONTROL TECHNOLOGIES BY

CONTROL EFFECTIVENESS 4-22

4.3.4 STEP 4 - EVALUATE THE MOST EFFECTIVE CONTROLS AND DOCUMENT

THE RESULTS 4-22

GCCDacotah Trinity Consultants
REVISED DECEMBER 12, 2002

4.3.5 STEP 5 - SELECT BACT 4-25

5. SUMMARY OF AIR QUALITY ANALYSES ••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••.•••••• 5-1

5.1 RESULTS FROMNAAQS AND INCREMENT CONSUMPTION ANALYSES 5-1

5.2 SYNOPSIS OF RESULTS FROM CLASS I AREA ANALYSES 5-2

5.3 ADDITIO~AL IMPACTS ANALYSIS 5-2

5.3.1 GROWTH Ii\IPACTS 5-2

5.3.2 SOILS AND VEGETATION 5-2

5.3.3 CLASS I AREA INCREMENT ANALYSIS 5-3

6. PERMIT LIMITS AND COMPLIANCE DEMONSTRAnON 6-1

6.1 COMPLIANCE DEMONSTRATION FOR NOx 6-1

6.2 COMPLIANCE DEMONSTRATION FOR CO 6-3

ApPENDIX A. SOURCE IDENTIFICATION FORMS ••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• I

ApPENDIX B. PSD NETTING ANALySIS II

APPENDIX C. SOURCE IDENTIFICATION •••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• 111

GCCDacotah ii Trinity Consultants
LIST OF FIGURES

FIGURE 2-1. GCC DACOTAH AREA MAP 2-2

FIGURE 2-2. GENERIC PORTLAND CEMENT MANUFACTURING PROCESS 2-3

FIGURE 2-3. KILN No.6 PROCESS FLOW DIAGRAM 2-5

FIGURE 2-4. PROPOSED PRELIMINARY PROCESS FLOW DIAGRAM 2-8

GCC Dacotah II Trinity Consultants
REVISED AUGUST 31, 2002

LIST OF TABLES

TABLE 3-1. PSD SIGNIFICANT EMISSION RATES 3-2

TABLE 3-2. NET NOx EMISSIONS CHANGE FOR PRIOR MODIFICATIONS AND PROPOSED

UPGRADES!MODIFICATIONS (TONS PER YEAR) 3-3

TABLE 3-3. NET CO EMISSIONS CHANGE FOR PRIOR MODIFICATIONS AND PROPOSED

UPGRADES!MODIFICATIONS (TONS PER YEAR) 3-3

TABLE 3-4. NET VOC EMISSIONS CHANGE FOR PRIOR MODIFICATIONS AND PROPOSED

UPGRADES!MODIFICATIONS (TONS PER YEAR) ...................................................•................ 3-3

TABLE 4-1. LONG-TERM NOxEMISSION FACTORS FOR DIFFERENT KILN TYPES 4-4

TABLE 4-2. NOx CONTROL TECHNIQUES RANKED FROM HIGHEST TO LOWEST ESTIMATED REMOVAL

EFFECTIVENESS 4-7

TABLE 4-3. LONG-TERM NOx EMISSION RATES NORMALIZED TO CLINKER PRODUCTION FROM EPA

RBLC AND/OR RECENTLY ISSUED PERMITS FOR PREHEATERIPRECALCINER PORTLAND

CEMENT KILNS 4-14

TABLE 4-4. SUMMARY OF EPA RBLC INFORMATION FOR PORTLAND CEMENT KILNS (CO

DETERMINATIONS, 1990-2000) 4-19

TABLE 4-5. RANKING OF AVAILABLE CO CONTROL OPTIONS BASED ON CONTROL EFFICIENCY. 4-22

TABLE 5-1. MAxIMUM PREDICTED AMBIENT IMPACTS FORNOzAND CO 5-1

TABLE 5-2. MAXIMUM CONCENTRATIONS RESULTING AT THE BADLANDS AND WIND CAVE CLASS I

AREAS 5-3

TABLE 6-1. REQUESTED PERMIT LIMITS AND COMPLIANCE DEMONSTRATION FORNOx 6-2

TABLE 6-2. REQUESTED PERMIT LIMITS AND COMPLIANCE DEMONSTRATION FOR CO 6-3

GCCDacotah iii Trinity Consultants
REVISED DECEMBER 12, 2002

LIST OF TABLES

TABLE 3-1. PSD SIGNIFICANT EMISSION RATES 3-2

TABLE 3-2. NET NO, EMISSIONS CHANGE FOR PRIOR MODIFICATIONS AND PROPOSED

UPGRADESIMODIFICATIONS (TONS PER YEAR) 3-3

TABLE 3-3. NET CO EMISSIONS CHANGE FOR PRIOR MODIFICATIONS AND PROPOSED

UPGRADESIMODIFICATIONS (TONS PER YEAR) 3-3

TABLE 3-4. NET VOC EMISSIONS CHANGE FOR PRIOR MODIFICATIONS AND PROPOSED

UPGRADESIMODIFICATIONS (TONS PER YEAR) 3-3

TABLE 4-1. LONG-TERJ\1 NO,EMISSION FACTORS FOR DIFFERENT KILN TYPES 4-4

TABLE 4-2. NOx CONTROL TECHNIQUES RANKED FROM HIGHEST TO LOWEST ESTIMATED

REMOVAL EFFECTIVENESS 4-7

TABLE 4-3. LONG-TERM NOx EMISSION RATES NORMALIZED TO CLINKER PRODUCTION FROM

EPA RELC AND/OR RECENTLY ISSUED PERMITS FOR PREHEATERIPRECALCINER

PORTLAND CEMENT KILNS 4-14

TABLE 4-4. SUMMARY OF EPA RELC INFORMATION FOR PORTLAND CEMENT KILNS

(CO DETERMINATIONS, 1990-2000) 4-19

TABLE 4-5. RANKING OF AVAlLABLE CO CONTROL OPTIONS BASED ON CONTROL EFFICIENCY. 4-22

TABLE 5-1. MAxIMUM PREDICTED AMBIENT IMPACTS FORN02 AND CO 5-1

TABLE 5-2. MAXIMUM CONCENTRAnONS RESULTING AT THE BADLANDS AND

WIND CAVE CLASS I AREAS 5 -3

TABLE 6-1. REQUESTED PERMIT LIMITS AND COMPLIANCE DEMONSTRATION FOR NOx 6-2

TABLE 6-2. REQUESTED HOURLY PERMIT LIMITS AND COMPLIANCE DEMONSTRATION FOR CO ... 6-3

TABLE 6-3. REQUESTED ANNUAL PERMIT LIMITS AND COMPLIANCE DEMONSTRATION FOR CO ... 6-4

GCCDacotah IV Trinity Consultants
1. INTRODUCTION

GCC Dacotah, a South Dakota Corporation, purchased the Dacotah Cement plant located in Rapid

City, South Dakota in January, 2001. From 1994 to 1996, the previous owner (Dacotah Cement)

performed modifications on Kiln No.6 at this plant. These modifications are being addressed

pursuant to a Compliance Plan and Schedule issued by the South Dakota Department ofEnvironment

and Natural Resources (SD DENR), dated February 26, 2001. The Compliance Plan requires that a

Prevention of Significant Deterioration (PSD) permit application be submitted for oxides of nitrogen

(NOx); this PSD permit application is submitted in accordance with that requirement.! An analysis of

the expected CO emissions has determined that PSD review is also necessary for this pollutant.

Therefore, a PSD permit is also being sought for CO emissions.

This application is divided into the following sections:

• Section 2 - Project Background and Overview. In this section, the location ofthe GCC Dacotah

.facility, an area map showing roads and residential areas, and the process description, which are

required by the general application form, are presented.

• Section 3 - PSD Applicability, Emissions Standards, and Requirements. The methodology for

determining PSD review applicability is presented. The PSD permit application requirements, the

applicable federal emission standards, and the SD DENR applicable requirements are also

discussed.

• Section 4 - Best Available Control Technology (BACT) Analyses. The analyses for NOxand CO

are presented.

• Section 5 - Summary of Air Quality Analyses. Summary results ofthe ambient air quality

analyses are presented. An analysis ofthe effects on soils and vegetation and an analysis of

associated growth are also included.2,3 Separate reports for Class I area modeling using the

CALPUFF model and non-Class 1 area modeling using the Industrial Source Complex ShortTerm version 3 (ISCST3) model are being submitted to SD DENR under separate cover.

• Section 6 - Permit Limits and Compliance Demonstration. Requested PSD permit limits are

presented and discussed.

• Appendix A - Permit Application Forms. The SD DENR general forms and forms for the

emission sources are included in Appendix A.

• Appendix B - PSD Netting Analysis. A detailed netting analysis is included in Appendix B.

• Appendix C - Source Identification. A table correlating the source numbers used in this permit

application to the Title V operating permit source numbers is contained in Appendix c.4

Based on the results ofthe modeling analyses, nitrogen dioxide (N02) and CO emissions due to the

modifications do not contribute to a violation ofthe National Ambient Air Quality Standards

(NAAQS) and compliance with the applicable United States Environmental Protection Agency (EPA)

I GCC Dacotah submitted a PSD permi! application for particulate matter less than 10 microns (PMIO) to SD DENR on

November 15,2001, for the 1996 Kiln No.6 modification project and the proposed modifications.

2 An analysis of the effects on soils and vegetation is required by Title 40 Code of Federal Regulations (40 CFR) Section

51.166 (0)(1).

3 An associated growth analysis is required by 40 CFR Section 51.166 (n)(3)(ii).

4 The South Dakota Operating Permit was issued to the previous facility owner on February 18, 1999.

GCC Dacotah I-I Trinity Consultants
air quality standards is demonstrated. The analyses also reveal that PSD increments are not

consumed. Furthermore, the analysis ofthe effects on soils and vegetation shows that the impacts are

negligible and the associated growth analysis reveals negligible growth-related air pollution impacts.

GCC Dacotah 1-2 Trinity Consultants
2•. PROJECT BACKGROUND AND OVERVIEW

This section ofthe permit application provides an overview ofthe portland cement manufacturing

process and description ofthe modifications addressed by this permit application. This section also

provides additional information on the plant location, process description, and background of project

modifications.

2.1 LOCATION OF FACILITY

The facility is located in Rapid City, South Dakota, within the county of Pennington. An area map

consisting ofthe plant property line overlaid upon the most recent United States Geological Survey

(USGS) 7.5-minute series topographical map ofthe area (1 :24,000 scale) is provided in Figure 2-1.

The area map shows terrain contours and the facility property relative to predominant geographical

features such as highways, roads, and streams, as well as significant landmarks. The Class 1 areas

nearest to the facility are the Badlands National Park located 55 kilom(lters (km) southeast ofthe

facility, and the Wind Cave National Park located 51 km south ofthe facility.

2.2 PROCESS DESCRIPTION

The following sections describe the processes and equipment used to manufacture portland cement.

The manufacturing process can be divided into three major operations: 1) kiln feed preparation, 2)

clinker production, and 3) finished cement grinding. A general process overview ofthe portland

cement manufacturing process is presented in Figure 2-2. The Standard Industrial Classification

Code for cement manufacture is 3241

GCC Dacotah 2-1 Trinity Consultants
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GCCDacotah

e Figure 2-2

Generic Portland Cement

Manufacturing Process

T~tyL). January 2002 COns tahts 014401.0088
REVISED AUGUST 31,2002

2.2.1 KILN FEED PREPARATION

The basic ingredients ofthe raw feed to a cement kiln include calcium carbonate and the

oxides ofsilicon, aluminum, and iron. Because ofthe large requirement for calcium

carbonate, portland cement plants are generally located near the source ofthe calcareous

material (limestone in the case ofGCC Dacotah). The limestone used in Kiln No.6 at the

GCC Dacotah plant is mined from a quany located at the site. Limestone is transported

from the quany to a crusher that reduces the rock to the desired size. Other raw materials,

iron ore from off-site sources, sand from the sand pit, and shale from the shale quany, are

carefully proportioned and added to the limestone to form the raw material mixture. An inline, roller mill is used to simultaneously dry and grind the raw materials to the desired

fineness. Hot preheater exhaust gas is used as the source ofthermal energy to dry the raw

materials. The dry powdered raw materials are collected in a particulate matter (PM)

control device, Le., cyclones and a baghouse-fabric filter (FF), and are subsequently fed to

a blending system that provides Kiln No.6 with a chemically homogenous raw feed. The

filtered gas is emitted to the atmosphere through the main kiln stack.

Because the raw material is dried prior to being fed to the kiln system, Kiln No.6 is

classified as a dry process kiln. In addition, Kiln No.6 is equipped with a preheater tower

and a calciner vessel, and is further classified as a preheater/precalciner kiln. Kiln systems

ofthis type are the most energy efficient kind currently in use in the cement industry. Kiln

No.6 is also equipped with an alkali by-pass system to reduce the concentration of

deleterious alkali salts in the [mal product. A small portion ofthe rotary kiln exit gas that

contains volatilized sodium and potassium is removed, processed, and emitted to the

atmosphere through a dedicated stack (the alkali by-pass stack), that is separate from the

main kiln stack.

A coal mill/dryer dries and grinds coal prior to its introduction into the kiln and the

calciner through an indirect firing system. Hot preheater exhaust gas is also utilized for

drying the coal and for conveying the powdered coal from the mill/dryer to a cyclone

collector and two baghouses in which it is collected prior to transfer to a coal storage bin.

Gas flowing through the two baghouses is combined and emitted to the atmosphere

through a dedicated vent (the coal mill/dryer stack), that is separate from the main kiln

stack.

The process flow diagram for Kiln No.6 is shown in Figure 2-3. Kiln No.6 and associated

equipment are the sources that are subject to PSD review as described in this application.

It should be noted that the facility also operates Kiln Nos. 4 and 5 that are wet process

types and have not been modified as part ofthe project covered by this application.

GCCDacotah 2-4 Trinity Consultants
e _

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Gee Dacotah

Figure 2-3

Kiln No.6

Process Flow Digram

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"T:'., n... InUt

ltyA- UJnsu tahts 014401.0088
2.2.2 CLINKER PRODUCTION

The production of portland cement clinker involves high temperature processing to

complete the chemical reactions that are necessary to convert the raw materials into clinker

within the pyroprocessing system. The preheatertower of Kiln No.6 is a succession of

vessels arranged in vertical series in which rising, hot gas from the rotary kiln and calciner

pass countercurrent to the falling raw materials. Very efficient heat transfer is

accomplished in a short time. At the base ofthe preheater tower is a vessel known as a

calciner in which the calcium carbonate component ofthe raw feed is almost completely

calcined in direct contact with burning coal. The product ofthe calciner is introduced into

the feed end ofthe rotary kiln. The rotary cement kiln is common to all clinker

manufacturing processes. It isa nearly-horizontal, countercurrent heating device in which

the material fed into the relatively-cool, upper end is slowly moved by gravity to the hot

end prior to its discharge into the clinker cooler. The burning coal at the discharge end of

Kiln No.6 produces a current of hot gas that further heats the calcined material to

clinkering temperature as the hot gas passes upward toward the feed end.

The cement clinker formation process in the kiln system may be divided into several

stages. In the preheater, uncombined water evaporates from raw materials as the material

temperature increases to the boiling point ofwater. Combined water is also liberated from

argillaceous components as the material temperature increases in the preheater to the point

of calcination. Subsequently, calcination occurs in the calciner in which carbon dioxide is

liberated from the calcium carbonate to yield calcium oxide. In the burning zone ofthe

kiln, sintering ofthe oxides occurs. The sintering (or clinkering) reactions combine

calcium oxide with silica, alumina, and iron oxide to form tricalcium silicate (C3S),

dicalcium silicate (C2S), tricalcium aluminate (C3A), and tetracalcium aluminoferrite

(C4AF). The product ofthis sintering stage is called clinker. The clinker is subsequently

cooled in a clinker cooler through direct heat transfer with ambient air.

2.2.3 FINISHED CEMENT GRINDING

The cooled clinker is sent to storage and then to the'finish mills where it is combined with

a small amount of gypsum (obtained from the gypsum quarry) and ground to a fine,

homogenous powder. The finished portland cement is transferred from the mills to cement

storage silos prior to shipment off-site.

GCC Dacotah 2-6 Trinity Consultants
2.3 1996 KILN No.6 MODIFICATION PROJECT

The project completed in 1996 included a variety of physical modifications to Kiln No.6 and its

appurtenances, as described in the netting analysis contained in Appendix B.

2.4 PROPOSED BACT RELATED MODIFICATIONS

As part of continued improvements, GCC Dacotah has proposed additional emissions control efforts,

as described in the BACT analysis described in Section 4 ofthis document.

A schematic is shown in Figure 2-4. These BACT related modifications are expected to reduce NO,

emIssIons.

GCC Dacotah 2-7 Trinity Consultants
GCC Dacotah

Figure 2-4.

PROPOSED PRELIMINARY

PROCESS FLOW DIAGRAM

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JANUARY 2002

014401.0088

• • c D
3. PSD ApPLICABILITY, EMISSIONS STANDARDS, AND REQUIREMENTS

This section discusses the permitting requirements and key applicable emissions standards for the

proposed project. Additionally, a discussion ofthe permit application requirements is also provided

herein.

3.1 PSD APPLICABILITY

In the 1977 Amendments to the federal Clean Air Act (CAA), Congress enacted a program for the

PSD regulations defining the requirements that a state must meet ifthat state chooses to adopt and get

EPA approval of a PSD program (42 U.S.C. §§7410(a)(2)(D), 7471). Among the PSD requirements

imposed, the state must require any proposed major emitting facility subject to the PSD program to

apply BACT for each pollutant subject to regulation under the CAA that the source emits in a

significant amount(42 U.S.C. §§7475(a)(4)). Under theCAA, BACT limits are. to be determined on

a case-by-case basis after taking into account energy, environmental, and economic impacts and other

costs (42 U.S.C. §§7479(3)).5

South Dakota has an EPA-approved PSD program, pursuant to an EPA-approved State Implementation

Plan (SIP). South Dakota air quality regulations require that BACT be applied to major modifications

for each pollutant with a significant net emission increase (NEI). The NEls are equal to the PSD

Significant Emission Rates (SER) as South Dakota adopted the federal PSD regulations.6 NOx

emissions resulting from the 1996 Kiln No.6 modification project have been determined to have been

above the significant NEI.'· 8

The regulation contained in 40 CFR Section 8I.342 documents that South Dakota has been

designated by the EPA as an area which is in attainment or unclassifiable for all criteria pollutants.9

As a portland cement manufacturing plant, GCC Dacotah is included in the list of 28 PSD source

categories with major source thresholds of 100 tons per year (tpy), and based on potential to emit, the

facility is considered a major source. As a major source in an attainment region, the facility is

potentially subject to the PSD permitting requirements as specified in ARSD 74:36:01: I5.

Under the applicable PSD permit regulations, a project is subject to PSD review ifthere is a physical

or operational change that results in a net emissions increase that exceeds the applicable SER for any

5 The only constraint the CAA places on the BACT determination is that the final BACT decision not yield an emission

limit less stringent than any applicable New Source Performance Standards (NSPS) or National Emission Standards for

Hazardous Air Pollutants (NESHAP). The minimum control efficiency to be considered BACT must result in an emission

rate less than or equal to any NSPSINESHAP emission limit. In other words, the applicable NSPSINESHAP represents the

maximum allowable emission limit from an emission source. However, neither ofthese federal emissions standards limits

the emissions ofNOx or CO and they therefore do not place a constraint on the BACT control efficiency.

6 Administrative Rules ofSouth Dakota (ARSD) 74:36:09:02.

, Compliance Plan and Schedule dated February 26, 2001, as noted in a letter dated March 30, 2001, from Steven M. Pimer,

SD DENR, to Steve Zellmer, Dacotah Cement.

8 When NOx is referred to as mass value in this application, it is provided in terms ofN02 or N02 equivalent, except as

otherwise noted.

9 40 CFR, Part 81, §81.342, July 1,2000, pp. 261-263.

GCC Dacotah 3-I Trinity Consultants
REVISED AUGUST 31, 2002

regulated pollutant. An emissions netting analysis is performed in which the total ofthe resulting net

emission changes due to the project and contemporaneous changes are compared to the SERs. Table

3-1 lists the SERs for the PSD Regulated Pollutants.

TABLE 3-1. PSD SIGNIFICANT EMISSION RATES

Pollutant Significant Emission

Rate (TonslYear)

Carbon Monoxide (CO) 100

Oxides ofNitrogen (NO,) 40 .

Sulfur Dioxide (S02) 40

Particulate Matter with a diameter of 10 micrometers or less (PMIO) 15

Total Suspended Particulate Matter (TSP) 25

Ozone (volatile organic compounds (VOCs» 40

Lead (Pb) 0.6

Fluorides (F) 3

Sulfuric Acid Mist 7

Total Reduced Sulfur (including H2S) 10

Hydrogen Sulfide 10

For each pollutant for which the net emission rate is determined to exceed the SER, the applicant

must submit a PSD permit application addressing the following items:

• BACT

• PSD Ambient Air Increments (including Class I areas, where applicable)

• NAAQS

• Effects on Soils and Vegetation

• Indirect Growth

3.1.1 EMISSION NETTING RESULTS

The netting analysis shows that the NO, and CO NEI exceeded the SER as a result ofthe

1996 Kiln No.6 modifications and/or proposed modifications. A detailed netting analysis

is contained in Appendix B. In addition, a netting analysis was also conducted for VOC

(presented in Appendix B), which shows that the VOC NEI is below the SER. A summary

ofthe net emission changes for NO" CO, and VOC (based upon a production capacity of

2,250 tons per day (tpd) of clinker) is provided in Tables 3-2 to 3-4.

GCCDacotah 3-2 Trinity Consultants
REVISED DECEMBER 12, 2002

TABLE 3-2. NET NOxEMISSIONS CHANGE FOR PRIOR MODIFICATIONS AND PROPOSED

UPGRADESIMODIFICATIONS (TONS PER YEAR)

Net change In emISSIOns IS compared to a SER of 40 tpy.

Baseline Emissions Potential Emissions

Two Year Average After NO, BACT Net Change in

Source Description 1993-1994 Related Modifications Emissions

New and Physically 1,124.99 2,152.27 1,027.28

Modified Sources

Associated Sources 70.41 114.56 44.15

Total 1,071.43*

•

TABLE 3-3. NET CO EMISSIONS CHANGE FOR PRIOR MODIFICATIONS AND PROPOSED

UPGRADESIMODIFICATIONS (TONS PER YEAR)

Net change 10 emISSIOns IS compared to a SER of 100 tpy.

Baseline Emissions Potential Emissions

Two Year Average After NO, BACT Net Change in

Source Description 1992-1993 Related Modifications Emissions

New and Physically 198.59 1,911.32 1,712.73

Modified Sources

Associated Sources 9.25 114.56 105.31

Total 1,818.04*

•

TABLE 3-4. NET VOC EMISSIONS CHANGE FOR PRIOR MODIFICATIONS AND PROPOSED

UPGRADESIMODIFICATIONS (TONS PER YEAR)

Baseline Emissions Potential Emissions

Two Year Average After NOxBACT Net Change in

Source Description 1992-1993 Related Modifications Emissions

New and Physically 36.48 66.2 29.72

Modified Sources

Associated Sources* 1.70 3.97 2.27

Total 31.99*

• Net change 10 elUlsS!ons IS compared to a SER of 40 tpy.

GCC Dacotah 3-3 Trinity Consultants
REVISED DECEMBER 12, 2002

In determining the net emission increases for NO" an actual emissions "baseline" (prior to the

modifications) was determined to be the average emissions of 1993 and 1994. This value was then

subtracted from the potential emissions from the source following the proposed modifications to

determine the net change in emissions. As CO emission values were not reported in 1993 and 1994,

an AP-42 emission factor was used instead.1O This factor was multiplied with the average annual

clinker production, as reported in the 1992 and 1993 Emission Inventories, to yield the actual

emissions because the 1994 EI does not report clinker production. The average clinker production for

1994 is not reported in the 1994 Emissions Inventory; therefore, NO, emissions for 1994 cannot be

calculated. The selection ofrepresentative baseline years of 1992 and 1993 is based on data

completeness. The actual emissions for VOC were determined in the same manner, as shown in

Appendix B.

The net change in emissions of 1,071.43 tpy ofNO, and 1,818.04 tpy ofCO (shown in Tables 3-2 and

3-3) exceed the respective SERs ofthese pollutants. Therefore, the project is subject to PSD review

for NO, and CO. Since the net change in emissions of 31.99 tpy for VOC (shown in Table 3-4) is

less than its SER, a PSD review is not required for VOC.

3.2 SD DENR PERMIT ApPLICATION REQUIREMENTS

This permit application has been prepared in accordance with the provisions ofthe South Dakota

Codified Laws (SDCL) 34A-I-21, which requires permitting for alterations. South Dakota has

adopted the Federal PSD rules by reference and the SD DENR has fully delegated PSD authority

pursuant to an EPA-approved SIP.

The PSD permit application requirements are:

• Timely and complete application. The Amended Compliance Plan requires submission ofthe

PSD permit application for NO, and CO on or before January 20, 2002. South Dakota PSD

regulations (ARSD 74:36:01:06) utilize the definition of "complete" contained in 40 CFR Part

52.21(22), which is that "an application for a [PSD] permit...contains all ofthe information

10 EPA, Compilation ofAirPollutant Emission Factors, Volume I: Stationary Point and Area Sources, AP-42, Fifth Edition,

Office of Air Quality Planning and Standards, Research Triangle Park, NC, January 1995, Section 11.6, Table 11.6-8.

GCC Dacotah 3-4 Trinity Consultants
necessary for processing the application." The application is believed to be complete in this

regard and the completed SO OENR forms are presented herewith.

• Completeness review. The SO OENR is requested to review the application and make a written

determination of whether "completeness" has been achieved.

To facilitate this review, the following ARSO 74:36:05: 12 Operating Permit checklist and applicant

responses are provided as a means for assisting the SO OENR in conducting a review ofthe

completeness ofthis PSO permit application. Forms provided in this application are for source

identification purposes only. A separate Title V operating permit application and relevant

certification will be provided at a later date.

(I) General company information, including the company name and address or the plant name and

address ifdifferentfrom the company name, the owner's name and agent, and the plant site

manager or contact;

This item is included in the General Information Form in Appendix A.

(2) A plant description in terms ofthe processes andproducts identified by the Standard Industrial

Classification Code, 1987, including any associatedwith each alternate scenario Identified by the

source;

This description is provided in Section 2.

(3) Thefollowing information on emissions:

(a) All emissions ofpollutantsfor which the source is major and all emissions ofregulated air

pollutants. The applicant must describe all emissions ofregulated air pollutants emittedfrom

any emissions unit, except when such units are exempt;

(b) Identification and description ofall emission points described in subsection (a) ofthis

subdivision in sufficient detail to establish the basisforfees and the applicability of

requirements ofthe Clean Air Act;

(c) Emissions rates in total tons per year and in any other terms necessary to establish

compliance consistent with the applicable standard reference test method;

(d) Fuels, fuel use, raw materials, production rates, and operating schedules;

(e) Identification and description ofair pollutioncontrol equipment and compliance monitoring

devices or activities;

(f) Limits on source operation affecting emissions or any workpractice standards, as applicable

for all regulatedpollutqnts;

(g) For all pollutants regulated at the source, other information required by any applicable

requirements including information related to stack height limits, such as the location of

emissions units, flow rates, building dimensions, and stackparameters, including height

diameter, andplume temperature; and

(h) Calculations on which the items in this subdivision are based; .

This information is provided in the accompanying application forms (Appendix A), permit limit and

compliance plan (Section 6.0), and CALPUFF and ISCST3 modeling reports.

GCC Dacotah 3-5 Trinity Consultants
(4) One copy ofany preparedplans and the specifications ofany equipment or otherfacilities that

may affect the S01,lrce, includingpollution control devices;

This item is provided via the forms for sources in Appendix A.

(5) An abatement strategies plan, ifrequired by chapter 74:36:03;

This plan is not required.

(6) A signed and notarized certification ofapplicantform, as provided by the department;

This item will be submitted with the operating permit application at a later date.

(7) The results ofany air dispersion modeling required by the department;

Tl)e modeling results are briefly summarized in Section 5 and discussed in detail in the accompanying

modeling reports.

(8) Citation and description ofall applicable air pollution control emission limit requirements;

This item is discussed in Sections 3.1 and 4.

(9) A review offugitive emissions included in the same manner as stack emissions, whether or not the

source is included in the list ofsources contained in the definition ofmajor source;

A review ofthe emissions sources under consideration indicates that there are no stationary fugitive

emissions ofNOx and CO.

(10) A description ofor reference to any applicable test methodfor determining compliance with

each applicable requirement;

This item is in Section 6.

(11) Any additional information that may be necessary to implement and enforce other requirements

ofthe Clean Air Act or to determine the applicability ofsuch requirements;

This submittal contains the information required. The facility's South Dakota Operating Permit will

be revised to include all future applicable requirements as a result ofthis PSD application.

(12) An explanation ofany proposed exemptionsfrom otherwise applicable requirements;

No exemptions are claimed.

GCC Dacotah 3-6 Trinity Consultants
(13) The use ofstandardizedformsfor acid rain portions ofpermit applications and compliance

plans;

This requirement is not applicable.

(14) Information necessary to define reasonably anticipated alternative operating scenarios, to

define permit terms and conditions pursuant to § 74:36:05:30, or to implement afederally

enforceable emission cap;

This item is discussed in Section 6.

(15) A compliance plan that contains all ofthe following and is at least as stringent as that

contained in anyjudicial consent decree or administrative order to which the source is subject:

(a) A description ofthe compliance status ofthe source jor all applicable requirements,

including applicable requirements that will become effective during the term ofthe permit;

(b) A description ofthe requirementsfor which the source is not in compliance at the time of

permit issuance and a narrative description and a compliance schedule ofhow the source

will achieve compliance with such requirements. The compliance schedule must include a

statement that progress reports will be submitted at least once every six months; and

(c) A statement that the source will continue to demonstrate compliance with applicable

requirements;

A Compliance Plan has been issued by the SO OENR. A PSO compliance schedule is being provided

under separate cover.

(16) A certification ofcompliance by a responsible official that addresses all air pollution control

requirements applicable to the source. A certification ofcompliancefor an affectedsource

subject to Title IVand chapter 74:36:16 must be submittedby the designatedrepresentptive.

This certification must be consistent with any applicable enhanced monitoring and compliance

certification requirement ofthe Clean Air Act and must include:

(a) A statement indicating methods used to determine compliance, including monitoring,

record keeping and reporting requirements, and test methods;

(b) A statement that compliance certifications will be submitted at least annually or at other

designated timesfor the duration ofthe permit to the department;

(c) A statement that the source is in compliance with all applicable requirements;

(d) A statement identifying the condition ofthe permit that is the basis ofthe certification,

indicating the compliance status, and identifying whether compliance is continuous or

intermittent; and

(e) A statement indicating the source's compliance status with any applicable enhanced

monitoring and compliance certification requirements ofthe Clean Air Act;

This item will be submitted with the operating permit application at a later date.

GCC Oacotah 3-7 Trinity Consultants
(17) A certification by a responsible official ofthe truth, accuracy, and completeness ofany

applicationform, report, or compliance certification submitted to the department. This

certification and any otherrequired certification muststate that, based on information and

beliefformed after reasonable inquiry, the statements and information in the documents are

true, accurate, and complete; and

This item will be submitted with the operating permit application at a later date.

(18) Any other information requested by the department aftersubmission ofan applicationfor a

permit to operate a Part 70 source which is relevant to determine compliance ofthe source

with the Clean Air Act. An applicationfor a renewal ofan operatingpermitfor a Part 70

source may refer to previously submittedmaterial.

Revisions to the facility's current South Dakota Operating Permit will be sought in the future in

accordance with applicable requirements in order to reflect any additional or new applicable

requirements that may result from this PSD permit application.

3.3 ApPLICABLE FEDERAL EMISSIONS STANDARDS

The NSPS contained in 40 CFR 60, Subpart A, General Provisions, and Subpart F, Standards of

Performance for Portland Cement Plants, apply to Kiln No.6, the Loesche Mill, and the associated

Fuller Dry Process Clinker Cooler. In addition to 40 CFR 60, Subpart A, the Coal Dryer - Coal

System No.6 is subject to the requirements of 40 CFR 60, Subpart Y, Standards of Performance for

Coal Preparation Plants. The facility may also be subject to the requirements ofthe NESHAP at 40

CFR 63, Subpart A, General Provisions, and Subpart LLL, NESHAP for the Portland Cement

Manufacturing Industry. None ofthe aforementioned standards specifies emission requirements for

NOxorCO.

GCC Dacotah 3-8 Trinity Consultants
4. BEST A VAILABLE CONTROL TECHNOLOGY ANALYSES

A technical review has been performed to investigate and quantify emission controls that have

recently been determined by various permitting authorities across the United States (U.S.) to satisfy

BACT requirements for NO, and CO from portland cement manufacturing facilities.

Trinity Consultants has significant experience in applying the federal and state regulatory mandates

for determining BACT, on a case-by-case basis, after taking into account energy, environmental, and

economic impacts and other costs. The EPA's Reasonably Available Control Technology (RACT) I

BACT I Lowest Achievable Emission Rate (LAER) Clearinghouse (RBLC)

(http://www.epa.gov/ttn/catc) and other sources were queried to determine what emission controls

have been recently accepted by permitting authorities as BACT for NO, and CO.

This section ofthe application presents the BACT analysis. The control technologies proposed in this

section as BACT for NOx and CO are consistent with recent determinations by various permitting

authorities to be BACT for cement kiln systems and material handling at portland cement plants.

It should be noted that in the evaluation oftechnologies in this section, Trinity Consultants has

utilized "normalized" emission data (i.e., expressed in pounds per ton of clinker) from various

technical sources for the purpose of comparing BACT alternatives to one another. These normalized

emission rates are not to be interpreted as short-term permit limitations, due the inherent variability of

emissions from cement kilns. Accordingly, the establishment of permit limits for protection of shortterm NAAQS must be distinct from the determination of BACT for PSD permitting purposes and the

resulting annual emission rate limits.

4.1 ANALYSIS PROCEDURE

The following steps have been utilized to determine BACT for Kiln No.6 for NO, and CO based

upon the process outlined in draft guidance published by the EPA: l1

I. Step I - Identify potential control technologies

2. Step 2 - Eliminate technically infeasible options

3. Step 3 - Rank remaining control technologies by control effectiveness

4. Step 4 - Evaluate most effective controls and document results

5. Step 5 - Select BACT

I 1 EPA, Office of Air Qualily Planning and Standards, New Source Review Workshop Manual: Prevention ofSignificant

Deterioration and Nonattainment Area Permitting, DRAFT, October 1990; pp. B.5 - B.9.

GCC Dacotah 4-1 Trinity Consultants
4.2 BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS FOR OXIDES OF

NITROGEN

In this analysis, the three emission points emanating from the Kiln No.6 system, Le., the main stack,

the alkali by-pass stack and the coal mill/dryer stack, are considered separately for purposes of a

BACT evaluation.

The NOx concentrations ofthe three streams are influenced by common causes. NOx control

strategies that are applied to the burner ofthe rotary kiln affect emissions from the alkali by-pass

stack, the coal mill/dryer stack and the main stack because all three emission points are downstream

in the gas flow path ofthis source ofNOx• On the other hand, NOx control strategies applied to the

precalciner affect the coal mill/dryer stack and the main stack, but not the alkali by-pass because the

extraction point for the by-pass is upstream in the gas flow path from the precalciner. As a result,

available control strategies vary.

To supplement the hot gas from the preheater tower, an auxiliary burner is required to provide

additional thermal energy to dry the highly wet coal. This auxiliary burner uses natural gas and,

therefore, also contributes a small amount ofNOx emissions, which emit from the coal mill/dryer

emission point.

4.2.1 GENERAnON OF OXIDES OF NITROGEN

In portland cement kilns, NO. is produced during fuel combustion by two primary

mechanisms: 12

I. Oxidation of molecular nitrogen present in the combustion air, which yields "thermal

NO•."

2. Oxidation of nitrogenous compounds present in the fuel, which yields "fuel NOx'"

Occasionally, the raw material feed to a cement kiln (typically a mixture oflimestone,

shale, sand, and iron ore) contains nitrogenous compounds that have the potential to be

oxidized to yield relatively small quantities of "feed NOx." The contribution offeed NOx

to overall NOx emissions from a cement kiln is thought to be minimized in a preheater/

precalciner system such as Kiln No.6 due to the relatively quick heating ofthe raw

materials when compared to a traditional rotary kiln. 13 Due to the very high flame

temperature (-3,400 OF) in the burning zone ofthe kiln where clinker is formed, NOx

emissions from the rotary kiln predominantly originate as thermal NO•. Because of

relatively low-temperature (1,500 to 2,000 OF) combustion in a calciner, NO. emissions

from the calciner originate predominantly as fuel NO. if nitrogenous compounds are

present in the fuel. Although NO. emissions from cement kilns include both nitrogen

12 EPA, Alternative Control Techniques Document - NOx Emissionsfrom Cement Manufacturing, (EPA-453/R-94-004,

March 1994), p. 4-1.

13 Penta Engineering Corporation, NO, Formation and Variability Potenti~l in Portland Cement Kilns Potential Control

Techniques and Their Feasibility and Cost Effectiveness, Portland Cement Association, R&D Serial Number 2227, 1999,

p.8.

GCC Dacotah 4-2 Trinity Consultants
oxide (NO) and N02, only a small fraction (typically less than 10 percent (%)) ofthe NOx

(in the stack) is N02•

14

Due to the many factors which playa role in NOx formation in a cement kiln (e.g., a

variable flame temperature in the rotary kiln of approximately 3,400 of or the amount of

excess air at the locations where fuel is burned in the rotary kiln, riser duct or calciner) and

the complex nature oftheNOx formation process in cement kilns, the NOx emission rates in

the cement industry, even for cement kilns in one ofthe four process classes, i.e., wet,

long-dry, preheater or preheater/precalciner, vary widely.ls Short-term NOx emission rates

(e.g., an hourly average) from the same kiln also have high variability under normal

operating conditions. Instantaneous and short-term emission rate data are not

representative ofthe long-term NOx emission rates guaranteed by vendors of cement

pyroprocessing systems. The BACT determinations in the RBLC represent long-term NOx

emission rates. This demonstrates the fact that variability in NOx emissions from the

portland cement manufacturing process has been recognized by EPA and state permitting

authorities. Even over the long term, the same NOx control strategy will not necessarily

produce identical results on cement kilns ofthe same process class or even ofsimilar

design within a process class.

Table 4-1 has been extracted from the Se'ptember 2000 EPA report, NO, Control Strategies

for the Cement Industry, and presents NOx emission factors for the four process (kiln)

types. 16 These data illustrate the variability ofNOx emission rates between and within

process classes, and the overlap ofNOx emission rates between classes. For the most part,

these factors are derived from continuous emission monitoring system data and represent

the best data that are currently available. It is clear that a lower thermal input per ton of

clinker results in a lower NOx emission factor. A preheater/precalciner kiln, such as Kiln

No.6, is in the process class with the lowest average NOx emissions. Since Kiln No.6 is

bdng retrofitted with a calciner ofrestricted dimensions because ofthe space constraints of

the existing preheater tower structure, it can be expected to have an emission factor at the

high end ofthe range for its process class. As a result ofthe calciner limitation, only 20-

25% ofthe total fuel for Kiln No.6 will be fed to the riser duct and calciner. Were Kiln

No.6 a new system, it would be designed to burn 55-60% ofthe total fuel in the riser duct

and calciner. Kiln No.6 cannot be configured as a "full" preheater/precalciner system and

represents necessary design compromises.

14 Nielsen, P.B., and O.L. Jepsen, An Overview ofthe Formation ofSO, andNO, in Various Pyroprocessing Systems,

presented at the IEEE Cement Industry Technical Conference XXXII, Tarpon Springs, Florida, May 22-24, 1990.

15 Personal Communication: Gene Nelson, GCC Dacotah, Jetter to Brian Gustafson, Administrator, SO DENR, dated April

12,2001 regarding the variability of NO, emissions from portland cement kilns.

16 Rebecca Battye, Stephanie Walsh, and Judy Lee-Greco, NO, Control Technologiesfor the Cement Industry, final report;

prepared for David Sanders, Ozone Policy and Strategies Group, Office of Air Quality Planning and Standards, EPA; (EC/R

Incorporated; September 19,2000), p. 49.

Gce Dacotah 4-3 Trinity Consultants
TABLE 4-1. LONG-TERM NOxEMISSION FACTORS FOR DIFFERENT KILN TYPES

Typical Heat Input Average NO, Range of NO,

.(MMBtu/ton of Emission Rate Emissions

Cement Kiln Type clinker) (Ib/ton of clinker) (Ib/ton of clinker)

Wet 6.0 9.7 3.6-19.5

Long Dry 4.5 8.6 6.1-10.5

Preheater 3.8 5.9 2.5-11.7

Preheater/Precalciner 3.3 3.8 0.9-7.0

4.2.2 STEP 1 - IDENTIFICATION OF POTENTIAL CONTROL TECHNOLOGIES

Based on the information contained in the RBLC and the recently issued EPA report on

NOx control technologies in the cement industry, the following list ofNOx control

technologies for portland cement kilns has been identified.17 The EPA report includes a

comprehensive review ofthe technologies previously contained in the EPA's alternative

control techniques document and the European Commission reference document. 18•

19

The NOx control technologies are categorized into the three types of control methods listed

below:

1. Combustion Control Methods

a. Staged Combustion

b. Low-NOx Burners

c. Flue Gas Recirculation (FGR)

d. Mid-Kiln Firing (MKF)

e. Tire-Derived Fuel (TDF)

f. Fuel Selection

g. Flame Cooling

2. NOx Removal Methods

a. Selective Catal~ic Reduction (SCR)

b. Selective Non-Catalytic Reduction (SNCR)

c. Bio-Solids Injection (BSI)

17 Rebecca Battye, op. cit., Chapter 5.

18 EPA, Alternative Control Techniques Document - NOx Emissionsfrom Cement Manufacturing (EPA-453/R-94-004,

March 1994).

19 EC~ Technologies for Sustainable Development, Integrated Pollution Prevention and Control (IPPC) Reference

Document on Best Available Techniques in the Cement and Lime Manufacturing Industries (European IPPC Bureau, March

2000).

GCC Dacotah 4-4 Trinity Consultants
3. Process Modifications

a. Process Control Improvements

b. Thermal Efficiency Improvements

c. CernStar Process

4.2.3 STEP 2 - ELIMINATE TECHNICALLY INFEASIBLE OPTIONS

Several factors must be considered when determining whether available control options

can be feasibly applied. Each control technology is considered and those that are clearly

infeasible based on physical, chemical, and/or engineering principles or limitations are

eliminated from further consideration. Based on the data provided in the aforementioned

literature, the following technologies, i.e., SCR, FGR, and MKF, are not considered

technically feasible for Kiln No. 6?0. 21 None ofthese control technologies has been

proven in the U.S. or Europe through full-scale, permanent application to preheater/

precalciner process kilns such as Kiln No.6. The following sections contain the technical

justification for eliminating each infeasible control technology.

4.2.3.1 SELECTIVE CATALYTIC REDUCTION

In the SCR process, ammonia is used as a reagent in the presence of a catalyst

to convert the NO, in the kiln flue gas to nitrogen and water. SCR has been

successfully used in the stack gas from combustion sources such as boilers and

electric power plants where gas streams are relatively clean.

Two types ofimpurities affect SCR catalyst: sulfur oxides and PM. The first

type causes poisoning to traditional catalyst materials so special catalysts such

as titanium dioxide or vanadium pentoxide should be used. On the other hand,

PM like that emitted from cement kilns, tends to foul catalysts obstructing their

pores. To avoid these problems, the SCR apparatus must be located following

the PM control device to minimize catalyst fouling. However, since SCR

requires a rather high temperature to be effective, exhaust gases from the

control device at a relatively low temperature (-300-400 OF) require reheating

to reach the necessary reaction temperature. This reheating needs the

combustion of additional fuel with a resulting decrease in overall thermal

efficiency ofthe process and an increase in combustion related pollutants other

than NO,.

Following a demonstration project, the EPA reported that the NO, removal

efficiencies dropped dramatically after a short period of operation in the only

full-scale demonstration of SCR on cement kilns.22 It was determined that

catalyst fouling was the cause ofthe drop in efficiencies. The EPA stated that

additional studies are needed to demonstrate SCR as a plausible NO, removal

20 Penta Engineering Corporation, op. cit., Chapter 4.

21 Rebecca Battye, op. cit., Chapter 5.

22 Rebecca Battye, op. cit., p. 69.

GCC Dacotah 4-5 Trinity Consultants
4.2.3.2

technique for cement kilns. Therefore, SCR is eliminated from further

consideration as a feasible technology for Kiln No.6.

FLUE GAS RECIRCULATION

FGR relies on recirculating a portion ofthe oxygen-deficient kiln exhaust gases

as primary air in the m~in burner to achieve a lower oxygen concentration in

the flame envelope. The intended effect ofFGR is a lower flame temperature

and reducing (oxygen-deficient) conditions in the flame to decrease both fuel

and thermal NOx formation.

The clinker-making process requires the heating ofthe raw material to about

2,700 OF for an optimum time to allow the desired chemical reactions to occur.

A relatively cool, long, lazy flame would be produced by FGR that is likely to

result in clinker of diminished or unacceptable quality because of an

inappropriate temperature profile in the burning zone and localized reducing

conditions. The clinkering reactions must take place in an oxidizing

atmosphere to produce a quality clinker that can be ground into cement meeting

the standards ofthe American Society for Testing and Materials or other

specifying organizations. Lastly, this technology has never been demonstrated

on a portland cement kiln. Therefore, FGR is not considered technically

feasible for Kiln No.6.

4.2.3.3 MID-KILN FIRING

The technique ofMKF is limited to the wet and long-dry cement kiln process

types where, with significant modifications, fuel can be fed directly into the

calcining zone at an appropriate point along the length ofthe kiln shell (i.e.,

mid-kiln). This technique is not applicable to preheater/precalciner kiln

systems because a significant portion ofthe calcination ofthe limestone

component ofthe raw mix takes place outside ofthe rotary kiln in the

calciner.23 Therefore, MKF is not technically feasible for Kiln No.6.

4.2.4 STEP 3 - RANK THE REMAINING CONTROL TECHNOLOGIES BY CONTROL

EFFECTIVENESS

Table 4-2 summarizes the technologies considered technically feasible for cement kilns

with a ranking based on NOx control effectiveness.

23 Rebecca Battye, op. cit., Table 5-10, p. 76.

GCC Dacotah 4-6 Trinity Consultants
TABLE 4-2. NOx CONTROL TECHNIQUES RANKED FROM HIGHEST TO LOWEST ESTIMATED

REMOVAL EFFECTIVENESS

NO, Control Technique

Staged Combustion

BSI

SNCR (via Ammonia or Urea Injection)

CemStar

Low-NO, Burner (with Indirect Firing System)

TDF

Process Control Methods

Increased Thermal Efficiency

Fuel Selection

Proper Kiln Operation

Estimated Removal Effectiveness • (%)

Up to 50

50 ••

10 to 50

23 to 40

4 to 47

30 to 40

Less than 25

Proportional

Unknown

0'"

• Rebecca Banye, op. Cll., Tables 5-9 and 5-11, pp. 75 and 77.

•• Estimated removal effectiveness is based on the results at only one facility at which the technology has been applied in

conjunction with TDF burning.

*** The base case removal effectiveness is listed-as 0 percent. The emission rate at 0 percent control is that achieved through

proper. normal operation. Ifthe kiln were not properly operated, the baseline emissions would be much higher.

4.2.5 STEP 4 - EVALUATE THE MOST EFFECTIVE CONTROLS AND DOCUMENT THE

RESULTS

This step involves the consideration of energy, environmental, and economic impacts

associated with each control technology as summarized below. The top-down BACT

process articulated in draft EPA guidance suggests that the evaluation begin with the most

effective technology. Ifthe "top" control technology is selected, evaluation ofthe

remaining technologies is not required.24 In this project, the application ofmore than one

control technology may be appropriate; therefore, all technically feasible NO. control

methods have been evaluated from the top down.

4.2.5.1 STAGED COMBUSTION

In principal, staged combustion is the burning offuel under sub-stoichiometric

conditions to reduce the formation of fuel and thermal NO.. This process

generates products of incomplete combustion, including CO, that is

subsequently burned when additional air (i.e., oxygen) is added to the flue gas

stream at a temperature that is low enough to suppress the formation of

additional thermal NO•.

24 Draft 1990 EPA NSR Workshop Manual, op. cit., p. B.8.

GCC Dacotah 4-7 Trinity Consultants
4.2.5.2

This process is applied to a cement kiln such as Kiln No.6 through the use of a

device known as an in-line, low-NO. calciner with riser-duct firing. Except for

the gas vented through the alkali by-pass for reasons of product quality, all the

gas from the rotary kiln is passed through a riser duct to the in-line calciner.

Hot tertiary air is ducted from the clinker cooler and is used for combustion in

the riser duct and calciner. Were it not for the tertiary air duct, the oxygen to

support combustion in the riser ductlcalciner would have to pass through the

combustion zone in the rotary kiln thereby increasing the oxygen concentration

at the main burner pipe location. This increased oxygen concentration near the

high-temperature flame would lead to higher NO. generation in the rotary kiln.

Fuel is burned in the riser duct under reducing (Le., oxygen deficient)

conditions. The absence of oxygen and the relatively low temperature at this

combustion site suppresses the formation offuel and thermal NO•. Finely

divided carbon from a solid fuel, e.g., coal, reacts with NO to form CO and

elemental nitrogen. The CO that is produced by this reaction and by

incomplete combustion reacts with the NO in the gas from the rotary kiln to

produce carbon dioxide and elemental nitrogen?5 Additional tertiary air is

added to the calciner vessel to bum out the residual CO in the gas stream. The

configuration ofthe calciner has been developed to minimize the formation of

NO. in that vessel. Overall, this process design reduces NO. formation in the

calciner and removes some ofthe NO. formed in the rotary kiln from the flue

gas stream. Staged combustion in an in-line, low-NO. calciner with riser duct

firing is applicable to Kiln No.6 as a method ofNO. reduction.

BIOSOLIDS INJECTION

There is only one application ofthis patented technology. This application is to

a cement kiln in California. Biosolids are the sludges resulting from the

treatment ofmunicipal wastewater. These "solids" are a liquid slurry of

70-84% moisture?6 The slurry is used as a pseudo-reagent and is a source of

ammonia for SNCR. Handling this material in winter weather in South Dakota

would be problematical at best. There must be a constant and adequate supply

of biosolids to reduce on-site inventory requirements and to feed the cement

kiln. The high water content ofthe biosolids causes an undesirable reduction in

the productive capacity ofthe pyroprocessing system and an increase in energy

consumption. Public relations problems associated with the use of biosolids

include health and odor concerns. Although BSI is being used at the California

plant, BSI is not regarded as a practical NO. reduction technology for Kiln No.

6 because ofthe surrounding neighborhood, the availability ofbiosolids, and

the local climate.

25 Rebecca Battye, op. cit., p. 64.

26 Rebecca Battye, op. cit., p. 72.

GCC Dacotah 4-8 Trinity Consultants
4.2.5.3 SELECTIVE NON-CATALYTIC REDUCTION

SNCR involves the reaction of ammonia with NOx without the benefit of a

catalyst to form elemental nitrogen and water. The source of ammonia can be

anhydrous ammonia, a water solution of ammonia or reagents, e.g., urea, that

yields ammonia upon thermal decomposition; The reactions must be carried

out in the relatively narrow temperature window of 1,600 of to 2,000 of with

sufficient retention time for the reactions to occur. The reactions that reduce

NOx emissions are:

4NH3 + 4NO + O2 4N 2 + 6H20

4NH3 + 2N02 + O2 3N 2 + 6H20

A significant concern with SNCR is that unreacted ammonia (Le., ammonia

slip) will enter the atmosphere as a HAP or will participate in the formation of a

high-opacity, detached plume of very fine PM at the main stack of a cement

kiln. If atmospheric conditions are conducive, small but sufficient quantities of

chlorine or hydrogen chloride and/or sulfur oxides can react with excess

ammonia to form ammonium chlorides and/or sulfates near the tip ofthe main

stack. These phenomena can be observed at cement kilns with only small

concentrations of ammonia from raw materials contained in the exit gas. If

maximum NOx reduction is desired, more ammonia than is stoichiometrically

required must be supplied to the gas stream with the continuous potential for a

detached plume. There is such high variability ofNOx generation in cement

kilns that a sub-stoichiometric addition rate of ammonia is difficult to achieve

on a continuous basis. The result may be short intervals with a detached plume.

SNCR has been applied in Europe to cement kiln systems of certain designs. A

limited number of SNCR demonstrations have been conducted in the U.S. but

SNCR has yet to be applied continuously to a cement kiln in the U.S.

However, SNCR is a potential NOx control technology for Kiln No.6.

4.2.5.4 CEMSTAR PROCESS

CemStar is a patented process that uses blast furnace or steel slag as a

replacement for cement raw materials. The slag serves as a calcium source that

does not require calcination; consequently, the thermal demand ofthe cement

kiln system is reduced. Reduced thermal demand means less fuel is required to

be burned for the same clinker production rate with an anticipated reduction in

NOx generation. It is also claimed that the slag serves as a mineralizer to

reduce the clinkering temperature. An investigation in connection with this

assessment indicates that there is no economically feasible steel or blast furnace

slag available in the Rapid City area. Consequently, CemStar is not regarded as

a practical NOx reduction technology for Kiln No.6 at the GCC Dacotah

facility.

GCC Dacotah 4-9 Trinity Consultants
4.2.5.5 Low-NOx BURNERS

4.2.5.5.1

4.2.5.5.2

,

'.:

,J" --"

IN THE KILN (WITH INDIRECT FIRING)

There are various burner designs for rotary cement kilns that have

the effectofproducing staged combustion in the flame envelope

through reduced flame turbulence, delayed fuel-air mixing, and

the development offuel-rich (reducing) zones that limit the

formation offuel and thermal NOx•

27 These burners are even

more effective when used in conjunction with an indirect coal

firing system. An indirect firing system separates the powdered

coal from the air used to dry and convey the coal in the coal mill.

The coal, thus separated, is pneumatically conveyed to the main

burner pipe with much less primary air than was necessary for

operation ofthe coal mill. The result is less oxygen available in

the interior ofthe flame at the main burner pipe. Both elements

ofthis NOx control technology, a 10w-NOx burner and indirect

firing, are suitable for application to Kiln No.6.

AUXILIARY BURNER FOR THE COAL MILLIDRYER

To properly dry the coal, the coal mill/dryer requires more

thermal energy than can be extracted from the gas stream

supplied to this device from the preheater tower. Consequently,

an auxiliary, natural gas-fired burner must be used to supply the

balance ofthe required thermal energy. The current burner emits

approximately 2 tons per year ofNOx• A burner that generates

slightly lower NOx emissions is available; however, ifthis burner

were applied to Kiln No.6, the reduction in NOx emissions would

be insignificant and the installation cost would be unreasonable.

4.2.5.6· TIRE-DERIVED FUEL

TDF consists ofwhole or chipped, used passenger car and light-truck tires.

Chipped tires can be pneumatically conveyed into the rotary kiln or calciner as

a replacement for solid fossil fuels. There is no significant advantage to the use

of chipped tires over solid fossil fuel for NOx suppression. The same flame

temperature must be achieved in the rotary kiln regardless ofthe type ofsolid

fuel so the generation offuel NOx would not be reduced. Scrap tires also have

a sufficient concentration of nitrogen from which fuel NOx can be formed in the

riser duct and calciner.28 Whole tires could be inserted into the feed end of Kiln

No.6. These tires would start burning on the feed shelfofthe rotary kiln in an

oxygen deficient atmosphere thereby generating CO to reduce thermal NOx

27 Rebecca Battye, op. cit., p. 59.

28 Rubber Manufactllrers Association Website, November 6,2001.

GCC Dacotah 4-10 Trinity Consultants
formed in the burning zone ofthe rotary kiln and fuel NOx formed in the

calciner. However, the same result can be achieved with equal or better

efficiency using staged combustion in the riser duct and calciner.

Based on feeding one tire per minute, an economically viable TDF program for

Kiln No.6 would require the availability of at least the equivalent of 475,000

passenger car tires per year. There are approximately 270 million scrap tires

generated in the U.S. annually?9 Since the estimated population ofthe U.S. is

slightly greater than this amount, there is about one passenger car tire per year

generated for every man, woman and child in the U.S.3D Typically, scrap tires

can be economically acquired within a 150 mile radius ofthe using facility at a

75% capture rate.3

! The population ofthe Rapid City Metropolitan Statistical

Area (approximately 88,000) and the surrounding area does not appear to be

sufficient to support a permanent TDF program at the GCC Dacotah facility at

this time.32 Because ofthis supply concern, the use ofTDF is not regarded as a

current, practical NO. reduction technology at the GCC Dacotah facility.

4.2.5.7 PROCESS CONTROL METHODS

Process controls are applied to every cement pyroprocessing system and have

the basic purposes of improving thermal efficiency, maintaining clinker quality

and reducing maintenance frequency and cost, for items such as the refractory

lining in the kiln.33 The intent ofthese process controls is to provide for kiln

operation that is as smooth and as stable as possible. The secondary effect of

process controls is to reduce emissions of constituents-of-concern, such as NO"

through the elimination of material surges and spikes in fuel demand. Kiln No.

6 already has in place appropriate process controls, such as continuous monitors

for fuel firing rates, for oxygen and CO concentrations in flue gas at process

critical points, and NOx concentrations in the exit gas at the main stack.

Programmable logic controllers contain set points to trigger alarms to alert

operators when the pyroprocess is becoming unstable or is operating outside of

the prescribed operating envelope. Kiln operators are trained to operate Kiln

No.6 as efficiently and as smoothly as possible.

4.2.5.8 INCREASED THERMAL EFFICIENCY

An increase in the thermal efficiency of a cement kiln system results in lower

fuel consumption per ton of clinker. Lower fuel consumption results in lower

NOx generation. One ofthe purposes ofthe proposed project is to improve the

thermal efficiency of Kiln No.6. It is expected that the thermal efficiency of

29 U.S. Department of Energy, Energy Efficiency and Renewable Energy Network Website, October 26, 2001.

3D u.s. Census Bureau Website, October 26,2001.

31 Personal Communication: Michael Blumenthal, Scrap Tire Management Council, electronic mail to Walter Greer, Trinity

Consultants, dated October 29, 2001.

32 u.s. Census Bureau Website, October 26, 2001.

33 R b B e ecca attye, op. CIt., .-p. )4.

GCC Dacotah 4-11 Trinity Consultants
Kiln No.6 will improve approximately 10% from the current values.

Proportional reductions in NO, emissions are expected to occur.

4.2.5.9 FUEL SELECTION

Cement kilns can use a variety offuels. Primary fuels are one ofthe three

fossil fuels, i.e., natural gas, oil, or coal. Petroleum coke and other waste

products are often used as supplementary fuels. Because oftheir uncertain

availability and high cost, petroleum products are seldom used as a primary

fuel. Refined products, such as diesel fuel, are limited to infrequent use as

start-up fuel to heat kiln systems to operating temperatures so that coal

combustion can occur readily. About one-third ofthe cost ofmanufacturing

cement is energy. A cost ofthis relative magnitude affects the economic

viability of a cement plant that must have a predictable operating schedule and

cost structure. Generally, the undependable availability and highly variable

cost of natural gas limits its use in cement kilns. Currently, GCC could not

obtain an uninterruptable supply ofnatural gas for Kiln No.6 because natural

gas has a higher and better use for residential and commercial space heating,

and as a raw material for several industries. In response to the energy crisis of

1974, the cement industry converted as many kilns as possible to coal burning.

About 90% ofthe cement kilns in the U.S. now use coal as the primary fuel.

GCC Dacotah is no exception. However, the choice between the two fuels has

implications for NO, generation in cement kilns.

In general, coal produces lower quantities ofthermal NO, in the rotary kiln

because of a lower flame temperature than natural gas.

34 The converse is true

in the calciner where the generation offuel NOx from nitrogenous compounds

in the coal predominates. In Kiln No.6, GCC Dacotah expects that 75-80% of

the fuel will be fired in the rotary kiln and 20-25% will be fired in the riser

ductlcalciner. Therefore, from the perspective ofNOx generation, the most

advantageous overall fuel for the pyroprocessing system is coal because the

preponderance ofthe fuel will be burned in the rotary kiln. Because ofthe

staged combustion that will occur in the riser ductlcalciner of Kiln No.6, the

generation offuel NOx from coal combustion will be suppressed; consequently,

there is no significant advantage for either fuel in this location. Although not

impossible, it is very unusual to use different fuels in the kiln and the calciner,

even if both are available and affordable. When all factors are considered, the

use of coal as the primary fuel for Kiln No.6 is appropriate for minimal NOx

generation. It is expected that natural gas may be used in the kiln and/or

calciner during periods ofstartup, shutdown or malfunction.

4.2.5.10 FLAME COOLING

Flame cooling is oflimited usefulness as a NOx reduction technique in a cement

kiln because a high flame temperature is required to heat the raw materials to

34 Rebecca Battye, op. cit., p. 57.

GCC Dacotah 4-12 Trinity Consultants
4.2.6

approximately 2,700 of. Flame cooling in cement kilns has been accomplished

through the insufflation of limited quantities of cement kiln dust or powdered

raw material into the flame. In Kiln No.6, the cement kiln dust was removed

from the system to improve product quality so it would be counterproductive to

reintroduce this material to the system through the flame. On the other hand,

the introduction ofraw mix would be a possibility. Flame cooling is

technically feasible for Kiln No.6.

The gas from the preheater tower that is used for drying and conveying in the

coal mill/dryer system has a relatively high dust burden consisting ofraw mix

from the first stage ofthe preheater. This inert dust is included in the powdered

coal product ofthe coal mill/dryer and is ultimately incorporated into the flame

in the kiln. While GCC Dacotah is not claiming any NOx reduction for this

eventuality, there is potential for an inherent NOx reduction because ofthe

inclusion ofthe raw mix in the powdered coal.

COMPARISON OF NOx EMISSION RATES

Table 4-3 provides a comparison of various preheater/precalciner kiln systems ofthe same

operating class as Kiln No.6 included in the EPA's RBLC and that have been recently

permitted in the U.S. Unlike Kiln No.6, these are predominantly new facilities. The range

of permitted, long-term (e.g., annual) BACT emission rates normalized to clinker

production for new and existing kilns combined, is 2.5 to 4.8 pounds ofNOx per ton of

clinker.35

GCC Dacotah is not constructing a new kiln line, but is retrofitting an existing kiln line

with staged combustion. The limited physical space available in and around the existing

preheater tower prevents an optimal sizing and configuration ofthe staged-combustion

system; therefore, the NOx emissions resulting from this retrofit should not be expected to

be equal to those of a new kiln system that is designed to accommodate the necessary size

and arrangement of preheater vessels, the calciner and the riser duct. The range oflongterm, permitted BACT emission rates for retrofitted kilns normalized to clinker production

rates is 3.4 to 4.5 pounds ofNOx per ton of clinker.

35 The lowest value in Table 4-3, 1.4 pounds ofNOx per ton of clinker for the Holnam Texas, L.P. (Holnam) plant located in

Midlothian, Texas, was not a BACT determination and has not been achieved in actual operation. This plant was reported to

operate around 3.5 pounds of NOx per ton of clinker in an application for a PSD permit amendment submitted to the Texas

Natural Resources Conservation Commission in July 2001, p. E5-3. The permit amendment application seeks to increase

the allowable emission rate to 2.8 pounds NOx per ton of clinker, the Texas SIP level as a result of ozone non-attainment in

the plant operating area.

'"

GCC Dacotah 4-13 Trinity Consultants
TABLE 4-3. LONG-TERM NOx EMISSION RATES NORMALIZED TO CLINKER PRODUCTION FROM

EPA RBLC AND/OR RECENTLY ISSUED PERMITS FOR PREHEATERIPRECALCINER PORTLAND

CEMENT KILNS

Normalized

Permitted

Emission Rate New or Retrofit

PlantlLocation (Ib/ton clinker) Installation Comments

Ash Grove Cement 4.3 116......1'..... ..(;/oJ' Retrofit

BACT was not specified in EPA RBLC or

,f

Nephi, UT 2''''''~ pel1TIit.

Blue Circle Cement 2.4 ?'? New

NSR avoidance. Staged combustion

Calera, AL design. Under construction.

Carolina's Cement J1lJ eY'" ,4 New

BACT - Good combustion practices. 4.8

Castle Hayne, NC 3· bS'

oo1• Facility never constructed.

'/..

Florida Crushed Stone 2.8 If LJJ~~\\

s-cP"I New BACT - Combustion practices. Brooksville, FL 3-D

Florida Mining 2.9 116r'4" r:H

.; «!-" New BACT - Good combustion.

Brooksville, FL ~_ 00/"

Great Star Cement /I ~.~ BACT - Traditional combustion design ,/ 3.1 ./ ",.. •ell New

Las Vegas, NV 3·0~· with SNCR. Facility not constructed.

Holnam, Inc. 1.4/2.8 77 New and retrofit

NSR avoidance. Failed initial compliance u- Midlothian, TX testing. See footnote on previous page.

Holnam, Inc.

BACT - Low NOx burners, burner

4.33 ?? New optimization, kiln optimization, staged Holly Hill, SC

combustion.

(!) Illinois Cement " BACT - Staged combustion design and tire 4.5 II ~,,\ to!> Retrofit

LaSalle,IL yo5'''''''' burning.

Lafarge Corp. 3.7 "",.4" New

BACT - Staged combustion design. Under

Sugar Creek, MO :3 -~- 001 .0<0 construction.

Lafarge Corp. 4.0 77 Retrofit BACT - Good combustion design. Davenport, IA ..

G Lehigh Cement 4.4 I/~"tll .. New

RACT - Staged combustion design. Under

Union Bridge, MD 3-oS·<:Jb construction.

/ National Cement 3.4 116,,,'\ Retrofit RACT - Precalciner addition. Lebec, CA ~~'!lo...-e\.§"td.I

.\\ Suwannee Cement 7< A)".7J BACT - Staged combustion design. Under ,r 2.9 New

Branford, FL . 3"'o~ construction.

l<- TXI 2.5 7? New BACT - Staged combustion design. Midlothian, TX -

4.2.7 EvALVAnON OF TECHNOLOGY COMBINAnONS

This section addresses the possibility of combining stand-alone, technically feasible control

technologies to determine if a combination of any ofthese NOx reduction technologies is

feasible, effective, and BACT.

GCC Dacotah 4-14 Trinity Consultants
4.2.7.1 STAGED COMBUSTION AND SELECTIVE NONCATALYTIC REDUCTION

SNCR requires the injection of ammonia or urea to reduce NO. without the use

of a catalyst. The reagent is injected into the kiln system at a location where the

gas temperature is between 1,600 of and 2,000 °F.36 Available oxygen is

required for the NO. reduction reactions to occur. In a kiln system with staged

combustion, the appropriate temperature region is located in the riser duct and

the calciner where oxygen deficient conditions have been created deliberately.

Without availab,le oxygen, the reactions between constituents ofNO. and

ammonia cannot be completed. These reactions are:37

Even after the remaining tertiary air is introduced into the combustion gas

stream in the calciner, the oxidation ofCO is competing with the NO. reduction

reactions for any available oxygen.

CO is a strong reducing agent compared to NO.. At this point in a cement kiln

using staged combustion, CO is much more abundant in the kiln gases than

NO. and will have a higher probability ofreacting with available oxygen.

Consequently, in the short distance that the gases must travel after the calciner

and before they cool below the 1,600 OF reaction boundary, there is limited time

and opportunity for the NO. reduction reactions to occur.

Under the conditions that exist in the riser duct and the calciner during staged

combustion as applied to Kiln No.6, the probability is very high that the

efficiency of SNCR will be very low thereby resulting in disappointing NO.

reduction and the attendant problems that occur with unreacted ammonia or

"ammonia slip." Because ammonia is a listed HAP, it should not be emitted

unnecessarily. Further, under favorable climatological conditions, ammonia

can react with available oxides ofsulfur and/or trace amounts of hydrogen

chloride or chlorine shortly after the kiln gases exit the stack to form very fine

PM that is observed as a detached plume of high opacity. The use ofSNCR

always carries a moderate risk of ammonia slip and a detached plume, but when

coupled with staged combustion in a retrofitted in-line calciner, there is a near

certainty that a detached plume will result.

Because ofthe anticipated slow completion ofthe NO. reduction reactions and

the high probability of a detached plume, the application of SNCR in

36 Rebecca Battye, op. cit., p. 70.

37 Rebecca Battye, op. cit., p. 68.

GCC Dacotah 4-15 Trinity Consultants
combination with staged combustion appears to be incompatible and is not

considered technically feasible at this time. Following a modification of Kiln

No.6, on-site testing ofthe combined technologies ofstaged combustion and

SNCR would be required to fully evaluate the effectiveness ofthe combination.

As previously discussed, SNCR has yet to be applied on a full-time basis to any

cement kiln system in the U.S. SNCR has not even been demonstrated in the

U.S. as a NOx reduction technology on a preheater/precalciner kiln using staged

combustion because staged combustion alone has been determined to be BACT

in recent permit actions.

4.2.7.2 STAGED COMBUSTION AND A Low-NOx BURNER USING INDIRECT

COAL FIRING

Staged combustion only occurs in the riser duct and calciner. This technology

is independent ofthe configuration or operation ofthe burner in the rotary kiln.

The inherent use of a tertiary air duct as part of a staged combustion system

serves to reduce the oxygen concentration in the vicinity ofthe burner in the

rotary kiln and has the potential to reduce NOx generation in the rotary kiln.

Staged combustion in the riser ductlcalciner and a 10w-NOx burner in the rotary

kiln using indirect coal firing are compatible, synergetic technologies when

applied to pyroprocessing systems such as Kiln No.6.

4.2.7.3 FLAME COOLING AND A Low-NOx BURNER

Flame cooling using the insufflation of raw mix into the flame at the main

burner would interfere with the proper operation of a 10w-NOx burner;

therefore, full-scale flame cooling by insufflation is incompatible with a lowNOx burner. However, the discussion in Section 4.2.5.10 suggests that there

may be some serendipitous NO, reduction occurring as a result ofraw mix

incorporated into the powdered coal.

4.2.8 STEP 5 - SELECT BACT

The final step in the BACT analysis is to select the most feasible and most effective control

option taking into account the prescribed factors enumerated previously.

Based on vendor guarantees and on the analysis provided previously, the BACT being

proposed by GCC Dacotah for NOx emissions from the main stack of Kiln No.6 is staged

combustion with a thermally-efficient, in-line, low-NO, calciner complimented by a lowNOx burner with indirect firing in the rotary kiln to achieve a NO, rolling annual average

emission rate of 1,718 tons per year ofNOx (equivalent to a normalized annual emission

rate of 4.50 pounds ofNOx per ton of clinker) updated at the end of each calendar month.38

38 Clinker production is 2,250 tons/day and the kiln uptime percentage is 93%.

GCC Dacotah 4-16 Trinity Consultants
REVISED AUGUST 31, 2002

Based on vendor projections and on the analysis provided previously, the BACT being

proposed by GCC Dacotah for NO, emissions from the alkali by-pass stack ofKiln No.6

is a low-NO, burner with indirect firing in the rotary kiln?9 The emission rates will be

updated at the end of each calendar month per procedure noted in Table 6-1.

The technologies proposed as BACT do not rely on the use ofhazardous chemicals and/or

additional process constraints that other control technologies such as SCR and SNCR

require. To ensure continuous use and effectiveness, the proposed BACT control

technologies are integral parts ofthe proposed design ofKiln No.6. Their reliability and

operation are required to produce cement clinker ofhigh quality as efficiently and

expeditiously as possible, and do not require special attention to remain effective for NO,

control.

The exhaust gas stream supplied to the coal mill/dryer contains gas from the preheater

tower that will have been subjected to BACT NO, control as proposed herein. Because

insufficient thermal energy is available in this gas stream to adequately dry the coal, it is

necessary that additional thermal energy be added to the gas stream through the use of an

auxiliary, natural-gas-fired burner. The existing auxiliary burner is rated at 5.3 MMBtu/hr

and emits approximately 2 tons per year ofNO, based on 8,760 hours of operation. This

amount ofNO, is insignificant when compared to the NO, emissions exiting the coal

mill/dryer stack that originate in the pyroprocessing system. Based on vendor projections

and on the analysis provided previously, the BACT being proposed by GCC Dacotah for

NO, emissions from the coal mill/dryer stack for Kiln No.6, is staged combustion with a

thermally-efficient, in-line, low-NO, calciner complimented by a low-NO, burner with

indirect firing in the rotary kiln. 40 The emission rates will be updated at the end of each

calendar month per procedure noted in Table 6-1.

A rolling annual average BACT emission limit is appropriate for NO, because the primary

NAAQS for N02 is an annual standard. A rolling annual average value for the NO,

emission rate also is appropriate for demonstrating compliance with annual PSD and

associated BACT requirements. Updating the rolling annual average for NO, emissions at

the end ofeach calendar month provides for short-term control and evaluation ofthe

emission rate ofNO, from all three emission points associated with Kiln No.6 for which a

"bubble" permit limit is being sought.

The variability ofNO, emissions from cement kilns is of critical concern in establishing an

appropriate emission rate limit.41 Each cement kiln system has its own baseline NO,

emission rate and its own unique range ofNO, emissions that cannot be determined with

accuracy until the system is operated for several months. The use of an annual rolling

39 The gas flow rate to the alkali by-pass is 6% ofthe gas flow rate ofthe main stack of Kiln No.6.

40 The gas flow rate to the coal mill/dryer is 20% ofthe gas flow rate ofthe preheater exit gas.

41 Personal Communication: Gene Nelson, GCC Dacotah, letter to Brian Gustafson, Administrator, SD DENR, dated April

12,2001 regarding the variability ofNOx emissions from portland cement kilns.

GCCDacotah 4-17 Trinity Consultants
average as proposed by GCC Dacotah eliminates the need for prospective estimates of

variability. The long-term, baseline emissions of a new or retrofitted cement kiln system

can be determined with acceptable accuracy by the equipment vendor. Several factors

affect the short-term NO, emission rates from cement kiln systems.42 These factors can be

synergetic or counteractive and contribute to seemingly large variations in NO, emissions

from cement kilns when those emissions are compared to other, more uniform combustion

sources. A frequency distribution ofshort-term NO, emissions from cement kilns is

typically skewed to higher values.43 For a properly operated preheater/precalciner system,

an hourly emission rate limit might have to approach a value of 2.6 to 2.9 times the

baseline emission rate to accommodate normal variations in NO, emissions.44 For

example, a preheater/precalciner kiln with a long-term, e.g., annual-average, emission rate

limit of 425 pounds per hour would require an hourly emission rate limit in the range of

I, I00 to 1,230 pounds per hour to accommodate normal NOx emissions.

4.3 BEST AVAILABLE CONTROL TECHNOLOGY ANALYSIS FOR CARBON

MONOXIDE

4.3.1 STEP 1 - IDENTIFICATION OF POTENTIAL CONTROL TECHNOLOGIES

In order to identify BACT, potentially applicable emission control technologies were

identified by researching the EPA control technology database and technical literature.

The RBLC lists technologies that have been approved in new source review permits as

RACT, BACT, or LAER for various processes and equipment. A RBLC database search

was performed to identitY the emission control technologies and emission levels that were

determined by permitting authorities as BACT for CO control on portland cement kilns.

The results ofthe search identified the controls summarized in Table 4-4. The single

technology listed in the RBLC database has been supplemented with three other

technologies that could potentially control CO emissions from portland cement kilns.

The potentially available technologies for controlling CO emissions from the cement kiln

are:

• Regenerative Thermal Oxidation (RTO)

• Thermal Oxidation (TO)

• Regenerative Catalytic Oxidation (RCO)

• Good Combustion Practice (GCP)

These CO control technologies are described in the following paragraphs.

. 42 Penta Engineering Corporation, op. cit., p.14.

43 P E' . C . . enta ngmeenng orporatlOn, op. CIt., p. 18.

44 Roger T. Shigehara, Proposed Missing NO, and Flow Rate Data Calclliation Routine for Portland Cement Kilns,

(Portland Cement Association R&D serial No. 2495, 1999), Table 3, p.i O.

GCC Dacotah 4-18 Trinity Consultants
TABLE 4-4. SUMMARY OF EPA RBLC INFORMATION FOR PORTLAND CEMENT KILNS

(CO DETERMINATIONS, 1990-2000)

J

j

Normalized .

Permitted New or

Emission Rate Retrofit

Plant/Location (Ib/ton clinker) Installation Comments

BACT Determination in RBLC

Florida Crushed Stone 1

BACT - Good combustion practices. Brooksville, FL2 ,.J .o~,1P New

S

Suwannee American ... " ;y' otJ>'1J'

Cement Company, Inc. 3.6 :3.05' New BACT - Good combustion practices.

Branford, FL

Ash Grove Cement • ~,~ .z:!'

Company 1.7 8-bs'cPD New BACT - Good combustion practices.

Chanute, KS

Lehigh Portland Cement

,¢

Company 4 "C.\. cf:P New BACT - Good combustion practices.

Union Bridge, MD :3. 05 '

Lafarge Corporation ,,' ,.01< New BACT - Good combustion practices. Sugar Creek, MO 1.6 ,'.' s,cP ~.o

Ash Grove Cement ;",

Company 4.3 .o6.cP',t> Retrofit BACT - Good combustion practices.

Durkee, OR :7

Puerto Rican Cement "",,,\-

Company, Inc. NA '7,00" New BACT - Good combustion practices.

Ponce, PR ,,0

Ash Grove Cement

Company 4.9" b.":... ,,# Retrofit

,0°

Nephi, UT 3' t>!>

Roanoke Cement

Company 2 ~.d" New BACT - Good combustion practices.

Cloverdale, VA 6'OS'

Mountain Cement v....... Company - Laramie lilA.

NA {.V ,M Retrofit BACT - Good combustion practices. Facility ~,~

Laramie, WY 2>'"

BACT Determination Not in RBLC

Blue Circle Cement

BACT - Good combustion practices. Calera, AL4.0 New

Holnam, Inc.

6.8 New BACT - Good combustion practices. Holly Hill, SC

Illinois Cement Company '1'1 ..,

Lasalle,IL

10.6 .. Retrofit BACT - Good combustion practices.

GCC Dacotah 4-19 Trinity Consultants
4.3.1.1 REGENERATIVE THERMAL OXIDATION

A RTO supplies sufficient combustion air at a suitable temperature to allow for

up to 90% oxidation of CO to carbon dioxide (C02), A properly designed and

operated RTO will recover up to 95% of all heat energy in the gas stream. If

necessary, the influent gas stream must be heated to the operating temperature

ofRTO (>1,500 OF) through the combustion in the gas stream of a relatively

clean fuel, e.g., natural gas, and the direct contact ofthe gas stream with heat

recovery media (i.e., ceramic random saddle packing or honeycomb monolith

structural types). Following oxidation, the gas with reduced CO concentration

is exhausted through downstream direct-contact heat recovery media to recover

the heat in the gas stream.

A RTO consists of at least two modules that are cycled between inlet and outlet

service to maintain appropriate operating temperatures and to conserve as much

thermal energy as possible. In cement kiln service, the inlet gases to the RTO

must be reheated because the cement pyroprocessing system extracts as much

thermal energy as possible from the flue gas stream and the temperature ofthis

gas stream is well below the required operating temperature ofthe RTO. This

supplemental combustion adds NO, to the exit gas stream. In addition, several

modules are required to accommodate the high-volume, exit-gas stream from a

cement kiln. A RTO also reduces hydrocarbons in the exit-gas stream,

including VOCs, through oxidation. Only recently, RTO has been applied to

two cement kilns in the U.S. to address hydrocarbon and odor concerns. These

installations are unrelated to CO BACT determinations in attainment areas.

There has been insufficient operation ofRTO to evaluate its application to

cement kilns. There are no published data on these installations.

4.3.1.2 THERMAL OXIDATION

TO is a technique similar to RTO in that CO is oxidized to CO2 at high

temperature, Le., 1,300 OF. However, TO has lower thermal efficiency than

RTO. A downstream heat exchanger can be used to recover up to 70% ofthe

thermal energy used in the flue gas treatment process. Consequently, TO can

require an increase in the amount ofthermal energy to reheat the exit gas

stream when compared to RTO and can result in increased combustion

products, including NO,. TO also reduces the concentration of hydrocarbons in

the exit gas stream. TO is typically used for small, intermittent flue gas streams

where thermal inefficiency does not represent a significant cost. TO has not

been applied to a cement kiln.

4.3.1.3 REGENERATIVE CATALYTIC OXIDATION

RCO employs the same principal as RTO or TO except that a catalyst is used to

increase the reaction rate thereby enabling the oxidization of CO to CO2 at a

lower reaction temperature than in RTO or TO. If necessary, the gas stream

must be reheated to a temperature sufficient to initiate the oxidation of CO as

GCC Dacotah 4-20 Trinity Consultants
the gas stream passes over a catalyst bed consisting of a noble metal such as

palladium or platinum. RCO also reduces the concentration of hydrocarbon in

the exit gas stream. As applied to a cement kiln, RCO would increase NOx

emissions relative to the untreated exit gas stream because the exit gas stream

would have to be reheated.

RCO operates at a relatively cool temperature, i.e., 600-700 of, relative to RTO

to achieve 95% or greater control of CO. A potential problem with RCO is the

possibility of catalyst poisoning by chlorine or sulfur oxides. The presence of

PM could also foul the catalyst by blinding the catalyst pores. RCOhas not

been applied to a cement kiln.

4.3.1.4 GOOD COMBUSTION PRACTICE

A properly designed and operated portland cement kiln system minimizes CO

formation. The kiln owner has economic incentive to minimize CO formation

because excess CO emissions indicate that unutilized thermal energy (Le.,

unburned fuel) is leaving the process and causing increased operating costs.

The presence of CO in the flue gas stream may be indicative of localized

reducing conditions in some part ofthe kiln system that could affect clinker

quality. Process instrumentation informs the kiln operator and/or process

control system about combustion conditions and temperature profiles

throughout the process. Fuel and air flows are appropriately adjusted to

maintain optimum combustion conditions wherever fuel is burned in the kiln

system. As shown in Table 4-4, the RBLC indicates that GCP is used

exclusively as BACT for the control ofCO in previous BACT determinations

for new and retrofitted cement kilns.

4.3.2 STEP 2 - ELIMINATE TECHNICALLY INFEASIBLE OPTIONS

Two ofthe options discussed above are eliminated due to technical infeasibility: RTO and

RCO. The rationale for their elimination is discussed below. Because there are no

technical barriers to application ofTO and GCP to a cement kiln, these technologies are

technically feasible options for Kiln No.6.

RTO is not a technically feasible option. In comparing a theoretical application of an RTO

system on a cement kiln in this case to a typical application of an RTO, the situations are

drastically different in the following ways:

• Exhaust gas volumes would be significantly lower in a typical RTO application than

would be required for the main stack, the alkali by-pass stack, and the coal mill dryer

stack of Kiln No.6 combined. Additional technical and operational complexities in

applications this large would be expected.

• VOC inlet concentrations are usually much higher in a typical application than would be

encountered in this case. RTO systems are normally designed to control VOCs and to

capitalize on the energy derived from the combustion of VOCs by the unit.

GCC Dacotah 4-21 Trinity Consultants
• Inlet loadings of other pollutants (non-VOC) in other applications are often negligible. In

this case, the effects of other pollutants would provide significant operational difficulties

and additional design considerations to overcome issues associated with corrosion.

• RTOs are not typically installed to primarily control CO emissions.

For these reasons, RTO is considered neither technically feasible nor proven to control CO

emissions from portland cement kilns. Therefore, RTO is not considered further in this

analysis.

RCO is not a technically feasible option for reduction of CO from a portland cement kiln.

Combustion products from the kiln may contain hydrogen chloride or chlorine and

certainly contain sulfur oxides and alkaline particulate matter that could poison or foul the

catalyst thereby rendering it ineffective. The extreme sensitivity of a noble metal catalyst

to these constituents of concern makes RCO an unsuitable control option for any cement

kiln. In addition, the flue gas stream from a cement kiln would require reheating and result

in additional NOx emissions associated with additional fuel combustion.

4.3.3 STEP 3 - RANK THE REMAINING CONTROL TECHNOLOGIES BY CONTROL

EFFECTIVENESS

As shown in Table 4-5, the two remaining control technologies are ranked based on their

CO control efficiencies. Since TO has a CO control efficiency reported to be greater than

80%, this technology has been placed at the top ofthe table. The application ofTO to Kiln

No.6 would require that the flue gas streams from the main stack, alkali by-pass stack, and

coal mill/dryer stack be combined to avoid independent treatment units for each gas

stream. Because of potential bag failures in the FF serving the coal mill and the resulting

explosion hazard, the use ofTO is not regarded as intrinsically safe. Information on the

efficiency of GCP is not available, but it could range from a low removal efficiency of 0%

to complete removal (100%) depending on the selection ofthe baseline emission rate from

which the efficiency calculation is made. Every cement kiln is designed and operated to

minimize the emission rate ofCO because CO emissions represent an economic loss in the

form ofunburned fuel; therefore, the CO control efficiency ofGCP would tend to be at the

high end ofthe range. There is no characteristic CO einission rate for cement kilns. CO

emissions are kiln and site specific.

TABLE 4-5. RANKING OF AVAILABLE CO CONTROL OPTIONS BASED ON CONTROL EFFICIENCY

Rank

1

2

Control Options

Thermal Oxidation

Good Combustion Practice

Control Efficiency

>80%

0-100%

4.3.4 STEP 4 - EVALUATE THE MOST EFFECTIVE CONTROLS AND DOCUMENT THE

RESULTS

Following the "top-down" BACT approach, the highest ranked control option, TO, is

evaluated first. Ifthe evaluation concludes that this option is technically and economically

GCC Dacotah 4-22 Trinity Consultants
feasible, and the option does not have unacceptable energy and/or adverse environmental

impacts, the option is determined to be the BACT. Otherwise, the next ranked control

option is evaluated. The evaluation process continues until a control option is found that

meets all ofthe BACT requirements. Once an option is determined as BACT, it is

unnecessary to evaluate the remaining options that are ranked below the selected BACT.

4.3.4.1 THERMAL OXIDATION

Use of a thermal oxidizer is technically feasible for CO control from a cement

kiln. However, ifTO were selected as the CO control technology, NOx

emissions would increase for the proposed project by 152 tons per year due to

the additional natural gas firing needed to raise the kiln exhaust (at 260 OF) to

the minimum TO operating temperature of 1,300 °F.45 There is no recognizable

environmental benefit from the use of a TO to control CO emissions from the

kiln since overall emissions, particuladyNO" would increase. Increasing fuel

usage and creating more combustion pollutants (e.g., NOx) to reduce CO

emissions would be an unacceptable compromise. Therefore, TO is infeasible

for Kiln No.6 based on the associated negative environmental impacts.

Even ifthe negative environmental impacts ofTO were ignored, TO would still

be economically infeasible due to the cost of natural gas required to reheat the

kiln exhaust. Following are calculations for the volume of natural gas required

to re-heat the exhaust gas and the cost per ton of CO controlled.

The main stack for Kiln No.6 has a much greater flow rate than either the alkali

by-pass or the coal mill/dryer; therefore, only stack gas parameters from the

kiln are considered in the following equations. Ifthe exhaust from the alkali

by-pass stack and the coal mill/dryer were included, the exhaust heating cost

and associated NOx emissions would be even higher. The kiln has an exhaust

temperature of260 of and a maximum airflow of240,000 actual cubic feet per

minute (acfm). The volume of natural gas that would be required to re-heat the

exhaust gas from 260 of back up to 1,300 OF can be calculated as follows:

(

460 + TS)scf gas J

HL = (D)(Cp)(TO -TF)

(460 + TF) acf gas

Where:

HL = Natural gas heat input (Btu/act)

Ts =Standard temperature (68 OF)

D = Density of air @ 68 of (0.0026 lb-mole/scf)

Cp = Specific heat of air, (7.0 Btu/lb-mole OF)

45 This value is based on 13.9 Btu 1acf as calculated and 240,000 acf1min, the design ofthe unit. In addition, an emission

factor of 190 lb 1106 scf is used. This value is listed in Table 1.4.1 of AP-42 Section·l.4 dated July 1998 (EPA, Office of

Air Quality Planning and Standards, Compilation ofAir Pollutant Emission Factors. Volume 1: Stationary Point and Area

Sources, Fifth Edition, Research Triangle Park, North Carolina). It is for an uncontrolled large boiler (greater than 100

MMBtulhr). Finally, the hours of operation are 8,147 per year (this assumes 93% uptime of the kiln).

GCC Dacotah 4-23 Trinity Consultants
TF = Exhaust gas temperature (260 OF)

To = Minimum temperature for TO combustion (1,300 OF)

and,

NGC = (HL)(QM )(1 MMBIU)(C)(488,820 min]

106 Btu year

Where:

NGC = Natural gas cost ($/yr)

HL =Natural gas heat input (Btu/act)

QM = Exhaust gas flow rate (240,000 acf/min)

C = Unit natural gas cost ($6.90IMMBtu)46

The heat input (HL) from natural gas for heating the exhaust gas was estimated

by the first equation to be 13.9 Btu/acf. Applying this value to the second

equation yields a natural gas cost of approximately $11,300,000 annually.

Applying a conservatively high, 90% 'control to the base case emission rate of

1;528 tons CO per year yields a potential CO reduction of 1,376 tons per year.

Based strictly on the annual cost of natural gas to reheat the exhaust gas, the

control cost is over $8,200 per ton of CO removed from the kiln exhaust.

These annual fuel costs alone (not including capital costs for the heating

system, other annual operating costs, or even the cost ofthe TO itself) indicate

that TO would not be economically feasible for the kiln. Therefore, there is no

need to factor additional annualized costs for other capital and operating

expenses to establish this option as economically infeasible.

Again, only the main kiln stack is included in this discussion. Ifthe alkali bypass stack and the coal mill/dryer stack streams were also included, the

emissions and cost would be even higher.

TO is not contained in the RBLC database. Due to the associated negative

environmental impacts and economic infeasibility ofTO, this technology has

not been selected as BACT for CO emissions from Kiln No.6.

4.3.4.2 GOOD COMBUSTION PRACTICE

GCP relies on the actions ofthe kiln operator, the design ofthe pyroprocessing

system and the functioning ofthe process control technology to optimally

operate the cement kiln with respect to fuel combustion and minimum CO

emissions. Together, these synergetic activities will eliminate the formation of

unwanted CO resulting from poor combustion and reduce emissions ofCO to

the environment. It is in the economic interest of GCC Dacotah to minimize

the generation of CO through GCP since CO is the result of unburned fuel. It is

46 Average natural gas cost for industrial consumers in South Dakota for year-to-date 2001, Energy Information

Administration/Natural Gas Monthly September 2001.

GCC Dacotah 4-24 Trinity Consultants
REVISED DECEMBER 12, 2002

preferable to prevent the generation of a pollutant rather than to control the

pollutant using a tail-pipe technology.

Because ofthe deliberate generation ofCO in the riser duct during staged

combustion for NO, control, combustion practices must be carefully monitored

to minimize CO emissions. CO emissions can be expected to be slightly higher

than ifstaged combustion were not being applied. CO is seldom a problem for

cement kilns when demonstrating compliance with NAAQS. If there must be a

tradeoff between the two constituents (i.e., CO and NO,), a slight increase in

CO emissions is preferable. GCP is the only technology previously applied to

cement kilns as BACT for CO emissions.

4.3.5 STEP 5 - SELECT BACT

The analysis contained in Section 4.3.4.1 shows that the installation of a thermal oxidizer is

economically infeasible for CO control for Kiln No.6. In addition, this technology has

undesirable energy and environmental impacts.

Based on vendor projections and the analysis provided previously, the BACT being

proposed by GCC Dacotah for CO emissions from the main stack ofKiln No.6 is GCP in

the rotary kiln and the calciner to achieve a rolling annual average emission rate of 1,528

tons ofCO per year (equivalent to a normalized annual emission rate of4.00 pounds ofCO

per ton of clinker) updated at the end of each calendar month.47

Based on vendor projections and the analysis provided previously, the BACT being

proposed by GCC Dacotah for CO emissions from the alkali by-pass stack of Kiln No.6 is

GCP in the rotary kiln.48 The emission rates will be updated at the end of each calendar

month per procedure noted in Table 6-3.

Based on vendor projections and the analysis provided previously, the BACT being

proposed by GCC Dacotah for CO emissions from the coal mill/dryer stack ofKiln No.6

is GCP in the rotary kiln.49 The emission rates will be updated at the end of each calendar

month per procedure noted in Table 6-3.

47 Clinker production is 2,250 tons/day and the kiln uptime percentage is 93%.

48 The gas flow rate to the alkali by-pass is 6% ofthe gas flow rate ofthe main stack of Kiln No.6.

49 The gas flow rate to the coal mill/dryer is 25% ofthe gas flow rate ofthe prehea!er exit gas.

GCCDacotah 4-25 Trinity Consultants
REVISED AUGUST 31, 2002

The proposed emission rate limits provide a short-term emission rate limit consistent with

the primary NAAQS and a long-term emission rate limit consistent with PSD and

associated BACT requirements that consider CO emissions on an annual basis. There is no

NSPS or NESHAP emission standard for CO from cement kilns.

GCCDacotah 4-26 Trinity Consultants
REVISED DECEMBER 12, 2002

5. SUMMARY OF AIR QUALITY ANALYSES

Impacts on ambient air quality due to the modifications are presented in separate submittals. Because

these projects are considered major modifications under the PSD permit program with respect to N02

and CO, the application must address compliance with the N02 and CO NAAQS standards and PSD

Increments. Additionally, air quality impacts for the Badlands and Wind Cave Class I areas are

addressed in this application. A summary ofthe results of the air quality analyses is presented in this

section. The analyses completed by Trinity Consultants were conducted in accordance with protocols

reviewed and approved by the SD DENR and EPA Region VIII.50

5.1 RESULTS FROM NAAQS AND INCREMENT CONSUMPTION ANALYSES

In the Significance, NAAQS, and PSD Increment (for non-Class I areas) modeling analyses

performed for N02 and CO over the associated averaging periods ofthese standards, the highest

predicted pollutant concentrations at a modeled receptor are determined using the EPA approved

ISCST3 and ISC-PRIME air dispersion models. A summary ofthe results is shown in Table 5-1.

TABLE 5-1. MAXIMUM PREDICTED AMBIENT IMPACTS FOR NOzAND CO

Averaging

Pollutant Period

N02 Annual

CO 8-hour

I-hour

I-hour

Maximum Modeled Results PSD Threshold Level

Analysis Type (Ilglm) (llglm3)

Significance 10.69· 1

NAAQS 52.01 100

PSD Increment 10.73 25

Significance 354.87 500

Significance 2,123.32 2,000

NAAQS 8,622.80·· 40,000

• A fullnnpact NAAQS AnalYSIS IS conducted only if SignIficance AnalySIS indIcates a modeled result above the PSD

Significance Threshold of I flglm'. The full impact analysis reveals that the facility is well within the NAAQS standard of

100 flglm'.

•• The background concentration is not included in this value. Since there is no CO monitoring station located in Rapid City,

South Dakota, the SO DENR suggested using monitoring data for North Dakota, a neighboring statl! The background

concentration for the I-hour averaging period from Fargo, North Dakota, is 3,875 flglm,.52 Therefore, the maximum modeled

result as shown in Table 1-2 (8,622.80 flglm') plus background concentration is 12,497.80 w'm', which is below the

NAAQS. Therefore, it is conservatively estimated that combined CO concentrations from background sources ofCO and

predicted impacts from the project will be below the NAAQS.

50 Personal Communication: Letter from Mr. Arun Kanchan, Trinity Consultants, to Mr. Chris Hansen, SO OENR, 11/12/01

confirming that Trinity Consultants has addressed all ofthe EPA's comments on the protocol.

51 Personal communication: telephone conversation between Mr. Chris Hanson, SD OENR, and Mr. Vineet Masuraha,

Trinity Consultants on January 9,2002, discussing CO background concentrations.

52 Personal communication: facsimile transmission from Mr. Chris Hanson, SD OENR, to Mr. Vineet Masuraha, Trinity

Consultants, concerning the CO background concentration. See Appendix F.

GCCDacotah 5-1 Trinity Consultants
Based on the results ofthe analyses, N02 and CO emissions due to the modifications at the GCC

Dacotah facility do not contribute to a violation ofthe NAAQS for N02 and CO and compliance with

the applicable EPA air quality standards is demonstrated. The modeling analyses also reveal that

PSD increments for non-Class I areas are not consumed due to the prior modifications and proposed

upgrades.

5.2 SYNOPSIS OF RESULTS FROM CLASS I AREA ANALYSES

The Class I Area Modeling Analysis performed for the Badlands and Wind Cave Class I Areas

include a Class I Increment analysis. For the Class I increment analysis, the effects ofthe net

emissions increases from the GCC Dacotah plant modifications are assessed by comparing the

CALPUFF predicted pollutant concentrations for N02 to the Class I Modeling Significance Levels

(MSLs). Since all predicted concentrations are below the EPA established MSLs for Class I areas,

further Class I increment analysis is not required.

5.3 ADDITIONAL IMPACTS ANALYSIS

The additional impacts analysis depends on existing air quality, the quantity of emissions, and the

sensitivity oflocal soils, and vegetation in the source's impact area. The analysis is presented in three

parts: (1) a growth analysis, (2) a soils and vegetation impacts analysis, and (3) a Class I area

increment analysis.

5.3.1 GROWTH IMPACTS

A growth analysis is intended to quantify the amount ofnew growth that is likely to occur

in support ofthe facility and to estimate emissions resulting from that associated growth.

Associated growth includes residential and commercial/industrial growth resulting from

the new facility. Residential growth depends on the number of new employees and the

availability of housing in the area, while associated commercial and industrial growth

consists of new sources providing services to the new employees and the facility. Since no

significant associated commercial or industrial growth is projected as a result ofthe

modifications, negligible growth-related air pollution impacts are expected.

5.3.2 SOILS AND VEGETATION

In addition to primary NAAQS, the EPA developed the secondary NAAQS in order to

protect certain air quality-related values (Le., soil and vegetation). The secondary NAAQS

represent levels below which most types ofsoil and vegetation are unaffected by criteria

pollutants. If ambient concentrations are less than the secondaryNAAQS, emissions from

the modified and associated units do not result in harmful effects to either soil or • 53 vegetatIOn.

53 EPA, Office of Air Quality Planning and Standards, New Source Review Workshop Monual: Prevention ofSignificant

Deterioration and Nonattainment Area Permitting, DRAFT, October 1990.

GCC Dacotah 5-2 Trinity Consultants
REVISED DECEMBER 12, 2002

As demonstrated in the Significance Analysis, the maximum off-property ground-level

concentrations ofCO due to the GCC Dacotah facility are less than the MSLs. Thus, the

impacts ofCO on soils and vegetation are presumed to be negligible.

As demonstrated in the Full Impact Analysis, the maximum off-property ground-level

concentrations ofN02 due to the GCC Dacotah facility, plus the applicable background

concentrations, are less than the NAAQS. Thus, the impacts ofN02 on soils and

vegetation are presumed to be negligible.

5.3.3 CLASS I AREA INCREMENT ANALYSIS

For the Class I Increment analysis, the effects ofthe net emissions increases from the GCC

Dacotah modifications are assessed by comparing the CALPUFF predicted pollutant

concentrations for N02 to the Class I MSLs. Since all predicted N02 concentrations are

below the EPA established MSLs for Class I areas, a Class I increment analysis for N02 is

not required. Class I increment analyses for CO are not required. Table 5-1 provides the

maximum predicted concentrations for the Badlands and Wind Cave Class I Areas.

TABLE 5-2. MAXIMUM CONCENTR.\TIONS RESULTING AT THE BADLANDS

AND WIND CAVE CLASS I AREAS

Averaging Badlands Wind Cave Significance Level

Pollutant Period (JIg/m3

) (JIg/m3

) (JIg/m3

)

N02 Annual 0.05 0.03 0.1

GCCDacotah 5-3 Trinity Consultants
REVISED DECEMBER 12, 2002

6. PERMIT LIMITS AND COMPLIANCE DEMONSTRATION

The requested pennit limits for the previously physically modified sources and proposed upgrades are

shown in Tables 6-1 and 6-2.

6.1 COMPLIANCE DEMONSTRATION FOR NOx

For NO" compliance with the proposed permit limits will be monitored using Continuous Emission

Monitoring Systems (CEMS) readings from the Kiln No.6 main stack and coal mill/dryer stack, and

deriving emissions for alkali by-pass stack, and comparing with the pennit limits (calculation

methodology provided in Appendix B). Since NO, emissions for all these three sources (i.e., Kiln

No.6 main stack, coal mill/dryer stack, and alkali by-pass stack) originate from the Kiln No.6

operation, a single emission limit (an emission "bubble") including all these sources is proposed. The

requested limit for NO, is listed in Table 6-1 with the compliance demonstration method.

GCCDacotah 6-1 Trinity Consultants
REVISED DECEMBER 12, 2002

TABLE 6-1. REQUESTED PERMIT LIMITS AND COMPLIANCE DEMONSTRATION FOR NOx

Permit Limit

Emission "Bubble" Description (tpy) Compliance Demonstration

The emission "bubble" includes the Annual • For BACT, based on CEMS results and

following three sources: permit limit gas flows measured in the main stack of

• Source 9: #6 Fuller of 2,267 tpy*, Kiln No.6, total NO, emission rates

Loesche Mill, Preheater updated on a (ER_MS, tons/month) for the Kiln No.6

and Rotary Kiln Process rolling 12- main stack will be calculated on a

(EDC619) (Kiln No.6 month basis monthly basis.

Main Stack)

• Source 11: Dry Process • For BACT, based on CEMS results and

Alkali By-pass (Alkali By- gas flows measured in the coal milVdryer

pass Stack) stack, total NO, emission rates

• Source 41: Coal Dryer- (ER_CM, tons/month) for the Kiln No.6

Coal System No.6 main stack will be calculated on a

(EDC628/9) (Coal monthly basis.

Mil1'Dryer Stack)

• The NO, emission rate for the alkali bypass stack (ER_ABP, tons/month)

equals:

(ER_MS + ER_CM) x FR_ABP

Where: FR_ABP = 6% ofpreheater

gas routed to the alkali by-pass

• The monthly NOx "bubble" emission rate

(ER_B, tons/month) equals:

ER MS+ER CM+ER ABP - - -

• A 12-month rolling average ofNOx

emissions (tpy) for the emission "bubble"

will be updated on a monthly basis.

• For BACT, each monthly NOx "bubble"

emission rate will be added to the eleven

previous monthly emission rates and the

sum compared to the limit of2,267 tpy.

The 13th oldest month will be dropped

offfrom the rolling average.

• The requested annual limit of2,267 tpy is derived by rounding offthe post-modification potential to emit (PTE) of2,266.83 tpy (as

reflected on Page B-7 ofthe PSD Netting Analysis contained in Appendix B of this permit application)

•• NOx emission rate for the coal milVdryer stack does not include the emissions from the 5.3 MMBtuIhr burner since it contributes

less than 0.1 % ofthe NO, emissions.

Gce Dacotah 6-2 Trinity Consultants
REVISED DECEMBER 12, 2002

6.2 COMPLIANCE DEMONSTRATION FOR CO

For CO, compliance with the proposed pennit limits will be demonstrated by calculating actual

emissions from the Kiln No.6 main stack and coal mill/dryer stack, and deriving emissions for alkali

by-pass stack, and comparing with the pennit limits (calculation methodology provided in Appendix

B). Since CO emissions for all these three sources (i.e., Kiln No.6 main stack, coal mill/dryer stack,

and alkali by-pass stack) originate from the Kiln No.6 operation, a single emission limit (an emission

"bubble") including all these sources is proposed. The requested limits for CO are listed in Table 6-2

and Table 6-3 with the compliance demonstration method.

TABLE 6-2. REQUESTED HOURLY PERMIT LIMITS AND COMPLIANCE DEMONSTRATION FOR CO

Permit Limit

Emission "Bubble" Description (Ib/hr) Compliance Demonstration

The emission "bubble" includes the Hourly • Based on CEMS results measured in the

following three sources: permit limit main stack of Kiln No.6, total CO

• Source 9: #6 Fuller of3,250 emission rates (ER_MS, poundslhour) for

Loesche Mill, Preheater lb/hr, updated the Kiln No.6 main stack will be

and Rotary Kiln Process on a discrete calculated on a 8-hour discrete block basis.

(EDC619) (Kiln No.6 block 8-hour The 8-hour averages shall be determined

Main Stack) basis from successive nonoverlapping 8-hour

• Source 11: Dry Process blocks starting at midnight each calendar

Alkali By-pass (Alkali By- day.

pass Stack)

• Source 41: Coal Dryer- • Based on CEMS results measured in the

Coal System No.6 stack of coal mill/dryer, total CO emission

(EDC628/9) (Coal rates (ER_CM, poundslhour) for the Coal

MilllDryer Stack) Mill stack wiII be calculated on a 8-hour

discrete block basis. The 8-hour averages

shall be determined from successive

nonovedapping 8-hour blocks starting at

midnight each calendar day.

• The CO emission rate for the alkali bypass stack (ER_ABP, poundslhour) equals:

(ER_MS + ER_CM) x FR_ABP

Where: FR_ABP = % ofpreheater gas

routed to the alkali by-pass.

• A 8-hour discrete block average ofCO

emissions (Iblhr) for the emission "bubble"

will be calculated and compared with the

BACT limit of3,025Ib/hr.

GCCDacotah 6-3 Trinity Consultants
REVISED DECEMBER 12, 2002

TABLE 6-3. REQUESTED ANNUAL PERMIT LIl\IITS AND COl\lPLIANCE DEl\IONSTR-\.TION FOR CO

Emission "Bubble" Permit Limit

Description (tpy) Compliance Demonstration

The emission "bubble" includes Annual permit • For BACT, based on CEMS results,

the following three sources: limit of 2,026 cumulative hourly emissions (lbhr) from

• Source 9: #6 Fuller tpy*, updated Kiln No.6 main stack will be added

Loesche Mill, Preheater on a rolling together for a month to calculate monthly

and Rotary Kiln l2-month emissions [ER_~[S]month,(tons/month).

Process (EDC6l9) basis

(Kiln No.6 Main • For BACT, based on CEMS results,

Stack) cumulative hourly emissions (lbihr) from

• Source 11: Dry Process coal mill/dryer stack will be added together

Alkali By-pass (Alkali for a month to calculate monthly emissions

By-pass Stack) [ER_CM]month' (tons/month).

• Source 41: Coal DryerCoal System No.6 • The CO emission rate for the alkali by-pass

(EDC628/9) (Coal stack (ER_ABP, tons/month) equals:

MilllDryer Stack) (ER..-MS + ER_CM)month x FR_ABP

Where: FR_ABP = % ofpreheater gas

routed to the alkali by-pass

• The monthly CO "bubble" emission rate

(ER_B, tons/month) equals:

(ER_MS + ER_CM + FR_ABP)month

• A l2-month rolling average ofCO

emissions (tpy) for the emission "bubble"

will be updated on a monthly basis.

• For BACT, each monthly CO "bubble"

emission rate will be added to the eleven

previous monthly emission rates and the

sum compared to the limit of2,026 tpy.

The 13th oldest month will be dropped off

from the rolling average.

• The requested annual limit of2,026 tpy is derived by rounding off the post-modification potential to emit (PTE) of 2,025.88 tpy <as

reflected on Page B-lO ofthe PSD Netting Analysis contained in Appendix B ofthis permit application)

GCC Dacotah 6-4 Trinity Consultants
APPENDIX A. SOURCE IDENTIFICATION FORMS

SD DENR does not have specific PSD application fonus and therefore, Title V source identification

fonus are provided to aid DENR's completeness review. A separate Title V operating penuit

modification will be sought in the future.

GCC Dacotah Trinity Consultants
TITLE V AIR QUALITY OPERATING PERMIT APPLICATION

SOUTH DAKOTA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES

SEND ALL MATERIALS TO:

SO Department ofEnvironment and Natural Resources

Air Quality Program

523 East Capitol

Pierre, South Dakota 57501-3181

Phone: (605) 773-3151 Fax: (605) 773-5286

A. GENERAL INFORMATION

1. Facility name: GCC Dacotah

2. Mailing address:

Street and/or box number: P.D. Drawer 360

City, state, zip code: Rapid City. SD 57709

3. Facility location (if plant is portable, enter location at time ofsubmittal):

Street and city: 501 N. St. Onge Street. Rapid City, SD 57709

and/or

Legal description and county: Sections 33. 34. T2N. R7E. Pennington County

(Quarter, Section, Township, Range)

4. Permit contact:

Name/title: Gene Nelson. Environmental Engineer

Telephone number: (605) 721-7033

5. Facility contact, if different than permit contact (Person to contact for arranging inspections):

Name/title: SAME AS PERMITCONTACT

Telephone number:

6. Responsible official: Dave Rydquist

Name/title: Vice President Operations

Telephone number:

A responsible official is defined as a president, vice president, secretary, or

treasurer for a corporation; general partner or the proprietor for a partnership;

and principal executive officer or ranking elected official for municipal, state,

federal or public agency.
B. PLANT DESCRIPTION

1. Standard Industrial Classification Code (SIC code);

Please contact the Department if unable to determine your SIC code.

Primary SIC code; 3241 Secondary SIC code (if applicable): NA

2. Briefly describe the operations at the facility, including raw materials and finished products:

This plant produces Portland Cement utilizing wet and dry processes. Raw materials are

crushed and burned in rotary kilns to produce clinker. The clinker is then ground to produce

the final cement product. Limestone, sand. gvmpsum. and shale are quarried on site, while

the iron ore and coal are from offsite sources. Please refer to Section 2.2 ofthe enclosed

application for additional information.

Please attach one copy, if available, of any prepared plans and the manufacturers specifications of

any equipment, including pollution control devices. If additional space is needed to describe

operations, please attach the additional paper to this application.

3. A new source or modification to an existing source, which has the potential to increase

emissions, is required to demonstrate that the operation ofthe new source or modification

will not prevent or interfere with the attainment or maintenance of an applicable ambient air

quality standard. Please attach air dispersion modeling or other documents which will

demonstrate the new source or modification will not prevent or interfere with the attainment

or maintenance of an applicable ambient air quality standard.

Has air dispersion modeling been conducted? Yes...x... No

Ifair dispersion modeling has been conducted, please attach a copy ofthe report to this

application unless the Department has a copy already.

Please refer to the ISCST3 and CALPUFF modeling reports for additional information.

C. COMPLIANCE PLAN

Ifit is anticipated that a permitted unit will not be operating in compliance at the time of

permit issuance, a proposed compliance plan shall be included with the application. The

proposed compliance plan shall include a narrative description ofthe following:

I. The requirements (Le., statutes, air quality rules, permit conditions, etc.) the source is not in

compliance with at the time ofsubmittal ofthis application or permit issuance;

2. How the facility intends to bring the unites) into compliance; and

3. A compliance schedule for when the source will achieve compliance with such requirements;

The compliance schedule must include a statement that progress reports will be submitted at

least once every six months and must be at least as stringent as that contained in any judicial

consent decree or administrative order to which the applicant is subject.

Please refer to Section 1 ofthe enclosed application for additional information.
D. MAPS

For stationary sources only, please enclose a map or a drawing showing roadways, location

of plant and the nearest residents in each direction from the source. Include other structures

which may be affected.

Please refer to Section 2.1 ofthe enclosed application for additional information.

E. AIR QUALITY EMISSIONS SUMMARY

If air quality emissions are available, please complete the following table:

Potential

Actual Potential Controlled Uncontrolled

Pollutant (tons per year) (tons per year) (tons per year)

Particulates

Sulfur Dioxide See Note Below

Nitrogen Oxide See Note Below

Volatile Organic Compounds See Note Below

Hazardous Air Pollutants

Remember that potential emissions are calculated assuming that the permitted unit is operated 24 hours

per day, 7 days per week, 52 weeks per year at maximum design capacity.

Section 3 ofthe enclosed application summarizes the emissions from the proposed

modifications.

Please contact the Department if assistance is needed for calculating emissions for the permitted units such

as emission factors, clarifying what potential emissions are, efficiency for control equipment, etc.

Please refer to the ISCST3 and CALPUFF modeling reports for additional information.
Source

Number

9

11

41

Source Form Table

Description

#6 Fuller Loesche Mill, Preheater and

Rotary Kiln Process (EDC619)

Dry Process Alkali By-Pass

Coal Dryer-Coal System No.6 (EDC628/9)

Source Form

Kiln or Dryer Operation

Kiln or Dryer Operation

Kiln or Dryer Operation
KILN OR DRYER OPERATION

I. Facility identification (i.e., Unit # I, Pierre Plant, etc.): Source #9. EDC619-#6 Fuller Loesche Mill.

Preheater and Rotary Kiln Process

2. Manufacturer: Fuller

Date ofmanufacture: 1977

Model number: Mill- IM-27. 2120

3. Check one: StationaryX Portable

4. Maximum design operating rate: 315 MMBtu/hr heat input

Processed material or product? 93.8 tons per hour clinker

Heat source? Coal

5. Actual or anticipated operation: 8.147 hours per year

Type ofmaterial processed or produced? Clinker

Amount ofmaterial processed or produced? 2.250 ton clinker per day

Primary and secondary fuel, fuel consumption, and fuel parameters:

Description Primary Fuel ~I Fuel Type (i.e., natural gas, #2 fuel oil, lignite coal, etc.) Coal Not applicable

Fuel Consumption

(i.e., cubic feet/hour, gallons/hour, pound/hour,

tons/hour, etc.) 38,000 lb/hr Not applicable

Heating value 8,350

(i.e., Btus/cubic feet, Btus/gallon, Btus/pound, etc.) Btus/pound Not applicable

Sulfur Content (Wt.%) 0.32 Wt.% Not applicable

Ash Content (Wt.%) 5.3 Wt.% Not applicable
6. Has a stack test been conducted? Yes X No

If a stack test(s) has been conducted, please attach a copy ofthe most recent stack test report to this

application and skip item #7. Ifthe Department already has a copy ofthe most recent stack test,

please specify the date ofthe most recent stack test:

Most recent stack test date: June 19. 2001

7. Stack information (if a stack is present):

Stack height (feet): 240.00 Stack diameter (feet): 10.17

8. Type of air pollution control equipment:

(Examples: wet scrubber, cyclone, baghouse, electrostatic precipitator, etc.)

Please complete the appropriate air pollution control equipment data sheet(s) for this unit.

Section 4 ofthe enclosed application provides details ofcontrol technology.
KILN OR DRYER OPERATION

I. Facility identification (Le., Unit #1, Pierre Plant, etc.): 11. EDC623-Dry Process Alkali By-Pass

2. Manufacturer: Fuller

Date ofmanufacture: 1977

Model number: Not available

3. Check one: StationaryX Portable

4. Maximum design operating rate: 20.764 tons/year

Processed material or product? Cement Kiln Dust

Heat source? Kiln No.6

5. Actual or anticipated operation: 8.147 hours per year

Type ofmaterial processed or produced? Cement Kiln Dust

Amount ofmaterial processed or produced? 20.764 tons/year

Primary and secondary fuel, fuel consumption, and fuel parameters:

Description Primary Fuel Secondary Fuel

Fuel Type (i.e., natural gas, #2 fuel oil, lignite coal, etc.) Not applicable Not applicable

Fuel Consumption

(i.e., cubic feet/hour, gallons/hour, pound/hour,

tons/hour, etc.) Not applicable Not applicable

Heating value

(i.e., Btus/cubic feet, Btus/gallon, Btus/pound, etc.) Not applicable Not applicable

Sulfur Content (ppm) Not applicable Not applicable

Ash Content (Wt.%) Not applicable Not applicable

6. Has a stack test been conducted? Yes X No
If a stack testes) has been conducted, please attach a copy ofthe most recent stack test report to this

application and skip item #7. Ifthe Department already has a copy ofthe most recent stack test,

please specify the date ofthe most recent stack test:

Most recent stack test date: November I, 2001

7. Stack information (if a stack is present):

Stack height (feet): 71.00 Stack diameter (feet): 5.00

8. Type of air pollution control equipment:

(Examples: wet scrubber, cyclone, baghouse, electrostatic precipitator, etc.)

Please complete the appropriate air pollution control equipment data sheet(s) for this unit.

Section 4 ofthe enclosed application provides details ofcontrol technology.
KILN OR DRYER OPERATION

1. Facility identification (i.e., Unit #1, Pierre Plant, etc.): 41. EDC628/9-Coal Dryer-Coal System No.6

2. Manufacturer: North American

Date ofmanufacture: 1994

Model number: 0514-8-B

3. Check one: Stationary .K Portable

4. Maximum design operating rate: 5.3 MMBTU/hr

Processed material or product? 18 tons per hour coal

Heat source? Coal Dryer

5. Actual or anticipated operation: 8.147 hours per year

Type ofmaterial processed or produced? Coal

Amount ofmaterial processed or produced? 18 tons per hour coal

Primary and secondary fuel, fuel consumption, and fuel parameters:

Description Primary Fuel Secondary Fuel

Fuel Type (i.e., natural gas, #2 fuel oil, lignite coal, etc.) Natural Gas Not applicable

Fuel Consumption

(i.e., cubic feet/hour, gallons/hour, pound/hour, 5.3 MMBtli

tons/hour, etc.) per hour Not applicable

Heating value 1,020

(i.e., Btus/cubic feet, Btus/gallon, Btus/pound, etc.) Btus/cubic feet Not applicable

Sulfur Content (ppm) tiI!I2m. Not applicable

Ash Content (Wt.%) OWt.% Not applicable

6. Has a stack test been conducted? Yes.K No
If a stack testes) has been conducted, please attach a copy ofthe most recent stack test report to this

application and skip item #7. Ifthe Department already has a copy ofthe most recent stack test,

please specify the date ofthe most recent stack test:

Most recent stack test date: November 28. 2001

7. Stack information (if a stack is present):

Stack height (feet): 105.00 Stack diameter (feet): 3.50

8. Type of air pollution control equipment:

(Examples: wet scrubber, cyclone, baghouse, electrostatic precipitator, etc.)

Please complete the appropriate air pollution control equipment data sheet(s) for this unit.

Section 4 ofthe enclosed application provides details ofcontrol technologv.
REVISED DECEMBER 12, 2002

ApPENDIX B. PSD NETTING ANALYSIS

This section describes the procedure for PSD netting and details the netting results for NO" CO, and

VOC.

The following common abbreviations are found in this section.

TABLE 1. COMMON ABBREVIATIONS DEFINED

Abbreviation Definition

Btu/scf British thermal units per standard cubic feet

hr/yr hours per year

Ib/hr pounds per hour

lb/ton pounds per ton

Ib/MMscf pounds per million standard cubic feet

MMBtu/hr million British thermal units per hour

tpd tons per day

tpy tons per year

In addition, the following common conversions are found in this section.

TABLE 2. COMMON CONVERSION FACTORS

2,0001b

8,760 hrs

365 days =

I ton

I year

1 year

1.1 PSD NETTING PROCEDURE

This section outlines the procedure for determining the net emissions change for the aforementioned

pollutants. The procedure is based on the suggested emissions netting procedure in the Draft EPA

New Source Review (NSR) Workshop Manual for PSD and nonattainment area permitting.t A sixstep procedure is used for determining the net emissions change as summarized below.

1. Determine the emissions increases from the proposed projece Ifincreases are significant,

proceed; ifnot, the project is not subject to review.

I EPA, Office ofAir Quality Planning and Standards, New Source Review Workshop Manual: Prevention of

Significant Deterioration and Nonattainment Area Permitting, DRAFT, October 1990.

2 This is a retroactive PSD application and thus, a majority ofthe "proposed" project has already been constructed.

GCCDacotah 1 Trinity Consultants
REVISED DECEMBER 12,2002

2. Detennine the beginning and ending dates ofthe contemporaneous period as it relates to the

proposed modification.

3. Detennine which emissions units at the source experienced (or will experience, including any

proposed decreases resulting from the proposed project) a creditable increase or decrease in

emissions during the contemporaneous period.

4. Detennine which emissions changes are creditable.

5. Detennine, on a poIlutant-by-poIlutant basis, the amount of each contemporaneous and

creditable emissions increase and decrease.

6. Sum all contemporaneous and creditable increases and decreases with the increase from the

proposed modification to detennine if a significant net emissions increase wiII occur.

Each ofthe netting procedure steps are further elaborated in the following subsections.

1.1.1 EMISSIONS INCREASES FROM THE PROPOSED PROJECT

In this step, the emissions increases from the proposed project are computed on a

poIlutant-by-poIlutant basis. These increases include both emissions that result from a

physical modification to a source and emissions from sources associated with the

physically modified sources. A PSD review applies only to those regulated pollutants with

a significant emissions increase from proposed modification; emission decreases are not

considered at this step. The computed emissions increase is compared to the PSD

significance levels shown in Table 3, and a PSD review is required ifthe proposed project

will result in a significant emissions increase (i.e., an emissions increase in excess ofthe

PSD significance level).

TABLE 3. PSD SIGNIFICANCE LEVELS

Pollutant PSD Significance Level

(tpy)

NOx 40

CO 100

Ozone 400fVOC

1.1.2 CONTEMPORANEOUS PERIOD

The contemporaneous period begins on the date five years prior to construction

commencing. The period ends on the date the emissions increase from the proposed

modification occurs. For this project, the contemporaneous period begins September 1989

and ends in 1996.

GCCDacotah 2 Trinity Consultants
REVISED DECEMBER 12, 2002

1.1.3 EMISSIOi'lS INCREASES AND DECREASES DURING THE CONTEMPORANEOUS

PERIOD

Creditable emissions increases within the contemporaneous period are associated with a

physical change or change in the method of operation at a source, which did not require a

PSD permit. Decreases are associated with a physical change or change in the method of

operation that are creditable, or reductions in actual emissions from a federally-enforceable

emission limit. Once the decrease has been made federally-enforceable, any proposed

increase above the federally-enforceable level must constitute a physical change or change

in the method of operation at the source or the reduction is not considered creditable.

1.1.4 CREDITABLE EMISSIONS CHANGES

An increase or decrease is creditable only ifthe relevant reviewing authority has not relied

upon it in previously issuing a PSD permit and the permit is in effect when the increase

from the proposed modification occurs. For pollutants with PSD increments, an increase

or decrease in actual emissions which occurs before the baseline date in an area is

creditable only ifit would be considered in calculating how much of an increment remains

available for the pollutant in question. A decrease is creditable only to the extent that it is

federally-enforceable from the moment that the actual construction begins on the proposed

modification to the source. The decrease must occur before the proposed emissions

increase occurs. A source cannot take credit for a decrease that it has had to make, or will

have to make, in order to bring an emissions unit into compliance. Furthermore, a source

cannot take credit for an emission reduction from potential emissions from an emissions

unit, which was permitted, but never built or operated.

1.1.5 AMOUNT OF THE EMISSIONS INCREASE AND DECREASE

An emissions increase or decrease is the difference between the new level of actual

emissions at the emissions unit and the old level. The new "actual emissions" level is the

lower ofthe unit's "potential" or "allowable" emissions after the modification. The old

level is calculated from the unit's actual operating data from a two-year period, which

directly preceded the physical change.

1.1.6 PSD REVIEW

The proposed project is subject to PSD review for each regulated pollutant for which the

sum of all creditable emissions increases and decreases results in a significant net

emissions increase. However, additional prospective and creditable emissions reductions

sufficient to provide for a less than significant net emissions increase at the source may be

proposed to avoid PSD review.

GCCDacotah 3 Trinity Consultants
REVISED DECEMBER 12, 2002

1.2 NOx EMISSIONS NETTING

When perfonning emissions netting for NO" only emissions from sources that were physically

modified or processes that are associated with the modified units are considered. Thus, emissions

from Kiln No.6, the alkali by-pass, and the coal mill/dryer are considered, whereas emissions from

Kiln Nos. 4 and 5 are not considered.

Past actual emissions of NO, are determined from an average of the annual emis30ns reported in the

1993 and 1994 Emissions Inventories for the Gee Dacotah facility, the two years prior to the Kiln

No.6 modification. Emissions are calculated using the hourly emission rate and the annual operating

hours reported in the emission inventories submitted to the SD DENR for 1993 and 1994. The coal

mill/dryer unit, which did not exist at that time, has been reported as having zero actual emissions.

Proposed NOx emissions are calculated using a clinker production capacity of 2,250 tpd. Maximum

uptime for the kiln is 93% ofthe total hours in a year.

1.2.1 KILN NO.6 (SOURCE 9)

1.2.1.1 POTENTIAL TO EMIT

Using the daily clinker production of 2,250 tpd and an emission factor of

4.5 1b/ton, the annual emissions ofNOx from Kiln No.6 are calculated with the

following equation. 3

NOx(tpy) = 2,250 tons of clinker x4.5 1bof N?x x ton of NOx x 365 days x 93% uptime = 1,718.47 tpy

day ton of clinker 2,0001b of NOx year

1.2.1.2 ACTUAL EMISSIONS

Actual emissions for Kiln No.6 are the average ofthe 1993 and 1994 reported

values as obtained from the respective emission inventories. The average

annual emissions during Mill On time for 1993 and 1994 are summed with the

average annual emissions during Mill Offtime for 1993 and 1994 to arrive at

the total emissions. Table 4, below, details these values and the actual emission

rate.

3 Personal Communication: Gene Nelson, GCC Dacotah,letter to Brian Gustafson, Administrator, and Kyrik

Rombough, Air Quality Program Engineer, SD DENR, dated June 28, 2002 with FL Smidth emission guarantees attached.

Gee Dacotah 4 Trinity Consultants
REVISED DECEMBER 12, 2002

TABLE 4. ACTUAL EMISSIONS FOR KILN No.6

Year Loesche Mill On Loesche Mill Off Total

Emission Operating Annual Emission Operating Annual (tpy)

Rate Hours Emissions Rate Hours Emissions

(lb/hr) (hr/yr) (tpy) (lb/hr) (hr/yr) (tpy)

1993 307.0 6,629 1,017.55 404.0 499 100.80

1994 307.0 6,826 1,047.79 404.0 415 83.83

Average 1,032.67 92.32 1,124.99

1.2.2 ALKALI BY-PASS (SOURCE 11)

1.2.2.1 POTENTIAL TO EMIT

Using the daily clinker production of2,250 tpd and an emission factor of

0.3 Ib/ton, the annual emissions ofNO, from the alkali by-pass are calculated

with the following equation.4

NO, (tpy) = 2,250 tons of clinker x 0.3 Ib of NO, x _t_o_n_o_f_N_O--",--x 365 days x 93% uptime = 114.56 tpy

day ton of clinker 2,000 Ib of NO, year

1.2.2.2 ACTUAL EMISSIONS

Actual emissions are calculated based upon the reported emissions from 1993

and 1994 as given in the emission inventories. The average calculation is

summarized in Table 5.

TABLE 5. ACTUAL EMISSIONS FOR ALKALI BY-PASS

Year Loesche Mill On

Emission Operating Annual

Rate Hours Emissions

Oblhr) (hr/yr) (tpy)

1993 19.6 7,128 69.85

1994 19.6 7,241 70.96

Average 70.41

4 Ibid.

GCCDacotah 5 Trinity Consultants
REVISED DECEMBER 12, 2002

1.2.3 COAL MILLIDRYER (SOURCE 41)

1.2.3.1 POTENTIAL TO EMIT

Using the daily clinker production of2,250 tpd and an emission factor of

1.13 lb/ton, the annual emissions of NO, from the coal mill/dryer are calculated

with the following equation.;

NO, (tpy) = 2,250 tons of clinker x 1.13 lb of NO, x ton of NO, x 365 days x 93% uptime = 431.52 tpy

day ton of clinker 2,000 lb of NO, year

In addition, there are NO, emissions associated with the firing ofnatural gas in

the coal mill/dryer. The rated capacity ofthe coal milYdryer is 5.3 MMBtu/hr.

Using an AP-42 emission factor of 100 IblMMscf and a heating value for natural

gas of 1,020 Btu/scf, the annual NO, emissions resulting from natural gas

combustion are computed with the following equation.6 For conservatism, the

93% uptime is not included in this equation.

NO ( ) 5 3MMBtu sef 100lb 8,760 hrs ton 228 , tpy = . x x x x =. tpy hr 1,020Btu MMsef yr 2,0001b

The total NO, emissions from the coal mill/dryer stack are determined by

summing the two previously computed values.

NO, (tpy)=431.52 tpy + 2.28 tpy =433.80 tpy

1.2.3.2 ACTUAL EMISSIONS

The coal mill/dryer unit did not exist prior to the 1994 modification and

therefore past actual emissions are zero.

1.2.4 NET INCREASE

Table 6 below summarizes the net increase in NO, emissions at the facility.

S Ibid

6 U.S. EPA, Compilation ofAir Pollutant Emission Factors. Volume I: Stationary Point and Area Sources. AP-42,

Fifth Edition, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, July 1998, Section 1.4.

GCCDacotah 6 Trinity Consultants
REVISED DECEMBER 12, 2002

TABLE 6. NET INCREASE OF NOx EMISSIONS

Emission Unit Past Actual Future Emission Net Emissions

Emissions Limit Increase

(tpy) (tpy) (tpy)

Kiln No.6 1,124.99 1,718.47 593.48

Alkali By-Pass 70.41 114.56 44.15

Coal Mill/Dryer 0.00 433.80 433.80

Total 1,195.40 2,266.83 1,071.43

The total emissions increase of 1,071.43 tpy is in excess ofthe PSD significance level of

40 tpy for NO,.

1.2.5 CREDITABLE EMISSION CHANGES

No creditable emissions changes occurred during the contemporaneous period; therefore,

the project is subject to a PSD review for NO,.

1.3 CO EMISSIONS NETTING

Only emissions from sources that were modified or are associated with a modification are considered

when performing emissions netting for CO. Therefore, emissions from Kiln No.6, the alkali by-pass,

and the coal mill/dryer are considered, whereas emissions from Kiln Nos. 4 and 5 are not.

Past actual emissions ofCO are calculated using the average clinker production from 1992 and 1993:'

The coal milVdryer unit, which did not exist at that time, has been reported as having zero actual

emissions.

PSD netting for CO is performed for emission limits sought by GCC Dacotah in the PSD permit

application.

1.3.1 KILN No.6 (SOURCE 9)

1.3.1.1 POTENTIAL TO EMIT

Using the daily clinker production of2,250 tpd and an emission factor of

4.0 Ib/ton, the annual emissions ofCO from Kiln No.6 is calculated with the

following equation.

7 The average clinker production for 1994 is not reported in the 1994 Emissions Inventory; therefore, CO

emissions for 1994 cannot be calculated. The selection ofrepresentative baseline years of 1992 and 1993 is based on data

completeness.

GCCDacotah 7 Trinity Consultants
REVISED DECEMBER 12, 2002

co ( ) 2 250 tons of clinker 4.0 lb of CO ton of CO 365 days 930/ . 1 52753 tpy = , x x x x /0 uptIme = , . tpy day ton of clinker 2,000 lb of CO year

1.3.1.2 ACTUAL EMISSIONS

As CO values were not reported in 1992 and 1993, an AP-42 emission factor is

used instead.s This factor, multiplied with the average annual clinker

production, as reported in the 1992 and 1993 Emission Inventories, determines

the actual emissions. Actual emission information is summarized in Table 7.

TABLE 7. CO ACTUAL EMISSIONS FOR KILN No. 6

AP-42 Emission 1992 Clinker 1993 Clinker Average Clinker CO

Factor Production Production Production Emissions

(lb/ton) (tpy) (tpy) (tpy) (tpy)

0.98 381,889 428,667 405,278 198.59

1.3.2 ALKALI BY-PASS (SOURCE 11)

1.3.2.1 POTENTIAL TO EMIT

The alkali by-pass emission rate is estimated to be approximately 6% ofthe

total CO in the PH exit gas. Therefore, annual emissions ofCO from the alkali

by-pass are calculated with the following equation.

co (tpy) =(1527.53+383.79) tpy x 0.06 =114.56 tpy

1.3.2.2 ACTUAL EMISSIONS

As CO values were not reported in 1992 and 1993, an AP-42 emission factor is

used instead.9 This factor, multiplied with the average annual clinker

production, as reported in the 1992 and 1993 Emission Inventories, determines

the actual emissions for the alkali by-pass. Actual CO emission information is

summarized in Table 8.

S U.S. EPA, Compilation ofAir Pollutant Emission Factors. Volume I: Stationary Point and Area Sources. AP-42,

Fifth Edition, Office of Air Quality Planning and Standards, Research Triangle Park, NC, January 1995, Section 1\.6, Table

11.6-8.

9 Ibid.

GCCDacotah 8 Trinity Consultants
REVISED DECEMBER 12, 2002

TABLE 8. CO ACTUAL EMISSIONS FOR ALKALI BY-PASS

AP-42 Emission 1992 Clinker 1993 Clinker Average Clinker CO Factor

(Ib/ton of Production Production Production Emissions

(tpy) (tpy) (tpy) (tpy) clinker feed)

0.98 16,175 21.573 18,874 9.25

1.3.3 COAL MILLIDRYER (SOURCE 41)

1.3.3.1 POTENTIAL TO EMIT

Since 20% ofthe PH exit gas is routed to the coal mill/dryer CO emissions

from coal mill/dryer are calculated as follows:

0.2

CO (tpy) = 1527.53 tpy x - = 381.88 tpy 0.8

In addition, there are CO emissions associated with the firing ofnatural gas in

the coal mill/dryer. The rated capacity ofthe coal mill/dryer is 5.3 MMBtu/hr.

Using an AP-42 emission factor of 84lbIMMscf and a heating value for natural

gas of 1,020 Btu/scf, the annual CO emissions resulting from natural gas

combustion are computed with the following equation.1o For conservatism, the

93% uptime is not taken into consideration in this equation.

co (tpy) = 5.3 MMBtu x scf x 841b x 8,760 hrs x ton = 1.91 tpy

hr 1,020 Btu MMscf yr 2,000 lb

The total CO emissions from the coal mill/dryer stack are determined by

summing the two previously computed values.

CO (tpy) =381.88 tpy +1.91 tpy = 383.79 tpy

1.3.3.2 ACTUAL EMISSIONS

The coal mill/dryer was not installed prior to the 1994 modification and

therefore, actual emissions are reported as zero.

1.3.4 NET INCREASE

Table 9 below summarizes the net increase in CO emissions at the facility.

10 u.S. EPA, Compilation ofAir Pollutant Emission Factors, Volume I: Stationary Point and irea Sources,

AP-42, Fifth Edition, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, July 1998, Section 1.4.

GCCDacotah 9 Trinity Consultants
REVISED DECEMBER 12, 2002

TABLE 9. NET INCREASE OF CO EMISSIONS

Emission Unit Past Actual Future Potential Net Emissions

Emissions Emissions Increase

(tpy) (tpy) (tpy)

Kiln No.6 198.59 1,527.53 1,328.94

Alkali By-pass 9.25 114.56 105.31

Coal Mill/Dryer Stack 0.00 383.79 383.79

Total 207.84 2,025.88 1,818.04

The total emissions increase of 1,818.04 tpy exceeds the PSD significance level of 100 tpy

for CO.

1.3.5 CREDITABLE EMISSION CHANGES

No creditable emissions changes occurred during the contemporaneous period; therefore,

the project is subject to a PSD review for CO.

1.4 VOC EMISSIONS NETTING

When performing emissions netting for VOC, only emissions from sources that were modified or are

associated with a modification are considered. Thus, emissions from Kiln No.6 and the coal

mill/dryer are considered, whereas emissions from Kiln Nos. 4 and 5 are not considered.

Past actual emissions ofVOC are determined from an AP-42 emission factor and the average clinker

production from 1992 and 1993.11 The coal milVdryer unit, which did not exist at that time, has been

reported as having zero actual emissions.

The potential emissions for VOC are calculated from an AP-42 emission factor and a clinker

production capacity of2,250 tpd. Maximum uptime for the kiln is 93% ofthe total hours in a year.

1.4.1 KILN NO.6 (SOURCE 9)

1.4.1.1 POTENTIAL TO EMIT

AP-42 for Portland Cement Manufacturing provides an emission factor for

Total Organic Compounds (TOe) emissions from a preheater process kiln with

a precalciner.12 For the purposes ofthis calculation, it is assumed that all TOC

II The average clinker production for 1994 is not reported in the 1994 Emissions Inventory; therefore, VOC

emissions for 1994 cannot be calculated. The selection ofrepresentative baseline years of 1992 and 1993 is based on data

completeness.

12 U.S. EPA, Compilation ofAir Pollutant Emission Factors. Volume I: Stationary Point and Area Sources.

AP-42, Fifth Edition, Office of Air Quality Planning and Standards, Research Triangle Park, NC, January 1995, Section

11.6, Table 11.6-8.

GCC Dacotah 10 Trinity Consultants
REVISED DECEMBER 12, 2002

is VOC. The emission factor multiplied with the daily clinker production,

2,250 tpd, and 93% uptime ofthe kiln determines the potential emissions for

Kiln No.6. Potential VOC emission information is calculated below.

VOC (tpy) = 2.250 tons of clinker x 0.12 lb of VOC x ton of NO, x 365 days x 93% uptime = 45.83 tpy

day ton of clinker 2,000 Ib of NO, year

1.4.1.2 ACTUAL EMISSIONS

AP-42 Section 11.6 provides an emission factor for TOC emissions from a

preheater process kiln.13 For this analysis all TOC is considered to be VOC.

The 1992 and 1993 clinker production values, as found in the 1992 and 1993

Emission Inventories, are averaged. Table 10 provides these values and the

actual emission rate.

TABLE 10. VOC ACTUAL EMISSIONS FOR KILN No.6

AP-42 Emission 1992 Clinker 1993 Clinker Average Clinker VOC

Factor Production Production Production Emissions

(lb/ton) (tpy) (tpy) (tpy) (tpy)

0.18 381,889 428,667 405,278 36.48 .

1.4.2 ALKALI BY-PASS (SOURCE 11)

1.4.2.1 POTENTIAL TO EMIT

The alkali by-pass emission rate is estimated to be approximately 6% ofthe

total VOC from the PH. For the purposes ofthis calculation, it is assumed that

all TOC is VOC. Therefore, annual emissions ofVOC from the alkali by-pass

are calculated with the following equation.

voe (tpy) = (45.83 + 20.37) tpy x 0.06 = 3.97 tpy

1.4.2.2 ACTUAL EMISSIONS

AP-42 Section 11.6 provides an emission factor for TOC emissions from a

preheater process kiln.14 For this analysis all TOC is considered to be VOC.

This AP-42 factor, multiplied with the average annual clinker production, as

reported in the 1992 and 1993 Emission Inventories, determines the actual

13 Ibid.

14 Ibid.

GCCDacotah 11 Trinity Consultants
REVISED DECEMBER 12, 2002

emissions for the alkali by-pass. Actual VOC emission information is

summarized in Table 11.

TABLE 11. VOC ACTUAL El\\ISSIONS FOR ALKALI BY-PASS

.

AP-42 Emission 1992 Clinker 1993 Clinker Average Clinker VOC Factor

(Ib/ton of Production Production Production Emissions

clinker feed) (tpy) (tpy) (tpy) (tpy)

0.18 16,175 21,573 18,874 1.70

1.4.3 COAL MILLIDRYER (SOURCE 41)

1.4.3.1 POTENTIAL TO EMIT

Since 20% ofthe PH exit gas is routed to the coal mill/dryer VOC emissions

from coal mill/dryer is calculated as follows:.

( 0.2vac tpy) =45.83 tpy x -=11.46tpy 0.8

In addition, there are VOC emissions associated with the firing ofnatural gas in

the coal mill/dryer. The rated capacity ofthe coal mill/dryer is 5.3 MMBtuIhr.

Using an AP-42 emission factor of 5.5 IblMMscf and a heating value for

natural gas of 1,020 Btu/scf, the annual VOC emissions resulting from natural

gas combustion are computed with the following equation.'s For conservatism,

the 93% uptime is not considered in this equation.

MMBtu scf x 5.51b x 8,760 brs x ton = 0.13 vae (tpy) = 5.3 x - tpy br 1,020 Btu MMscf yr 2 000 Ib

Finally, there are VOC emissions associated with the coal being used in the

coal mill/dryer due to the high organic content ofthe coal used. The coal

cleaning emission factor is deemed most appropriate to account for the high

organic content ofthe coal. AP-42 provides an emission factor of 0.098 lb/ton

for the cleaning of coal in a fluidized bed dryer with a venturi scrubber.16 The

maximum predicted annual coal usage for Kiln No.6 is 179,230 tpy. Thus,

IS U.S. EPA, Compilation ofAirPollutant Emission Factors, Volume I: Stationary Point and Area Sources.

AP-4Z, Fifth Edition, Office of Air Quality Planning and Standards, Research Triangle Park, NC, July 1998, Section 1.4.

16 U.S. EPA, Compilation ofAirPollutant Emission Factors. Volume I: Stationary Point and Area Sources.

AP-4Z, Fifth Edition, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, November 1995, Section

1I.l0, Table 1I.Io-Z.

GCCDacotah 12 Trinity Consultants
REVISED DECEMBER 12, 2002

VOC emissions as a result of drying coal are computed using the following

equation.

Ib ton ton VOC (tpy) = 0.098- x 179,230- x =8.78 tpy

ton yr 2,0001b

Thus, the total VOC emissions from the coal mill/dryer stack are calculated, as

follows.

voc (tpy) = 11.46 tpy + 0.13 tpy + 8.78 tpy = 20.37 tpy

1.4.3.2 ACTUAL EMISSIONS

The coal mi11ldryer was not installed prior to the 1994 modification and thus,

has zero actual emissions.

1.4.4 NET INCREASE

Table 12 below summarizes the net increase in VOC emissions at the facility.

TABLE 12. NET INCREASE OF VOC EMISSIONS

Emission Unit Past Actual Future Potential Net Emissions

Emissions Emissions Increase

(tpy) (tpy) (tpy)

Kiln No. 6 36.48 45.83 9.35

Alkali By-Pass 1.70 3.97 2.27

Coal Mill/Dryer Stack 0.00 20.37 20.37

Total 38.18 70.17 31.99

The total emissions increase of 33.06 tpy is less than the PSD significance level of40 tpy

on an annual basis. Therefore, a PSD review is not required for VOC.

1.5 SUMMARY OF PSD NETTING ANALYSIS

A summary ofthe net emission increase calculations for the GCC Dacotah Plant is provided in Table

13.

GCCDacotah 13 Trinity Consultants
REVISED DECEMBER 12, 2002

TABLE 13. NET EMISSIONS INCREASE

Past Future Net

Actual Potential Emission

Emissions Emissions Increase

Pollutant (tpy) (tpy) (tpy)

NO, 1,195.40 2,266.83 1,071.43

CO 207.84 2,025.88 1,818.04

VOC 38.18 70.17 31.99

GCCDacotah 14 Trinity Consultants
1,020 Btulscf, the annual VOC emissions resulting from natural gas combustion

are computed with the following equation.II For conservatism, the 93% uptime

is not considered in this equation.

VOC ( ) 5 3MMBtu sef 5.51b 8,760 hrs ton 0 13 tpy = . x x x x =. tpy hr 1,020 Btu MMsef yr 2,000 Ib

Fin'ally, there are VOC emissions associated with the coal being used in the

coal dryer due to the high organic content ofthe coal used. The coal cleaning

emission factor is deemed most appropriate to account for the high organic

content ofthe coal. AP-42 provides an emission factor of 0.098 Iblton for the

cleaning of coal in a fluidized bed dryer with a venturi scrubber.12 The

maximum predicted annual coal usage for Kiln No.6 is 179,230 tpy. Thus,

VOC emissions as a result of drying coal are computed using the following

equation.

VOC(tpY)=0.098~xI79,230tonx ton 8.78tpy

ton yr 2,0001b

Thus, the total VOC emissions from the coal dryer stack are calculated, as

follows.

voe (tpy) = 8.78 tpy + 0.13 tpy + 13.75 tpy = 22.66 tpy

1.5.2.2 ACTUAL EMISSIONS

The coal dryer was not installed prior to the 1994 modification and thus, has

zero actual emissions.

11 U.S. EPA, Compilation ofAir Pollutant Emission Factors, Volume I: Stationary Point and Area Sources,

AP-42, Fifth Edition, Office of Air Quality Planning and Standards, Research Triangle Park, NC, July 1998, Section 104.

12 U.S. EPA, Compilation ofAir Pollutant Emission Factors, Volume I: Stationary Point and Area Sources,

AP-42, Fifth Edition, Office of Air Quality Planning and Standards, Research Triangle Park, NC, November 1995, Section

11.1 0, Table 1I.1 0-2.

GCC Dacotah 15 Trinity Consultants
1.5.3 NET INCREASE

Table 14 below summarizesthe net increase in YOC emissions at the facility.

TABLE 14. NET INCREASE OF voe EMISSIONS

Emission Unit Past Actual Future Potential Net Emissions

Emissions Emissions Increase

(tpy) (tpy) (tpy)

Kiln No. 6 36.48 45.83 9.35

Coal Dryer Stack 0.00 22.66 22.66

Total 36.48 68.49 32.01

The total emissions increase of32.01 tpy is less than the PSD significance level of40 tpy

on an annual basis. Therefore, a PSD review is not required for YOC.

1.6 SUMMARY OF PSD NETTING ANALYSIS

A summary ofthe net emission increase calculations for the GCe Dacotah Plant is provided in Table

15.

TABLE 15. NET E~IISSIONSIl\'CREASE

Past Future Net

Actual Potential Emission

Emissions Emissions Increase

Pollutant (tpy) (tpy) (tpy)

NO, 1,118.27 2,339.40 1,221.13

eo 207.84 2,079.35 1,871.51

S02 60.03 88.43 28.881

VOC 36.48 68.49 32.01

. . I Due to net emISSIOns decreases, thIS value does not equal the difference between future potential and past actual emissions.

Gce Dacotah 16 Trinity Consultants
ApPENDIX C. SOURCE IDENTIFICATION

The following table provides the correlation between the proposed source numbers and source

numbers, which appeared in previous facility documentation.

GCC Dacotah Trinity Consultants
GCC Dacotah

Rapid City, South Dakota

Table 1

Current

Source

Number

Old Source

Number Old Description New Description

3 3 1955 Allis Chalmers Wet Process RotaIJ.:Ki~#4 __ ESP402-1955 A~~~h~':J.l~r.~.:--V...:!Process Rotary Kiln #"-- .

1__-'4 __ 1957~lIis Ch~lmer~."Y..~t.P!?_ces~_~ota!2'.Ki~~ ._ESP403-1955 Allis C':~~~s..Wet Process Rotary_I:S!~.!'.5__. _

9 9 #6 Fuller Loesche Mill, Preheater and Rotary Kiln EDC619-#6 Fuller Loesche Mill, Preheater and Rotary Kiln

Process Process

11

41

11 Dry Process Alkali By-Pass EDC623-Dry Process Alkali By-Pass

EDC628/9-Coal Dryer-Coal System No.6

Dashed cells Indicate that the source IS not Included In the current TItle V operatIng permit, Issued on February 18, 1999.

NOxCOS02SourceTranslation.xls - Newvs.Old

Trinity Consultants

Printed: 01/16/2002 - 1:00 PM