# (f>GCC Dacotah
January 16, 2002

Mr. Brian Gustafson Department ofEnvironment and Natural Resources

- Air Quality Program Joe Foss Building 523 East Capitol Pierre, SD 57501-3182 DearMr. Gustafson: In 

### accordance with the Amended Compliance Plan, GCe Dacotah submits the following documents to the South Dakota Department ofEnvironment and Natural Resources ("Department") for the Rapid City portland cement manufacturing facility. 1. Application for a "Prevention ofSignificantDeterioration" ("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 Departmenthas had an opportunity to review the enclosed, we would like to schedule a meeting with the Departmentto review all ofour submittals. Specifically, we request that the Department determine the "completeness" ofthe 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 ofdeveloping the PSD pennit applications submitted under separate coverto the Department onNovember 15,2001 and January 17, 2002, respectively, GCC Dacotah has investigated the lead time necessary for the completion ofthe proposed PSDrelatedphysical 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 withrespect to PM, N02 and CO emissions. B. PROPOSED PSD PROJECT-RELATED TIME LINES AND CRITICAL CONSIDERATIONS Gee Dacotah is aware that South Dakotaregulations do notprovide a specific set of procedural requirements for PSD pennits. PSD pennit applications are instead governed by South Dakotaregulatory provisions for the separate and distinct Operating Permitprogram. In developing both PSD pennit applications, Gee Dacotah believes that ithas closely followed the South Dakotarequirements for assembling a completepermit application and requests that the Department make a detennination to that effect as soon as possible. While the South Dakotaregulations allow apotentially long period oftime for a pennit application to be processed, following a completeness determination, GCe Dacotah requests an expedited pennit review from the Departmentin orderthat 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 individualproject complements, and their anticipated duration within the estimated 18-monthperiod: ANTICIPATED TASK ANTICIPATED DURATION Total anticipated PSD pennit-related program 18 months Expansion ofquarry reclamation areas and associated 12

- 13 months reduction ofquarry 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 MalingJldctess: Po. Box360 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 WNN.ga::.can

# ,

# <,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 Ductwork 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 multifacetedprojectwith weatherconditions, seasonal market conditions, specialized contractor availability, and scheduled maintenance outages, GCC Dacotah requests that the Department issue a PSD permitby no laterthan May 

### 31, 2002. GCC Dacotahbelieves that working closely with the Department overthe next four to five months is critical in orderto avoid otherwise costly and duplicative design and engineering efforts and equipmentpurchases. Basedupon the above-describedproject 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 Box360 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 • SeniorProjectManager Walter Greer· SeniorTechnical Associate Mike Remsberg· ProjectManager Stacy Carr • Project Supervisor Erick Mertooetomo • ProjectConsultant

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 OFNITROGEN 4-2 4.2.2 STEP 1 - IDENTlFICATlON OF POTENTIAL CONTROLTECHNOLOGIES 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 STEP4 - EVALUATE THE MOST EFFECTIVE CONTROLS AND DOCUMENT THE RESULTS 4-7 4.2.6 COMPARISON OFNOx 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 CONTROLTECHNOLOGIES 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 STEP4 - EVALUATE THE MOSTEFFECTIVE 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. NETNOxEMISSIONS CHANGEFOR PRIOR MODIFICATIONS AND PROPOSED UPGRADES!MODIFICATIONS (TONS PERYEAR) 3-3 TABLE 3-3. NET CO EMISSIONS CHANGEFORPRIORMODIFICATIONS AND PROPOSED UPGRADES!MODIFICATIONS (TONS PERYEAR) 3-3 TABLE 3-4. NET VOC EMISSIONS CHANGEFORPRIORMODIFICATIONS AND PROPOSED UPGRADES!MODIFICATIONS (TONS PERYEAR) ...................................................•................ 3-3 TABLE

### 4-1. LONG-TERM NOxEMISSION FACTORS FORDIFFERENT KILN TYPES 

### 4-4
TABLE4-2. NOxCONTROL TECHNIQUES RANKED FROM HIGHEST TO LOWEST ESTIMATED REMOVAL EFFECTIVENESS 4-7 TABLE4-3. LONG-TERM NOxEMISSION RATES NORMALIZED TO CLINKERPRODUCTION FROM EPA RBLC AND/ORRECENTLY ISSUED PERMITS FORPREHEATERIPRECALCINERPORTLAND CEMENT KILNS 4-14 TABLE

### 4-4. SUMMARY OF EPA RBLC INFORMATION FOR PORTLAND CEMENT KILNS (CO DETERMINATIONS, 1990-2000) 4-19 TABLE4-5. RANKING OF AVAILABLE CO CONTROL OPTIONS BASED ON CONTROL EFFICIENCY. 4-22 TABLE 

### 5-1. MAxIMUM PREDICTED AMBIENT IMPACTS FORNO

### zAND CO 

### 5-1
TABLE 5-2. MAXIMUM CONCENTRATIONS RESULTING AT THE BADLANDS AND WIND CAVE CLASS I AREAS 5-3 TABLE 6-1. REQUESTED PERMITLIMITS AND COMPLIANCE DEMONSTRATION FORNOx 6-2 TABLE 6-2. REQUESTED PERMIT LIMITS AND COMPLIANCEDEMONSTRATION FORCO 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 CONTROLTECHNIQUES RANKED FROM HIGHEST TO LOWEST ESTIMATED REMOVAL EFFECTIVENESS 4-7 TABLE

### 4-3. LONG-TERM NOx EMISSION RATES NORMALIZED TO CLINKERPRODUCTION 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 FORNOx 

### 6-2
TABLE 

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

### 6-3
TABLE 

### 6-3. REQUESTED ANNUALPERMIT 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 atthis 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 ofSignificantDeterioration (PSD) permitapplication be submitted for oxides ofnitrogen (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 ofAir 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 - PermitLimits 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 AmbientAir 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 ofthe effects on soils and vegetation is required by Title 40 Code ofFederal 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 Consultantsair 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 ofproject modifications. 

## 2.1 LOCATION OF FACILITY The facility is located in Rapid City, South Dakota, within the county ofPennington. An area map consisting ofthe plant property line overlaid upon the mostrecent 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 majoroperations: 1) kiln feed preparation, 2) clinkerproduction, 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 cementmanufacture is 3241

GCC Dacotah 2-1 Trinity Consultants

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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 cementkiln include calcium carbonate and the oxides ofsilicon, aluminum, and iron. Because ofthe large requirement for calcium carbonate, portland cementplants 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 Dacotahplantis mined from a quany located at the site. Limestone is transported from the quany to a crusherthatreduces the rockto the desired size. Otherraw materials, iron ore from off-site sources, sand from the sandpit, and shale from the shale quany, are carefullyproportioned 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. Hotpreheaterexhaust gas is used as the source ofthermal energy to dry the raw materials. The dry powderedraw materials are collected in aparticulate matter (PM) control device, Le., cyclones and abaghouse-fabric filter (FF), and are subsequently fed to ablending systemthatprovides 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 driedpriorto being fed to the kiln system, KilnNo.6 is classified as a dryprocess kiln. In addition, Kiln No.6 is equipped with apreheater tower and a calciner vessel, and is further classified as apreheater/precalcinerkiln. Kiln systems ofthis type are the most energy efficientkind currently in use in the cementindustry. 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 emittedto 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 priorto its introduction into the kiln and the calcinerthrough an indirect firing system. Hotpreheaterexhaust 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 collectedpriorto 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 KilnNo.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 

### shouldbe noted thatthe facility also operates Kiln Nos. 4 and 5 that are wetprocess types and have notbeen modified as part ofthe project coveredby this application.

GCCDacotah 2-4 

### Trinity Consultants

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### Kiln No.6 Process Flow Digram Kiln No.6

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# UJnsu tahts 014401.0088

### 2.2.2 CLINKER PRODUCTION The production ofportland cement clinker involves high temperature processing to complete the chemical reactions that are necessaryto convertthe raw materials into clinker within the pyroprocessing system. The preheatertower ofKiln No.6 is a succession of vessels arranged in vertical series in which rising, hot gas from the rotary kiln and calciner pass countercurrentto the falling raw materials. Very efficientheattransfer is accomplished in a shorttime. At the base ofthe preheatertower is a vessel known as a calciner in which the calcium carbonate component ofthe raw feed is almostcompletely calcined in direct contact with burning coal. The product ofthe calciner is introduced into the feed end ofthe rotary kiln. The rotary cementkiln is common to all clinker manufacturing processes. It isa nearly-horizontal, countercurrentheating device in which the material fed into the relatively-cool, upper end is slowly moved by gravityto the hot end priorto its discharge into the clinkercooler. The burning coal atthe discharge end of Kiln No.6 produces a current ofhot 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 preheaterto the point ofcalcination. Subsequently, calcination occurs in the calciner in which carbon dioxide is liberated from the calcium carbonateto 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 clinkercoolerthrough direct heat transferwith ambient air. 

### 2.2.3 FINISHED CEMENT GRINDING The cooled clinker is sentto storage and then to the'finish mills where it is combined with a small amount ofgypsum (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 priorto 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 ofphysical 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 ofcontinued 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 ConsultantsGCC Dacotah Figure 2-4. PROPOSED PRELIMINARY PROCESS FLOW DIAGRAM CI<D TO QUARRY EXISTING BYPASS OUST COlLECTCR fAN

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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 ofa 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 subjectto the PSD program to apply BACT for each pollutant subjectto regulation underthe 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 aftertaking into account energy, environmental, and economic impacts and other costs (42 U.S.C. §§7479(3)).5 South Dakotahas an EPA-approved PSD program, pursuantto 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 significantnet emission increase (NEI). TheNEls are equal to the PSD SignificantEmission Rates (SER) as South Dakota adoptedthe federal PSD regulations.6 NOx emissions resulting from the 1996 Kiln No.6 modification projecthave been determined to have been above the significantNEI.'· 8 The regulation contained in 40 CFR Section 8I.342 documents that South Dakotahas been designated by the EPA as an area which is in attainment or unclassifiable for all criteria pollutants.9 As a portland cement manufacturingplant, GCC Dacotah is included in the list of28 PSD source categories with major source thresholds of 100 tons peryear (tpy), and based on potential to emit, the facility is considered a major source. As a major source in an attainmentregion, the facility is potentially subjectto the PSD permittingrequirements as specified inARSD 74:36:01: I5. Under the applicable PSD permitregulations, a project is subjectto 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) orNational 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 SIGNIFICANTEMISSION RATES
Pollutant Significant Emission Rate (TonslYear) CarbonMonoxide (CO) 100 Oxides ofNitrogen (NO,) 40

. SulfurDioxide (S02) 40 Particulate Matterwith adiameter of10 micrometers orless (PM IO) 15 Total Suspended Particulate Matter (TSP) 25 Ozone (volatile organic compounds (VOCs» 40 Lead (Pb) 0.6 Fluorides (F) 3 Sulfuric AcidMist 7 TotalReduced 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 proposedmodifications. A detailednetting analysis is contained in Appendix 

### B. In addition, anetting 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 (basedupon a production capacity of 2,250 tons per day (tpd) ofclinker) is provided inTables 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 of40 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 10emISSIOns 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) BaselineEmissions 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*

• Netchange 10 elUlsS!ons IS compared to a SER of40 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 notreported in 1993 and 1994, an AP-42 emission factor was used instead. 1O This factor was multiplied with the average annual clinkerproduction, as reported in the 1992 and 1993 Emission Inventories, to yield the actual emissions because the 1994 EI does not report clinkerproduction. The average clinkerproduction 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 of31.99 tpy for VOC (shown in Table 3-4) is less than its SER, a PSD review is notrequired 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 DENRhas 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 orbefore January 20, 2002. South Dakota PSD regulations (ARSD 74:36:01:06) utilize the definition of"complete" contained in40 CFRPart 52.21(22), which is that 

### "an application for a [PSD] permit
...contains all ofthe information

10 EPA, Compilation of AirPollutantEmission Factors, Volume I: Stationary PointandArea Sources, AP-42, Fifth Edition, Office ofAirQuality Planning and Standards, Research Triangle Park, NC, January 1995, Section 11.6, Table 11.6-8. GCC Dacotah 3-4 Trinity Consultantsnecessary for processingthe 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 ofwhether "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 companyname andaddress ortheplant name and address 

## if different from the company name, the owner's name andagent, andtheplantsite manager orcontact; This item is included in the General Information Form in Appendix A. (2) Aplantdescription in terms of theprocesses andproducts identifiedby the StandardIndustrial Classification Code, 1987, includingany associatedwith each alternate scenario Identifiedby the source; This description is provided in Section 2. (3) Thefollowing information on emissions: (a) Allemissions of pollutants for which the source is majorandallemissions of regulatedair pollutants. The applicantmust describe allemissions of regulatedairpollutants emitted from any emissions unit, except when such units are exempt; (b) Identification anddescription of all emissionpoints describedin subsection (a) of this subdivision in sufficientdetail to establish the basis for fees andthe applicability of requirements of the CleanAirAct; (c) Emissions rates in total tonsperyearand in any otherterms necessary to establish compliance consistentwith the applicable standardreference test method; (d) Fuels,fuel use, raw materials, production rates, andoperatingschedules; (e) Identification anddescription of airpollutioncontrol equipmentandcompliance monitoring devices or activities; (f) Limits on source operation affectingemissions or any workpractice standards, as applicable for all regulated pollutqnts; (g) For allpollutants regulatedat the source, other information requiredby any applicable requirements including information relatedto stackheight limits, such as the location of emissions units,flow rates, buildingdimensions, andstackparameters, including height diameter, and plume 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 of anyprepared plans andthe specifications of any equipment orother facilities that may affect the S01,lrce, includingpollution controldevices; This item is provided via the forms for sources in Appendix A. (5) An abatementstrategiesplan, ifrequiredby chapter 74:36:03; This plan is not required. (6) A signedandnotarizedcertification of applicantform, asprovidedby the department; This item will be submitted with the operating permit application at a later date. (7) The results of any airdispersion modeling requiredby the department; Tl)e modeling results are briefly summarized in Section 5 and discussed in detail in the accompanying modeling reports. (8) Citation anddescription of all applicable airpollution controlemission limit requirements; This item is discussed in Sections 3.1 and 4. (9) A review offugitive emissions includedin the same manneras stackemissions, whetherornotthe source is included in the list of sources containedin the definition of majorsource; A review ofthe emissions sources under consideration indicates that there are no stationary fugitive emissions ofNOx and CO. (10) A description of or reference to any applicable test method for determining compliance with each applicable requirement; This item is 

### in Section 6. (11) Any additional information thatmay be necessary to implementandenforce otherrequirements of the CleanAirActorto determine the applicabilityof such 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 of anyproposedexemptionsfrom otherwise applicable requirements; No exemptions are claimed.

GCC Dacotah 3-6 Trinity Consultants(13) The use of standardizedformsfor acidrainportions of permitapplications andcompliance plans; This requirementis not applicable. (14) Information necessaryto define reasonablyanticipatedalternative operatingscenarios, to definepermitterms andconditionspursuantto 

### § 74:36:05:30, orto implementafederally enforceable emission cap; This item is discussed in Section 6. (15) A complianceplan thatcontains allof thefollowing andis at leastas stringentas that containedin any judicialconsentdecree oradministrative orderto which the source is subject: (a) A description of the compliance status of the sourcejorall applicable requirements, includingapplicable requirements that willbecome effectiveduring the term of thepermit; (b) A description of the requirementsfor which the source is not in compliance at the time of permit issuance anda narrativedescription anda compliance schedule of how the source willachieve compliance with such requirements. The compliance schedule must include a statementthatprogress reports will be submittedat least once everysixmonths; and (c) A statementthat the source willcontinue 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 of compliance bya res ponsible officialthataddresses allairpollution control requirements applicable to the source. A certificationof compliance for an affectedsource subjectto Title IVandchapter 74:36:16 mustbe submittedby the designatedrepresentptive. This certificationmust be consistentwith anyapplicable enhancedmonitoringandcompliance certification requirement of the CleanAirActandmust include: (a) A statement indicatingmethods usedto determine compliance, includingmonitoring, recordkeeping andreporting requirements, andtestmethods; (b) A statementthat compliance certifications willbe submittedat leastannually orat other designatedtimes for the duration of thepermitto the department; (c) A statementthat the source is in compliance with allapplicable requirements; (d) A statementidentifyingthe condition of thepermitthat is the basis of the certification, indicating the compliancestatus, andidentifyingwhethercompliance is continuous or intermittent; and (e) A statement indicating the source's compliance status with anyapplicable enhanced monitoringandcompliance certification requirements of the CleanAirAct; This item will be submitted with the operating permit application at a laterdate.

GCC Oacotah 3-7 Trinity Consultants(17) A certification by a responsible officialof the truth, accuracy, andcompleteness of any application form, report, orcompliance certificationsubmittedto the department. This certification andany otherrequiredcertificationmuststate that, basedon information and beliefformedafterreasonable inquiry, the statements andinformation in the documents are true, accurate, andcomplete; and This item will be submitted with the operating permit application at a later date. (18) Any otherinformation requestedby the departmentaftersubmission of an application for a permit to operate a Part 70source which is relevantto determine compliance of the source with the CleanAirAct. An applicationfora renewal of an operatingpermitfora Part 70 source may refertopreviouslysubmittedmaterial. Revisions to the facility's current South DakotaOperating Permit will be sought in the future in accordance with applicable requirements in orderto reflect any additional or new applicable requirements that may result from this PSD permitapplication. 

## 3.3 ApPLICABLE FEDERAL EMISSIONS STANDARDS The NSPS contained in 40 CFR 60, SubpartA, General Provisions, and SubpartF, Standards of Performance for Portland CementPlants, apply to Kiln No.6, the Loesche Mill, and the associated FullerDry Process Clinker Cooler. In additionto 40 CFR 60, SubpartA, the Coal Dryer

- Coal System No.6 is subjectto the requirements of40 CFR 60, SubpartY, Standards ofPerformance for Coal Preparation Plants. The facility may also be subjectto the requirements ofthe NESHAP at 40 CFR 63, SubpartA, General Provisions, and SubpartLLL, 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, aftertaking 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 todetermine 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 consistentwith recent determinations by various permitting authorities to be BACT for cementkiln 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 perton ofclinker) from various technical sources for the purpose ofcomparing 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 cementkilns. Accordingly, the establishmentofpermit limits for protection ofshortterm NAAQS must be distinctfrom the determination ofBACT 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 forNO, 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 ofAir Qualily Planning and Standards, New Source Review Workshop Manual: Prevention of Significant Deterioration andNonattainmentArea 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 ofa 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 stackbecause all three emission points are downstream in the gas flow path ofthis source ofNOx• On the otherhand, NOxcontrol strategies applied to the precalcineraffectthe coal mill/dryer stack and the main stack, but notthe alkali by-pass because the extraction point for the by-pass is upstream in the gas flow path from the precalciner. As aresult, available control strategies vary. To supplementthe hot gas from the preheatertower, an auxiliary burner is required to provide additional thermal energy to dry the highly wet coal. This auxiliaryburner 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 cementkilns, NO. is produced during fuel combustion by two primary mechanisms: 12

I. Oxidation ofmolecular nitrogen present in the combustion air, which yields "thermal NO•." 2. Oxidation ofnitrogenous compounds present in the fuel, which yields "fuel NOx'" Occasionally, the raw material feed to a cementkiln (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"feedNOx." The contribution offeed NOx to overall NOx emissions from a cement kiln is thought to be minimized in apreheater/ precalciner system such as Kiln No.6 due to the relatively quickheating 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 calcineroriginate predominantly as fuel NO. ifnitrogenous compounds are present in the fuel. Although NO. emissions from cement kilns include both nitrogen

12 EPA, Alternative Control Techniques Document

- NO x Emissionsfrom Cement Manufacturing, (EPA-453/R-94-004, March 1994), p. 4-1. 13 Penta Engineering Corporation, NO, Formation and Variability**Potenti~l** in PortlandCementKilns Potential Control Techniques and Their Feasibility and CostEffectiveness, Portland Cement Association, R&D Serial Number2227, 1999, p.8. GCC Dacotah 4-2 Trinity Consultantsoxide (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 NOxformation in a cementkiln (e.g., a variable flame temperature in the rotary kiln ofapproximately 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 cementkilns, the NOx emission rates in the cement industry, even for cement kilns in one ofthe four process classes, i.e., wet, long-dry, preheater orpreheater/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 ofcement pyroprocessing systems. The BACT determinations in the RBLC represent long-termNOx 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 overthe long term, the sameNOxcontrol 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'ptember2000 EPA report, NO, ControlStrategies for the CementIndustry, and presents NOx emission factors for the four process (kiln) types. 16 These data illustratethe variability ofNOx emission rates between and within process classes, and the overlap ofNOx emission rates between classes. Forthe most part, these factors are derived from continuous emission monitoring system data and represent the best data that are currently available. It is clearthat a lower thermal input per ton of clinkerresults in a lowerNOx emission factor. A preheater/precalcinerkiln, 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 preheatertower 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/precalcinersystem and represents necessary design compromises.

14 Nielsen, P.B., and O.L. Jepsen, An Overview of the Formation of SO, 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 ofNO, emissions from portland cement kilns. 16 Rebecca Battye, Stephanie Walsh, and Judy Lee-Greco, NO, Control Technologiesfor the CementIndustry, final report; prepared for David Sanders, Ozone Policy and Strategies Group, Office ofAir Quality Planning and Standards, EPA; (EC/R Incorporated; September 19,2000), p. 49. 

## Gce Dacotah 4-3 Trinity ConsultantsTABLE 4-1. LONG-TERM NOxEMISSION FACTORS FOR DIFFERENT KILN TYPES Typical HeatInput Average NO, Range ofNO,

.(MMBtu/ton of Emission Rate Emissions Cement Kiln Type clinker) (Ib/ton ofclinker) (Ib/ton ofclinker) 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 ofcontrol 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

- NO x Emissionsfrom CementManufacturing (EPA-453/R-94-004, March 1994). 19**EC~** Technologies for Sustainable Development, IntegratedPollution Prevention andControl (IPPC) Reference Document on BestAvailable Techniques in the Cement andLime Manufacturing Industries (European IPPC Bureau, March 2000). GCC Dacotah 

### 4-4 Trinity Consultants3. 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, permanentapplicationto preheater/ precalcinerprocess kilns such as Kiln No.6. The following sections contain the technical justificationfor 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 ofa 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 catalystmaterials so special catalysts such as titanium dioxide orvanadium pentoxide should be used. On the other hand, PM like that emitted from cementkilns, tends to foul catalysts obstructing their pores. To avoid these problems, the SCR apparatus mustbe located following the PM control device to minimize catalystfouling. However, since SCR requires a ratherhigh 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 ofadditional fuel with a resulting decrease in overallthermal efficiency ofthe process and an increase in combustion related pollutants other than NO,. Following a demonstration project, the EPA reported thatthe NO, removal efficiencies dropped dramaticallyafter a short period ofoperation in the only full-scale demonstration ofSCR on cementkilns.22 It was determinedthat 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., Chapter5. 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-deficientkiln exhaust gases as primary air in the**m~in** burnerto 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 ofdiminished or unacceptable quality because ofan 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 clinkerthat 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 cementkiln 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/precalcinerkiln systems because a significantportion 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 cementkilns with a ranking based on NOx control effectiveness.

23 Rebecca Battye, op. cit., Table 5-10, p. 76. GCC Dacotah 4-6 Trinity ConsultantsTABLE 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'"

• RebeccaBanye, op. Cll., Tables 5-9 and 5-11, pp. 75 and 77
. •• Estimatedremoval effectiveness is based on the results at only one facility at which the technology has been applied in conjunction withTDF burning. *** The base case removal effectiveness is listed-as 0 percent. The emission rate at 0 percentcontrol is that achieved through proper. normal operation. Ifthe kiln were not properly operated, the baseline emissions would be muchhigher. 

### 4.2.5 STEP

### 4 - EVALUATE THE MOST EFFECTIVE CONTROLS AND DOCUMENT THE RESULTS This step involves the consideration ofenergy, 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 offuel and thermal NO.. This process generates products ofincomplete 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 cementkiln such as Kiln No.6 through the use ofa device known as an in-line, low-NO. calcinerwith riser-duct firing. Except for the gas vented through the alkali by-pass for reasons ofproduct quality, all the gas from the rotary kiln is passed through a riserduct to the in-line calciner. Hot tertiary air is ducted from the clinkercooler 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 ductlcalcinerwould have to pass through the combustion zone in the rotary kiln thereby increasing the oxygen concentration at the main burnerpipe location. This increased oxygen concentrationnear the high-temperature flame would lead to higherNO. generation in the rotary kiln. Fuel is burned in the riser duct under reducing (Le., oxygen deficient) conditions. The absence ofoxygen 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 calcinervessel to bum outthe residual CO in the gas stream. The configuration ofthe calcinerhas been developed to minimizethe 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. calcinerwith riser duct firing is applicableto 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 winterweather in South Dakota would be problematical at best. There must be a constant and adequate supply ofbiosolids to reduce on-site inventory requirements and to feed the cement kiln. The high watercontent ofthe biosolids causes an undesirable reduction in the productive capacity ofthe pyroprocessing system and an increase in energy consumption. Public relations problems associatedwith the use ofbiosolids include health and odor concerns. Although BSI is being used atthe California plant, BSI is not regarded as a practicalNO. reductiontechnology 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 ofammonia with NOx without the benefit ofa catalyst to form elemental nitrogen and water. The source ofammonia can be anhydrous ammonia, a water solution ofammonia 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 ofwith sufficientretention 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 enterthe atmosphere as a HAP orwill participate in the formation ofa high-opacity, detached plume ofveryfine PM at the main stack ofa cement kiln. Ifatmospheric conditions are conducive, small but sufficientquantities of chlorine or hydrogen chloride and/or sulfur oxides can react with excess ammonia to form ammonium chlorides and/or sulfates nearthe tip ofthe main stack. These phenomenacan be observed at cementkilns with only small concentrations ofammonia from raw materials contained in the exit gas. If maximum NOxreduction is desired, more ammoniathan 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 ofammonia is difficultto achieve on a continuous basis. The result may be short intervals with a detached plume. SNCR has been applied in Europe to cementkiln systems ofcertain designs. A limited number ofSNCR demonstrations have been conducted in the U.S. but SNCR has yet to be applied continuously to a cementkiln in the U.S. However, SNCR is a potentialNOx control technology for Kiln No.6. 

### 4.2.5.4 CEMSTAR PROCESS CemStar is a patented process that uses blastfurnace or steel slag as a replacementfor cementraw 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 clinkerproduction rate with an anticipated reduction in NOx generation. It is also claimed that the slag serves as a mineralizerto reduce the clinkeringtemperature. An investigation in connection with this assessment indicates that there is no economicallyfeasible steel or blastfurnace 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-NOxBURNERS 

### 4.2.5.5.1

4.2.5.5.2

, '.: 

### ,J" --" IN THE KILN (WITH INDIRECT FIRING) There are various burner designs for rotary cementkilns 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 limitthe 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 airthan was necessary for operation ofthe coal mill. The result is less oxygen available in the interiorofthe flame at the main burnerpipe. Both elements ofthis NOx control technology, a 10w-NOxburner and indirect firing, are suitable for applicationto Kiln No.6. AUXILIARY BURNER FORTHE COAL MILLIDRYER To properly dry the coal, the coal mill/dryerrequires more thermal energy than can be extracted from the gas stream supplied to this device from the preheatertower. 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 lowerNOx 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-trucktires. Chipped tires can be pneumaticallyconveyed into the rotary kiln or calciner as a replacementfor solid fossil fuels. There is no significantadvantage to the use ofchipped 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 ofnitrogen from which fuel NOx can be formed in the riser duct and calciner.28 Whole tires could be inserted into the feed end ofKiln 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 ManufactllrersAssociation Website, November 6,2001. GCC Dacotah 4-10 Trinity Consultantsformed 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 ofat leastthe equivalent of475,000 passengercartires peryear. There are approximately 270 million scrap tires generated in the U.S. annually?9 Since the estimated population ofthe U.S. is slightly greaterthan this amount, there is about one passengercartire peryear 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 appearto be sufficientto support a permanentTDF program at the GCC Dacotah facility at this time.32 Because ofthis supply concern, the use ofTDF is notregarded 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 ofimproving thermal efficiency, maintaining clinkerquality 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 ofconstituents-of-concern, such as NO" through the elimination ofmaterial 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 ofa cementkiln system results in lower fuel consumption perton ofclinker. Lowerfuel consumption results in lower NOx generation. One ofthe purposes ofthe proposed project is to improve the thermal efficiency ofKiln No.6. It is expected that the thermal efficiency of

29 U.S. Department ofEnergy, Energy Efficiency andRenewable EnergyNetwork 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 WalterGreer, 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 ConsultantsKiln 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 infrequentuse 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 ofa cement plantthat must have a predictable operating schedule and cost structure. Generally, the undependable availability and highly variable cost ofnatural gas limits its use in cementkilns. Currently, GCC could not obtain an uninterruptable supply ofnatural gas for Kiln No.6 because natural gas has a higher and betteruse 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 cementkilns. In general, coal produces lower quantities ofthermal NO, in the rotary kiln because ofa lowerflame temperaturethan natural gas.34 The converse is true in the calcinerwhere 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 combustionthat will occur in the riser ductlcalciner ofKiln No.6, the generation offuel NOx from coal combustion will be suppressed; consequently, there is no significant advantage for eitherfuel in this location. Although not impossible, it is very unusual to use different fuels in the kiln and the calciner, even ifboth are available and affordable. When all factors are considered, the use ofcoal 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 calcinerduring periods ofstartup, shutdown ormalfunction. 

### 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 cementkilns has been accomplished through the insufflation oflimited quantities ofcement 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 reintroducethis material to the system through the flame. On the otherhand, the introduction ofraw mix would be a possibility. Flame cooling is technically feasible for Kiln No.6. The gas from the preheatertower that is used for drying and conveying in the coal mill/dryersystem has arelativelyhigh dust burden consisting ofraw mix from the first stage ofthe preheater. This inert dust is included in the powdered coal product ofthe coal mill/dryerand is ultimately incorporated into the flame in the kiln. While GCC Dacotah is not claiming any NOxreduction 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 ofvarious preheater/precalcinerkiln 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 predominantlynew facilities. The range ofpermitted, 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 ofNOxperton 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 preheatertower prevents an optimal sizing and configuration ofthe staged-combustion system; therefore, the NOx emissions resulting from this retrofit should not be expectedto be equal to those ofa new kiln system that is designed to accommodatethe necessary size and arrangement ofpreheater vessels, the calciner and the riser duct. The range oflongterm, permitted BACT emission rates for retrofitted kilns normalizedto clinkerproduction rates is 3.4 to 4.5 pounds ofNOx perton ofclinker.

35 The lowest value in Table 4-3, 1.4 pounds ofNOx per ton ofclinker 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 ofNOx perton ofclinker 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 perton ofclinker, the Texas SIP level as a result ofozone non-attainment in the plant operating area. 

# '" GCC Dacotah 4-13 Trinity ConsultantsTABLE 4-3. LONG-TERM 

### NOxEMISSION RATES NORMALIZED TO CLINKERPRODUCTION FROM EPA RBLC AND/OR RECENTLY ISSUED PERMITS FORPREHEATERIPRECALCINERPORTLAND 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~~\\** New BACT

- Combustion practices. s-cP"I 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 7? 

### 2.5 New BACT

- Staged combustion design. Midlothian, TX


# - 4.2.7 EvALVAnON OFTECHNOLOGY COMBINAnONS This section addresses the possibility ofcombining stand-alone, technically feasible control technologies to determine ifa combination ofany 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 ofammonia or ureato reduce NO. withoutthe use ofa 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 tooccur. In a kiln system with staged combustion, the appropriatetemperature regionis located in the riser duct and the calcinerwhere oxygen deficient conditions have been created deliberately. Without availab,le oxygen, the reactions between constituents ofNO. and ammonia cannotbe completed. These reactions are:37

Even afterthe remainingtertiary 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 comparedto NO.. At this point in a cementkiln 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 afterthe calciner and before they cool below the 1,600 OF reaction boundary, there is limitedtime and opportunity forthe NO. reduction reactions to occur. Under the conditions that exist in the riserduct and the calciner during staged combustion as applied to Kiln No.6, the probability is very high thatthe efficiency ofSNCR will be very low thereby resulting in disappointingNO. reduction and the attendant problems that occurwith 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/ortrace amounts ofhydrogen chloride or chlorine shortly afterthe kiln gases exitthe stackto form very fine PM that is observed as a detached plume ofhigh opacity. The use ofSNCR always carries a moderate risk ofammonia slip and a detached plume, but when coupled with staged combustion in a retrofitted in-line calciner, there is a near certaintythat a detached plume will result. Because ofthe anticipated slow completion ofthe NO. reduction reactions and the high probability ofa detached plume, the application ofSNCR in

36 Rebecca Battye, op. cit., p. 70. 37 Rebecca Battye, op. cit., p. 68. GCC Dacotah 4-15 Trinity Consultantscombination with staged combustion appears to be incompatible and is not considered technically feasible at this time. Following a modification ofKiln 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 NOxreduction technology on a preheater/precalcinerkiln 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 BURNERUSING INDIRECT COAL FIRING Staged combustion only occurs in the riser duct and calciner. This technology is independent ofthe configuration or operation ofthe burnerin the rotary kiln. The inherent use ofa tertiary air duct as part ofa 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-NOxBURNER Flame cooling using the insufflation ofraw mix into the flame at the main burner would interfere with the proper operation ofa 10w-NOxburner; 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 selectthe 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 ofKiln No.6 is staged combustion with a thermally-efficient, in-line, low-NO, calciner complimentedby a lowNOxburner with indirect firing in the rotary kiln to achieve a NO, rolling annual average emission rate of 1,718 tons per year ofNOx (equivalentto a normalized annual emission rate of4.50 pounds ofNOxperton ofclinker) updated at the end ofeach calendarmonth.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 vendorprojections and on the analysis providedpreviously, the BACTbeing proposedby 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 ofeach calendarmonth perprocedure noted in Table 6-1. The technologies proposed as BACT do notrely 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. Theirreliability and operation are required to produce cement clinker ofhigh quality as efficiently and expeditiously as possible, and do notrequire special attention to remain effective forNO, control. The exhaust gas stream supplied to the coal mill/dryer contains gas from the preheater tower that will have been subjectedto BACT NO, control as proposedherein. Because insufficientthermal energy is available in this gas stream to adequately dry the coal, it is necessary that additional thermal energy be addedto the gas stream through the use ofan auxiliary, natural-gas-firedburner. The existing auxiliary burner is rated at 5.3 MMBtu/hr and emits approximately 2 

### tons peryear ofNO, based on 8,760 hours ofoperation. This amount ofNO, is insignificantwhen compared to the NO, emissions exiting the coal mill/dryer stackthat originate in thepyroprocessing system. Based on vendorprojections and on the analysis providedpreviously, the BACTbeing proposedby 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 complimentedby a low-NO, burnerwith indirect firing in the rotarykiln.40 

### The emission rates will be updated at the end ofeach calendarmonth perprocedure noted in Table 6-1. Arolling 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 BACTrequirements. Updating the rolling annual average for NO, emissions at the end ofeach calendarmonthprovides for short-term control and evaluation ofthe emission rate ofNO, from all three emission points associated with Kiln No.6 for which a "bubble" permitlimit is being sought. The variability ofNO, emissions from cement kilns is ofcritical concern in establishing an appropriate emission rate limit.41 

### Each cementkiln systemhas its own baselineNO, emission rate and its own unique range ofNO, emissions that cannotbe determined with accuracy until the system is operated for several months. The use ofan annual rolling

39 The gas flow rate to the alkali by-pass is 6% ofthe gas flow rate ofthe main stack ofKiln No.6. 40 The gas flow rate to the coal mill/dryer is 20% ofthe gas flow rate ofthe preheater exitgas. 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 Consultantsaverage as proposed by GCC Dacotah eliminates the need for prospective estimates of variability. The long-term, baseline emissions ofa new orretrofitted cement kiln system can be determined with acceptable accuracy by the equipmentvendor. Several factors affectthe short-term NO, emission rates from cement kiln systems.42 These factors can be synergetic or counteractive and contributeto seemingly large variations in NO, emissions from cementkilns 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 of2.6 to 2.9 times the baseline emission rate to accommodate normal variations in NO, emissions.44 For example, a preheater/precalcinerkiln with a long-term, e.g., annual-average, emission rate limit of425 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 identitYthe 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 potentiallycontrol CO emissions from portland cementkilns. The potentially available technologies for controlling CO emissions from the cementkiln 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, ProposedMissing NO, andFlow Rate Data Calclliation Routinefor PortlandCement Kilns, (Portland Cement Association R&D serial No. 2495, 1999), Table 3, p.iO. GCC Dacotah 4-18 Trinity ConsultantsTABLE 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, FL 2 

## ,.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, AL 4.0 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 sufficientcombustion air at a suitabletemperature to allow for up to 90% oxidation ofCO to carbon dioxide (C02), A properly designed and operated RTO will recover up to 95% ofall 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 ofa 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-contactheat recovery mediato recover the heat in the gas stream. A RTO consists ofat leasttwo modules that are cycled between inlet and outlet service to maintain appropriate operatingtemperatures and to conserve as much thermal energy as possible. In cementkiln 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 accommodatethe 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 applicationto cement kilns. There are no published data on these installations. 

### 4.3.1.2 THERMAL OXIDATION TO is a technique similarto RTO in that CO is oxidized to CO2 at high temperature, Le., 1,300 OF. However, TO has lowerthermal efficiency than RTO. A downstream heat exchangercan 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 ofhydrocarbons in the exit gas stream. TO is typically used for small, intermittentflue gas streams where thermal inefficiency does not represent a significantcost. TO has not been applied to a cementkiln. 

### 4.3.1.3 REGENERATIVE CATALYTIC OXIDATION RCO employs the same principal as RTO orTO exceptthat a catalyst is used to increase the reaction rate thereby enablingthe oxidization ofCO to CO2 at a lower reaction temperature than in RTO or TO. Ifnecessary, the gas stream must be reheated to a temperature sufficientto initiate the oxidation ofCO as GCC Dacotah 4-20 Trinity Consultantsthe gas stream passes over a catalystbed consisting ofa noble metal such as palladium or platinum. RCO also reduces the concentration ofhydrocarbon in the exit gas stream. As applied to a cementkiln, RCO would increaseNOx 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 ofCO. A potential problem with RCO is the possibility ofcatalystpoisoning by chlorine or sulfur oxides. The presence of PM could also foul the catalystby blindingthe catalystpores. 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 ofCO in the flue gas stream may be indicative oflocalized 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 throughoutthe process. Fuel and air flows are appropriately adjusted to maintain optimum combustion conditions whereverfuel 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 atechnically feasible option. In comparing a theoretical application ofan RTO system on a cementkiln in this case to atypical application ofan 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 ofKiln 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 ofVOCs by the unit.
GCC Dacotah 4-21 Trinity Consultants• Inlet loadings ofotherpollutants (non-VOC) in other applications are often negligible. In this case, the effects ofotherpollutants 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 neithertechnically 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 ofCO from a portland cementkiln. Combustion products from the kiln may contain hydrogen chloride or chlorine and certainly contain sulfuroxides and alkaline particulate matterthat could poison orfoul the catalystthereby rendering it ineffective. The extreme sensitivity ofa noble metal catalyst to these constituents ofconcern 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 greaterthan 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 independenttreatment units for each gas stream. Because ofpotential 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 ofGCP is not available, but it could range from a low removal efficiency of0% to complete removal (100%) depending on the selection ofthe baseline emission rate from which the efficiencycalculation is made. Every cementkiln 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 endoftherange. 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 highestranked control option, TO, is evaluated first. Ifthe evaluation concludes that this option is technically and economically GCC Dacotah 4-22 Trinity Consultantsfeasible, 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 ofa 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 ofa 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 ofnatural gas required to reheat the kiln exhaust. Following are calculations for the volume ofnatural gas required to re-heatthe exhaust gas and the costper ton ofCO controlled. The main stack for Kiln No.6 has a much greaterflow rate than eitherthe 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/dryerwere 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 ofnatural gas that would be required to re-heatthe exhaust gas from 260 of back up to 1,300 OF can be calculated as follows:

( 460 + TS)scfgas

# J HL 

### = (D)(Cp)(TO -TF) (460 + TF) acfgas Where: HL 

### =Natural gas heat input (Btu/act) Ts 

## =Standard temperature (68 OF) D 

### = Density ofair 

### @ 68 of (0.0026 lb-mole/scf) Cp 

### = Specific heat ofair, (7.0 Btu/lb-mole OF)

45 This value is based on 13.9 Btu 1acfas calculated and 240,000 acf 1min, the design ofthe unit. In addition, an emission factor of 190 lb 1106 scfis used. This value is listed in Table 1.4.1 ofAP-42 Section·l.4 dated July 1998 (EPA, Office of Air Quality Planning and Standards, Compilation of AirPollutantEmission Factors. Volume 1: StationaryPoint andArea Sources, Fifth Edition, Research Triangle Park, North Carolina). It is for an uncontrolled large boiler (greaterthan 100 MMBtulhr). Finally, the hours ofoperation are 8,147 peryear (this assumes 93% uptime ofthe kiln). GCC Dacotah 4-23 Trinity ConsultantsTF 

### = 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 tothe second equation yields a natural gas cost ofapproximately $11,300,000 annually. Applying a conservativelyhigh, 90% 'control to the base case emission rate of 1;528 tons CO per year yields a potential CO reduction of 1,376 tons peryear. Based strictly on the annual cost ofnatural gas to reheat the exhaust gas, the control cost is over $8,200 per ton ofCO 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, onlythe 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 cementkiln 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 ofGCC Dacotah to minimize the generation ofCO through GCP since CO is the result ofunburned fuel. It is

46 Average natural gas cost for industrial consumers in South Dakotafor year-to-date 2001, Energy Information Administration/NaturalGas Monthly September 2001. GCC Dacotah 4-24 Trinity Consultants

## REVISED DECEMBER 12, 2002 preferable to prevent the generation ofapollutantrather 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 notbeing applied. CO is seldom a problem for cement kilns when demonstrating compliance with NAAQS. Ifthere mustbe a tradeoffbetween 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 ofa thermal oxidizer is economically infeasible for CO control for Kiln No.6. In addition, this technology has undesirable energy and environmental impacts. Based on vendorprojections and the analysis provided previously, the BACT being proposedby GCC Dacotah for CO emissions from the main stack ofKiln No.6 is GCP in the rotary kiln and the calcinerto achieve arolling annual average emission rate of 1,528 tons ofCO peryear (equivalent to a normalized annual emission rate of4.00 pounds ofCO perton ofclinker) updated at the end ofeach calendarmonth.47 Based on vendorprojections and the analysis providedpreviously, the BACT being proposedby GCC Dacotah for CO emissions from the alkali by-pass stack ofKiln No.6 is GCP in the rotary kiln.48 The emission rates will be updated atthe end ofeach calendar monthperprocedure noted in Table 6-3. Based on vendorprojections and the analysis provided previously, the BACTbeing proposedby 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 ofeach calendar month perprocedure 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 ofKiln No.6. 49 The gas flow rate to the coal mill/dryer is 25% ofthe gas flow rate ofthe prehea!erexitgas. GCCDacotah 4-25 Trinity Consultants

## REVISED AUGUST 31, 2002 The proposed emission rate limits provide a short-term emission rate limit consistent with the primaryNAAQS and a long-term emission rate limit consistent with PSD and associatedBACTrequirements that consider CO emissions on an annual basis. There is no NSPS orNESHAP emission standard for CO from cementkilns.

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 permitprogram 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 ofthe air quality analyses is presented in this section. The analyses completedby 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 (fornon-Class I areas) modeling analyses performed for N02 and CO overthe associated averaging periods ofthese standards, the highest predictedpollutantconcentrations 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 NO

### zAND 

### CO Averaging Pollutant Period N02 Annual

CO 8-hour I-hour I-hour Maximum Modeled Results PSD Threshold Level Analysis Type (Ilgl 

### m) (llgl 

### m3) 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 ifSignIficance AnalySIS indIcates amodeled result above the PSD

Significance Threshold ofI 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 ConsultantsBased 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 priormodifications 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. Forthe 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 ofemissions, 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 ofnew employees and the availability ofhousing in the area, while associated commercial and industrial growth consists ofnew 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 orderto 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. Ifambient 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 ofAir Quality Planning and Standards, New Source Review Workshop Monual: Prevention of Significant Deterioration andNonattainmentArea 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 ImpactAnalysis, 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 Forthe 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 notrequired. Class I increment analyses for CO are notrequired. 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 of2,267 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) (KilnNo.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 SystemNo.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 monthlybasis.



## • ForBACT, 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 13tholdestmonth willbe dropped offfrom the rolling average.

• The requested annual limitof2,267 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 ofthis permit application)

•• NOx emission rate for the coal milVdryer stack does not include the emissions from the 5.3 MMBtuIhrburner since itcontributes 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 ofKiln No.6, total CO 

## • Source 9: #6 Fuller of3,250 emissionrates (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-hourdiscrete blockbasis. (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 SystemNo.6 stack ofcoal mill/dryer, total CO emission (EDC628/9) (Coal rates (ER_CM, poundslhour) for the Coal MilllDryer Stack) Mill stackwiII be calculated on a 8-hour discrete blockbasis. The 8-hour averages shall be determined from successive nonovedapping 8-hourblocks starting at midnight each calendar day.



## • The CO emissionrate 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 of2,026 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 SystemNo.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" willbe updated on a monthlybasis.


## • ForBACT, 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 limitof2,026 tpy is derived by rounding offthe post-modification potential to emit (PTE) of2,025.88 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: GCCDacotah 

### 2. Mailing address: Street and/orbox number: P.D. Drawer360 

### City, state, zip code: RapidCity. SD 57709 

### 3. Facility location (ifplant is portable, enterlocation attime ofsubmittal): Streetand city: 501 N. 

### St. Onge Street. RapidCity, SD 57709 

### and/or Legal description and county: Sections 

### 33. 34. T2N. R7E. Pennington County (Quarter, Section, Township, Range) 

### 4. Permitcontact: Name/title: Gene Nelson. EnvironmentalEngineer 

### Telephone number: (605) 721-7033 

### 5. Facility contact, ifdifferentthan permitcontact (Person to contact for arranging inspections): Name/title: SAMEASPERMITCONTACT 

### 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 partneror the proprietorfor a partnership; and principal executive officeror ranking elected official for municipal, state, federal orpublic agency.B. 

### PLANT DESCRIPTION 1. 

### Standard Industrial Classification Code (SIC code); Please contact the Department ifunable to determine your SIC code. 

### Primary SIC code; 3241 Secondary SIC code (ifapplicable): NA 

### 2. Briefly describe the operations at the facility, including raw materials and finished products: This plantproduces PortlandCement utilizingwet anddryprocesses. Raw materials are crushedandburnedin rotary kilns to produce clinker. The clinker is then groundto produce thefinal cementproduct. Limestone, sand. gvmpsum. andshale are quarriedon site, while the iron ore andcoalarefrom offsite sources. Please refer to Section 

### 2.2 ofthe enclosed applicationfor additionalinformation.

Please attach one copy, ifavailable, ofany prepared plans and the manufacturers specifications of any equipment, including pollution control devices. Ifadditional space is needed to describe operations, please attach the additional paper to this application. 

### 3. A new source ormodificationto an existing source, which has the potential to increase emissions, is required to demonstratethatthe operation ofthe new source or modification will not prevent or interferewith the attainmentor maintenance ofan applicable ambient air quality standard. Please attach air dispersion modeling or otherdocuments which will demonstrate the new source ormodification will notpreventorinterfere with the attainment ormaintenance ofan 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 referto the ISCST3 andCALPUFFmodeling reports for additionalinformation. 

### C. COMPLIANCE PLAN Ifit is anticipatedthat a permittedunit 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 narrativedescription ofthe following: I. The requirements (Le., statutes, air quality rules, permitconditions, etc.) the source is not in compliance with at the time ofsubmittal ofthis application or permitissuance; 2. How the facility intends to bring the unites) into compliance; and 3. A compliance schedule for when the source will achieve compliancewith such requirements; The compliance schedule must include a statementthat progress reports will be submitted at least once every six months and mustbe at least as stringentas that contained in anyjudicial consent decree or administrativeorderto which the applicantis subject. Please refer to Section 

### 1 ofthe enclosedapplicationfor additional information.

### D. MAPS For stationary sources only, please enclose a map or a drawing showing roadways, location ofplant and the nearestresidents in each direction from the source. Include other structures which may be affected. Please referto Section 2.1 ofthe enclosedapplicationfor additional information. 

### E. AIR QUALITY EMISSIONS SUMMARY Ifair quality emissions are available, please complete the following table:
Potential Actual Potential Controlled Uncontrolled Pollutant (tons peryear) (tons peryear) (tons peryear) 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 of the enclosedapplication summarizes the emissionsfrom the proposed modifications.
Please contact the Department ifassistance is needed for calculatingemissions for the permitted units such as emission factors, clarifying what potential emissions are, efficiency for control equipment, etc. 

### Please referto the ISCST3 andCALPUFFmodeling reportsfor additionalinformation.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 orDryer 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-#6FullerLoesche Mill. PreheaterandRotaryKiln Process 

### 2. Manufacturer: Fuller 

### Date ofmanufacture: 1977 Model number: Mill- IM-27. 2120 

### 3. Check one: Stationary

## X Portable 4. Maximum design operating rate: 315 MMBtu/hrheat input 

### Processed material or product? 93.8 tons perhourclinker 

### Heat source? Coal 

### 5. Actual or anticipated operation: 8.147 hoursperyear 

### Type ofmaterial processed orproduced? Clinker 

### Amount ofmaterial processed orproduced? 2.250 ton clinkerperday 

### 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 Notapplicable 

### 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.% Notapplicable

### 6. Has a stacktestbeen conducted? Yes

### X No Ifa stack test(s) has been conducted, please attach a copy ofthe most recent stacktest reportto this application and skip item #7. Ifthe Department already has acopy ofthe most recent stack test, please specifythe date ofthe mostrecent stacktest: Most recent stacktest date: June 

### 19. 2001 

### 7. Stack information (ifa stack is present): Stack height (feet): 240.00 

### Stack diameter(feet): 10.17



### 8. Type ofairpollution 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 enclosedapplicationprovides details of controltechnology.

### KILN OR DRYER OPERATION

I. Facility identification (Le., Unit #1, Pierre Plant, etc.): 11. EDC623-Dry ProcessAlkaliBy-Pass 

### 2. Manufacturer: Fuller 

### Date ofmanufacture: 1977 Model number: Not available 

### 3. Check one: Stationary

## X Portable 4. Maximum design operating rate: 20.764 tons/year 

### Processed material or product? Cement Kiln Dust 

### Heat source? Kiln No.6 

### 5. Actual oranticipated operation: 8.147 hoursperyear 

### Type ofmaterial processed or produced? Cement Kiln Dust 

### Amount ofmaterial processed orproduced? 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 Notapplicable 

### Fuel Consumption (i.e., cubic feet/hour, gallons/hour, pound/hour, tons/hour, etc.) Notapplicable Not applicable 

### Heating value (i.e., Btus/cubic feet, Btus/gallon, Btus/pound, etc.) Not applicable Notapplicable 

### SulfurContent (ppm) Not applicable Notapplicable 

### Ash Content (Wt.%) Notapplicable Notapplicable



### 6. Has a stacktestbeen conducted? Yes

## X NoIfa stacktestes) has been conducted, please attach a copy ofthe most recent stacktest report to this application and skip item #7. Ifthe Department already has a copy ofthe most recent stack test, please specifythe date ofthe most recent stacktest: Most recent stacktest date: 

### November I, 2001 7. Stack information (ifa stack is present): Stack height (feet): 

### 71.00 Stack diameter (feet): 

### 5.00

8. Type ofairpollution control equipment: (Examples: wet scrubber, cyclone, baghouse, electrostaticprecipitator, etc.) 

### Please complete the appropriate air pollution control equipment data 

### sheet(s) for this unit. 

### Section 4 

### ofthe enclosedapplicationprovides details of controltechnology.

### KILN ORDRYER OPERATION

1. Facility identification (i.e., Unit

### #1, Pierre Plant, etc.): 41. EDC628/9-CoalDryer-CoalSystem No.6 

### 2. Manufacturer: NorthAmerican 

### Date ofmanufacture: 1994 

### Model number: 0514-8-B 

### 3. Check one: Stationary.K Portable 4. Maximum design operatingrate: 5.3 MMBTU/hr 

### Processed material orproduct? 

### 18 tonsper hourcoal 

### Heat source? CoalDryer 

### 5. Actual or anticipated operation: 8.147 hoursperyear 

### Type ofmaterial processed orproduced? Coal 

### Amount ofmaterial processed orproduced? 

### 18 tonsperhourcoal 

### 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.) perhour Not applicable 

### Heating value 1,020 

### (i.e., Btus/cubic feet, Btus/gallon, Btus/pound, etc.) Btus/cubicfeet Not applicable 

### SulfurContent (ppm) 

## tiI!I2m. Not applicable 

### Ash Content (Wt.%) OWt.% Not applicable



### 6. Has a stacktestbeen conducted? Yes.K No

### Ifa stack testes) has been conducted, please attach a copy ofthe most recent stacktest reportto this application and skip item #7. Ifthe Departmentalreadyhas a copy ofthe mostrecent stack test, please specifythe date ofthe mostrecent stacktest: Most recent stacktest date: November

### 28. 2001 

### 7. Stack information (ifa stack is present): Stack height (feet): 105.00 

### Stack diameter(feet): 3.50



### 8. Type ofairpollution control equipment: (Examples: wet scrubber, cyclone, baghouse, electrostaticprecipitator, etc.) 

### Please complete the appropriate air pollution control equipmentdata sheet(s) for this unit. Section 4 of the enclosedapplication provides details of controltechnologv.

## REVISED DECEMBER 12, 2002 ApPENDIX B. 

## PSD NETTINGANALYSIS

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 peryear Ib/hr pounds perhour lb/ton pounds perton Ib/MMscf pounds per million standard cubic feet 

### MMBtu/hr million British thermal units perhour tpd tons per day tpy tons peryear
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 NETTINGPROCEDURE 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 DraftEPA New Source Review (NSR) Workshop Manual for PSD andnonattainment areapermitting.t A sixstep procedure is used for determining the net emissions change as summarizedbelow.
1. Determine the emissions increases from the proposedprojece Ifincreases are significant, proceed; ifnot, the projectis not subjectto review.

I EPA, Office ofAir Quality Planning and Standards, New SourceReview Workshop Manual: Prevention of SignificantDeterioration andNonattainmentAreaPermitting, DRAFT, October 1990. 2This is a retroactive PSD application and thus, amajority ofthe "proposed" project has alreadybeen 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 ofeach 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 ifa 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-poIlutantbasis. 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 periodbegins 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 ofoperation 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, orreductions 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 aphysical change or change in the method ofoperation at the source orthe 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 aPSD permit and the permit is in effect when the increase from the proposed modification occurs. Forpollutants with PSD increments, an increase or decrease in actual emissions which occurs before the baseline date in an area is creditable only ifit wouldbe considered in calculating how much ofan 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 occurbefore the proposed emissions increase occurs. A source cannottake credit for a decrease that ithas had to make, or will have to make, in orderto bring an emissions unit into compliance. Furthermore, a source cannottake credit for an emissionreduction from potential emissions from an emissions unit, which was permitted, butneverbuilt or operated. 

### 1.1.5 AMOUNT OF THE EMISSIONS INCREASE AND DECREASE An emissions increase or decrease is the difference between the new level ofactual 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 atwo-yearperiod, which directly preceded the physical change. 

### 1.1.6 PSD REVIEW The proposed project is subjectto PSD review foreachregulated pollutant for which the sum ofall creditable emissions increases and decreases results in a significantnet emissions increase. However, additional prospective and creditable emissions reductions sufficient to provide for a less than significantnet emissions increase at the source may be proposed to avoid PSDreview.

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 orprocesses 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 ofNO, are determined from an average ofthe 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 calculatedusing 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/dryerunit, which did not exist at that time, has been reported as having zero actual emissions. Proposed NOx emissions are calculated using a clinkerproduction capacity of2,250 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 clinkerproduction of2,250 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 ofclinker x4.5 1bofN?x x ton ofNOx x 365 days x 93% uptime = 1,718.47 tpy day ton ofclinker 2,0001b ofNO x year

1.2.1.2 ACTUAL EMISSIONS Actual emissions for Kiln No.6 are the average ofthe 1993 and 1994reported 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,letterto Brian Gustafson, Administrator, and Kyrik Rombough, Air QualityProgram 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 clinkerproduction 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 ofclinker x0.3 Ib ofNO, x_t_o_n_o_f_N_O--",--x 365 days x93% uptime = 

### 114.56tpy day ton ofclinker 2,000Ib ofNO, year


### 1.2.2.2 ACTUAL EMISSIONS 

### Actual emissions are calculatedbasedupon the reported emissions from 1993 and 1994 as given in the emission inventories. The average calculation is summarizedin Table 5. TABLE 

### 5. ACTUAL EMISSIONS FORALKALI 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 ofclinker x 1.13 lb of

### NO, x ton of

### NO, x 365 days x 93% uptime = 431.52 tpy day ton ofclinker 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 IblMMscfand aheating 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/dryerunit did not existpriorto the 1994 modification and therefore past actual emissions are zero. 

### 1.2.4 NET INCREASE Table 6below summarizes the net increase in 

### NO, emissions at the facility.

S Ibid 6 U.S. EPA, Compilation of AirPollutantEmission Factors. Volume I: Stationary PointandArea 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 forNO,. 

## 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 KilnNo.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 clinkerproduction from 1992 and 1993:' The coal milVdryerunit, which did not exist at that time, has beenreported as having zero actual emissions. PSD netting for CO is performed for emission limits soughtby 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 clinkerproduction 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 clinkerproduction for 1994 is notreported in the 1994 Emissions Inventory; therefore, CO emissions for 1994 cannotbe calculated. The selection ofrepresentativebaseline years of 1992 and 1993 is based on data completeness. 

### GCCDacotah 

### 7 Trinity Consultants

## REVISED DECEMBER 12, 2002 

# co( ) 2 250 tons ofclinker 4.0lb ofCO ton ofCO 365 days 930/ . 1 52753 tpy 

## = , x x x x /0uptIme = , . tpy day ton ofclinker 2,000 lb ofCO 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 FORKILN 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 emissionrate 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 of AirPollutantEmission Factors. VolumeI: StationaryPointandAreaSources. AP-42, Fifth Edition, Office ofAir 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 of84lbIMMscfand aheating value for natural gas of1,020 Btu/scf, the annual CO emissions resulting from natural gas combustion are computedwith 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 installedpriorto 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 of AirPollutantEmission Factors, Volume I: StationaryPointandirea Sources, AP-42, Fifth Edition, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, July 1998, Section 1.4. GCCDacotah 

### 9 Trinity ConsultantsREVISED 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 andthe 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 CementManufacturing provides an emission factor for Total Organic Compounds (TOe) emissions from apreheaterprocess kiln with a precalciner. 12 For the purposes ofthis calculation, it is assumed that all TOC

II The average clinkerproduction for 1994 is notreported in the 1994 Emissions Inventory; therefore, VOC emissions for 1994 cannotbe calculated. The selection ofrepresentative baseline years of 1992 and 1993 is based on data completeness. 12 U.S. EPA, Compilation of AirPollutantEmission Factors. Volume I: StationaryPointandArea Sources. AP-42, Fifth Edition, Office ofAir 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 clinkerproduction, 2,250 tpd, and 93% uptime ofthe kiln determines the potential emissions for Kiln No.6. Potential VOC emission information is calculatedbelow.
VOC (tpy) = 2.250 tons ofclinker x 0.12 lb of VOC x ton of NO, x 365 days x 93% uptime = 45.83 tpy day ton ofclinker 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 preheaterprocess kiln. 13 Forthis analysis all TOC is considered to be VOC. The 1992 and 1993 clinkerproduction 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 ACTUALEMISSIONS 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. Forthe 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 x0.06 = 3.97 tpy 

### 1.4.2.2 ACTUAL EMISSIONS AP-42 Section 11.6 provides an emission factor for TOC emissions from a preheaterprocess kiln. 14 Forthis analysis all TOC is considered to be VOC. This AP-42 factor, multiplied with the average annual clinkerproduction, 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/dryeris calculated as follows:. ( 0.2 vac tpy) =45.83 tpyx -= 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/dryeris 5.3 

### MMBtuIhr. Using an AP-42 emission factor of5.5 IblMMscfand 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 1,020Btu 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 of0.098 lb/ton for the cleaning ofcoal in a fluidized bed dryerwith a venturi scrubber.16 The maximumpredicted annual coal usage for Kiln No.6 is 179,230 tpy. Thus,

IS U.S. EPA, Compilation of AirPollutantEmission Factors, Volume I: StationaryPointandArea Sources. AP-4Z, Fifth Edition, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, July 1998, Section 1.4. 16 U.S. EPA, Compilation of AirPollutantEmission Factors. Volume I: Stationary PointandArea Sources. AP-4Z, Fifth Edition, Office ofAirQuality Planning and Standards, Research Triangle Park, NC, November 1995, Section 1I.l0, Table 1I.I

### o-Z. GCCDacotah 12 Trinity Consultants

## REVISED DECEMBER 12, 2002 VOC emissions as aresult ofdrying 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 installedpriorto the 1994 modification and thus, has zero actual emissions. 

### 1.4.4 NET INCREASE Table 12below summarizes the net increase in VOC emissions at the facility. TABLE 12. NET INCREASE OFVOC EMISSIONS Emission Unit Past Actual Future Potential NetEmissions 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 of33.06 tpy is less than the PSD significance level of40 tpy on an annual basis. Therefore, aPSD review is notrequired for VOC.



## 1.5 SUMMARY OF

## PSD NETTING ANALYSIS A summary ofthe net emission increase calculations for the GCC Dacotah Plantis provided inTable 

### 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 Consultants1,020 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 of0.098 Iblton for the cleaning ofcoal in a fluidized bed dryerwith a venturi scrubber. 12 The maximum predicted annual coal usage for Kiln No.6 is 179,230 tpy. Thus, VOC emissions as a result ofdrying 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 priorto the 1994 modification and thus, has zero actual emissions.

11 U.S. EPA, Compilation of AirPollutantEmission Factors, Volume I: Stationary Point andArea Sources, AP-42, Fifth Edition, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, July 1998, Section 104. 12 U.S. EPA, Compilation of AirPollutant Emission Factors, Volume I: Stationary Point andArea Sources, AP-42, Fifth Edition, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, November 1995, Section 11.10, 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 notrequired 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~IISSIONS** Il\'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 28.88 1 VOC 36.48 68.49 32.01



### . . IDue to netemISSIOns 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 ConsultantsGCC 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