GCC info

Rick.Boddicker to

: Gail Fallon 10/11/2011 10:21 AM

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From: <Rick.Boddicker@state.sd.us>

To: Gail Fallon/R8/USEPA/US@EPA

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Gail, here ’ s some info from Kyrik on Kiln #6. Let me know if you need anything else.

RickIn November 2001, GCC Dacotah submitted a Prevention of Significant Deterioration (PSD) air quality

application to DENR for its upgrade to Kiln #6. In January 2003, the National Park Service submitted comments on the draft PSD permit for GCC Dacotah. One of the National Park Service ’ s comments was
selective non

- catalytic reduction technology should have been considered BACT for Kiln #6 in addition to

DENR ’ s nitrogen oxide BACT determination. DENR determined nitrogen oxide BACT for Kiln #6 was the
installa tion of staged combustion with a thermal efficient in

- line low

- NOx calciner complimented by a low NOx burner with indirect firing in the kiln.

DENR determined at that time that selective non

- catalytic reduction technology was not technically feasible for inclusion with the chosen BACT for the following reasons: 1) The chosen nitrogen oxide emission controls (e.g., staged combustion, low NOx burn er, etc.) are designed to operate in oxygen deficient zones; 2) A selective non

- catalytic reduction system requires a reaction between ammonia or urea, nitrogen oxide, and excess oxygen. This reaction needs to take place between 1,600 and 2,000 degrees

F ahrenheit with sufficient retention time; 3) The appropriate temperature profile for the selective non

- catalytic reduction system would have been in the riser duct and calciner portion of the existing Kiln #6 system. However, the use of stage
combustion i n the riser duct and calciner portion of existing Kiln #6 system deliberately reduces the oxygen available to begin and complete the necessary reaction for a selective non

- catalytic reduction system. Therefore, the two technologies compete against each ot her; 4) The staged combustion process produces emissions of incomplete combustion (i.e. high quantities of carbon monoxide). These emissions complete the combustion process when excess air or tertiary air (oxygen) is injected into the system. The excess air is injected at a temperature where the formation of nitrogen oxide emissions would be suppressed. This location occurs at the low temperature range
for the selective non

- catalytic reduction system. However, due to the high quantities of carbon

monoxi de, the additional oxygen generally reacts with the carbon monoxide prior to reacting with the nitrogen oxide and ammonia. In addition, by the time the carbon monoxide emissions are reduced to a point where the nitrogen oxide and ammonia reaction may more readily take place, the temperature in the kiln drops below the 1,600 degree Fahrenheit temperature profile. As such, there was not sufficient retention time in the Kiln #6 system to complete the necessary nitrogen oxide reduction reactions; 5) Since th ere was not an appropriate temperature or retention time window that adequately worked with the staged combustion, a selective non

- catalytic reduction system would have had an unnecessarily high ammonia slip. The ammonia slip would readily react and form particulate matter. At the time, Rapid City was considered an unclassifiable are for particulate matter. Therefore, purposely generating particulate matter without any significant reductions in nitrogen oxide emissions was not considered reasonable; 6) A large calciner system may have had an appropriate location for a selective non

- catalytic reduction system and was also considered during the analysis. However, the larger calciner system was considered not cost effective as BACT for nitrogen oxide; and 7) The nitrogen oxide BACT emission limits at the time associated with a selective non

- catalytic reduction system were greater than required for GCC Dacotah.

In April 2003, a PSD permit was issued to GCC Dacotah for Kiln #6 and BACT for nitrogen oxid e was the installation of staged combustion with a thermal efficient in

- line low

- NOx calciner complimented by a low NOx burner with indirect firing in the kiln.During the 2011 public notice period for the revisions to South Dakota ’ s Regional Haze prog ram, the

National Park Service submitted a comment requesting DENR consider in its reasonable progress analysis the use of a selective non

- catalytic reduction technology for the Kiln #6 at GCC Dacotah as it outlined in its January 2003 comments on GCC Daco tah ’ s Prevention of Significant Deterioration permit. Since a BACT analysis and Best Available Retrofit Technology (BART) review is similar, DENR determined that it was unnecessary to reconsider Kiln #6 for reasonable progress and presented its previous BA CT decision at the hearing for the Regional Haze program.

Based on the information provided by the National Park Service and DENR ’ s testimony during the Regional Haze program public hearing, the Board of Minerals and Environment did not require an
addi tional reasonable progress analysis for Kiln #6.