GCC info

Rick.Boddicker to

:

Gail Fallon 

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

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

History:

This message has been replied to and forwarded.

Gail, here’s some info from Kyrik on Kiln #6.

Let me know if you need anything else.

Rick
In 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 

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. 

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 burner, 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 

Fahrenheit 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 in 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 other;

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 

monoxide, 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 there 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 oxide 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 program, 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 Dacotah’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 BACT 

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 

additional reasonable progress analysis for Kiln #6.