RE: Dust shuttling to reduce Hg emissions Linero, Alvaro

to: Bohan, Richard
09/07/2009 09:07 PM

Cc: tomm, ccohrs, jimmy.rabon, SauerG, DCrowley, rrogers
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Mr. Rick Bohan,
Portland Cement Association Manufacturing Committee

Hi Rick:

Attached is a copy of the Florida DEP comments to the EPA.

Please have a look at just Section V regarding the dust shuttling option.

The 5 minutes it takes will be worth it.

We hired a cement expert to look at the matter for us.

His report is attached and we also got advice from overseas.

Note that the PCA economic forecast of the impact of the Hg rule indicating closures and shortfalls in production is based on the following assumption.

"Technology assumptions were made regarding the effectiveness of various mercury emission control systems, include activated carbon injection (ACI), wet scrubbers, and baghouse/ESP systems. No other systems or technology measures are considered in the context of this analysis."

Reference Page 8:http://www.cement.org/econ/pdf/Cement%20Consumption%20Outlookmercuryfinal. pdf

To many operators, the dust shuttling option doesn't look appealing. But when they see the projected cost of an ACI system with additional baghouse or a wet scrubber things will look a lot different.

When real world money is on the table, operators will really seek to get the opinions of their best technical people or consultants instead of legal or industry positions.

In fact the dust shuttling option would do at least as well as the $5,000,000/million ton capacity upgrades described in the above reference to use carbon within existing baghouse or ESPs (assumed at 25% by the reference).(Except for a very few operators) the $20,000,000/million ton capacity

ACI plus additional baghouse or the wet scrubbers described in the reference would be the last considerations and not early ones.

Once the closures were predicted, it was probably time to go back and
look at the other control techniques.

The Lehigh Union Bridge dust shuttling case proves this.

Yes they might need to add ACI after they do the dust shuttling.

But they recently started using sewage sludge with much greater Hg

content than their standard coal fuel so they need to abate those Hg increases.

It may turn out that lime will do the job if their Hg is largely
oxidized.

I'm sure an operator or from Florida (I copied them all) will call me to let me know if I'm way off base.

Sincerely,

Al Linero.

The Department of Environmental Protection values your feedback as a customer. DEP Secretary Michael W. Sole is committed to continuously assessing and improving the level and quality of services provided to

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From: Bohan, Richard [mailto:rbohan@cement.org]
Sent: Thu 8/13/2009 4:27 PM To: Linero, Alvaro

Cc: Subject: RE: Dust shuttling to reduce Hg emissions

Al,

Thank you for your note. I will be contacting Lehigh to see if they are willing to share this information.

Best regards,

Rick

Rick Bohan, PE, FACI
DirectorManufacturing Technology

847-972-9038

From: Linero, Alvaro [mailto:Alvaro.Linero@dep.state.fl.us] Sent: Wednesday, August 12, 2009 9:17 AM To: Bohan, Richard Cc: agee@htcnam.com; Matz, Tim; senior@reaction-eng.com; RSchrei45@aol.com; fran.streitman@ashgrove.com; Sullivan, Edward; tsirigotis.peter@epa.gov Subject: Dust shuttling to reduce Hg emissions

Richard Bohan PCA Manufacturing Committee
Hello Richard. Read below a very important news release about Lehigh, Union Bridge. It confirms that movement of some baghouse dust (as an inorganic process addition) to product actually does reduce Hg emissions significantly (for at least some kilns). Might be worth your while to have Lehigh tell your manufacturing committee about it (if they will). So far, we’ve seen IEEE/PCA presentations suggesting this will not work well (Paone IEEE-2008 and Schreiber IEEE-2009) based strictly on unproven models.

But the real world says differently. And it will work even better when they incorporate some temperature control. The approach by Lehigh suggests that the future capacity sag claimed in

Ed Sullivan’s cement outlook presentation (due to Hg rule) does not have to become reality. Sincerely, Al Linero.

Maryland Cement Plant Agrees to Comply Early With Mercury Limits Proposed by EPA. ANNAPOLIS, Md.—The Lehigh Cement Co. has entered into a voluntary agreement with Maryland officials to reduce mercury emissions at its portland cement plant to levels that would meet an Environmental Protection Agency proposed standard one year earlier than its 2013 compliance date. Under the Aug. 6 agreement with the Maryland Department of the Environment, Lehigh Cement has committed to reducing mercury emissions from its Union Bridge, Md., plant by approximately 80 percent—from nearly 400 pounds per year to 86 pounds per year—no later than Sept. 30, 2012. The reduction in emissions is roughly the same that would be required under EPA's first-time proposal to establish mercury emissions limits for existing portland cement kilns (116 DEN A-3, 6/19/09). The Union Bridge cement plant is about 45 miles Northeast of Baltimore. Plant manager Kent Martin told BNA the company is “excited about the technologies we're looking at to reduce mercury emissions.” Martin said Lehigh already has implemented a baghouse dust inter-grinding system that encapsulates mercury in concrete. “With this, we think we can reduce mercury emissions by 30 percent to 40 percent,” he said. Plant Will Use Activated Carbon Injection For the longer term, Martin said, “we believe the solution for our plant is activated carboninjection technology” in which mercury is captured on activated carbon. “We feel this could reduce mercury emissions by as much as 80 percent,”

he said. Lehigh Cement will embark this month on a testing and product sampling program costing “a couple hundred thousand dollars” to evaluate activated carbon injection at the plant, Martin said. “We are very confident that the combination of these two technologies”—baghouse dust inter-grinding and activated carbon injection—“will be successful in reducing our emissions to EPA's proposed levels one year earlier than 2013,” Martin told BNA. Under the voluntary pact, Lehigh Cement's Union Bridge plant will report to MDE in early 2010 on the results of its evaluation of activated carbon injection. By March 30, 2012, the company must install and begin operating such a system, and it must comply with EPA's proposed emission limits by Sept. 30, 2012. Pact Offsets Burning of Biosolids Martin explained that the agreement for early mercury emissions reductions evolved from Lehigh Cement's request for authority to burn treated dried sewage sludge, or biosolids, as an alternative to coal in the Union Bridge plant's fuel mix. “Because biosolids have such a high mercury content, we worked with MDE

on an agreement to offset the mercury emissions associated with burning biosolids,” he said. Shortly after the voluntary agreement was executed, the company's Union Bridge plant received authorization for the burning of class A dried
biosolids. According to Environmental Integrity Project, Lehigh Cement's Union Bridge cement plant is Maryland's second-highest emitter of mercury, behind Constellation Energy's Brandon Shores power generating plant. EIP praised the agreement between MDE and Lehigh Cement but said the plant's permits “should be amended to reflect this agreement, and to require continuous monitoring of mercury emissions to make sure that pollution controls are working as intended.” Power Plant Emission Cuts Anticipated MDE describes mercury is a highly toxic metal that bioaccumulates in fish and poses a health risk from consumption. MDE secretary Shari T. Wilson said in a statement that “reducing mercury in our environment is important to protect the health of all Marylanders. Ten species of fish are subject to mercury consumption advisories in our state, so we must take every step we can to address
this situation.” Noting that Maryland's Healthy Air Act requires coal-fired power plants

to begin reducing mercury emissions in January 2010, MDE's statement said

the Lehigh Cement agreement and the power plant requirements “will reduce Maryland's annual statewide emissions of mercury from nearly 2,500 pounds to approximately 600 pounds.” Particulate Matter Violations Also Settled in a separate agreement with MDE involving particulate matter emissions, Lehigh Cement's Union Bridge plant also entered into a consent agreement that imposes a $202,500 penalty for past violations of emission limits and requires correctiveaction to prevent excess emissions in the future. MDE filed both a complaint and a consent decree regarding particulate matter emissions Aug. 5 in Maryland Circuit Court. No case number had

been assigned as of Aug. 11. According to MDE, the consent decree will take effect when entered by the court. The complaint alleged that, between April 2007 and July 2007, Lehigh Cement exceeded particulate matter emission limits for its cement kiln and clinker cooler stacks. In addition to the fine, the consent decree mandates more frequent stack testing and weekly inspections of pollution control equipment.