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 

 Show Details 

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 

you. 

Please take a few minutes to comment on the quality of service you 

received. Simply click on this link to the DEP Customer Survey. Thank you 

in advance for completing the survey. 

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 

Director 
Manufacturing 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 carbon 
injection 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 corrective 
action 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.