SOUTH DAKOTA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES 

## STATEMENT OF BASIS

PREVENTION OF SIGNIFICANT DETERIORATION

PRECONSTRUCTION PERMIT

GCC DACOTAH

PORTLAND CEMENT PRODUCTION FACILITY

RAPID CITY, SOUTH DAKOTATABLE OF CONTENTS

Page

SOUTH DAKOTA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES 1.0 Background 1

2.0 Proposed Operation 2

3.0 Emission Factors 7

4.0 Prevention of Significant Det erioration (PSD) Permit Review 11

4.1 Best Available Control T echnology (BACT) Analysis 13

4.1.1 PM and PM10 14

4.1.1-1 Identifying Options 14 4.1.1-2 Technical Feasibility 17 4.1.1-3 Top-Down Approach 17 4.1.1-4 BACT Determination for PM 18

4.1.2 Sulfur Dioxide 18

4.1.2-1 Identifying Options 18 4.1.2-2 Technical Feasibility 18 4.1.2-3 Top-Down Approach 19 4.1.2-4 BACT Determination for SO2 19

4.1.3 Nitrogen Oxide 20

4.1.3-1 Identifying Options 20 4.1.3-2 Technical Feasibility 20 4.1.3-3 Top-Down Approach 23 4.1.3-4 BACT Determination for NOx 24

4.1.4 Carbon Monoxide 24

4.1.4-1 Identifying Options 24 4.1.4-2 Technical Feasibility 25 4.1.4-3 Top-Down Approach 25 4.1.4-4 Department’s BACT Determination for CO 26

4.2 BACT Limits 26

4.2.1 BACT Limits for Particulate 26 4.2.2 BACT Limits for Sulfur Dioxide 26 4.2.3 BACT Limits for Nitrogen Oxide 27 4.2.4 BACT Limits for Carbon Monoxide 28TABLE OF CONTENTS

Page

SOUTH DAKOTA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES 4.3 Air Quality Analysis 28

4.3.1 De Minimis Monitoring Levels 31 4.3.2 National Ambient Air Quality Standards 31 4.3.3 Increment Consumption 33 4.3.4 Class I Area Impacts 36

4.3.4-1 Class I Significant Impact Levels 36 4.3.4-2 Visibility 37

4.4 Other Impacts 41

4.4.1 Commercial, Residential, and Industrial Growth 41 4.4.2 Soils and Vegetation 41

4.5 Summary of PSD Requirements 42

4.5.1 Particulate Matter 42 4.5.2 Sulfur Dioxide, Nitrogen Oxide and Carbon Monoxide 42

4.5.2-1 Sulfur Dioxide 42 4.5.2-2 Nitrogen Oxide 44 4.5.2-3 Carbon Monoxide 45

4.6 New Source Performance Standards 25

4.6.1 40 CFR Part 60 Subpart F – Standard of Performance for Portland Cement Plants 46 4.6.2 40 CFR Part 60 Subpart Y – Standards of Performance for Coal Preparation Plants 46 4.6.3 40 CFR Part 60 Subpart OOO – Standards of Performance for Non-Metallic Mineral Processing Plants 46

4.7 National Emission Standards for Hazardous Air Pollutants 47

4.7.1 40 CFR Part 63 Subpart LLL – National Emission Standards for Hazardous Air Pollutants for Portland Cement Manufacturing Industry 47

4.8 Title V Permit 47

5.0 Recommendation 47LIST OF TABLES

Tables Page

SOUTH DAKOTA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES 1 Description of Units, Operations and Processes Impacted by Kiln #6 Upgrade 3 2 Description of Fugitive Dust So urces Impacted by Kiln # 6 Upgrade 6 3 Particulate Emission Ra tes and Proposed Limits 8 4 Sulfur Dioxide Emission Rates 10 5 Nitrogen Oxide Emission Rates 10 6 Carbon Monoxide Emission Rates 10 7 Volatile Organic Compound Emission Rates 11 8 Regulated Air Pollutants Sign ificant Emission Comparison 12 9 Control Device for Fugitive Dust Sources Impacted by Kiln #6 Upgrade 14 10 Project Modeled Parameters 29 11 Modeled Emission Rates 29 12 Highest Modeled Ambient Air Quality Impact from Project 30 13 Prevention of Significant Deterioratio n Class II Significant Impact Levels 32 14 National Ambient Air Quality Standards 33 15 Modeled SO2 Increment Increase 34 16 Modeled NOx Increment Increase 35 17 Increment Consumption 35 18 Class I Significant Impact Level Analysis 36 19 Class I Increment Consumption 37 20 Badlands Visitation Records 39 21 Visibility Impairment Conditions 39 22 Relativity Humidity 40 23 Sulfur Dioxide BACT Emissi on Limit for Kiln System 42 24 Nitrogen Oxide BACT Emi ssion Limit for Kiln System 44 25 Carbon Monoxide BACT Emission Limit for Kiln System 45LIST OF APPENDICES

Appendix

SOUTH DAKOTA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES A Potential Criteria Air Emission Factor Determination B Criteria Pollutant Calculations C Visibility Report to CongressPage 1 

### 1.0 BACKGROUND

On June 14, 1993, Dacotah Cement submitted an app lication to renew its air quality permit for a limestone quarry and portland cement plant in Rapid City, South Dakota. Dacotah Cement is a state owned facility that quarried limestone, sa nd, and gypsum in the surrounding area to provide raw materials for its portland cement plant. Ot her raw materials such as iron and shale are shipped in by truck from other areas. Coal is used as the heat source and is shipped in by railcar. The limestone is processed through two crushers a nd screens before conveyor belts transfer it to a raw material storage shed. Conveyors transfer the raw material to one of two mills. One mill grinds the raw material for two wet kiln processes and the other mill grinds material for a dry kiln process. The ground material is temporarily stored in two silo s before it is transferred to the kilns. The dry kiln process is capable of r eceiving ground material directly from the Fuller Loesche mill. The dry kiln process includes a preheater and a precalcinator. The three kilns produce clinker, which is conveyed to a clinker stor age shed. The clinker is then sent to one of seven finish mills where gypsum is added to produce cement. The cement is pneumatically transferred to cement storage silos before it is either bagged or bulk loaded in trucks and railcars.

Dacotah Cement requested an alte rnative operating scenario be pl aced in its permit that would allow Dacotah Cement to upgrade kiln #6 by in creasing the cement clinker production capacity from 1,650 tons per day to 2,250 tons per day. On November 19, 1993, Dacotah Cement submitted additional information and proposed the inst allation of an indirect coal firing system.

On May 13, 1994, the Department of Environment a nd Natural Resources (department) issued an air quality permit to Dacotah Cement. The perm it required Dacotah Cement to submit general specifications and application forms for the kiln #6 upgrade and indirect co al firing system. On June 23, 1994, Dacotah Cement submitted the genera l specifications and application forms for the kiln #6 upgrade as required by the existing air qual ity permit. The application included the modification to kiln #6, kiln feed system, dry pr ocess clinker cooler, the pre-heater tower, and the installation of a precalcinator. The applica tion identified expected air emission increases, dispersion modeling results, and proposed particul ate emission offsets as required. Based on the information in the application, the department agreed that Dacotah Cement’s kiln #6 upgrade was not considered a major modification under the Prevention of Significant Deterioration (PSD)
program.
On January 4, 1995, Dacotah Cement notified the de partment that kiln #6 would be shutdown on January 14, 1995, to initiate the upgrade. Dacota h Cement experienced operational problems after the upgrade was completed and the departme nt approved Dacotah Cement’s requests to delay stack testing until November 1996. In the process of being purchased by another company it was discovered that the kiln #6 upgrade shoul d have been considered a major modification under the PSD program based on the results of th e stack tests in November 1996. On December 27, 2000, the department issued a notice of viol ation and both parties signed a settlement agreement. On February 26, 2001, Dacotah Cement submitted an approved compliance plan.

On March 16, 2001, GCC Dacotah bought the lime stone quarry and portland cement plant and took over responsibility for fulfilling the settl ement agreement and compliance plan. GCC Dacotah submitted a PSD permit application for particulate on November 16, 2001. On JanuaryPage 2 17, 2002, GCC Dacotah submitted a PSD permit a pplication for nitrogen oxide and carbon monoxide. The applications were considered incomplete because the applications did not contain all of the maximum process rates, proces s descriptions did not agree with the existing permit and stack tests, the appli cation did not contain a detailed economic analysis, etc. GCC Dacotah submitted the additional information and the department considered the application complete on May 8, 2002.

Based on the review of the application, th e department concluded the kiln #6 upgrade was also applicable to a PSD review for sulfur dioxi de. At a June 18, 2002, meeting, the department requested GCC Dacotah reexamine the sulfur di oxide emissions and submit a PSD application for sulfur dioxide. In a letter dated June 28, 2002, GCC Dacotah confirmed the department’s conclusion that a PSD review for sulfur di oxide was required. On September 5, 2002, GCC Dacotah submitted the sulfur dioxide PSD permit a pplication. The department considered the proposed sulfur dioxide emission limits t oo high. On September 10 and 25, 2002, the department requested additional information to determine the correct sulfur dioxide emission limits. GCC Dacotah submitted the required information and the department considered the application complete on December 18, 2002.



### 2.0 PROPOSED OPERATIONS

The kiln #6 upgrade increased the clinker production capacity of kiln #6, de-bottlenecked existing material transfer systems and added a precal cinator. The kiln is fueled by coal to create the heat necessary to complete the process of converting the raw material into clinker. The amount of coal or heat that is required is referre d to as fuel input. The existing operations have approximately 90 percent of the co al burned in the kiln and the remaining 10 percent burned in the new precalcinator. GCC Dacotah’s PSD application proposed the following:

1. Eight new baghouses at additiona l material handling points to control particulate emissions; 2. Proposed to upgrade the precalcinator so it produ ces 35 percent of the total fuel input; and 3. Identified existing air emission points that were not permitted under the existing Title V air quality permit and impacted by the kiln #6 upgrade.

Table #1 identifies the processes and equipment th at were impacted by th e kiln #6 upgrade and will be consider under this PSD review. In a ddition, Table #1 notes if the control device is existing, proposed, and/or previously permitte d. Table #2 identifies fugitive dust sources impacted by the kiln #6 upgrade and identifies fugitive dust control techniques listed by GCC Dacotah in the permit application.Page 3Table #1Description of Units, Operations, andProcesses Impacted by Kiln #6 UpgradeMaximumControl DeviceUnitDescription of ProcessOperating RateDescriptionStatusPermitted1 EDC101Primary and secondary crushers 1,000 tons per hour Baghouse Existing Permitted2 EDC102Screen 1,000 tons perhour Baghouse Existing Permitted9 EDC619Loesche mill and rotary kiln #6 2,250 tons clinker per dayPreheater,Precalcinator, andBaghouseExisting Permitted6 EDC652Raw material storage building totwo kilnfeed storage silos180 tons per hourBaghouse Existing Permitted6a EDC501Rock silo to Loesche mill 180 tons per hour Baghouse Existing Not Permitted6b EDC602Kiln feed storage silo to kiln #6 160tons per hour Baghouse Existing Not Permitted7b EDC710Clinker shed to finish mills 500 tonsper hour Baghouse Existing Not Permitted7c EDC706Raw shed to Loesche mill 40 tons per hour 2001 Fuller baghouse Proposed Not Permitted7d EDC701Raw material transferred from beltconveyor 107 to belt conveyor 108800 tons per hour 2001 Fuller baghouse Proposed Not Permitted10 EDC615Dry process clinker cooler 2,250 tonsclinker per day Baghouse Existing Permitted7e EDC705Gypsum raw shed to old clinker building 350 tonsper hour 2001 Fuller baghouse Proposed Not Permitted7f EDC703Raw shed to Loesche mill 40 tons per hour 2001 Fuller baghouse Proposed Not Permitted7g EDC704Gypsum raw shed to old clinker building 350 tonsper hour 2001 Fuller baghouse Proposed Not Permitted8 EDC614Penthouse storage #2 (north) 2,250 tons clinker per day Baghouse Existing Permitted8a EDC627Penthouse storage #2 (north) 2,250 tons clinker per day Baghouse Existing Not Permitted8b EDC613Penthouse storage #2 (north) 2,250 tons clinker per day Baghouse Existing Not Permitted8c EDC707Rock silo discharge 1,000 tons per hour2001 Fuller baghouse Proposed Not Permitted11 EDC623Alkali bypass and alkali waste to waste bintransfer system2,250 tons clinker per day Baghouse Existing Permitted12 EDC731Finish mill #3 35 tons perhour Baghouse Existing PermittedPage 4MaximumControl DeviceUnitDescription of ProcessOperating RateDescriptionStatusPermitted13 EDC741Finish mill #4 40 tons per hour Baghouse Existing Permitted14 EDC751Finish mill #5 45 tons per hour Baghouse Existing Permitted15 EDC761Finish mill #6 45 tons per hour Baghouse Existing Permitted16 EDC771Finish mill #7 (mill sweep) 85 tonsper hour Baghouse Existing Permitted16a EDC772Finish mill #7 (mill separator) 85 tonsper hour Baghouse Existing Not Permitted16b EDC708Finish mill #7 (transfer) 500 tons per hour Baghouse Existing Not Permitted16c EDC709Finish mill #7 (transfer) 500 tons per hour Baghouse Existing Not Permitted16d EDC713Clinker transfer system 500 tons perhour 2001 BHA baghouse Proposed Not Permitted17 EDC804Bulk storage silos 125 tons per hour Baghouse Existing Permitted18 EDC821Bulk storage silos 125 tons per hour Baghouse Existing Permitted19 EDC805Bulk storage silos 125 tons per hour Baghouse Existing Permitted20 EDC832Bulk storage silos 125 tons per hour Baghouse Existing Permitted21 EDC824Bulk storage silos 200 tons per hour Baghouse Existing Permitted24 EDC827Rail storage silos 125 tons per hour Baghouse Existing Permitted25 EDC828Rail storage silos 125 tons per hour Baghouse Existing Permitted26 EDC834Rail storage silos 125 tons per hour Baghouse Existing Permitted27 EDC853Bulk rail loadouts 500 tons per hour Baghouse Existing Permitted28 EDC854Bulk rail loadouts 500 tons per hour Baghouse Existing Permitted35 EDC825East bulk truck loadout 500 tons per hour Baghouse Existing Permitted36 EDC826West bulk truck loadout 500 tonsper hour Baghouse Existing Permitted37 EDC801Cement bagging 114 tons perhour Baghouse Existing Permitted38 EDC802Cement bagging 114 tons perhour Baghouse Existing Permitted39 EDC803Cement bagging 114 tons perhour Baghouse Existing Permitted41ECD628EDC6291995 ABB Raymond coal mill20 tons coal per hour5.3 MMBtus per hourSingle stage cyclonefollowed by twoExisting Not PermittedPage 5MaximumControl DeviceUnitDescription of ProcessOperating RateDescriptionStatusPermittedheat inputbaghouses operated inparallel41b EDC274Coal stacker top 400 tons per hour Baghouse Existing Not Permitted41c EDC275Coal surge bin top 400 tons per hour Baghouse Existing Not Permitted41d EDC702Coal tunnel to coal stacker 400 tons per hour New baghouse Proposed Not Permitted41e EDC276Coal surge bin top 400 tons per hour Baghouse Existing Not Permitted41f EDC277Coal transfer 400 tons per hour Baghouse Existing Not Permitted41i EDC278Coal bin #6 400 tons per hour Baghouse Existing Not Permitted41j EDC630Coal dryer – FK pump 20 tons per hour Baghouse Existing Not Permitted62bEDC272EDC273Coal – hopper to conveyor 400 tons per hourTwo baghousesoperated in parallelExisting Not PermittedPage 6 Table #2 Description of Fugitive Dust Sources Impacted by Kiln #6 Upgrade

Unit Description of Process Control Techniques

42 Topsoil removal (bulldozer) None
43 Drilling Drilling rig dust collector
79b Shale crusher Partially enclosed / Wet suppression
80 Disturbed area None
45 Quarried limestone: front-end loader to truck Quarry below grade
46 Sand: front-end loader to truck (100% is loaded at the pit) None

46a Sand: front-end loader to truck (10% of total sand delivery from pit is stored prior to the process) None

47 Shale: pile to truck None
49 Gypsum: quarry to truck None
49a Gypsum: pile to truck None
50 Crushed limestone: raw shed to truck by front-end loader Partially enclosed
50a Crushed limestone (crusher back-up) : pile to truck (to process) None
50b Crushed limestone: conveyor to screen Enclosed
50c Crushed limestone: conveyor to raw shed Enclosed
51 Strip dirt from limestone quarry area None
52a Alkali/Kiln dry waste ash: bin to truck Wet suppression
53 Quarried limestone: truck to crusher Partially enclosed

54 Sand: truck to semi-enclosed sh ed (90% from offsite delivery and 10% from storage pile) Partially enclosed

54a Sand: truck to pile (10% fr om offsite delivery) None
55 Shale: FE loader from quarry to crusher None
55a Shale: truck to shed (100%) Partially enclosed
55b Shale: stacker to pile None
56 Iron ore: truck to pile None
56a Iron ore: front-end loader to shed Partially enclosed
57 Gypsum: truck to pile None
57a Gypsum: truck to crusher Partially enclosed / Wet suppression
57b Gypsum: conveyor to gypsum storage shed Partially enclosed
58 Crushed limestone (crusher b ack-up): truck to pile None
58a Crushed limestone: truck to raw shed Partially enclosed
62 Coal: truck to pile (10% of coal hauled on site for kiln #6) None

62a Coal: Truck/Front-end loader to hopper (90% of coal hauled on site for kiln #6) Partially enclosed

63 Unloading strip dirt from truck NonePage 7 Unit Description of Process Control Techniques
64a Alkali/Kiln dry waste ash truck to quarry Below grade
79 Shale pile/quarry Below grade
79a Shale pile at the quarry None
82 Crushed limestone pile None
83 Sand pile None
84 Sand pit Below grade
84a Sand pit 2 Below grade
85 Iron ore pile None
86 Coal pile Berm on north and west side
87 Gypsum pile/quarry Below grade
87a Gypsum pile None
87b Gypsum storage shed Covered and next to building
87c Gypsum muck pile None
91 Alkali waste to quarry (paved) Wet sweeper and wash roads
92 Sand hauling road (paved) Wet sweeper and wash roads
93 Shale hauling road (paved) Wet sweeper and wash roads
94 Iron ore hauling road (paved) Wet sweeper and wash roads
95 Gypsum hauling road (paved) Wet sweeper and wash roads
96 Coal hauling road (paved) Wet sweeper and wash roads
97 Transporting product out (paved) Wet sweeper and wash roads
99 Alkali waste to quarry (unpaved) Treat with dust suppressant
101 Quarried limestone to crusher traffic (unpaved) Treat with dust suppressant



### 3.0 EMISSION FACTORS

Trinity Consultants (Trinity) prepared GCC Dacotah’s PSD pe rmit application. The emission rates and proposed limits listed in this section were derived fr om the application, FL Smidth performance data, the state’s air emissi on inventory data, a nd EPA’s AP-42 and “ Uncontrolled Emission Factor Listing for Criteria Air Pollutants ,” documents.

Tables #3 through #7 contain the emission factors for the equipment and operations impacted by the kiln #6 upgrade prior to the upgrade a nd GCC Dacotah’s proposed emission limit where applicable. Appendix A provides details on how and where the emission factors were derived.

There are slight differences be tween some of the emission rate s listed in Tables #3 through #7 and the emission rates listed in GCC Dacotah’s PSD permit application. Trinity used calendar years for 1992 and 1993 to derive the emission ra tes prior to the upgrad e. The department reviewed the data and believes emission rate s based on calendar years 1993 and 1994, are morePage 8 representative of the prior opera tions. Therefore, the annual em ission rates prior to the upgrade in Tables #3 through #7 are based on calendar years 1993 and 1994 data.

Trinity originally determined particulate emi ssions from the material handling equipment for particulate based on annual emi ssion inventories provided by th e department. The material handling equipment handles the raw materials for kilns #4, #5 and #6. The only particulate emissions increases subject to a PSD review are the ones attri buted to the kiln #6 upgrade. Trinity did not subtract the particulate emissions attributed to kilns #4 and #5 when determining actual emissions before the kiln #6 upgrade. The department required Trinity to convert the grain loading emission factors to a pound per ton of ma terial processed to determine the emission increases attributed to the kiln #6 upgrade. Tr inity reviewed the depart ment’s information and submitted an addendum to the PSD permit a pplication in September 2002. The revised particulate calculations may be observed in Appe ndix B. The revised particulate emission rates are reflected in the “Summary of Annual Pa rticulate Emission Rates” section of Table #3.

Table #3 Particulate Emission Rates and Proposed Limits

Unit Emission Rates Unit Emission Rates Prior to Upgrade 1 Proposed Limit 3 Prior to and After Upgrade 2

Point Sources Fugitive Sources

1 0.00131 pounds/ton 0.01 grains/dscf 42 0.62 pounds/hour

2 0.00031 pounds/ton 0.01 grains/dscf 43 0.16 pounds/blasts

6 0.005 pounds/ton 0.01 grains/dscf 79b 0.0007 pounds/ton

6a 0.005 pounds/ton 0.01 grains/dscf 80 0.12 pounds/acres

6b 0.005 pounds/ton 0.01 grains/dscf 45 0.00192 pounds/ton

7b 0.005 pounds/ton 0.01 grains/dscf 46 0.00029 pounds/ton

7c 0.053 pounds/ton 0.01 grains/dscf 46a 0.00029 pounds/ton

7d 0.053 pounds/ton 0.01 grains/dscf 47 0.00012 pounds/ton

7e 0.053 pounds/ton 0.01 grains/dscf 49 0.0141 pounds/ton

7f 0.053 pounds/ton 0.01 grains/dscf 49a 0.0141 pounds/ton
7g 0.053 pounds/ton 0.01 grains/dscf 50 0.00192 pounds/ton

8 0.005 pounds/ton 0.01 grains/dscf 50a 0.00192 pounds/ton

8a 0.005 pounds/ton 0.01 grains/dscf 50b 0.00192 pounds/ton

8b 0.005 pounds/ton 0.01 grains/dscf 50c 0.00192 pounds/ton

8c 0.053 pounds/ton 0.01 grains/dscf 51 0.00026 pounds/ton

9 4 9.07 / 9.15 pounds/hour 0.01 grains/dscf 52a 0.566 pounds/ton

10 5.56 pounds/hour 0.01 grains/dscf 53 0.00192 pounds/ton

11 0.85 pounds/hour 0.01 grains/dscf 54 0.00029 pounds/ton

12 0.002 pounds/ton 0.01 grains/dscf 54a 0.00029 pounds/ton

13 0.002 pounds/ton 0.01 grains/dscf 55 0.00012 pounds/tonPage 9 Unit Emission Rates Unit Emission Rates Prior to Upgrade 1 Proposed Limit 3 Prior to and After Upgrade 2

Point Sources Fugitive Sources

14 0.002 pounds/ton 0.01 grains/dscf 55a 0.00012 pounds/ton

15 0.002 pounds/ton 0.01 grains/dscf 55b 0.00012 pounds/ton

16 0.001 pounds/ton 0.01 grains/dscf 56 0.00129 pounds/ton

16a 0.001 pounds/ton 0.01 grains/dscf 56a 0.00129 pounds/ton

16b 0.005 pounds/ton 0.01 grains/dscf 57 0.0141 pounds/ton

16c 0.005 pounds/ton 0.01 grains/dscf 57a 0.0141 pounds/ton

16d 0.053 pounds/ton 0.01 grains/dscf 57b 0.0141 pounds/ton

17 0.014 pounds/ton 0.01 grains/dscf 58 0.00192 pounds/ton

18 0.014 pounds/ton 0.01 grains/dscf 58a 0.00192 pounds/ton

19 0.014 pounds/ton 0.01 grains/dscf 62 0.00006 pounds/ton

20 0.014 pounds/ton 0.01 grains/dscf 62a 0.00006 pounds/ton

21 0.014 pounds/ton 0.01 grains/dscf 63 0.00026 pounds/ton

24 0.014 pounds/ton 0.01 grains/dscf 64a 0.566 pounds/ton

25 0.014 pounds/ton 0.01 grains/dscf 79 0.13 pounds/acres

26 0.014 pounds/ton 0.01 grains/dscf 79a 0.13 pounds/acres

27 0.014 pounds/ton 0.01 grains/dscf 82 0.86 pounds/acres

28 0.006 pounds/ton 0.01 grains/dscf 83 0.27 pounds/acres

35 0.006 pounds/ton 0.01 grains/dscf 84 0.27 pounds/acres

36 0.006 pounds/ton 0.01 grains/dscf 84a 0.27 pounds/acres

37 0.006 pounds/ton 0.01 grains/dscf 85 0.95 pounds/acres

38 0.006 pounds/ton 0.01 grains/dscf 86 0.65 pounds/acres

39 0.006 pounds/ton 0.01 grains/dscf 87 0.38 pounds/acres

41 Did not exist 0.01 grains/dscf 87a 0.38 pounds/acres

41b 0.005 pounds/ton 0.01 grains/dscf 87b 0.51 pounds/acres

41c 0.005 pounds/ton 0.01 grains/dscf 87c 0.24 pounds/acres

41d 0.053 pounds/ton 0.01 grains/dscf 91 2.83 pounds/mile

41e 0.005 pounds/ton 0.01 grains/dscf 92 0.74 pounds/mile

41f 0.005 pounds/ton 0.01 grains/dscf 93 0.80 pounds/mile

41i 0.005 pounds/ton 0.01 grains/dscf 41j 0.005 pounds/ton 0.01 grains/dscf
62b 0.005 pounds/ton 0.01 grains/dscf Summary of Annual Particulate Emission Rates Prior to Upgrade Application 162 tons per year 197 tons per yearPage 10 1 - The emission factors takes into account control equipment

. 2 - The emission factors are for uncontrolled operations.
3 - The proposed limits are based on manufacturer’s guarantees and the BACT review (dscf – dry standard cubic foot).
4 - The two emission factors are for when the raw mill is on and when the raw mill is off, respectively.

Table #4 Sulfur Dioxide Emission Rates

Annual Emission Rates
Unit Prior to Upgrade Proposed Limit

9 454 tons per year 685 tons per year
11 44 tons per year 82 tons per year
41 Did not Exist 273 tons per year Combined Emissions 498 tons per year 1 1,040 tons per year

1 DENR has developed emissions prior to the upg rade from historical data. The developed emissions are higher than those noted in the appl ication. For this review, the above emissions would result in a worse case approach.

Table #5 Nitrogen Oxide Emission Rates

Annual Emission Rates
Unit Prior to Upgrade Proposed Limit

9 1,125 tons/year 1,718 tons/year
11 70 tons/year 103 tons/year
41 Did not Exist 518 tons/year Combined Emissions 1,195 tons per year 2,339 tons per year

Table #6 Carbon Monoxide Emission Rates

Annual Emission Rates
Unit Prior to Upgrade Proposed Limit

9 207 tons/year 1,528 tons/year
11 13 tons/year 92 tons/year
41 Did not Exist 460 tons/year

Combined Emissions 220 tons per year 2,080 tons per yearPage 11 Table #7 Volatile Organic Compound Emission Rates

Annual Emission Rates
Unit Prior to Upgrade After Upgrade 9, 11, and 41 1 38 tons/year 74 tons/year

1 - The emission factor is from AP-42 for a kiln as a wh ole process, which would include the emissions from the main stack, alkali bypass, and coal dryer stack.



### 4.0 PREVENTION OF SIGNIF ICANT DETERIORATION (PSD) PERMIT REVIEW

The PSD regulations are designed to ensure that the air quality in existing attainment areas does not significantly deteriorate or exceed the National Ambient Air Quality Standards (NAAQS) while providing a margin for future industrial and commercial growth. The primary provisions of the PSD regulations require sources to:

1. Apply Best Available Control Technology (BAC T) to minimize air pollutants emitted by the proposed project; 2. Ensure compliance with the NAAQS; 3. Ensure the applicable PSD air qual ity increments are not exceeded; 4. Ensure there are not adverse impacts to Federal Class I areas; and 5. Ensure there are no other impacts.

A PSD review applies to new major stationary so urces and major modifications to existing major stationary sources in areas desi gnated as attainment or unclass ifiable under Section 107 of the Clean Air Act for any criteria po llutant. If the source is considered one of the 28 named PSD source categories listed in Section 169 of the fede ral Clean Air Act, the major source threshold is 100 tons per year of any regulated pollutant. Th e major source threshold for all other sources is 250 tons per year of any regulated pollutant. The following is a list of regulated pollutants emitted by the proposed project:

• Total suspended particulate (PM);

• Particulate with a diameter less th an or equal to 10 microns (PM10);

• Sulfur dioxide (SO2);

• Nitrogen oxides (NOx);

• Carbon monoxide (CO);

• Ozone – measured as volat ile organic compounds (VOCs);

• Lead;

• Fluorides

• Sulfuric acid mist;

• Hydrogen sulfide;

• Reduced sulfur compounds; and

• Total reduced sulfur.Page 12 GCC Dacotah is considered one of the 28 named PSD source categories, therefore, the major source threshold is 100 tons per year. GCC Dacotah’s existing operations have actual emissions of particulate matter, sulfur di oxide, nitrogen oxides, and car bon monoxide greater than 100 tons per year. Therefore, GCC Dacotah is cons idered an existing ma jor source under the PSD program for those pollutants. Once a source is considered major any new construction, reconstruction or modification th at increases potential air emissi ons above significant threshold is subject to a PSD review.

A comparison of the potential air emission increases for the kiln #6 upgrade to the significant emission rates established in 40 CFR § 52.21(b)(23)(i ) was used to determine if a PSD review is required. Table #8 provides the increase of emissi on based on the air emissions prior to the kiln #6 upgrade and the proposed limits (see Tables #3 through #7).

Trinity did not include air emission increases fo r lead, fluorides, sulfuric acid mist, hydrogen sulfide, reduced sulfur compounds and total re duced sulfur. The department used emission factors from EPA’s AP-42, actual operations from calendar year 1993 and 1994, and potential operations after the kiln #6 upgrade to calculate prior emissions and potential emissions for these air pollutants. The results of the department’s evaluation are shown in Table #8. EPA’s AP-42 documentation did not list emission factors for su lfuric acid mist and hydrogen sulfide. Therefore, sulfuric acid mist and hydrogen su lfide emissions are considered negligible.

Table #8 Regulated Air Pollutants Significant Emission Comparison

Proposed Limit

or Potential Emissions After Upgrade Prior
Emissions Increase
of
Emissions Significant
Rate Pollutant

tons/year Tons/year Tons/year tons/year PSD Review

PM 1 235 193 42 25 Yes
PM10 197 162 35 15 Yes
Sulfur Dioxide 885 498 387 40 Yes Nitrogen Oxide 2,339 1,195 1,144 40 Yes Carbon Monoxide 2,080 220 1,860 100 Yes Ozone (measured as VOC) 74 38 36 40 No
Lead 0.03 0.02 0.01 0.6 No
Fluorides 0.38 0.2 0.18 3 No Sulfuric Acid Mist Negligible Negligible Negligible 7 No Hydrogen Sulfide Negligible Negligible Negligible 10 No Reduced Sulfur Compounds 8.71 4.47 4.24 10 No
Total Reduced Sulfur 8.71 4.47 4.24 10 NoPage 13 1 - PM10 emissions are estimated at 84 percent of total particulate emissions for sources not controlled by a baghouse. PM10 and PM emissions are assumed to be equivalent when exiting a baghouse. To simplify the calculations, the PM10 total was divided by 0.84 to obtain the PM total.

A PSD review is required for particulate, su lfur dioxide, nitrogen oxide, and carbon monoxide.

4.1 Best Available Control Technology (BACT) Analysis

In accordance with 40 CFR § 52.21(j), a major modification to a major source shall apply best available control technology (BACT) for each pol lutant subject to regulation under the federal Clean Air Act for which it would result in signi ficant net emissions at the source. Based on Table #8, GCC Dacotah’s kiln #6 up grade had the potential to emit the following air pollutants at or equal to the federal si gnificant emission rates:

1. Total suspended particulate (PM) 2. Particulate equal to or less th an 10 microns in diameter (PM 10 ); 3. Sulfur dioxide (SO2); 4. Nitrogen oxide (NOx); and 5. Carbon monoxide (CO).

BACT is based on the maximum reduction achievab le for each pollutant subject to a regulation under the federal Clean Air Act. The departme nt determines BACT on a case-by-case basis taking into account energy, environmental, and ec onomic impacts, and other costs. BACT is achievable through application of production pr ocesses or available methods, systems, and techniques, including fuel cleaning or treatment or innovative fuel combustion techniques for control of such pollutant. In no case shall application of BACT result in an emission limit for any pollutant that would be gr eater than the emission limit allo wed by any applicable standard under 40 CFR Parts 60 and 61.

The BACT analysis is based on four steps. The fi rst step consists of the applicant identifying all available control options for the pollutant unde r consideration (Identi fying Options). The department reviews these options to ensure all available control op tions are considered.

In the second step the applicant evaluates the t echnical feasibility of th e various control options in relationship to the specific unit under consideration (Technical Feasibility). The department reviews the technical feasibility provided by the applicant to determ ine if it is accurate.

In the third step the remaining control options are reviewed in a top- down approach (Top-Down Approach). A top-down approach means the best c ontrol measures will be evaluated first and if they are not feasible, the next best control measur e will be evaluated. In this step the applicant lists the control efficiency, the expected emissi on rate, the expected emission reduction, and the cost, environmental, and energy impacts for each control option. The department reviews the top-down approach provided by the appli cant to determine if it is accurate.

In the fourth step the department evaluates the applicant’s first three steps and determines BACT for the particular pollutant unde r review (BACT Determination).Page 14 4.1.1 PM and PM 10
4.1.1-1 – Identifying Options

GCC Dacotah considered the followi ng options to control PM and PM 10 emissions from point and fugitive sources:

1. Point sources:

a. Fabric filter; b. Electrostatic precipitator; and

c. Wet scrubber. 2. Fugitive sources – see Table #9.

Table #9 Control Devices for Fugitive Dust Sources Impacted by Kiln #6 Upgrade

Unit Description of Process Control Device Natural Events Action Plan Requirements
42 Topsoil removal (bulldozer) None None
43 Drilling Drilling rig dust collector None

79b Shale crusher Partially enclosed / wet suppression Enclosure 1

80 Disturbed area None None

45 Quarried limestone: front-end loader to truck Quarry below grade None

46 Sand: front-end loader to truck (100% is loaded at the pit) None None

46a Sand: front-end loader to truck (10% of total sand delivery from pit is stored prior to the process) None None

47 Shale: front-end loader to truck from pile None None

49 Gypsum: front-end loader to truck at
quarry None None

49a Gypsum: front-end loader to truck from pile None None

50 Crushed limestone: front-end loader to truck from raw shed Partially enclosed None

50a Crushed limestone (crusher backup): front-end loader to truck from pile (to process) None None

50b Crushed limestone: conveyor to

screen Enclosed Enclosure 1Page 15 Unit Description of Process Control Device Natural Events Action Plan Requirements

50c Crushed limestone: conveyor to raw shed Enclosed None

51 Strip dirt from limestone quarry area None

52a Alkali/Kiln dry waste ash: loading truck from bin Wet suppression None

53 Quarried limestone: dumping truck into crusher Enclosed None

54 Sand: dumping truck into shed (90% from offsite delivery and 10% from storage pile) Partially enclosed None

54a Sand: dumping truck onto pile (10% from offsite delivery) None None

55 Shale: front-end loader from quarry to crusher None None

55a Shale: dumping truck into shed (100%) Partially enclosed None

55b Shale: stacker to pile None None
56 Iron ore: dumping truck onto pile None None
56a Iron ore: front-end loader to shed Partially enclosed None
57 Gypsum: dumping truck onto pile None None

57a Gypsum: dumping truck into crusher Partially enclosed / wet suppression Enclosure 1

57b Gypsum: conveyor to gypsum storage shed Partially enclosed None

58 Crushed limestone (crusher backup): dumping truck onto pile None None

58a Crushed limestone: dumping truck into raw shed Partially enclosed None

62 Coal: dumping truck onto pile (10% of coal hauled on site for kiln #6) None None

62a Coal: dumping truck/front-end loader into hopper (90% of coal hauled on site for kiln #6) Partially enclosed None

63 Unloading strip dirt from truck None None

64a Alkali/Kiln dry waste ash: dumping truck into waste pit in quarry Below grade None

79 Shale pile/quarry Below grade Chemical stabilizer, water, or two-sided enclosure 2

79a Shale pile at the quarry None Chemical stabilizer, water, or two-sided enclosure 2Page 16 Unit Description of Process Control Device Natural Events Action Plan Requirements

82 Crushed limestone pile None Chemical stabilizer, water, or two-sided enclosure 2

83 Sand pile None Chemical stabilizer, water, or two-sided enclosure 2

84 Sand pit Below grade None
84a Sand pit 2 Below grade None

85 Iron ore pile None Chemical stabilizer, water, or two-sided enclosure 2

86 Coal pile Berm on north and west side Chemical stabilizer, water, or two-sided enclosure 2

87 Gypsum pile/quarry Below grade Chemical stabilizer, water, or two-sided enclosure 2

87a Gypsum pile None Chemical stabilizer, water, or two-sided enclosure 2

87b Gypsum storage shed Covered and next to building None

87c Gypsum muck pile None Chemical stabilizer, water, or two-sided enclosure 2

91 Alkali waste to quarry (paved) Wet sweeper and wash roads Sweep and water flush or vacuum and water flush

92 Sand hauling road (paved) Wet sweeper and wash roads Sweep and water flush or vacuum and water flush

93 Shale hauling road (paved) Wet sweeper and wash roads Sweep and water flush or vacuum and water flush

94 Iron ore hauling road (paved) Wet sweeper and wash roads Sweep and water flush or vacuum and water flush

95 Gypsum hauling road (paved) Wet sweeper and wash roads Sweep and water flush or vacuum and water flush

96 Coal hauling road (paved) Wet sweeper and wash roads Sweep and water flush or vacuum and water flush

97 Transporting product out (paved) Wet sweeper and wash roads Sweep and water flush or vacuum and water flush

99 Alkali waste to quarry (unpaved) Treat with dust suppressant Chemical stabilizer

101 Quarried limestone to crusher (unpaved) Treat with dust suppressant Chemical stabilzer

1 - Openings must be covered by a curtain or other method to minimize the opening but allow material or equipment
movement. 2 – Open storage pile is defined as a storage pile with a s ilt content of four percent or gr eater, has a height of three feet or more, and a total surface area of 150 square feet or more.Page 17 The department reviewed the control options provided by GCC Dacotah and agrees with the options for the point sources. The department c onsiders the fugitive dust controls listed in the Natural Events Action Plan for Rapid City as the minimal requirements for fugitive dust sources (see Table #9). GCC Dacotah’s proposal meets or exceeds most of the fugitive dust control requirements in the Natural Events Action Plan except for open storage piles. Fugitive dust control requirements for open st orage piles that meet the defi nition in footnote 2 of Table #9 must be considered in the BACT analysis.

4.1.1-2 – Technical Feasibility

GCC Dacotah believes that a fabric filter and electrostatic precipita tor are technically feasible.

The particulate control device serving kiln #6’s ma in stack receives the pr oduct of the in-line raw mill. This process step is used to generate and collect a dry powder as the feed stock for kiln #6. The collection of this material by a wet scrubbe r would defeat the purpose of collecting a dry product. Therefore, GCC Dacotah believes a wet scrubber is not technica lly feasible for kiln #6’s main stack.

The particulate control device serving the kiln #6 ’s alkali bypass and clin ker cooler receives dust from the rotary kiln and clinke r cooler, respectively. The dust collected c ontains particles of portland cement clinker, which is used to produc e portland cement. Collection of this material by a wet scrubber would set up in the wet scrubber and render the wet scru bber inoperable. GCC Dacotah believes a wet scrubber is not technicall y feasible in controlling particulate emissions from the alkali bypass and clinker cooler.

The particulate control device serving the coal m ill/dryer receives and co llects the product of the coal mill/dryer. The coal/ mill/dryer is used to dry the coal before being used as fuel for kiln #6. Collection of this material usi ng a wet scrubber defeats the pu rpose of drying the coal. GCC Dacotah believes a wet scrubber is not technica lly feasible for the coal mill/dryer stack.

The department concurs with GCC Dacotah that a wet scrubber is not technically feasible. The department agrees that the fabric filter and electrostatic precipita tor are technically feasible for the point sources operated by GCC Dacotah. The de partment also agrees that the fugitive dust control measures outlined by GCC Dacotah are technically feasible . In addition, the department believes the treatment of open storage piles with a chemical stabilizer or water or building a twosided enclosure is also technical feasible.

4.1.1-3 – Top Down Approach

There are two control techniques that are technicall y feasible to install or implement for the kiln #6 upgrade. The two approaches are the installa tion of a fabric filter or an electrostatic precipitator. Both technologi es have comparable particulat e control efficiencies.

The control technologies that are technically feasible for fugiti ve dust sources are based on GCC Dacotah’s application and the Natural Events Acti on Plan for Rapid City. Both approaches will be compared to each other and the control techni que that has the best control will be required.Page 18 4.1.1-4 – BACT Determinat ion for Particulate

The department concurs with GCC Dacotah that BACT for point s ources is a fabric filter or electrostatic precipitator. The department will le t GCC Dacotah decide on if it wants to install a fabric filter or electrostatic precipitator on each point source impacted by the kiln #6 upgrade.

GCC Dacotah is located within the area subject to the Rapid City Natural Events Action Plan. The Rapid City Natural Events Action Plan is designed to minimize fugitive dust emissions by requiring Best Available Control Measures (BACM) on fugitive dust sources. GCC Dacotah will be required to meet at least the minimum require ments of the Natural Events Action Plan (see Table #9) to control fugitive dust emissions.

4.1.2 Sulfur Dioxide

4.1.2-1 – Identifying Options

GCC Dacotah considered the following options to control sulfur dioxide emissions:

1. Wet scrubber; 2. Inherent sulfur dioxide removal; 3. Dry reagent injection; 4. Hot meal injection; and 5. Spray dryer absorbers.

The department agrees with the above options an d will also evaluate low sulfur coal and raw materials.

4.1.2-2 – Technical Feasibility

A wet scrubber reduces the sulfur dioxide emissi ons by passing the exhaust gases through water, which contains an absorbent material. The absorbent material is generally limestone. The limestone absorbent and water mixture produces a sl urry that contains calcium sulfite or calcium sulfate. A review of cement plan ts in the United States showed that one cement plant (Dragon Cement Plant in Thomaston, Maine) tried to ope rate a wet scrubber in the late 1980’s and 1995. Both attempts were unsuccessful. Therefore, GCC Dacotah believes that a wet scrubber is not a technically f easible option.

Sulfur dioxide emissions are effectively reduced wh en the flue gas is in contact with limestone. Cement kilns have large quantities of crushed lime stone and fresh highly reactive lime present to reduce the sulfur dioxide emissions. Therefore, GCC Dacotah believes that inherent sulfur dioxide removal is tech nically feasible.

Dry reagent injection reduces the sulfur dioxide emissions by inje cting a dry absorbent into the exhaust gas stream. Common absorbents ar e calcium hydroxide or hydrated lime. The absorbent reacts with the sulfur dioxide to form calcium sulfite or calcium sulfate. Hot mealPage 19 injection and spray dryer absorbers operate in si milar manner as a dry reag ent injection system. Therefore, GCC Dacotah believes that dry reagent injection, hot meal injection and spray dryer absorbers are technically feasible options.

The department concurs with GCC Dacotah that a wet scrubber is not technically feasible to control sulfur dioxide emissions. The department agrees that i nherent sulfur dioxide removal, dry reagent injection, hot meal in jection and spray dryer absorber s are technically feasible.

In addition, the amount of sulfur dioxide emissi ons that may be produced is dependent on the sulfur content in the material processed through k iln #6. The lower the sulfur content in the coal and raw materials, the lower the amount of sulfur dioxide emissions that may be produced. The department believes it is techni cally feasible to use raw materi als and coal with a low sulfur content to reduce sulfur dioxide emissions.

4.1.2-3 – Top Down Approach

There are five control techniques that are technically feasible and practical to install or implement for the kiln #6 upgrade. The five appr oaches are the inherent sulfur dioxide removal, dry reagent injection, hot meal injection, spray dryer absorbers, and low sulfur fuel and raw material.

The dry reagent injection, hot meal injecti on, and spray dryer abso rber all commonly use hydrated lime (limestone) as its ab sorption process. The inherent sulfur dioxide removal process uses the crushed limestone (hydrated lime) in the cement kiln to absorb and reduce sulfur dioxide emissions. Therefore, there is no significant difference between these absorption techniques, except that there is a cost associated with inst alling the dry reagent inje ction, hot meal injection, and spray dryer absorber systems. All four techniques are comparable on controlling sulfur dioxide emissions.

GCC Dacotah quarries a majority of its raw material at the site. Therefor e, shipping costs would make it economically infeasible to lower sulfur dioxide emission by lowering the sulfur content of the raw materials because of sh ipping costs. The coal used to f eed kiln #6 is shipped from the Power River Basin in Wyoming and is considered a low sulfur coal.

4.1.2-4 – Department’s BACT Det ermination for Sulfur Dioxide

GCC Dacotah proposes using the in herent sulfur dioxide removal process as BACT for sulfur dioxide. The department reviewed the RACT/BACT/LAER Clearinghouse (RBLC) to determine if GCC Dacotah’s proposal was cons idered BACT. Based on the RBLC, BACT for “new” cement plants and modifications to existin g plants has been inherent sulfur dioxide removal and/or limits on the sulfur cont ent of the coal and raw material in a preheater/precalcinator type kiln. Therefore, th e department agrees wi th GCC Dacotah’s BACT determination on using the inherent sulfur di oxide removal process for cement kilns.Page 20 4.1.3 Nitrogen Oxide

4.1.3-1 – Identifying Options

GCC Dacotah considered the following opti ons to control nitr ogen oxide emissions:

1. Combustion control methods:

a. Flue gas recirculation (FGR); b. Mid-kiln firing (MKF);

c. Staged combustion; d. Low-NOx burners;

e. Tire-derived fuel (TDF); f. Fuel selection; and
g. Flame cooling. 2. Nitrogen oxide removal methods:

a. Selective non-catalyt ic reduction (SNCR); b. Selective catalytic reduction (SCR); and

c. Bio-solids injection (BSI). 3. Process modifications:

a. Process control improvements; b. Thermal efficiency improvements; and

c. CemStar process.

The department reviewed the control options provided by GCC Dacotah and compared them to EPA’s final report for NOx Control Technologies for the Cement Industry (September 19, 2000), and agrees with the options.

4.1.3-2 – Technical Feasibility

Flue Gas Recirculation (FGR):

The FGR reduces the peak flame temperature by heating the inert combus tion products contained in the recycled flue gas. FGR relies on c ooling the flame and generating an oxygen deficient atmosphere for combustion to reduce nitrogen oxi de formation. High flame temperature and an oxidizing atmosphere are process requirements to produce quality clinker product. Therefore, GCC Dacotah believes a FGR control device is not a feasible tec hnology for kiln #6. The above information was obtained from page 59 of NOx Control Technologies for the Cement Industry (September 19, 2000).

Mid-Kiln Firing (MKF):

MKF is a staged combustion of fuels in convent ional wet and long-dry kilns by injecting solid fuel into the calcining zone. GCC Dacotah’s kiln #6 is a preheater/p recalcinator kiln. Therefore, GCC Dacotah believes a MKF control device is not a feasible technology for the kiln #6

. The above information was obtained from page 65 of NOx Control Technologies for the Cement Industry (September 19, 2000).Page 21 Staged Combustion:

Staged combustion allows the fuel to be burned in a fuel-rich/oxygen-poor zone and a fuel-lean zone. The fuel-rich/oxygen poor zone provide s the high temperature for completion of the clinker process and the nitrogen oxide emissions are minimized by the oxygen deprived zone. The lower temperatures in the fuel-lean zone minimize the nitrogen oxide formations. For effective staging of combustion air to reduce n itrogen oxide emissions, cement plants must have indirect-fired kilns. Kiln #6 is considered an indirect-fired kiln. Therefore, GCC Dacotah believes staged combustion is considered technica lly feasible for kiln #6. The above information

was obtained from pages 58 through 64 of NOx Control Technologies for the Cement Industry (September 19, 2000).

Low NOx Burners:

Low NOx Burners are designed to reduce flame tu rbulence, delay fuel/air mixing, and establish fuel-rich zones for initial combustion. Th e fuel-rich/oxygen poor zone provides the high temperature for completion of the clinker pr ocess and the nitrogen oxide emissions are minimized by the oxygen deprived zone. Theref ore, GCC Dacotah believes Low NOx Burners is considered technically feasible for kiln #6

. The above information was obtained from pages 59 and 60 of NOx Control Technologies for the Cement Industry (September 19, 2000).

Tire Derived Fuel (TDF):

TDF may be fed into the secondary firing zone (preheater/precalcinator). TDF has a greater heating value (14,000 Btus/pound) compared to th e coal (8,000 Btus/pound). With a larger heating value, less material needs to be fed and the less amount of nitrogen oxide is formed. The above information was obtained from page 63 of NOx Control Technologies for the Cement Industry (September 19, 2000).

GCC Dacotah estimates that 475,000 tires per year are required for a viable TDF program. The Pennington County area has a popul ation of 90,000. If each pers on in Pennington County owns a vehicle and changes their tir es once per year, GCC Dacotah would be able to obtain 360,000 tires per year. It is estimated that most people drive approximately 10,000 to 12,000 miles per year. Most tires have a guarantee of 30,000 to 50,000 miles. Therefore, the rate of changing tires is closer to once every thr ee to five years. In either case, the Pennington County area does not generate enough used tires to support a TD F program. Therefore, GCC Dacotah believes a TDF program is not a feasible technology for kiln #6.

Fuel Selection and Flame Cooling:

Switching to a fuel with a highe r heating value and lower nitrogen content may reduce nitrogen oxide emissions. The use of petroleum coke would provide a higher heating value and lower nitrogen content. However, petroleum coke ma y not be burned alone beca use it does not provide enough volatile matter. Therefore, the use of petr oleum coke as an independent fuel source isPage 22 not feasible. The above information was obtained from pages 57 and 58 of NOx Control Technologies for the Cement Industry (September 19, 2000).

Selective Noncatalytic Reduction (SNCR):

SNCR is a process that uses ammonia or urea without the presence of a catalyst to reduce nitrogen oxide emissions. Without the use of a catalyst, the reaction between the ammonia or urea to reduce the nitrogen oxide emissions is temperature depe ndent. The reaction needs to take place between 1,600 and 2,000 degrees Fahrenheit. In a preheater/precalcinator kilns, the temperature at the cooler end of the kiln, in the riser duct and lowe r end of the preheater is likely to be within the 1,600 to 2,000 degree Fahrenheit range. Therefore, GCC Dacotah considers a SNCR control device as a feasible technology for kiln #6. The above information was obtained from page 70 of NOx Control Technologies for the Cement Industry (September 19, 2000).

Selective Catalytic Reduction (SCR):

SCR is a process that uses ammonia in the pr esence of a catalyst to reduce nitrogen oxide emissions. This technology is used for nitrogen oxide abatement in other industries, such as coal-fire power stations, waste incinerators, gas turbines, and internal combustion engines. The SCR reactor system can be designed for a desire d nitrogen oxide reduction using an appropriate reagent ratio, catalyst bed volume, and operating conditions. At a cement plant the catalysts may be fouled or deactivated by the particulate (alkalies and lime) and sulfur dioxide emissions. Due to the fouling problems, the SCR system must be installed after the particulate collection device.

The optimum temperature for the catalytic re actions depends upon the catalyst used. The temperature required ranges from 570 to 840 degrees Fahrenheit. The exhaust gases from the particulate control device at GCC Dacotah ranges from 300 to 400 degrees Fahrenheit. To reach the optimum temperature the exhaust gases would n eed to be reheated. Reheating would require additional combustion of fuels with a resulting increase of emissions. Therefore, GCC Dacotah believes the SCR control device is no t technically feasible for kiln #6.

The above information was obtained from pages 68-6970 of NOx Control Technologies for the Cement Industry (September 19, 2000).

Biosolids Injection (BSI):

BSI is a selective noncatalytic re duction process. Instead of us ing ammonia or urea for reduction of nitrogen oxide emissions, the naturally occurring ammonia in the biosolids (sludge from the treatment of municipal wastewat er) is used. The above informa tion was obtained from pages 72 through 73 of NOx Control Technologies for the Cement Industry (September 19, 2000)

GCC Dacotah believes BSI is tech nically feasible for kiln #6, but is not considered a practical method of control for nitrogen oxi de based on the following reasons:

1. A constant and adequate supply of biosolids is re quired for this process to be effective. BSI is being used at Mitsubishi Cement Corporat ion’s Cushenbury plant in Lucerne Valley,Page 23 California. Lucerne Valley is located in Sa n Bernadino County and is about two hours from Orange County and Los Angeles. San Be rnadino County has a population of about 1.7 million. GCC Dacotah is located in Rapid Cit y, South Dakota, with a population of about 60,000. Rapid City is located in Pennington County, with a population of about 90,000. Therefore, an adequate supply of bioso lids may not be available in Rapid City. 2. The biosolids have a high water content. Th e #6 kiln is a dry pro cess. Therefore, the addition of wet material to a dry process cause s a reduction in production capacity and would increase the energy consumption for the #6 kiln; and 3. The use of biosolids may cause concerns over health and odor, which would have to be addressed.

Process Control Methods and Thermal Efficiency:

Process control methods are installed to increas e thermal efficiency. An increase of thermal efficiency results in lower fuel consumption. The lower the fuel consumption, less nitrogen oxide emissions are generated. GCC Dacotah believes process control methods and thermal efficiency is a technically feasible for kiln #6. The above information was obtained from page 58 of NOx Control Technologies for the Cement Industry (September 19, 2000)

CemStar Process:

CemStar is a patented process, which feeds steel slag into the raw kiln feed. Steel slag is chemically similar to clinker. Therefore, many of the chemical reactions to produce the clinker have already occurred in produci ng the steel slag in a steel furn ace. This requires less fuel to complete the final chemical reactions to convert th e steel slag to clinker than it would for the raw material to clinker. The a bove information was obtained from pages 72 through 73 of NOx Control Technologies for the Cement Industry (September 19, 2000). GCC Dacotah believes the CemStar process is technically feasible for k iln #6. However, the CemStar process is not considered a practical method of control for nitr ogen oxide because there is no steel furnace in the area to provide steel slag economically.

4.1.3-3 – Top-Down Approach

There are five control techniques that are technically feasible and practical to install or implement for the kiln #6 upgrade. The five approaches are:

1. Staged combustion; 2. Low NOx burners; 3. SNCR; 4. Process control methods; and 5. Thermal efficiency.

The use of ammonia in the SNCR system introduces an element of environmental risk since it is a toxic substance under Title III of the S uperfund Amendments and Reauthorization Act (SARA). Accidental release of the ammonia can occur durin g the handling and storage of ammonia. Another environmental concern is the ammonia slip. The portion of unreactedPage 24 ammonia passing through the catalyst and emitted form the stack is called ammonia slip. The ammonia emitted into the ambient air may cause s econdary particles such as ammonium sulfate and ammonium nitrate. The addition of these particles will increase PM10 and PM2.5 emissions, which is a concern in Rapid City. Th erefore, SNCR is not cons idered an appropriate control device for nitrogen oxide in Rapid City.

GCC Dacotah proposed to use staged combusti on with a thermal efficient in-line low-NOx calciner complimented by a low NOx burner with indi rect firing in the rotary kiln to achieve nitrogen oxide controls. The calciner system proposed by GCC Dacotah would use up to 35 percent of the total heat input in the kiln system. GCC Dacotah has the option of installing a calciner system that may use up to 50 percent of the total heat input in the kiln system. GCC Dacotah evaluated the incremental cost effectiv eness of the 50 percent calciner system. The incremental cost effectiveness was determined to be $3,888 per ton of nitrogen oxide removed. The department reviewed the data provided by G CC Dacotah and agrees with the effectiveness of $3,888 per ton of nitrogen oxide removed. In a previous PSD review, the department determined that $7,100 and $4,500 were too high fo r an incremental cost effectiveness.

GCC Dacotah did not evaluate the incremental cost effectiveness of the larger calciner system. The existing support structure and location of existing equipment would not accommodate a larger calciner system. The larger calciner syst em would have to have a new separate structure built and some of the existing equipment would n eed to be moved. Therefore, the department agrees that the incremental cost effectiveness for the proposed calciner system is feasible and a larger calciner system is not economically or physically feasib le at this time.

4.1.3-4 – Department’s BACT Determination for Nitrogen Oxide

The department reviewed the RACT/BACT’/LAE R Clearinghouse (RBLC) to determine if GCC Dacotah’s proposal was representa tive of previous BACT determinations. Based on the RBLC, BACT for “new” cement plants has been staged combustion in a preheate r/precalcinator type kiln. The department agrees with GCC Daco tah’s BACT determination on installing staged combustion with a thermal efficient in-line low-NOx calciner complimented by a low NOx burner with indirect firing in the rotary kiln to achieve nitr ogen oxide emission controls.

4.1.4 Carbon Monoxide

4.1.4-1 – Identifying Options

GCC Dacotah considered the following opti ons to control carbon monoxide emissions:

1. Regenerative Thermal Oxidation (RTO); 2. Thermal Oxidation (TO); 3. Regenerative Catalytic Oxidation (RCO) and 4. Good Combustion Practices (GCP)

GCC Dacotah reviewed the RACT, BACT, LA ER Clearinghouse (RBLC) database and technical literature for ca rbon monoxide control technol ogy. The RBLC listed only goodPage 25 combustion practices as a carbon monoxide contro l method for cement kilns. The other three methods were reviewed based on technical literature.

The department reviewed the control options prov ided by GCC Dacotah and agrees with the four options.

4.1.4-2 – Technical Feasibility

The process of oxidizing carbon mo noxide and other hydrocarbons to carbon dioxide is similar for regenerative thermal oxidation (RTO), ther mal oxidation (TO), and regenerative catalytic oxidation (RCO) units. Temperature, residence tim e, and turbulence are the three key factors for the destruction of carbon monoxide to carbon di oxide for all three control devices. The temperature required to reduce the carbon monox ide is approximately 1,500 degrees Fahrenheit with a residence time of about 0.5 seconds . This information was derived from Air Pollution Control Equipment -Theodore, Louis and Buonicore, An thony; 1892 by Prentice Hall Inc., Englewood Cliffs, NJ.

The exhaust gases from the main kiln stack, co al mill/dryer stack, and alkali bypass would have to be reheated from 250 to 550 degrees Fahre nheit to 1,300 to 1,500 degrees Fahrenheit by the RTO and TO. The exhaust gas temperatures w ould have to be raised to 600 to 700 degrees Fahrenheit for the RCO. To decrease the amount of fuel needed to reheat the exhaust gases, the RTO uses a heat recovery media to sustain the heat required for the destruction process. The TO does not use a heat recovery media to help decrease the amount of fuel input as in the RTO. To increase the rate of reaction a nd use of a lower temperature, the RCO uses a catalyst for the destruction process. All three control devices would have additional heat input requirements, which would increase the emissions of nitrogen oxide, sulfur dioxide, an d other pollutants. Corrosion and fouling of the heat recovery media for the RTO and catalyst for the RCO is also a concern. Therefore, the RTO, TO and RCO are considered a feasible technology but not a practical technology due to the in crease of air emissions.

Carbon monoxide emissions are ge nerally generated from the incomplete combustion of the fuel material in the kiln system. By usi ng good combustion practices, the carbon monoxide emissions can be minimized. This will be accomplished by having complete and efficient combustion of the fuel. Good combustion practi ces are considered a feasible and practical technology for control of carbon monoxide emissions.

4.1.4-3 – Top-Down Approach

The regenerative thermal oxidation, thermal oxi dation, and regenerative catalytic oxidation control devices are considered feasible technologies but not practical tech nologies due to the increase of air emissions. Theref ore, the only control measure that is feasible and practical is good combustion practices.Page 26 4.1.4-4 – Department’s BACT Determination for Carbon Monoxide

The department reviewed the RBLC and f ound that good combustion practices has been approved for numerous new and modified cement pl ants. The department agrees with the GCC Dacotah’s BACT determination on using good com bustion practices for the kiln #6 upgrade.

4.2 BACT Limits

4.2.1 BACT Limits for Particulate

BACT for particulate emissions was established to be either a fabric filter or electrostatic precipitator. GCC Dacotah decided not to install an electrostatic precipitator on any of the point sources. GCC Dacotah proposed a PM10 emission lim it for each point source with a fabric filter to be 0.01 grains per dry standard cubic foot. The department ag rees with an emission limit of 0.01 grains per dry standard cubic foot. This ty pe of emission limit varies depending on the size of the fan pulling air into or thr ough the fabric filter. Therefore, the department will include the maximum flow rate for each baghouse in the permit.

4.2.2 BACT Limits for Sulfur Dioxide

BACT for sulfur dioxide was established as i nherent sulfur dioxide removal process. GCC Dacotah proposed a BACT limit of 1,040 tons per year for the main kiln stack (685 tons per year), coal mill/dryer stack (273 tons per year) and the alkali bypass stack (82 tons per year). GCC Dacotah did not propose a short-term limit to demonstrate compliance with the short term National Air Quality Standards. After reviewing the modeling results, the department determined that GCC Dacotah’s proposed limits c onsumed a majority of the PSD increments for sulfur dioxide, would prohibit econo mic growth in the quarry area a nd were not protective of the short-term National Ambient Air Quality Standards.

GCC Dacotah reproposed a BACT limit of 885 tons per year for the main kiln stack (584 tons per year), coal mill/dryer stack (232 tons per year ) and the alkali bypass stack (69 tons per year). To protect the National Ambient Air Quality St andards, GCC Dacotah accepted a short-term emission limit of 632 pounds per hour.

Because the emissions generated by the kiln system are emitted through three emission points, and the ratio of emissions for each emission point are estimated, the BACT limits are subject to the kiln system as a whole and not per each emi ssion point. The emissions limits of 885 tons per year is approximately 2.2 pounds of sulfur dioxi de per ton of clinker produced and 632 pounds per hour is approximately 6.7 pounds of sulfur dioxide per ton of clinker produced. These emission limits were compared to the emission li mits stated in the RBLC. The BACT sulfur dioxide emission limits displayed in RBLC for th e new and retrofitted preheater/precalcinator type kilns range from 0.3 to 7.6 pounds per ton cli nker produced for the enti re kiln system. The long-term and short-term emission limits fall within this range.Page 27 4.2.3 BACT Limits for Nitrogen Oxide

BACT was established as staged combustion with a thermal efficient in-line low-NOx calciner complimented by a low NOx burner with indirect firing in the rotary kiln. GCC Dacotah proposed a BACT limit of 2,339 tons per year for th e main kiln stack (1,718 tons per year), coal mill/dryer stack (518 tons per year) and the alkali bypass stack (103 tons per).

GCC Dacotah’s proposed limits fo r nitrogen oxide were based on the manufacturer guaranteeing 1,718 tons per year (70 percent of the preheater emissions) from the main kiln stack with a minimum of 30 percent of the emissions from th e preheater tower going to the coal mill/dryer. Discussions with the manufacturer noted that th e guarantee of the 1,718 tons per year was based on 80 percent of the preheater emissions going to the main kiln stack and the remaining 20 percent of the emissions going to the coal mill/d ryer. Based on this information GCC Dacotah submitted a letter stating the BACT limit is 2,267 t ons per year from the main kiln stack (1,718 tons per year), coal mill/dryer stack (434 tons per year) and the alkali bypass stack (115 tons per).

Because the emissions generated by the kiln system are emitted through three emission points, and the ratio of emissions for each emission point are estimated, the BACT limits are subject to the kiln system as a whole and not per each emission point. The emissions limit of 2,267 tons per year is approximately 5.5 pounds of nitroge n oxide per ton of clinker produced. The emission limit was compared to th e emission limits stated in the NOx Control Technologies for the Cement Industry (September 19, 2000) and RBLC. On page 49 of NOx Control Technologies for the Cement Industry (September 19, 2000), it states that preheater/precalcinator type kilns have a range of nitrogen oxide emissions from 0.9 to 7.0 pounds per ton clinker produced for the entire kiln system. The RBLC shows the emission ranges for the preheater/precalcinator type kiln s to be in the range of 2.9 to 4.5 pounds per ton clinker produced for the entire kiln system.

GCC Dacotah proposed nitrogen oxide emissi on limit is within the range noted in the NOx Control Technologies for the Cement Industry (September 19, 2000) but is higher than the emission limits noted in the RBLC and GCC D acotah’s permit application. The department reviewed the operations to dete rmine the difference. The difference in the emission limit is mainly due to the amount of heat input that is transferred from the kiln burner to the precalcinator system. The precalcinator systems in the RBLC, such as Illinois Cement Company and Lehigh Union Bridge, used up to 50 percent of the heat input of the kiln system.

The department did find one precalcin ator system at Ash Grove in S eattle that used 20 percent of the heat input and had an emission limit of 4.5 p ounds per ton of clinker produced for the entire kiln system. However, this system uses a satellite clinker cooler. The secondary air characteristics and extremely dusty conditions of a sate llite cooler make it possible to obtain lower nitrogen oxide emissions. GCC Dacotah’s ex isting facility does not use a satellite cooler system. Therefore, GCC Dacotah’s emission limit can not be comparable to the one obtained by Ash Grove.Page 28 4.2.4 BACT Limits for Carbon Monoxide

BACT for carbon monoxide has been determin ed to be good combustion practices. GCC Dacotah proposed a BACT limit of 2,079 tons per ye ar for the main kiln stack (1,528 tons per year), coal mill/dryer stack (459 tons per year) and the alkali bypass stack (92 tons per). GCC Dacotah did not propose a short-te rm emission limit to maintain the short-term National Ambient Air Quality Standards.

GCC Dacotah’s proposed limits fo r nitrogen oxide were based on the manufacturer guaranteeing 1,528 tons per year (70 percent of the preheater emissions) from the main kiln stack with a minimum of 30 percent of the emissions from th e preheater tower going to the coal mill/dryer. Discussions with the manufacturer noted that th e guarantee of the 1,528 tons per year was based on 80 percent of the preheater emissions going to the main kiln stack and the remaining 20 percent of the emissions going to the coal mill/dry er. Based on this information the BACT limit is 2,002 tons per year from the main kiln stack (1,528 tons per year), coal mill/dryer stack (382 tons per year) and the alkali bypass stack (92 to ns per). In addition, GCC Dacotah accepted a short-term emission limit of 3,250 pounds per hour.

Because the emissions are generated by the ki ln system are emitted through three emission points, and the ratio of emissions for each emissi on point are estimated, the BACT limits will be combined and subject to the kiln system as a whole and not per each emission point.

4.3 Air Quality Analysis

The air quality analysis must sa tisfy three criteria before the construction of a major source or major modification to a major source can be approved:

1. The air quality analysis must determine if the PSD de minimis monitoring levels are triggered, which would require preconstruc tion ambient air quality monitoring; 2. The air quality analysis must demonstrate that the BACT emission limits from the proposed modification added with the background concentr ations for each pollutant will not cause a violation of any applicable National Ambient Air Quality Standards (NAAQS); and 3. The BACT emission limits from the proposed modification do not exceed any applicable PSD Class I or II increments.

For the air quality analysis, GCC Dacotah used the industrial source complex Short-term 3 (ISCST3) and industrial source complex plume rise model enhancements (ISC-PRIME) air dispersion models. Both models are EPA approve d models. GCC Dacotah used terrain data for the area, five years of meteorology data from th e Rapid City area and the specified regulatory defaults identified in the EPA model guidance. The grid for the model was set at 100 meter spacing from the fence-line out to 1,000 meter, 500 meter spacing from 1,000 meters out to five kilometers, and 1,000 meter spacing from five kilometers out to 50 kilometers.

Table #10 lists the units that were modified dur ing the kiln #6 upgrade and were modeled for sulfur dioxide, nitrogen oxide, and carbon monoxide. Stack lo cations and parameters arePage 29 provided for the units described in Table #10. Du e to the number of units for the particulate modeling, the list for these units may be found in the application.

Table #10 Project Modeled Parameters

Unit Description of Unit Northing

meters Easting
Meters Stack Height
Meters Stack
Diameter

meters Exit Temp

K Exit Velocity
m/s Flow
Rate
ft3/min

9 Fuller Loesche mill, preheater, precalciner, and Rotary kiln #6 4,883,021 638,286 73.15 3.10 399.8 15.02 240,000

11 Alkali bypass (dry process) and 1977 Longhorn alkali waste to waste bin transfer system 4,883,070 638,394 21.64 1.52 560.9 15.52 60,000

41 1995 ABB Raymond coal mill 4,883,026 638,474 32.00 1.07 355.4 22.17 42,000

Table #11 summarizes the emission rates that co rrespond to the emission limits used for sulfur dioxide, nitrogen oxide, and car bon monoxide. The hourly rates are used to determine compliance with the short-term National Ambient Air Quality Standards and the annual limits are used to determine compliance with the l ong-term National Ambient Air Quality Standards and PSD Increments. Table #11 Modeled Emission Rates

Unit # Description of Unit SO2 NOx CO

9 Fuller Loesche mill, preheater, precalciner, and Rotary kiln #6 477 lbs/hour 584 tons/year 1,718 tons/year 2,453 lbs/hour 1,528 tons/year

11 Alkali bypass (dry process) and 1977 Longhorn alkali waste to waste bin transfer system 119 lbs/hour 69 tons/year 115 tons/year 184 lbs/hour 92 tons/year

41 1995 ABB Raymond coal mill 36 lbs/hour 232 tons/year 434 tons/year 613 lbs/hour 382 tons/year

Combined Emissions 632 lbs/hour 885 tons/year 2,267 tons/year 3,250 lbs/hour 2,002 tons/yearPage 30 The highest modeled ambient ai r quality impacts from the kiln #6 upgrade using the emission rates from Table #11 are listed in Table #12.

Table #12 Highest Modeled Ambient Air Quality Impact from Project

UTM Location Ambient Air Impacts Easting Northing Proposed Project Pollutant (meters) (meters) (ug/m 3 ) PM10 (24-hour) – Fence Line 638,161 4,883,035 8.92 PM10 (24-hour) – Fine Grid 638,900 4,883,400 5.98 PM10 (24-hour) – Medium Grid 634,000 4,891,000 1.05 PM10 (24-hour) – Coarse Grid 632,000 4,896,000 0.60

PM10 (Annual) – Fence Line 637,152 4,885,286 2.27 PM10 (Annual) – Fine Grid 637,200 4,885,300 1.62 PM10 (Annual) – Medium Grid 640,000 4,880,000 0.13 PM10 (Annual) – Coarse Grid 639,000 4,877,000 0.05

SO2 (3-hour) – Fence Line 638,162 4,883,010 439.65 SO2 (3-hour) – Fine Grid 638,100 4,883,000 321.03 SO2 (3-hour) – Medium Grid 636,500 4,881,000 57.92 SO2 (3-hour) – Coarse Grid 638,000 4,877,000 32.77

SO2 (24-hour) – Fence Line 638,161 4,883,035 135.68 SO2 (24-hour) – Fine Grid 638,100 4,883,000 84.56 SO2 (24-hour) – Medium Grid 640,000 4,880,500 15.41 SO2 (24-hour) – Coarse Grid 639,000 4,877,000 6.14

SO2 (Annual) – Fence Line 638,161 4,884,244 7.73 SO2 (Annual) – Fine Grid 637,500 4,883,700 6.17 SO2 (Annual) – Medium Grid 640,000 4,881,000 2.87 SO2 (Annual) – Coarse Grid 639,000 4,877,000 0.80

NOx (Annual) – Fence Line 638,161 4,883,035 10.69 NOx (Annual) – Fine Grid 637,500 4,883,700 8.98Page 31 UTM Location Ambient Air Impacts Easting Northing Proposed Project Pollutant (meters) (meters) (ug/m 3 ) NOx (Annual) – Medium Grid 640,000 4,881.000 4.82 NOx (Annual) – Coarse Grid 641,000 4,877,000 1.53

CO (8 hour) – Fence Line 638,161 4,883,035 354.77 CO (8 hour) – Fine Grid 637,900 4,883,200 329.85 CO (8 hour) – Medium Grid 635,500 4,881,000 101.94 CO (8 hour) – Coarse Grid 637,000 4,877,000 45.18

CO (1 hour) – Fence Line 638,162 4,883,010 2,122.78 CO (1 hour) – Fine Grid 638,100 4,883,000 1,583.73 CO (1 hour) – Medium Grid 634,500 4,880,000 319.08 CO (1 hour) – Coarse Grid 638,000 4,873,000 161.83

The department believed that since the particul ate emission increases were negated by particulate emission decreases in the same area, modeling woul d not be required to determine if there was a net air benefit. However, Brenda South, Kevin Golden, and Catherine Collins, with EPA Region VIII, required modeling to determine if there was a net air benefit. Therefore, the department requested a simple model to be completed to show the net air benefit. GCC Dacotah submitted a full modeling impact analysis and demonstrated compliance with the NAAQS and PSD Increments.

4.3.1 De Minimis Monitoring Levels

As allowed in 40 CFR § 52.21(i)(8)(i), modeling ma y be conducted to determine if the proposed BACT emission limits would exceed the de mini mis monitoring levels. If the de minimis monitoring levels are not exceeded, preconstruc tion ambient monitoring is not required. Preconstruction ambient monitoring is used to de termine the background concentration prior to a new source or new modifica tion is constructed.

GCC Dacotah’s kiln #6 upgrade occurred in 1996. Th erefore, in the pre-a pplication meeting, the department agreed that GCC Dacotah did not need to conduct preconstruction ambient monitoring and could use ex isting monitoring data that was collected.

4.3.2 National Ambient Air Quality Standards

Based on EPA’s guidance, New Source Review Workshop Manual, October 1990, if the maximum modeled impact for the proposed proj ect does not exceed the Class II significant impact levels then EPA does not require any fu rther NAAQS or PSD Class II increment analysesPage 32 for that pollutant. Table #13 shows a comparis on of the maximum modeled concentrations as noted Table #12 and the signi ficant impact levels.

Table #13 PSD Class II Significant Impact Levels

Significant Project Impact Impact Level Pollutant (ug/m 3 ) (ug/m 3 ) Further Analysis Required PM10 (24-hour) 8.92 5 Yes PM10 (annual) 2.27 1 Yes

SO2 (3-hour) 439.65 25 Yes SO2 (24-hour) 135.68 5 Yes SO2 (annual) 7.73 1 Yes

NOx (annual) 10.69 1 Yes

CO (1-hour) 2,122.78 2000 Yes CO (8-hour) 354.77 500 No

The modeled project concentrations for the kiln #6 upgrade exceed the part iculate matter, sulfur dioxide, nitrogen oxide and carbon monoxide (1-hou r) concentration levels for PSD Class II significant impact levels. The modeled proj ect concentration does not exceed the Carbon Monoxide (8-hour). Therefore, further modeling is not required.

As required in 40 CFR § 52.21(d), an analysis wa s conducted to determine if the project would exceed the NAAQS. Based on the Class II significant impact le vel review, the NAAQS review is necessary for PM10 (24-hour), PM10 (annual), SO2 (3-hour), SO2 (24-hour), SO2 (annual), NOx (annual), and CO (1-hour). The backgroun d monitoring sites for PM10, SO2, NOx and CO were approved for use in this analysis in a pre-application meeting between Trinity and the department.

The background monitoring location agreed upon were the department’s monitoring stations at Northdale in Rapid City for PM10, South Dakot a National Guard Armory in Rapid City for sulfur dioxide and nitrogen oxide, and the West Acres Shopping Mall in Fargo, North Dakota for carbon monoxide. The calendar years used were 1997, 1998, and 1999 for PM10; 1999 and 2000 for sulfur dioxide; 1999 and 2000 for n itrogen oxide; and 1990, 1991, 1992, 1993, and 1994 carbon monoxide.Page 33 The highest modeled project concentration for the pollutants that exceeded the significant impact levels were added to the background concentr ation to compare to the National Ambient Air Quality Standards. Table #14 shows the compar ison of the modeled im pacts to the National Ambient Air Quality Standards.

Table #14 National Ambient Air Qu ality Standards (NAAQS)

Existing Sources
and Proposed Project Monitor Background Total Impact NAAQS NAAQS Pollutant

(ug/m 3 ) (ug/m 3 ) (ug/m 3 ) (ug/m 3 ) Violation PM10 (24-hour) 81 48 129 150 No PM 10 (annual) 17 19 36 50 No

SO2 (3-hour) 836 129 965 1,300 No SO2 (24-hour) 208 40 248 365 No (SO2 annual) 13 3 16 80 No

NOx (Annual) 33 18 51 100 No

CO (1-hour) 8,619 3,875 12,494 40,000 No

It must be noted that the background ambient monitoring data includes the existing operation of the kiln #6 upgrade and the existi ng sources. Therefore, the total concentration is conservatively high because it includes the emissions from exis ting sources in the background concentration and modeled existing source concentrations.

The department concluded the air emissions from the kiln #6 upgrade will not cause a violation of the NAAQS for PM10, sulfur dioxid e, nitrogen oxide, and carbon monoxide.

4.3.3 Increment Consumption

Black Hills Power and Light Company’s Lange Co mbustion Turbine Facility triggered the minor source baseline date for PM10 and nitrogen oxide in the Rapid City area. GCC Dacotah will trigger the minor source baseline date for su lfur dioxide. There is no increment for carbon monoxide at this time. Any future PSD applicati ons within the 50 kilomete r radius of the Black Hills Power and Light Company’s Lange Combus tion Turbine Facility and GCC Dacotah have to take into account major and minor source changes for PM 10 , sulfur dioxide, and nitrogen oxide.Page 34 Black Hills Power and Light Company’s Lange Combustion Turbine Facility is the only additional source or change that has occurr ed since the minor source baseline date was established for the Rapid City area. Therefore, this project will have to include the emissions from Black Hills Power and Light Company’s Lange Combustion Turbine Facility in the increment analysis. In accordance with 40 CF R § 52.21(c), GCC Dacotah must demonstrate that the ambient air increments for the area will not be exceeded.

The increments are based on the comparison of the potential emissions af ter the kiln #6 upgrade to the actual emissions in the Rapid City area. Tables #15 and #6 show the potential increase of emissions based on the annual emission rates note d in Table #12 that was used to demonstrate compliance with the increments. Please note du e to the number of particulate matter emission points, those emission rates may be found in the application.

Table #15 Modeled SO2 Increment Increases

Unit # Description of Unit Baseline
SO2 (tons/year) Limits
SO2 (tons/year) Difference in SO2 (tons/year)

9 Fuller Loesche mill, preheater, precalciner, and Rotary kiln #6 454 584 130

11 Alkali bypass (dry process) and 1977 Longhorn alkali waste to waste bin transfer system 44 69 25

41 1995 ABB Raymond coal mill -- 232 232
Combined 498 885 387

Trinity based the baseline sulfur dioxide emission on the manuf acturer’s mass balance. The mass balance was calculated on a dry basis. Th e department reviewed historical data and developed a baseline sulfur dioxi de emission of 551 tons per year . The department’s calculation was based on a wet basis because the historical da ta is on a wet basis. If Trinity’s mass balance is converted from a dry basis to a wet basis, the mass balan ces are comparable. The major difference noted is that Trinity’ s sulfur content of 0.6 percent on a dry basis would convert to a sulfur content of approximately 0.42 percent sulf ur on a wet basis. The department used the sulfur content of 0.48 percent. The department agrees to use Trinity’s baseline sulfur dioxide emission because it provides a larger difference than the departments. However, at a future date, the department plans to review th e baseline calculation to verify if the baseline emissions should be higher.Page 35 Table #16 Modeled NOx Increment Increases

Unit # Description of Unit Baseline
NOx (tons/year) Limits
NOx (ton/year) Difference in NOx (tons/year)

9 Fuller Loesche mill, preheater, precalciner, and Rotary kiln #6 1,125 1,718 593

11 Alkali bypass (dry process) and 1977 Longhorn alkali waste to waste bin transfer system 70 115 45

41 1995 ABB Raymond coal mill -- 434 434
Combined 1,195 2,267 1072

Table #17 shows the amount increments consumed based on the emission increases in Table #18 for the air pollutants that exceeded the significant impact analysis.

Table #17 Increment Consumption

Model PSD Class II Increments
Results Amount Remaining Increments
Pollutant (ug/m3) (ug/m3) (ug/m3) Consumed PM10 (24-hour) 7.87 1 30 2 22.13 No PM 10 (annual) 2.28 17 14.72 No

SO2 (3-hour) 339 1 512 2 173 No SO2 (24-hour) 72.4 1 91 2 18.6 No (SO2 annual) 8 20 12 No

NOx (Annual) 10.73 25 14.27 No

1 – Represents the highest 2 nd high impact.
2 – Can be exceeded once per year.

Based on this analysis, the kiln #6 upgrade will not exceed the PSD increments and allows for economic growth in the area.Page 36 4.3.4 Class I Area Impacts

4.3.4-1 – Class I Significant Impact Levels (SIL)

GCC Dacotah used Calpuff (version 5.0) to determ ine if air pollution levels from the kiln #6 upgrade would exceed Class I area significant impact levels. The pollutants evaluated were PM10, sulfur dioxide, and nitrogen oxide. The re sults of the analysis for the emission increases noted in Table #15 and #16 are found in Table #18. The Class I significan t impact levels are calculated as four percent of th e Class I increment values. These values can be found in the Federal Register, Vol. 61, No. 142, Tuesday, July 23, 1996, page 38292.

Table #18 Class I Area Significant Impact Level Analysis

Maximum Predicted Impact Class I Significant Impact Levels Class I

Area Pollutant (ug/m3) (ug/m3) Further Analysis Required
Badlands PM10 (24-hour) 0.011 0.3 No
Badlands PM10 (annual) 0.001 0.2 No

Badlands SO2 (3-hour) 0.8 1.0 No
Badlands SO2 (24-hour) 0.2 0.2 No
Badlands SO2 (annual) 0.02 0.1 No

Badlands NOx (annual) 0.053 0.1 No

Wind Cave PM10 (24-hour) 0.012 0.3 No
Wind Cave PM10 (annual) 0.001 0.2 No

Wind Cave SO2 (3-hour) 0.8 1.0 No
Wind Cave SO2 (24-hour) 0.2 0.2 No
Wind Cave SO2 (annual) 0.01 0.1 No

Wind Cave NOx (annual) 0.028 0.1 No

Based on the above analysis, the project will not exceed the Class I area significant impact levels. Therefore, no further anal ysis is required for Class I area increment analysis. However, the department did review how th e Class I sulfur dioxide incremen ts would be impacted by thisPage 37 application and a recent Wyoming increment analysis submitted to DENR on June 21, 2002. Table #19 shows the amount increments consumed for sulfur dioxide (3-hour), sulfur dioxide (24-hour), and sulfur dioxide (annual ). It should be reiterated that based that this full impact analysis is not required. Table #19 Class I Increment Consumption

GCC Dacotah’s
Model Wyoming’s
Model PSD Class I Increments Class I

Area Results Results Amount Remaining Pollutant

(ug/m3) (ug/m3) (ug/m3) (ug/m3) Increments
Consumed

Badlands SO2 (3-hour) 0.8 1.9 25 22.3 No
Badlands SO2 (24-hour) 0.2 0.7 5 4.1 No
Badlands SO2 (annual) 0.02 0.08 2 1.9 No

Wind Cave SO2 (3-hour) 0.8 2.1 25 22.1 No
Wind Cave SO2 (24-hour) 0.2 1.0 5 3.8 No
Wind Cave SO2 (annual) 0.01 0.13 2 1.86 No

Based on this analysis, the Class I increments will not be exceeded with the kiln #6 upgrade project. Therefore, a more detailed cumulative re view of the Class I increments is not warranted or required.

4.3.4-2 – Visibility

GCC Dacotah conducted a regional haze analysis to evaluate potential visibility impacts to the two Class I areas that fall within the impact range of this project. The Class I areas are the Badlands National Park and Wind Cave National Park. Visibility impairment would occur as a result of the scattering and abso rption of light due to particle s and gases emitted from this project. Regional haze impairs vi sibility by obscuring the clarity, co lor, texture and form of what is seen at these Class I areas. Th is analysis was conducted to ensure that visibility at these Class I areas is not adversely impacted.

GCC Dacotah conducted a visibility analysis to determine the pr ojects estimated visibility impacts to the two Class I areas. This was accomplished by using the Calpuff Lite air modeling system in accordance with guidance in the Interagency Workgroup on Air Quality Modeling

. The air modeling usually incorporates meteorol ogical data for five years. However, GCC Dacotah only conducted the modeling for the cale ndar year 1990. The 1990 calendar year is the only year that all of the meteor ological data has been compiled a nd is readily available for air modeling. Therefore, additiona l air modeling years were no t required.

Based on the Federal Land Managers’ Air Quality Related Values Workgroup (FLAG) document, a change of five percent will evoke a “just” noticeable change in most landscapes. The changes of 10 percent or greater are generally considered unacceptable. The project visualPage 38 impacts (B exts ) should attain less than five percen t change in the background extinction coefficient (B extb ) for each Class I area.

The background extinction coefficient is derived from the following equation:

B extb = 3.912/vr where B extb = background extinction coefficient, 1/km vr = visual range, km

The project impacts were determined by the predicted model concentrations at the Class I areas based upon the following equation:

B exts = (3)(RH f )[(NH 4 ) 2 SO 4 + NH 4 NO 3 )] + (1)(PM fine )

Where RH f = Relative humidity correction factor to adjust for the effects of the ambient humidity on light extinction calculations

(NH 4 ) 2 SO 4 = Concentration of ammonium sulfate in units of ug/m3 - (note because SO 2 is not emitted in excess of the PSD significant emission threshold, it was not included in this analysis and the default was set to zero)

NH 4 NO 3 = Concentration of ammoni um nitrate calculated as NO 3 24 hour concentration ug/m3 times 1.29, the ratio of molecular weights of NH4NO3 and NO 3 , assuming all NO 3 converts to NH 4 NO 3

PM fine = Concentration of primary fine particle in units of ug/m3, calculated as (PM/PM10 24- hour concentration ug/m3) X (1.0), assuming all pm/pm10 is primary fine particle

3 and 1 = Are the extinction coefficient given for the specific pollutant

To determine the project's impact, the source background extinction coefficient (B exts ) is divided by the Class I areas backgr ound extinction coefficient (B extb ) and multiplied by 100 percent.

GCC Dacotah conducted the Calpuff model. The analysis resulted in a few background extinctions of greater than 5 pe rcent. The modeling analysis re sulted in six days and one day where the percent changes were greater than five percent at the Badla nd and Wind Cave National Parks, respectively. The analysis resulted in two and zero days where the percent change was greater than 10 percent at the Badland a nd Wind Cave National Parks, respectively.Page 39 Visibility Extinction Discussion:

Significant impairment to visibility as define d by 40 CFR 51.301 states visibility impairment which, in the judgement of the Administrator, interferes with the management, protection, preservation, or enjoyment of the visitor’s visual experience of the Class I Federal area. This determination must be made on a case-by-case basis taking into account the geographic extent, intensity, duration, frequency and time of the vi sibility impairment, and how these factors correlate with (1) times of vi sitor use of the mandatory Cla ss I Federal Area, and (2) the frequency and timing of natural conditions that re duce visibility. Table #20 displays the average number of visitors per month.

Table #20 Badlands Visitation Records

Month Average Visits (1991 through 1999) January 9,000 February 10,000 March 15,000 April 27,000 May 70,000 June 196,000 July 271,000 August 294,000 September 120,000 October 50,000 November 15,000 December 10,000

Table #21 displays the days the model depicted visibility impairment and the meteorological conditions that day.

Table #21 Visibility Impair ment Conditions

Date Class I Area Percent Extinction Time Period 1 Sunrise Sunset Percent Relative Humidity 2 Weather Conditions 3

1/16/90 Badlands 16 6:00 PM to Midnight 7:20 AM 4:40 PM 96 to 100 Snow Showers and Heavy Fog

30 to 31 Fahrenheit

1/17/90 Badlands 12 Midnight
to 8:00 AM 7:20 AM 4:40 PM 88 to 100 Heavy Fog

24 to 28Page 40 Date Class I Area Percent Extinction Time Period 1 Sunrise Sunset Percent Relative Humidity 2 Weather Conditions 3

Fahrenheit

2/8/90 Badlands 6 3:00 AM
to 8:00 AM 7:00 AM 5:10 PM 81 to 88 None Noted 19 to 27 Fahrenheit

4/24/90 Badlands 8 5:00 PM
to 11:00 PM 5:50 AM 7:40 PM 86 to 96 Rain Showers around noon.

50 to 54 Fahrenheit

5/21/90 Badlands 5.5 4:00 AM
to 7:00 AM 5:20 AM 8:20 PM 96 Heavy Fog

48 to 49 Fahrenheit

12/17/90 Badlands 8 8:00 AM
to 9:00 PM 6:50 AM 4:20 PM 58 to 88 None Noted

11 to 28 Fahrenheit

3/13/90 Wind Cave 7 6:00 PM
to Midnight 6:10 AM 5:50 PM 60 to 96 Snow

32 to 38 Fahrenheit

1 – “Time Period” represents the period in which the percent extinction is greater than 5 percent.
2 – “Percent Humidity” is the relative humidity noted fr om the National Oceanic and Atmospheric Administration weather data for Rapid City, South Dakota for the date and time period selected.
3 - The weather conditions were noted from the National Oc eanic and Atmospheric Administration weather data for Rapid City, South Dakota, for the date and time period selected.

In modeling the visibility impairment, the relati ve humidity correction factor used in the visibility calculation has a signi ficant impact on the visibility calculations. The relative humidity is temperature dependent. The relative humidity will significantly change with small changes at low temperatures but will not change significantl y with small changes at high temperatures. For example, the relative humidity for a specific amount of water in the air would have the relative humidity displayed in Table #22.

Table #22 Relative Humidity 1

Temperature

Fahrenheit Relative Humidity Percent Relative Humidity Correction Factor
26 100 18.1
27 95 9.8
28 90 4.7Page 41 Temperature

Fahrenheit Relative Humidity Percent Relative Humidity Correction Factor
30 80 2.7
40 55 1.3
60 26 1.0
80 13 1.0
100 8 1.0

1 – The relative humidity is based on the psychrometry chart from Perry’s Chemical Engineer’s Handbook, 7 th edition, page 12-5. The relative humidity is for 20 grains of moisture per pound of dry air at 29.92 inches of
mercury.
Visibility is reduced during times of snow, rain, fog, and/or hi gh humidity. Based on the above tables, the visibility impairments appear to have occurred at the same time that natural conditions would have caused visibility impairments. The majority of the visibility impairments (above 5 percent) occurred during the evening (after s undown and before sunrise) and was during the months that the Class I areas have the least amount of visitors.

The department reviewed the November 2001, Report to Congress on Visibility in Class I areas. The report stated that between 1994 and 1998 that the visibility either stayed the same or improved for the Badlands and Wind Cave Natio nal Parks. This time period covers the time when GCC Dacotah’s kiln #6 was upgraded, which occurred in 1996. In addition, the department reviewed the monitoring data on the visibility constituents and concluded that the visibility has improved from the early 1990s to 2000 (Appendix C).

Therefore, based on the above information, the de partment concludes that GCC Dacotah’s kiln #6 upgrade does not have a significan t adverse effect on visibility at the Class I areas.

4.4 Other Impacts

4.4.1 Commercial, Residential, and Industrial Growth

GCC Dacotah indicates there will be no commercial, residential or industrial growth due to the project. There will only be a temporary increas e in the labor force durin g the construction phase to finish this project. Th ere are no plans to hire new employees for this project.

The department anticipates negligible growth -related air pollution impacts from the kiln #6 upgrade.

4.4.2 Soils and Vegetation

GCC Dacotah indicated with its am bient air impact analysis that the predicted emission impacts from the project will be lower than the NAAQS. The NAAQS have been established to protect public health and welfare, ther efore, the department does not anticipate any adverse impacts on soils and terrestrial vegetation in this area from this project.Page 42 4.5 Summary of PSD Requirements

4.5.1 Particulate Matter

BACT for particulate matter is determined for poin t sources to be a fabric filter or electrostatic precipitator. The BACT PM10 emission limit for the fabric filter and elec trostatic precipitator will be 0.01 grains per dry standard cubic foot. There are seven un its that do not have a fabric filter or electrostatic precipitator installed at th is time. GCC Dacotah decided to install fabric filters on these seven operations. The permit will re quire the installation of a fabric filter on all seven units within 12 months of permit issuan ce. Compliance with the PSD emission limit for particulate matter will be based on stack performance tests.

Rapid City experienced problems with exceedin g the National Ambient Air Quality Standards for particulate matter. Therefore, the depart ment requires at least one-to-one offsets for particulate matter (PM 10 ) emissions from new facilities and m odifications to existing facilities. These offsets are reviewed and will be required in the Title V permit. These offsets were not required to met the requirements of the PSD progr am. For the Title V review, the department determined that GCC Dacotah should offset an increase of particulate em issions of 35 tons per year. Particulate offsets have been created when the fabric filters that were installed to control particulate emissions from materi al transfer stations during the kiln #6 upgrade are in operation when material is transferred for kilns #4 and #5.

BACT for particulate matter is determined for fugitive sources to be the fugitive dust control measures required in the Rapid C ity Natural Events Action Plan.

4.5.2 Sulfur Dioxide, Nitrogen Oxide, and Carbon Monoxide

The air emissions from the kiln system are crea ted as a whole and routed through three separate emission points (Unit #9 - main kiln, Unit #11 - al kali bypass, and Unit #41 - coal mill/dryer). The sulfur dioxide, nitrogen oxide, and carbon m onoxide emissions from each emission point are dependent on how the kiln system operates. Therefore, the BACT limits will be combined and subject to the kiln system as a whole and not per each emission point.

4.5.2-1 – Sulfur Dioxide

BACT for sulfur dioxide is determined to be the inherent sulfur dioxi de removal of the raw material and the use of low sulfur coal. Table #23 displays the BACT em ission limits for sulfur dioxide.

Table #23 Sulfur Dioxide BACT Emission Limit for Kiln System

Sulfur Dioxide BACT Limit
Short Term 632 pounds per hour Long Term 885 tons per yearPage 43 Compliance with the short term limit will be based on a 24-hour block average. Compliance with the long term limit will be ba sed on a 12-month rolling average.

GCC Dacotah proposes to demonstrate complian ce with the sulfur dioxide emission limits by estimating sulfur dioxide emissions from the co al mill/dryer stack and alkali bypass stack. The sulfur dioxide emissions would be estimated by calculating monthly em issions for these two units based on the main kiln stack’s conti nuous emission monitor. GCC Dacotah would determine the emission rates for the coal mill/dryer and alkali bypass by multiplying the emission rate from the main kiln stack by a ratio of the air flow rates from the coal mill/dryer stack and alkali bypass stack to the main kiln stack, respectively.

For this proposal to correctly identify the amoun t of sulfur dioxide emissions the airflow rates and sulfur dioxide concentrations need to be co nstant. If the airflow ra te is not constant, the emissions may be underestimated or overestimated for the three emission points. Based on stack tests, the airflow rates are not consistent for each emission point to derive a ratio. Therefore, the airflow rate needs to be measured directly at al l three emission points. GCC Dacotah will install, operate, and maintain continuous emission monitori ng systems that measures the airflow rate at all three units.

GCC Dacotah’s proposal assumes that the sulfur dioxide concentrations are the same for the main kiln stack and alkali bypass stack and an estim ated ratio from the main kiln stack to the coal mill/dryer stack. Reviewing the past stack tests for the main kiln and alkali bypass conducted at similar times, the stack tests show the sulfur concentratio ns are significantly different between these two emissi on points. Therefore, this approach is not valid. The sulfur dioxide emissions needs to be measured from the main kiln stack and alkali bypass stack. GCC Dacotah will be required to install, operat e, and maintain a continuous emission monitoring system to measure the sulfur dioxide emissions fr om the main kiln stack. Due to the amount of emissions routed to the alkali bypass stack being a small portion of the total emissions from the kiln system, the alkali bypass emissions may be determined by an annual stack test.

The main kiln and coal mill/dryer emissions are derived from the preheater tower. The emissions from preheater tower are routed into two air streams. The first stream is routed to the coal mill/dryer and out the coal mill/dryer stack. The second stream is routed to the raw mill and out the main kiln stack. When the raw mill is in operation, it has th e inherent property of scrubbing out sulfur dioxide emissions. GCC Da cotah’s application stat es that there is an approximately 40 percent control when the raw mill is operating to when the raw mill is not operating. GCC Dacotah states that the scrubbing rate of sulfur dioxide will decrease when the amount of sulfur in the raw materi al increases. Therefore, estima ting a control efficiency to back calculate the coal mill/dryer stack emissions is not valid. GCC Dacotah will be required to install, operate, and maintain a continuous emissi on monitoring system to measure sulfur dioxide emissions from the coal mill/dryer stack.Page 44 4.5.2-2 – Nitrogen Oxide

BACT for nitrogen oxide is determined to be a staged combustion system with a thermalefficient in-line, low-NOx calciner complimented by a low NOx burner with indirect firing in the rotary kiln

. Table #24 displays the BACT em ission limits for nitrogen oxide.

Table #24 Nitrogen Oxide BACT Emission Limit for Kiln System

Nitrogen Oxide BACT Limit Long Term 2,267 tons per year

Compliance with the long term limit will be ba sed on a 12-month rolling average. Nitrogen oxide does not have a short-term National Ambien t Air Quality Standard or PSD Increment to met, therefore, a short term limit is not required.

GCC Dacotah proposes to estimate the nitrogen oxi de emissions from the coal mill/dryer stack and alkali bypass stack by using a monthly calculation based on the main kiln stack’s continuous emission monitor. GCC Dacotah would determin e nitrogen oxide emissions from the coal mill/dryer stack and alkali bypass by multiplying the emission rate from the main kiln stack by a ratio of the airflow rates from the coal mill/dry er stack and alkali bypass st ack to the main kiln stack, respectively. Based on the previous disc ussion for sulfur dioxide , a continuous emission monitoring system will be installed, operated, and ma intained to measure the air flow rate for all three units.

GCC Dacotah’s proposal assumes that the nitrogen oxide concentrations are the same for the main kiln stack and alkali bypass stack and estimates a ratio from the main k iln stack to the coal mill/dryer stack. Reviewing the past stack tests for the main kiln and alkali bypass conducted at similar times, the stack tests show the nitrogen oxide concentrations are significantly different between these two emission points. In addition, GCC Dacotah stated during meetings that the concentrations in the alkali bypa ss and main kiln stack were not the same. Therefore, this approach is not valid. The nitr ogen oxide emissions need to be measured from the main kiln stack and alkali bypass stack. GCC Dacotah will be re quired to install, op erate, and maintain a continuous emission monitoring system to measure the nitrogen oxide emissions from the main kiln stack. Due to the amount of emissions routed to the alkali bypass stack being a small portion of the total emissions from the kiln system, the alkali bypass emissions may be determined by an annual stack test.

The main kiln and coal mill/dryer emissions are derived from the preheater tower. The emissions from preheater tower are routed into two air streams. The first stream is routed to the coal mill/dryer and out the coal mill/dryer stack. The second stream is routed to the raw mill and out the main kill stack. Based on the submitted in formation, the nitrogen oxide concentrations in the coal mill/dryer should be the same as the main kiln stack. Therefore, nitrogen oxide emissions do not need to be measured from the coal mill/dryer stack.Page 45 4.5.2-3 – Carbon Monoxide

BACT for carbon monoxide is determined to be good combustion practices. Good combustion practices will be achieved by operating and maintaining the equipment according to the manufacturer’s specifications. Table #25 di splays the BACT emission limits for carbon monoxide.

Table #25 Carbon Monoxide BACT Emission Limit for Kiln System

Carbon Monoxide BACT Limit
Short Term 491 pounds per hour Long Term 2,002 tons per year

Compliance with the short term limit will be base d on an 8 hour block average. There will be three 8 hour block averages per day. The three 8 hour blocks shall be fr om Midnight to 7:59 AM, 8:00 AM to 3:59 PM and 4:00 PM to 11:59 PM. Compliance with the long term limit will be based on a 12-month rolling average.

GCC Dacotah proposes to estimate the carbon m onoxide emissions from the coal mill/dryer stack and alkali bypass stack by us ing a monthly calculation based on the main kiln stack’s continuous emission monitor. GCC Dacotah w ould determine carbon monoxide emissions from the coal mill/dryer stack and alkali bypass by multip lying the emission rate from the main kiln stack by a ratio of the air flow rates from the coal mill/dryer stack and alkali bypass stack to the main kiln stack, respectively. Based on the previ ous discussion for sulfur dioxide, a continuous emission monitoring system will be installed, opera ted, and maintained to measure the air flow rate for all three units.

GCC Dacotah’s proposal assumes th at the carbon monoxide concentr ations are the same for the main kiln stack and alkali bypass stack and estimates a ratio from the main k iln stack to the coal mill/dryer stack. Reviewing the past stack tests for the main kiln and alkali bypass conducted at similar times, the stack tests show the nitrogen oxide concentrations are significantly different between these two emission points. It is assu med that this effect is the same for carbon monoxide. In addition, GCC Dacotah stated during meetings that th e concentrations in the alkali bypass and main kiln stack were not the same. Ther efore, this approach is not valid. The carbon monoxide emissions need to be measured from the main kiln stack and alkali bypass stack. GCC Dacotah will be required to install, operat e, and maintain a continuous emission monitoring system to measure the carbon monoxide emissions from the main kiln stack. Due to the amount of emissions routed to the al kali bypass stack being a small porti on of the total emissions from the kiln system, the alkali bypass emissions may be determined by an annual stack test.

The main kiln and coal mill/dryer emissions are derived from the preheater tower. The emissions from the preheater tower are routed into two air streams. The firs t stream is routed to the coal mill/dryer and out the coal mill/dryer stac k. The second stream is routed to the raw mill and out the main kill stack. Based on the submitted information, the carbon monoxidePage 46 concentrations in the coal mill/dryer should be the same as the main kiln stack. Therefore, carbon monoxide emissions from the coal mill/dryer can be estimated.

4.6 New Source Performance Standards (NSPS)

The PSD BACT limit determined above must be as stringent as the federal new source performance standard (NSPS). The following NSPS were reviewed:

1. Standards of performance for Portland cement plants; 2. Standards of performance for coal preparation plants; and 3. Standards of performance for non-metallic mineral processing plants

4.6.1 40 CFR Part 60, Subpart F - Standards of Performance for Portland Cement Plants

The provisions of this subpart are applicable to the following units a nd processes at portland cement plants that commence construction or m odifications after Augus t 17, 1971: kiln, clinker cooler, raw mill system, finish mill system, raw mill dryer, raw material storage, clinker storage, finish product storage, conveyor transfer points, bagging and bulk loading and unloading systems. However, in accordance with 40 CFR § 63.1356, a facility subject to 40 CFR Part 63, Subpart LLL is exempt from the applicable ne w source performance standards contained in 40 CFR Part 60, Subpart F. Ther efore, 40 CFR Part 60, Subpart F is no longer applicable.

4.6.2 40 CFR Part 60, Subpart Y - Standards of Performance for Coal Preparation Plants

The provisions of this subpart are applicable to the following units and processes in coal preparation plants that commen ce construction or modifications after October 24, 1974: thermal dryers, pneumatic coal cleaning equipment, co al processing and conveying equipment, coal storage systems, and coal transfer and loading systems. An indirect coal firing system was installed on kiln #6 when the unit was modified in 1996. The system pulls air from the back end of kiln #6 and uses the air to dr y the coal prior to being fired in kiln #6. Air pollution equipment associated with the coal firing system is a single stage cyclone followed by two baghouse dust collectors that are operated in pa rallel. A third smaller baghouse controls air emissions from a vent on the coal feed pumps. Therefore, the coal preparation system for kiln #6 is applicable to this NSPS.

In accordance with 40 CFR § 60.252(a)(1), the coal dr yer system (Unit #41) is subject to a total suspended particulate emission limit of 0.031 grai ns per dry standard cu bic foot. The BACT emission limit for Unit #41 is 0.01 grains per dry st andard cubic foot and is measured as PM10. Therefore, the BACT emission limit is mo re stringent then the NSPS requirement.

4.6.3 40 CFR Part 60, Subpart OOO – Standards of Performance for Non-metallic Mineral Processing Plants

The provisions of this subpart are applicable to the following units and processes in non-metallic mineral processing plants that are not subject to Subpart F or follow any process that is subject toPage 47 Subpart F that commences construction or modi fications after August 31, 1983: crusher, grinding mill, screening operation, bucket elevator, belt conveyor, bagging operating, storage bin, enclosed truck or rail car loading station. The cr ushing and screening opera tions that occur prior to the raw mill system would not be covered by Subpart F. A revi ew of the construction date of the crushing and screening operation demons trates that GCC Dacotah’s crushers were constructed prior to August 31, 1983. GCC Dacotah did not upgrad e or modify any portion of the existing crusher or screening operations during the kiln #6 upgrade. The kiln #6 upgrade increased the actual process rate for the crus hing and screening operati on. Increasing hours of operation or production rate for a unit is not subject to a New Source Performance Standard if that unit was capable of operati ng at that production rate. GCC Dacotah’s crusher and screening operations were capable of handling the increas e of “actual” production rate. Therefore GCC Dacotah is not subject to this subpart at this time.

4.7 National Emission Standards for Haza rdous Air Pollutant (MACT – Part 63)

The PSD regulations do not require the Na tional Emission Standards for Hazardous Air Pollutants also known as Maximum Achievable Control Technology (MACT) standards be included or reviewed for PSD permits. Since th e following MACT is taking the place of a Part 60 requirement, this review is briefl y discussing it applicability.

4.7.1 40 CFR, Part 63, Subpart LLL – National Emission Standards for Hazardous Air Pollutants from the Portland Ce ment Manufacturing Industry

The provisions of this subpart are applicable to each new and existing portland cement plants. GCC Dacotah is an existing portland cement plant and is applicable to this subpart. This subpart will be included into GCC Dacotah’s existing Ti tle V permit but not the PSD permit.

4.8 Title V Air Quality Operating Permit

Any source operating in South Dakota that meet s the requirements of ARSD 74:36:05:03 is required to obtain a Title V air quality operating permit. GCC Dacotah is required to obtain a Title V air quality operating permit because their pot ential criteria air emissions are greater than 100 tons per year. In accordance with the ARSD 74:36:05:03.01, GCC Daco tah is required to submit an application for a Title V air quali ty operating permit within 12 months after commencing operation. The requirements for the k iln #6 upgrade are already in the Title V air quality operating permit. However, the permit w ill need to be revised to include PSD permit requirements.



### 5.0 RECOMMENDATION

GCC Dacotah’s kiln #6 upgrade is considered a major modification under the PSD program. Therefore, a PSD review is requir ed. Modeling results indicate that the increase in air emissions will not cause an exceedance of the National Ambi ent Air Quality Standards or exceed the PSD increment levels for particulate matter, sulfur dioxide, nitrogen oxide, or carbon monoxide.Page 48 Based on information received in the permit a pplication and this analysis, the department recommends issuance of a PSD pe rmit to GCC Dacotah. Any questions pertaining to this permit recommendation should be directed to Ky rik Rombough, Natural Resources Engineering Specialist.A-1 

## Appendix A

Potential Criteria Air Emi ssions Factor DeterminationA-1 Particulate

The emission factors for particulate are derive d from Compilation of Air Pollutant Emission Factors, AP-42, Fifth Edition, Volume I: Stationary Point and Area Sources

, Uncontrolled Emission Factor Listing for Criteria Air Po llutants, Volume II, Chapter 14, June 2000, facility specific stack tests, manufacturer guarantees and the established BACT limits.

Due to the number of particulate matter sources a nd the use of past and present emission factors, the emission factors are divided into several tables. The following tables are separated into equipment areas and the time frame

Table #A-1 Point Source Emission Factors (PM10) Prior to Upgrade

Unit Description Emission Rates 1 Emission Citation 9 Rotary Kiln #6 Loesche Mill On 9.07 lbs/hour May 1991 stack test Loesche Mill Off 9.15 lbs/hour May 1991 stack test 10 Clinker Cooler #6 5.56 lbs/hour July 1991 stack test 11 Alkali By-Pass 0.85 lbs/hour May 1991 stack test 41 Coal Dryer Did Not Exist Did not Exist

1 The stack tests gave the results in total particulate matter . To derive the emission factors for particulate less than 10 microns, ratios were used based on information from AP42 11.6 (1/95). PM10 is considered 84 percent of the total particulate for Unit #9 and #11. PM10 is considered 76 percent of the total particulate for Unit #10.

Table #A-2 Dust Collectors Emission Factors (PM10) Prior to Upgrade

Unit Description Emission Rates Control Efficiency Emission Citation

1 1954 Allis Chalmers/Superior primary crusher and secondary crusher 0.00131 lbs / ton AP-42, 11.6-14, 1/95 3

2 1954 Cedar Rapids screen 0.00031 lbs / ton AP-42, 11.6-14, 1/95 3

6 Kiln Feed Storage Silo 0.15 lbs / ton 97.0% EIIP - SCC 3-05-006-12, 6/00
6a Rock Silo to Loesche Mill 0.15 lbs / ton 97.0% EIIP - SCC 3-05-006-12, 6/00
6b Kiln Feed Storage Silo to Kiln 0.15 lbs / ton 97.0% EIIP - SCC 3-05-006-12, 6/00
7b Clinker Shed to Finish Mills 0.15 lbs / ton 97.0% EIIP - SCC 3-05-006-12, 6/00
7c Raw Shed to Loesche Mill 0.15 lbs / ton 65.0% EIIP - SCC 3-05-006-12, 6/00
7d BC107 to BC108 Transfer 0.15 lbs / ton 65.0% EIIP - SCC 3-05-006-12, 6/00

7e Gypsum Raw Shed to Old Clinker 0.15 lbs / ton 65.0% EIIP - SCC 3-05-006-12, 6/00A-2 Unit Description Emission Rates Control Efficiency Emission Citation

7f Raw Shed to Loesche Mill 0.15 lbs / ton 65.0% EIIP - SCC 3-05-006-12, 6/00
7g Gypsum Raw Shet to Old Clinker 0.15 lbs / ton 65.0% EIIP - SCC 3-05-006-12, 6/00

8 Penthouse Storage #2 (north) 0.15 lbs / ton 97.0% EIIP - SCC 3-05-006-12, 6/00
8a Penthouse #2 (north) 0.15 lbs / ton 97.0% EIIP - SCC 3-05-006-12, 6/00
8b Penthouse #2 (north) 0.15 lbs / ton 97.0% EIIP - SCC 3-05-006-12, 6/00
8c Rock Silo Discharge 0.15 lbs / ton 65.0% EIIP - SCC 3-05-006-12, 6/00

12 Finish mill #3 – 1953 Allis Chalmers finish mill 0.05 lbs / ton 97.0% AP-42 11.6-14 1/95

13 Finish mill #4 – 1953 Allis Chalmers finish mill 0.05 lbs / ton 97.0% AP-42 11.6-14 1/95

14 Finish mill #5 – 1976 Allis Chalmers finish mill 0.05 lbs / ton 97.0% AP-42 11.6-14 1/95

15 Finish mill #6– 1976 Allis Chalmers finish mill 0.05 lbs / ton 97.0% AP-42 11.6-14 1/95

16 Finish mill #7– 1978 Traylor finish mill (mill sweep) 0.02 lbs / ton 97.0% AP-42 11.6-14 1/95

16a Finish mill #7– 1978 Traylor finish mill (mill separator) 0.03 lbs / ton 97.0% AP-42 11.6-14 1/95

16b Finish mill #7– 1978 Traylor finish mill (transfer) 0.15 lbs / ton 97.0% EIIP - SCC 3-05-006-12, 6/00

16c Finish mill #7– 1978 Traylor finish mill (transfer) 0.15 lbs / ton 97.0% EIIP - SCC 3-05-006-12, 6/00

16d Clinker Transfer System 0.15 lbs / ton 65.0% EIIP - SCC 3-05-006-12, 6/00

17 Bulk Storage Silos (22 btwn 17- 21) 0.46 lbs / ton 97.0% AP42-11.12-5 10/01

18 Bulk Storage Silos (22 btwn 17- 21) 0.46 lbs / ton 97.0% AP42-11.12-5 10/01

19 Bulk Storage Silos (22 btwn 17- 21) 0.46 lbs / ton 97.0% AP42-11.12-5 10/01

20 Bulk Storage Silos (22 btwn 17- 21) 0.46 lbs / ton 97.0% AP42-11.12-5 10/01

21 Bulk Storage Silos (22 btwn 17- 21) 0.46 lbs / ton 97.0% AP42-11.12-5 10/01

24 Rail Storage Silos (10 btwn 24 and 26) 0.46 lbs / ton 97.0% AP42-11.12-5 10/01

25 Rail Storage Silos (10 btwn 24 and 26) 0.46 lbs / ton 97.0% AP42-11.12-5 10/01

26 Rail Storage Silos (10 btwn 24 0.46 lbs / ton 97.0% AP42-11.12-5 10/01A-3 Unit Description Emission Rates Control Efficiency Emission Citation

and 26)

27 Bulk Rail Loadouts (10 btwn 27 and 28) 0.20 lbs / ton 97.0% EIIP - SCC 3-05-006-19, 6/00

28 Bulk Rail Loadouts (10 btwn 27 and 28) 0.20 lbs / ton 97.0% EIIP - SCC 3-05-006-19, 6/00

35 East bulk truck loadout 0.20 lbs / ton 97.0% EIIP - SCC 3-05-006-19, 6/00
36 West bulk truck loadout 0.20 lbs / ton 97.0% EIIP - SCC 3-05-006-19, 6/00
37 St. Regis cement bagging 0.20 lbs / ton 97.0% EIIP - SCC 3-05-006-19, 6/00
38 St. Regis cement bagging 0.20 lbs / ton 97.0% EIIP - SCC 3-05-006-19, 6/00
39 St. Regis cement bagging 0.20 lbs / ton 97.0% EIIP - SCC 3-05-006-19, 6/00
41b Coal Stacker Top 0.15 lbs / ton 97.0% EIIP - SCC 3-05-006-12, 6/00
41c Coal Surge Bin Top 0.15 lbs / ton 97.0% EIIP - SCC 3-05-006-12, 6/00
41d Coal Tunnel to Coal Stacker 0.15 lbs / ton 65.0% EIIP - SCC 3-05-006-12, 6/00
41e Coal Surge Bin Top 0.15 lbs / ton 97.0% EIIP - SCC 3-05-006-12, 6/00
41f Coal Transfer 0.15 lbs / ton 97.0% EIIP - SCC 3-05-006-12, 6/00
41I Coal Bin #6 0.15 lbs / ton 97.0% EIIP - SCC 3-05-006-12, 6/00 41j Coal Dryer – FK pump 0.15 lbs / ton 97.0% EIIP - SCC 3-05-006-12, 6/00
62b Coal: Hopper to Conveyor 0.15 lb s / ton 97.0% EIIP - SCC 3-05-006-12, 6/00

1 The emission factors are for uncontrolled operations.
2 The emission factors takes into account controlled equipment
3 AP-42 emission factor is for TSP and based on a fabric filter. The PM10 emission factor will be assumed to be the

same. AP42 – Compilation of Air Pollutant Emission Factors, AP -42, Fifth Edition, Volume I: Stationary Point and Area Sources. EIIP – Uncontrolled Emission Factor Listing for Criteria Air Pollutants, Volume II, Chapter 14, June 2000.A : 1 Table #A-3 Fugitive Emission Factors (PM10) Prior to Upgrade

Unit Description Emission Rates Control Efficiency Emission Derivation

42 Topsoil Removal (Bulldozer) 0.62 lbs/hour 0.0% Trinity Provided In Application
43 Drilling 0.16 lbs/blasts 95.0% Trinity Provided In Application
79b Shale Crusher 0.0007 lbs/ton 80.0% Trinity Provided In Application
80 Disturbed Area 0.12 lbs/acres 0.0% Trinity Provided In Application

45 Quarried Limestone: Front-End Loader to Truck 0.00192 lbs/ton 50.0% Trinity Provided In Application

46 Sand: Front-End Loader to Truck (100% is loaded at the pit) 0.00029 lbs/ton 0.0% Trinity Provided In Application

46a Sand: Front-End Loader to Truck (10% of total sand delivery from pit is stored prior to the process) 0.00029 lbs/ton 0.0% Trinity Provided In Application

47 Shale: Pile to Truck 0.00012 lbs/ton 0.0% Trinity Provided In Application
49 Gypsum: Quarry to Truck 0.0141 lbs/ton 0.0% Trinity Provided In Application
49a Gypsum: Pile to Truck 0.0141 lbs/ton 0.0% Trinity Provided In Application

50 Crushed Limestone: Raw Shed to Truck by Front End Loader 0.00192 lbs/ton 10.0% Trinity Provided In Application

50a Crushed Limestone (Crusher Back-up): Pile to Truck (to process) 0.00192 lbs/ton 0.0% Trinity Provided In Application

50b Crushed Limestone: Conveyor to Screen 0.00192 lbs/ton 90.0% Trinity Provided In Application

50c Crushed Limestone: Conveyor to Raw Shed 0.00192 lbs/ton 90.0% Trinity Provided In Application

51 Strip Dirt from Quarry Area (to Quarry Limestone) 0.00026 lbs/ton 0.0% Trinity Provided In Application

52a Alkali/Kiln Dry Waste Ash: Bin to Truck 0.566 lbs/ton 80.0% Trinity Pr ovided In Application

53 Quarried Limestone: Truck to Crusher 0.00192 lbs/ton 80.0% Trinity Provided In Application

54 Sand: Truck to Semi-Enclosed Shed (90% from offsite delivery and 10% from storage pile) 0.00029 lbs/ton 10.0% Trinity Provided In Application

54a Sand: Truck to Pile (10% from offsite delivery) 0.00029 lbs/ton 0.0% Trinity Provided In Application

55 Shale: FE Loader from Quarry to Crusher 0.00012 lbs/ton 0.0% Trinity Provided In Application

55a Shale: Truck to Shed (100%) 0.00012 lbs/ton 10.0% Trinity Provided In Application
55b Shale: Stacker to Pile 0.00012 lbs/ton 0.0% Trinity Provided In Application
56 Iron Ore: Truck to Pile 0.00129 lbs/ton 0.0% Trinity Provided In Application
56a Iron Ore:Front End Loader to 0.00129 lbs/ton 10.0% Trinity Provided In ApplicationA : 2 Shed

57 Gypsum: Truck to Pile 0.0141 lbs/ton 0.0% Trinity Provided In Application
57a Gypsum: Truck to Crusher 0.0141 lbs/ton 80.0% Trinity Provided In Application

57b Gypsum: Conveyor to Gypsum Storage Shed 0.0141 lbs/ton 10.0% Trinity Provided In Application

58 Crushed Limestone (Crusher Back-up): Truck to Pile 0.00192 lbs/ton 0.0% Trinity Provided In Application

58a Crushed Limestone: Truck to Raw Shed 0.00192 lbs/ton 10.0% Trinity Provided In Application

62 Coal: Truck to Pile (10% vs 62a) 0.00006 lbs/ton 0.0% Trinity Provided In Application

62a Coal: Truck/Front-End Loader to Hopper (90% vs 62) 0.00006 lbs/ton 10.0% Trinity Provided In Application

63 Unloading Strip Dirt from Truck 0.00026 lbs/ton 0.0% Trinity Provided In Application

64a Alkali/Kiln Dry Waste Ash Truck to Quarry 0.00048 lbs/ton 50.0% Trinity Provided In Application

79 Shale Pile/Quarry 0.13 lbs/acres 50.0% Trinity Provided In Application
79a Shale Pile at the Quarry 0.13 lbs/acres 0.0% Trinity Provided In Application
82 Crushed Limestone Pile 0.86 lbs/acres 0.0% Trinity Provided In Application
83 Sand Pile 0.27 lbs/acres 0.0% Trinity Provided In Application
84 Sand Pit 0.27 lbs/acres 50.0% Trinity Provided In Application
84a Sand Pit2 0.27 lbs/acres 50.0% Trinity Provided In Application
85 Iron Ore Pile 0.95 lbs/acres 0.0% Trinity Provided In Application
86 Coal Pile 0.65 lbs/acres 50.0% Trinity Provided In Application 87 Gypsum Pile/Quarry 0.38 lbs/acres 50.0% Trinity Provided In Application
87a Gypsum Pile 0.38 lbs/acres 0.0% Trinity Provided In Application
87b Gypsum Storage Shed 0.51 lbs/acres 10.0% Trinity Provided In Application

87c Gypsum Muck Pile 0.24 lbs/acres 0.0% Trinity Provided In Application
91 Alkali Waste-Quarry 2.83 lbs/mile 90.0% Trinity Provided In Application
92 Sand Hauling Road 0.39 lbs/mile 90.0% Trinity Provided In Application
93 Shale Hauling Road 0.41 lbs/mile 90.0% Trinity Provided In Application 94 Iron Ore Hauling Road 0.85 lbs/mile 90.0% Trinity Provided In Application
95 Gypsum Hauling Road 0.33 lbs/mile 90.0% Trinity Provided In Application
96 Coal Hauling Road 0.96 lbs/mile 90.0% Trinity Provided In Application
97 Transporting Product Out 0.69 lbs/mile 90.0% Trinity Provided In Application 101

A Quarry Limestone (Quarry to Crusher) Traffic 2.83 lbs/mile 90.0% Trinity Provided In Application

99 Alkali Waste-Quarry 2.78 lbs/mile 80.0% Trinity Provided In Application

101 Quarry Limestone (Quarry to Crusher) Traffic 2.78 lbs/mile 80.0% Trinity Provided In ApplicationA : 3 Table #A-4 Point Source BACT (PM10) Limit

Unit Description Emission Rates Emission Derivation 1
9 Rotary Kiln #6 Loesche Mill On 11.95 lbs/hour Back calculated from 0.01 gr/dscf Loesche Mill Off 11.95 lbs/hour Back calculated from 0.01 gr/dscf 10 Clinker Cooler #6 8.59 lbs/hour Back calculated from 0.01 gr/dscf 11 Alkali By-Pass 2.36 lbs/hour Back calculated from 0.01 gr/dscf 41 Coal Dryer 2.09 lbs/hour Back calculated from 0.01 gr/dscf

1 gr/dscf is grains per dry sta ndard cubic feet. The manufacturer of the baghouses guarantees the exit concentration. The exit con centration was back calculated to determine the pound per hour emission rate.

Table #A-5 Dust Collectors BACT (PM10) Limit

Unit Description Emission Rates Emission Derivation 1

1 1954 Allis Chalmers/Superior primary crusher and secondary crusher 0.0005 lbs/ton Back calculated from 0.01 gr/dscf

2 1954 Cedar Rapids screen 0.0006 lbs/ton Back calculated from 0.01 gr/dscf

6 Raw material storage building to two kiln feed storage silos 0.0025 lbs/ton Back calculated from 0.01 gr/dscf

6a Rock Silo to Loesche Mill 0.0042 lbs/ton Back calculated from 0.01 gr/dscf
6b Kiln Feed Storage Silo to Kiln 0.0016 lbs/ton Back calculated from 0.01 gr/dscf
7b Clinker Shed to Finish Mills 0.0023 lbs/ton Back calculated from 0.01 gr/dscf
7c Raw Shed to Loesche Mill 0.0064 lbs/ton Back calculated from 0.01 gr/dscf
7d BC107 to BC108 Transfer 0.0003 lbs/ton Back calculated from 0.01 gr/dscf

7e Gypsum Raw Shed to Old Clinker 0.0007 lbs/ton Back calculated from 0.01 gr/dscf

7f Raw Shed to Loesche Mill 0.0064 lbs/ton Back calculated from 0.01 gr/dscf
7g Gypsum Raw Shet to Old Clinker 0.0007 lbs/ton Back calculated from 0.01 gr/dscf

8 Penthouse Storage #2 (north) 0.0040 lbs/ton Back calculated from 0.01 gr/dscf
8a Penthouse #2 (north) 0.0028 lbs/ton Back calculated from 0.01 gr/dscf
8b Penthouse #2 (north) 0.0038 lbs/ton Back calculated from 0.01 gr/dscfA : 4 Unit Description Emission Rates Emission Derivation 1

8c Rock Silo Discharge 0.0001 lbs/ton Back calculated from 0.01 gr/dscf

12 Finish mill #3 – 1953 Allis Chalmers finish mill 0.0280 lbs/ton Back calculated from 0.01 gr/dscf

13 Finish mill #4 – 1953 Allis Chalmers finish mill 0.0210 lbs/ton Back calculated from 0.01 gr/dscf

14 Finish mill #5 – 1976 Allis Chalmers finish mill 0.0194 lbs/ton Back calculated from 0.01 gr/dscf

15 Finish mill #6– 1976 Allis Chalmers finish mill 0.0192 lbs/ton Back calculated from 0.01 gr/dscf

16 Finish mill #7– 1978 Traylor finish mill (mill sweep) 0.0198 lbs/ton Back calculated from 0.01 gr/dscf

16a Finish mill #7– 1978 Traylor finish mill (mill separator) 0.0569 lbs/ton Back calculated from 0.01 gr/dscf

16b Finish mill #7– 1978 Traylor finish mill (transfer) 0.0006 lbs/ton Back calculated from 0.01 gr/dscf

16c Finish mill #7– 1978 Traylor finish mill (transfer) 0.0011 lbs/ton Back calculated from 0.01 gr/dscf

16d Clinker Transfer System 0.0015 lbs/ton Back calculated from 0.01 gr/dscf

17 Bulk Storage Silos (22 btwn 17-21) 0.0024 lbs/ton Back calculated from 0.01 gr/dscf

18 Bulk Storage Silos (22 btwn 17-21) 0.0023 lbs/ton Back calculated from 0.01 gr/dscf

19 Bulk Storage Silos (22 btwn 17-21) 0.0024 lbs/ton Back calculated from 0.01 gr/dscf

20 Bulk Storage Silos (22 btwn 17-21) 0.0054 lbs/ton Back calculated from 0.01 gr/dscf

21 Bulk Storage Silos (22 btwn 17-21) 0.0019 lbs/ton Back calculated from 0.01 gr/dscf

24 Rail Storage Silos (10 btwn 24 and 26) 0.0024 lbs/ton Back calculated from 0.01 gr/dscf

25 Rail Storage Silos (10 btwn 24 and 26) 0.0024 lbs/ton Back calculated from 0.01 gr/dscf

26 Rail Storage Silos (10 btwn 24 and 26) 0.0060 lbs/ton Back calculated from 0.01 gr/dscf

27 Bulk Rail Loadouts (10 btwn 27 and 28) 0.0002 lbs/ton Back calculated from 0.01 gr/dscf

28 Bulk Rail Loadouts (10 btwn 27 and 28) 0.0010 lbs/ton Back calculated from 0.01 gr/dscf

35 East bulk truck loadout 0.0005 lbs/ton Back calculated from 0.01 gr/dscf
36 West bulk truck loadout 0.0006 lbs/ton Back calculated from 0.01 gr/dscf
37 St. Regis cement bagging 0.0039 lbs/ton Back calculated from 0.01 gr/dscfA : 5 Unit Description Emission Rates Emission Derivation 1

38 St. Regis cement bagging 0.0039 lbs/ton Back calculated from 0.01 gr/dscf
39 St. Regis cement bagging 0.0039 lbs/ton Back calculated from 0.01 gr/dscf
41b Coal Stacker Top 0.0002 lbs/ton Back calculated from 0.01 gr/dscf
41c Coal Surge Bin Top 0.0001 lbs/ton Back calculated from 0.01 gr/dscf
41d Coal Tunnel to Coal Stacker 0.0001 lbs/ton Back calculated from 0.01 gr/dscf
41e Coal Surge Bin Top 0.0008 lbs/ton Back calculated from 0.01 gr/dscf
41f Coal Transfer 0.0002 lbs/ton Back calculated from 0.01 gr/dscf
41I Coal Bin #6 0.0002 lbs/ton Back calculated from 0.01 gr/dscf 41j Coal Dryer – FK pump 0.0019 lbs/ton Back calculated from 0.01 gr/dscf
62b Coal: Hopper to Conveyor 0.0002 lbs/ton Back calculated from 0.01 gr/dscf

1 The emission factors takes into account controlled equipment
2 gr/dscf is grains per dry standard cubic feet. The manufact urer of the baghouses guarant ees the exit concentration. The exit concentration was back calculated to determine the pound per hour emission rate.

Sulfur Dioxide

Table A-6 Sulfur Dioxide Emissions Prior to Upgrade

Variables Operating Rates Sulfur Input of System Kg S / Mt clinker 1 Conversion Factor 2 Raw Mill Off (lbs/hour) Raw Mill On (lbs/hour) Kiln Feed 2.755 241.77 666 666 1.066 241.77 257 257

System Output of System Clinker 1.802 241.77 436 436 Alkali Dust 1.037 241.77 251 251 Main Kiln Exhaust 0.926 4 241.77 224 134 3 Alkali Bypass Exhaust 0.056 4 241.77 13 13

1 – Kg S / Mt clinker – kilograms sulfur per metric ton clinker
2 – Conversion factor takes into account the molecular weight of sulfur to sulfur dioxide, kilograms to pound, and clinker production rate.
3 – Raw Mill On rate for the Main Kiln Exhaust uses G CC Dacotah’s assumptions that the when the raw mill is on that 40% of the sulfur is absorbed into the raw feed.
4 – The main kiln (94.34%) and alkali bypass (5.66%) exhaust gases are the amount of sulfur (as sulfur dioxide) not collected in the clinker or alkali dust.A : 6 Table A-7 Operating Rates used in Emission Calculations

Variables Operating Rates Sulfur Input of System S0 3 (%) 1 S (%) 2 Flowrates Operating Rate 3
Kiln Feed / Clinker 0.4 1.72 (kg feed / kg clinker) Coal Feed 0.48 12.21 (mtph) 3

System Output of System Clinker 0.45 54.94 (mtph) 4
Alkali Dust 5.61 2.54 (mtph) 4 Main Kiln Exhaust 0.9434 (x) Alkali Bypass Exhaust 0.0566 (x)

(x) – is the remaining sulfur dioxide flowrate (lbs/hour) for the entire kiln system after the clinker and alkali dust have been subtracted out.
1 – These parameters were given by GCC Dacotah in the application.
2 – The average sulfur content fr om the US Geological Survey.
3 – These parameters were determined by the opera tional reports submitted in 1991 through 1994.
4 – mtph – metric tons per hour Table A-8 Operational Parameters used to Develop Operating Rates 1

Operational Parameters Calendar Year 1991 1992 1993 1994 Clinker Production (tons/year) 459,121 381,889 428,667 415,511 Kiln Feed (Raw Material) (tons/year) 776,444 658,429 733,598 707,864 Hours of Kiln Operation (hours/year) 7,238 6,289 7,128 7,241 Alkali Waste (tons/year) 17,174 16,175 21,573 Coal Usage in Kiln (tons/year) 94,704 83,093 97,365

Operational Parameters Calendar Year 1991 1992 1993 1994 Kiln Feed / Clinker Production 1.69 1.72 1.71 1.70 Coal Usage (mtph) 11.89 12.01 12.42 12.22 Alkali Waste (mtph) 2.16 2.34 2.75 Clinker (mtph) 57.67 55.20 54.67

Operational Parameters Average of Years 1991/1992 1992/1993 1993/1994 Kiln Feed / Clinker Production 1.71 1.72 1.71 Coal Usage (mtph) 11.95 12.21 12.32 Alkali Waste (mtph) 2.25 2.54 Clinker (mtph) 56.43 54.94A : 7 1 The operational parameters were taken from the annual op erational reports submitted to the department that were used to develop the emission inventories
Nitrogen Oxides

Table A-9 Nitrogen Oxide Emission Factors Prior to Upgrade

Unit Description Emission Rate (pounds/hour) Citation

9 Rotary Kiln #6 Loesche Mill On 307.00 1991 stack test Loesche Mill Off 404.00 1991 stack test 11 Alkali By-Pass 19.60 1991 stack test 41 Coal Dryer 0.00 Not in Existence

Carbon Monoxide

Table A-10 Carbon Monoxide Emission Factors Prior to Upgrade

Unit Description Emission Rate (pounds/ton clinker) Citation

9 Rotary Kiln #6 Loesche Mill On 0.98 AP42 11.6 1/95 Loesche Mill Off 0.98 AP42 11.6 1/95 11 Alkali By-Pass 0.06 6% of 0.98 41 Coal Dryer 0.00 Not in Existence

Volatile Organic Compounds

Table A-11 Volatile Organic Compound Emissi on Factors Prior to Upgrade

Unit Description Emission Rate (pounds/ton clinker) Citation

9 Rotary Kiln #6 Loesche Mill On 0.18 AP42 11.6 1/95 Loesche Mill Off 0.18 AP42 11.6 1/95 11 Alkali By-Pass 0.18 AP42 11.6 1/95 41 Coal Dryer 0.00 Not in ExistenceA : 8 Table A-12 Volatile Organic Compound Emission Factors After Upgrade

Unit Description Emission Rate (pounds/ton clinker) Citation

9 Rotary Kiln #6 Loesche Mill On 0.18 AP42 11.6 1/95 Loesche Mill Off 0.18 AP42 11.6 1/95 11 Alkali By-Pass 0.18 AP42 11.6 1/95 41 Coal Dryer 0.00 Not in Existence

Hazardous Air Pollutants

Table A-13 Hazardous Air Pollutants Emission Factors Prior to Upgrade

CAS number HAP Emission Factor Pounds / ton Clinker Citation
75070 Acetaldehyde ----- AP-42, 11.6 1/95 71432 Benzene 1.60E-02 AP-42, 11.6 1/95 117817 Bis(2-ethylhexyl)phthalate (DEHP) 9.50E-05 AP-42, 11.6 1/95 75150 Carbon disulfide 1.10E-04 AP-42, 11.6 1/95 108907 Chlorobenzene 1.60E-05 AP-42, 11.6 1/95 84742 Dibutylphthalate 4.10E-05 AP-42, 11.6 1/95 100414 Ethyl benzene 1.90E-05 AP-42, 11.6 1/95 50000 Formaldehyde 4.60E-04 AP-42, 11.6 1/95 110543 Hexane ----- AP-42, 11.6 1/95 7647010 Hydrochloric acid 1.40E-01 AP-42, 11.6 1/95

78933 Methyl ethyl ketone (2-But anone) 3.00E-05 AP-42, 11.6 1/95 75092 Methylene chloride (Dichloromethane) 4.90E-04 AP-42, 11.6 1/95 91203 Napthalene 1.70E-03 AP-42, 11.6 1/95 108952 Phenol 1.10E-04 AP-42, 11.6 1/95 100425 Styrene 1.50E-06 AP-42, 11.6 1/95 108883 Toluene 1.90E-04 AP-42, 11.6 1/95 1330207 Xylenes (isomers and mixtures) 1.30E-04 AP-42, 11.6 1/95 Arsenic Compound (including arsine) 1.20E-05 AP-42, 11.6 1/95 Beryllium Compound 6.60E-07 AP-42, 11.6 1/95 Cadmium Compound 2.20E-06 AP-42, 11.6 1/95 Chromium Compound 1.40E-04 AP-42, 11.6 1/95 Lead Compound 7.50E-05 AP-42, 11.6 1/95 Manganese Compound 8.60E-04 AP-42, 11.6 1/95 Mercury Compound 2.40E-05 AP-42, 11.6 1/95 Selenium Compound 2.00E-04 AP-42, 11.6 1/95 Non Hazardous Air Pollutants -- Subject to PSD Review Fluorides * 9.28E-04 AP-42, 11.6 1/95 Hydrogen Sulfide AP42 did not list AP-42, 11.6 1/95 Sulfuric Acid Mist AP42 did not list AP-42, 11.6 1/95A : 9 Total Reduced Sulfur ** 2.12E-02 AP-42, 11.6 1/95 Total Reduced Sulfur Compounds ** 2.12E-02 AP-42, 11.6 1/95 * -- Fluorides included Fluoride, Fluoranthene, and Fluorene from AP42 documentation

** -- Reduced Sulfur included Sulfur Trioxide and Sulfate from AP42 documentation

Table A-14 Hazardous Air Pollutants Emission Factors After Upgrade

CAS number HAP Emission Factor 1 Citation 75070 Acetaldehyde 2.56E-01 2000 stack test 71432 Benzene 2.60E-01 2000 stack test 117817 Bis(2-ethylhexyl)phthalate (DEHP) 9.50E-05 AP-42, 11.6 1/95 75150 Carbon disulfide 1.10E-04 AP-42, 11.6 1/95 108907 Chlorobenzene 1.60E-05 AP-42, 11.6 1/95 84742 Dibutylphthalate 4.10E-05 AP-42, 11.6 1/95 100414 Ethyl benzene 1.24E-02 2000 stack test 50000 Formaldehyde 6.62E-01 2000 stack test 110543 Hexane 2.30E-02 2000 stack test 7647010 Hydrochloric acid 1.81E+00 2000 stack test

78933 Methyl ethyl ketone (2-But anone) 3.00E-05 AP-42, 11.6 1/95 75092 Methylene chloride (Dichloromethane) 4.90E-04 AP-42, 11.6 1/95 91203 Napthalene 7.35E-03 2000 stack test 108952 Phenol 4.93E-03 2000 stack test 100425 Styrene 2.40E-03 2000 stack test 108883 Toluene 9.60E-03 2000 stack test 1330207 Xylenes (isomers and mixtures) 1.73E-01 2000 stack test Arsenic Compound (including arsine) 1.20E-05 AP-42, 11.6 1/95 Beryllium Compound 6.60E-07 AP-42, 11.6 1/95 Cadmium Compound 2.20E-06 AP-42, 11.6 1/95 Chromium Compound 1.40E-04 AP-42, 11.6 1/95 Lead Compound 7.50E-05 AP-42, 11.6 1/95 Manganese Compound 8.60E-04 AP-42, 11.6 1/95 Mercury Compound 2.40E-05 AP-42, 11.6 1/95 Selenium Compound 2.00E-04 AP-42, 11.6 1/95 Non Hazardous Air Pollutants -- Subject to PSD Review Fluorides * 9.28E-04 AP-42, 11.6 1/95 Hydrogen Sulfide AP42 did not list AP-42, 11.6 1/95 Sulfuric Acid Mist AP42 did not list AP-42, 11.6 1/95 Total Reduced Sulfur ** 2.12E-02 AP-42, 11.6 1/95 Total Reduced Sulfur Compounds ** 2.12E-02 AP-42, 11.6 1/95

1 – The emission factor for the 2000 stack test are in pounds per hour while for AP-42 it is in pounds per ton clinker * -- Fluorides included Fluoride, Fluoranthene, and Fluorene from AP42 documentation ** -- Reduced Sulfur included Sulfur Trioxide and Sulfate from AP42 documentation

## Appendix B

Criteria Pollutant Calculations

## Appendix C

Visibility Report to Congress